ASM(AGENCY FOR SPECIALIZED MONITORING) – DOCUMENTS & PROCEDURE FOR APPLICATION

An Agency for Specialized Monitoring (ASM) is a mechanism of the bank, which allows it to take several steps to prevent or minimize the number of money laundering cases and misappropriation of funds. ASMs are committed to providing due diligence support in India.

ASM audits involve extensive analysis of a company’s transactions, operations, and financial health. The broad scope of ASM Audit work involves the following activities:

  • Stock & Receivable Audit
  • Cash flow Monitoring
  • Sales/Purchase Monitoring
  • End Use of Funds/Siphoning of Funds
  • Verification of group company transactions at arms-length
  • Validation of Drawing Power as per Banks’ sanctioned terms
  • LIE Work for Term Loans/Projects
  • Review of project progress vis-a-vis scheduled milestones, Capacity Utilization, asset book size, quality and diversification.
  • Verification of re-valuation of assets if any
  • Verification of routing of project revenue and expenses through designated bank accounts
  • Verification of project expenses, payments to creditors and advances to suppliers
  • Review of unbilled revenue and WIP and justifiable reasons for the same
  • Litigations/Contingent Liabilities including letters of comfort
  • Pre-disbursement verification of some specific high value transactions as the Banks may deem necessary
  • External Ratings, statutory and regulatory compliances, insurance cover.
  • Assessment of Quarterly Key Financial Indicators/Movement in stock exchanges
  • Movement in promoter holding in the company from time to time and percentage holding pledged to financial institutions and banks to raise capital
  • Any other Key Areas Review (KAR) which the Banks find necessary to be monitored

DOCUMENTS REQUIRED TO BE SUBMITTED:

The Firm / Company shall submit their application / details in the prescribed format (self-attested)

  • Registration with professional bodies / organizations.
  • GST Registration Certificate
  • Details of all the Key Personnel comprising their name, qualification and their education.
  • CV as per format provided of all key personnel, including that of technical / financial experts.
  • Memorandum and Articles of Association along with Certificate of Incorporation for company / registered partnership deed along with the Registrar of Firm certificate in case of partnership firms
  • Audited Balance sheets along with all annexure for preceding 2 years
  • Other documents supporting their expertise in any particular field
  • Letters of empanelment from other banks / financial institutions, if any
  • Details of projects undertaken as per format provided
  • Letters of assignments from other clients / lenders.

All these documents need to be complete and shall be uploaded successfully. No manual submission is required for the application under ASM.

FEE STRUCTURE FOR APPLICATION OF ASM (2022-23):

  • Application Fee for Fresh Empanelment is Rs.50,000 and for the Renewal of registration is Rs.25,000.
  • After being shortlisted, Empanelment Fee is Rs.1,00,000 for General Category and Rs.1,50,000 for Specialized category (irrespective of being fresh applicant or existing applicant).
  • The Fees mentioned above is non-refundable under any circumstance and exclusive of GST.

PROCEDURE TO APPLY for ASM:

  1. Invitation for application by IBA (https://www.iba.org.in/)
  2. Submission of application with supporting documents (details mentioned below) by ASMs
  3. Successful Payment of stipulated application fees by the ASMs
  4. Scrutiny of the application and eligibility by the Working Group constituted by IBA
  5. Finalization of eligible agencies for empanelment
  6. Payment of stipulated Empanelment fees by the ASMs
  7. Approval of the panel by the Managing Committee of IBA
  8. Publication of the approved list of empaneled ASMs
  9. Sharing of the approved panel with member banks

AFTER APPLICATION

  • After submitting the application, the applicant shall wait for being shortlisted. The shortlisting process would take a period of around a month.
  • Once shortlisted, the applicant would receive a mail from IBA for further payment of Rs.1,00,000/ Rs,1,50,000 as per the General/Special category respectively. Once the Payment has been made, it would be represented by the “Tick” on the Payment Tab.
  • The category (General/Special) would be decided and mentioned in the mail by the Managing Committee accordingly.

FINAL SELECTION

  • Once the additional amount has been paid, IBA would take minimum of 30 days to process all the applications.
  • The final decision shall be declared by IBA through a mail. If the firm has been empaneled for taking us ASM assignments, an empanelment letter would be attached in the mail. That empanelment letter has to be signed by the authorized signatory and shall be uploaded in the online portal under the ‘Confirmation’ tab.

AGENCY FOR SPECIALIZED MONITORING(ASM)

WHY ASM?

As indicated by the RBI, frauds had arisen as the most genuine concern in the administration of functional risk, with 90% of them situated in the credit portfolio of banks. Due to ever increasing frauds and the amount of non-Performing assets increasing drastically in every bank in India, RBI took the stand and introduced new reform, i.e., Agencies for Specialized Monitoring (ASM).

 Indian Bank’s Association (IBA) has impaneled 83 agencies to monitor stressed loan accounts and regulate the cash flows of banks.

WHAT IS ASM?

ASM is an external agency (Chartered Accountants) which is introduced to monitor large credit exposures and huge advances of Banks/Consortium of banks. Consortium refers to the coming together of banks to sanction the limits for a certain purpose. There is always a Lead bank in a Consortium who has the majority power over others.  Lead bank in a consortium of bank will select any particular agency and give the assignment to it for monitoring of account.

An Agency for Specialized Monitoring (ASM) is a mechanism of the bank, which allows it to take several steps to prevent or minimize the number of money laundering cases and misappropriation of funds. ASMs are committed to providing due diligence support in India. In the banking world, the explanation for due diligence support & services involves an in-depth investigation and analysis of the business or person’s credits, assets, and liabilities. A bank before investing or finalizing a transaction in a business initiates acquisition or gives out a loan to a customer to ensure that the deal would be lucrative and safe for the bank.

PURPOSE OF ASM:

With the effect of reporting under ASM, we come to know the problem in advance like inventory buildup, delay in receivables and diversion of funds. All the transactions will be under a strict vigilance. As employees of the banking industry don’t have such expertise in all the sectors and related business transaction, the services of ASM to closely track the activity of complex nature of transaction of borrower is to be tracked on each stage.

APPLICABILITY:

ASM will be applicable to all the debtors where exposure is above Rs.250 crores. The scope of work includes:

  • Regular auditing and scrutinizing deviations or fluctuations.
  • Monitoring of cash flow and transactions.
  • Analyzing of the organization’s work input and output.
  • Checking for misappropriation of funds or diversion of funds.
  • Ensuring compliance of terms and condition of sanction.
  • Extensive analysis of a company’s transactions, operations, and financial health.
  • Analyzing of Fund Flow Statement.

ASM is an entity having Chartered Accountants with good domain knowledge, experience and skill in different sectors, industries etc. In case of large exposure or exposure of specialized nature, such agency provides services of inspection, stock audit, cash flow monitoring and end use verification etc.

After bringing ASM to the banking world, Chartered Accountants have to be more careful and work diligently towards the responsibility of reporting under ASM.

FOCUS AREAS:

Under ASM, Chartered Accountants does not have to necessarily check all the transactions, they mainly checks the transactions which are above the exposure limit. The main focus areas are:

REPORTING REQUIREMENTS:

There are some important areas which shall be covered by the firm under ASM reporting, these are-

  • Physical verification of stock shall be verified and reported with the help of GR note, e-way bill, etc.
  • Bank statements need to be verified extensively and sanction of drawing limit shall be checked.
  • Inventory Holding, Working Capital, Debtors, Ageing, Ratios, Shareholding Pattern etc.; all need to be checked thoroughly.
  •  Documentation of working papers shall be managed properly by the Agency.
  • Any change in the industry and its impact on the client shall also be included in the report.
  • Disclosure of any contingencies and legal issues shall be reported.
  • And, report shall also specify whether the client has cooperated with the Agency and justifications for the same.

Along with these issues, report shall also include any disaster covered or any value addition or adverse remark by the company and any comment on the overall health of the company, whether good or bad as per the respective Chartered Accountant.