Sunday, 8 March 2020

An Approach to reduce Idle Funds: A case study of Government Accounts in Public Sector Banks in Ghazipur, Uttar Pradesh, India[1]



1.      Background
Government has been trying to bring in different techniques of better cash flow and treasury management. Public Financial Management System was developed as a tool to achieve this objective apart from other goals set for the same. Government of India has made consistent efforts for complete implementation of PFMS in all its schemes both; Central Sector as well as Centrally Sponsored Schemes.  All agencies operating government schemes are expected to be registered on PFMS with their dedicated bank account meant for the transactions of government business of the concerned scheme. Data of the unspent balances for the registered agencies is available on the PFMS system. Though are gaps in data and it may not be termed as comprehensive, it indicates that a huge amount of funds is lying in the bank accounts. There may further balance lying in term deposits and bank accounts not registered in PFMS. Further, there are accounts with bank balances, which are not in the radar of even the senior state officials. These funds may be brought back to the treasury account and put to better use. The country is already facing recourse crunch and such idle funds not getting leveraged is very disappointing and reflects poorly on the financial management. All efforts need to be made to identify idle funds, bring back to the treasury of concerned government and use it most effective manner.
2.      Objective
To ascertain the gravity of the matter and find back accounts as well as idle funds resting with them, a study was conducted in Ghazipur, Uttar Pradesh. This study is aimed to identify the accounts, suggest methods of getting the idle accounts closed by suitably withdrawing funds from there and suggest process through which funds are to be moved to State Treasury and Government of India accounts. It has focused on Government Accounts in Public Sector Banks related to various State and Central schemes.
3.      Methodology
Ghazipur, UP was chosen as pilot district being one of the backward districts of the country and may be considered as it is a reasonably representative district for rural India. State government officers were contacted and briefed about the objective. District Magistrate and all concerned District officials of Ghazipur and the respective bank representatives were interviewed regarding the status of the government accounts and the related issues. State officials were requested to provide information on the Government Accounts related to various State and Central Schemes in Ghazipur. Every district in India has a Lead Bank Manager (LDM) to coordinate the banking operation of the public sector banks in the district. LDM of the district was requested to get the list of all government bank accounts maintained by the banks. All departments were also asked to confirm the bank accounts maintained as per their records. All bank accounts registered in PFMS were also extracted through reports available in PFMS. Banks also maintain central subsidy sundry account and state subsidy sundry accounts. Banks were approached to confirm any government funds lying there in these accounts and common sundry account maintained by the banks.
4.      Process
State and district level officers were requested to follow a systematic approach to identify the accounts, agencies and idle funds under different schemes. Status of agencies handling government schemes/programs in Ghazipur was identified and scheme-wise bank accounts were listed. Reports as per PFMS were generated consisting of agency details, bank accounts and funds lying in them as per PFMS were prepared. The list was shared with the State and agencies and accounts were validated. The state was requested to provide further information related to Government Accounts of various State and central schemes implemented in the districts (Proforma A).
Chief Development Officer (CDO) is in charge of the development schemes in the District. He was requested to prepare the list of all the departments (as per Proforma B) and the list of concerned officers (as per Proforma C) and share it with LDM. All the officers in charge of respective schemes were informed and requested to provide the details. A list of closed and currently active schemes implemented in the district (as per Proforma D) with the respective bank accounts was prepared and shared with LDM. Based on the inputs from the scheme in charge and banks in the district, LDM prepared the department-wise government accounts. These accounts were checked and confirmed by the scheme in charge and gaps were filled. Headquarters or regional offices of the banks concerned were requested to confirm the details provided by the local branch in Ghazipur.

         Out of the list of accounts, dormant and inactive accounts were identified and confirmed. All identified bank accounts had some balances and these balances were confirmed along with the Government Sundry account balances and any other sundry balances lying with the concerned bank. In the process, it emerged that amounts are lying in the sundry accounts of the banks also. Further, there were accounts which were closed but still reflected as active in the records. Similarly, there were accounts which are inactive or dormant for a long time and there is no transaction taking place from them. Sundry account balances were confirmed from the regional headquarters of the bank concerned.

5.      Analysis and Observations
Through the efforts of the banks and the state officials, bank accounts dealing with government transactions were identified.
  • There were 1850 accounts with the balance of Rs.2.83 billion identified which are related to various State and Central schemes implemented in Ghazipur (Bank-wise summary is attached as Annex 1).
  • Out of 1850 accounts, 1442 accounts with a balance of Rs.943.5 million are related to Central Schemes. Further analysis showed that 8 accounts with a balance of Rs.199.2 million are related to Department of Drinking Water and Sanitation (DoDWS) and Ministry of Panchayati Raj (Local Government) (MoPR) (Annex 2).
  • A list of agencies and respective accounts registered for the Central schemes of Ministry of Rural Development (MoRD), DoDWS and MoPR implemented in Ghazipur were extracted from the PFMS reports. There were 66 accounts with a balance of 846.7 million which are related to the central schemes of MoRD, MoDWS and MoPR (Annex 3).
  • Further analysis revealed that there are gaps in both the lists of accounts generates through PFMS and sourced locally from the field through the state officials and banks.
  • It was also noticed that there were 15 inactive accounts, 155 dormant accounts out of the list provided by State. A summary of account status is attached as Annex 4.
6.      Findings and Way Forward
From the analysis, it is clear that a huge amount of funds are lying idle in the bank accounts. In one district alone an amount of Rs.2.83 billion is lying primarily in idle or transitory accounts. In India, there are more than 700 similarly placed districts. Thus it is estimated that about Rs.2 trillion is lying in either in an idle or unproductive manner.
 Same may be put to use by bringing it to the nodal treasury account of the State. In the cases where schemes are already closed, such funds may be remitted back to the treasury of the State and central government by following a systematic approach to identify and get the funds back to the treasury account. Government of India officers of the Ministry of Finance may identify the district-wise bank accounts and funds lying in them as per PFMS. PFMS team will extract the list of accounts registered in PFMS for all districts with agency and scheme-wise details. The list may be shared with the States and agencies and accounts may be validated. States may be requested to provide the information related to Government Accounts of various State and central schemes implemented in the districts.
States may initiate the process of idle fund reversal as per the guidelines of the Government to make the funds usable. In this regard guidleines of RBI to handle idle and dormant accounts may also be of some use (Annex-6).

Proforma A: Government Account Details
S.No
Filed Name
Details
1
Bank Name

2
Branch Name

3
IFSC

4
Account Number

5
Account Type

6
Account Status

7
Active from

8
Last Transaction Date

9
Last Transaction Amount

10
Available Balance (Actuals)

11
Scheme Type

12
Scheme Name

13
Account Holder Name

14
Department Name

15
Account Registered in PFMS (Yes/No)

16
PFMS Agency Unique Code


Proforma B: List of Government Departments
S.No
Field Name
Details
1
Department Name

2
Heard of the Department Name

3
Mobile Number

4
Office Land Line

5
Office Address


Proforma C: Department-wise list of concerned officers
Sl.No
Field Name
Details
1
Officer Name

2
Designation

3
Department/Organization

4
Mobile Number

5
Email ID

6
Reporting Officer Name

7
Phone/Office Number

8
Email ID


Proforma D: List of State or Central Government Schemes implemented in the District
S.No
Field Name
Details
1
Scheme Name

2
Scheme Type (State or Central)

3
Scheme status (Active or Closed)

4
Scheme launch Year

5
State Share

6
Centre Share


 Annex 1
Bank-wise no of Govt. Accounts in Ghazipur and Balances
Name of the Bank
No of Accounts
BALANCE  (in millions)
Union Bank of India
805
20,25.64
Punjab National Bank
42
5,03,17
ALLAHABAD BANK
98
84.78
Oriental Bank of Commerce
8
5.3
State Bank of India
398
4.0
IDBI Bank
45
4.3
Bank of Baroda
20
6.6
Bank of India
40
5.5
Kashi Gomti Samyut Gramin Bank
383
8.0
HDFC BANK
1
0
ICICI
2
4.0
AXIS BANK
1
7.8
BANDHAN BANK LTD
4
4.6
INDIAN BANK
1
2.7
Development Credit Bank Ltd.
2
0.3
Grand Total
1850
28,22.73

Source: List of accounts as per UP State


 Annex 2
Details of bank accounts related to GoI Schemes of DoDWS and MoPR implemented in Ghazipur
Name of Bank
Account Number
IFSC
SCHEME NAME
SCHEME TYPE (State/Central)
STATUS OF ACCOUNT
BALANCE in million
Punjab National Bank
4483000100037462
PUNB0992600
Swachh Bharat Mision
Central and State
Active
7.514
United Bank of India
441502010064163
UBIN0544159
RKVY
CENTRAL
ACTIVE
0.063
United Bank of India
441502010064164
UBIN0544159
RKVY
CENTRAL
ACTIVE
0.028
United Bank of India
441502010064165
UBIN0544159
RKVY
CENTRAL
ACTIVE
0.043
United Bank of India
441502010064166
UBIN0544159
RKVY
CENTRAL
ACTIVE
0.074
United Bank of India
392702010337077
UBIN0539279
SBM-G EXTRA BUDGETARY RESOURCES
CENTRAL
ACTIVE
9.802
United Bank of India
392702010337436
UBIN0539279
PERFORMANCE INCENTIVE GRANT FUND SBM G
CENTRAL
ACTIVE
107.027
United Bank of India
392702010337704
UBIN0539279
GANGA ACTION PLAN
CENTRAL
ACTIVE
74.725

Source: List of accounts as per UP State


 Annex 3
Bank-wise Summary of accounts registered in PFMS for GoI schemes of MoRD, DoDWS and MoPR implemented in Ghazipur
S.No
Bank Name
No of Accounts
Unspent Balance
(Rs. In Actuals)
1
UNION BANK OF INDIA
45
79,75,55,273.96
2
ORIENTAL BANK OF COMMERCE
6
2,48,27,186.00
3
PUNJAB NATIONAL BANK
5
2,19,63,925.15
4
STATE BANK OF INDIA
2
18,31,876.30
5
BANK OF BARODA
4
4,61,206.00
6
ALLAHABAD BANK
3
1,49,123.00
7
BANK OF INDIA
1
12

Grand Total
66
84,67,88,609.53

Source: PFMS
Annex 4
Account Status-wise summary of Govt accounts in Ghazipur
Account Status
CENTRAL
Central and State
State
Not Specified
Total No of A/c
Total Balance in million
No of A/c
Balance in million
No of A/c
Balance in million
No of A/c
Balance in million
No of A/c
Balance in million
ACTIVE
1431
4
1
7.5
144
9.3
103
1.0
1679
1.8
Inactive
2
0


13
9.1


15
9.1
DORMANT
8
2


73
1.8
74
8.0
155
1.8
Closed




1



1

Grand Total
1441
9.359
1
0.75
231
14.003
177
4.790
1850
28.227

Source: List of accounts provided by UP State


Annex 6
GUIDELINES TO HANDLE DORMANT / INACTIVE ACCOUNTS – SCHEDULED COMMERCIAL BANKS
As per RBI guidelines vide circular no. Circular DBOD.No.Leg.BC.34/09.07.005/2008-09 dated August 22, 2008, paragraph 2(iv) of on Unclaimed Deposits/Inoperative Accounts in Banks in terms of which savings, as well as current account, should be treated as inoperative/dormant if there are no transactions in the account for over two years. Further, in terms of paragraph 2(vi), to classify an account as inoperative, both the types of transactions i.e. debit, as well as credit transactions induced at the instance of customers as well as third party, should be considered. (Copy of circular is attached).
Further, as per para vii of the circular, the segregation of the inoperative accounts is from reducing the risk of frauds etc. However, the customer should not be inconvenienced in any way, just because his account has been rendered inoperative. The classification is there only to bring to the attention of dealing staff, the increased risk in the account. The transaction may be monitored at a higher level both from preventing fraud and making a Suspicious Transactions Report. However, the entire process should remain un-noticeable by the customer.
Para viii of the circular suggests that operation in such accounts may be allowed after due diligence as per risk category of the customer. Due diligence would mean ensuring the genuineness of the transaction, verification of the signature and identity etc. However, it has to be ensured that the customer is not inconvenienced as a result of the extra care taken by the bank
Customer Due Diligence
RBI has given its master directions vide their circular RBI/DBR/2015-16/18 Master Direction DBR.AML.BC.No.81/14.01.001/ 2015-16 Master Direction - Know Your Customer (KYC) Direction, 2016 (Updated as on July 12, 2018) Copy attached).
RBI/2016-17/173 DBR.AML.BC.No.44/14.01.001/2016-17 dated December 06, 2016 - Requirement of customer due diligence and need for maintenance of records.
As per these guidelines, RBI has referred Banks to two of its earlier circulars for reactivation of dormant accounts. It is referred paragraph 24.2 (ix) of the Master Circular on ‘Customer Services in Banks’ dated July 1, 2015, requiring that operation in dormant accounts with banks may be allowed after due diligence as per risk category of the customer. As stated therein, ‘due diligence’ would mean ensuring the genuineness of the transaction, verification of the signature and identity etc.
RBI has also invited attention to Chapters VI and VII of their Master Direction on KYC dated February 25, 2016, addressed to all Regulated Entities (REs) in terms of which
  1. as part of the Customer Due Diligence Procedure, certified copies of officially valid documents for proof of identity and address are to be obtained while establishing an account-based relationship;
  2. REs shall, among others, take steps for preserving the customer account information including preservation of records of the identification of the customers and their addresses obtained while opening the account, for at least five years after the business relationship is ended.
Inoperative Accounts
RBI /2014-15/200
DBOD.No. Leg. BC. 36/09.07.005/2014-15
September 1, 2014
All Scheduled Commercial Banks
(excluding RRBs)
Dear Sir/Madam,
Inoperative Accounts
Please refer to paragraph 2(iv) of our Circular DBOD.No.Leg.BC.34/09.07.005/2008-09 dated August 22, 2008, on Unclaimed Deposits/Inoperative Accounts in Banks in terms of which savings, as well as current account, should be treated as inoperative/dormant if there are no transactions in the account for over two years. Further, in terms of paragraph 2(vi), for the purpose of classifying an account as inoperative, both the types of transactions i.e. debit as well as credit transactions induced at the instance of customers as well as third party should be considered.
2. There may be instances where the customer has given a mandate for crediting dividend on shares to Savings Bank account and there are no other operations in the Savings Bank account. Some doubts have arisen whether such an account is to be treated as inoperative account after two years.
3. In this connection, we clarify that since dividend on shares is credited to Savings Bank accounts as per the mandate of the customer, the same should be treated as a customer induced transaction. As such, the account should be treated as operative account as long as the dividend is credited to the Savings Bank account. The Savings Bank account can be treated as inoperative account only after two years from the date of the last credit entry of the dividend, provided there is no other customer induced transaction.
Yours faithfully,
(SudarshanSen)
Chief General Manager– in--Charge





Unclaimed Deposits / Inoperative Accounts in Banks
RBI / 2008-09 / 138
DBOD.No.Leg. BC. 34  /09.07.005/2008-09
August  22,  2008
All Scheduled Commercial Banks 
(Excluding RRBs)
Dear Sir,
Unclaimed Deposits / Inoperative Accounts  in banks
Please refer to our Circular DBOD.No.Com.BC.109/C.408/A-77 dated October 1, 1977 wherein banks were advised that deposit accounts which have not been operated upon over a period, say two years should be segregated and maintained in separate ledger/s. Further, banks were also advised vide our circular no. DBOD.No.Leg.BC.45/C.466 (IV) / 89 dated November 15, 1989 that they should ensure that their branches follow-up accounts which remained inoperative for a year or so by sending suitable advices to the customers and if the said letters are returned undelivered, they may immediately be put on enquiry to find out the whereabouts of customers or their legal heirs in case they are deceased.
2. In view of the increase in the amount of the unclaimed deposits with banks year after year and the inherent risk associated with such deposits, it is felt that banks should play a more pro-active role in finding the whereabouts of the account holders whose accounts have remained inoperative. Further several complaints have been received in respect of difficulties faced by the customers on account of their accounts having been classified as inoperative. Moreover, there is a feeling that banks are undeservedly enjoying the unclaimed deposits, while paying no interest on it. Keeping these factors in view, we have reviewed the above instructions issued by us and advise banks to follow the instructions detailed below while dealing with inoperative accounts:
(i) Banks should make an annual review of accounts in which there are no operations (i.e. no credit or debit other than crediting of periodic interest or debiting of service charges) for more than one year. The banks may approach the customers and inform them in writing that there has been no operation in their accounts and ascertain the reasons for the same. In case the non operation in the account is due to shifting of the customers from the locality, they may be asked to provide the details of the new bank accounts to which the balance in the existing account could be transferred.
(ii) If the letters are returned undelivered, they may immediately be put on enquiry to find out the whereabouts of customers or their legal heirs in case they are deceased.
(iii) In case the whereabouts of the customers are not traceable, banks should consider contacting the persons who had introduced the account holder. They could also consider contacting the employer / or any other person whose details are available with them. They could also consider contacting the account holder telephonically in case his telephone number / Cell number has been furnished to the bank. In case of Non Resident accounts, the bank may also contact the account holders through e-mail and obtain their confirmation of the details of the account.
(iv) A savings as well as current account should be treated as inoperative / dormant if there are no transactions in the account for over a period of two years.
(v) In case any reply is given by the account holder giving the reasons for not operating the account, banks should continue classifying the same as an operative account for one more year within which period the account holder may be requested to operate the account. However, in case the account holder still does not operate the same during the extended period, banks should classify the same as inoperative account after the expiry of the extended period.
(vi) For the purpose of classifying an account as ‘inoperative’ both the type of  transactions i.e. debit as well as credit transactions induced at the instance of customers as well as third party should be considered. However, the service charges levied by the bank or interest credited by the bank should not be considered.

(vii) Further, the segregation of the inoperative accounts is from the point of view of reducing risk of frauds etc. However, the customer should not be inconvenienced in any way, just because his account has been rendered inoperative. The classification is there only to bring to the attention of dealing staff, the increased risk in the account. The transaction may be monitored at a higher level both from the point of view of preventing fraud and making a Suspicious Transactions Report. However, the entire process should remain un-noticeable by the customer.
(viii) Operation in such accounts may be allowed after due diligence as per risk category of the customer. Due diligence would mean ensuring genuineness of the transaction, verification of the signature and identity etc. However, it has to be ensured that the customer is not inconvenienced as a result of extra care taken by the bank.
(ix) There should not be any charge for activation of inoperative account.
(x) Banks are also advised to ensure that the amounts lying in inoperative accounts ledger are properly audited by the internal auditors / statutory auditors of the bank.
(xi) Interest on savings bank accounts should be credited on regular basis whether the account is operative or not. If a Fixed Deposit Receipt matures and proceeds are unpaid, the amount left unclaimed with the bank will attract savings bank rate of interest.
3. Banks may also consider launching a special drive for finding the whereabouts of the customers / legal heirs in respect of existing accounts which have already been transferred to the separate ledger of ‘inoperative accounts’.
Yours faithfully
(PrashantSaran)
Chief General Manager-in-Charge

Requirement of customer due diligence and need for maintenance of records
RBI/2016-17/173
DBR.AML.BC.No.44/14.01.001/2016-17
December 06, 2016
All Regulated Entities (REs)
Dear Sir/Madam,
Requirement of customer due diligence and need for maintenance of records
It has been reported that, of late, a lot of customers are approaching banks for re-activation of dormant accounts.
2. In this regard, we invite attention to paragraph 24.2 (ix) of the Master Circular on ‘Customer Services in Banks’ dated July 1, 2015, requiring that operation in dormant accounts with banks may be allowed after due diligence as per risk category of the customer. As stated therein, ‘due diligence’ would mean ensuring genuineness of the transaction, verification of the signature and identity etc.
3. Attention is also invited to Chapters VI and VII of our Master Direction on KYC dated February 25, 2016, addressed to all Regulated Entities (REs) in terms of which
  1. as part of the Customer Due Diligence Procedure, certified copies of officially valid documents for proof of identity and address are to be obtained while establishing an account based relationship;
  2. REs shall, among others, take steps for preserving the customer account information including preservation of records pertaining to the identification of the customers and their addresses obtained while opening the account, for at least five years after the business relationship is ended.
4. It is reiterated that REs shall ensure compliance, inter alia, with the above mentioned instructions as applicable on activation of dormant accounts, customer due diligence and record management, scrupulously.
(S.S.Barik)
Chief General Manager - in - Charge



DBR-Master Circular on Customer Service in Banks 2015 dt 01.07.2015
24. Unclaimed Deposits / Inoperative Accounts in banks
24.1 Section 26 of the Banking Regulation Act, 1949 provides, inter alia, that every banking company shall, within 30 days after close of each calendar year submit a return in the prescribed form and manner to the Reserve Bank of India as at the end of each calendar year (i.e., 31st December) of all accounts in India which have not been operated upon for 10 years.
24.2 In view of the increase in the amount of the unclaimed deposits with banks year after year and the inherent risk associated with such deposits, banks should play a more pro-active role in finding the whereabouts of the account holders whose accounts have remained inoperative. Further several complaints were received in respect of difficulties faced by the customers on account of their accounts having been classified as inoperative. Moreover, there is a feeling that banks are undeservedly enjoying the unclaimed deposits, while paying no interest on it. Keeping these factors in view, the instructions issued by RBI have been reviewed and banks are advised to follow the instructions detailed below while dealing with inoperative accounts:
(i) Banks should make an annual review of accounts in which there are no operations (i.e., no credit or debit other than crediting of periodic interest or debiting of service charges) for more than one year. The banks may approach the customers and inform them in writing that there has been no operation in their accounts and ascertain the reasons for the same. In case the non- operation in the account is due to shifting of the customers from the locality, they may be asked to provide the details of the new bank accounts to which the balance in the existing account could be transferred.
(ii) If the letters are returned undelivered, they may immediately be put on enquiry to find out the whereabouts of customers or their legal heirs in case they are deceased.
(iii) In case the whereabouts of the customers are not traceable, banks should consider contacting the persons who had introduced the account holder. They could also consider contacting the employer / or any other person whose details are available with them. They could also consider contacting the account holder telephonically in case his Telephone number / Cell number has been furnished to the bank. In case of Non Resident accounts, the bank may also contact the account holders through e-mail and obtain their confirmation of the details of the account.
(iv) A savings as well as current account should be treated as inoperative / dormant if there are no transactions in the account for over a period of two years.
(v) In case any reply is given by the account holder giving the reasons for not operating the account, banks should continue classifying the same as an operative account for one more year within which period the account holder may be requested to operate the account. However, in case the account holder still does not operate the same during the extended period, banks should classify the same as inoperative account after the expiry of the extended period.
(vi) For the purpose of classifying an account as ‘inoperative’ both the type of transactions i.e., debit as well as credit transactions induced at the instance of customers as well as third party should be considered. However, the service charges levied by the bank or interest credited by the bank should not be considered.
(vii) There may be instances where the customer has given a mandate for crediting the interest on Fixed Deposit account and/or crediting dividend on shares to the Savings Bank account and there are no other operations in the Savings Bank account. Since the interest on Fixed Deposit account and/or dividend on shares is credited to the Savings Bank accounts as per the mandate of the customer, the same should be treated as a customer induced transaction. As such, the account should be treated as operative account as long as the interest on Fixed Deposit account and/or dividend on shares is credited to the Savings Bank account. The Savings Bank account can be treated as inoperative account only after two years from the date of the last credit entry of the interest on Fixed Deposit account and/or dividend on shares, whichever is later, provided there is no other customer induced transaction.
(viii) Further, the segregation of the inoperative accounts is from the point of view of reducing risk of frauds etc. However, the customer should not be inconvenienced in any way, just because his account has been rendered inoperative. The classification is there only to bring to the attention of dealing staff, the increased risk in the account. The transaction may be monitored at a higher level both from the point of view of preventing fraud and making a Suspicious Transactions Report. However, the entire process should remain un-noticeable by the customer.
(ix) Operation in such accounts may be allowed after due diligence as per risk category of the customer. Due diligence would mean ensuring genuineness of the transaction, verification of the signature and identity etc. However, it has to be ensured that the customer is not inconvenienced as a result of extra care taken by the bank.
(x) There should not be any charge for activation of inoperative account.
(xi) Banks are also advised to ensure that the amounts lying in inoperative accounts ledger are properly audited by the internal auditors / statutory auditors of the bank.
(xii) Interest on savings bank accounts should be credited on regular basis whether the account is operative or not. If a Fixed Deposit Receipt matures and proceeds are unpaid, the amount left unclaimed with the bank will attract savings bank rate of interest.
24.3 Banks may also consider launching a special drive for finding the whereabouts of the customers / legal heirs in respect of existing accounts which have already been transferred to the separate ledger of ‘inoperative accounts’.
24.4 Display list of Inoperative Accounts: Banks should, in addition to the instructions contained above, play a more pro-active role in finding the whereabouts of the accountholders of unclaimed deposits/ inoperative accounts. Banks are, therefore, advised that they should display the list of unclaimed deposits/inoperative accounts which are inactive / inoperative for ten years or more on their respective websites. The list so displayed on the websites must contain only the names of the account holder(s) and his/her address in respect of unclaimed deposits/inoperative accounts. In case such accounts are not in the name of individuals, the names of individuals authorized to operate the accounts should also be indicated. However, the account number, its type and the name of the branch shall not be disclosed on the bank’s website. The list so published by the banks should also provide a “Find” option to enable the public to search the list of accounts by name of the account holder.
Banks should also give on the same website, the information on the process of claiming the unclaimed deposit/activating the inoperative account and the necessary forms and documents for claiming the same. Banks are required to have adequate operational safeguards to ensure that the claimants are genuine.
24.5 Strengthening the Regulatory Framework for Unclaimed Deposits
With a view to further strengthen the regulatory framework for inoperative accounts and unclaimed deposits, banks are advised to put in place a Board approved policy on classification of unclaimed deposits; grievance redressal mechanism for quick resolution of complaints; record keeping; and periodic review of such accounts. The first periodic review of unclaimed deposits/inoperative accounts should be put up to their respective bank Boards by September 30, 2012.
24.6 Treatment of certain savings bank accounts opened for credit of Scholarship amounts and credit of Direct Benefit Transfer under Government Schemes
State and Central Governments have expressed difficulties in crediting cheques/Direct Benefit Transfer/Electronic Benefit Transfer/Scholarships for students, etc. into accounts/Accounts with zero balance opened for the beneficiaries under various Central/State Government schemes but had been classified as dormant/inoperative due to non-operation of the account for over two years.
Keeping the above in view, banks are advised that they may allot a different “product code” in their CBS to all such accounts opened by banks so that the stipulation of inoperative/dormant account due to non-operation does not apply while crediting proceeds as mentioned above.
In order to reduce the risk of fraud etc., in such accounts, while allowing operations in these accounts, due diligence should be exercised by ensuring the genuineness of transactions, verification of signature and identity, etc. However, it has to be ensured that the customer is not inconvenienced in any manner.
24.7 Treatment of accounts opened for credit of Scholarship Amounts under Government Schemes
Bombay High Court has brought to our notice that banks fix a limit on total credits in zero balance accounts opened for students studying in primary, secondary / higher secondary schools and technical institutions. Resultantly, in cases where scholarship amounts exceed the credit limit, banks do not allow the credit and return the amount to the disbursement account of the Government. Further, in some cases banks are reported to have closed zero balance accounts unilaterally without intimating student beneficiaries concerned. Instances of banks refusing to open zero balance account for students have also been brought to our notice.
As directed by the Bombay High Court, banks are advised to ensure that accounts of all student beneficiaries under the various Central/State Government Scholarship Schemes are free from restrictions of ‘minimum balance’ and ‘total credit limit’.





SUNDRY ACCOUNTS IN BANKS

SUNDRY ACCOUNT is an account where miscellaneous items are recorded, e.g. infrequent transactions involving customers or suppliers that are not tracked in the normal course of business.
In most of the Banks, transactions in such accounts are to be monitored on day to day basis and got adjusted daily except in certain cases when there is a need to keep such balances in Sundry Accounts. Banks also keep some of the amounts in Imprest Accounts where there is a need to hold balances but these are also monitored on day to day basis and entries adjusted except for certain cases.
These are Non Personal or Impersonal Accounts.
Ways to prevent Banks to not to place Implementing Agency’s funds into their Sundry Account
  • IAs not to give any debit authority to Banks for keeping their funds aside, without which they cannot debit their accounts.
  • Banks in turn provide information about transactions of IA accounts on daily basis in terms of PFMS KPIs.
  • Controllers to strictly have a watch on IAs’ accounts for any such debits.
  • In case, controllers find any such transaction, they may ask for Utilization Certificate from IA.
  • Controllers to develop mechanism to check such events in second or subsequent level IA accounts.
  • On certain occasions, IAs authorize Banks to keep Sweep facility into their accounts, whereby CBS system automatically transfers excess balances into FDRs. This may show lesser balances in their accounts.
  • On certain other occasions, IAs invest money in FDRs which may not be shown in their running accounts (SB/CA),
  • There can be an occasion when Bank has debited IA account and is keeping amount into Bank’s pool account for further remittance to NPCI until the window is open.
Usually, such entries are adjusted by Banks themselves as explained above. In case, there is any long pending entry, IA can always take up with the Bank for its credit to their account.



[1] Ajay S Singh is a civil servant and views are personal

Innovation in Risk-Based Internal Audit in Rural Development Schemes of Government of India[1]




1.       Introduction: Ministry of Rural Development (MoRD) of Government of India is responsible to formulate policy for the development of rural India and promote the welfare of its rural people. The vision and mission of the MoRD is sustainable and inclusive growth of rural India through a multipronged strategy for eradication of poverty by increasing livelihoods opportunities, providing a social safety net and developing infrastructure for growth.  In this process, it runs several people-centric schemes through the States (sub-national) Government. These schemes have a very elaborate process and offer benefits to marginalise and poor of rural India. MoRD has huge budget outlays of more than Rs.1220 billion. Flagship Schemes like Mahatma Gandhi National Rural Employment Guarantee Scheme (MGNREGS) has financial provisions of more than Rs. 800 billion and affecting the lives of more than 120 million rural poor. To ensure that benefits are transferred to intended beneficiaries, many accountability matrices have been put in place. Risk-Based Internal Audit (RBIA) is one such mechanism. Risk management including identification, prioritization and mitigation of risks for these schemes is important to ensure transparency and accountability.

2.       Challenges to conduct RBIA: Under the existing manual system some of the bottlenecks were as follows:

a.  There are more than 4000 audit units expected to be audited. Due to limited resources, selection of sample and identification of teams through a manual system becomes very challenging. Conducting audit and follow up is also very difficult. Further, the details of auditee units used to be collected manually and entire scheme details, demographic particulars of and listing of decision-makers of the auditee were collated in physical files after reaching the venue of the auditee. This process was very time consuming and many details were either missed or collected incorrectly.
b.   The paper-based system was not amenable to easy monitoring and does not support institutionalizing good governance practices. The movement of paper/file across the various levels in a department was time-consuming, cost-inefficient and caused undue delay in initiating corrective action. Follow up action was slow and therefore, fixing accountability was tough.
c.        Mistakes are committed repeatedly, year after year across the offices and the manual systems are not equipped to cross-check across different offices and schemes.
d.       Lack of quantification and consolidation of reported loss due to poor execution or compliance failure by the Program Implementation Agencies.

3.       Development of GRIP: To address these core issues, a portal namely GRameen Internal audit Portal (GRIP) was developed, tested and deployed. An effort was made to automate process flow for two leading schemes namely MGNREGS for employment and Pradhan Mantri Awas Yojna- Grameen (PMAY-G) for rural housing.

a.       GRIP is a web-based portal that can be accessed from anywhere. It is used to conduct RBIA even at the level of lowest level implementing agencies such as Panchayati Raj Institutions (local self-governance bodies).
b.       It can cover all 722 districts across India involving around 5,500 blocks having around 2,50,000 Panchayats (lowest level of elected body). As of 1st January 2020, it covers 23 States in their 55 districts and more than 200 blocks. Inclusion of new districts and blocks is increasing day by day.
c.        During the process of development of GRIP, the entire process of Internal Audit has been re-engineered. An Internal Audit report generally has 18 to 20 observations. In the manual process, unless the entire Audit report gets prepared, it will not move for the approval process across the various levels/actors of the Audit Department, thereby leading to delay in the process. However, the new automated system, flexibility is provided in such a way that either single observation moves forward and other are kept on hold or a multiple/ complete set of observations are moved forward simultaneously as per the workflow.
d.       The system can bifurcate observations and move only the approved observation forward to the next level/actor and unapproved observation move to backward level/actor as per workflow, on which further clarifications may be required This has led to increase in efficiency which reflects into the increased output.
e.        With GRIP, the report not only remains in the system and visible to the auditors and auditee it is also sent electronically for necessary action. In the re-engineered process, reports are now available on a single click of a mouse. This system facilitates to view the entire trail of the history of the audit conducted under any scheme and for any audit. Further, this system also facilitates analysis of the reports under the same scheme or as per demographic variations.
f.        Under the new system, old reports may be taken to the GRIP portal. It facilitates the monitoring of the old audit observations and analysis of the findings of the audit conducted in the past. Monitoring of closure of audit observations can now be done easily. Auditee response is also online through the portal. GRIP portal generates reports and graphic representation of non-responded observations leads to the improvement of follow up. Automated reminders are sent to the auditee through e-mails.
g.        GRIP is customized for RBIA of schemes, risk matrix has been uploaded in it, it generates risk category wise reports also i.e. how the observations of the same risk vary between various Audit units. This comparative data analytics strengthens the decision-making process and improves the implementation of programs.
h.       This application has been developed in a generic way where both types of Audit can be configured viz., Internal or External Audit.  For catering to various aspects and requirements of Audit, any depth of process flow can be handled, and any department/scheme/program can be configured in the simplest way possible. The application is web-based and can be easily accessed online.
i.         It allows designing the forms for Case Record and Fact Sheet easily and dynamically keying in the formulae’s and necessary fields with required validations. It facilitates generation & download of various graphical reports in PDF and Excel formats for easy analysis and monitoring based on customizable Report Templates.
j.         It captures the complete process of the audit and enables reply and follow up instantaneously and amenable for analysis and monitoring.
5. Benefits of GRIP:
a.       GRIP has re-engineered the internal audit process flow. It has reduced unnecessary manual work. 24*7 availability has led to increased efficiency. Before GRIP, it used to take about 2 months to complete an audit against 15 days taken to complete an audit approval process. It has increased in efficiency by about 400%.
b.       It has led to an increase in the number of total internal audits conducted in a year from 23 (2015-16) to 108 (2017-18) and further to 112 in (2018-19).
c.        Coverage of districts covered after the launch of GRIP has increased from 23 to 78. Till now a total of 81 audits have been conducted in GRIP raising total 1162 audit observations.
d.       Internal audits conducted on GRIP have pointed out irregularities in various risk areas of scheme execution. In case of MGNREGS, it has indicated blockade/ parking of funds of about Rs. 460 million, the inadmissible expenditure of about Rs. 3.3 billion. For PMAY-G scheme, GRIP has pointed out more than Rs.102 million idle government funds parked in different banks and inadmissible expenditure of about Rs. 204 million.
e.        MGNREGS scheme is a poor centric scheme and cash benefits must reach to the targeted beneficiaries in time. RBIA has taken delay in payment as one of risk area and analysed the reasons. It has led to an improvement in timely payments from 20% of transactions in 2015-16 to more than 82% in 2019-20.
f.        Office printing has a huge environmental cost. One A4 sheet uses 0.5 litres of water. One tree is cut down for 9000 A4 sheets. The manual process of conducting around uses around 1,200 pages. Thus, 81 Audits conducted through GRIP have saved about 97,200 pages equaling to 11 trees and 48,600 LTRs. of water. Its replication in all schemes of civil ministries of Government of India alone will result in saving of 2,560 trees and 11.5 million LTRs. of water.


[1] A brief note by Dr.Ajay S Singh, a civil servant with Government of India, views are personal