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Date: 2024-01-31 Category: Not Applicable State: Union Government Country: India

Streamlining of Internal Compliance monitoring function – leveraging use of technology

Issued by Reserve Bank of India · Not Applicable

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Executive Summary & Key Takeaways

**Summary:** The Reserve Bank of India (RBI) has issued a directive (DoS.CO.CSITEG.SEC.No.93101015/2023-24) on January 31, 2024, addressing the streamlining of internal compliance monitoring functions through the leveraging of technology. This directive is applicable to Scheduled Commercial Banks (excluding Regional Rural Banks), Small Finance Banks, Payments Banks, Primary Urban Cooperative Banks (Tier III and IV), Upper and Middle Layer Non-Banking Financial Companies (including Housing Finance Companies), Credit Information Companies, and All India Financial Institutions (EXIM Bank, NABARD, NaBFID, NHB, and SIDBI). The RBI's assessment of select Supervised Entities (SEs) revealed varying levels of automation in compliance monitoring, often relying on manual intervention. The RBI emphasizes the need for comprehensive, integrated, enterprise-wide, and workflow-based solutions to enhance the effectiveness of this function. These solutions should facilitate communication and collaboration among stakeholders (business, compliance, IT, and senior management), support the identification, assessment, monitoring, and management of compliance requirements, escalate non-compliance issues, record approvals for deviations or delays, and provide a unified dashboard view of the Regulated Entity's (RE) overall compliance position to senior management. The choice of specific tools and mechanisms for compliance monitoring and unified dashboard development is left to the RE, based on its size and operational complexity. Regulated Entities are directed to conduct a thorough review of existing internal compliance tracking and monitoring processes and implement necessary changes or new systems by June 30, 2024. An appropriate monitoring mechanism should also be established to track the progress of implementation. For acknowledgements or further information, contact T K Rajan, Chief General Manager, CSITE Group, RSD, Department of Supervision, Central Office, 13th floor, Maker Tower E, Cuffe Parade, Mumbai – 400005. Telephone: 91 22 22189131/39; Fax: 91 22 22180157; Email: csiterbi.org.in.

Key Entities Referenced

Reserve Bank of India: The central bank of India, responsible for regulating the banking system. Scheduled Commercial Banks: Banks in India excluding Regional Rural Banks that are listed in the Second Schedule of the Reserve Bank of India Act, 1934. Regional Rural Banks: Regional Rural Banks in India. Small Finance Banks: A type of niche bank in India. Payments Banks: A type of niche bank in India, that can accept deposits and remittances. Primary Urban Cooperative Banks: Urban Cooperative Banks in India. Non-Banking Financial Companies: Financial institutions that provide banking services without meeting the legal definition of a bank. Mumbai, Maharashtra: City in India where the central office of Reserve Bank of India is located.
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भारतीय �रज़व र् बक� RESERVE BANK OF INDIA www.rbi.org.in ___________________________________________________________________ RBI/2023-24/117 DoS.CO.CSITEG.SEC.No.9/31-01-015/ 2023-24 January 31, 2024 The Chairman/Managing Director/Chief Executive Officer Scheduled Commercial Banks (excluding Regional Rural Banks); Small Finance Banks; Payments Banks; Primary (Urban) Co-operative Banks (Tier III and IV); Upper- and Middle-Layer Non-Banking Financial Companies (including Housing Finance Companies); Credit Information Companies and All India Financial Institutions (EXIM Bank, NABARD, NaBFID, NHB and SIDBI) Madam/ Dear Sir, Streamlining of Internal Compliance monitoring function – leveraging use of technology RBI had recently carried out an assessment in select Supervised Entities (SEs) of the prevailing system in place for internal monitoring of compliance with regulatory instructions and the extent of usage of technological solutions to support this function. It is seen that SEs have adopted varying levels of automation to support this function, ranging from use of macro-enabled spreadsheets to workflow-based software solutions. The review brought out that automation of the compliance monitoring process in SEs remains a work in progress with various aspects of this function being carried out with significant manual intervention. There is, thus, a need to implement comprehensive, integrated, enterprise-wide and workflow-based solutions/ tools to enhance the effectiveness of this function. 2. Such a solution/ tool should, among other things, provide for effective communication and collaboration among all the stakeholders (by bringing business, compliance and IT teams, Senior Management, etc. on one platform); have processes for identifying, assessing, monitoring and managing compliance requirements; escalate issues of non-compliance, if any; require recording approval of competent authority for deviations/ delay in compliance submission; and have a unified dashboard view to Senior Management on compliance position of the Regulated Entity पयर्वेक्षण िवभाग, क��ीय कायार्लय, वल्ड र्�ेड स�टर, कफ परेड, मुंबई 400005 CSITE Group, RSD, Department of Supervision, Central Office, 13th floor, Maker Tower-E, Cuffe Parade, Mumbai 400005 Te1e: +91 22 22189131-39; Fax +91 22 22180157; email: csite@rbi.org.in(RE) as a whole. The RE, based on the size and complexity of its operations, may decide on the tools/ mechanism it would prefer to deploy for monitoring of compliance and development of the unified dashboard. 3. Accordingly, REs are advised to carry out a comprehensive review of the existing internal compliance tracking and monitoring processes and institute necessary changes to existing systems or implement new systems latest by June 30, 2024. 4. An appropriate monitoring mechanism may also be put in place to review the progress of its implementation. 5. Please acknowledge receipt. Yours sincerely, (T K Rajan) Chief General Manager 2

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