DAMODARAM SANJIVAYYA NATIONAL LAW UNIVERSITY

VISHAKAPATNAM

TOPIC

BANK AUDIT – A STATUTORY FRAMEWORK

SUBJECT

BANKING LAW

FACULTY

BUSHRA QUASMI

STUDENT NAME

L. SAI RADHA KRISHNA

ROLL.NO/SEC

2016055-A

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 ACKNOWLEDGEMENT

I am using this opportunity to express my gratitude to everyone who supported me through

the course of the project. I would like to thank our teacher who encouraged and supported me
for doing this project. And I am sincerely grateful to them.

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 TABLE OF CONTENTS

INTRODUCTION……………………………………………………………………03

AUDIT OF BANKING COMPANY…………………………………………………03-04

INSPECTION OF BANKING COMPANHY………………………………………..04-05

PRINCIPLES OF AUDITING………………………………………………………..05-06

AUDIT COMMITTEE………………………………………………………………..06-07

LIMITATIONS OF AUDITING………………………………………………………07

TYPES OF BANK AUDITING……………………………………………………….07-10

STAGES IN AUDITING………………………………………………………………11-13

PROCEDURE, LIABILITIES AND POWERS OF AUDITORS…………………….14

APPROACH TO BANK AUDITS…………………………………………………….15

AUDIT PLANNING……………………………………………………………………15

SUPERVISORY FUNCTION IN INDIA………………………………………………16-17

CONCLUSION………………………………………………………………………….17-18

BIBILOGRAPHY………………………………………………………………………..20

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 1. INDTRODUCTION
Banks occupy the pride of place in any financial system by virtue of the significant role they
play in spurring economic growth by undertaking maturity transformation and supporting the
critical payment systems. The specificity of banks, the volatility of financial markets,
increased competition and diversification, however, expose banks to risks and challenges.
The protection of depositors’ interests and ensuring financial stability are two of the major
drivers for putting in place an effective system of supervision of banks.

Credibility of an institution, particularly that of financial institution depends on its internal

control and supervision mechanism which can promptly detect irregularities, if any, and take
corrective measures and ensure non recurrence of irregularities. Business of banking is
susceptible to frauds. It is therefore necessary to have an internal control and supervision
mechanism for ensuring that no one person is in a position to violate procedures, rules,
regulations, guidelines, do an unauthorized act detrimental to the organization which remains
undetected for an indefinite period or long time. Therefore, inspection and audit plays crucial
role in success of banking operations.1

2. AUDIT OF BANKING COMPANY

The balance sheet and the profit and loss account of a banking company have to be audited as
stipulated under Section 30 of the Banking Regulation Act, 1949. Every banking company’s
account needs to be verified and certified by the Statutory Auditors as per the provisions of
legal frame work. The powers, functions and duties of the auditors and other terms and
conditions as applicable to auditors under the provisions of the Companies Act are applicable
to auditors of the banking companies as well. The audit of banking companies books of
accounts calls for additional details and certificates to be provided by the auditors.

They include whether or not:

 information and explanation, required by the auditor were found to be satisfactory;

 The transactions of the company, as observed by the auditor were within the powers
of the company.

1 Review of Supervisory Processes for Commercial Banks dated 19th June,2012

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  Profit and loss account shows a true picture of the profit or loss for the period for
which the books have been audited and any other observations to be brought to the
notice of the shareholders.

Special responsibility is cast on the bank auditor in certifying the bank’s balance sheet and
profit and loss account, since that reflects the sound financial position of the banking
company. Apart from the balance sheet audit, Reserve Bank of India is empowered by the
provisions of the Banking Regulation Act, 1949 to conduct/order a special audit of the
accounts of any banking company. The special audit may be conducted or ordered to be
conducted, in the opinion of the Reserve Bank of India that the special audit is necessary;

 In the public interest and/or

 In the interest of the banking company and/or
 In the interest of the depositors.2

The Reserve Bank of India’s directions can order the bank to appoint the same auditor or
another auditor to conduct the special audit. The special audit report should be submitted to
the Reserve Bank of India with a copy to the banking company. The cost of the audit is to be
borne by the banking company.

3. INSPECTION OF BANKING COMPANY

As per Sec 35 of the Banking Regulation Act, the Reserve Bank of India is empowered to
conduct an inspection of any banking company. After conducting the inspection of the books,
accounts and records of the banking company a copy of the inspection report to be furnished
to the banking company. The banking company, its directors and officials are required to
produce the books, accounts and records as required by the RBI inspectors, also the required
statements and/or information within the stipulated time as specified by the inspectors.3

Government’s role:

The Central Government may direct the Reserve Bank to conduct inspection of any banking
company. In such cases, a copy of the report of inspection needs to be forwarded to the
Central Government. On review of the inspection report, the Central Government can take

2
Audits Of Banks: Lessons From Crisis
3
Marshall C. Cons, Bark Auditing –Cambridge, Mass

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appropriate action. In the opinion of the Central Government if the affairs of the banking
company are not being carried out in the interests of the banking company, public and or
depositors, the Central Government may

 prohibit the banking company to accept fresh deposits

 Direct the Reserve Bank to apply for winding up of the banking company under the
provisions of the Banking Regulation Act.

Before taking action, the Government has to give an opportunity to the banking company to
explain their stand. Based on the response, the Government can initiate appropriate action as
required.

Scrutiny:

Apart from inspecting the books and accounts of the company, the Reserve Bank can conduct
scrutiny of the affairs and the books of accounts of any banking company. Like in the case of
inspection, the Reserve Bank can handle the scrutiny as required.

4. PRINCIPLES OF AUDITING
 Integrity, objectivity and independence:

The auditor should be honest and sincere in his audit work. He must be fair and objective. He
should also be independent.

 Confidentiality:

The auditor should keep the information obtained during audit, confidential. He should not
disclose such information to any third party. He should, keep his eyes and ears open but his
mouth shut.

 Skill and competence:

The auditor should have adequate training, experience and competence in Auditing. He
should have a professional qualification and practical experience. He should be aware of
recent developments in the field of auditing such as statement of ICAI, changes in company
law, decisions of courts etc.

 Working papers:
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The auditor should maintain working papers of important matters to prove that audit was
conducted with due care according to the basic principles.

 Planning:

The auditor should plan his audit work. He should prepare an audit programmed to complete
the audit efficiently and in time.

 Audit evidence:

The report of the auditor should be base on evidence obtained in the course of audit. The
evidence may be obtained through vouching of transactions, verification of assets and
liabilities, ratio analysis etc.

 Evaluation of accounting system and internal control:

The auditor should ensure that the accounting system is adequate. He should see that all the
transaction has been properly recorded. He should study and evaluate the internal controls.

 Opinion and report:

The auditor should arrive at his opinion on the account based on the audit evidence and
submit his report. The opinion may be unqualified, qualified or adverse. The audit report
should clearly express his opinion. Law should require the content and form of audit report.

5. AUDIT COMMITTEE

In pursuance of RBI circular September 26, 1995, a bank is required to constitute an Audit
Committee of its Board. The membership of the audit committee is restricted to the Executive
Director, nominees of Central Government and the RBI, Chartered Accountant director and
one of the nonofficial directors.

One of the functions of this committee is to provide direction and oversees the operations of
the total audit function in the bank. The committee also has to review the internal inspection
function in the bank, with special emphasis on the system, its quality and effectiveness in
terms of follow up. The committee has to review the system of appointment and
remuneration of concurrent auditors.

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The audit committee is connected with the functioning of the system of concurrent audit. The
method of appointment of auditors, their remuneration and the quality of their work is to be
reviewed by the Audit Committee. It is in this context that periodical meeting by the
members of the audit committee with the concurrent auditors help the audit committee to
oversee the operations of the total audit function in the bank.

6. LIMITATIONS OF AUDITING

1. An auditor cannot check each and every transaction he has to check only the selected areas
and transaction on a sample basis.

2. Audit evidence is not conclusive in nature thus confirmation by a debtor is not conclusive
evidence that the amount will be collected. It is said evidence is rather than conclusive in
nature.

3. An auditor cannot be expected to discover deeply laid frauds usually involves acts
designed to conceal them such as forgery , celibate failure to record transactions, false
explanation and hence are difficult to detect.

4. Audit cannot assure the users of account about the future profitability, prospects or the
efficiency of the management.

5. An auditor has to rely upon expert auditor may have to rely on expert in related field such
as lawyers, engineers, value’s etc. for estimating contingent liabilities, valuation of fixed
assets etc.

7. TYPE OF AUDIT IN BANK

The entire process of audit depends upon the type of audit. Type of audit to be conducted is
to be selected carefully, keeping in mind the objects of audit in each and every case. Hence it
is essential to study the various types of audit before laying down the programme for any
audit work.

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BASED ON AUTHORITY:

 Statutory Audit:

It is the audit, which is compulsory under the law*Appointment of auditors, removal,

Remuneration, rights; duties, and liabilities are governed as per the provisions 'of the
respective law applicable to the organisation. Scope of audit work and all other terms are
as laid down by the law. It can be conducted only by a qualified Chartered Accountant.

 Non-Statutory Audit:

Non-statutory audits are voluntary audits. These audits are not compulsory under any law.
Terms and conditions of audit are determined as per the agreement made between the
auditor and proprietor for e.g. financial audit of a sole trader or partnership firm. It also
includes non-financial audits e.g. internal audit, management audit, Operational audit,
Social audit, etc.

 Internal Audit:

This type of audit is also optional. It is conducted by the internal auditor who is appointed
by the proprietor. Even the employee of the organisation may be appointed as an internal
auditor to examine the books of accounts. All the terms and conditions of audit work are
determined by the agreement. The basic purpose of internal audit is not only to examine
the books of accounts but also to review the present working and make valuable
suggestions to improve it.

BASED ON SCOPE:

 Complete Audit:

In complete audit the auditor has to check each and every transaction, voucher document
etc. relating to the transactions of business. These types of audit are not possible in case
of large business organizations.

 Partial Audit:

Sometimes auditor may be called upon to audit few books and give his finding thereon.
Sometimes he may be called upon to audit only the payment side of cashbook or receipts
side only. This is called as Partial Audit. Auditor has to be very careful when he

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 undertakes this type of audit. Usually this type of audit is called for when a fraud or
misappropriation is" suspected. While submitting the report auditor should clearly
mention -the scope and documents or books made available to him for his audit. Partial
audit is not practical. Such an audit’s possible where audit is not a legal necessity.

BASED ON TIME:

 Continuous Audit:

“One where the auditor, or his staff, is constantly engaged in checking the accounts
during the whole period or where the auditor or his staff attends at regular or irregular
intervals during the period.” Continuous audit means an audit at regular intervals
throughout the accounting year. Continuous audit, accounting and’ auditing work is done
side by side.

 Final /annual /periodical / completed Audit:

Periodic audit is also known as 'final or completed audit'. Final audit is carried out
continuously until it is completed. It is a past accounts audit. In case of a final audit, the
auditor gets hold of all the books of accounts and the vouchers for the, accounting Period.
He is in possession of all the facts and figures relating to the accounting period for which
the audit is being conducted. In case of this audit, the auditor visits the clients place only
once and remains there till the audit is over. Generally this type of audit is appropriate for
smaller business concerns. Generally majority of audits are in the nature of Final Audits.

 Interim audit:

It is a kind of audit, which is conducted in between the annual or final audits. It is

conducted to find out the interim profit and know the financial 'position at the end of a
part of the accounting year. This is usually carried out at half yearly intervals. Hence, this
is also called as half yearly audit.

BASED ON OBJECT:

 Special audit:

Under section 233 A of companies Act, the central government has power to direct
special audit under following circumstances:

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a) When the affairs of any company are not managed as per the sound business principles.
b) When the financial position of the company is such as to endanger its solvency.

c) When company is being managed in a manner which is likely to cause serious injury or
damage to the interest of trade or industry The auditor appointed by the government is
required to report to the government.

 Cost audit:

It is a type of audit, which involves verification of cost records maintained by the

organisation. Under section 233 B of the companies Act, 1956 the central government
may direct an audit of cost records by a person who is qualified. Appointment of auditor
is done by the board of director subject to the approval of the central government. The
auditor’s report to the government, the copy of the report is send to the company. It has
been defined as” the verification of the correctness of cost accounts and of adherence to
the cost accounting plan.

 Management audit:

'Management auditing is concerned with review of operations and performance of

management to improve efficiency and effectiveness of the organisation. It is, thus, an
extension of internal audit function. Some authors use the terms management auditing
and operational auditing interchangeably because of the close resemblance of
methodology employed. But it may be noted, although operational auditing is also
concerned with review of operations of an entity, management auditing, in addition to it
also includes review of managerial performance. Secondly, the frame of reference of a
management audit is derived, generally, from the expectations of the external participants
and not of organisation's management as in case of operational auditing.

 Social audit:

Social audit is a recent development in the field of at it is based on the modern concept of
social responsibility of business. Social audit examines to what extent the business is
discharging the social responsibilities. It examines the contribution of the concern to the
society at large.

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 8. STAGES IN AUDITING
1) PRELIMINARY WORK:

a) The auditor should acquire knowledge of the regulatory environment in which the bank
operates. Thus, the auditor should familiarize himself with the relevant provisions of
applicable laws and ascertain the scope of his duties and responsibilities in accordance
with such laws. He should be well acquainted with the provisions of the Banking
Regulation act, 1956 in the case of audit of a banking company as far as they relate of
preparation and presentation of financial statements and their audit.

b) The auditor should also acquire knowledge of the economic environment in which the
bank operates. Similarly, the auditor needs to acquire good working knowledge of the
services offered by the bank. In acquiring such knowledge, the auditor needs to be aware
of the many variation in the basic deposit, loan and treasury services that are offered and
continue to be developed by banks in response to market conditions. To do so, the auditor
needs to understand the nature of services rendered through instruments such as letters of
credit, acceptances, forward contracts and other similar instruments.

c) The auditor should also obtain and understanding of the nature of books and records
maintained and the terminology used by the bank to describe various types of transaction
and operations. In case of joint auditors, it would be preferable that the auditor also
obtains a general understanding of the books and records, etc, relating to the work of the
other auditors, In addition to the above, the auditor should undertake the following:

I. Obtaining internal audit reports, inspection reports, inspection reports and concurrent
audit reports pertaining to the bank/branch.

II. Obtaining the latest report of revenue or income and expenditure audits, where
available.

III. In the case of branch auditors, obtaining the report given by the outgoing branch
manager to the incoming branch in the case of change in incumbent at the branch during
the year under audit, to the extent the same is relevant for the audit.

D) One set of tests that the auditor at both the branch level and head office level may
apply for audit of banks in analytical procedure.

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2) EVALUATION OF INTERNAL CONTROL SYSTEM:

It may be noted that transaction in banks are voluminous and repetitive, and fall into limited
categories/heads of account. It may, therefore, be more appropriate that the evaluation of the
internal control is made for each class/category of transaction. If the exercise of internal
control evaluation is properly carried out, it assist the auditor to determine the effectiveness
or otherwise of the control systems and accordingly enable him to strengthen his audit
procedures, and lay appropriate emphasis on the risk prone areas. Internal control would
include accounting control administrative controls.

a) Accounting controls:

Accounting controls cover areas directly concerned with recording of financial transactions
and maintenance of such registers/records as to ensure their reliability.

Internal accounting controls are also envisaging such procedures as would determine
responsibility and fix accountability with regard to safeguarding of the assets of the bank. It
would not be out of place of mention that there is a distinction between accounting system
and internal accounting controls. Accounting system envisages the processing of the
transaction and events, their recognition, and appropriate recording. Internal controls are
techniques, method and procedures so designed and usually built into systems, as would
enable prevention as well as detection of errors, omissions or irregularities in the process of
execution and recording of transaction/events.

b) Administrative control:

These are broadly concerned with the decision making process and laying down of
authority/delegation of powers by the management. It may be noted that in the normal course,
the head office use the zone/regional offices do not conduct any banking business. They are
generally responsible for administrative and policy decisions which are executed at the
branch level.

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3) PREPARATION OF AUDIT PROGRAMME FOR SUBSTANTIVE TESTING AND
IT’S EXECUTION:

Having familiarized him the requirements of audit, the auditor should prepare an audit
programme for substantive testing which should adequately cover the scope of his work. In
framing the audit programme, due weight age should be given by the auditor to areas where,
in his view, there are weaknesses in the internal controls. The audit programme for the
statutory auditors would be different from that of the branch auditor. At the branch level,
basic banking operations are to be covered by the audit. On the other hand, the statutory
auditors at the head office (provisions for gratuity, inter- office accounts, etc.). The scope of
the work of the statutory auditors would also involve dealing with various accounting aspects
and disclosure requirements arising out of the branch returns.

4) PREPARATION AND SUBMISSION OF AUDIT REPORT:

The branch auditor forwards his report to the statutory auditors who have to deal with the
same in such manner, as they considered necessary. It is desirable that the branch auditors’
reports are adequately in unambiguous terms. As far as possible, the financial impact of all
qualification or adverse comments on the branch accounts should be clearly brought out in
the branch audit report. It would assist the statutory auditors if a standard pattern of reporting,
say, head wise, commencing with assets, then liabilities and thereafter items related to
income and expenditure, is followed.

In preparing the audit report, the auditor should keep in mind the concept of materiality.
Thus, items which do not materially affect the view presented by the financial statements
may be ignored. However, in the judgement of the auditor, an item though not material, is
contrary to accounting principles or any pronouncements of the Institute of Chartered
Accountants of India or in such as would require a review of the relevant procedure, it would
be appropriate for him to draw the attention of the management to this aspect in his long form
audit report.

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 9. PROCEDURE, RIGHTS AND LIABILITIES OF AUDITORS

Central statutory auditors:

The statutory central auditors are appointed by the bank concerned on the basis of the names
recommended by RBI from out of a panel of auditors. The RBI formulates required norms on
the basis of which a panel is prepared by the Comptroller and Auditor General of India.

Branch auditors:

For the appointment of branch auditors in case of nationalised banks including State Bank of
India and its subsidiaries, RBI maintains a panel which is prepared by ICAI. ICAI invites
applications for this purpose for empanelment. On the basis of these applications, ICAI
prepares and sends the panel to RBI.

The remuneration of statutory central auditors as well as branch auditors is fixed on the basis
of certain norms laid down by RBI.

Right and liability:

The auditor of a bank has the same rights and liabilities as those of a company auditor with
the following exceptions.

 The rights and powers of the auditors of a co-operative bank are governed by the
relevant Co-operative Societies Act.
 If a person, in any return, balance sheet or other document, wilfully and knowingly
makes a statement, which is false in any material particular or wilfully omits to make
a material statement, he is liable for punishment with imprisonment for a term which
may extend to three years and is also liable to fine under Section 46 of the Banking
Regulation Act.

Special audit:

In addition to the normal audit, a special audit of a bank can be ordered by RBI under Section
30 (1B) of the Banking Regulation Act. If the RBI is of the opinion that it is necessary to do
so in public interest or in the interest of the bank or its depositors, it can give the order for
special audit. For conducting the special audit, RBI may either appoint any person who is
qualified to act as a company auditor or direct the statutory auditor of the bank to conduct the
special audit.

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 10. APPROACH TO BANK AUDITS

The guidance note on the audit of banks issued by the ICAI, recognise that the general
approach to audit of banks involves essentially the same stages as in any other audits.
However at each stage, the auditor has to take into account the following special
characteristics of banks;

 Custody of large volumes of monetary items, thereby requiring formal operating

procedure, well-defined limits on the individual discretions and rigorous internal
control.
 Large volume and variety of the transactions and containing development of new
products and services, many of which may involve complex accounting
 Wide geographical dispersal of the operations with consequent difficulties in
maintaining uniform operating practices and accounting system, particularly in the
case of the overseas operations.
 Significant commitments without transfer funds not requiring formal recognitions in
the books of accounts.
 Special nature of risk with operations.
 A strict legal and regulatory framework that inter alia, influence the accounting and
auditing.
11. AUDIT PLANNING
 Proper allocation of work among Audit Team should be done for smooth performance
of Audit.
 A checklist of work to be done should be made with time frame, which should be
specifically adhered to.
 Review latest available inspection report and concurrent audit report of branch. 
Review closing circular issued by HO
 Study business Mix of branch to decide the sample size and mix.
 Study of significant policies of the branch and computer system.
 Study the previous year’s Statutory Audit Report and LFAR
 Ask for ‘Stress List’ from Branch
 Give special importance to clients whose names are in Stress List, or which are
highlighted in Concurrent Audit Report.
 Keep a note of points you come across during audit, which are relevant for LFAR.

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 12. SUPERVISORY FUNCTION IN INDIA

The legal and institutional framework for bank supervision in India is provided under the
Banking Regulation Act, 1949. Until 1994, different departments in Reserve Bank of India
were exercising supervision over banks, non-banking financial companies and financial
institutions. To keep a close watch on financial markets and avoid recurrence of crisis in the
financial system, the Board for Financial Supervision was set up under the aegis Reserve
Bank under Reserve Bank of India (Board for Financial Supervision) Regulations, 1994 with
the objective of paying undivided attention to the supervision of the institutions in the
financial sector.

To have better supervision and control, a separate board was constituted namely “The Board
for Financial Supervision” as per the provisions of the RBI. The Board has the jurisdiction
over the banking companies, nationalized banks, State Bank of India and its subsidiaries. The
members of the Board are: Governor of the Reserve Bank of India as the chairperson, Deputy
Governors of the Reserve Bank of India, and one of the deputy governors should be
nominated by the Governor as the full time vice chairman, four directors from the Central
Board of the Reserve Bank nominated by the Governor as members.4

SUPERVISORY POWERS, RESPONSIBILITIES AND FUNCTIONS

An effective system of banking supervision has clear responsibilities and objectives for each
authority involved in the supervision of banks and banking groups. There are twenty nine
Core Principles in all out of which we enlist a few:

 Supervisory approach:

An effective system of banking supervision requires the supervisor to develop and

maintain a forward-looking assessment of the risk profile of individual banks and banking
groups, proportionate to their systemic importance; identify, assess and address risks
emanating from banks and the banking system as a whole; have a framework in place for
early intervention.

4
http://financialservices.gov.in/banking/circulars/2012/Guidelines%20on%20Bank%20Audit%20Systems28.06.2012.pdf/

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  Supervisory techniques and tools:

The supervisor uses an appropriate range of techniques and tools to implement the
supervisory approach and deploys supervisory resources on a proportionate basis, taking
into account the risk profile and systemic importance of banks.

 Internal control and audit:

The supervisor determines that banks have adequate internal control frameworks to
establish and maintain a properly controlled operating environment for the conduct of
their business taking into

 Financial reporting and external audit:

The supervisor determines that banks and banking groups maintain adequate and reliable
records, prepare financial statements in accordance with accounting policies and practices
that are widely accepted internationally and annually publish information that fairly
reflects their financial condition and performance and bears an independent external
auditor’s opinion

 Disclosure and transparency:

The supervisor determines that banks and banking groups regularly publish information
on a consolidated and, where appropriate, solo basis that is easily accessible and fairly
reflects their financial condition, performance, risk exposures, risk management strategies
and corporate governance policies and processes.

13. CONCLUSION

The Bank Audit is a vast area. In addition, there are number of seminars conducted. Apart
from the sources of knowledge made available, the auditor has to understand the purpose of
audit, conduct the audit with logical thinking and application of knowledge. The report has to
be drafted in such a manner that it should stand on the test of contents, clarity and utility.

A well conceived audit policy put to practice by those who are expected to discharge the
onerous responsibility in the bank would depict that the audit operations is not mere ritual but
a critical operation and need to be dealt with beyond numbers. Experienced audit committee

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in bank do make sense and value edition when audit function is given a direction and indeed
great comfort to all concerned with the bank.

Therefore, few recommended action plan for greater compliance with the Basel Core
Principles are:

 Provide greater certainty regarding the independence of RBI by removing impeding

provisions from related acts.

 Provide greater clarity regarding the role of the nominee director in the public banks,
which can blur the distinction between the legal powers of RBI as a banking
supervisor and an active role of RBI appointed staff in the management or compliance
function of a bank. .

 Developing mechanisms for written material (including inspection reports) to be

regularly shared on a timely basis;

 Broadening and strengthening escalation protocols to promptly alert other relevant

supervisors about concerns that a supervisor is developing; and

14. BIBILOGRAPHY

 Regulatory Framework of Bank Audit and Inspection- A Critical Study- Hariharan

 https://cleartax.in/s/statutory-audit-of-banks
 https://www.rbi.org.in/scripts/bs_viewcontent.aspx?Id=946
 http://www.sircoficai.org/downloads/Guidance-Note-Audit-Banks-2017-
edition.pdf
 Bank audit – opportunities and concerns – M.M. chitale

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