Investment Securities Audit Program by fanzhongqing

VIEWS: 18 PAGES: 4

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                                     I. OBJECTIVES

1.   To determine if policies, procedures, practices, and internal controls regarding
     investments are adequate; that officers/employees are operating in accordance with
     established guidelines.

2.   To ensure transactions are properly authorized, recorded, and executed at current
     market prices; that securities, as recorded, are on hand or in possession of custodians
     for the bank's account.

3.   To determine that subsidiary records are reconciled on a regular basis and are in
     agreement with G/L control accounts.

4.   To determine that accrual of income, amortization of premiums, and accretion of
     discounts are appropriate and accurate.

5.   To determine compliance with laws, rulings, and regulations.

                                      II. PLANNING

1.   Complete Section I of the Audit Planning and Review Guide.

                             III. PRELIMINARY REVIEW

1.   Request appropriate person(s) to complete, sign and return, the Internal Control
     Questionnaire.

2.   Obtain copies of investment policies and procedures. Review for potential control,
     and/or operational weaknesses. Basic investment policy objectives should include the
     following:

          Guidelines on the quality and quantity of each type of security to be held, with
            the stipulation that securities acquired will be eligible and in amounts conform-
            ing to the limitations prescribed by 12 USC 24 (7) and 23 CFR 1;

          A program for obtaining and evaluating current credit information on securities
            in the portfolio, including credit analysis /reviews prior to purchase and
            periodic credit updates;

          Risks diversification, i.e., credit risk, interest rate risk, and market risk, associ-
            ated with concentrations in holdings;

          Generating a favorable return on investments;

          A well defined maximum allowable maturity program in meeting liquidity
            requirements;

          Meeting pledging requirements.

3.   Determine policies/procedures reflect FASB-115, "Accounting for Certain Investments
     in Debt and Equity Securities", (effective 1/1/94), including;

          Classification of investments into 3 categories, i.e., Available-for-Sale (AFS),
            Held-to-Maturity (HTM), and Trading Account;

          Description of accounting requirements;

          Pricing and periodic evaluation;

          Disclosures for sales and transfers.

4.   Supplement review of policy and procedures with control reviews /interviews with
     Investment Officer and other personnel, as appropriate. Document/update permanent
     file for the following:
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               Discuss/describe risk diversification associated with concentrations in
                holdings, in the portfolio, and how controlled /managed;

               Discuss/describe investments maturity program in meeting the bank's
                liquidity requirements, i.e., anticipated loan increases, deposit decreases, and
                unexpected liquidity demands;

               Discuss/describe Investment Committee and BOD approvals, if and when
                required, under what circumstances (obtain copies for PF);

               Discuss/describe selection and approval of securities dealers and determine
                whether the BOD or Committee has reviewed/approved a list of securities
                firms (obtain copy for PF) with whom the bank is authorized to do business.
                The dealer selection process should include:
                      ability to fulfill commitments, as evidenced by capital strength and
                          operating results disclosed in current financial data;
                      general reputation for financial stability;
                      inquiry/knowledge of any enforcement actions against the dealer,
                          affiliates, or associated personnel;
               inquiry, as appropriate, into the background of the sales representative to
                determine experience and expertise;Discuss/describe securities trading
                activities, to what extent, if and when allowed;
               Discuss/describe securities lending activities, to what extent, if and when
                allowed;

               Discuss/describe overall impact of FASB-115 on the bank's investment
                strategy and efforts to comply with its requirements, including:
                      the process used in determining the quality and quantity/amount of
                         the types securities placed in each investment category;
                      actual or perceived impact to the bank's balance sheet brought about
                         by the accounting changes (good, bad, or indifferent);

               Inquire of the Investment Officer whether off-balance sheet derivative
                products, i.e., interest rate swaps, futures contracts, etc., are utilized in the
                investment decision making processes. If so, determine that:
                     derivatives activity is conducted under close Management and BOD
                         supervision;
                     valuation of derivatives and positions in determining the risks in-
                         volved;
                     policies/procedures governing these activities are detailed including,
                         prohibition on the use of leveraged and complex derivatives with
                         limitations on the total amount of derivative contracts that may be
                         outstanding at any time.

               Note: Derivative products are used by financial institutions to improve
               its balance between interest-sensitive assets and interest-sensitive
               liabilities in managing interest rate sensitivity, while continuing to meet
               the credit and deposit needs of its customers. Properly managed, the
               use of non-complex, non-leveraged derivative products can reduce the
               potential negative impact on net interest income in a rising interest rate
               environment.

5.   Based upon review of the ICQ and this preliminary review, conclude on the adequacy,
     effectiveness, and efficiency of the internal control systems over investment securities
     operations /functions.

6.   Document any significant weaknesses in the General Binder, Section GB-6, Possible
     Report Comments. Also, identify audit priorities and consider the need to adjust
     procedures.

                                     IV. AUDIT STEPS

     Balancing
1.   Obtain subsystem reports and reconcilements for all investment accounts, related
     income/expense accounts, and any suspense/clearing accounts, as of our audit date;
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              Foot reconcilements and verify mathematical accuracy;

              Trace subsystem totals from reconcilement to supporting subsystem reports;

              Trace G/L totals from the reconcilement to the Daily Balance Sheet;
              Trace all reconciling items to clearance and investigate any old and unusual
               items.

2.    Determine the bank's subscription of Federal Reserve Stock equals 6% of the bank's
      capital and surplus, of which, 3% must be paid in.

              Recalculate dividend income and trace to G/L.

     Confirmations
3.    Prepare and mail confirmation requests for securities held in safekeeping by
       correspondent banks and other custodians, as of audit date;

              Compare securities safekeeping lists received from the correspondents/agents to
               the bank's securities inventory report;

              Determine pledge status is properly noted;

              Investigate and clear all exceptions;

              Send second requests to safekeeping agents from whom no reply was received.

4.    Examine/count any securities on hand and compare details to the securities inventory
      report;

              Account for all bond coupons, if any;

              Investigate any discrepancies.

      Tests of Security Transactions
5.    Select a sample of investments purchased, since the previous audit, and perform the
      following:

              Verify cost by examining invoices/advices;

              Trace purchases to entries in the G/L;

              Trace purchase transactions to approval in the Investment Committee or BOD
               minutes.

6.    For securities sold, verify that gains or losses were accurately computed and recorded;

              Verify sales price by examining invoices and broker's advices;

              Check computation of book value on settlement date;

              Calculate gain or loss and trace to G/L;

              Verify G/L has been properly relieved of the investment, accrued interest,
               premium, discount, and any other related accounts;

               Trace sales transactions to approval in the Investment Committee or BOD
                minutes.

      Premium Amortization/Discount Accretion
7.    For investments purchased at a premium or discount, since the previous audit, select a
      sample and test book value, by performing the following:

             Determine method used to calculate and record amortization of premiums and
              accretion of discounts; and
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          Determine the gross amount of premium or discount at purchase date;
          Determine period to maturity or call date;
          Calculate the amount of premium or discount remaining to be amortized or
           accreted;
          Determine that book value is properly reflected in the general ledger;
          Investigate any discrepancies.

       Accrued Interest
8.     Determine the bank's method of calculating and recording interest accruals. Using the
       sample selected in Step 7, test accrued interest:

          Obtain trial balance of accrued interest, if maintained separately, from trial balance
           of investments and;
                            Determine interest rate and last interest payment date;
                        Calculate accrued interest and compare to the trial balance;
                        Investigate any significant discrepancies.

9.     Prepare, a schedule, for each kind of investment, showing accrued interest balance and
       investment balance at each quarter end, since last audit:

          Calculate the ratios of accrued interest to investment balance for each type and time
           period;

          Investigate significant fluctuations/trends.

       Other
10.    Review the bank's compliance with FASB-115, "Accounting for Certain Investments in
       Debt and Equity Securities".

               Note: FASB-115 places many restrictions on the sales /transfers of
               Held-to-Maturity (HTM) securities and such transactions are expected
               to be unusual and rare.

          Review all sales/transfers out of the HTM category, since previous audit, and verify
           that:
                   o Sufficient documentation exists outlining intent /circumstances leading
                        to decision;
                   o Reasons comply with FASB-115 requirements for changes in circum-
                        stances;
                   o The BOD, as noted in the minutes approves such transactions.

          Determine whether portfolio classifications are periodically re-assessed for
           appropriateness (quarterly);
                Those adjustments, as applicable, are properly recorded on the bank's
                   books.

11.   Review the bank's compliance with OCC's Investment Securities Regulation (12CFR1).

								
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