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Ann. 2.1 – Policy of Empanelment of CA Firms/LLPs and Selection of Auditors


          4.   Number of SCAs / SAs and Branch Coverage              20 branches (to be selected strictly in order of the level
                                                                     of outstanding advances) to SCAs in such a manner as
          4.1   For Entities with asset size of ₹15,000 crore and above   to cover a minimum of 15% of total gross advances of
               as at the end of previous year, the statutory audit should   the bank by SCAs. For other Entities (excluding Payment
               be conducted under joint audit of a minimum of two audit   Banks  and  Core  Investment  Companies),  SCAs/SAs
               firms  [Partnership  firms/Limited  Liability  Partnerships   shall  visit  and  audit  at  least  the Top  20  branches/Top
               (LLPs)]. All other Entities should appoint a minimum of   20% of the branches of the Entities (in case of Entities
               one  audit  firm  (Partnership  firm/LLPs)  for  conducting   having less than 100 branches), to be selected in order
               statutory audit. It shall be ensured that joint auditors of   of the level of outstanding advances, in such a manner
               the Entity do not have any common partners and they   as to cover a minimum of 15% of total gross advances
               are not under the same network  of audit firms. Further,   of the Entities. In addition, the banking companies and
                                         3
               the Entity may finalise the work allocation among SCAs/  NBFCs  shall  ensure  adherence  to  the  provisions  of
               SAs, before the commencement of the statutory audit,   Section 143 (8) of the Companies Act, 2013 regarding
               in consultation with their SCAs/SAs.
                                                                     audit of accounts of all branches.
          4.2   The  Entities  should  decide  on  the  number  of  SCAs/
               SAs based on a Board/Local Management Committee   5.   Eligibility Criteria of Auditors
               (LMC) Approved  Policy,  inter  alia,  taking  into  account      Each  Entity  is  required  to  appoint  audit  firm(s)  as  its
               the  relevant  factors  such  as  the  size  and  spread  of   SCA(s)/SA(s) fulfilling the eligibility norms as prescribed
               assets, accounting and administrative units, complexity   in Annex I.
               of transactions, level of computerization, availability of
               other independent audit inputs, identified risks in financial
               reporting, etc.                                 6.    Independence of Auditors
                                                                                                                 4
                                                               6.1   For Commercial Banks (excluding RRBs) and NBFCs ,
               Considering  the  above  factors  and  the  requirements   the Audit  Committee  of  the  Board  (ACB)/  LMC  shall
               of  the  Entity,  the  actual  number  of  SCAs/SAs  to  be   monitor  and  assess  the  independence  of  the  auditors
               appointed  shall  be  decided  by  the  respective  Boards/  and  conflict  of  interest  position  in  terms  of  relevant
               LMC, subject to the following limits:
                                                                     regulatory  provisions,  standards  and  best  practices.
                 Sl.    Asset Size of the Entity   Maximum           Any  concerns  in  this  regard  may  be  flagged  by  the
                No.                               number of          ACB/LMC to the Board of Directors of the Commercial
                                                  SCAs/SAs           Bank  (excluding  RRBs)/NBFC  and  concerned  Senior
                                                                     Supervisory  Manager  (SSM)/Regional  Office  (RO)  of
                1.   Upto ₹5,00,000 crore         4                  RBI.
                2.   Above ₹ 5,00,000 crore and Upto  6
                     ₹ 10,00,000 crore                               For UCBs/remaining NBFCs, the Board of Directors shall
                3.   Above  ₹  10,00,000  crore  and  8              monitor and assess the independence of the auditors.
                     Upto ₹ 20,00,000 crore                          Any  concerns  in  this  regard  may  be  flagged  by  the
                4.   Above ₹ 20,00,000 crore      12                 Board of the UCB/NBFC to the concerned SSM/RO of
                                                                     RBI.
               The above  limits have been prescribed  to ensure  that   6.2   In  case  of  any  concern  with  the  Management  of  the
               the number of SCAs/SAs appointed by the Entities are   Entities  such  as  non-availability  of  information/non-
               adequate, commensurate with the asset size and extent   cooperation  by  the  Management,  which  may  hamper
               of operations of the Entities, with a view to ensure that   the  audit  process,  the  SCAs/SAs  shall  approach  the
               audits are conducted in a timely and effective manner.   Board /ACB/LMC  of  the Entity, under  intimation  to  the
                                                                          5
               This  will  be  subject  to  review  in  future  based  on  the   concerned SSM/RO of RBI.
               experience.
                                                               6.3   Concurrent  auditors  of  the  Entity  should  not  be
          4.3   In  terms  of  RBI  guidelines  on  ‘Norms  on  eligibility,   considered for appointment as SCAs/SAs of the same
               empanelment and selection of Statutory Branch Auditors   Entity. The audit of the Entity and any entity with large
               in Public Sector Banks (PSBs)’, PSBs shall allot the Top
                                                                     exposure   to  the  Entity  for  the  same  reference  year
                                                                             6
          3    As defined in Rule 6(3) of the Companies (Audit & Auditors) Rules, 2014
          4    For the NBFCs which are required to constitute an Audit Committee of the Board (ACB) in terms of Para 70 (1) of Master Direction - Non-
              Banking Financial Company - Systemically Important Non-Deposit taking Company and Deposit taking Company (Reserve Bank) Directions,
              2016 to be read with Section 177 of the Companies Act, 2013.
          5    Board shall be directly approached only when ACB is non-existent in the Entity or the auditors notice a matter of concern involving any
              member of the ACB.
          6    As defined in RBI instructions on ‘Large Exposures Framework’


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