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Internal controls and housekeeping in banks
To promote effective concern in reconciliation of debit entries in inter-branch accounts the concept of making provision for net debits outstanding for more than three years in inter -branch accounts has been introduced. The cut off period for provisioning has been reduced to more than two years from the period ended March 2001. Similarly, to have an effective monitoring on remittance transactions, the banks have been advised not to route entries on account of such transactions through normal inter branch account but evolve a separate account for this purpose. The banks have also been asked to ensure that outstanding entries under remittance transactions are reconciled on a weekly basis. Banks are required to ensure that the practice of forced matching of inter-branch entries should be subject to appropriate checks and balances. Any forced matching practice adopted by banks for adjustment of old unreconciled entries in inter-branch accounts should have the approval of their Audit Committee of the Board and the Board of Directors should be apprised of the full details of such practice. The statutory auditors of the bank should also look into the justifiability from the angle of fair accounting practice. There has been considerable improvement in the reconciliation of inter-branch accounts in public sector banks and the position of un-reconciled entries pending for more than two years. Total number of un-reconciled entries over two years, which stood at 22.58 lakh entries (Rs. 50706 crore) as on March 31, 1996, had declined to 14.74 lakh entries (Rs. 3824 crore) as on March 31, 2000. All public sector banks were advised to appoint a senior officer of the bank as Compliance Officer who should act as a nodal agency to ensure compliance of internal management controls as well as regulatory and guidance. Further, the banks were advised to review the present system of concurrent audit immediately and incorporate necessary changes therein based on the guidelines of RBI. The banks are also to review once a year the effectiveness of the system and take necessary measures to correct the lacunae in implementation. Banks are cautioned about the details of individuals/companies/firms/ proprietary concerns involved in perpetration of frauds, furnishing details of their directors/partners /guarantors/associates. In addition, modus operandi of new types of frauds is also circulated among banks and financial institutions, to put them on guard. RBI also conducts special scrutiny in respect of large value frauds at the branch/controlling office level to find out lapses contributing to the frauds. All cases of frauds involving large amounts are analysed to identify the contributory factors and taken up with the banks concerned for remedial measures. The aspects relating to recovery, staff accountability and improvement in internal controls are also pursued with the banks which are advised in the process to report the fraud cases to Police/CBI, if not already done. Detailed instructions have been issued by Reserve Bank of India towards streamlining fraud prevention and control/monitoring system. With a view to expediting the investigation of fraud cases, RBI reports cases involving Rs. 1 crore and above as also those revealing inter-state ramifications irrespective of the amounts to CBI. The banks are advised to examine staff accountability aspect in all cases. Obtaining photographs of accountholders while opening accounts is one of the measures introduced to control frauds. In-depth examination of large value frauds reported by commercial banks was conducted by a Study Group under the Chairmanship of CMD of a public sector bank. The group indicated common types of frauds by giving the modus operandi thereof and recommended several measures for early detection and prevention of frauds including recommendations for improvement in internal control, house-keeping, vigilance, management, etc. Apart from implementing the recommendations the banks were advised to adopt certain measures to avoid delay in reporting. It has also been decided that if large value frauds were due to non-observance of prescribed internal control system, certain restrictions are to be placed on opening of new branches by these banks. The banks have been advised to scrupulously follow the time limit laid down by Chief Vigilance Commissioner (CVC) and the position of adherence to CVC guidelines reviewed by their board on a quarterly basis. If these guidelines are not strictly followed, the concerned banks should furnish a report to the CVC. An Advisory Board on bank frauds was set up by the Governor, RBI with effect from March 1, 1997 under the Chairmanship of Shri S.S. Tarapore, former Member of BFS and Deputy Governor of RBI and five members drawn from areas such as law, administration, police, professional accounting and commercial banking. The Board has since been converted as Central Advisory Board on Bank Frauds and functions as part of the Central Bureau of Investigation (CBI) of Government of India. The Board advises on the cases referred by the CBI either directly or through the Ministry of Finance for investigation/ registration of cases against bank officers of the rank of General Manager and above. The Department of Banking Supervision is providing the secretarial assistance and RBI meets the cost of the functioning of the Board. |
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