financials of banks. the point i am trying to make is that if the rbi inspectors are able to identify these divergences in the limited time - frame that they are on - site, why the banks ’ auditors are not able to do so. i am not sure how many acbs actually ask their statutory auditors and internal auditors the reasons for their inability to identify such instances? is it a question of efficiency of the auditors or is there a much deeper issue – something to do with the transparency of the process itself? for a fair representation of accounts, it is also imperative that adequate provisions for post - retirement benefits like pension, gratuity, leave encashment, etc. ( wherever applicable ) are held. it is important that the acb asks the right questions to the management about various underlying assumptions that go into computation of the required provisions such as life expectancy, discount rate, expected return on investments, etc. i urge the acbs to ask uncomfortable questions. going forward, under a full - fledged rbs process, rbi ’ s dependence on auditors is only going to increase and a very competent acb will provide a great deal of supervisory comfort to us. role of audit committees in group companies 10. as a financial conglomerate, icici group pursues diverse business interests which subject it to the regulations of various domestic and overseas regulators. some of the critical roles that the audit committee of the boards are expected to play in terms of sebi ’ s corporate governance guidelines include : bis central bankers ’ speeches reviewing the annual financial statements and auditor ’ s reports before submission to the board for approval, with particular reference to major accounting entries involving estimates based on the exercise of judgment by management ( similar to what i had mentioned in the previous point ) reviewing the statement of uses / application of funds raised through an issue ( public issue, rights issue, preferential issue, etc. ) scrutiny of inter - corporate loans and investments reviewing the adequacy of internal audit function reviewing the functioning of the whistle blower mechanism ; approval of appointment of cfo review of the appointment, removal and terms of remuneration of the chief internal auditor the corporate governance guidelines of irda also envisage a similar role for the acbs of the insurance entities. 11. all financial conglomerates ( fcs ) tend to have complex group structures with significant interconnectedness amongst the group entities. such complexity generally masks the inherent risks and interconnectedness. the domestic financial

found lacking in proper monitoring. had it not been so, many observations or rather, similar kind of observations would not be appearing in successive supervisory reports. i would like the acbs to appreciate that rbi findings are based, in many cases, on a sample check. but the banks ’ compliance should not be limited to the instances highlighted. the objective should be to rectify the systems and processes across the bank so that there is no recurrence. the emphasis should be on the nature of deficiency and not on the rectification of the number of deficiencies identified by the supervisor. a crucial underpinning of the risk - based approach is a focus on systems and processes in banks. it would be important for the top management of banks, and more specifically, the acb members to internalize these aspects quickly and to develop a deeper understanding of the entire rbs process. ( c ) frauds : this is another area which needs increased focus and greater sensitivity from the acb members. everyone acknowledges the importance of putting in place appropriate systems and processes as the first and foremost requirement for preventing such incidents. the systems and processes may be in place. but do they really work? we tend not to look at it until and unless something serious happens. how fast is the dissemination of information within the bank? how quickly internal communications reach the staff manning the front office in the branches? an evaluation of this may not shore up a bank ’ s bottom - line but would definitely save it a lot of embarrassment. in our recently concluded scrutiny into fixed deposit related frauds in some banks, it emerged that even the caution advices issued by rbi in respect of certain individuals had not percolated down to the branch officials quickly enough to enable appropriate preventive measures. does acb have a role here? i would say that acbs should take upon themselves to monitor the trend of frauds, assimilate key learnings and ensure that mitigation measures are put in place by the management. ( d ) review of quarterly / annual results : as i mentioned earlier, one of the key expectations of all stakeholders, including the regulators, from the acb is that they ensure the integrity of accounting system. in respect of banks, the acbs are expected to take a close look into the asset quality, instances of restructuring of advances, provisioning held, etc. during rbi inspections, our inspectors sometimes report significant divergences with regard to asset classifications and provisions held, which have substantial implications for the