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The document outlines a comprehensive audit program aimed at detecting revenue leakage in bank branches operating on the Finacle CBS platform. It focuses on critical income streams such as interest income, processing fees, penal charges, commitment charges, and service-related fees. The audit procedures emphasize verifying correct rate of interest application, timely MCLR/EBLR resets, penal interest recovery, and proper treatment of NPA-related income. It also addresses fee-based income like processing fees, renewal charges, inspection charges, and documentation charges, ensuring these are not waived without proper authorization. The program highlights risks arising from CBS glitches, manual overrides, and parameterization errors that may lead to systematic revenue loss. Additionally, it ensures compliance with RBI guidelines, service charge circulars, and sanction terms, while promoting strong internal controls, accurate GL reconciliation, and proper reporting through audit mechanisms such as LFAR and MOC.

Further, the audit framework covers operational and compliance areas including locker rent recovery, SMS/ATM charges, minimum balance penalties, and monitoring of BC/DD outstanding balances. It emphasizes scrutiny of suspense and sundry accounts to detect misappropriation or income suppression. Specialized checks are prescribed for forex and trade finance income streams such as LC/BG commissions and remittance charges. The program also identifies IT-related risks, including duplicate CIFs, incorrect CBS parameter settings, override misuse, and migration errors, which can cause large-scale revenue leakage. A dedicated section ensures GST compliance on all taxable banking services, preventing both revenue loss and regulatory violations. The audit concludes with a structured reporting format for quantifying leakage, assigning risk priorities, and recommending corrective actions. Overall, it serves as a detailed, systematic tool for auditors to identify gaps, strengthen controls, and ensure accurate revenue recognition in banking operations.

REVENUE LEAKAGE AUDIT PROGRAM | Punjab & Sind Bank — CBS (Finacle) Environment

Audit Type Concurrent / Statutory Branch Audit
Bank Punjab & Sind Bank (PSB)
CBS Platform Finacle (Infosys)
Branch / Period ______________ / FY 2025-26
Document Ref AAJ/PSB/RLA/2025-26

CONFIDENTIAL — FOR AUDIT TEAM USE ONLY

LEGEND / KEY

Column Description Column Description
S.No. Serial Number WPR No. Working Paper Reference Number
Area Area / Head of Revenue Leakage Done? Checkbox — tick when step completed
Procedure Detailed audit step / procedure to be performed CBS Menu Finacle menu command / reference

SCOPE & OBJECTIVES

This Audit Program is designed to assist in identifying Revenue Leakage during Concurrent / Statutory Branch Audit of Punjab & Sind Bank branches operating on Finacle CBS platform. The program covers all major heads of revenue — interest income, fee-based income, penal charges, and service charges.

Objectives

  • Identify gaps in interest income charging — wrong ROI, missed penal interest, NPA-related suspense issues
  • Verify that all applicable fee-based charges are correctly debited in CBS and not waived without approval
  • Detect parameterization errors and manual override patterns in Finacle that cause systematic revenue leakage
  • Ensure compliance with PSB service charge circulars, RBI guidelines, and sanction letter terms
  • Strengthen internal controls and escalate findings via MOC / LFAR / Audit Report

SECTION 1: INTEREST INCOME LEAKAGE

Interest income is the primary revenue source for PSB. Leakage occurs due to wrong ROI mapping, missed penal interest, MCLR/EBLR non-reset, and NPA-related interest not flowing to suspense correctly.

1A — ROI / MCLR / EBLR Verification
S.No. Area Audit Procedure CBS Menu Done? WPR No. Remarks /Finding
1.1 ROI Correctness Obtain list of all live advance accounts from Finacle (ACLI/LNACLI). Cross-verify Rate of Interest (ROI) loaded in CBS against respective Sanction Letters. Check for MCLR +Spread correctness as per latest PSB circular. ACLI / LNACLI WPR-1.1
1.2 MCLR/EBLR Reset For floating rate accounts, verify that MCLR/EBLR reset has been done on due date (reset anniversary). Check if old (lower) rate continues beyond reset date — common revenue leakage point. Use PRCM menu to check rate change history. PRCM WPR-1.2
1.3 Spread Waiver Check if any spread waivers have been granted at branch level. Obtain list of accounts with concessional ROI. Verify sanctioned authority for spread waiver — unauthorised waivers to be highlighted. ACLHM WPR-1.3
1.4 Interest Calculation Basis Verify that interest is calculated on daily product basis as per PSB norms. For term loans, check that moratorium periods are correctly configured and interest is correctly charged post moratorium. ACLI WPR-1.4
1.5 Restructured A/c ROI For restructured accounts, verify that ROI post-restructuring is as per OTS/approved restructuring scheme. Check that concessions granted are within sanctioned limits. ACLHM / LNACLI WPR-1.5

1B — Penal Interest Leakage
S.No. Area Audit Procedure CBS Menu Done? WPR No. Remarks / Finding
1.6 Penal Interest — Overdues Verify that penal interest is charged on overdue instalments of term loans as per sanction letter and PSB circular. Generate list of term loan accounts with overdue instalments using IPCM/PENALM menu. Cross-check GL credit entry for penal interest income. IPCM / PENALM WPR-1.6
1.7 Penal Int. — NPA Reversal For accounts slipping to NPA and subsequently upgraded, verify that penal interest was correctly charged during the NPA period and on regularization. Check NPAENQ to confirm NPA dates and ACLI for interest entries. NPAENQ / ACLI WPR-1.7
1.8 Interest Suspense — NPA A/cs For NPA accounts, verify that interest debited is parked in Interest Suspense Account (INTSUS) and not credited to P&L. Conversely, ensure that no income is recognised prematurely. Reconcile INTSUS GL balance with individual account records. INTSUS / ACLI WPR-1.8
1.9 Penal — Review Non-Renewal As per RBI MC RBI/2013-14/62: accounts not reviewed/renewed within 180 days to be treated as NPA. Generate ACDREV report. Verify whether penal/additional interest is charged on accounts pending renewal beyond 90 days as per PSB policy. ACDREV WPR-1.9

SECTION 2: PROCESSING FEE & UPFRONT CHARGES

Processing fee, upfront fee, and facility charges are one-time income at the time of sanction. CBS glitches, manual interventions, and missing configurations frequently cause non-recovery of these charges.

2A — Processing Fee Audit
S.No. Area Audit Procedure CBS Menu Done? WPR No. Remarks / Finding
2.1 Processing Fee — Fresh Sanctions Generate list of all loans sanctioned during the audit period from Finacle. For each sanction, verify that processing fee as per sanction letter has been debited to the borrower’s account. Cross-verify with GL — Income: Processing Fee A/c. LNACLI / GL WPR-2.1
2.2 Processing Fee — CBS Auto-Debit Although PSB CBS auto-debits processing fee, verify for technical glitch scenarios — check if any account shows sanction without corresponding processing fee debit. This is a high-risk area especially for manually sanctioned/migrated accounts. LNACLI WPR-2.2
2.3 Processing Fee — Waivers Obtain list of accounts where processing fee is waived/partially waived. Verify sanctioned authority for each waiver. Ensure waivers are within delegated power matrix of PSB. Report any waivers granted without proper authority. LNACLI / Sanction File WPR-2.3
2.4 Renewal/ Enhancement Fee Verify that at the time of limit enhancement or renewal, applicable processing/renewal fee has been charged as per PSB’s current service charge circular. Check if CBS correctly recalculated fee on enhanced limit. LNACLI / ACLHM WPR-2.4
2.5 Upfront/ Facility Fee For large corporate / NBFC accounts with fund-based + non-fund-based limits > Rs.1 Cr: Verify facility fee charged as per NBG circular. This is applicable on FB+NFB limits (excluding TL). Check if facility fee was charged at time of sanction. LNACLI / NBG Circular WPR-2.5

SECTION 3: COMMITMENT CHARGES

Commitment charges are levied when borrower underutilizes the sanctioned CC/OD limit (typically below 50% threshold). PSB CBS does not auto-calculate these in most cases — making manual verification critical.

3A — Commitment / Non-Utilization Charges
S.No. Area Audit Procedure CBS Menu Done? WPR No. Remarks / Finding
3.1 Identification of Eligible A/cs Generate list of all CC/OD accounts with sanctioned limit > Rs.1 Crore. From Finacle CLRPT/ODLRPT, extract quarterly average utilization percentage for the audit period. Flag all accounts where average utilization < threshold (per PSB circular, typically 60-70% of limit). CLRPT / ODLRPT WPR-3.1
3.2 Commitment Charges Debited? For accounts identified in 3.1, verify from ACLI that commitment charges have been debited quarterly as per applicable rate. Cross-verify GL — Income: Commitment Charges A/c. Compute expected charges and compare with actual. ACLI / GL WPR-3.2
3.3 Calculation Accuracy Verify the computation of commitment charges: (Unutilized Limit – Free Threshold) x Rate x Days/365. Check if PSB’s rate and threshold are correctly applied. Recalculate for a sample of 5-10 accounts. ACLI / PSB Circular WPR-3.3
3.4 Waiver of Commit. Charges Check for accounts where commitment charges have been waived. Verify sanctioning authority for such waivers. Report waivers granted beyond delegated power as revenue leakage and revenue sacrifice. ACLI / Branch Records WPR-3.4

SECTION 4: RENEWAL / REVIEW CHARGES

CC/OD/Term Loan accounts are required to be reviewed/renewed every year. Failure to recover applicable renewal charges from borrowers is a recurring source of income leakage.

4A — Renewal & Review Charge Verification
S.No. Area Audit Procedure CBS Menu Done? WPR No. Remarks / Finding
4.1 Accounts Due for Renewal Run ACDREV in Finacle as on audit date. Generate list of all accounts pending renewal. Identify accounts overdue by 0-90 days, 91-180 days, and >180 days. For RBI compliance: >180 days overdue = NPA risk. ACDREV WPR-4.1
4.2 Renewal Charges Debited For all renewed accounts during audit period, verify that renewal charges (as per PSB service charge circular applicable at time of renewal) have been debited to borrower’s account. Select sample of 10-15 renewals and trace from ACLI. ACLI / LNACLI WPR-4.2
4.3 Calculation of Renewal Charges Verify that renewal charges are computed on correct base — FB limit or FB+NFB limit as per applicable circular. Check if GST on renewal charges is separately charged and deposited. Reconcile with GST output records. ACLI / GST Records WPR-4.3
4.4 Waiver / Deferral of Renewal Check accounts where renewal is due but renewal charges not debited (pending renewal beyond 3 months). These represent deferred/waived income. Obtain explanation from branch and verify if within power. ACDREV / Branch Records WPR-4.4

SECTION 5: INSPECTION CHARGES

Inspection charges are levied for physical verification of securities (stock, property, plant). These must be recovered per sanction letter terms — monthly/quarterly/half-yearly/annually based on limit size.

5A — Inspection Charge Audit Steps
S.No. Area Audit Procedure CBS Menu Done? WPR No. Remarks / Finding
5.1 Frequency as per Sanction For each CC/OD account: check sanction letter for prescribed inspection frequency. Verify that number of inspections conducted during audit period matches requirement (Monthly for >Rs.5 Cr, Quarterly for Rs.1-5 Cr, Half-yearly/Annual for others — verify PSB norms). Sanction Letter / Branch Records WPR-5.1
5.2 Inspection Charge Debit For every inspection conducted, verify corresponding inspection charge debit from ACLI. Ensure charges match PSB’s current service charge circular. Sum total inspection charges received vs expected for the period. ACLI WPR-5.2
5.3 Facility Fee vs Inspection In accounts where Facility Fee is charged, verify that Inspection Charges are waived (as per PSB policy — no double charging). Ensure this offset is correctly applied in CBS. ACLI / PSB Circular WPR-5.3
5.4 Pre/Post Sanction Inspection Verify that pre-sanction and post-sanction inspection charges are recovered where applicable. Check if inspection reports are placed in file and charges debited contemporaneously. Sanction File / ACLI WPR-5.4

SECTION 6: DOCUMENTATION CHARGES

Documentation charges are applicable on creation, modification, or release of security documents including registered mortgage, equitable mortgage, hypothecation agreements, and guarantee deeds.

6A — Documentation Charge Steps
S. No. Area Audit Procedure CBS Menu Done? WPR No. Remarks /Finding
6.1 New Sanction — Docume-ntation For all new loans sanctioned during the period: verify that documentation charges as per PSB circular were debited from borrower’s account at the time of execution of security documents. Trace from ACLI — check date proximity to disbursement. ACLI / Sanction File WPR-6.1
6.2 Mortgage — Registered / Equitable For accounts with registered mortgage: verify stamp duty and registration charges are borne by borrower. For equitable mortgage: verify that documentation charges as per slab are recovered. Check ACLI for corresponding debit. ACLI / Mortgage Deed WPR-6.2
6.3 Modific-ation of Documents When any security document is modified (change in limit, extension of hypothecation, addition of guarantor): verify that modification/supplemental documentation charges are recovered. These are frequently missed. ACLI / Branch Records WPR-6.3
6.4 CERSAI / ROC Charge Recovery For loans with SARFAESI-applicable security: verify that CERSAI registration charges and ROC filing charges (where applicable) have been recovered from borrowers and not absorbed by the bank. ACLI / CERSAI Records WPR-6.4

SECTION 7: LOCKER CHARGES & MISC. FEES

Locker charges, if not recovered annually, represent straightforward revenue loss. Additionally, miscellaneous charges like SMS alert fees, ATM charges, and minimum balance penalties need verification.

7A — Locker, SMS & Miscellaneous Charges
S.No. Area Audit Procedure CBS Menu Done? WPR No. Remarks / Finding
7.1 Locker Charges Recovery Obtain physical Locker Register from branch. Cross-verify list of lockers allotted vs. Finacle CBS data. Verify that annual locker rent has been debited from linked account of each locker holder. Check for overdue/unpaid locker rent. Locker Register / ACLI WPR-7.1
7.2 Broken Period / Part-Year Locker For lockers allotted/surrendered mid-year: verify proportionate rent charged. Ensure security deposit forfeiture (if locker surrendered without proper notice) is correctly accounted. Locker Register / ACLI WPR-7.2
7.3 SMS Alert Charges Verify that SMS alert charges are being deducted from all savings/current accounts as per PSB circular. Generate CBS report of accounts enrolled for SMS facility vs. charges recovered. Check for exempted category accounts. ACLI / CBS Report WPR-7.3
7.4 ATM Charges / Interchange Verify that ATM transaction charges (beyond free limit) are correctly debited to customer accounts. Check that interchange income from other bank’s card usage at PSB ATMs is correctly captured in GL. ACLI / GL ATM Income WPR-7.4
7.5 Minimum Balance Charges For non-BSBD savings accounts: verify that minimum balance charges are being levied on accounts with average balance below the prescribed minimum, as per PSB circular. Check exempted categories (Jan Dhan, minors, senior citizens). ACLI / CBS Batch Report WPR-7.5

SECTION 8: BANKER’S CHEQUE / DD OUTSTANDING

Long-outstanding Banker’s Cheques and Demand Drafts must be monitored carefully. Unclaimed amounts must be transferred to designated GL accounts as per RBI guidelines — failure represents liability mismanagement and potential revenue recognition issues.

8A — BC/DD Outstanding Verification
S.No. Area Audit Procedure CBS Menu Done? WPR No. Remarks / Finding
8.1 Generate BC Outstanding Report Run BCREPORT in Finacle: Report To: M, Self: Y, Paid Only: N. Generate list of all BCs issued and outstanding. As per RBI Circular RBI/2013-14/69 dated 01/07/2013: BCs presented after 3 months should not be paid. Flag all BCs outstanding > 90 days. BCREPORT WPR-8.1
8.2 BC Outstanding > 1 Year From BCREPORT, identify BCs outstanding for more than 1 year. These represent liabilities not crystallised. Verify that such amounts are transferred to Stale BC A/c or Unclaimed Liability GL as per PSB policy. Check GL transfer entries. BCREPORT / GL WPR-8.2
8.3 DD Outstanding — Verification Similarly generate DD outstanding report. Cross-verify with GL — Payable DDs A/c. Verify that income from DDs (exchange/ commission) has been correctly credited to P&L. Identify DDs revalidated beyond permissible period. GL DD Payable WPR-8.3
8.4 Transfer to Unclaimed Deposits Verify that BC/DD balances outstanding for 10 years are transferred to RBI under DEAF (Depositor Education Awareness Fund). Obtain last DEAF remittance certificate from branch and verify GL balance vs amount remitted. DEAF Records / GL WPR-8.4

SECTION 9: SUSPENSE & SENSITIVE ACCOUNT MONITORING

Suspense, Sundry, and Sensitive accounts are prime areas for revenue suppression, fictitious credits, and misappropriation. Auditors must ensure all entries are supported, current, and non-recurring.

9A — Suspense & Sundry Account Audit
S.No. Area Audit Procedure CBS Menu Done? WPR No. Remarks / Finding
9.1 Suspense Account — Outstanding Obtain complete list of entries in Suspense Account from GL. Classify entries by age: <30 days, 31-90 days, >90 days, >6 months, >1 year. All entries > 30 days require explanation. Entries > 3 months are high-risk and must be reported. GL Suspense A/c WPR-9.1
9.2 Sundry Deposits / Creditors Verify Sundry Deposits and Sundry Creditors GLs. Identify stale/unexplained credits — these could represent unearned income wrongly parked or misappropriated collections. Each entry must have documentary support. GL Sundry WPR-9.2
9.3 Special Debit / Income GL Review Special Debit Account and miscellaneous income GLs. Ensure no income entries have been reversed without proper authority. Verify that charges recovered from customers are fully credited to income GLs. GL Income A/c WPR-9.3
9.4 Inter-Branch Transac-tions Verify outstanding Inter-Branch entries (IBT) in Branch GL. Unreconciled IBT entries older than 30 days must be investigated. IBT entries used to park income or delay expense booking are a red flag. IBT GL / IBTS Report WPR-9.4
9.5 Pension Payment Account For branches handling pension payments: verify Pension Payment Account balance is Nil at end of each payment cycle. Outstanding balance indicates unrecovered/unremitted pension amounts. GL Pension A/c WPR-9.5

SECTION 10: FOREX / TRADE FINANCE CHARGES

For authorized forex dealing branches of PSB: SWIFT charges, LC commission, Bank Guarantee commission, forward contract charges, and remittance charges require specific verification via IRM/ORM and Trade Finance modules of Finacle.

10A — Forex & Trade Finance Revenue Audit
S.No. Area Audit Procedure CBS Menu Done? WPR No. Remarks / Finding
10.1 SWIFT / Outward Remittance Charges From ORM (Outward Remittance Maintenance) in Finacle: generate list of all outward remittances during audit period. Verify that SWIFT charges, correspondent bank charges, and forex conversion margin are correctly recovered. Cross-verify with GL: Forex Income A/c. ORM / GL Forex WPR-10.1
10.2 Inward Remittance Charges From IRM (Inward Remittance Maintenance): verify inward remittances received. Confirm that handling charges and NOSTRO charges are recovered from beneficiary as per PSB schedule. Check for cases where charges are waived without authority. IRM / GL WPR-10.2
10.3 LC Commission Income For Letter of Credit (LC) transactions: verify that opening commission, amendment commission, acceptance commission, and negotiation commission are correctly charged as per FEDAI/PSB schedule. Trace from Trade Finance module to GL Income. Trade Finance / GL WPR-10.3
10.4 Bank Guarantee Commission For BG issuances: verify commission charged as per BG value and tenor, consistent with PSB circular. Also check that expired/invoked BGs are removed from contingent liability register promptly and commission income recognised correctly. Trade Finance / BG Register WPR-10.4
10.5 Packing Credit — Overdue From Finacle (Packing Credit Overdue report): identify all packing credits disbursed which are overdue. As per RBI, recovery must be initiated. Verify that penal interest on overdue packing credits is charged. Confirm due date as per sanction letter. PC Overdue Report WPR-10.5

SECTION 11: CBS PARAMETERIZATION & IT-RELATED RISKS

CBS parameterization errors cause systematic, large-scale revenue leakage — affecting all accounts in a scheme rather than individual accounts. These are high-value findings with bank-wide implications.

11A — CBS / Finacle IT Risk Verification
S.No. Area Audit Procedure CBS Menu Done? WPR No. Remarks / Finding
11.1 Duplicate CIF / UCIC Issues Check if any customer has multiple CIF/CUST IDs in Finacle (using CUMM/CUMI). Multiple CIFs defeat UCIC purpose and may cause regulatory reporting errors, duplicate concession grants, or missed aggregate exposure limits (CEL/RL limits). CUMM / CUMI WPR-11.1
11.2 Charge Parameters Mismatch Obtain from PSB IT department the current parameterized charge rates in CBS (processing fee, locker fee, service charges). Compare with latest PSB service charge circular. Any mismatch indicates systematic under-collection across all accounts. CBS IT Parameters WPR-11.2
11.3 User Override Log Review Request from branch/IT: CBS transaction override log for the audit period. Review cases where system-generated charges were manually overridden by users. Verify authorisation level for each override. High override frequency = internal control weakness. CBS Audit Trail / IT Dept WPR-11.3
11.4 Migration Data Integrity For accounts migrated from legacy system: verify that all original terms (ROI, limit, security details) are correctly captured in Finacle. Post-migration errors frequently cause interest undercollection or security gaps. Legacy Records / ACLI WPR-11.4
11.5 Auto-Debit Failure Report Request CBS automated charge debit failure report from branch IT. This report lists accounts where system attempted to debit charges but failed (insufficient balance, closed account, frozen A/c). Verify if manual recovery was done subsequently. IT Dept / CBS Report WPR-11.5
11.6 EOD / BOD Process Completeness Verify that End-of-Day and Beginning-of-Day batch processes ran successfully throughout the audit period without failures. Partial EOD failures can result in missed interest accruals and charge debits. Obtain EOD success logs. IT EOD Logs WPR-11.6

SECTION 12: GST ON BANK CHARGES — LEAKAGE VERIFICATION

PSB is registered under GST. Non-charging or under-charging of GST @ 18% on taxable services (processing fee, locker rent, SWIFT charges, commitment charges, LC/BG commission) represents both revenue leakage and GST non-compliance risk.

12A — GST Compliance on Service Charges
S.No. Area Audit Procedure CBS Menu Done? WPR No. Remarks / Finding
12.1 GST on Processing Fee Verify that GST @ 18% is charged on processing fee separately and credited to GST Output Payable GL. Cross-check GST amount with total processing fee income. Ensure GST is not subsumed within the processing fee — must be separately disclosed. ACLI / GST GL WPR-12.1
12.2 GST on LC/BG Commission LC/BG commission is taxable @ 18% GST. Verify that GST is charged over and above the commission amount from the customer. Check if PSB’s Trade Finance module auto-calculates GST or it is manually added. Verify GL entry correctness. Trade Finance / GST GL WPR-12.2
12.3 GST on Locker Rent Locker rent is subject to GST @ 18%. Verify that GST is recovered from locker holders along with annual locker rent. Check GST output GL vs total locker rent income. Report any under-collection of GST. Locker Register / GST GL WPR-12.3
12.4 GST on Other Service Charges Verify GST applicability and collection on: renewal charges, inspection charges, documentation charges, commitment charges, SWIFT charges, and other fee-based income. Reconcile monthly GST GSTR-3B with GL for the audit period. GSTR-3B / GL WPR-12.4

SECTION 13: SUMMARY OF REVENUE LEAKAGE FINDINGS

S.No. Section Area of Leakage Finding / Observation Estimated Amount (Rs.) Priority (H/M/L) Recomm-endation
1
2
3
4
5
6
7
8
9
10
TOTAL ESTIMATED REVENUE LEAKAGE Rs. ______________

SECTION 14: AUDIT TEAM SIGN-OFF

Role Name Signature Date
Engagement Partner CA ABC
Audit Manager
Audit Senior
Audit Assistant

Declaration: We confirm that this audit program has been executed in accordance with the Standards on Auditing issued by ICAI, RBI guidelines, and PSB’s internal policies. All findings have been documented with adequate working paper references.

For M/s XYX, Chartered Accountants

CA ABC | Partner

No.: ______________ | FRN: ______________

Date: ______________ | Place: ______________

****

Prepared by: CA ASHISH JAIN | Partner — M/s ASHISH AKHILESH JAIN, Chartered Accountants

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