Operational Risk Management (ORM)

Control Testing Exercise for an NBFC

A comprehensive review of key controls across various departments to ensure robust risk management.

Credit

Testing of controls related to loan application verification, credit scoring accuracy, and adherence to the credit approval matrix. The focus is on ensuring a robust and consistent evaluation process to minimize default risk.

Operations

Review of controls governing the end-to-end loan disbursement process, data entry integrity, and reconciliation of loan accounts. Key focus is on preventing manual errors and ensuring operational efficiency.

Collection

Evaluation of controls for adherence to fair collection practices, communication protocols with borrowers, and the process for escalating non-performing assets. This aims to mitigate legal and reputational risks.

Compliance

Testing to ensure compliance with all regulatory requirements (e.g., RBI guidelines), internal policies, and anti-money laundering (AML) procedures. A key control is the periodic review of policy documents.

Information Technology

Review of controls related to system development lifecycle, change management, and IT infrastructure maintenance. The goal is to ensure the reliability and security of core banking systems.

Information Security

Testing access controls, data encryption mechanisms, and incident response plans. The primary objective is to protect sensitive customer data and prevent cyber-attacks.

Customer Service

Evaluation of controls for complaint resolution, customer feedback mechanisms, and adherence to service level agreements (SLAs). This is crucial for maintaining customer trust and satisfaction.

Finance & Accounts

Review of controls over financial reporting, bank reconciliation processes, and expense management. The aim is to ensure the accuracy and integrity of financial data.

People Practices (HR)

Testing of controls related to payroll accuracy, employee data management, and compliance with labor laws. This mitigates risks associated with human resources and operational continuity.

Administration

Evaluation of controls for physical security, asset management, and vendor onboarding processes. Key focus is on safeguarding physical assets and ensuring vendor reliability.

Marketing

Testing of controls for marketing material approvals, adherence to regulatory guidelines for advertising, and managing brand reputation risks. This ensures ethical and compliant communication.

Secretarial

Review of controls for corporate governance, maintenance of statutory registers, and timely submission of filings to relevant authorities. This ensures the NBFC's legal standing and compliance.

Corporate Legal

Evaluation of controls for legal document review, contract management, and management of any litigation or legal disputes. This is crucial for mitigating legal and financial risks.

Treasury

Testing of controls related to cash flow forecasting, liquidity management, and fund transfer processes. This ensures the NBFC has sufficient funds to meet its obligations and operate smoothly.

Risk

The ORM team conducts this exercise, but also tests its own controls, such as the effectiveness of risk identification processes, risk assessments, and the accuracy of risk reporting.

Insurance

Review of controls to ensure appropriate insurance coverage for the NBFC's assets and operations, and proper management of claims processes.

Sales

Testing of controls on sales practices, lead generation, and the quality of customer onboarding. The focus is on ensuring a transparent and compliant sales process to prevent mis-selling.

CSR

Evaluation of controls related to the allocation of funds for Corporate Social Responsibility activities, tracking of project milestones, and reporting compliance.