RBI unveils risk-based internal audit guidelines for select NBFCs, urban co-op banks, BFSI News, ET BFSI

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The Reserve Bank of India (RBI) on Wednesday unveiled the risk-based internal audit (RBIA) system for select non-bank lenders and urban co-operative banks, with a view to enhance the quality and effectiveness of their internal audit system. All the deposit-taking non-banking financial companies (NBFCs) and the ones with an asset size of over Rs 5,000 crore, and urban co-operatives banks (UCBs) with assets of over Rs 500 crore will have to migrate to the new system, the RBI said.

Currently, all the entities supervised by the RBI have their own approaches on internal audit, resulting in certain inconsistencies, risks and gaps in the system, the RBI said.

The NBFCs and UCBs face risks similar to the ones for scheduled commercial banks which require an alignment of processes, it added.

The central bank said the RBIA is an audit methodology that links an organisation’s overall risk management framework. It provides an assurance to the board of directors and the senior management on the quality and effectiveness of the organisation’s internal controls, risk management and governance-related systems and processes, it added.

The internal audit function is an integral part of sound corporate governance and is considered as the third line of defence, it said.

Historically, the internal audit system at NBFCs/UCBs has generally been concentrating on transaction testing, testing of accuracy and reliability of accounting records and financial reports, adherence to legal and regulatory requirements, which might not be sufficient in a changing scenario.

A shift to a framework which focuses on evaluation of the risk management systems and control procedures in various areas of operations, in addition to transaction testing, will help in anticipating areas of potential risks and mitigating such risks, the RBI said.

RBIA should undertake an independent risk assessment for the purpose of formulating a risk-based audit plan, which considers the inherent business risks emanating from an activity/location and the effectiveness of the control systems for monitoring such inherent risks, it said.

The entities have to implement the RBIA framework by March 31, 2022, and have been asked to constitute a committee of senior executives with the responsibility of formulating a suitable action plan.

The panel may address transitional and change management issues and should report progress periodically to the board and senior management, the central bank said.



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RBI to banks: Ensure authority, stature, independence, resources to internal audit function

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The Reserve Bank of India (RBI) has asked banks to ensure that the internal audit function has sufficient authority, stature, independence and resources within the bank to enable internal auditors to carry out their assignments with objectivity. It also emphasised that this function cannot be outsourced.

These directives are aimed at strengthening governance arrangements in banks under the Risk-Based Internal Audit (RBIA) Framework.

The central bank said the Head of Internal Audit (HIA) should be a senior executive of the bank with the ability to exercise independent judgement.

Also read: Audit firms told to delve deep into management explanations

The HIA as well as the internal audit function should have the authority to communicate with any staff member and have access to all records or files that are necessary to carry out the entrusted responsibilities.

RBI underscored that requisite professional competence, knowledge and experience of each internal auditor is essential for the effectiveness of banks’ internal audit functions.

The desired areas of knowledge and experience may include banking operations, accounting, information technology, data analytics and forensic investigation, among others.

The HIA will directly report to either the Audit Committee of the Board (ACB) / MD & CEO or Whole Time Director (WTD).

“Should the Board of Directors decide to allow the MD & CEO or a WTD to be the ‘reporting authority’ of the HIA, then the ‘reviewing authority’ shall be with the ACB and the ‘accepting authority’ shall be with the Board in matters of performance appraisal of the HIA,” the RBI said in a circular.

Besides, in such cases, the ACB should meet the HIA at least once in a quarter, without the presence of the senior management, including the MD & CEO/WTD.

As per the circular, the HIA will not have any reporting relationship with the business verticals of the bank and will not be given any business targets.

In foreign banks operating in India as branches, the HIA will report to the internal audit function in the controlling office / head office.

Except for the entities where the internal audit function is a specialised function and managed by career internal auditors, the Board should prescribe a minimum period of service for staff in the Internal Audit function and HIA should be appointed for a reasonably long period, preferably for a minimum of three years.

“The Board may also examine the feasibility of prescribing at least one stint of service in the internal audit function for those staff possessing specialised knowledge useful for the audit function, but who are posted in other departments, so as to have adequate skills for the staff in the Internal Audit function,” RBI said.

Also read: RBI to mandate risk-based internal audit for large UCBs, NBFCs

The central bank observed that the independence and objectivity of the internal audit function could be undermined if the remuneration of internal audit staff is linked to the financial performance of the business lines for which they exercise audit responsibilities.

Thus, the remuneration policies should be structured in a way that it avoids creating conflict of interest and compromising audit’s independence and objectivity.

No outsourcing

While the internal audit function should not be outsourced, RBI said where required, experts, including former employees, could be hired on contractual basis subject to the ACB being assured that such expertise does not exist within the audit function of the bank.

“Any conflict of interest in such matters shall be recognised and effectively addressed. Ownership of audit reports in all cases shall rest with regular functionaries of the internal audit function,” the circular said.

RBI has encouraged banks to adopt the International Internal Audit standards, such as those issued by the Basel Committee on Banking Supervision (BCBS) and the Institute of Internal Auditors (IIA).

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