Audited Entities' Attitudes Towards Recommendations (%)


Internal audits were not timely and complete, leading to many serious consequences. As one of the major cases of Agribank, although the Agribank Nam Ha Noi branch was inspected, checked and audited many times, no violations were detected.

Box 2.6: Internal audit fails to detect many violations

- Related to the case of loss of 2,500 billion VND at Agribank Nam Ha Noi.

Defendant Kieu Trong Tuyen - former Deputy General Director of Agribank, born in 1953, former Deputy General Director in charge of supplementing 34 documents related to inspection and audit related to the Nam Ha Noi branch. However, the results of this inspection and audit did not detect any violations , but only when the investigation agency came in did they discover the violations. No other branch has had so many inspections.

- Related to the case of Agribank Hong Ha Branch.

“Mr. Do Duc Hung, 56 years old, was prosecuted for “Abuse of power while performing official duties”. Two subordinates of Mr. Hung were also prosecuted for the above crime: Ms. Do Thi Minh Hien, born in 1968, former Head of Credit Department; and Mr. Truong Dang Dan (born in 1974), former Deputy Head of Credit Department.

According to the investigation documents, Mr. Hung signed many payment guarantees without records, without accounting, without collecting guarantee fees for a number of businesses, with a total amount of more than 345 billion VND. Currently, the amount of money that the related parties still owe each other is about 180 billion VND.

......

(Source: [96])

In terms of authority, the Auditor at Agribank has full access to all information sources and documents of the unit. Assuming the above is true, why is the internal audit still disabled in the face of risks and fails to detect loopholes in the business processes of the unit? NCS proposes the following hypotheses:

- Auditors have full authority to access information in theory, but in practice encounter many difficulties when auditing in the field due to the lack of cooperation of the audited unit.

- Auditors have full access to documents and records in practice, but due to the presentation


Limited capacity failed to detect the violations.

- Auditors have discovered violations but are not allowed to publish the conclusions due to pressure from all sides, so they are not decisive in giving their opinions in the audit report; or even auditors are hesitant to give their opinions due to fear of affecting personal interests while there are no regulations on responsibility that bind them to act decisively.

A leader of the internal audit department at Agribank shared his opinion: “ If the Government Inspectorate has the Inspection Ordinance, the State Audit has the State Audit Law, the Independent Audit has the Independent Audit Law and clear auditing standards, then currently the authority of internal audit in general is very limited, Agribank itself has not clearly defined the authority of the department, causing many difficulties in implementing the work, even in making conclusions, it must be very flexible, sometimes not daring to do it decisively .”

This is even more evident when comparing internal audits with independent auditors' assessments of Agribank's operating procedures.

Box 2.7: Ernst&Young's recommendations when auditing credit activities


Credit is a key business of the Bank, so credit risk management has been established and implemented more intensively than the management of all other types of risks. During the assessment of the current situation, we found some gaps scattered in each component of the Governance Framework, but not all. We will present some prominent issues in credit risk management in each main component of the Credit Risk Management Framework, including: i Credit risk management policies and procedures, ii Credit risk measurement and iii Credit risk management reporting system.

(i Credit risk management policies and procedures

Firstly , regarding the credit process, the Bank has issued lending regulations for customers in the system. However, the lending regulations are only specified into lending procedures for production households and individuals. The Bank has not issued regulations on lending procedures for business customers . The lack of specific regulations leads to the fact that the lending process is being applied inconsistently among branches in the entire system. In addition, according to the assessment


In our opinion, the current lending process does not meet the requirements for separation of responsibilities to ensure the independence and objectivity of the officers involved in the process. Specifically, except for loan appraisal work performed by independent appraisal officers for loans exceeding the prescribed materiality threshold, other tasks such as customer relations, customer information collection, customer scoring, collateral assessment, disbursement, and debt collection are mainly performed by credit officers. The lack of separation of tasks in the lending process leads to serious ethical and operational risks. A reasonable credit risk management structure solution can minimize these risks. Second , regarding credit limits, setting credit limits for customers is an effective way to manage the overall risk for a customer. Currently, the Bank has reviewed the credit limit annually for each customer at the branch level. However, the Bank has not established a centralized limit on the entire system , leading to the risk that the total credit limit for a customer across the entire system may exceed the customer's repayment capacity and the level of risk that the Bank can accept. In addition, the Bank has not yet reviewed the credit limit for a group of related customers.

an agency or an economic sector .

Firstly , regarding the management of collateral, although the bank has issued regulations on implementing loan security measures and applied them uniformly throughout the system, in the process of studying the current situation of collateral management at the Bank, we found that the regulations on collateral management still have many unclear and unclear points . For example, the criteria for accepting collateral, the list of accepted types of assets, regulations on asset valuation and revaluation including the frequency and criteria for valuation, asset management and monitoring processes, regulations on the loan ratio on the value of each type of collateral, etc. The bank needs to have stricter policies and procedures for managing collateral to prevent unforeseen risks or when the customer's expected repayment plan cannot be implemented.

Fourth , the Bank's problem debt management activities are being carried out in a scattered manner at branches because the Bank does not have specific policies and strategies for problem debt management . Specifically, the Bank has not issued regulations on identifying, handling and managing problem debt.

Fifth , the Bank has not yet issued specific policies, processes and procedures.


may be related to credit portfolio management activities , in which it is necessary to clearly state the orientation on portfolio management, methods of measuring portfolio risk, and measures to minimize risk. Currently, portfolio management activities are demonstrated through fragmented, unsystematic and passive procedures that are not supported by a system of tools and reports. In addition, the Bank has not established a specialized department responsible for risk quantification, management, supervision and monitoring of the credit portfolio towards building an optimal investment portfolio.

ii Credit risk measurement

Firstly , the Bank's internal credit rating system was built in 2007 and officially put into use in late 2011. The Bank uses this system for the purpose of debt classification, provisioning and supporting credit granting decisions. According to Basel requirements, the credit rating system needs to be authenticated annually to ensure the ability to differentiate between rating groups. However, the Bank has not yet implemented the authentication procedure for the internal credit rating system . In addition, the internal credit rating system has not been connected to and supported the Bank in calculating risk measurement parameters such as the probability of default (PD), expected loss ratio LGD, outstanding debt at the time of default (EaD).

Second , currently, the Bank only calculates the capital adequacy ratio (CAR) according to the regulations of the State Bank in Circular 13/2010/TT-NHNN issued on May 20, 2012, in which banks are required to maintain a minimum capital adequacy ratio of 9%. Due to the lack of requirements from the State Bank, the Bank has not applied the calculation of capital requirements for credit risk according to the regulations of Basel II . The Bank can apply one of three methods: the standardized method, the basic method based on internal ratings, the advanced method based on internal ratings to determine risk measurement parameters such as probability of default (PD), expected loss ratio LGD, outstanding balance at the time of default (EaD) and maturity (M), from which the required capital can be calculated.

iii) Credit risk management reporting system

The Bank uses the IPCAS core banking system to collect and store credit data. From a loan perspective, information related to loans and collateral is stored relatively completely. However, the Bank has not yet established a reporting system for credit risk management purposes nor has it developed an accompanying reporting mechanism .

Source [8]


After making general assessments, the independent auditor also makes specific assessments and makes recommendations so that the bank can overcome and limit future risks. A separate example is in section (i) Credit risk management policies and procedures.

Box 2.8: Credit process recommendations


Problems

Assess the current situation

Recommendation

Credit policy

The Bank has issued documents related to credit policies from the perspective of each loan. However, these policies are issued sporadically and do not ensure systematicity in documents and regulations….

From a portfolio perspective, the Bank does not have a risk management process.

list

Banks need to have a credit policy that establishes criteria and procedures for granting credit, monitoring, supervising and managing credit at the individual loan and portfolio levels.

Limit

credit

for a customer

The Bank has not set an overall limit for each customer across the system, except for compliance with the 15% equity limit as prescribed by the State Bank. Thus, in the case of a customer having credit relationships with many branches, the total credit limit granted to that customer may far exceed the customer's ability to repay as well as the ability to accept risks.

Bank risk

The Bank should determine a credit limit for each customer. The credit limit should be determined based on the customer's ability to repay (e.g. a higher rated customer may have a higher limit) and the Bank's risk tolerance.

Credit limits should be reviewed periodically and adjusted based on changes in the customer's ability to repay and economic conditions.

Credit Limit – Limit

for one

group

The bank has not yet set specific limits for different customer groups. The bank is still having difficulty in determining

related customer groups due to:

Banks need to set credit limits for each relevant customer group so that they can compare and contrast the types of risks in their bank books.

goods and on the transaction book, internal and

Maybe you are interested!

Audited Entities Attitudes Towards Recommendations (%)


related customers

1 The definition of the relevant customer group of the State Bank is quite broad.

According to Circular 13/2010/TT-NHNN, therefore, the Bank needs to determine specific criteria to identify relevant customer groups; (2) due to culture and habits, collecting information about relevant customers from borrowers is very difficult.

Cases of exceeding the limit for the relevant customer group must

approved by the State Bank

off balance sheet

Banks should determine credit limits for each relevant customer group.

The Law on Credit Institutions of Vietnam stipulates that the credit limit for a group of related customers must not exceed 25% of the equity capital of a commercial bank.

128.1 - Law on Vietnamese credit institutions).

Collateral Management Policy and Procedures

The Bank has issued a policy on collateral for securities in 1300/QD-HĐQT-TĐHo.

This regulation does not comply with international practices because it only mentions the following sections: Conditions for accepted collateral, Types of collateral, Authority to accept collateral, Maximum loan-to-collateral ratio.

This Decision does not clearly define the types of accepted collateral, the criteria for asset valuation, and the process for monitoring and managing collateral.

revaluation frequency of assets

Banks should have formal regulations on the types of collateral accepted, the process for valuing collateral, and the process for checking the legality and validity of collateral in the present and future.

The Board of Directors or its authorized agencies shall approve the regulations and specify the procedures related to collateral.

Source: [ 8 ]

Thus, when asked to advise on credit processes, in addition to the ability to raise phenomenal issues, E&Y independent auditors are also able to explain the causes and recommend very clear solutions, with the goal of perfecting the internal control process to limit risks in the process.


future. From such recommendations for editing and perfecting the process, Agribank has updated and issued many new, more suitable decisions. For example, Decision 1300/QD-HDQT-TĐHo has now been replaced by Decision 35/QD-HDTV-TDHo on secured transactions... So why has internal audit, whose main role is to advise on improving processes, regulations, and activities in the bank, not been able to do so over the years?

- Third: The attitude of audited units is often not easy to accept the conclusions of the internal auditor.

When issuing these reports, the auditor will send them to the audited unit to discuss the results of the work. Most of the audited units are satisfied (68.2%), but for the rest, the auditor often receives reactions from the business unit, in many cases the unit has to reluctantly accept. This is not too difficult to understand because business units often pursue profit and sales targets, so they have to sacrifice compliance with laws, regulations, and procedures. Therefore, when the auditor discovers and requests acceptance of the findings, the units often do not easily accept.

Chart 2.5: Attitude of audited entities towards recommendations (%)


Not accepted, 0

Accept, dissatisfied, 31.8

Satisfied, 68.2

Very satisfied, 0

- Fourth: The time to issue audit reports is quite fast.

The audit release time is usually quite fast, in line with international practice, usually 7-10 days after the audit is completed.


Table 2.12: Time of issuance of audit report


Time of audit report release

Usage rate (%)

Not included

hour

Seldom

Please

occasionally

Often

through

1. Immediately after the audit is completed

0.0

4.5

90.9

4.5

2. After 01 week to 10 days from the end of the audit

0.0

0.0

9.1

90.9

3. After 02 weeks from the end of the audit

100.0

0.0

0.0

0.0

4. After 1 month from the end of the audit

100.0

0.0

0.0

0.0

5. Unstable, sometimes fast, sometimes slow depending on the situation

100.0

0.0

0.0

0.0

(Source: Author's survey)

Step 4: Post-audit Monitoring Phase:

Conducting a survey using a questionnaire, the author obtained the following results:

Table 2.13: Current status of the audit department monitoring its recommendations



Monitoring of recommendations

Usage rate (%)

Are not

ever

Rare

When

Please

occasionally

Often

through

1. Yes, immediately after the audit is completed.

0.0

0.0

13.6

86.4

2. Yes, in the next audit

68.2

4.5

27.3

0.0

3. Yes, next year

90.9

4.5

4.5

0.0

4. Do Not Track

100.0

0.0

0.0

0.0

(Source: Author's survey)

Thus, the audit department regularly monitors its recommendations from the previous year to the unit to see the progress of handling and correcting violations. The implementation of the unit's recommendations is not immediate, but not too late, usually taking place within 1 year from the date the audit report is signed and accepted.

Comment


Agree Privacy Policy *