Bank Audit Manual 2011-2012
Bank Audit Manual 2011-2012
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BANK AUDIT
MANUAL
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2011-2012
Key Points 3
Break Even Date for NPA is 01.01.2012 for the year 2011-2012
Once an account has been classified as NPA, all the facilities granted to the borrower will be
treated as NPA except in respect of Primary Agricultural Credit Societies (PACS)/Farmers
Service Societies (FSS).
Overdue period starts immediately on expiry of due date, concept of ‘past due’ has already been
dispensed with in past years.
Interest on advances (accrued and outstanding) should be calculated as on 31 st March (few banks
charges interest on advances few days prior to 31st March which should not be considered)
Long outstanding entries (unexplainable and where there is no movement at all) in suspense
account should be suggested for provisioning.
MOC should also be countersigned by Branch Manager (views of the BM if any has to be
attached on a separate sheet duly signed by him)
Submit all the REPORTS including TAX AUDIT REPORTS & LFAR immediately on
completion of Audit and before leaving the branch
Availability of security or net worth of borrower/guarantor should not be considered for the
purpose of NPA recognition – it should always be based on recovery
100% provision is required for assets which has become doubtful for more than 3 years i.e. NPA
date on or before 31.03.2008.
To specifically report simultaneously to the CEO of the bank and regional office of the Dept of
Banking Supervision RBI where the HO of the bank is situated, any matter susceptible to be
fraud or fraudulent activity or any foul play in any transactions. Any deliberate failure on part
of the Auditors should render himself liable for action. If amount of fraud involve Rs 1 Crore or
more – central office of the Dept of Banking Supervision, RBI, Mumbai to be reported
immediately.
Investments
Advances provisioning
Fixed assets
5. Auditors Report & The Auditors Report should be a self contained document
Memorandum of Changes and should contain no reference of any point made in any
other report including the LFAR;
Bank Audit Manual by CA. Sanjay K Agarwal Page No.6
Include Audit Qualifications in the Auditors Report and not
in the LFAR;
Quantify the Audit Qualifications for a better appreciation
of the point made to the reader;
For suggesting any changes in the financial statements of
the branch, quantify the same in the Memorandum of
Changes (MOC) and make it a subject matter of
qualification and annexe it to the Auditors Report.
7. Computerised Branches Review off-site back and daily back-up procedure of Bank
Exception reports viz. password errors, limit verification,
irregular advances
Custodian of pass word and unauthorized access of
password, computer room
Periodical report to controlling authority on functioning of
computerised system and compliance of controlling
authority instructions in this respect
Short duration crops are those other than long duration crops
Cash Credits The account remains continuously “out of Banks may not classify an account
and order” for a period of more than 90 days; merely due to existence of some
Overdrafts i.e., outstanding balance remains deficiencies, which are of temporary
continuously in excess of the sanctioned nature such as non-availability of
limit/drawing power adequate drawing power, balance
outstanding exceeding the limit, non-
or submission of stock statements and non-
renewal of the limits on the due date,
there are no credits continuously for a etc.
period of 90 days as on the date of Balance
Sheet However, generally stock statements
older than three months would be
or deemed irregular and the working capital
borrowal account will become NPA if
credits are not enough to cover the interest such irregular drawings are permitted in
debited during the same period. the account for a continuous period of 90
days even though the unit may be
working or the borrower’s financial
position is satisfactory.
Important Points
Key Words
Exclusion 1. Undernoted categories of advances should be excluded, as NPA norms are
not normally applicable to them:
All staff loans sanctioned under various staff loan schemes including housing
loans;
Advances against Banks deposits, NSC, IVP, KVP and LIP etc provided
adequate margin is available to cover the unrealized interest;
Credit facilities backed by State Govt. Guarantees where the default does not
exceed 90 days as on 31.03.2012;
All 2. Once an account has been classified as NPA, all the facilities granted to the borrower
Facilities will be treated as NPA except in respect of Primary Agricultural Credit Societies
(PACS)/Farmers Service Societies (FSS). Also, in respect of additional facilities
sanctioned as per package finalised by BIFR and/or term lending institutions,
provision may be made after a period of one year from the date of disbursement in
respect of additional facilities sanctioned under the rehabilitation package. The
original facilities granted would however continue to be classified as sub-
standard/doubtful, as the case may be
Adequate 3. Interest on advances against term deposits, NSCs, IVPs, KVPs and Life policies may
Margin be taken to income account on the due date, provided adequate margin is available
in the accounts
Reversal of 4. Till the time the account is identified as NPA, income is recognised irrespective of
Interest whether realised or not. Where an account is identified as NPA during the year,
unrealised income should not be recognised for the year. Also, interest accrued and
credited to income account in the previous year should be reversed or provided for
if the same is not realised.
Regularise 5. If the accounts of the borrowers have been regularised before the balance sheet
d before date by repayment of overdue amounts, the same should be handled with care and
balance without scope for subjectivity. Where the account indicates inherent weakness on
sheet date the basis of the data available, the account should be deemed as a NPA. In other
genuine cases, the banks must furnish satisfactory evidence to the Statutory
Auditors/Inspecting Officers about the manner of regularisation of the account to
eliminate doubts on their performing status.
Fees and 6. Fees and commissions earned by the banks as a result of re-negotiations or
commissions rescheduling of outstanding debts should be recognized on an accrual basis over the
(re-
period of time covered by the re-negotiated or rescheduled extension of credit.
negotiations)
LOC or 7. If the debits arising out of devolvement of letters of credit or invoked guarantees
guarantees are parked in a separate account, the balance outstanding in that account also
should be treated as a part of the borrower’s principal operating account for the
purpose of application of prudential norms on income recognition, asset
classification and provisioning.
Income 8. Income on NPA accounts to be recognized on realisation basis (conservative
recognition approach)
Loss Loss asset is one where loss 100% of the Such an asset is considered
Assets has been identified by the outstanding should be uncollectible and of such little
bank, external or internal provided for/written value that its continuance as
auditors or the RBI off. a bankable asset is not
inspectors, but the amount warranted although there
has not been written off may be some salvage or
(wholly or partly). recoverable value.
Dec SST D1 D2 D2
30 % of Secured portion of
Mar SST D1 D2 D2 outstanding and 100% of
Unsecured portion of outstanding
2
Jun SST D1 D2 for NPAs from 01.04.2008 to
0
31.03.2010
0
Sep SST D1 D2
9
Dec SST D1 D2
Mar SST D1 D2
2
Jun SST D1
0
20 % of Secured portion of
1
Sep SST D1 outstanding and 100% of
0
Unsecured portion of outstanding
Dec SST D1 for NPAs from 01.04.2010 to
31.03.2011
Mar SST D1
2
Jun SST
0
1 General – 10% of outstanding (20%
Sep SST
1 of outstanding if ab-initio
unsecured) for NPAs on or after
Dec SST
01.04.2011
2012 Mar SST
Date: ____________
Dear Sirs,
This representation letter is provided in connection with your audit of the financial statements of
_____________ branch of _______________ BANK for the period ended 31-3-2012 for the purpose of
expressing an opinion as to whether the financial statements give a true and fair view of the financial
position of ___________ branch of _______________ BANK as of 31-3-2012 and of the results of
operations for the period then ended. We acknowledge our responsibility for preparation of financial
statements in accordance with the requirements of the Reserve Bank of India and recognised
accounting policies and practices, including the Accounting and Auditing Standards issued by the
Institute of Chartered Accountants of India.
We confirm, to the best of our knowledge and belief, the following representations:
ACCOUNTING POLICIES
1. The accounting policies, which are material or critical in determining the results of operations
for the period or financial position are set out in the financial statements and are consistent with
those adopted in the financial statements for the previous period. The financial statements are
prepared on accrual basis except as stated otherwise in the financial statements.
ASSETS
2. The branch has a satisfactory title to all assets and there are no liens or encumbrances on the
company's assets.
FIXED ASSETS
3. The net book values at which fixed assets are stated in the balance sheet are arrived at:
a. after taking into account all capital expenditure on additions thereto, but no expenditure
properly chargeable to revenue;
b. after eliminating the cost and accumulated depreciation relating to items sold, discarded,
demolished or destroyed;
CAPITAL COMMITMENTS
4. At the balance sheet date, there were no outstanding commitments for capital expenditure
excepting those disclosed in Note No. ___ to the financial statements.
INVESTMENTS
5. The current investments as appearing in the balance sheet consist of only such investments as
are by their nature readily realisable and intended to be held for not more than one year from
the respective dates on which they were made. All other investments have been shown in the
balance sheet as `long-term investments'.
7. In respect of offers of right issues received during the year, the rights have been either been
subscribed to, or renunciated, or allowed to lapse. In no case have they been renunciated in
favour of third parties without consideration which has been properly accounted for in the books
of account.
8. All the investments produced to you for physical verification belong to the entity and they do
not include any investments held on behalf of any other person.
9. The entity has clear title to all its investments including such investments which are in the
process of being registered in the name of the entity or which are not held in the name of the
entity. There are no charges against the investments of the entity except those appearing in the
records of the entity.
10. The following items appearing in the books as at 31st March, 2012 are considered good and
fully recoverable with the exception of those specifically shown as "doubtful" in the Balance
Sheet:
Loans and Advances Rs.
11. In the opinion of the Board of Directors, other current assets have a value on realization in the
ordinary course of the company's business, which is atleast equal to the amount at which they
are stated in the balance sheet.
LIABILITIES
14. We have disclosed in notes to the financial statements all guarantees that we have given to
third parties and all other contingent liabilities.
15. Contingent liabilities disclosed in the notes to the financial statements do not include any
contingencies, which are likely to result in a loss and which, therefore, require adjustment of
assets or liabilities.
16. Provision has been made in the accounts for all known losses and claims of material amounts.
17. There have been no events subsequent to the balance sheet date, which require adjustment of,
or disclosure in, the financial statements or notes thereto.
GENERAL
19. The following have been properly recorded and, when appropriate, adequately disclosed in the
financial statements:
20. There have been no irregularities involving management or employees who have a significant
role in the system of internal control that could have a material effect on the financial
statements.
21. The financial statements are free of material misstatements, including omissions.
22. The company has complied with all aspects of contractual agreements that could have a
material effect on the financial statements in the event of non-compliance. There has been no
non-compliance with requirements of regularity authorities that could have a material effect on
the financial statements in the event of non-compliance.
23. We have no plans or intentions that may materially affect the carrying value or classification of
assets and liabilities reflected in the financial statements.
24. The branch has not received any notice, show cause, inspection advice, etc. from Government
of India, Reserve Bank of India or any other monitoring authority of India that could have a
material effect on the financial statements.
Authorised Signatory
April 1, 2012
_____________ Bank
_____________ Branch
Mumbai
Dear Sir:
As you are aware, we have been appointed as the Statutory Auditor to report on the accounts of your
Branch for the year 2011-2012.
In order to enable us to finalise the audit programme and furnish our report on the audit of the
accounts for the year 2011-2012 of your branch, may we request you to keep ready the
information/clarification as stated below and make the same available to our audit team at the earliest.
1. Latest Reports
The following latest reports on the accounts of your bank, and compliance by the bank
on the observations contained therein may be kept ready for our perusal:
Report on any other Inspection/Audit that may have been conducted during the course
of the year relevant to the financial year 2011-2012.
Please let us have a copy of the Head Office circulars/instructions in connection with the closing
of your accounts for the year, to the extent not communicated to us or incorporated in our
letter of appointment.
3. Accounting policies
Kindly confirm whether, as compared to the earlier year, there are any changes in the
accounting policies during the year under audit.
4. Balancing of books
Kindly confirm the present status of balancing of the subsidiary records with the relevant control
accounts. In case of differences between balances in the control and subsidiary records, please
give the details thereof and let us know the efforts being made to reconcile/balance the same.
This information may be given head-wise for the relevant control accounts, indicating the date
when the balances were last tallied.
5. Deposits
Please let us have the interest rate structure, applicable for the current year, for all the
types of deposits accepted by the branch.
b. Advances
Kindly confirm whether in respect of the advances against tangible securities, the branch
holds evidence of existence and latest market value of the relevant securities as at the
year-end.
Kindly inform the year-end status of the accounts, particularly those which have been
adversely commented upon in the latest reports of RBI/Internal Auditors/Concurrent
Auditors/Statutory Auditors, etc. on the branch as also accounts in respect of which
provisions have been made/recommended as at the previous year-end.
b. Type of facility
c. * Total amount outstanding as at the year-end (both for principal and interest)
specifying the date up to which interest has been levied and recovered.
Kindly confirm whether the borrowers’ account have been categorised according to the
norms applicable for the year into Standard, Sub-standard, Doubtful or Loss assets, with
special emphasis on Non-Performing Assets (NPA) and whether such classification has
also been made applicable by the branch to advances with balances of less than Rs.
25,000 each.
Kindly confirm whether you have examined the accounts and applied the norms
borrower-wise and not account-wise for categorising the accounts. Please let us have the
particulars of provisions computed/recommended in respect of the above during the
financial year under audit.
A list of all advances accounts which have been identified as bad/doubtful accounts and
where pending formal sanction of the higher authorities, the relevant amount have not
been re-classified/re-categorised in the book of the branch for provision/write off. This
covers all account identified by the branch or internal/external auditor or by RBI
inspectors but the amount has not been written-off wholly or partly.
In case the bank has recommended action against the borrowers or for initiating legal or
other coercive action for recovery of dues, a list of such borrowers’ accounts may be
furnished to us.
Please let us have a list of borrowers’ accounts where classification made as at the end
of the previous year has been changed to a better classification, stating reasons for the
same.
Kindly also confirm whether any income has been adjusted/recorded to revenue,
contrary to the norms of income recognition notified by the Reserve Bank of India and/or
Head Office circulars issued in this regards; and particularly where the chances of
recovery/realisability of the income are remote.
Kindly also confirm whether any income has been recorded on Non-Performing Accounts
other than on actual realisation.
Please let us have a statement of entries (head-wise) which originated prior to the year-
end at other branches, but were responded during the period after 31-3-2012 at the
branch.
e. Contingent liabilities
Kindly confirm whether other than for advances, there are any matters involving the
bank in any claims in litigation, arbitration or other disputes in which there may be some
financial implications, including for staff claim, municipal taxes, local levies etc. If so,
Kindly confirm whether guarantees are being disclosed net of margins, or otherwise as at
the year-end, and whether the expired guarantee where the claim year has also expired,
continue to be disclosed in the branch return. Please confirm specifically.
f. Interest provision
Kindly confirm whether interest provision has been made on deposits etc. in accordance
with the latest instruction of the RBI/interest rate structure of the bank. A copy of such
instructions/rate structure may be made available for our scrutiny.
Kindly confirm whether any amount recorded as income up to the year-end, which
remains unrecovered or not realisable, has been reversed from any of the income heads
or has been debited to any expenditure head during the financial year. If so, please let
us have details to enable us to verify the same.
Kindly confirm whether amount outstanding as at the year-end have been converted as
at the year-end rates prescribed by FEDAI. An authenticated copy of the FEDAI rates
applied may be given for our records.
Kindly confirm the amount of inward value of foreign currency parcels, if any, which
originated prior to the year-end from other banks, but could not be recorded as these
were in transit and for which entries were made after the year end.
h. Investment/Stationery
These may be produced for physical verification and/or evidence of holding the same be
made available.
Stock of unused security paper stationery/numbered forms like B/Rs, SGL forms, etc.
may please be produced for physical verification.
It may be confirmed whether income accrued/collected has been accounted as per the
laid down procedure.
It may be confirmed whether Investment Valuation has been done as per the extant RBI
guidelines.
In connection with the Long Form Audit Report, please let us have complete information as
regards each item in the questionnaire, to enable us to verify the same for the purpose of our
audit.
Please let us have the information required for the tax audit under section 44AB of the Income-
tax Act, 1961 to enable us to verify the same for the purpose of our report thereon.
k. Other certification
Please furnish us the duly authenticated information as regards other matters, which as per the
letter of appointment require certification.
Please let us have the duly reconciled statements for all Nostro as well as Local bank accounts.
A copy of the year-end balance confirmation statements should also be called for and kept
ready for our review.
Kindly keep ready all the books of accounts and other records like vouchers, documents, fixed
assets register, etc. for our verification.
Thanking you,
Yours truly,
Chartered Accountants
11. Date on which the asset was first classified as NPA (where applicable)
12. Facilities sanctioned:
Date of Nature of Limit Margin% Balance outstanding Prime Collateral
Sanction facilities (Rs. in at the year-end security security
Lakhs)
Current Previous
Year Year
Provision made: Rs.________ lakhs
13. Whether the advance is a consortium advance or an advance made on multiple-
bank basis
14. If Consortium,
15. If on multiple banking basis, names of other banks and evidence thereof
16. Has the Branch classified the advance under the Credit Rating norms in accordance
with the guidelines of the controlling authorities of the Bank
17. a. Details of verification of primary security and evidence thereof;
b. Details of valuation and evidence thereof
Provide the date and value of the guarantee in respect of the above.
20. Compliance with the terms and conditions of the sanction
Terms and Conditions
Compliance
i. Primary Security
a. Charge on primary security
b. Mortgage of fixed assets
c. Registration of charges with Registrar of Companies
d. Insurance with date of validity of policy
ii. Collateral Security
a. Charge on collateral security
b. Mortgage of fixed assets
c. Registration of charges with Registrar of Companies
d. Insurance with date of validity of policy
iii. Guarantees - Existence and execution of valid guarantees
iv. Asset coverage to the branch based upon the arrangement (i.e., consortium
or multiple-bank basis)
v. Others:
a. Submission of Stock Statements/Quarterly Information Statements
and other Information Statements
b. Last inspection of the unit by the Branch officials: Give the date and
details of errors/omissions noticed
c. In case of consortium advances, whether copies of documents
executed by the company favouring the consortium are available
21. Key financial indicators for the last two years and projections for the current year (Rs. in lakhs)
Indicators Audited year Audited year Estimates for
ended 31st ended 31st year ended 31st
March___ March___ March ___
Turnover
Increase in turnover % over previous
year
Profit before depreciation, interest and
tax
Less: Interest
Net Cash Profit before tax
Less: Depreciation
Less: Tax/Net Profit after
Depreciation and Tax
Net Profit to Turnover Ratio
Capital (Paid-up)
Reserves
Bank Audit Manual by CA. Sanjay K Agarwal Page No.22
Net Worth
Turnover to Capital Employed Ratio (The
term capital employed means the sum of
Net Worth and Long Term Liabilities)
Current Ratio
Stock Turnover Ratio
Total Outstanding Liabilities/total Net
Worth Ratio
In case of listed companies, Market Value
of Shares
a. High;
b. Low; and
c. Closing
i. Documentation;
ii. Operations;
iii. Security/Guarantee; and
iv. Others
1. In respect of common irregularities, the Auditors can give their comments borrower-wise in the
format given hereunder:
2. In respect of Column 9 above, “Irregularity No.”, the number as given in the “Glossary to
Irregularities” in Point 5, under the head “Item” below should be given for the irregularity
applicable to respective borrower.
In case the auditors feel that in spite of the list of irregularities given below, there are some
other irregularities, which the auditor would like to bring to notice, the auditor may separately
disclose under the given head by giving “appropriate number”.
For the aforesaid purpose, “appropriate number” would mean, for example, if the auditors feels
that in case of “Review/Monitoring/Supervision”, which has the number “4”, any additional
irregularity has to be incorporated, he may give a number after the last number appearing in
the list such as “4.52”, and onwards. Similarly in case of “Credit Appraisal” which has the
number “1”, any additional irregularity may be given “1.14”, and so on.
3. The borrower-wise details may be given in descending order based on the Amount
outstanding.
4. In addition to the above, auditors wanting to give notes in respect of Critical Advances (large or
small) with gross irregularities should give the same as per the format given in “Point 6” below.
5. GLOSSARY TO IRREGULARITIES
Item REMARK
1 Credit Appraisal
1.1 Loan application not on record at branch.
1.2 The appraisal form was not filled up correctly and thereby the appraisal and assessment
was not done properly.
1.3 Loan application is not in the form prescribed by Head Office.
1.4 The bank did not receive certain necessary documents and Annexures required with the
application form.
1.5 Basic documents such as Memorandum & Articles of Association, Partnership deed, etc.,
which are a pre-requisite to determine the status of the borrower, not obtained.
1.6 Certain adverse features of the borrower not incorporated in the appraisal note forwarded
to the management.
1.7 Industry/group exposure and past experience of the bank is not dealt in the appraisal
note sent to the management for sanction.
1.8 The level for inventory/book-debts/creditors for finding out the working capital is not
properly assessed.
1.9 Techno-economic feasibility report, which is required to know the technical aspects of the
borrower’s business, is not obtained from Technical Cell.
1.10 Credit report on principal borrowers and confidential report from their banks are not
insisted from the borrowers.
1.11 The opinion reports of the associate and/or sister concerns of the borrower are not
(Rupees in lakhs)
Facility Sanctioned Limit Drawing Power Outstanding as on 31.3.2012
Fund based:
Non-Fund based:
7. Security :
o Primary :
o Collateral :
Financial performance :
Operational comments :
The schedule of audit fees admissible to the Auditors for the audit work of the Branches, depending upon
the quantum of advances (as on the date with reference to which the audit is conducted) will be as under:-
Reserve Bank of India has advised in its recent communication that wherever Banks have Guest House or
visiting Officers’ flats, the same may be utilised to cater to the needs of the auditors.
Boarding Charges:
Major A Class Area I Other Places
Cities
----------------- -------- ---------------
(Rs.) (Rs.) (Rs.)
Proprietors/Partners of the
audit firm 500.00 400.00 325.00
Qualified Assistant 450.00 350.00 313.00
Unqualified Assistant 350.00 313.00 275.00
Boarding Charges as above shall be subject to production of Bills and when no bills are produced, boarding
charges @ 60% of the rates prescribed above to cover the boarding and other incidental expenses will be
paid.
Daily Conveyance Charges :
i) The actual local conveyance charges incurred by Auditors while working away from their
headquarters for conducting the Bank’s audit, not exceeding Rs.188/- per day for
proprietors/partners, Rs.94/- and Rs.75/- per day for qualified assistants and unqualified assistants
respectively may be reimbursed on the basis of self-declaration.
ii) In the case of local Auditors, if the distance between Auditors’ Office and Bank’s Office/Branch is
beyond 8 kms., actual expenditure not exceeding Rs.188/- per day for proprietors/partners, Rs.94/-
and Rs.75/- per day for qualified assistants and unqualified assistants respectively may be reimbursed
on a self-declaration.
iii) However, the reimbursement of such expenses shall not exceed 10% of the audit fees payable to the
respective auditors.
1. Unqualified Report
2. Qualified Report
3. Disclaimer of Opinion
4. Adverse Report
B. Various types of reports include:
a. Jilani Committee Report
b. Ghosh Committee Report
c. Special Reports as applicable (Prime Minister Rojgar Yojana Scheme Report etc.)
d. Long Form Audit Report
e. Tax Audit Report
f. Main Report (Sec. 30(3) of Banking Regulation Act, 1949)
C. Accounting standards not applicable to bank
Of the effective twenty eight standards, the following standards are not applicable to banks to the
extent specified.
a) AS 13, Accounting for Investments, does not apply to investments of banks.
b) AS 11, “The Effects of Changes in Foreign Exchange Rates”, does not apply to accounting of
exchange difference arising on a forward exchange contract entered into to hedge the foreign
currency risk of a firm commitment or a highly probable forecast transaction.
D. Considerations for overall audit Plan
• The terms of his engagement and any statutory responsibilities
• The nature and timing of reports or other communication
• The applicable legal or statutory requirements
• The accounting policy adopted by bank and changes in these polices
• The identification of significant audit areas
• The degree of reliance he expects to be placed on accounting systems and internal control
• The nature and timing of audit evidence obtained
• The work of internal auditors and extent of their involvement
• The involvement of expert
• The allocation of work to be undertaken between joint auditors and procedures for its control and
review
• Establishing and coordinating staffing requirements
E. Documentation
Following certificates should be obtained from management
Cash Retention Limit duly certified by the Branch Manager
A photo copy each of the confirmation certificates for Balances with RBI, SBI and other banks
A copy of the reconciliation statement in respect of differences in such balances with RBI, SBI and
other banks
List of overdue or matured investments at the end of the year duly confirmed by the Branch
Manager;
A certificate stating that the Branch did not hold any investments on behalf of the Head Office (if
there are no such investments held by the Branch
List of large advances i.e. those in respect of which the outstanding amount is in excess of 5% of the
aggregate advances of the Branch or Rs.2.00 crores whichever is less duly certified by the Branch
Manager
A copy of the letter from Head Office regarding Sanction limit of the Branch Manager;
F. Auditor should plan his work based on the client?s business to enable him to conduct an effective
audit in an efficient and timely manner as per AAS 8
Statement of companies (Auditor’s Report ) order 2003 is not applicable to banking company as
defined in clause (c) of section 5 of Banking regulation act.1949 Banking company means any
company, which transacts the business of banking in India;
Any company which is engaged in the manufacture of goods or carries on any trade and which
accepts deposits of money from the public merely for the purpose of financing its business as
such manufacturer or trader shall not be deemed to transact the business of banking
Specimen Audit Program