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10 /2013
16.02.2013
(Dilip Saha)
GENERAL SECRETARY
--------------------------------------------------------------------------------------------------------------------------------AIPNBOA/70
15.02.2013
The present accountability policy contained in Inspection & Audit Division Circular No. 46 dated
15.05.2012 with further Circular No. IAD/SAC/69/2012 dated 31.12.2012 to identify erring officials under
staff accountability policy are itself not in sync with operational risk management, credit risk and market
risk management.
The accountability policy pursued in our Bank has created a feeling among officers that there should be
no room for error in ones own work.
The Bank is a commercial organization and not a regulatory body. An advance can go bad due to a
number of factors. External factors like change in Government policy, market conditions, economic
situation in other countries with whom the business is carried out, inefficient management of borrowing
concern, willful default by borrower etc., can be cause of an account becoming NPA. All these factors are
beyond the control of the bank or its officials. While examining staff accountability these factors are never
commented upon nor any remedial measures ever suggested. Records of all such staff accountability cases
are testimony.
It is often seen that inconsequent procedural lapses have been highlighted in Inspection Report or Special
Investigation Report and accountability fixed. The very exercise of staff accountability is to safeguard the
larger interest of the Bank and to meet that, the first step should be taken to identify areas where rules
and procedures are difficult to follow and necessary corrective steps by way of strengthening any
knowledge gap or by way of augmenting the resources or any other action to create an environment
which should be conducive for better observances of rules and procedures. Punishing an officer becomes
the primary objective of the accountability policy overriding the need to take such corrective steps.
Otherwise the increase of DAC cases & higher punishment should have reduced level of NPA in our bank.
Bank branches / offices and its business are subject to various audits throughout the year like, Revenue
Audit, Concurrent Audit, Annual Inspection, RBI Annual Inspection, RBI inspection for Government
Business & Pension, Statutory Audit, CARD Audit, MARD Audit, Stock Audit, Space Audit, Security Audit,
System Audit (IT) and Senior Officials Visit etc. All activities as well as business parameters are monitored
on daily real time basis by various authorities.
In the light of the above, there is no necessity of a Special Report and Special Investigation for other
than NPA account and NPA account respectively. This procedure of special report and special
investigation was introduced in our Bank in the year 2004 as at that time most of the operations were
still on manual system and free flow of information as well as day to day monitoring was not as
effective as is today. Whenever an inspecting official is assigned to submit a special report or special
investigation report, the very nomenclature suggests that he should find someone accountable as he
has been given a special assignment and he needs to justify it.
There is enough accountability detection mechanism available from where accountability can be identified
namely,
Central Office: 306, Kirti Mahal, 19, Rajendra Place, New Delhi 110008 Fax: 011-25735979
i)
ii)
iii)
iv)
v)
In most of the public sector banks viz., Bank of Baroda, Canara Bank, IOB, Bank of India, IDBI Bank etc.,
there is no policy of Special Investigation or any other investigation by any inspecting official from
Inspection Division. They capture data mainly from existing available source for the purpose of
accountability. A few banks gets a preliminary enquiry done in select cases, if need be, to gather more
information through Branch / Circle / Zonal Office officials by means of a simple format.
In most banks there is a cooling period of two subsequent quarters to the quarter in which the account
become NPA in order to ascertain if the aberration in the account becoming NPA is technical or only a
temporary development, leaving scope for immediate up-gradation in the two succeeding quarters.
In the accountability policy circulated vide Inspection & Audit Division Circular No. 46 dated 15.05.2012,
there are certain provisions which prohibits fixing of accountability but most violation is taking place on
those provisions by the inspecting official and in the absence of any corrective mechanism or escalating
violation of circular to any higher official / arbitrator, the DAC department is acting on such report in
initiating not only staff side case but in many cases with vigilance angle. The clauses, which give
protection but ignored to initiate action, are at Sl. No. 4.2.7 (i) & (ii), Sl. No. 9.2 (i) of the circular.
Similarly, Sl. No. 5.2.4.5 deals in categorization of lapses into internal and external reasons and sub-divided
into recovery and non recovery prospects whereas it should have been sub-divided into procedural and
non-procedural lapses. Since recovery depends on various tangible as well as intangible aspects, legal
positions to be tested only in a court and the art of recovery pursued by different officials, it would be
premature to attempt to ascertain position of recovery at such early stage when inspection is taking place
and investigation officials cannot be judgmental about such matters. The pragmatic approach should be to
ascertain whether lapses are attributable to the account becoming NPA or not.
As if the above accountability policy which is totally loaded towards finding fault was not enough, an
exhaustive chart / list is devised to find out each aspect of lapse, which is nothing but a directive to the
inspecting official to somehow find fault in one item or the other. Further, one more Circular No.
IAD/SAC/69/2012 dated 31.12.2012 is issued to identify erring officials under staff accountability policy.
This circular mostly targets a few designated officials at the branch level for most of the lapses and
reinforces the fear factor among officers that there should be no room for error in ones own work and.
Since to err is human it is better not to take decision so as not to err is the signal given to sincere officers.
After receiving a Status Report it is send to GM, Recovery Division, HO or to a committee of 3 GMs for
ascertaining whether special investigation is required or not. However, a report is also sent to Inspection
Division as well as to the Vigilance Department. It has been seen in many cases that Vigilance Department
has over ridden the decisions of even the 3 GMs committee recommendations. Similarly, once
Central Office: 306, Kirti Mahal, 19, Rajendra Place, New Delhi 110008 Fax: 011-25735979
accountability is established all cases go to the IAC for identification of vigilance angle and here again their
collective decision has been overturned. It is strange that why a particular lapse is perceived as having
vigilance tone is not even communicated to the Circle Offices leave alone to the officer concerned. In
many PSU Banks such reporting and vetting is not being done to/by vigilance department.
We have already communicated earlier that the level of punishment has become unreasonable and
unprecedentedly high in the recent past. NPA is not the phenomenon of only last 2 years. A chart should
be prepared with comparative level of punishments between the two periods mentioned below will aptly
bring out the truth:
Punishment Level
5+ increments cut
8+ Increments cut
12+ Increments cut
15+ Increments cut
Downgrade to lower scale
Downgrade to 2 lower scales
Downgrade to lower scale plus reduction of pay
Number of CRS
No. of Dismissal
No. of Invocation of Sec. 20 (3)
We are sure the result will be an eye opener. The punishment level is equated with financial loss to the
employee on account of the punishment with amount of NPA.
The fear and negativity in the rank and file due to such harsh punishments is further compounded by
adopting a seal cover procedure in variance with Government guidelines. We have already clarified our
position vide our letter dated 18.10.2012 & 08.11.2012. Similarly, the CVC guidelines on anonymous,
pseudonymous complaints and complaints under whistle blower policy are not implemented in letter &
spirit. Please refer our letter dated 14.02.2013 on this issue.
The present state of affairs prevailing in the Bank due to charge sheets and punishments is having a
negative impact affecting business growth of the Bank. You have been making sincere efforts to correct
the situation to motivate the rank and file and encouraged by your positive approach, we are submitting
herewith our suggestions on accountability as well as changes require in the processes of DAC matters as
per Annexure I and hope to get your support for accepting those changes.
Accountability policy of Bank of Baroda, Canara Bank, IDBI Bank, Indian Overseas Bank, Bank of India etc.,
may also be looked into.
Central Office: 306, Kirti Mahal, 19, Rajendra Place, New Delhi 110008 Fax: 011-25735979
We have immense confidence that given a fair treatment, the same set of officers who are responsible for
taking our bank to greater heights shall deliver much better under your able leadership.
Thanking you,
Yours faithfully,
(Dilip Saha)
GENERAL SECRETARY
Central Office: 306, Kirti Mahal, 19, Rajendra Place, New Delhi 110008 Fax: 011-25735979
ANNEXURE I
SUGGESTIONS ON ACCOUNTABILITY POLICY AND DAC MATTERS
The system of data collecting through Special Report & Special Investigation Report should be completely
done away with and instead accountability should be determined from Inspection Report of branches /
controlling offices, Internal / External concurrent audit, statutory audit, RBI Inspection, Branch visits,
Review meetings of NPA, periodical returns, access to CBS, genuine Complaints, Whistle blowing etc.
ZAOs and IAD should only be assigned regular concurrent audit, annual audit, revenue audit etc., and
should be restricted to these assignments. Since all types of audit & Inspection have failed to prevent an
account becoming NPA, their role identifying lapses afresh on NPA accounts amounts to covering for
their earlier work. Further NPA or Recovery has nothing to do with inspection and audit. Therefore IAD
division and its officials should be out of the authority to examine staff accountability or preparation of
any report required to examine staff accountability as otherwise it becomes a conflict of interest.
It is imperative that the accountability policy is restricted to policy direction which will have a wider scope
and not make it into a bulky instruction manual as is presently devised. All employees are duty bound to
follow prescribed rules so as to reduce operational, credit as well as market risks but it is equally
important that those implementing such rules through an accountability policy does not violate provisions
of the policy. In order to safe guard the abuse of the provisions by any official of authority, the process of
escalating such cases is suggested as a check and balance method.
All data should be collected from existing available sources and wherever required to collect any
additional information, a simple format be devised (the penchant for lengthy policy and lengthy format
should be done away with) and information be collected limit-wise / outstanding-wise by officials from
the office of the authority as under:
Jurisdiction for examination of staff
accountability
Amount of limit or
Outstanding
whichever is lower
All advances accounts sanctioned Rs.400 lacs
under BM Power up to Scale IV
branch.
All advances accounts sanctioned Rs.2000 lacs
under Branch power of ELB headed by
Scale V and by Circle Level Committee.
All advances accounts sanctioned Rs.3500 lacs
under FGM Office & sanctioned under
HO level committee.
Authority
Central Office: 306, Kirti Mahal, 19, Rajendra Place, New Delhi 110008 Fax: 011-25735979
Sl.No.
1.
2.
3.
4.
5.
Sl.No.
6.
7.
8.
9.
10.
11.
12.
13.
14.
15.
16.
17.
Central Office: 306, Kirti Mahal, 19, Rajendra Place, New Delhi 110008 Fax: 011-25735979
Sl.No.
Suggestions on information collection and / or report on accountability
18. Need for collection of additional data to be decided by the above committees under authorities
up to the category and amount suggested above.
19. Officer require to collect such data should be deputed from the respective offices under whose
authority the category and amount falls.
20. Officer deputed to collect data should have experience as branch incumbent of minimum 4 to 7
years with adequate knowledge on credit, forex and related area.
21. Officer deputed to collect data should not be junior to the officer heading the branch where
account has become NPA.
22. Staff strength of the branch at the relevant period and other infrastructure available at the
branch viz-a-viz the business figure should be commented upon in the report to be prepared so
as to bring out whether quality of work could be maintained viz-a-viz work load. This is more
applicable where mass loans are sanctioned, large number of instruments processed in RCC
etc., without adequate manpower to monitor and maintain quality.
23. A tolerance level for error of judgment should be introduced by preparing an exhaustive chart
showing performance of the concerned officer in the entire carrier as also in the immediate
past. This report should be prepared and submitted along with report on data collection to
enable authorities to arrive at accountability.
24. In case of perceived fraud in cheque payment or cloning of cheque an outside expert opinion
as to possibility of detection of defect in instrument is possible through naked eye or not
should be part of any such report.
Sl.No. Suggestions on examination of accountability and vigilance angle
25. All efforts should be made to collect information from the existing channels without resorting
to deputing any official from the respective offices as per jurisdiction for amount of advances
as suggested above. Only in select cases wherever adequate information is not available,
additional information be collected through simple format to capture cause of NPA as per
decision of the respective committees.
26. The officer so deputed should have the following experience:
a. Deputed by Circle Office should have experience of branch incumbency of 4 to 5 years
with adequate knowledge on credit, forex or related area on which data to be
collected.
b. Deputed by FGM Office should have experience of branch incumbency of 5 to 6 years
with adequate knowledge on credit, forex or related area on which data to be
collected.
c. Deputed by Head Office should have experience of branch incumbency of 6 to 7 years
with adequate knowledge on credit, forex or related area on which data to be
collected.
27. Once a report received from such official or collected through regular channel, the same
should be examined in terms of following:
a. Whether the information put up confirms to the laid down guidelines and within the
parameters fixed.
Central Office: 306, Kirti Mahal, 19, Rajendra Place, New Delhi 110008 Fax: 011-25735979
Sl.No.
28.
29.
30.
31.
32.
33.
34.
35.
Central Office: 306, Kirti Mahal, 19, Rajendra Place, New Delhi 110008 Fax: 011-25735979
(Dilip Saha)
GENERAL SECRETARY
Central Office: 306, Kirti Mahal, 19, Rajendra Place, New Delhi 110008 Fax: 011-25735979