Bank Audit Provisions under Special Circumstances
- Provision on additional facilities sanctioned as per package finalised by BIFR and/or term lending institutions, need not be made for a period of one year from the date of disbursement
- Advances against term deposits, NSCs eligible for surrender, IVPs, KVPs, and life policies would attract provisioning requirements as applicable to their asset classification status.
- Advances against gold ornaments, government securities and all other kinds of securities are not exempted from provisioning requirements.
- Advances covered by ECGC/CGTSI guarantee: In the case of advances classified as doubtful and guaranteed by ECGCI CGTSI, provision is required to be made only for the balance in excess of the amount guaranteed by the corporation. Further, while arriving at the provision required to be made for doubtful assets, realisable
Banks are required ta revert SNA acceuats as per
prescribed limit el expesare ta Central Repesitenr ef
Information an Large Credits ICRILC) ef RBL
value of the securities should first be deducted from the outstanding balance in respect of the amount guaranteed by the corporation and then provision should be made,
- Provisioning norms for sale of financial assets to securitisation company (SC)/ reconstruction company (RC)-
- If the sale of financial assets to SC/RC, is at a price below the net book value (NBV) (i.e., book value less provisions held), the shortfall should be debited to the profit and loss account of that year.
- If the sale is for a value higher than the NBV, the excess provision will not be reversed but will be utilised to meet the shortfall/loss on account of sale of other financial assets to SC/RC.
- Framework for Revitalisation of Distressed Assets
The new frame work is given in part C of the Master Circular. The purpose of this frame work is to ensure that the banking system recognises financial distress timely, takes prompt steps to resolve it and ensures fair recovery for lenders and investors. Due to space constraints the same are not discussed in detail. However, some of the key aspects are discussed in brief hereunder: i) Banks are required to identify incipient stress
- Banks are required to report SMA accounts as per prescribed limit of exposure to Central Repository of Information on Large Credits (CRILC) of the RBI.
- As soon as an account is reported as SMA2, banks have to form a committee called Joint Lender’s Forum (JLF). The JLF in turn would decide Corrective Action Plan (CAP) which would be either rectification or restructuring or recovery.
- While a restructuring proposal is under consideration by the JLF/CDR, the usual asset classification norm would continue to apply.
- As a measure to impose disincentives on borrowers not maintaining credit discipline, accelerated provisioning norms are prescribed (Refer para 26 of the Master Circular).
- As per para 27 of the Master Circular, banks would be required to identify directors whose name appear more than once in the list of willful defaulters as also no cooperative borrowers. The provisioning for such cases will be at the rate of 5% if it is a standard account and accelerated provision as per para 27 if it is NPA.
Having discussed the Master Circular, audit steps for verification of NPA and some important issues are discussed here:
- Generally, all the banks have a system driven process of identification of account as NPA in place. Verify the system and various parameters to ensure the accuracy of classification, reversal of unrealised interest/ income, categorisation of account into substandard or doubtful I, II, III, calculation of provision, carry forward of classification of NPA date,
- Some of the critical areas in CC/OD accounts which auditor need to verify are determination of correct drawing power, temporary deficiencies, fresh sanction to regularise an account, regularisation of account near about the balance sheet date through genuine sources,
- Reversal of unrealised interest on classification of an account as NPA and non-recognition of income subsequently.
- Accounting and recognition of income in NPA accounts on recovery.
- If an account is classified as NPA, all the facilities of the borrower to be classified as NPA.
- Up gradation of accounts from NPA to Standard if any and whether the same is in accordance with the guidelines given in the Master Circular.
- Verification of secured and unsecured portion and provisioning. Many a times, valuation report of securities are not available. In such cases, auditor will have to be careful in evaluating the value of securities and take an appropriate view.
- If the debits arising out of devolvement of letters of credit or invoked guarantees are parked in a separate account, the balance outstanding in that account also should be treated as part of the borrower’s principal operating account for the purpose of prudential norms on income recognition, asset classification and provisioning. (Para 4.2.7(ii) of Master Circular)
- If an account is restructured, ensure that guidelines as prescribed in the Master Circular are followed.
Important aspects relevant for audit of NPAs have been discussed in this article. Needless to mention that auditor should refer Master circular dated 1st July, 2014 of RBI for better understanding of the subject. ■