(On the letter head of the firm) A

March __, 2021

The Manager
_____________ Bank
_____________(Branch) URGENT
___________________

Dear Sir,

Sub: Audit of the accounts of your Branch for the year 2020-21 - Audit engagement/
Letter seeking information/Management Representations:

You have already been informed by your Management, that we have been appointed as
the auditors to audit and report on the accounts of the Branch for the year 2020-21.
We have accepted the appointment, and we confirm that the audit shall be carried out in
accordance with the applicable legal provisions and the regulatory requirements, besides
the applicable authoritative pronouncements of the Institute of Chartered Accountants of
India, with the objective of expressing an opinion on the Branch financial statements. For
this purpose we will perform sufficient tests to obtain reasonable assurance as to whether
the information contained in the accounting records and other source data is reliable and
sufficient as the basis of the preparation of the financial statements; and whether the
information is properly presented in the said statements.

Management’s Responsibility for the Financial Statements:

You are aware that it is the Management’s responsibility for the preparation of the financial
statements including adequate disclosures and making judgments and estimates, that are
reasonable and prudent so as to give a true and fair view of the state of affairs of the
Branch at the end of the financial year and of the financial performance by way of true
position of profit or loss of the Branch for the year then ended, in accordance with the
statutory and Regulatory requirements for the time being applicable. The Management’s
responsibility includes the maintenance of adequate accounting records, the selection and
consistent application of appropriate accounting policies and implementation of applicable
accounting standards along with proper explanation relating to any material departures
from those accounting standards and the design, implementation and maintenance of
internal controls, not only for the safeguard of the assets of the Bank/branch, but that are
relevant to the preparation and fair presentation (of the state of affairs as at the year end
and the true balance of profit or loss for the year under audit) reflected in the financial
statements that are free from material misstatement, whether due to fraud or error.

Our objectives are to obtain reasonable assurance about whether the financial statements
are free from material misstatement, whether due to fraud or error, and to issue an
auditor’s report that includes our opinion. Reasonable assurance is a high level of
assurance, but is not a guarantee that an audit conducted in accordance with SAs will
always detect a material misstatement when it exists. Misstatements can arise from fraud
or error and are considered material if, individually or in the aggregate, they could
reasonably be expected to influence the economic decisions of users taken on the basis of
these financial statements.

Bnkad21.sanjay v & mmk 1

(On the letter head of the firm) A
As part of an audit in accordance with SAs, we shall exercise professional judgment and
maintain professional skepticism throughout the audit. In respect of the Branch, we shall
also:
• identify and assess the risks of material misstatement of the financial statements,
whether due to fraud or error, design and perform audit procedures responsive to those
risks, and obtain audit evidence that is sufficient and appropriate to provide a basis for
our opinion. The risk of not detecting a material misstatement resulting from fraud is
higher than for one resulting from error, as fraud may involve collusion, forgery,
intentional omissions, misrepresentations, or the override of internal control.
• obtain an understanding of internal control relevant to the audit in order to design audit
procedures that are appropriate in the circumstances. Under section 143(3)(i) of the
Companies Act, 2013, we are also responsible for expressing our opinion on whether the
bank has adequate internal financial controls system in place and the operating
effectiveness of such controls.
• evaluate the appropriateness of accounting policies used, to the extent applicable to the
Branch, and the reasonableness of accounting estimates and related disclosures made
by management of the Branch.
• be able to conclude on the appropriateness of management’s use of the going concern
basis of accounting and, based on the audit evidence obtained at branch, whether a
material uncertainty exists related to events or conditions that may cast significant doubt
on the Bank’s ability to continue as a going concern.
• evaluate the overall presentation, structure and content of the financial statements,
including the disclosures, and whether the financial statements represent the underlying
transactions and events in a manner that achieves fair presentation.

We shall communicate with those charged with governance regarding, among other
matters, the planned scope and timing of the audit and significant audit findings, including
any significant deficiencies in internal control that we identify during our audit.

We shall also provide those charged with governance with a statement that we have
complied with relevant ethical requirements regarding independence, and to communicate
with them all relationships and other matters that may reasonably be thought to bear on
our independence, and where applicable, related safeguards.

From the matters communicated with those charged with governance, we shall determine
those matters that are of most significance in the audit of the financial statements of the
current period and are, therefore, the key audit matters. We shall describe these matters
in our auditor’s report unless law or regulation precludes public disclosure about the
matter or when, in extremely rare circumstances, we shall determine that a matter should
not be communicated in our report because the adverse consequences of doing so would
reasonably be expected to outweigh the public interest benefits of such communication.

In addition to our report on the financial statements, we expect to provide you with a
separate letter concerning any material weaknesses in accounting and internal control
systems which might come to our notice through the Long Form Audit Report (LFAR),
essentially in response to the questionnaire prescribed by the Reserve Bank of India, or
otherwise.

We also wish to invite your attention to the fact that our audit process is subject to `peer
review’ under the Chartered Accountants Act, 1949 and the reviewer may examine our
working papers during the course of such review.

We wish to complete some audit procedures even prior to the year-end, depending on
your state of readiness/response.

Bnkad21.sanjay v & mmk 2

(On the letter head of the firm) A
In view of the severe time constraints imposed, we are confident you will make
available to us, strictly within the dates stipulated, the following Branch
returns/statements duly completed, pre- reviewed and duly authenticated, to enable
us to furnish our reports in the form and manner desired of us by law or by the
Reserve Bank of India and not necessarily in the form and manner prescribed by the
Bank:
Statements/returns:
a) the Balance Sheet as at 31.3.2021;
b) the Profit and Loss Account for the year 2020-21;
c) the statements relating to the particulars of Advances as at 31.3.2021; and
d) other supporting returns/statements/annexures (including those covering the LFAR
requirements).

In connection with our assignment, we seek from you the Information/ clarifications as
stated in Annexure `I' to this letter and may seek further information on other matters in
the course of audit. As part of the audit process, we will expect to receive from the
Management, written confirmation of the representations made to us; and a written
response (para-wise), to our requirements is imperative, and such response is to
be based on your verification of facts and evidence.

To enable us to monitor the progress of the audit and completion of the assignment,
please indicate/mention, the actual date(s) of completion as well as handing over to
us of each statement/return/ confirmation or other information required to be
prepared by you (as per the contents of the letter of appointment sent to us), by
your endorsement of the date on each such statement/return/confirmation, (duly
authenticated).
We await your commitment.

We shall be indemnified for all legal and other costs as may be required to be incurred by
us if we are required to defend ourselves in respect of frauds detected / reported where
we are sought to be made a party in litigation/arbitration/resolution of any disputes.

We shall be grateful if you could confirm the name(s) of the Officer(s) designated by the
Branch to comply with our requirements in connection with the audit, so that our reports
are expedited.

We shall appreciate your co-operation in the matter.

Thanking you,
Yours faithfully,

CHARTERED ACCOUNTANTS

Bnkad21.sanjay v & mmk 3

(On the letter head of the firm) A
Annexure I to letter dated March __, 2021
INFORMATION /REQUIREMENTS IN CONNECTION WITH THE AUDIT OF ACCOUNTS FOR
THE YEAR ENDED MARCH 31, 2021
1. Latest Reports:
For our scrutiny, the following latest reports on the accounts of your Branch, and
compliance by the Branch on the observations contained therein:
a) Branch Audit Report and Accounts;
b) Long Form Audit Report;
c) Quarterly review report (if any);
d) Internal Inspection Report;
e) Internal/Concurrent Audit Report(s);
f) Credit Audit Report;
g) RBI Inspection Report, if such inspection took place;
h) Income and Expenditure Control Audit/Revenue Audit Report;
i) IS/ IT/Computer/EDP Systems Audit; and
j) any special inspection/investigation report.
If there has been a change of Incumbent during the year in the Branch, our attention
may be drawn to any reservations, observations/remarks that may have been made by
the Incoming Branch Head, with regard to the financials of the Branch that have effect
on its state of affairs or working of the Branch, particularly as regards the
classification status of the advances.
2. Circulars in connection with Accounts/financial statements:
Please confirm that you will have at the Branch, for our ready reference, a list and copy of all
the HO/CO/RBI circulars, including the year-end closing of Accounts Circular(s),
relevant to the accounts for the year 2020-21; and that you will make these available in the
course of audit.

3. Accounting Policies, as applicable to the Branch:

If there is a change, since the preceding year, in the Accounting policies, as having
an impact on the Branch statements/returns, we may be duly informed of the same and
the financial effect thereof may be communicated for our verification.

4. Accounts, if maintained on Computer/ in the EDP environment:

Please confirm:
a. the system followed for maintenance of accounts in relation to the branch, including in
particular the system generated information/data and that on the decentralized basis at
the branch. We may also be informed of the nature of software package(s) currently
installed at the Branch to supplement/interlink the centralised system; and whether there
are any changes/ modifications in the package(s) since the preceding year, as regards the
systems as well as changes in the system driven information, brought about by
virtue of regulatory/statutory amendments and H.O. Circulars, including in particular
affecting the revenue, due to applicability of revised interest rates on deposits, advances
etc.
The nature, basis and the effective dates of the modifications, may please be
confirmed to us.
b.whether the input data relating to the Branch is duly reviewed on facts and
evidence/documentation, before being input into the Bank’s centralized system, particularly
as regards applicable interest rates on deposits and advances, as also data having effect
on the classification and income recognition as regards advances.
c.whether, all transactions that required manual intervention to the system generated
information/data have been duly adjusted in the books and incorporated in the
financial statements of the Branch up to the year end.
d.the system laid down for computer and data security, back-ups, off-site storage (including
locations and personnel in charge), contingency and disaster recovery system/plans and
adherence thereto at the Branch; and whether the system ensures periodic testing of the
same.
Bnkad21.sanjay v & mmk 4
(On the letter head of the firm) A
Annexure I to letter dated March __, 2021 (Contd.)

Any adverse features observed during the year may be confirmed, along with the
remedial action taken.
e. Whether the computerized system applicable for the branch, has been validated to
ensure that all the requisite /applicable parameters are incorporated therein. This
may be evidenced.
f. Whether daily exception reports as to the “system” as well as “transactions”, are
available and that there is no pending remedial action/ compliance up to the year end; as
also that the statements incorporate adjustments required based on the month-end/day-
end procedures as at the year-end. Any such report that is pending compliance may be
brought to our notice.

5. Deposits
a) Overdue/matured Term Deposits:
Please confirm whether:
i) there are unclaimed/overdue/matured term deposits, which are included in Term
Deposits, instead of Demand Deposits. These may be quantified and made known.
ii) any interest provision/adjustment is made up to the year end in respect of
unclaimed/unpaid/matured deposits, particularly in respect of deceased depositors..
The amount may be confirmed both, for Rupee denominated as well as foreign currency
deposits.
iii) renewals of deposits are made, including interest accretion, at net of tax
deduction at source, at the rates as applicable.
iv) there are any deposits, (received/ suo moto renewed), where :
- formal deposit receipts, on security paper stationery, are not physically issued,
although book entries have been made as per the computerized system,
- deposit receipts are physically issued but not dispatched to deposit holders
(particularly where the amounts received in foreign currency are to be covered by
Deposit Receipts from another foreign exchange authorized Link Branch). A list of
such unissued/ undispatched Deposit Receipts in the physical custody of the
Branch may be given and the Receipts produced for our verification.
- renewals have been made by endorsement on the existing Deposit Receipts
,without issuing fresh receipts.
v) any deposits have been renewed other than in the name(s) of the original holder e.g. in
the case of deceased depositors. In such cases, it may be confirmed to us as to
whether the Branch holds the necessary evidence on record as to the authenticity of
the deposit holder.
vi) Interest accrued but not due and for which provision is made as at the year end,
is shown in the balance sheet as part of:
 Rupee denominated Fixed/Term Deposits(indicate interest accrued and not
due, if forming of the Deposits); or
 FCNR(B) deposits (indicate interest accrued and not due forming part of
Deposits); or
 Savings Bank Accounts; or
vii) Interest Accrued in Savings Bank accounts after the date of the last application
has been shown as part of Other Liabilities. If so, the amount may be made
known to us;

Bnkad21.sanjay v & mmk 5

(On the letter head of the firm) A
Annexure I to letter dated March __, 2021 (Contd.)

viii) the Branch holds any foreign currency denominated (FCNR(B)) deposits , whether with
fixed maturity or otherwise, which have become inoperative. You are aware that in
terms of Foreign Exchange Management (Crystallization of Inoperative Foreign Currency
Deposits) Regulations, 2014 and vide Notification No. FEMA 10A/2014-RB dated March
21, 2014, issued under Foreign Exchange Management Act (FEMA), 1999 relating to
inoperative foreign currency deposits, directions had been issued under Sections 10(4)
and 11(1) of FEMA; inoperative deposits having a fixed term and those with no
fixed term maturity, after the expiry of a three month notice upon completion of
three years, will get crystallized into Rupee dominated deposits. Please confirm if
any such action was required, but not taken in the Branch.
ix) any FCNR (B) have been accepted/renewed without evidencing on record the Non-
residential status of the Depositor. If so details may be provided. Refer Para 1(c) of Part
II of the LFAR questionnaire.

b) Tax Deduction at Source

i) Please confirm the system followed by the Bank with regard to deduction of tax at
source on interest on deposits (including in respect of interest accrued but not due as
aforesaid), and whether in respect of interest (based on credit or payment
whichever is earlier), including in respect of cumulative Deposit Schemes and on
renewals of matured deposits, Tax as required to be deducted at source was so
deducted on due dates and deposited within the prescribed period; Cases of non
compliance may be listed for our review and incorporated in Form 3CD (Tax
Audit Reporting Format).Please confirm that the relative returns have been filed
in required Forms.

ii) We may be informed if there are any amounts paid at the Branch, on account of
Tax Deducted at source (either due to a demand raised by the Tax Authorities, or
in respect of provisions, or otherwise), which remain to be linked to the accounts
of the depositors, and in respect of which the amounts have not yet been
incorporated in the related TDS Returns. The total amount paid and not linked
may be made known.

c) Back- ended or other subsidies adjustable against advances

Please confirm whether Deposits include any amounts received under specific schemes. If
so, the amount thereof and interest, if any, paid thereon during the year, may be
confirmed; and whether interest on advances is calculated net of Govt. subsidies, if
any, in such schemes, contrary to RBI applicable norms.

d) Deposits held as margins:

Please confirm whether against issue of guarantees/ LCs and other similar obligations, the
Branch holds any cash margins by way of fixed deposits, which are shown as part of the
`Deposits’ portfolio.
If so, the aggregate amount of such deposits may be made known to us.

e) Inoperative Deposit Accounts:

Please confirm the procedure followed at the Branch with regard to identification of
Dormant/ Inoperative Accounts and safeguards as to operations therein; and whether
the identified accounts are segregated/ maintained in separate distinct ledgers.
Please let us have information as regards debits, if any, in accounts while the
accounts were held as inoperative or dormant.

Bnkad21.sanjay v & mmk 6

(On the letter head of the firm) A
Annexure I to letter dated March __, 2021 (Contd.)

f) Gold Monetization Scheme 2015 (GMS) (if applicable to the Branch):

Please confirm if the Bank Branch is designated to accept / hold deposits under the Gold
Monetization Scheme (GMS), in terms of the RBI Master Direction
No.DBR.IBD.No.45/23.67.003/2015-16 dated 22-10-2015, as updated till 16-8-2019
Please Confirm whether the Branch:
 is designated to accept, from eligible persons, deposits, the principal and interest of
which under the Scheme and Directions, is to be denominated in gold.
 has accepted any such deposits {STBD (Short term Bank Deposits)} and recorded them
in its books on due dates; and maintains on behalf of the Central Govt., a record of
{MLTGD (Medium and Long term Govt. Deposits)}
 has evidence on record as to the option excised by depositor (at the time of making the
STBD deposit) to redeem either in gold or at Rupee equivalent of the gold value.
 has followed the internal controls with regard to acceptance of deposits, including ‘KYC’
norms.
 has kept in safe custody, and is in possession of the gold accepted till the date of
commencement of interest.
 has appropriately disclosed the value of gold held in its Balance Sheet.
 has imported any gold for redemption of STBD; and whether any such deposits were
redeemed as per Scheme.
 has maintained a memoranda record of MLTGD, including safe custody of gold
equivalent of MLTGD on behalf of the Government.
 has sold any gold to MMTC for minting India Gold Coins (IGC), or to jewelers and other
banks participating in Gold Monetisation Scheme (GMS).
 has lent gold under Gold Metal Loan (GML) Scheme to MMTC for minting IGC and to
jewelers
 has accounted for the advances to jewelers based on the contractual terms to obtain the
value of the gold on completion of tenure of loan together with interest accretion.

6. Balance(s) with other Banks(including RBI/ *SBI):

[* not applicable to branches of SBI]
We seek balance confirmation certificates in evidence of the year end outstanding balances
with other banks, and the related reconciliation statements (in respect of entries originating
prior to 31-3-2021 but not responded till the year), also confirming whether any entries in
such reconciliation statements, have effect on the revenue up to 31.3.2021. Please confirm
whether the pending items in reconciliation were adjusted after 31.3.2021, and whether
these are considered in the Memorandum of Changes (MOCs).

In case a currency chest is attached to the Branch, whether all deposits into, and
withdrawals from, the Currency Chest, have been duly communicated on a value
date basis to the linked branch of the Bank, unless the Branch itself maintains the
account of Reserve Bank of India, to effect the necessary adjustments. In the latter
case, it may be confirmed whether the inward currency chest slips from other linked
offices are recorded on a value date basis till the year end, unless covered by MOC.

7. Advances:
a) Please confirm whether the aggregate of the advances as per the Branch Balance Sheet as
at 31.3.2021 reconciles with the Particulars of Advances (Portfolio) statement after including
/considering:
 interest bearing staff advances;
 credit card dues;
 debit balances in Savings/Current/deposit accounts;
 unappropriated credit balances (including in litigation) which were otherwise required to
be adjusted;
Bnkad21.sanjay v & mmk 7
(On the letter head of the firm) A
Annexure I to letter dated March __, 2021 (Contd.)
 DICGC/ECGC and other credit guarantee claims received and pending adjustment;
 Interest Suspense or any account of similar nature;
 FITL Accounts and related credit towards provision;
 Subsidies (and interest thereon, to the extent requiring adjustment) ;
 foreign exchange differences on the above, if decentralized; and
 value dated entries pertaining to Advances Accounts originating prior to the year-
end but recorded after that date.

b) A summary of the particulars of Advances as per Annexure II may be provided to us:

(information includes pre-merger information as on 31.03.2020, where the Branch was an
erstwhile branch of a bank merged on 1.4.2020)

i) Top 25 NPAs and their status as at 31.3.2021 and 31.3.2020.

ii) NPAs upgraded to Standard classification during the period 1.4.2020 to 31.3.2021,
justifying reasons for the same; also indicating the amount of any unapplied interest
in such accounts (not debited/charged to the borrower);- refer Item 3 of Annexure
IA.
iii) While upgrading the NPA to ‘Standard’, is there any element of default (causing the NPA)
which has not been fully remedied, e.g. where there are arrears of interest which caused
the default.

c) Centralised Advances Processing Cells/ Centres /Clusters

Where all or any of the loan procedures (whether in connection with grant or renewal of
credit facilities) are not processed at the Branch, but are centralized at a Loan Processing
Cell/Centre/Cluster (e.g., Retail Assets and Small & Medium Enterprises City Credit Centre,
Retail Assets Credit Processing Centre, Retail Credit Processing Centre, or by whatever
name called), involving appraisal, sanction, execution of documents, collection and holding
of post dated cheques etc., and the documents are in the custody and control of the such
centralized Cell/ office, please confirm as to how the compliance of the applicable RBI
prudential norms of asset classification, income recognition and provisioning has been
made, in so far as the advances at your Branch are concerned.
We would like you to satisfy us as to the compliance of the appraisal systems,
completeness and accuracy of the original records/documents in the custody and control of
the centralized office, pursuant to which you are maintaining the borrowal account; and in
particular:
i. that confirmation is available from the said Office as to the number and amount of the
advances accounts, and whether these tally with the data in the Branch;
ii. that the latest Sanction Letters, issued to you by the said centralized office (together with
all modifications , if any therein as updated) , and held by you for your compliance at the
Branch, are duly authenticated (and not merely computer generated, without
authentication), confirmed by such centralized office as updated and in consonance with
the regulatory guidelines and Bank’s laid down policy for the time being in force. .
iii. that the drawing power/limits if conveyed to you have been properly computed at the
centralized office, for your ensuring that the account of the borrower is monitored at the
Branch accordingly, without any defaults;
iv. that adverse features pointed out by the Internal/concurrent/inspection audit of the
centralized office as regards the appraisal, disbursement, sanction, documentation
under their control, have been considered by you for classification of the account; and
further that there are no unbanked cheques / instruments for amounts due/received up to
the year end, that are held by the said office affecting the borrowers’ accounts.

Bnkad21.sanjay v & mmk 8

(On the letter head of the firm) A

Annexure I to letter dated March __, 2021 (Contd.)

vi. that for the purpose of audit, the Branch will arrange to provide evidence, as to the
documents, security and guarantee aspects etc. to justify the classification of the amount
reflected in the branch books as advances; and information sought, including on all large
advances, in the manner required by us.
The above information is critical to our examination/reporting on advances and may
please be ensured at the Branch.

d) Please let us have a list and particulars of advances accounts corresponding to each
category as per the recommended format in Annexure IA (and Section C 1) to this letter.

e) In respect of Advances(large borrowers), each with outstanding aggregate balance of

fund based and non-fund based advances above 10% of the total Advances
Portfolio of the Branch or Rs. 10 crores , whichever is lower , the year-end Status
Report on these may be given as per Annexure III, III.1 and III.2, which includes
information as per the LFAR.
Where there are adverse comments on any borrowal accounts in any internal/external
report as to classification, please let us have reasons/justification for not accepting
such adverse comments, or change in classification.

f) Please confirm whether:

- the borrowers' accounts have been classified by the Branch strictly according to the RBI
norms for the time being applicable, particularly the Non-Performing Assets(NPA) [Sub-
Standard, Doubtful or Loss assets].
In case a computerized package is being used for such classification, whether the
Branch can demonstrate effectively that the applicable latest parameters as per the
prudential norms of RBI, have been duly incorporated in the package.
- the Branch has examined the accounts based on documentation security / guarantee /
operations aspects etc., and except as otherwise required by RBI, determined the
classification status borrower-wise and not account-wise, as above (including in
respect of the loans processed at a centralized/designated office) as also stated in Para
7(c) above.
- the classification as at the year-end of borrowal accounts under consortium
arrangements with other participating banks, and in cases of multiple banking, has been
done on the basis of operation of the accounts as per your Branch, without the
necessity of relying on classification made by other participating banks; however,
confirming to us, the status of the borrower, if known as adverse, in case of other
lenders.
- you have any amounts due to/from other banks in consortium or multiple banking
arrangements where such amounts are contractually due to/from such other banks as at
the year end to the extent of any difference; also confirm if these have any effect on the
account of any borrower, corresponding to any inter-bank outstandings with such banks.
- the Branch has evidence of the existence, ownership and realistic realizable value
of the security and that the computation of the Drawing Power (DP) has been
correctly made, net of margin applicable on “paid for stocks” and “eligible”
debtors. In case of consortium advances, where another bank is the leader,
whether you have received and verified the DP to be in consonance with the terms
of your sanction. Please review all cases to determine if, and to the extent, the DP is
required to be modified and as may have a bearing on the classification of the borrower,
based on such computation of limits/drawing power, as also where relaxation, if allowed
due to COVID. This may also be evidenced.

Bnkad21.sanjay v & mmk 9

(On the letter head of the firm) A

Annexure I to letter dated March __, 2021 (Contd.)

- the ownership/existence/market value is evidenced, based on physical inspections or
otherwise through stock audit or other verification procedures applied nearer the
balance sheet date; which evidence may be produced for our examination.
- parity in classification is maintained at all branches in respect of the same borrower,
particularly where the branch maintains a “sub limit” out of the borrowings sanctioned at
another branch of the Bank.
- in respect of facilities of Rs.5.00 crores and above,
 Whether and in which cases stock audit was required, but was not conducted;
and
 Cases in which stock audit was conducted where adverse features noticed have
not been addressed particularly where the borrower has not produced the related
records for stock audit; and whether it has any effect on classification of any
borrowers.
- any borrower has defaulted in complying with the terms of sanction relating to
submission of periodical statements of stock/debtors and whether the Branch has
verified the information.
- in case of NPAs, the periodicity of valuation, and the basis on which valuation is
arrived at in respect of advances for the year under audit, particularly in case the
security valuation reports/dates are older than one year.
- there are at the year-end, any stray / other credits (including wrong entries/mere
book adjustments) in any borrowal account but for which the account would be
NPA, particularly if the said credit(s) is/are reversed after the year-end.
- there are any cheques discounted at the year end and credit given to borrowers in
cases where, but for such credit the advance would be NPA.
- as at the year-end, upgradation in classification of any advance is made , based on
any subsequent favourable events, including recovery of amounts in default that
may have caused the borrowing to be NPA.
- where the amounts are disbursed in installments (e.g. Housing Loans) the EMIs have
been recomputed for effective dates
g) Besides furnishing us information as per Annexure II, may we request you to
provide us with a list of the:
i) Borrowers identified/classified as NPAs during the year and whether, and extent to
which, unrealized income on such accounts is reversed/ derecognized. In case the
unrealized income on such accounts has been reversed by giving credit to the
accounts of the borrowers, the amounts so reversed may be made known to us;
particularly, if any reversal pertains to unrealized income in respect of accounts
taken over on merger from an erstwhile bank.
ii) List of Borrowers, treated as Standard, where one time settlement was sanctioned, but
there is a default in repayment or in compliance of the terms thereof;
iii) Particulars of Advances where there is divergence of opinion between the Branch
Management and the RBI/Inspection/ Internal/Concurrent audit Reports etc., as to the
classification, provisioning, income recognition, indicating as to how this has been
addressed by the Branch.
iv) The aggregate of the amounts of advances in the standard category which have the
status of “critical amount due”; and whether any amounts comprised therein are over 90
days in default as at 31.3.2021.
A list of such accounts may be made available and quantified, for our review.
v) Borrowal accounts (in standard category), which have been “short reviewed” or not
reviewed/ renewed for 180 days since the due date of their last renewal, or where there is
a default on the part of the borrower in submission of stock statements, for a
period of 90 days beyond any period of default/irregularity, including that commencing
prior to 31.3.2020; and if so, whether such borrowers are classified as NPAs.
Particulars of accounts overdue for review/renewal and in default for 6 months and 1
year, and those over 1 year may be provided.

Bnkad21.sanjay v & mmk 10

(On the letter head of the firm) A

Annexure I to letter dated March __, 2021 (Contd.)

vi) accounts which do not fall within the definition of advances, such as interest
free employee advances, but have been shown as such in the accounts of the
Branch may be listed for our review.
vii) borrowal accounts in the “Standard” or “Sub Standard” category which are the
subject matter of reference to BIFR/ DRT or in litigation, justifying their classification.
vii)Advances to borrowers on the list of willful defaulters (as per the latest list and
guidelines of the RBI).
viii) all accounts where the default resulted in WCTL, FITL, WCDL etc. and
whether the advances would be NPAs but for such facilities.
h) Upgradation of classification:
Please let us have a list of borrowers' accounts (including projects under
implementation and restructured accounts), where classification previously made, as
NPA has been upgraded to a better classification, stating reasons for the same; and
whether provision (including for the Interest sacrifice, if made), on the borrowal accounts,
is sought to be reversed contrary to RBI’s master circular.
Please confirm whether Advances comprising Funded Interest, if already
recognized as income, is fully provided for and not reckoned as income till
realization/ redemption of securities. This would also apply to funded interest where
the same is converted into securities (equity, debentures or other instruments), if
held at the branch.
i) Please confirm:
i. In case of one time settlement proposals under consideration or where rehabilitation/
rephasement is being done, whether the amount of sacrifice including anticipated
sacrifice is provided fully.
ii. Particulars of accounts where the borrowers have defaulted in their commitments after
sanction of the compromise proposal, indicating classification of the accounts.
iii. Whether the Bank has a recovery policy in cases of compromise/ settlement/write off
and is the policy available at the Branch.
iv. Particulars of cases of compromise/settlement/write off involving write off/
waiver, each in excess of Rs. 25 lakhs, on which information may please be
furnished.
v. The name and amount outstanding in the case of the non-corporate borrowers, each
having working capital limits beyond the limit, set by the Bank (which limit may also be
confirmed to us); as also those subject to compulsory audit under any statute, whether
the latest audited accounts are on record; and if received, whether these statements are
reviewed including as to matters having a bearing on the facilities provided by the
Branch, and whether found to be adequate. Please confirm whether the authentication of
these has been checked through UDIN.
vi. Compliance by the Branch of the RBI Master Circular No.
DBOD.No.Dir.BC.10/13.03.00/2016-17 dated 1-7-2015, relating to statutory and other
restrictions as regards Loans and Advances. In particular it may be confirmed as to
whether, at the Branch:
- there are any loans and advances against security of the Bank’s own shares.
- there is any laid down procedure as regards identification of directors/ officers and
their relatives and of directors of other banks for purposes of sanction of loans to them
or to concerns in which directors are interested, as per the said circular.
- loans have been given to companies for buy back of their shares/securities.
vii. Compliance by the Branch of the RBI Circular No. DOR.No.BP.BC.26/21.04.048/
2020-21 dated 26.10.2020 in respect of crediting the difference between compound
interest and simple interest for six months from (01.03.2020 to 31.08.2020) in the
eligible borrowers’ accounts as per scheme for grant of ex-gratia payment. The
amount for the branch, if it was of an erstwhile bank, having merged with the
Bank, may be made known.

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j) Advances to share brokers/NBFCs:
Please confirm whether at the Branch, there are advances to:
- share brokers; if so, the total amount of limits granted and the aggregate advance due as
at the year-end.
- NBFCs; if so please confirm whether the RBI has taken any adverse view as
regards their registration or otherwise. The status on advances to NBFCs may please be
made known, along with their classification.
k) Advances to Staff -Please confirm:
- the procedure with regard to Advances to Staff (interest/non-interest bearing), by the
Bank, both in its capacity as a banker and as an employer; also whether such interest-
bearing advances are being disclosed as Advances.
- the verification procedures followed in respect of Staff Housing Loans, and in particular,
whether the original documents are held at the Branch and can be produced for our
examination.
- If there are any cases in default of collection of the principal/interest, where due and
recoverable
l) Please let us know whether there are any borrower accounts comprising MSME accounts as
also large borrower accounts as stipulated respectively in Circular No. FIDD.MSME &
NFS.12/06.02.31/2017-18 dated 24-7-2017 and DBR.No.BP.BC.101/21.04.048/2017-18
dated 12.2.2018 of the RBI with regard to which you have applied appropriately the IRAC
Norms. Please confirm whether this is in accordance with the Board approved Policies.
Special attention may be paid to large restructured accounts requiring reporting as to their
credit information and classification (SMA-0, SMA-1, SMA-2) ; and further accounts that
require reconsideration as to the IRAC norms, if covered by RBI
DBR.No.BP.BC.101/21.04.048/2017-18 dated 12.2.2018 circular. PIB Delhi, Union Ministry
of Micro, Small and Medium Enterprises (M/o MSMEs) has issued Gazette notification to
pave way for implementation of the upward revision in the definition and criteria of MSMEs in
the country. The new definition is effective from 1st July, 2020 (based on the criteria of
Investment in plant and machinery as also the levels of turnover), with existing
registrations being valid till 31-03-2021.
m) Sanctioned working capital limits of Rs. 150 crores or more:
Please confirm whether, and to the extant of which, compliance was required at your
branch for bifurcation of working capital limits into the loan component and cash
credit, effective 01.04.2019 (and revised with effect from 01.07.2019), in accordance
with the policy of the Bank, as revised in terms of RBI Circular No.
DBR.BP.BC.No.12/21.04.048/2018-19 dated 05.12.2018 (Guidelines on Loan System for
Delivery of Bank Credit)

n) Credit Cards :
Please confirm the system followed at the Bank/Branch for recovery of credit card dues; and
whether, and the extent to which, there are debit outstandings on account of Credit card
dues, and that these have been treated as Advances, and not ‘Other assets’

o) If there are any Advances sanctioned / disbursed for buy-back of Shares/Securities to any
Companies, the total amount of facilities granted and aggregate advances due at the year
end, alongwith their classification may be made known. Refer Para 5(c) (iii) of Part I of the
LFAR questionnaire.

p) Please confirm whether the branch has on its record, a due diligence report (from a
Chartered Accountant, Company Secretary, Cost Accountant), in the form and manner as
required, in respect of advances under consortium and multiple banking arrangements. A list
of such borrowers in whose case the due diligence report is not obtained/ on record, may be
made available to us. Refer Para 5(e) (v) of Part I of the LFAR questionnaire.

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q) Please confirm whether the branch has any red-flagged accounts, where any deviations
have been made in compliance of the Bank’s Policy. A list of such accounts may be made
available to us. Refer Para 5(e) (viii) of Part I of the LFAR questionnaire.

r) List of accounts and amounts involved, where the Branch has yet to take action on
advances, where legal action for recovery has been authorised by the relevant controlling
authority of the bank. Refer Para 5(f) (iv) of Part I of the LFAR questionnaire.

s) Whether there are any accounts wherein process under IBC is mandated; if yes, list of such
accounts may be made available to us alongwith the accounts against whom the process of
IBC is initiated by any creditors, including banks. Refer Para 5(f) (v) of Part I of the LFAR
questionnaire.

t) Whether there are any accounts against whom decrees have obtained but not executed;
also provide age-wise analysis of decrees obtained and pending execution in the Format
recommended as per Para 5(f) (ix) of Part I of the LFAR questionnaire..

u) Devolved Letters of Credit(LCs)/ co-acceptances, and guarantees:

Please confirm:
- the precise procedure followed for accounting treatment of devolved
obligations (guarantees/LCs); and whether the debits have been raised in separate
distinct accounts of the borrowers or to the normal cash credit/overdraft accounts
of the borrowers; and whether these are aggregated for determination of the
classification of the borrower/account
- whether, and the extent to which, there are any devolved LCs up to the year-end,
which are pending payment.
For Information on guarantees invoked, and outstanding LCs/ co-
acceptances. Refer format in Para 5(g) of Part I of the LFAR questionnaire.

v) Issue arising from the Interim order dated 03/09/2020 of the Hon’ble Supreme Court:
Please let us know whether the bank has taken any view with regard to the compliance
of the interim order dated 03/09/2020 of the Hon’ble Supreme Court as regards non-
declaration of advances as NPAs to the extent covered by the said order, and the
corresponding effect thereof as to classification, consequential provisioning and
income recognition upto the year end. Please also confirm whether there would be a
change of accounting policy in this regard as having effect on the branch financials. If
any instructions have been issued on this issue the same may be made known to us.

8. Outstandings in Suspense/Sundries:
Please let us have a summary of the year-wise break up of amounts:
- debited to Suspense Account (or similar account) indicating, as at the year end, the number
of entries and the amount thereof, with reasons for non-adjustment of old/large/ unusual
entries.
The amount of provision for doubtful amounts may be confirmed.
- credited to Sundries / Sundry Deposit Accounts, indicating the reasons for non- adjustment of
items included therein, particularly in respect of items which are over 90 days.
(Information may please be provided in the formats as per para 6(a) of Part I of the
LFAR questionnaire).

- Please confirm the amount at debit on account of TDS paid and outstanding, not linked
to any customer.

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9. Provisions/Liabilities remaining unadjusted against corresponding advances:
Please confirm whether provisions for known liabilities, up to the year end have been made
(also, based on subsequent entries made); and if, and the extent to which, any provisions
are required towards advances of expenditure nature (e.g. Travel Advance).

10. Inter-branch/Office Accounts/Head Office Account:

a) Please let us have a statement of entries (head-wise) which originated prior to the year-
end at other branches, but were responded after the year-end at the Branch, up to the cut
off date, if given by Head Office; otherwise, up to the date of the audit. (Refer Format at
Annexure V).
b) Date-wise details of debits in various nominal or other sub-heads relating to Inter-branch
transactions, with reasons, particularly for old/ large outstanding amounts, including those
which are pending for over 7 days as at the Balance Sheet date.
c) Please confirm:
- whether there are any temporary debits pertaining to any advance /borrower’s account
wrongly recorded in Inter branch /Head Office account , that have been reversed after the
year end.
- whether the Branch has effectively complied with the centralised Reconciliation Cell, all
their queries in relation to unmatched entries.
Communications pending action, and having effect on the accounts for the year,
may be made available for our review.
- the number of old unadjusted entries and the aggregate amount as at the year-end
comprising unlinked debits retained at the Branch, in respect of Drafts and TTs, MTs paid,
which remain outstanding at the Branch; and whether, and the extent to which,
provision is being considered for the same.
- the period up to which the Reconciliation Cell has sent the statements of unmatched
entries (head-wise).
11. Foreign Currency outstanding transactions:
If the Branch is carrying balances (including in off-balance sheet items) in foreign currencies
as at the year-end, whether, and the basis on which, these have been converted as at the
year-end, may be made known. Evidence/basis of the rates as applied may be made
available.
12. Contingent Liabilities etc.:
Please confirm whether:
- there are any demands/claims (whether statutory, regulatory, contractual or otherwise) on
account of litigation, arbitration or other disputes having financial implications, including
claims from customers, fraud cases, for staff claims, municipal taxes, local levies
etc. The nature and extent of such contingent liabilities, if not considered in the
Branch financial statements, may be communicated.
(Reference may also be made to the LFAR - Para II.3).
- guarantees are being disclosed in the Branch Balance Sheet, net of cash margins and
term deposits; and whether, and the extent to which, expired letters of credit, and
guarantees where the claim period has also expired, and obligations have
ceased, these continue to be disclosed in the Branch returns.
The amount of such expired obligations may be made known.
- other obligations assumed, e.g., Letters of comfort have been disclosed in the Branch
returns; and that, based on the related documentation, these do not comprise
funded liabilities by or on behalf of the bank (by way of Buyers’ Credit etc.)
- there are any outstanding contracts on capital account (including for fixed assets to be
acquired/ constructed). Details thereof may be given.
- there are any awards in arbitration/litigation or disputes involving any liability (including
based on any awards by the Banking Ombudsman).

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13. Interest Income/Expenditure:
a) Please let us have a statement showing the rates of interest applicable during the year on
various categories of
- Advances Accounts
- Deposits Accounts
giving reference of the relevant circulars of the Head Office, and indicating the
effective dates and periodicity of application of the interest rates; and evidencing that the
computer programme was modified from such effective date(s), for any changes during
the year.
b) Please confirm whether the rates and changes therein for advances, are based on
the appropriate Credit rating, as and where applicable and reflected in the
accounts/ documentation.
c) Please confirm whether interest being debited at the end of each month on advances, is
being compounded for levy of further interest on a monthly basis. Where interest on
advances is being computed and debited by the system up to a date prior to the month-
end, whether the Branch has computed the same for the residue period for the month of
March 2021.
d) System of appropriation of recoveries in NPAs:
Please confirm the basis on which the Bank exercises the right of appropriation of
recoveries in NPA Accounts, where there are no instructions by the borrowers; and
in such cases, whether the appropriation is made by giving priority to “principal” rather
than to unrealized charges, and interest.
Please confirm whether there are upgraded restructured/rehabilitated advances
accounts, where the “right of recompense” of sacrifice borne by the Bank was a
precondition, but the same was not exercised at the time of upgradation of the
borrower.
If so, details thereof may please be given to us.
e) As regards advances (including bills), whether any income has been adjusted
/recorded to revenue, contrary to the norms of income recognition issued by the
Reserve Bank of India and/or Head Office circulars issued in this regard; and
particularly, in Non Performing Accounts (including overdue bills) , if the same has been
recorded except on actual realisation from the borrowers, and not out of fresh
limits sanctioned by the Bank.

f) Interest income, if recognized on certain advances:

Please confirm whether and the extent to which, you have recognized any interest as
income on the following types of advances:
 On Central Govt. guaranteed advances, if NPA, but for reasons that the guarantee is
not invoked or repudiated requiring the account to be treated as and retained in,
Standard category.
 In cases of restructured accounts, where the income recognized earlier, was, to the
extent unrealized and converted to FITL and fully provided for, is reversed or treated
as standard for further accretion of income.
 in case documents under LC are not accepted on presentation or payment under the
LC is not made on the due date by the LC issuing bank for any reason and the
borrower does not immediately make good the amount disbursed as a result of
discounting of concerned bills, whether the outstanding bills discounted continue to be
classified as Standard and treated as ‘performing’.
 in respect of accounts identified as NPAs during the year, amounts contractually due
but remaining unrealized as interest, fees, commission and other charges are
reversed for all earlier periods; and the unapplied interest has been computed and
recorded upto date.
Amount of income accrued, if any, as at 31.3.2021 on NPAs may be made known.

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g) Please confirm whether interest adjustments on inter branch balances (as per the
Transfer Price Mechanism) as communicated by Head Office, have been duly recorded in
the Profit & Loss Account of the Branch.
Relevant evidence thereof may please be made available to us.
h) If there are significant debits in interest income Account, the justification thereof.
i) Please let us know whether there are any borrower accounts to whom interest subvention
is given / to be given and provide scheme-wise/ borrower-wise list of eligible borrowers;
also let us know the accounting entries passed by the Branch in respect interest
subvention.

14. Commission on Govt. business

Please confirm whether at the Branch, income has been accrued up to 31.3.2021. Income
upto the year end not claimed/ recorded/ received may please be confirmed to us, together
with basis/computation thereof.

15. Interest Provision on Deposits:

Please confirm whether interest provision has been made upto the year end, on Term
and Savings Bank account deposits, on eligible Current Accounts and unclaimed/unpaid
deposit accounts of deceased depositors, in accordance with the applicable contractual
rates and latest instructions of the Head Office; and the amount as at 31.03.2021 may be
confirmed in respect of the following:
 interest accrued till the date of maturity on FCNR(B) deposits, if included in Deposits.
 Interest accrued but not applied on Savings bank deposits, if treated as part of “Other
Liabilities – Interest Accrued”
Correspondingly, if considered as due, whether Tax deduction at source has been
made and deposited within the prescribed time with the Govt.

16. Employee/Staff Payments and benefits

Please confirm that all payments and staff benefits due to the Branch employees upto the
year end, have been duly computed and recorded under the respective sub heads, including
incremental liability towards arrears, if any.

17. Rent, Rates and Taxes

Please confirm that the rent (payable as tenant, and not as allowance/reimbursement to staff
towards their rent obligations), rates and taxes, are recorded up to the year end, based on:
- rent/lease agreements for the time being in force and liability being reckoned on the
basis of claims/demands and contractual enhancements due;
- municipal taxes and levies up to the year-end, based on the demands accepted; and
- in case of disputed liabilities, if any, the related contingent liability has been disclosed.
18. Penalties/fines etc:
Please confirm whether any fines or penalties have been imposed on the Branch, or
incurred or paid by the Branch during the year as arising out of any defaults to meet
statutory or regulatory requirements or otherwise. If so, the particulars thereof may be made
known; as these would require separate disclosure in the financial statements of the Bank
and for consideration in the Tax Audit Report under Section 44 AB of the Income tax Act
1961.
19. Frauds etc.:
Please confirm whether for the purpose of provisioning, the relevant particulars
have been prepared at the Branch and whether :
- there are any frauds reported/recorded up to 31.3.2021;
- there are any known cases or transactions or events, or any enquiries that have been
initiated for any suspected frauds/aberrations.

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- there are any cases of vigilance or similar enquiry, or financial claims/potential claims
that may arise, from customers/others in respect of the Branch. The relevant
information with regard to these may please be made available.
- the Branch has complied with the reporting requirements of RBI and communicated the
same as per the requisite formats, including where central investigating agencies have
initiated criminal proceedings or where the RBI had directed that a matter be treated as
fraud.
20. Recommendations of the Mitra Committee – Bank Frauds
While drawing your attention to the contents of the SA 240 -The Auditor’s Responsibility to
Consider Fraud and Error in an Audit of Financial Statements, issued by the Institute of
Chartered Accountants of India, particularly in that the responsibility for the prevention and
detection of fraud and error rests with the management through the implementation and
continued operation of an adequate system of internal control, we would request you to
confirm whether, in relation to the operations/activities of the Branch, anything has come to
light which is in the nature of a fraud, any fraudulent activity, or any matter susceptible to
fraud or foul play, which should receive our attention; and particularly, if there is anything
which invokes, or is the subject matter of any vigilance, enquiry, investigation or
examination as regards any transaction or event that is suggestive of attracting compliance
or for reporting to the competent authorities within the Bank, or to the regulatory authorities.
This would include matters that could arise out of inadequacies in, or absence/breach
of the laid down, internal control systems and procedures (both accounting and
administrative).
Your attention is drawn to the RBI relevant Master Circulars Nos.
DBR.No.BP.BC.92/21.04.048/2015-16 April 18, 2016 ,
DBS.CO.CFMC.BC.No.1/23.04.001/2016-17 dated July 01, 2016, relating to Frauds –
Classification and Reporting; as also Para 4.2.9(ii) of the RBI Master Circular dated 1-
7-2015 covering prudential norms applicable to Advances.

21.Compliance of Ghosh and Jilani Committee recommendations

Please confirm whether the Branch has duly complied with the requirements of the Ghosh
and Jilani Committees and whether such compliance has been got verified from the Bank’s
Inspection Division and/or the Concurrent Auditors.
It may be confirmed as to whether there are any adverse observations in respect of any
requirements that may also have bearing on the financial statements of the Branch; and if so,
these may please be made known to us.

22.Consideration of laws and regulations for the purpose of the audit of financial
statements:
Please confirm as to whether the Branch is maintaining a codified list of the related laws and
regulations applicable to the Bank/Branch in respect of its operations/activities to cover all
transactions and events, with which it is concerned; and whether the Branch management
has come across, or is aware of anything that needs to be brought to our notice for our
consideration or anything suggesting that there is fundamental effect on the state of affairs or
operations of the Branch on account of non-compliance of these.

23. Transactions and events after the Balance sheet date

Please let us have a statement of any significant transactions or events occurring after the
Balance sheet date but which relate to the period prior to 31-3-2021, whether or not yet
recognized or recorded in the accounts of the Branch. This would include items of
income or expense or capitalization etc. relating to the period prior to the year end.
(particularly also, if these are reported in the inspection/internal/concurrent audit reports
relating up to March 2021), which need to be incorporated in the MOC.

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24. Implementation of KYC/AML guidelines:

Please confirm that the branch has adequate systems and processes to ensure adherence
to KYC/ALM guidelines towards prevention of money laundering and terror financing and
also confirm that the branch has fully complied with those guidelines. Refer Para 5 of Part
IV of the LFAR questionnaire.

25.Asset Liability Management:

Please let us have, duly authenticated, the financial information regarding the disclosures to
be made as at 31.3.2021, as required by the Reserve Bank of India, indicating the
procedure/basis followed to arrive at the financial data.
Instructions from the Controlling Authority, in this behalf, may be made known.

26. Other Certification

Please let us have, duly authenticated, information as regards other matters
which, as per the letter of appointment, require certification/validation.
The certificates relate to the following (besides the data as per the letter of appointment to us):
a) DICGC
b) PMRY
c) 12 odd dates data for verification of SLR (Refer Annexure A VI)
d) Implementation of the Ghosh and Jilani Committee recommendations
e) Movement Chart of NPAs and Provision of NPAs (Refer Annexure A II)
f) Others (as communicated to you by Head Office)

27.Long Form Audit Report-Branch response to the Questionnaire:

In connection with the Long Form Audit Report, please let us have complete
information, and evidence, as regards each item in the questionnaire, to enable us to
verify the same for the purpose of our audit.

28.Tax Audit in terms of section 44AB of the Income-Tax Act,1961 (if applicable):
In case the assignment covers our appointment as Tax Auditors, we would request that you
may provide us, duly reviewed and authenticated, information required in terms of section
44AB of the Income tax Act, 1961, and the related records to enable us to verify the same for
the purpose of our report thereon.

Information that may be relevant / useful on the affairs of the Branch, arising from the
transactions / balances, while it was a branch of an erstwhile bank which was merged
(effective 1.4.2020) with the Bank, may be provided, to enable certain analytical
procedures usually adopted in audit. This is particularly relevant to the determination of
the monetary/non-monetary defaults to identify NPAs and compliance of conditions of
restructuring etc.

Information duly completed and authenticated in respect of Paras 1 to 28 should be

made available simultaneously with the returns / statements / schedules, to be given by
the Branch on 1.4.2021.

We may seek further information on matters as these arise in the course of the audit,
including on verification of information/representations made by you and would request
you to respond to the same expeditiously, considering the severe time constraints within
which the assignment needs to be completed and the reports furnished.

CHARTERED ACCOUNTANTS

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