REVAMP OF INTERNAL AUDIT PROCESS WITH EFFECT FROM 01.04.2018 &
SUBSEQUENT MODIFICATIONS IN THE AUDIT PROCESS VIDE CIRCULAR
NO.IMA/IMA-RFIA/6/2019-20 dated 4
March 2020
Separate Scores of 1000 each to CRM, ORM & FEMA and Separate Gradings,
i.e., A, B, C & D.
Offline Scores (RADAR) introduced and scores will be integrated with onsite
Scores.
Penalties for false compliances in OTMS, Previous compliances and also
during closure of report, any false compliance observed during CBS
verification and Evidence based testing upto maximum 30 in CRM & 50 in
ORM.
Recurrent income leakage will attract negative scores. (Maximum 25 marks)
External compliances, integrated in CRM & ORM through value statements
and deviations exceeds 15%, Risk rating will be down graded to “C” from “A”
or “B”.
Graded disincentives ( penalties) introduced for EC deviations up to 15% ( EC
Deviations up to 5% disincentive score is 0-5, deviations >5% to 10
disincentive score is >5 to 10, for deviations >10 to
15% disincentive score is 10 to 15.
Maximum negative score of 10 marks introduced for non-compliance with
RBI/Banks policies under CRM.
Maximum negative score of 20 marks introduced in CRM for exposure at
Stress ( RG 2 and RG 3) . (level of irregular/stressed assets to total advances).
Maximum negative score of 20 marks introduced for variance in self audit
score of more than 10% between the validated self audit score and the audit
score awarded by the IA both under CRM and ORM.
Penalty for False compliances in RADAR introduced. (Min penalty 10 and
maximum penalty 20 marks ).
Audit date is derived on OUTLIER model, which is based on negative scores of
branch.
New Sub-Parameter -Customer Satisfaction Metric (CSM) is introduced under
ORM and CSM will carry 140 marks with in overall score of 1000.
Due to the modifications vide above circular, total no of value statements in
2
ORM reduced from 940 to 907 and increased from 832 to 884 under CRM.
RATINGS
Risk
Rating
Risk Profile Score
A A >=85%
B B >=72.50% AND
<85%
C C >=65% AND
<72.50%
D D <65%
SCORE DISTRIBUTION
Total Score Online Audit Offline Audit
CRM 1000 590 to 855 145 to 410 *
ORM 1000 740 26
0
FEMA 1000 1000 0
* 145 for normal branches and maximum of 410 for branches with Concurrent
Auditor, ERS and Credit Auditable accounts).
OUTLIER STATUS / SCORES & PERIODICITY OF AUDIT (DYNAMIC)
OUTLIER STATUS NEGATIVE SCORE
RECEIVED
PERIODICITY OF
AUDIT
NORMAL 0 TO 250 18 – 21 MONTHS
ACCEPTABLE > 250 TO 350 15 – 18 MONTHS
MODERATELY
OUTLIER
> 350 TO 450 12 – 15 MONTHS
OUTLIER > 450 TO 1000 09 – 12 MONTHS
These scores are dynamic and refreshed on monthly basis between 10
th
to 15
th
.
Basing on the rectifications made by the branch, the status will change. The
following parameters which encompass the entire gamut of branch operations are
considered for scrutiny for identification of Outlier Branches.
CREDIT RISK MANAGEMENT
1) Gaps in controls (Based on Missing/Outlier/Incorrect data in source systems)
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2) Exposure at stress Based on the arrears condition attached to each loan
account indicating status of repayment of instalment / interest, stock
statement, renewals of credit limit, irregularity in the account etc.
3) Quick Mortality Exposure.
4) Growth in Advances.
5) Increase in NPAs.
OPERATIONAL RISK MANAGEMENT
1) Gaps in controls (Based on Missing / Outlier / Incorrect data in source system)
2) Increase in Controllable overheads.
3) Reconciliation of Office Accounts.
4) Complaints – Nature and Resolution.
5) Spurt in Non-interest income.
MOVEMENT IN AUDIT RATING
FRAUDS: Penal score over and above the score for critical parameters.
CHECK LIST FOR BRANCHES DUE FOR AUDIT
NOTE: This list is only indicative and not Exhaustive. Branch Managers are
requested to check the other areas applicable to the branch, which
are not covered in this list.
PREPARATORY WORK:
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Up Keep of premises and white wash if required. Loose wiring to be
plugged. Review the seating arrangements for customers and staff also and
drinking water facility to customers.
Arrange a separate table with Computer with network and printer is
connected.
Ensure additional cartridge for printer is available and white papers are
available.
Display of important notices in the premises.
Conduct staff meeting for allotment of duties for RFIA.
Keep ready the previous audit File and check for status of compliances of
persisting irregularities. Previous Statutory Audit Report, other audit
reports, viz., compliance audit, RBI audit, Credit Audit, etc., to be keep
ready.
Vetted Self Audit (3) and RADAR off line audit scores are ready.
Prepare list of accounts slipped into NPA and upgradations and recoveries for
the period of Audit.
Ensure subordinates wear uniform and identity cards.
All staff should wear Identity cards.
Branch should have access to ILTT (Income Leakage Tracking Tool).
Ensure all income leakages pointed out in earlier audits are recovered
fully. Otherwise attracts penalty marks.
BRANCH MANAGER:
1. ATTENDANCE: Attendance register for Award & Sub Staff
is verified daily. Absentees Register & Late
Attendance is maintained Attendance for
Officers is maintained.
2. STAFF ACCOUNTS SCRUTINY: All accounts of Staff to be verified by the
Branch Manager on monthly basis and Branch Manager accounts are
scrutinized by Controllers. Register and Print outs to be maintained.
3. SAFE DEPOSIT RECEIPT FOR DUPLICATE KEYS: To be kept with Branch
Manager (Not in Branch Documents), duly entering in Branch Documents
Register.
4. PERIODICAL VERIFICATION OF DUPLICATE KEYS: Duplicate keys should be
withdrawn and verified after reporting of Joint Custodians / Field Officer.
5. CRP / CSC / PVC / CUSTOMER DAY / CUSTOMER CALL: Ensure conducting
these meetings as per periodicity, minutes are recorded.
6. BMMC / e_BMMC: e_BMMC to be vetted by controllers and hard copies to
5
be made available for the period of audit.
7. CHARGES RETURN: Controlled copies to be filed for the entire period of
audit. (say, previous 18 Months)
8. OFFICE ORDER REGISTER: Ensure periodic job rotation through office
order. INB maker and checker to be identified through an Office Order.
9. CONTROLLERS VISIT / SECURITY OFFICERS VISIT: Take print outs of all visits
from previous audit upto date and keep in a file. Ensure compliance given
for all visits. Ensure that branch has given compliance remarks to the visits
recorded in CVS.
10. SELF AUDIT: To be conducted meaningfully and vetted by controllers
on half yearly basis, preferably May & November and before
commencing of Audit, if required.
11. OTMS ALERTS: Maintain Back up file with copy of relative vouchers / KYC
with remarks. (to be closed within 7 days) Please note false compliance
attracts penalty marks in RFIA.
12. CMS: Back up register for recording complaints received in CMS and
resolution thereon.
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13. SECURITY ARRANGEMENTS: Security register to be updated. Register
for recording periodic checking of Burglary / Fire alarm and Hot Line.
Also record pest control treatment details.
14. CCTV: Ensure that 90 days back up is available and important areas are
covered.
15. FIXED ASSETS: Update Register and Ledger, Tally IFAMS balance with BGL,
Ensure numbering for assets, Stock verification, Annual possession
certificate from Officers holding Fixed Assets.
16. Government / RBI directives duly acknowledged by concerned staff.
17. HRMS SALARY: Monthly salary paid details to be printed and filed after
verification.
18. DAK: Inward / Outward registers are maintained, disposal recorded.
Postage / dispatch register should contain contents of covers, postal
receipt no. / courier receipt no. to be recorded under authentication of
concerned official.
19. FIRE EXTINGUISHERS: ensure validity of refilling.
20. RECORDS: Record room should be maintained neatly. Record register to be
updated. Record
requisition and issued register to be maintained, Old record destruction is
recorded in the register and respective certificate for effective destruction is
obtained.
21. Subordinate clothing register is updated.
22. Bonus register is updated and Suspense entry, if any is reversed.
23. Gun license is within the validity and all guards are entered as retainers.
24. Gun history register is updated with Gun servicing, Repairs, Cartridges firing
and refilling.
25. Scrutiny of exceptional reports on regular basis.
26. Police verification and KYC verification of outsourced employees.
27. Complaints & suggestions box opening and key holding.
28. USROMD: Register balance tallied with BGL. Receipts for advance rent are
obtained.
29. Ensure interest not paid on SB accounts of Government Departments, unless it
is provided for.
ACCOUNTANT (MANAGER – BRANCH OPERATIONS)
1. BRANCH DOCUMENTS: (Carry nearly 250 Marks in ORM through various
value statements).
Branch Lease Deed / ATM Lease Deed / Generator Agreement /
Officers Residential Accommodation – Lease deeds are current, duly
7
sanctioned & controlled by appropriate authority.
BC & OR duly approved by the controllers is current (valid for 1 year)
and having acknowledgement of staff members responsible. Latest
BC&OR testing report scrutinized by controllers.
Locking up arrangements are approved for the current year. Ensure all
keys are entered in Key Register, handing over and taking over are
recorded.
Copy of Insurance of Cash / Gold / Fixed Assets to be downloaded from
Circle Site.
Valid AMC for computers, Air Conditioners and other equipment.
Valid Agreement for our sourced employees, if any.
Emergency Relief arrangements approved by controllers.
ATM pass words in sealed covers (to be changed quarterly or when a
change in custodian).
Previous Audit Notes.
Weights & Measures renewal certificate for weighing machines.
Deceased settlements.
Fraud folders / files, if any.
8
2. Ensure Branch License is available, preferably hanged in strong room / BM
chamber in a photo frame. [EC]
3. Passbook issue register – acknowledgement and authentication of entries.
4. Proper custody of IOI forms, Welcome Kits, INB kits, Undelivered ATM cards
/ cheque books. Half yearly verification of Security forms by an officer other
than Joint Custodians.
5. Invoices for IOI forms received should be filed in chronological order.
6. LOCKERS: Locker module is updated.
Interchanging of
locks. Key Register is
updated.
Locker agreements with
KYC. Rent is collected up
to date.
7. POSTAGE: Contents of cover should be written in the register.
Postal / Courier receipt number is noted under authentication
of official. Postage balance is verified on monthly basis.
Payment of Courier bills after scrutiny of PODs.
8. OVVR: Dashboard print to be taken and filed daily.
9. VOUCHERS: Cancellation of drawer’s signature after payment.
Branding with teller partition stamp by maker and
checker. Crossing with Blue indelible pencil after
checking.
Second scrutiny of vouchers and crossing with Red indelible
pencil.
Signature of the checking staff / officer on the cover with name
and pf no. of checker.
No. of debit and credit vouchers to be written on the cover.
Vouchers to be moved to Record Room on T + 2 basis duly
entering in Record Register.
10. AOF: should be sent to LCPC on daily basis.
Discrepant AOFs to be rectified and submitted immediately thru work
flow.
11. CRR register is used for operations in inoperative accounts (KYC
documents to be obtained and updated in CBS).
12. Risk Category updated at stipulated intervals for all CIFs every 2 / 8 / 10
Years for High / Medium / Low Risk customers). [value statement for EC in
ORM]
9
13. Obtaining Photo ID proof / Address Proof / PAN or Form 60 / 61. [EC]
14. AUDIT BGL: No entry is pending for more than 90 days.
98581 & 98582 to be reversed before 30 days.
Trickle feed rejected entries to be reversed on
same day. Back up register for debits to
income accounts.
15. User ID creation register is updated with details of staff existing at the
branch. Transferred employee details should be marked off with remarks.
Resetting of tellers should be noted with reasons thereof.
16. Proper custody of undelivered Bankers Cheques duly entering in the register.
17. Ensure Lien marked on PF balances for all Staff Advances.
18. Proper filing of DA1 forms with authentications. [EC]
19. Access to System Room is only after entering in the register and with proper
authentication.
20. Police Beat Book and Security arrangements letter duly acknowledged by local
police authority.
21. BCSBI board should be displayed in the banking hall.
22. Controllers name & phone number to be displayed.
10
23. RTI: CPIO & Appellate authority information to be displayed.
24. Checking of high value instruments under UV lamp / Fugitive ink test.
25. Half yearly balancing of securities.
26. Safe Deposit articles balancing and recovery of charges.
27. Authority letter for Courier boy and his KYC.
28. Record of Drop Box opening and distribution of cheques against
acknowledgement.
29. Time Locks operations.
30. STATIONERY ACCOUNT: Register is updated with the invoices and
consumption entry is passed before 5
th
March. Stationery Ledger is
updated.
31. Life Certificate to be obtained from all pensioners and record in the System.
[EC]
32. Specimen signatures of RBI officials.
CASH OFFICER
1. Monitoring of high value receipts into newly opened accounts, proper record.
2. Double passing of high value instruments.
3. Cash & Gold retention limit approval is current (Kept with BDs). Excess
cash retention report is submitted to controllers and scrutinized returns
are available.
4. SWO cash boxes are maintained, and duplicate key is deposited with CO.
5. Register for Excess / Short cash.
6. HAND BALANCE REGISTER: Rubber stamp “CGL-BGL-PHYSICAL CASH TALLIED”
is branded. Daily 2 denominations are to be verified by Accountant and full
verification on weekly basis, monthly by other than joint custodian.
7. Cash reports to be printed daily and SWO to sign on all pages. Month wise
binding.
8. Cash Jotting report to be printed daily.
9. Cash remittances sent / received register is updated. Acknowledgement
for remittances sent should reach in registered post.
10. ATM cash replenishment register is updated, admin slips are pasted
(Xerox) with signatures of joint custodians.
11. INTRA DAY CASH VERIFICATION: To be done periodically, report printed
and signed by joint custodians and other officer as evidence should be
filed and record in register.
12. GOLD LOANS: Register to be maintained. Documents should be in joint
custody. In – Out register to be maintained for gold bags. Tags to bags and
contents slip inside bag. Half yearly verification by officer other than joint
custodian.
11
13. Mutilated notes exchange register & NSM record.
14. Register for single side errors rectifications.
15. CURRENCY CHEST: Bin cards to be displayed on each BIN and inside card also
to be updated.
ICCOMS daily report should be filed. Soiled currency to be shown under
Soiled section only. Vault register, Bi monthly verification reports, RBI audit
compliance, In & Out register.
16. Forged notes impounding register.
ADVANCE RELATED
1. Ensure all documents are available as per Loan Balance file & CCOD file
and stored in FRRC or Pucca Strong Room.
2. All documents are enforceable and properly filled in without blanks.
RL is obtained wherever necessary.
12
3. Check for ZERO interest rate accounts and abnormal rate of interest
accounts and make necessary corrections.
4. Convert Loan Balance & CCOD files into XLS and sort from top to
bottom on exposure. Take list of accounts covering 80% of total
exposure and rectify in CBS as well as in documents.
5. Recommendation / Sanction is recorded in all cases and controlled by
appropriate authority.
6. Pre-sanction / Post sanction inspections are conducted, and report is made
available.
7. Inspection Register updating.
8. KYC documents obtained and verified. [EC]
9. Risk Categorization is done correctly. [EC]
10. CIBIL reports are drawn and verified. [EC]
11. Insurance of primary /collateral is obtained and updated in CBS.
12. Copy of RC obtained and updated in CBS where ever applicable.
13. Mortgage is created and confirmation thereof is received through
registered post. Recital is recorded against signatures of maker and
checker.
14. CERSAI is registered and values are updated in CBS. Print outs to be kept
with documents.
15. Processing fee (at annual intervals for Cash Credit) is collected upfront.
16. Documents execution register is updated.
17. Irregularity reports sent to controllers and scrutinized copy held on record.
18. NPA back up register is maintained and effective follow up for Irregular
accounts is evidenced.
19. Applications received and disposed register is updated.
20. AUCA back up register and quarterly review scrutinized by controllers are
in place.
21. Approvals for Transfer to Recalled Assets and Transfer to AUCA are on
record. Back up register for written off accounts.
22. Suit filed register is updated and periodical report on status of pending
cases is received from panel advocates and submitted to controllers.
23. Review of Term loans and Renewal of Cash Credit accounts is done
and updated in CBS. Validated copy of CRA is available for eligible
accounts (Rs. 50 Lacs and above accounts).
24. External Ratings for Rs. 50.00 Crores above accounts.
25. TIR on standard format and Annexure E & F are compiled. EC to be
obtained annually.
26. Valuation reports are of below 3 years old and value confirmations are
noted by concerned official.
27. Back up register for control forms sent and received.
28. Field officers tour diary in agri intensive branches.
13
29. Expired Bank guarantees are reversed in CBS. Commission is recovered.
30. CGTMSE is covered for all eligible accounts. (Flag should be NO for
MUDRA accounts as it is covered under CGFMU)
31. Reports on Failed SI / excess drawings / Insurance expired to be scrutinized
periodically.
32. OTS / Compromise register and approvals.
33. Back up register for Agri Interest subvention.
34. Stock statements are obtained at specified intervals and Drawing Power
is regulated through D.P.Register.
35. Individual Control Forms noted are kept with respective documents.
36. PDCs are kept in joint custody and not with documents.
37. Primary & Collateral security values are entered in CBS.
38. EM charges / CERSAI fee / BG commission is collected.
39. Failed SI report is scrutinized at regular intervals.
POST AUDIT EXERCISE:
14
- Ensure full compliance of irregularities pointed out by Inspecting Official.
- Maintain back up for such compliances.
- Plan for submission of compliance remarks well within stipulated time.
- Avoid false compliance as it attracts penalty in marks of current score
and may lead to down grading of rating.
- Submit replies to Management Letter and Special letter, if any, within 1 month
of RFIA report.
- Be prepared to submit Evidences sought by Circle Audit Office while
examining your compliances. Time given for submission of evidences for
Evidence Based Testing is 7 working days for branch and 2 days for
controllers. You will get the details of evidences to be submitted through e-
mail. Please note that if not submitted in time, it amounts to false
compliance and penalty will be levied in present score.
- Continue to attend RADAR deviations regularly to avoid RFIA for the next 21
months and improve the scoring in next RFIA.
GIST OF EC RELATED VALUE STATEMENTS – CRM
HANDLING OF LOAN APLICATIONS:
Applications in the Banks standard format, as applicable for the
specific scheme, has not been obtained.
Acknowledgement of the borrower is not on record (Application for
facilities upto Rs. 2.00 Lacs only)
KYC DUE DILIGENCE:
Prescribed KYC documents of Borrower(s) are not held on record.
Self-attested photographs of the Borrower(s) are not on record.
Prescribed KYC documents of Guarantor(s) are not on record.
Self-attested photographs of Guarantor(s) are not on record.
Periodic risk review has not been done.
Risk categorization is not correct.
Regulatory Clearances have not been obtained.
Municipal / Corporation / Urban Authority approval have not been
obtained and are not held on record.
Project related compliances with regard to environmental / social /
statutory requirements have not been recorded, e.g., Land conversion
/ Power / Water / Industrial license / Explosives / Pollution control /
Drug license / Mining / Fuel storage, etc.
CREDIT INFORMATION REPORTS:
15
Credit information reports (CIR) on the borrower (New connections,
MBA, Consortium etc.,) have not been obtained / not held on record.
In respect of Loans / Ad-hoc loans / renewals sanctioned to new /
existing borrowers under MBA / Consortium Banking necessary
information on unhedged currency exposures, derivatives, etc., has
not been exchanged with other Banks.
SCRUTINY OF DEFAULTERS LIST:
Appropriate certificate downloaded from Central Fraud Registry of RBI
has not been incorporated in the proposal for sanction.
CRA RATING:
16
External rating (ECR) has to be obtained in applicable accounts.
GIST OF EC RELATED VALUE STATEMENTS – ORM
CUSTOMER DUE DILIGENCE:
NOC of existing bankers of declaration having no credit facilities in
other bank is not obtained (from Current Account Opening
Customers)
The beneficial owners have not been identified (In case of legal entities)
RISK CATEGORISATION:
Customer has not been categorized as High risk, Medium risk or Low
risk while opening the account.
The customer has been assigned a High Risk. KYC updation exercise
has not been carried out every 2 years.
The customer has been assigned a Medium Risk. KYC updation
exercise has not been carried out every 8 years.
The customer has been assigned a Low Risk. KYC updation exercise
has not been carried out every 10 years.
Accounts of jewellers / bullion dealers, NRIs, HNIs, trusts, charities,
NGOs, PEPs, non-face to face persons to be categorized as high risk
requiring enhanced due diligence.
OTP BASED e-KYC PROCESS OF ACCOUNTS:
Specific consent from the customers for authentication through OTP has
not been obtained.
Where accounts are opened using OTP based e-KYC, aggregate
balance of all deposit accounts of such customer exceeds Rs. One lakh.
Where accounts are opened using OTP based e-KYC, the aggregate of all
credits in a financial year, in all the deposit taken together, does
exceed Rs. 2 lakhs
It is not indicated while uploading KYC information in CKYCR, that the
account was opened using OTP based e-KYC and other Banks should
not open the accounts with OTP based e- KYC procedure.
A declaration not obtained from the customer to the effect that no
other account has been opened nor will be opened using OTP based
KYC either with State Bank of India or with any other Bank.
Accounts, both deposit and borrowal, opened using OTP based e-KYC
have been allowed for more than one year without completing
Customer Due Diligence (CDD) procedure (obtaining a certified copy of
17
OVD, Recent photograph and other documents as specified in the
Banks KYC policy).
For deposit accounts opened using OTP based e-KYC wherever CDD
procedure is not completed within a year, the account has not been
closed immediately. In respect of borrowal accounts further debits are
not allowed.
SEARCH OF NEGATIVE LIST OF CUSTOMERS:
The names of individuals / entities appearing in UN Security Council
Resolutions are not updated for implementation of Section 51 A of the
Unlawful Activities Act, 1967.
Before opening new account, banks to ensure that no account is held or
linked to any of the entities / individuals included in the negative list.
Banks also should scan all existing accounts when a new list is
received.
18
Details of accounts resembling any of the individuals / entities in the
list are not reported to FIU-IND.
Accounts are opened in the names of individuals / entities appearing in
the above list.
Following steps have been taken regarding maintenance, preservation
and reporting of customer account information as per the provisions
of PML Act and Rules. i) Maintaining all necessary records of
transactions for at least five years from the date of transaction. ii)
Preservation of records pertaining to identification of customers and
their addresses or at least five years after the business relationship has
ended.
Information has not been furnished as per Rule 3 of PML Rules 2005
(All STRs, Cross border wire transactions of value of more than Rs. 5.00
Lacs or its equivalent in Foreign Currency where the origin or
destination of funds is in India) to the Director, FIU-IND.
CUSTOMER ACCEPTANCE & IDENTIFICATION – INDIVIDUALS:
Photo Identify Proof has not been obtained.
Proof of address has not been obtained.
A copy of PAN card / Aadhar Card / Form 60/61 has not been obtained.
MONITORING OF TRANSACTIONS:
Intentional structuring of transactions – IOI, Bankers Cheques Issued,
NEFT, Cash Deposited into a series of transactions below the threshold
of Rs. 50,000/- have not been scrutinized for identification of
suspicious activity, if any.
In case, the amount of cash deposit by third party results into deposit
of cash in aggregate to all the accounts more than Rs. 50,000/- in a
day, tenderor’s PAN number not obtained and a copy not attached
with pay in slip after verification of signature from PAN card.
In the absence of PAN card for cash deposit by third party result into
deposit of cash in aggregate to all the accounts more than 50,000/- in
a day, Form 60 is not obtained and tenderers identity not verified from
Aadhar Card or any other OVD available with him.
All suspicious transactions advised by Customer / Law Enforcement
Agencies are not reported to AML / CFT Dept., through one page STR.
STOP created after receiving instructions from Revenue / Government
19
Authorities due to customer’s financing / cheating etc., are removed
without obtaining written instruction and verifying the genuineness of
the issuing authorities. Related documents not retained as Branch
Documents, along with the original instructions.
Nomination Facility: Nomination facility has not been extended.
Pension Accounts: Life Certificates have not been obtained from all
pensioners and are not recorded in the system.
Branch License & Pass Words: Licence from RBI / under shops &
Establishment Act (If applicable) for Branch opening, Extension counter, off-
site ATM is not on record.
// END //
20
by Prashant Singh (CM BOPM) 1
RFIA – IN YOUR HAND
RFIA WORKSHOP – APRIL 2018
(by BOPM-III, LHO Lucknow)
by Prashant Singh (CM BOPM) 2
RFIA – IN YOUR HAND
THE PALM RULE
by Prashant Singh (CM BOPM) 3
by Prashant Singh (CM BOPM) 4
PALM RULE : WILL POWER
• Keep Confidence in yourself
• Keep Ambitions high – Target an increase of minimum 75 Marks and CRM & ORM % above 82 %
• Present your Branch as fully compliant to the IO
• Educate your Juniors
• Follow Dress Code
• Know everything about Scoring Pattern
by Prashant Singh (CM BOPM) 5
WARNING : 50 MARKS MAY BE DEDUCTED AFTER EVIDENCE BASED TESTING
by Prashant Singh (CM BOPM) 6
by Prashant Singh (CM BOPM) 7
by Prashant Singh (CM BOPM) 8
by Prashant Singh (CM BOPM) 9
DEDUCTIONS
Area Penalty
Zero Tolerance Areas : Direct Deduction from CRM & ORM – Will reduce CRM/ORM %
46
OTMS : Deduction from overall Score – Will reduce Rating 5
Compliance Audit Score : Deduction from overall Score – Will reduce Rating
50
Fraud : Separate Allocation in overall Marks – Penalty & Award Both
25
Evidence Testing : Deduction from overall Score – Will reduce Rating
50
Total 176
DEDUCTIONS : ZTA CRM (2 Marks deduction per ZTA)
1 Prescribed KYC documents of Borrower(s) not held on record (ZTA)
2
Pre-sanction inspection to the site/farm/unit/residence/business place of borrower/guarantor not
done/not on record, for the advances sanctioned / renewed during the period under review..(ZTA)
3
Credit Information Reports on borrowers/guarantors from the listed Credit Information Companies
not obtained as applicable to the loan products.(ZTA)
4
Physical verification of properly not done and independent verification of valuation not carried out as
per Annexure F circulated vide e-Cir SI No. 41 dated 13.04.2013.(ZTA)
5
TIRs not obtained on Bank's standard format as circulated vide e-Cir SI No. 41 dated 13.04.2013 /
revised vide e-Cir SI No.696/2017-18 dated 25.09.2017.(ZTA)
6 Loan Documents for the sampled accounts not produced for verification.(ZTA)
7 Mortgage of all properties stipulated in sanction not created. (ZTA)
8
(i) Registration of EM/RM with Central Registry (CERSAI) has not been done (ii) Data updation in
CBS with the four CERSAI data fields-(1) Asset ID (2) Security intrest ID (3) Date of creation of EM
and (4) Date of registration in CERSAI,has not been done (ZTA).
9 Eligible accounts not covered under CGTMSE. (ZTA)
10
Scrutinised copy of Control Return for sanction not on record, even after three months
from Date
of Sanction. (ZTA)
by Prashant Singh (CM BOPM) 10
DEDUCTIONS : ZTA ORM (2 Marks deduction per ZTA)
1 Risk categorization of new customers / CIFs into low, medium and high not done.(ZTA)
2
Form No 15G and 15H not obtained from customers wherever applicable and they not submitted
to the tax authorities at prescribed periodicity (ZTA)
3
Scanned pages of discrepant AOFs placed in ftp site are not downloaded by Branch and not
resubmitted after compliance to LCPC promptly. (ZTA)
4
Remittances done based on Fax messages received from the customers, without following
approved procedure. (ZTA)
5
Genuineness of KYC documents (applicable OVDs) and the specimen signature of the authorised
signature(s), in case of Non-Personal accounts not verified.(ZTA)
6
Manual Intervention of Transactions in Interest Expenses & Income Accounts observed and
Manual Back Up Register / records not maintained and approval not obtained (ZTA)
7
Deviations in Critical / High Risk areas pointed in the previous audits, recurred in the current Audit
also.(ZTA)
8
Fraud established through the fraud angle investigation not reported immediately to the Fraud
Committee at LHO for declaration of the case as fraud as per SOP circulated vide e-Cir SI No.
1476/2015-16 dated 03.03.2016.(ZTA)
9
Opening and maintaining Parking Accounts without approval under Savings Bank and Current
Account products.(ZTA)
10 Reconciliation of BGL Accounts pending for exceeding 90 days, attracting provision.(ZTA)
11
Transactions with value dates prior to transaction dates not approved by authorised officials and
monitored (ZTA)
12 Locker access module in the CBS is not put into use. (ZTA)
13
Instances of Incorrect/False Certif
b
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ther than those already reported in
PARAMETER
PENAL
SCORES
Fraud–Delay in Detection (Beyond 30 days of occurrence of
fraud)
3
Fraud–On detection, Branches to report immediately to
controllers. Any deviation in reporting to controllers.
2
Fraud-If the fraud is established after investigation by the
controller / LHO in more than 15 days of detection of fraud,
then the penalty imposed on the Branch.
8
Fraud-Lack of Internal Control & Inadequacy in due diligence.
12
TOTAL PENAL SCORE 25
Fraud – Award (15 Marks)
PARAMETER SCORES
Status of existing Frauds (As per JASPER Report)
a. Fraud reported prior to period under review have been adequately followed up /
closed.
b. There is no fraud reported during the period under review
6
Fraud During Review Period
Identification of fraud - prone areas is done & Preventive Vigilance Committee
meetings are held and minutes reported to Controllers. Modus operandi of frauds
reported is discussed and deficiencies found at the Branch, if any, rectified
6
Status of Suspected Frauds
Fraud - prone Areas and other critical areas are monitored. e.g. :
a) Proper delivery of IOIs (Drafts, Banker’s Cheques, etc) to costumers.
b) Proper authenticated Checking of VVRs / BGL Reports.
c) Unauthorized persons do not have access to Records.
6
Suspected Fraud During Review Period 6
Preventive Vigilance Committee 12
TOTAL SCORE 36
NORMALISED SCORE by Prashant Singh (CM BOPM) 1155
DEDUCTIONS : EVIDENCE TESTING– FALSE COMPLIANCE (50 Marks)
(Checking of RFIA Compliance at CAO level taking evidence from Branch)
The items to be tested are as under:
Sl.
No.
CORE AREA
(Evidence based testing)
Sl.
No.
Non Core Area
(Evidence based testing)
1 KYC 6 CONTROL RETURN
2 PRE SANCTION 7 DOCUMENT NOT PRODUCED NOT FOR VERIFICATION
3 MORTGAGE 8
APPROVAL OF APPROPRIATE AUTHORITY TO
TRANSFER TO RECALLED ASSETS
4
INSURANCE
9
VALUE DATED TRANSACTIONS/APPROVAL OBTAINED
FROM CONTROLLERS POST RFIA, IF ANY, TO BE
VERIFIED AT THE TIME OF COMPLIANCE TESTING
5 PARKING ACCOUNT 10 INCORRECT/FALSE CERTIFICATION
CBS BASED TESTING
1 CERSAI REGISTRY 5 PRIMARY/COLLATERAL SECURITY
2 CGTSME 6 ACCOUNT CLOSURE
3 IRAC STATUS 7 RC COPY
4 CRA RATING 8 LOCKER
Award of Penalty
(i) A penalty of 3 marks per false compliance in core areas and 2 marks per false compliance in non
core area in respect of evidence bases testing.
(ii) A penalty of 2 marks per false compliance in respect of CBS bases testing.
(iii) Minimum penalty of 20 marks and maximum penalty marks restricted to 50.
(v)The total penalty marks to be deducted from the overall score.
by Prashant Singh (CM BOPM) 16
SCORING METHODOLOGY
• RFIA Evaluate every area on value statement
• Each Value Statement have Marks
• Each Value Statement is also divided in four Risk categories i.e Critical , High , Medium & Low
• Value Statement Marks are having waitage according to above risk
• The entire RFIA is based on Sample Verification & General observation
• CRM will be evaluated on Sample Verification
• ORM will be covered on General observation
by Prashant Singh (CM BOPM) 17
THE THUMB RULE
by Prashant Singh (CM BOPM) 18
THUMB RULE - BRANCH DOCUMENT – FACE OF THE BRANCH
(Prepare an Information Sheet and provide to IO)
by Prashant Singh (CM BOPM) 19
BRANCH DOCUMENT INFORMATION SHEET (Continue...)
by Prashant Singh (CM BOPM) 20
BRANCH DOCUMENT INFORMATION SHEET (Continue...)
by Prashant Singh (CM BOPM) 21
BRANCH DOCUMENT – COMMON DEFICIENCIES
a. Old/ expired items not removed in time.
b. Insurance policies are expired.
c. All AMCs except of UPS are expired.
d. Branch Cash retention/ Gold retention limit approval from controllers not on record.
e. Branch TAN not on record.
f. Receipt of advance deposit with TNEB not on record.
g. No passwords are kept on record.
h. Copy of compensation policy and other policies not on record.
i. Protective arrangements not on record.
j. Approved locking up arrangement not on record.
k. Approved BCP/ DRP not on record.
l. Branch brass seal not available.
m. Branch LAN diagram not on record.
by Prashant Singh (CM BOPM) 22
THE INDEX FINGER RULE
by Prashant Singh (CM BOPM) 23
INDEX FINGER RULE – Preparation Check
1. Obtain following information from controllers for RFIA exercise:
a) IOA memos (IBTS, etc)
b) Complaints.
c) Suits filed against the Bank
d) Consumer Forum cases
e) Ombudsman cases
f) Frauds
g) Reconciliation of NOSTRO, STEPS, ELENOR, GAD etc.
h) Budget for Business & NPA for the past two years
i) Leave on Loss of Pay, if any
2. Hold a staff meeting to distribute works among all the staff members for smooth completion
of RFIA.
3. Provide all previous Audit Reports relating to RFIA, Credit Audit (If applicable for branch),
Statutory. Audit, RBI Audit, Government Audit etc if any. In such cases, ensure to file the
report closure letter received from appropriate authority in respective audit reports.
4. Provide the hard and soft copy of the compliance remarks of previous RFIA containing
Branch and Controller’s remark
b
s
y
.
Prashant
Singh
(CM
BOPM)
24
5. Obtain the list of sampling of loan accounts and deposit accounts (For KYC) and provide them to the
respective officials to keep them ready for verification by inspecting officials.
6. Provide the necessary data for filling up Annexure in ARF.
7. Branch Document items should be arranged page-wise. (Branch License, current and approved
Emergency Relief Arrangement, Locking-up Arrangement, DRP/BCP, Insurance of cash and
valuables, Aide memoire etc)
8. AMCs are current and recorded in AMC register.
9. Provide the files containing P-form, Budget Papers, performance highlights under cross selling etc.
10. Update the Branch Drossier and provide the same to the Inspecting Official.
11. Identify all income leakages in various areas as per the check list and recover the same during the
course of inspection positively.
12. Obsolete Security forms, if any to be destroyed during inspection after verification by the Inspecting
Official. Approval from controllers to be obtained in all such cases.
by Prashant Singh (CM BOPM) 25
13. Ensure that BMMC is submitted in revised format and all the scrutinized copy of BMMC are
available. Also ensure that controller’s remarks in scrutinized copy are complied .
14. On-line reports on visit of controllers including the branch compliance should be made available.
15. Fraud and other important files to be made available.
16. Maintenance of all the required registers with updated data, information
17. All the system suspense and sundry deposit accounts are duly reconciled. No
unauthorized parking account is existing at the branch.
18. In case currency chest branches, strong room fitness certificate is available, Bio-metric access
System is installed, frisking is done before entering the chest, BIN cards are displayed inside BIN,
ICCOM reporting is correct
19. Intraday cash verification is done on regular basis and the reports duly signed by all concerned
are filed properly and such instances are recorded in a standard register.
20. When cash box is provided to the SWOs, proper register is maintained to record monthly
and random verification of such cash box.
by Prashant Singh (CM BOPM) 26
21. SWO daily reports of the review period duly signed by SWO are kept ready for
verification.
22. Cash Receipt and Delivery Register is maintained SWO-wise and is duly signed by SWO.
23. Cash Balance Register for all the days during the review period are kept ready. Ensure that all
the Columns in the register including Dr/Cr summation are filled in, any two/three items of hand
balance are verified daily by one of the joint custodians (Accountant) on daily basis and the
register is duly signed by the joint custodians.
24. Send all pending control forms to RBO and provide a list of control returns sent to RBO.
25. VVR checking status to be brought up to date.
26. Arrangement of documents with all annexure, revival letters, etc. as per CC/OD & Loan
balance file. (No instance of missing documents to be ensured).
27. Feed particulars of Insurance Policies (all segments), details of safe deposit lockers, suit filed
accounts and Unit Inspections in CBS, if not done earlier.
28. Ensure that Lien is noted on PFbybParalsahnancteSininghr(eCMspBeOcPtMo) f all applicable staff loans along 27
with hard copies thereof in respective loan documents.
29. Revival Letters are obtained in 100% cases and are recorded in Doc Execution Register.
30. Insurance cover obtained and recorded in CBS in 100% cases.
31. EM formalities, CERSAI etc. completed in 100% cases.
32. EM charges duly recovered in all eligible cases.
33. Correct interest rate entered in the system for all advances accounts.
34. Irregularity reports / SMA reports to be submitted to controllers and Scrutinized copies are
held on Record duly acted upon by the branch.
35. Present position of all the suit filed cases to obtained from respective Advocates and the suit
filed register is updated.
36. Self-Audit exercise carried out after every six months and vetted/reviewed by
controllers.
37. Cleaning of the branch premises / toilets etc to be ensured up to an expected level.
by Prashant Singh (CM BOPM) 28
THE MIDDLE FINGER RULE
by Prashant Singh (CM BOPM) 29
MIDDLE FINGER : Self Assessment
• Mark every Item in Self Assessment Form
• Arrange Basis amenities immediately
• Prepare list of Missing Items required to be obtained from Controllers > Provide list to CM
Compliance and take said missing Items
• Prepare list of deficiencies > Remove deficiencies in a time bound manner
• Check Status of Advances Document > Put Checklist on every Loan document > Identify
deficiencies and remove it
• Repeat Self Assessment on weekly basis
by Prashant Singh (CM BOPM) 30
THE RING FINGER RULE
by Prashant Singh (CM BOPM) 31
RING FINGER : WALLET
(698 / 498 Marks can be scored before RFIA Start)
Sl. Name of the Report
NON
BPR
BPR
Branch
1 ADHOC AUDIT REPORTS – COMPLIANCE 250 250
2 OFFSITE AUDIT REPORTS – COMPLIANCE 50 50
3 IS AUDIT 55 24
4 NPA REDUCTION BY 50% 22
5 CORRECT IRAC 9
6 SUIT FILED 17
7 AUCA/WRITE OFF 12
8 SELF AUDIT 10 10
9 RDI 10 10
10 BD REGISTER 18 10
11 PROTECTIVE ARRANGEMENTS 17 6
12 STATIONARY & RECORDS 20 10
13 OFFICE ACCOUNTS 26 11
14 RECONCILIATION 8 3
15 RISK HISTORY 12 6
16 CUSTOMER SERVICE(CSP/CRP/NOTICE BOARDS/AMBIENCE) 38 18
17 COMPLAINT MANAGEMENT 8 4
18 PREMISES/FIXED ASSETS 7 5
19 DEALING WITH AUDIT REPORTS 17 13
20 KYE/STAFF WELFARE FUND 10 4
21 CHARGES/ESTABLISHMENT 7 4
22 LOCKER MANAGEMENT 25 10
23 RBI/GOI INSTRUCTIONS 20 20
24 FATCA/RBI TRANCHE III 10 10
25 MAINTENANCE OF PRESCRIBED REGISTERS 20 20
GRAND TOTAL (POCKETABLE
by
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698
498
32
ADHOC AUDIT REPORT – CRM (100 MARKS)
Sl.
No
Adhoc Audit
Report No.
Name of the Report
Score
in ARF
1 BR1788-01 Inspection for Term loans 4
2 BR1786-01 Stock statements 6
3 BR2422-01 Expired stock statements 6
4 BR2458-01 Report on Pending Control Reports 4
5 BR2588-01 List of Accounts due for Revival 4
6 BR2397-01 Report on Irregularity due to Excess Drawings 4
4 BR2490-01 Statement for Irregular Overdue Loan Account 4
8 BR2444-01 Securities given as collateral for loans (Matured) 4
9 BR8536-01 Insurance Report 6
10 BR2572-01 List of Accounts NPA 6
11 BR2011-01 Opinion Reports 4
12 BR2023-01 Audit Report on Vehicle Loans Where Bank Charge noting not carried out 6
13 BR1790-01 List of accounts, where suits have been waived as on date of inspection 4
14 BR1790-01 List of accounts, where suits have been filed as on date of inspection 6
15 BR2571-01 Deposits under lien for advances 4
16 BR1789-01 List of pre-sanction visits between two dates of inspection 6
17 BR4411-01 Manual changes in irac codes 6
18 BR2303-01 Accounts covered under CGTMSE & classified as NPA 4
19 RP3722-01 Sanction renewal date older than one Year 4
20 BR1787-01 Unsatisfactory features observed on unit inspection 4
21 DJ0202-01 Standing instructions 4
TOTAL WEIGHbTyAPGraEsh/aSntCSOingRhE(CSMUBNOPDME)R CRM: 1
3
0
3
0
ADHOC AUDIT REPORT – ORM (150 MARKS)
by Prashant Singh (CM BOPM) 34
Sl.
No
Adhoc
Report No.
Name of the Report
Score in
ARF
1 SY337A-01 Interest Rate changes at product Level 6
2 IN574A-01 Handling of Dormant / Inoperative Accounts 8
3 SY389A-01 Payment of interest on delayed collections (Goiporia Committee) 4
4 SY0333-01 List of Instruments lost/damaged 6
5 BR388A-01 Manual credit interest adjustments (Loans) 6
6 SY388A-01 Manual credit interest adjustments (Deposits) 6
7 BR3233-01 Report on Penal Interest 4
8 BR2596-01 Report on Penal Interest (o/a Non Renewal) 4
9 BR1785-01 Paper based securities 2
10 SY0590-01 Manual Adjustments in Suspense Account No.98958 4
11 SY1918-01
List of locker a/c's opened during the review period where lock has
not been interchanged
6
12 SY1919-01 List of lockers opened during 6
13 SY1717-01 List of instruments returned unpaid for want of insufficient funds 6
14 IN1009-01 Report with list of accounts with special rates of interest for audit 6
15 IN1099-01
Report on high value transactions, both debit & credit for Rs. 5
lacs and above
6
ADHOC AUDIT REPORT – ORM (150 MARKS)
Sl.
No
Adhoc
Report No.
Name of the Report Score in
ARF
16 IN1095-01 List of a/cs with concession in service charges 6
17 BR2564-01 Interest rate changes at account Level 6
18 GL0805-01 Age wise breakup of outstanding Entries 6
19 BR2562-01 List of transaction above Rs. 10.00 Lacs 6
20 SY3706-01
Audit adhoc report for bankers cheque paid by revalidation
/cancellation
6
21 SY3707-01 IBTS Transaction above 10 lacs 6
22 GL0815-01
BGL accounts which were reversed after 30 days from the date of
origination with amount more than 10,000/-
6
23 GL0720-01 Expenses on charges account except through HRMS 4
24 IF1192-01 ATM manual transactions 4
25 GL0719-01 Manual txns on expense accounts 2
26 GL0719-01 Manual txns on income accounts 2
27 SY0418-01
List of users added/amended/deleted since last inspection
/migration
6
28 BR2560-01 Back Value Transaction 6
29 BR2013-01 Income Leakage 4
TOTAL WEIGHTAGE/SCORES UNDER ORM: 150
by Prashant Singh (CM BOPM) 35
Sl.
No
Name of the Report
Score in
ARF
1 Account Opening & KYC Norms 6
2 Signature Scanning 12
3 Scrutiny of Staff A/cs 8
4 De-duplication of multiple CIFs 6
5
Effectiveness of follow up of KYC non compliant accounts not Evidenced
4
TOTAL WEIGHTAGE/SCORES: 36
by Prashant Singh (CM BOPM) 39
PROBLEM LOAN MANAGEMENT – A SCORING BASKET 120 MARKS
PROBLEM LOAN MANAGEMENT – A SCORING BASKET 120 MARKS
by Prashant Singh (CM BOPM) 39
PROBLEM LOAN MANAGEMENT – A SCORING BASKET 120 MARKS
by Prashant Singh (CM BOPM) 40
THE LITTLE FINGER (PINKY) RULE
(Know common deficiencies)
by Prashant Singh (CM BOPM) 41
No. Common deficiencies observed in CRM
1 Submission of Control Forms / Returning of Scrutinized Control Forms not ensured.
2 Documents not produced for verification/missing.
3 Completion of EM formalities not done. Annexure- E and F are not prepared.
4
Registration under CERSAI not done / copy thereof is not enclosed in
concerned loan document. CERSAI charges not recovered.
5
Full chain of Revival Letters not on record. As a result, large number /amount of Time
barred documents were observed.
6 Timely Review / Renewal of eligible accounts not done.
7 Asset Classification not as per IRAC norms
8 CRA rating not done / updated in CBS.
9
Weight and Purity of Gold is not tested by branch officials / Gold smith report is not
held before disbursement of Gold Loans.
10 Conducting of pre / post sanction inspections, not fed in CBS / report not held.
11
Advances > 1 Crore – Income Leakage – CRA rating done but ROI not corrected,
Processing charges not recovered ( whether review / renewal done or not)
12 Insurance not taken / inadequate / Bank’s charge not noted / not fed in CBS correctly.
by Prashant Singh (CM BOPM) 42
by Prashant Singh (CM BOPM) 43
No. Common deficiencies observed in CRM
13
Follow up of irregular / SMA accounts not ensured & such recording in concerned Inspection
registers not done.
14 CGTMSE cover for the eligible accounts not done.
15 KCC borrowers Personal Accidents Insurance cover not done in eligible cases.
16
SARFAESI notices sent / promised by borrower to pay / SARFAESI action deferred and thereafter
no follow up by branch, position remains the same as
was earlier.
17
Safe keeping of Gold ornaments are not as per Bank’s circular instructions / Purity never checked
by branch staff. Instruments of checking of purity not held / not being used.
18
TIR is not obtained in the Bank’s standard format.NEC for the broken period and on annual basis
was not obtained.
19
Valuation Report is not being obtained at stipulated periodicity. If obtained, it is not confirmed for
reasonableness of value by the branch official.
20 Post sanction inspection/stage wise inspection/periodic inspection not ensured.
21 Critical mandatory cases seriously in Mudra loan.
22 Incorrect IRAC status
by Prashant Singh (CM BOPM) 44
23 Migration of accounts to CPCs in prescribe time
No Common deficiencies observed in ORM
1 All OVVRs are not checked & checking records not kept properly for easy reference
2 Proper custody & accounting of pre printed INB kit with ID/password not on record.
3 Signature Scanning not done / pendency not followed up with LCPC for clearance.
4 KYC deficient CIFs /KYC documents not obtained periodically.
5 Unauthorized Parking accounts / Non-reconciliation of BGL Accounts.
6
High Value undelivered Banker’s Cheque – many favoring Branch Name, TDS, Government
departments, difference in unreconciled accounts / books.
7 Unreconciled ATMs physical balance with BGL balance observed.
8 False Compliances in Branch Manager’s Monthly Certificate.
9 Subsidy Register not maintained / not balanced periodically as per norms.
10 Interest paid in ineligible SB accounts as per circular instructions.
11 Balancing of Subsidy /STEPS Accounts not done.
12
Casual Labour engaged without approval of Controllers /payment is not as per approval condition.
by Prashant Singh (CM BOPM) 45
13
KYC non compliance in respect of accounts opened pre/Post- LCPC: Non review of stop and hold
accounts.
No Common deficiencies observed in ORM
14
Risk categorization / review of risk not done as per extant instructions particularly in advance
accounts, migrated accounts etc.
15 Time lock not provided / not functional, Embedding of Cash safe in walls.
16
False compliances submission in respect of critical/ high risk areas like INB, Insurances, EM, KYC,
CIBIL / Locker Agreements etc. It is to be STRICTLY avoided.
17
Control Copies of Charges returns are not available. Queries raised by Controller’s are neither
attended nor replied.
18
Fixed Assets ledger / registers are not balanced periodically at monthly intervals / accounted for all
items. All Fixed Assets items are not numbered.
19
Ambience is very poor / no maintenance of the premises is visible / ugly look appearance etc
20
Postages / inward mails are not marked off in register. Old register/s not held for verification.
21
Staff accounts scrutiny by the branch head. Conduct of CSC / CRP meetings is not meaningful.
22 BD Register is not properly maintained.
23
ATM Passwords are not being changed at Qtrly intervals as per instructions. Public accounts are
continuing as staff accounts and are applied of higher interest rate.
24 Password secrecy is not maintained by joint custodians.
25 Gold retention/ Cash retentionbylimPraisthiasntnSiontgha(CpMprBoOvPMed) / reviewed by controlling authori4t5y
PINKY FINGER : COMMON DEFICIENCIES
(Some Critical & High Risk Areas)
Sr Value Statement Risk
1 Genuineness of Title Deed & other documents verified have not been certified in TVSR C
2 Root / chain of title have not been adequately furnished in the legal opinion H
3 TVSR not on record/ Fresh TVSR not obtained. C
4 Only photocopy of TVSR on record. M
5 Original Search Fee Receipt & certified copies of title deeds issued by SRO not enclosed. C
6
Additional due diligence by perusal of any two of the followings were not incorporated in the
TVSR :a. Electricity Billb. Water Bill c. Sales Tax Registration d. Land / property Tax Paid etc.
M
7
Demarcation of the land not commented in the TIR. Boundaries / extent covered etc. not
clearly specified
H
8 Certificate of Title is silent whether the property is SARFAESI compliant C
9 Annexure-E was not compiled based on TIR and was not duly signed by the auth. officials. M
10 List of documents to be obtained for creation of EM not mentioned in TVSR H
11
Property acquired through Gift Deed but TVSR does not mention this fact. Vetting by Banks
Law Officer at ZO / LHO not obtained.
C
12
Satisfactory TIR from two different panel advocates in Banks Standard Format are not held
on record in applicable cases.
H
13 TVSR not obtained on Banks standard format. H
14
Validity of the POA and the documents executed under the POA has not been commented
upon in the TIR
C
15 EC not obtained upto the date of creation of EM /Subsequent to noting of our charge. H
16 Supplementary TIR is not obtained after the receipt of the original document. C
17 Opinion from the Law Department has not been obtained (Wherever applicable) H
18 Value of Primary Securities not ente
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Si
.
ngh (CM BOPM)
4
M
6
Some Critical & High Risk Areas : Continue....
Sr Value Statement Flag
19 Valuation report not obtained from Approved valour / revenue authority. H
20 Valuation report with location sketch of the property not obtained in standard format. H
21 Valuation report not obtained at prescribed periodicity. H
22 Realisable / residual value not shown in the appraisal memorandum. H
23 Valuation report is not held on record. C
24 Value of Collateral Securities not entered in CBS. M
25 Valuation report is not concurred/ countersigned by Bank Official. H
26 Valuation reports from two independent valuers not obtained, where Applicable H
27 Date of creation of EM is prior to Date of Application /Sanction / Arrangement Letter. C
28 EM / EM extension for enhanced for limits not created. C
29 EM Created at non-notified centre C
30 Mortgage of all properties stipulated in sanction not created. C
31
Description of property mentioned in the proposal does not tally with the original
documents on which EM is created
C
32 Memorandum of Deposit of Title Deeds not stamped / under stamped. H
33 EM Confirmation not sent under Registered Post H
34 SME 5 / 7 not signed by two officials of the Branch (who had signed the EM Recital) H
35
Recital of Creation / Extension of EM was not properly recorded in the EM / Title Deed
Register.
H
36 EM (recital) Memorandum SME 5 / 7 is not held on record. C
by Prashant Singh (CM BOPM) 47
Some Critical & High Risk Areas : Continue....
Sr Value Statement Flag
37
Copies of Recital (duly certified) are not on record, wherever extension of EM is created
at other branches of SBI
H
38 Confirmation to EM - Form A/Form B /SME 6/SME8 not on record. C
39 Confirmation letter incomplete. H
40 SME 5 / 7 is blank / partially filled up. H
41 EM register not in proper format H
42 EM register not signed by two officials at the Branch. H
43 All original title deeds stipulated in TVSR not held on record. C
44 Banks laid down procedure, in respect of Title deeds which are laminated, not followed M
45
Mortgage of Lease hold properties, the owner has additionally has not created the
mortgage as absolute owner. (wherever stipulated in the Sanction).
C
46
Agreement to create mortgage document has not been obtained, wherever mortgage is
to be created at a later date.
C
47
In case building is in the name of the Company and plot is in the name of the individual,
both have not created the EM after completion of the construction
C
48
NOC / Noting of Banks interest from Lessor (Govt. Agency - e.g., KSIIDC, MIDC, APIIC /
Co-operative Societies, etc.), have not been obtained as per terms of Lease.
C
49 Pattadhar pass book/ mutation documents etc. not obtained. Entries, C
50
EM created with the Copy / Certified Copy of document without completion of required
formalities.
C
51 NEC / broken period NEC not held with document. H
52 Land conversion (from AGL to NA) certificate not held on record. H
53
Description of property mentioned in the proposal does not tally with the original
documents on which EM is created
C
54 Link documents not recorded. by Prashant Singh (CM BOPM) 4H8
Some Critical & High Risk Areas : Continue....
Sr Value Statement Flag
55 Fresh NEC not obtained at stipulated periodicity. H
56 Where noting of EM / RM created, EC not obtained evidencing Banks charge recorded H
57 Registration of EM / Memorandum of Deposit (MOD) recording has not been done C
58
Noting of Banks charge with Revenue authorities (applicable only in the States where
Revenue Recovery Act is in force) not evidenced
C
59
Evidence (e.g. 7/12 extract/ GavNama/ Schedule of Declaration) in respect of all the
properties mortgaged to the Bank not held on record.
C
60 Details of Insurance Policies not entered in CBS. M
61 Banks charge not noted on the Insurance policy. C
62 Assets charged to the Bank are underinsured / not insured for full value. C
63
Sanction for waiver of insurance has not been obtained. Insurance waiver letter not
obtained wherever approval for waiver of insurance is there
H
64 Current insurance policy for collateral security not on record. C
65 Bank stipulated risks like fire/ burglary/ earthquake etc. not covered in policy. C
66 Current insurance policy for primary security not on record. C
67
Crops not covered under National Agricultural Insurance Scheme /by other Private
Insurance companies.
C
68 Revival letter not backed / not executed as per Board Resolution. H
69 Full chain of Revival Letters is not held on record. H
70 Revival Letter not properly executed. H
71 Revival letter not entered in Docum
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by Prashant Singh (CM BOPM) 50
Some Critical & High Risk Areas : Continue....
Sr Value Statement Flag
72 Revival Letter undated / not signed / not stamped. H
73
Letter of Acknowledgement of Debt not obtained from Borrowers/ Guarantors in
Documents barred by Limitation
C
74
Letter of Acknowledgement of Debt not obtained from Legal heirs in
the case of Deceased Borrowers / guarantors
H
75
Meaningful observations such as Activity levels, level of stocks, realization of book debts,
piling up of stocks, etc., are not commented upon.
H
76 Inspection Register not maintained / not Updated. M
77
Inspection Reports are not put up to higher authority in the standard format for WC
facility or TL under disbursement
H
78 Particulars of Unit Inspection were not fed in CBS. M
79 Collateral Assets not inspected periodically. H
80 Inspection at various stages of disbursement not evidenced. H
81
Adverse findings during the inspection, not taken up with Borrowers / Units and
improvement is not monitored
H
82 Periodicity of unit inspection is not maintained H
83 Post Sanction Inspection not conducted . C
by Prashant Singh (CM BOPM) 51
Important bullet points for score improvement / risk mitigation – ( BULLET
POINTS)
1. System Suspense Account to be zeroised at the end of the day before leaving the branch positively.
2. GL Day Book & VVRs are to be checked daily by all concerned.
3. ATM—Dual custody is MUST.
4. ATM Returned Cards & PINS are handled by TWO officials under Office Order.
5. Txns in NEW accounts to be monitored suitably under recording in Chq refer register.
6. KYC compliance is MUST in all cases of Pre-LCPC, Post-LCPC and Advances accounts.
7. Threshold Limits must be fed in CBS without fail as per customer PROFILE.
8. Accounts opened with BM id must be checked properly under recording in register.
9. Account opening forms must be filled in completely in addition to mandatory fields.
10.Mandatory Checking Reports List to be perused daily by the authorized official.
11. Cash Transactions Reports > Rs. 10 Lacs must be sent fortnightly to Controllers.
12. IP code must be put YES in CBS, if any.
13. KYC of other joint account MUST be done by the concerned official.
14. Manual Interest rate change must be authorized to be seen in the Report. 15.Nominations
to be entered in the PASSBOOKS with the consent of the depositor. 16.Uploading of the SS &
Photo must be ensured in all cases.
17. In Govt business transactions, obtaining of VDMS are MUST and kept safely date wise.
18. Whether account is being opened in correct product code or not to be ensured.
19.Sanction Limit is fed in CBS in all cases.
20. Expiry date of the stock statement must be fed & verified in CBS.
21. Details of Insurance / Collateral Insurance & Ratings must be fed in CBS. 22.Interest Rate
correctly fed in CBS as per product code. Is any concession is given in
CBS, check it.
23. OD against STDR, Set Rate are to be fed in CBS.
by Prashant Singh (CM BOPM) 52
24. STDRs of diff interest rate, Multi Limit creation is to be used for interest rate.
Product code for MULTI LIMIT set is--- 60801001 Set OD-Others in CBS, then automatically, Multi Limit menu
appears.
25. Intt Subvention upto Rs 3.00 Lacs is applicable upto Due date / 01 yr whichever is earlier. It is to be
ensured / confirmed in all eligible cases of KCC.
26. Cancellability clause to be set as “YES” in CBS in all applicable cases.
27.Customer no of CGTMSE has to be link as Guarantor in CBS. (DEN No)
28. Whether correct expiry date is given for Agr accounts or not?
29. In case of SBI Life loan, additional loan not to be used for Housing Loan. 30.Inspection
Profile, Security profile, Document Revival profile MUST be fed in CBS.
31. In H/L, print of the Repayment schedule MUST be kept in loan file.
32. Disbursement schedule must be properly accounted for in CBS for avoiding Pre / early
disbursement.
33. Recital to be created in CBS also in all applicable cases.
34. Current Rating of the loan account MUST be recorded in CBS for conservation of capital.
by Prashant Singh (CM BOPM) 53
35. List of accounts where HOLIDAYS FOR NPAs has been given in CBS must be seen by branch
officials for correctness.
36. BGL Day Book must be scrutinized by the Branch Manager without fail. (as staff member was
debiting BGL & crediting to own account was found in a branch)
37. Leaving Cash Cabin unlocked by the concerned SWO is a HIGH risk deviation.
38.Customers if are walking behind the Cash Cabins freely, is a HIGH risk deviation.
39. CCTV cameras to be kept always in working condition.
40. Back value dated transactions to be checked by the branch head on a daily basis as chances of
fraud are more in PPF accounts.
41. Debited Charges account TWICE for the same bill. To be ensured by the branch that it is not
happening, if Charges bills are checked by the branch head only and not by others without Control.
42. ATM Admin balance / Physical cash balance should always be same or of smaller difference.
by Prashant Singh (CM BOPM) 54