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Internal bank control and its types. Organization of current control in the bank. Subsequent control and methods for its implementation. Internal audit: goals, objectives and features of the organization in the bank.

Control in a commercial bank and its organization

Internal bank control and its types

An important area of ​​banking activity is the organization of internal bank control. General requirements the need for internal control in a credit institution is determined by the federal laws “On the Central Bank of the Russian Federation”, “On Banks and Banking Activities”, “On the Securities Market”. Intrabank control is characterized as a set of techniques and methods used by the bank to control its transactions. However, internal control cannot be viewed as a simple one-time procedure.

Internal control is a process that is constantly carried out at all levels of banking activities, which must be carried out in the bank by the board of directors, senior officials, senior officials and employees of all levels of management. Internal bank control allows you to create a system that provides a complete and high-quality audit of the bank’s activities in all areas. Responsibility for the formation of an internal control system rests with the bank's management team, but every bank employee must be involved in this process.

The main purpose of the internal control system in a bank is to check:

compliance with current legislation;

compliance of the credit institution’s activities with its development plan;

reliability, efficiency and completeness of financial and management information;

rationality of measures taken to maintain liquidity, profitability and stability of the bank.

The internal control system includes the actual control of banking activities, as well as the organization of monitoring in all areas of the bank’s work, which consists of constant monitoring of the work of all departments commercial bank in order to assess the effectiveness of their work and develop strategic plans for further improvement and development of the banking business. Based on the results obtained during the monitoring process, the bank’s management makes decisions, the implementation of which should lead to the elimination of existing shortcomings in the bank’s activities and the normalization of the financial position of the commercial bank.

The effectiveness of organizing an internal bank control system depends on a number of external and internal factors. External factors include, first of all, the presence of the necessary regulatory framework for organizing an internal control system. Internal factors include the presence of specialists who can qualitatively and quickly assess the current situation in the bank and give qualified recommendations on minimizing the risks of banking activities. To carry out intrabank control, a special unit must be created in the bank. An important factor in ensuring an effective internal control system is the creation in the bank of a system for identifying and assessing banking risks. And finally, a prerequisite for conducting high-quality internal control is the availability of complete and reliable information about the state of affairs both in the bank itself and in competing banks.

The current system of internal bank control includes current and subsequent control in banks and the organization of internal audit. Let us dwell in more detail on the characteristics of each type.

Organization of current control in the bank

Current banking control is carried out in the process of daily banking operations at each of the areas of organizing the work of the accounting and operational apparatus. Thus, when organizing document flow, the main purpose of current control 1 is to verify the legality of transactions and compliance with established | rules for their implementation and correct execution of documents. When organizing current control, significant attention is paid to checking the analytical and synthetic accounting registers at the close of the operating day. This is done by responsible executives, accountants of the operational department, employees who control their work, as well as heads of bank departments. In the process of carrying out current intra-bank control, they are guided by the current regulatory documents and rules for conducting certain banking operations.

Responsible executives, when accepting payment documents from clients, monitor the correct completion of all necessary details and check the availability of funds in the organization’s current account. The documents submitted for payment are also checked from the point of view of the legality of the transaction being performed. Essentially, at this stage, the bank employee determines the intended purpose of using the client’s funds. Great responsibility falls on the accountant when carrying out various forms of non-cash payments, the choice of which the client makes independently together with his counterparty. The task of the responsible executive and controller of the bank is to verify compliance with the principles of organizing non-cash payments. For example, when using payment requirements in calculations, a bank employee checks the availability of shipping documents confirming the shipment of goods, performance of work or provision of services. If the client refuses to accept the same payment request, it is necessary to verify its legality, correct execution and compliance with the deadline established for this procedure. Other forms of payment that the client uses in his payment transactions are subject to the same thorough check. Special attention requires verification of compliance with all requirements for letter of credit, check and bill forms of payment. If there are insufficient or no funds in the client’s current account, the bank employee is responsible for the timely entry of payment documents into file cabinet No. 2 and their payment as funds arrive in accordance with the order of payments established by law.

Upon enrollment Money, received by the client, the responsible executive must ensure that the copy of the document received from the payer contains the signature of an employee of the paying bank, i.e. check the authenticity of the document. Transactions related to non-cash transfers of funds are subject to special control. individuals in deposits. This is necessary to avoid errors in crediting funds to account holders. When opening and maintaining a client’s loan account, the correctness of drawing up urgent obligations for loan repayment is checked and daily monitoring is carried out over the timeliness of its repayment.

Certain types of banking operations are subject to double current control. Thus, applications for the issuance of checks and checkbooks, acceptance of payment orders, in addition to the responsible executor, are certified by the signature of the controller. All monetary settlement documents and records in analytical accounting for the accounts of military personnel and citizens, fixed assets of the bank, other material assets, collection of fines from clients for violation of the rules for conducting settlement transactions, for settlements with self-supporting enterprises of the bank, for the formation of operating bank income and expenses], etc. Operations on transit and current subaccounts, on personal pension accounts, on state budget accounts, and on loan accounts of individual borrowers also require double control. In some cases, by decision of the bank, other operations are controlled in a similar manner.

Particular attention is paid to the organization of current control in the process of cash transactions. A significant place here is given to preliminary control when performing expense cash transactions. In this case, control is entrusted to three employees of the credit institution involved in this operation: the responsible executive, the controller and the cashier. The task of organizing control in this area is to prevent payment for incorrectly executed documents without prior verification by the responsible executor. The controller's task is to check the correctness of execution of each expense cash document.

When a client receives cash using a personal check, the controlling employee must make sure that there is a mark on the check indicating that the recipient has presented a passport or other document proving his identity. In addition, the check or expense order must contain his receipt of funds. When a cash receipt is received, the signatures of the persons authorized to sign it and the client’s seal are compared with the samples available to the responsible executor and the controller, indicated on the corresponding card. The controller and cashier also compare the signature of the responsible executor with the available sample. All expenditure cash documents are subject to careful control by the cash employee.

The chief accountant of the bank is responsible for organizing current control. He directly controls the correct execution of transactions for opening settlement and current accounts of clients, organizes ongoing control and daily monitoring of its implementation in all areas of the bank’s accounting, operational and cash operations. The responsibilities of the chief accountant and his deputy include monitoring the introduction of corrections to personal accounts, the opening and closing of accounts, the calculation of interest on them, the movement of strict reporting forms and cash receipts. The bank's chief accountant checks the conclusion of cash transactions daily; the completeness of the posting of money, both collected and received at the evening cash desk; correct formation and storage of all monetary settlement documents and other accounting documentation. Every day he monitors the timeliness and quality of compiling a summary of bank balance sheet turnover for the day.

Subsequent control and methods of its implementation

In the process of carrying out intrabank control in a bank, an important place is given to the correct organization of subsequent control, the purpose of which is to systematically check all areas of accounting and operational work in the period after banking transactions. The following tasks of organizing subsequent control can be identified:

checking accounting and document flow;

confirmation of the correct performance by employees of the accounting and operational apparatus of the duties assigned to them

checking the legality and correctness of execution of transactions performed.

In a credit institution, the work on subsequent control is headed by the chief accountant, his deputies, and in large banks This is done by special subsequent control inspectors. Subsequent inspections are carried out according to plans, which are thematic in nature and drawn up quarterly. Both comprehensive inspections and inspections affecting only certain areas of accounting and operational work can be carried out. An example would be conducting an audit of only cash or only memorial documents for a certain period of the bank’s activities. In the process of conducting a comprehensive audit, the entire scope of work of certain responsible performers is examined. Typically, plans for subsequent inspections are drawn up in such a way that during the quarter all areas of accounting and operational work are subsequently monitored.

In the course of subsequent control, documents that were not subject to control by the chief accountant and his deputy are examined on a selective basis. During the verification process, the legality of the transaction, the correctness of their execution and reflection in accounting are established. After establishing the legality of the transaction, the correctness of the documents is checked: compliance with the form, the presence of all necessary details, accounting entries, as well as compliance with the available sample signatures and seal imprint on the document. Close attention is paid to the presence in payment orders, payment requests, settlement checks, references to the numbers and dates of shipping documents confirming the fact of shipment of goods, performance of work and provision of services. In this case, a random comparison can be made of the first copies of payment documents with the copies on the basis of which entries were made in correspondent accounts.

An audit is carried out as a follow-up control. Areas of the bank's accounting and operational work that were subject to audit or inspection are allowed not to be checked over the next three months.

The results of inspections and audits are reviewed by the management of a commercial bank, which results in the development and implementation of measures to eliminate identified deficiencies and prevent their occurrence in the future. As a rule, control over the elimination of deficiencies identified by subsequent periodic audits is directly carried out by the chief accountant of the bank.

The president of the bank bears overall responsibility for the state of accounting, organization of document flow and control in a commercial bank. His responsibilities include ensuring that the daily bank balance is compiled on time and is presented to him for signature.

Internal audit: goals, objectives and features of the organization in the bank

In addition to current and subsequent control, in each commercial bank, in accordance with the current regulatory documents of the Bank of Russia, an internal audit system must be created and function effectively. Internal audit can be considered as a system of bank security measures to ensure the protection of the interests of depositors, preservation and achievement of specific results in the bank’s activities.

In the context of the development of market relations, the establishment of a two-tier banking system, and the expansion of the network of commercial banks, competition begins to appear between them to attract clients, deposits, interbank credit and other credit resources. The success of banking, the stability of the bank, the degree of business confidence in it on the part of founders, shareholders and clients largely depend on the proper organization of management of its activities and the qualifications of its personnel. The commercial interests of the bank determine the need to have reliable information about the state of affairs in various areas of banking activities in order to maintain the stable operation of the bank, respect the interests of the founders, shareholders, clients and employees, adjust the deposit and loan policy, and ensure the safety of money, valuables and property. Such information can be obtained from various sources, but it must be carefully verified. In addition, commercial banks, especially those with an extensive network of branches, have a need to organize an internal preliminary audit of their own activities in order to prevent possible negative facts that may be established by inspections of bodies supervising commercial banks (central bank, tax inspectorate, law enforcement agencies ).

The presence of a legislative framework and the practice of daily work to control the risks of banking activities led Russian banks in the process of their formation and development to realize the need to create (in one form or another) internal audit systems. However, banks did not have clear formalized guidelines in the formation of such systems , and the inspectors of the Central Bank of the Russian Federation, when inspecting this or that bank, did not have normatively established criteria for assessing the effectiveness of internal bank control. This served as the basis for the adoption by the Central Bank of the Russian Federation on August 28, 1997 of the Regulations on the organization of internal control in banks No. 509. In development of this document, on July 7, 1999, the Bank of Russia Instructions “On the procedure for implementing internal control over the compliance of activities in financial markets with the legislation on financial markets in credit institutions" No. 603-U and "On the procedure for certification of compliance controllers of credit institutions" No. 604-U. In accordance with this Regulation, the goals and objectives of internal audit, the functions, rights and responsibilities of the relevant service, the requirements for its employees, and approaches to the Bank of Russia’s assessment of the state of internal control in banks were determined.

The main goal of internal banking audit is to protect the interests of the bank, its shareholders and clients by monitoring compliance by individual services and specific employees with legislation, other regulations and standards of professional activity, resolving conflicts of interest, ensuring an appropriate level of reliability and stability of the bank. This leads to the main tasks of internal audit. The most significant of them include:

checking the bank’s compliance with the requirements of federal legislation and regulations of the Bank of Russia;

determination and compliance with established procedures and powers when making decisions affecting the interests of the bank, its owners and clients;

making timely and effective decisions aimed at eliminating identified shortcomings and violations in the bank’s activities;

fulfillment of requirements for effective risk management of banking activities;

checking the safety of bank assets;

checking the correctness of the bank's transactions in accounting;

control over the state of reporting, which allows obtaining the necessary information about the bank’s activities and the risks associated with it;

effective interaction with external auditors, government regulatory and supervisory authorities.

Thus, the main task of internal banking audit is to minimize the risks of banking activities. Internal audit can be organizationally represented as a structural unit of the bank. This service has a special status. It operates on the basis of the bank's charter and the regulations on the internal audit service. To successfully solve the tasks assigned to it, the internal audit service must have fairly broad powers. She must have the right:

access to work with all bank documents;

assess the compliance of actions and operations carried out by its employees with current regulatory and internal bank requirements;

attracting employees of the bank’s structural divisions, etc.

At the same time, the internal audit service is assigned certain responsibilities:

1) carrying out constant monitoring of banking risks;

3) timely informing the bank’s management about exceeding acceptable risk standards, about actual and possible violations, etc.

The internal service may be subordinated directly to the head of the bank or its founder. Its work must be based on plans specially approved by the board of the bank, which necessarily provide for inspections of branches, branches and divisions of a commercial bank. Inspection plans must contain a specific list of banking transactions subject to inspection. The main sections of audit programs conducted by the internal audit service may be the following:

legality of the bank's formation;

timeliness and correctness of the formation of the authorized capital, reserve and other funds of the bank, the legality of their formation;

confirmation of the reliability and correctness of the reflection in accounting and reporting of funds, accounts and deposits in banks and other credit institutions, customer deposits;

the legality of the conduct and reliability of the reflection of settlement transactions in accounting and reporting;

legality and reliability of reflection in accounting and reporting of lending operations;

correctness of implementation and legality of cash transactions;

the legality and correctness of the foreign economic activities of a commercial bank;

reliability, correctness of registration and reflection of accounts accounting transactions with securities;

checking the correctness of the accounting and reporting of the bank's fixed assets and other tangible and intangible assets;

checking the completeness, correctness and reliability of the reflection in the accounting of income and expenses of the bank.

Once a year, as part of the annual report, banks are required to submit reports on the state of internal control to the Bank of Russia, which has the right to, if necessary, audit the state of internal control and the work of the internal control service in banks.

conclusions

Banking activities are associated with high degree risk, which implies the need for the bank itself to constantly monitor all banking operations.

Intrabank control is a set of techniques and methods used by the bank for its operations.

The current system of internal bank control includes current and subsequent control in banks and the organization of internal audit.

Current banking control is carried out in the process of daily banking operations at each of the areas of organizing the work of the accounting and operational apparatus.

The purpose of subsequent control is the systematic verification of all areas of accounting and operational work in the period after banking transactions.

Internal audit is a system of bank security measures to ensure the protection of the interests of depositors, maintaining and achieving specific results in the bank’s activities,

Terms and concepts

Internal control system

Elements of the internal control system

Current control

Subsequent control

Directions of current control

Organization of follow-up control

Internal audit

Goals and objectives of internal audit

Questions for independent work

1. What causes the need for internal control in banks?

2. What are the objectives of its organization?

3. What types of internal control exist?

4. Describe the features of current monitoring.

5. What is follow-up?

6. Who in the bank is responsible for organizing subsequent control?

7. What is internal audit?

8. Describe the goals, objectives and main directions of internal audit.

Banking activity is one of the most important government-regulated areas of activity. This is due to the fact that in the process of operation of a commercial bank the property interests of a wide range of legal entities and individuals are affected. The stability of the banking system is of fundamental importance for the country's economy, which is why credit organizations are subject to regulation by government agencies to a greater extent than any other business entities. Increasing risks in banking activities should be minimized by creating a global system of internal control in each bank, the presence of the necessary regulations that allow adequately and flexibly customizing these systems to the specifics of a particular bank. Within this framework, the main task of developing the legislative and regulatory framework for the activities of banks is to create the basis for adapting the Russian banking system to changing market conditions, to the possibility of eliminating possible risks, and ensuring the stability of the banking system.

According to the federal law “On the Central Bank”, “the Bank of Russia is the body of banking regulation and supervision” to maintain the stability of the banking system and protect the interests of depositors and creditors. That is, banking regulation and supervision is carried out by the Bank of Russia. However, “the Bank of Russia does not interfere in the operational activities of credit institutions, except in cases provided for by federal laws.” The Bank of Russia establishes rules for organizing internal control that are mandatory for credit institutions.

The main regulatory documents that legislatively establish the rules for organizing internal control are the Federal Law “On Banks and Banking Activities” No. 395-1-FZ dated December 2, 1990 and the Regulations of the Central Bank of the Russian Federation No. 242-P dated December 16, 2003 “On the Organization internal control in credit institutions and banking groups.”

Consequently, regulation of banking activities is carried out through the Central Bank as a supervisory body that ensures the stability of the banking system as a whole, and through the internal structural divisions of the bank - let's call this control by the bank's management.

Today, the system of control over the activities of a commercial bank in general view carried out at three levels.

The first level is control carried out daily in each operational or regional unit, including verification of transactions and their reliable accounting, preliminary control of expenditure orders and control of their execution, regular reconciliation of account balances and regular preparation of reports, preservation of media and postings.

The second level is control, most often carried out by an internal auditor or auditor, whose task is to check the effectiveness of the organization of internal control, security and monitoring the performance of bank employees and managers of their duties. In this regard, the role of the auditor is to check the reliability of the functioning of banking structures and a transition is made from direct control to control of inspections. The first and second levels of control constitute the so-called internal control system.

The third level is control carried out by external auditors and inspectors of the Bank of Russia.

The importance of the regulator in the field of banking supervision is shown in the document of the Basel Committee on Banking Supervision “International convergence of capital measurement and capital standards: new approaches” (Basel II). The second component of Basel II – the Supervisory Process – can be divided into two parts. The first reveals the main functions of supervision of credit institutions, the second covers issues of risk management (interest, credit, operational). The importance of the supervisory process lies not only in guaranteeing that banks have adequacy own funds to cover the risk, but also to stimulate credit institutions to develop and apply improved methods of monitoring and risk management. According to Basel II, supervision implies not only the process of monitoring the activities of organizations in order to prevent losses, but also the introduction of responsibility for the management of credit institutions for the development and implementation of internal procedures for assessing equity capital and determining its level commensurate with the nature and volume of the bank’s operations.

The ideal model, in accordance with the document under consideration, is close interaction between supervisory authorities and credit institutions.

This allows you to quickly respond when deficiencies are detected and take active actions if necessary to reduce risks or increase your own funds (capital). In turn, the bank's internal control structure is of great importance for the capital assessment process. It is the Board of Directors that is entrusted with the function of regularly checking the effectiveness of the internal control system.

Control over a credit organization is carried out externally by the Central Bank of the Russian Federation and external auditors, and from within - with the help of internal divisions. The key point in the organization of internal control is the creation and approval of high-quality internal documents.

The main task in preparing internal regulatory documents is to increase the manageability and controllability of the organizational processes of a credit organization. This will allow you to avoid failure to comply with the requirements of regulatory authorities, as well as incorrect, unacceptable actions on the part of employees of the credit institution. Strict adherence to internal regulations should be one of the conditions for successful work, since they are developed in each credit institution independently, approved in the prescribed manner by their managers and mandatory for all employees.

Internal documents on internal control issues must be interconnected and comply with the charter of the credit institution.

It is also necessary to touch upon the problem of updating internal regulatory documents. Quite often, credit institutions do not update documents due to a change, for example, in the name or organizational structure, or the updated documents are not brought to the attention of branches in a timely manner, which may indicate a formal approach to the implementation of internal control.

The letter of the Bank of Russia dated June 30, 2005 No. 92-T “On organizing the management of legal risk and the risk of loss of business reputation in credit institutions and banking groups” states that the inconsistency of the internal regulations of the credit organization with the legislation Russian Federation, as well as the inability of a credit institution to timely bring its activities and internal documents into compliance with changes in legislation, indicate the presence of a certain legal risk.

Thus, both shareholders and managers of a credit institution are interested in well-written internal documents. Each credit institution, in accordance with the nature and scale of its operations, needs to take measures to improve its regulatory framework, develop and establish more detailed procedures for monitoring banking risks, including the procedure for the participation of branches in this process, eliminate existing contradictions in internal regulatory documents, and timely update them taking into account the requirements of regulations and recommendations of the Bank of Russia.

Internal control is an activity carried out by a credit institution (its management bodies, divisions and employees) and aimed at achieving certain goals.

Based on Regulation No. 242-P, the goals of organizing internal control in commercial banks can be depicted schematically (see Fig. 5.1).

Rice. 5.1. Goals of internal control in credit institutions

Thus, a fairly wide list of goals is presented; therefore, internal control covers almost all areas of the bank’s activities. However, it is possible to propose expanding the presented list by adding goals related to the organization and performance criteria of management in the bank, the development of intrabank and interbank relations, relations with clients and some others that are of paramount importance.

Based on the objectives presented above, a bank's internal control can be characterized as a system of methods adopted by a credit institution to protect its assets, comply with management policies, verify the reliability of accounting and financial statements and ensure operational efficiency. Internal control is a process constantly carried out at all levels of banking activities, implemented not only by the bank’s special control services, but also by all other departments, its managers and ordinary employees.

Internal control as a process can be represented in the form of interconnected elements (see Figure 5.2).

Rice. 5.2. Interrelated components of internal control

The internal control system is understood as the totality of the system of bodies and areas of internal control that ensures compliance with the procedure for implementing and achieving the goals established by the legislation of the Russian Federation, these Regulations, and the constituent and internal documents of the credit organization.

Internal control should be carried out by the following organizational units:

• management bodies of a credit institution;
• audit commission (auditor);
• chief accountant (his deputies) of a credit institution;
• the head (his deputies) and the chief accountant (his deputies) of a branch of a credit institution;
• divisions and employees exercising internal control in accordance with the powers determined by the internal documents of the credit organization, including the internal control service (hereinafter referred to as the ICS), the responsible employee (structural unit) for combating the legalization (laundering) of proceeds from crime and the financing of terrorism and others structural units.

Consequently, according to the document under consideration, internal control is carried out not only by the internal control system; a sufficient number of participants are involved in this process. Note that the list does not include ordinary bank employees, although they are the performers - participants in the bank’s business processes, therefore, control at the execution level could be the key to increasing the overall efficiency of control procedures.

According to Federal law“On Joint Stock Companies” No. 208-FZ of December 26, 1995 and the Federal Law “On Limited Liability Companies” No. 14-FZ of February 8, 1998, the audit commission is internal organ, controlling on behalf of the bank's owners (Board of Directors) the activities of the bank's management. In practice, banks often approach the formation and functioning of the audit commission formally; an appropriate level of control over the actions of the bank’s management is not ensured.

According to the report of the Basel Committee on Banking Supervision, the internal control system must include all divisions and services, management, and all employees of the credit institution.

The internal control service is a structural unit of a credit organization that carries out internal control activities and assists the management bodies of the credit organization in ensuring the effective functioning of the credit organization.

Among the functions of the internal control system, it is worth noting the verification of the completeness of application and effectiveness of the methodology for assessing banking risks and banking risk management procedures. Consequently, the formation of an effective internal control system department is the key to minimizing banking risks. The Internal Control Service carries out an independent assessment of banking business processes and possible risks associated with their implementation, which is especially important in the context of the ongoing global financial crisis. Please note that in regulatory documents there is no clear distinction between the concepts of “internal control” and “internal audit”. At the same time, there are no clear recommendations on the place and role of the internal control system in the overall structure of the bodies involved in internal control. Control should fit organically into the management system, and not act as an end in itself and an addition to it. Otherwise, the quality of management suffers, the natural system of management and internal control is destroyed, and conflict situations arise between the internal control system and employees of the credit institution.

In accordance with the current regulations, the bank is obliged to ensure the continuity of activity, the independence and impartiality of the internal control system, the professional competence of the manager and employees, and create conditions for the unhindered and effective implementation of its functions by the internal control service.

The internal control service is obliged to carry out inspections in all areas of the credit organization's activities. The object of inspections is any department and employee of a credit institution. If, in the opinion of the head of the internal control service, the management of the division and (or) management bodies have taken on a risk that is unacceptable for the credit institution, or the control measures taken are inadequate to the level of risk, then the head of the internal control service is obliged to inform the board of directors (supervisory board) of the credit institution. organizations.

The bank's internal control system performs a protective function - the function of minimizing external and internal risks of origin (causes) and is designed to ensure such a procedure for conducting banking operations (transactions) that contributes to the achievement of set targets and goals while complying with the requirements of legislation, regulations of the Bank of Russia, as well as internal procedures, standards and rules established in the bank. In essence, intrabank control is supervision conducted by the bank and directed by it to itself. If the bank management process is considered as a cycle, then control is the final link in the cycle of actions.

The organization of the internal control system in relation to the above components of control is based on principles that ensure the continuous operation of control mechanisms and functions in all areas of banking activities and at all levels of decision-making:

• separation of duties;
• continuity;
• objectivity;
• inclusiveness and diversity;
• information sufficiency for decision making and limiting access to information;
• use various types control depending on the functional affiliation of the objects of control, the current need and the complexity of the tasks.

Internal control should always be based on two fundamental qualities - independence and objectivity. Independence refers to organizational independence, characterized to a large extent by the level of subordination of the internal control service. Objectivity is an individual quality of internal control, which consists in the degree of impartiality in assessments and conclusions.

It is important to note that the degree of complexity of internal control is directly related to the cost of using specific controls and the potential losses in the event of their absence. Therefore, if the costs of maintaining internal controls exceed the expected losses due to the “weakness” of internal controls, it is advisable to abandon the use of these control procedures.

The main requirement for internal control is consistency, which characterizes the comprehensive nature of its implementation at the organizational and functional levels. The internal control system is designed to reduce banking risks and provide the bank's management, shareholders and clients with a flow of reliable information about the bank's activities.

The leading goal of internal control is to protect the interests of bank investors and their clients by monitoring bank employees’ compliance with legislation, regulations and professional standards, resolving conflicts of interest, ensuring an appropriate level of reliability corresponding to the nature and scale of the bank’s operations and minimizing the risks of banking activities.

Persons interested in the effectiveness of internal control are both the owners and management of the credit institution. For owners who do not always have physical ability control the situation completely, the ICS can provide objective information about the current state of affairs. At the same time, the efficiency of management decision-making increases thanks to internal control, since with its help it is possible, firstly, to obtain information relating to all aspects of the activities of a credit institution, and tools for summarizing and analyzing data. Secondly, internal control will allow you to objectively look at the situation and assess the quality of implementation of management decisions made.

5 groups can be offered possible errors in organizing internal control.

1. Lack of proper management control and accountability system, inability to create a high culture of control in the bank. In many cases, large losses are the result of inattention and neglect on the part of the management (owners and management) of the bank to the issues of forming and maintaining an up-to-date control system, insufficient management of processes and weak control, lack of a clear system of management accountability based on a thoughtful and clear delineation of the circle tasks and responsibilities.
2. Insufficiently effective identification and assessment of risks, especially for some types of on-balance sheet and off-balance sheet operations of the bank. Many banks do not identify and assess the risks associated with new banking products, or risk assessment systems are not updated, despite significant changes in banking activities. For example, control systems that are quite suitable for traditional or simple banking products are ineffective for non-traditional or more complex products.
3. Absence or weakness of key control structures and control activities, such as segregation of duties, transaction authorizations, account reconciliations, cross-checks, and operational audits.
4. Unsatisfactory exchange of information between different levels of management in the bank, especially when transmitting messages about emerging (or escalating) problems to the upper level of management. Documents documenting the bank's policies and internal procedures can only be effective if they are communicated to employees involved in these activities. Meanwhile, some losses in banks are caused by the fact that the relevant employees did not know and did not understand the policies of the bank management. In some cases, violations that should have been reported to higher management were not brought to the attention of owners or management until the problems grew to alarming proportions. In other cases, information contained in reports to bank management was incomplete or inaccurate, giving the appearance of a good state of affairs.
5. Inadequate or ineffective audit (monitoring) of remediation of deficiencies. In many cases, they are not strict enough audits failed to identify and point out internal control deficiencies typically found in troubled banks. In other cases, there was no mechanism to ensure that deficiencies were corrected by the management of the credit institution.

These typical and other deficiencies in internal control should be identified by specialized divisions of the bank through regular monitoring of the effectiveness of internal control. The departments that must ensure the functioning of a full-fledged internal control system in a bank may be internal control services, the internal audit service (IAS), or an independent body, the Audit Committee.

The role of the internal control system in managing banking risks cannot be underestimated. In practice, the main function of the internal control service as a body in the bank’s internal control system is to monitor the availability and quality of control (anti-crisis) mechanisms, the timely and professional competent use of which by other divisions, services and managers of the bank should minimize the risks of its activities. Deficiencies in the organization of internal control lead to the fact that the bank ceases to be stable and moves into the category of problem banks, which, in turn, reduces the attractiveness of the credit institution in the eyes of potential clients and investors.

5.2. Methods of conducting internal control

For the effective functioning of the internal control system in a credit institution, it is necessary to analyze the methods (methods) of its implementation and their classification.

The main methods of carrying out inspections by the internal control service of a credit organization are reflected in Regulation No. 242-P dated December 16, 2003. The methods of implementing internal control are:

• financial audit, the purpose of which is to assess the reliability of accounting and reporting;
• checking compliance with the legislation of the Russian Federation (banking, on the securities market, on issues of combating the legalization (laundering) of proceeds from crime and the financing of terrorism, on taxes and fees, etc.) and other acts of regulatory and supervisory authorities, internal documents of the credit organization and the methods, programs, rules, orders and procedures established by them, the purpose of which is to assess the quality and compliance of the systems created in the credit organization to ensure compliance with the requirements of the legislation of the Russian Federation and other acts;
• operational audit, the purpose of which is to assess the quality and compliance of systems, processes and procedures, analyze organizational structures and their sufficiency to perform assigned functions;
• management quality control, the purpose of which is to assess the quality of approaches of management bodies, divisions and employees of a credit institution to banking risks and methods of controlling them within the framework of the credit institution’s set goals.

The head and employees of the internal control service must have unhindered access to all inspected premises, including those used for storing documents (archives), cash and valuables (cash vaults), data processing (computer rooms) and storing data on computer media, compliance access procedures defined by the credit institution’s internal documents. They are allowed to receive documents and copies of documents and other information, as well as any information available in information systems ah of the credit organization necessary to exercise control, in compliance with the requirements of the legislation of the Russian Federation and the requirements of the credit organization for working with restricted information. They may require employees of the credit institution to provide access to documents and other information necessary for conducting inspections, as well as involve them in carrying out inspections.

The plan for conducting inspections carried out by the internal control service must include a schedule for their implementation and be drawn up based on the methodology for assessing banking risk management adopted by the management bodies of the credit institution, taking into account changes in the internal control system and new areas of activity of the credit institution. When drawing up a schedule for inspections, the frequency of inspections established in the credit institution in the areas of activity of structural divisions and the credit institution as a whole should be taken into account. Work plans for the internal control service are developed by the internal control service and must be approved by the Board of Directors (supervisory board) of the credit institution. The work plans of the internal control service may be coordinated with the sole and (or) executive collegial body. Reports on the implementation of inspection plans are submitted by the internal control service at least twice a year to the Board of Directors (supervisory board).

The inspection program carried out by the internal control service provides for the development of a separate inspection program for each area of ​​activity of the credit institution. It should contain the objectives of the audit and identify key banking risks and mechanisms to ensure the completeness and effectiveness of control in the area of ​​banking activity being audited. The working documents of inspections of the internal control service reflect the stages of the inspection and the inspection procedures performed, data on the documents reviewed and other information obtained during the inspection.

Reports and proposals based on the results of inspections are submitted by the internal control service to the Board of Directors (supervisory board), the sole executive (his deputies) and (or) collegial body, and the heads of the inspected structural divisions of the credit organization (branch). Reports must contain a description of the objectives of the audit, the work performed, identified violations, errors and shortcomings in the activities of the credit institution, which may pose a threat to the interests of creditors and depositors or affect the financial stability of the credit institution, and recommendations of the internal control service for improving work and eliminating violations, errors and shortcomings.

Taking as a basis the above methods of carrying out checks, they can be presented in the form of a classification of internal control according to the form of implementation. Having considered the forms of control: administrative (legal and managerial), financial and technological, we can move on to a detailed study of the types of internal control depending on the methods of its implementation.

Administrative control includes two classes - legal and managerial types of control. Management control consists of checking the compliance of operations with authority officials and is a system of operational activities and procedures. Legal control is a tool for supervising the legality of all operations carried out by the bank, including compliance with internal rules and procedures. Legal control includes compliance control, the main function of which is to ensure that the relevant internal bank rules, procedures and procedures do not conflict with the requirements of legislation and regulations governing the banking activities of the authorities, and the actions of the organization’s employees do not deviate from the established rules, orders and procedures. The goals of compliance control apply to any issues of compliance by the bank with the provisions of current legislation. This is necessary, in particular, to protect the name and reputation of the bank. The remaining subtypes of legal and management control are quite clear.

Financial control consists of checking the compliance of ongoing operations and transactions with the bank’s policies in relation to different types of banking products and services and their adequate reflection in accounting and reporting.

The form of technological control includes monitoring compliance with the technology of operations, job descriptions, limits and internal standards, as well as monitoring the condition of technical equipment, software, automated systems, etc.

It is important that through the use of administrative, financial and technological control, the effectiveness of the bank’s risk management system and the measures taken in all areas and levels of the bank’s activities to identify and minimize risks are determined.

Both administrative, financial and technological control in a bank can be carried out in a preliminary, current and subsequent manner.

The next important criterion for studying methods of implementing internal control is its classification depending on the methods. Methods for implementing internal control of a credit organization include remote control and on-site inspections, which are divided into functional and inspection inspections.

Under remote control of the credit institution, current control over the preparation and provision of internal and external reporting, analysis and monitoring is provided. External reporting includes reporting to the Bank of Russia, tax reporting and other mandatory types of reporting for external users. Internal reporting includes reporting on the execution of plans, budgets and other internal decisions of the credit institution. Regular analysis of the bank's reporting and activities is an absolutely necessary method of analytical control over its own activities, its main trends and problems. Monitoring and analysis must be carried out throughout the entire control process, at all its stages and stages.

On-site inspections are a set of interrelated activities carried out by authorized entities directly at various facilities of the credit institution. These checks are divided into functional and inspection. Functional inspections of internal control represent a set of activities carried out by divisions of a credit institution or individual authorized persons not related to the internal control bodies, and carried out within the framework of the functional powers of these divisions and persons. Functional checks include accounting control measures (subsequent and additional control), financial and technical control measures. Inspection checks mean control carried out by special control units (internal control or audit service). Inspections are divided according to the completeness of their coverage into comprehensive (cover the entire range of operations), thematic (cover a limited range of operations), and targeted (carried out on a specific issue) inspections. Based on the nature of control activities, inspections are divided into scheduled (carried out according to plan) and unscheduled (carried out on the basis of an order from the manager) inspections. Based on the depth of the issues being checked, inspections are divided into local (one unit, a separate type of operation is checked) and end-to-end, where the operation is monitored from the moment it begins to completion, covering all the units involved. Based on the repetition of the same questions, inspections are divided into primary, additional and repeat inspections. According to the degree of coverage of the verified data during inspections, selective, continuous and combined methods are used. Random checks: a subset of documents is checked, most often randomly selected. Continuous: all operations and data for a certain period of time are subject to verification. Conclusions made on the basis of a complete inspection are more reliable and allow a more accurate characterization of the correctness of the operation or activity of the controlled object. Combined: simultaneous use of selective and continuous methods. According to the expectedness of the object being checked, types of checks are divided into expected and unexpected.

Let's consider the techniques and procedures of a bank's internal control, which are necessary when conducting inspections using various methods.

Depending on the procedures used, internal control can be classified into general methodological and documentary-factual control methods. General methodological techniques include: separation of functions (provides clear establishment of levels of subordination), data security (access control), review of transactions and transactions, reporting, keeping records of transactions and transactions, training, monitoring, internal investigation (in critical situations) and other techniques . Documentary-factual techniques do not need comments.

An important feature of internal control is its dependence on the level of control: individual, micro levels and macro levels. At the individual level, the object of the internal control system is the individual employee, his motivation and competence in decision making. At the micro level, the main object of the system is the state of the decision-making system in the bank and compliance with the chosen tactics for the development of commercial activities. At the macro level, the object of the internal control system is the state of analytical work from the point of view of taking into account in the process of bank management the influence of economic and regulatory conditions of its work on the effectiveness of the chosen directions of the bank’s current and future development.

The division of control according to the quality of content involves dividing it into formal and real. Formal control involves checking the operation for compliance with the requirements of the law and internal rules; real control involves analyzing the financial efficiency and feasibility of the operation. The general classification of types of internal control provides a construction scheme based on the integrity of internal control and allows us to identify the most complete typology of its connections.

This classification is an integrated approach, which consists of close interaction between administrative, financial and other aspects of control activities.

It is necessary to pay attention to the richness of types of control identified on the basis of different criteria. The system set is the most effective methods, forms and technologies of control depends on the construction of an internal control system and the experience of managers of a credit institution; when implemented, it allows mitigating the negative impact of banking risks.

5.3. Stages of internal control

Internal control is a process carried out by the Board of Directors, senior officials and employees at all levels of management, special services (internal control service), which allows the formation of a system that ensures a complete audit of all bank activities. This process is carried out continuously at all levels within the bank. Bank management is responsible for establishing an internal control system and monitoring it, but every employee of the organization must participate in this process. Control activities are most effective when they are viewed by managers and all other employees as component daily activities of the bank. The set of organizational structure, methods, and procedures adopted by the bank’s management as a means for the orderly and efficient conduct of banking activities constitutes an internal control system. The system is an element of bank management that allows the bank’s management to assert with a reasonable degree of confidence that the staff at their level correctly understands the bank’s policies, and all the goals set by management are achieved in compliance with the established forms.

The internal control system consists of the following elements:

• control environment;
• regulation;
• accounting systems;
• control procedures;
• internal control services.

Control environment is a concept that characterizes the general attitude, awareness and practical actions, activities and procedures of bank management aimed at establishing and maintaining an internal control system. These are the conditions of existence in the bank that are created by the management of the credit institution. The control environment is formed depending on the policies and methods of management, the organizational structure of the bank, the activities of management to maintain the functioning of the system, the distribution of management functions and responsibilities, personnel policies and the interaction of various types and methods of control.

Regulation is a system of regulatory internal and external documents regulating the activities of the bank, its divisions and employees.

Accounting system – an orderly system for collecting, registering and summarizing information in monetary terms about the property and obligations of an economic entity and their movement through continuous, continuous and documentary recording of all factors of the credit organization’s activities.

Control procedures are methods and rules that complement the elements of the control environment and accounting system developed by the administration to achieve the bank’s goals. Control procedures are aimed at preventing errors and distortions that may occur during operations. Control procedures are classified into mandatory (defined by regulation), special control (activities of the internal control service), procedures for controlling large and high-risk transactions (to minimize risks).

The internal control service is created in the bank in order to monitor the process of functioning of the internal control system, identify and analyze problems associated with its functioning, as well as develop proposals for improving the system and increasing the efficiency of its functioning, as described above.

On the first stage When creating a credit organization, a division is created, consisting of a manager and a minimum number of employees. The purpose of this unit is to develop and approve the regulations on the internal control service, prepare the structure, staffing table and distribution of tasks among employees. The creation and operation of internal control and regular review of its effectiveness in the bank fall within the competence of the Board of Directors. The competence of executive bodies includes the distribution of responsibilities of departments and employees responsible for specific areas (forms, methods of implementation) of internal control, delegation of authority to develop rules and procedures in the field of internal control to heads of structural divisions and control over their implementation. The management bodies of a credit institution ensure the participation in internal control of all bank employees in accordance with their job responsibilities and establish a procedure for reporting all violations and abuses. At this stage, the internal control service interacts with the bank’s management and human resources department.

At the second stage a list of the most important tasks for the bank from a control point of view is highlighted. The composition of these tasks can vary greatly for different banks. An important selection criterion here should be an assessment of the risk of losses and the volume of operations in this area of ​​business. The bank's management assesses the risks affecting the achievement of its goals and takes measures to minimize them based on the information provided by the internal control service. To effectively identify and monitor new or previously uncontrolled risks, the organization of the internal control system is reviewed in a timely manner. Reception and control of compliance with documents on the interaction of the internal control service with other divisions of the bank is carried out. At this stage, the internal control service interacts with the bank’s accounting department and its divisions.

At the third stage control procedures are developed to solve the assigned tasks. At the same time, the Board of Directors takes measures to ensure the prompt implementation of recommendations and comments of the internal control service, and also checks the compliance of internal control with the nature, scale and conditions of the credit organization’s activities. Executive bodies create an effective system for the transfer and exchange of information, a system for monitoring the elimination of identified violations and deficiencies in internal control, and also review materials and results of periodic assessments of the effectiveness of internal control, check the compliance of the bank’s activities with internal documents defining the procedure for exercising control. At this stage, the internal control service should be in close cooperation with the following divisions of the bank:

1. With the sales department regarding:

• control of open position limits and maximum loss;
• control of limits on counterparties;
• control of restrictions related to client transactions;
• providing dealer positions and client order logs;
• access to information systems and exchange information to check market rates of concluded transactions.

2. With accounting on issues:

• control of transaction confirmations;
• conducting legal affairs for clients and counterparties;
• storage of primary documents and registration of transactions;
• access to documents of the day;
• explanations of transaction account balances;
• report on the results of transactions, reconciliation of actual credits/debits to NOSTRO accounts based on the results of transactions.

3. With the information support service on issues:

• interaction to organize access to the necessary information;
• development and implementation of operational control procedures in systems.

4. With SWIFT departments regarding access to SWIFT and TELEX messages for transactions.

5. With departments carrying out transactions with bank cards, on the following issues:

• monitoring the compliance of analytical and synthetic accounting data;
• overdraft control;
• control of the completeness and integrity of databases of card account management systems.

The implementation of control functions at this stage involves:

• participation in the development of regulations and regulations for conducting operations, the procedure for their accounting and control, and assessment of emerging risks;
• possible introduction of additional control (vising) of large payments, transactions, contracts with amounts exceeding the established ones.

It is important that at this stage the internal control service already includes specialists who are able to independently set and solve information processing tasks, who are proficient in working with database management systems and programming in the software environment used in the bank.

At the fourth stage the list of controlled positions is expanding, gradually covering all aspects of the bank’s activities.

Studying the stages of internal control and covering various aspects of the bank’s activities allows us to propose two forms of structural organization of the internal control service in the bank.

In Fig. 5.3 presents a separate structural unit in the form of the internal control service (ICS), the internal audit service (IAS), the compliance control unit (CC) (if it is not included in the IC), the risk calculation service (RRR), analytical departments and others that interact with each other and with other divisions of the bank. With this option, each service must be endowed with appropriate powers, rights, responsibilities, as well as means of exercising control.

Rice. 5.3. Form of structural organization of the internal control service (option 1)

In the second case, Fig. 5.4 reflects the unified internal control service (USlVK), which includes various divisions: internal control (internal audit), risk management department, as well as a number of other analytical and control divisions of the bank. In fact, this is a multifunctional department that covers various aspects bank activities. This method is more preferable, as it allows you to minimize the quantitative composition by reducing the duplicated functions of various control units, optimize the control process, and also reduce the financial costs of maintaining control bodies.

Rice. 5.4. Form of structural organization of the internal control service (option 2)

If the bank is multi-branch, then at the fifth stage The activities of the internal control service extend to branches. In a multi-branch bank, each branch must have a specially authorized employee of the internal control service - a controller. He is appointed to the position of branch manager, but in his work and reporting he reports to the head of the internal control service. In the absence of such a possibility, the functions of the controller are assigned to one of the employees by order of the manager. The candidacy of a controller or an employee combining his or her duties with the responsibilities of a controller must be agreed upon with the head of the internal control service. The status of the controller and his subordination are secured by the regulations on the controller. The controller must have a description of the procedures that he must perform and regulations for their implementation. The purpose of the procedures performed is to ensure effective control over the work of the branch in the provision and support of banking services in the conditions of centralized management of the bank.

At all stages of the implementation of internal control in the management process of the bank's management, the adoption of rules and the implementation of practices that may stimulate the commission of actions that contradict the legislation of the Russian Federation and the goals of internal control must be excluded.

The internal control process in commercial banks includes:

• planning control activities;
• implementation of control (application of control procedures);
• registration of control results;
• monitoring the elimination of identified violations.

During planning, a composition (list) of control tasks is developed, on the basis of which control activities are planned.

When exercising control, the main attention is paid to checking the legality, reliability, feasibility, and economic efficiency of financial and business operations.

Registration of control results involves processing the received data in order to present them in the form of a logically coherent document. It describes the identified violations, indicates the main causes and culprits of these violations, and provides recommendations for eliminating the identified deficiencies.

Control over the elimination of identified violations is carried out in the form of monitoring the implementation of developed measures aimed at eliminating the identified deficiencies.

An important control tool is economic analysis, which is used throughout the entire process of its implementation.

Monitoring is carried out by the credit institution’s internal control service and is based on both internal and external information flows. It is a system for identifying failures in the internal control system. Elimination of deficiencies should be based on a methodological approach to identified failures in the functioning of the internal control system. This means that the priority should not be punishing employees, but adjusting the system itself to prevent similar failures.

The production and financial aspects of maintaining internal control depend on how effectively and efficiently the bank manages its assets and other resources, and what is its likelihood of incurring losses. In this aspect, the internal control process should be aimed at ensuring that bank employees strive to achieve their goals effectively and honestly, avoiding ill-considered and excessive expenses or putting other interests (for example, the interests of the employee, partner or client) above the interests of the bank .

A properly established process of functioning of internal control should contribute to the compliance of the activities of the credit organization with the goals and plans of its development; reliability, completeness, timeliness of financial and management information, compliance with current legislation and effective development of the credit organization.

conclusions

A credit institution is obliged to organize internal control to ensure an appropriate level of reliability corresponding to the nature and scale of its operations.

Internal control is an activity carried out by a credit institution and aimed at achieving certain goals.

The bank's internal control system performs a protective function - the function of minimizing external and internal risks and is designed to ensure such a procedure for conducting banking operations that contributes to the achievement of set targets and goals while complying with the requirements of legislation, regulations of the Bank of Russia, as well as internal procedures, standards and rules established in the bank.

The modern scale of activity of credit institutions necessitates the creation of complex internal control systems, but such systems are not created immediately, but gradually, along with the growth and development of the bank itself.

A properly established process of functioning of internal control should contribute to the compliance of the activities of the credit organization with the goals and plans of its development; reliability, completeness, timeliness of financial and management information, compliance with current legislation and effective development.

Self-test questions

1. What tasks does the bank’s internal control service solve?
2. What regulatory documents regulate the activities of the bank’s internal control service?
3. What functions does the internal control service perform?
4. What methods are used to conduct internal control?
5. What stages does the process of internal control of a bank consist of?
6. How are transfer prices set?
7. How is the performance of individual bank divisions determined?

Bibliography

1. Regulations of the Central Bank of the Russian Federation “On the organization of internal control in credit institutions and banking groups” dated December 16, 2003 No. 242-P.
2. Letter of the Central Bank of the Russian Federation “On the recommendations of the Basel Committee on Banking Supervision” dated November 2, 2007 No. 173-T.
3. Letter of the Bank of Russia “On organizing the management of legal risk and the risk of loss of business reputation in credit institutions and banking groups” dated June 30, 2005 No. 92-T.
4. Banking: Textbook / Ed. Beloglazova G.N., Krolivetskaya L.P. – St. Petersburg: Peter, 2009. – 400 p.
5. Makeev R.V. Setting up internal control systems: from reporting audits to business efficiency. – St. Petersburg: Vershina, 2008. – 287 p.
6. Managing the activities of a commercial bank (banking management) / Ed. O. I. Lavrushina. – M.: Yurist, 2003. – 688 p.

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The internal control system in the bank performs a protective function. Its task is to minimize external and internal risks and ensure such a procedure for conducting banking operations and transactions that contributes to the achievement of set goals while complying with the requirements of legislation, regulations of the Bank of Russia, as well as internal procedures, standards and rules.

The legal field of the internal control service is determined by the regulation of the Bank of Russia “On the organization of internal control in banks” dated August 28, 1997 No. 509. Direct actions aimed at minimizing the bank’s risks are determined by a number of instructive acts, such as, for example, the Bank of Russia Directive dated July 7 . 1999 No. 603-U “On the procedure for implementing internal control over the compliance of activities in financial markets in credit institutions”, Resolution of the Federal Commission for the Securities Market dated July 19, 2001. No. 16 “On approval of the Regulations on internal control of a professional participant in the securities market”, rule (standards) of auditing activities “Study and assessment of accounting and internal control systems during an audit” (approved by the Auditing Commission under the President of the Russian Federation on December 25, 1996 city, protocol No. 6) and a number of other acts.

IN organizational basis The internal control system contains principles that ensure the continuous operation of control mechanisms and functions in all areas of banking activities and decision-making levels. These include, in particular, the principles:

• separation of duties;
• continuity;
• objectivity and specificity;
• objectivity;
• inclusiveness and diversity;
• information sufficiency for decision-making and restriction of access to information not related to the conduct of a specific operation and/or
  exceeding the limit of functional necessity within the scope of job duties;
• the use of various types of control depending on the functional affiliation of the objects of control, the current need and the complexity of the tasks.

The efforts of the internal control service (based on the general situation and the creation of a high-tech bank in the future) are aimed mainly at controlling:

• for the creation of a unified technological structure for conducting all operations and customer service;
• for creating compliance of the technological structure, formalized in the form of regulations, orders, instructions, methods, procedures, with the actual practice of the bank;
• for adequate banking accounting, as well as the creation and effective functioning, within the framework of a single technological structure, of mechanisms for subsequent control over banking operations;
• for compliance of internal regulations, orders, instructions, methods, procedures with external legislation.

To build a unified technological structure in a bank, a number of problems must be solved.

1. Develop (together with other divisions of the bank) unified and standardized rules and algorithms for the creation (formalization) of internal regulations, orders, instructions, methods, procedures, as well as their implementation, application, change (correction) and cancellation.
2. Monitor the unification and standardization of internal regulations and methodological acts.
3. Monitor the adaptability of internal regulations to a rapidly changing external environment.
4. Formalize all processes of the bank's activities.
5. Monitor the continuity of technological chains of the bank’s activities.

When talking about control, you should clearly understand its types. As a rule, these are administrative and financial controls. Administrative control consists of checking the compliance of operations and transactions with the powers of officials defined by bank regulations and procedures for making and implementing decisions. As a result of financial control, the compliance of ongoing operations and transactions with the bank’s policies set out in regulations, their adequate accounting and reporting is verified. It is important that both administrative and financial control determine the effectiveness of the bank’s risk management system and the measures taken to identify and minimize risks.

So, the goals and functions of the internal control service are clear. However, the question arises: what is the functional difference between the internal control function and the units involved in internal audit? After all, functionally, such divisions also exercise internal control over the bank’s activities.
To answer this, it is necessary to clearly distinguish between the concepts of “internal control system” and “internal control service”. The first covers all types of operations and all hierarchical levels of the bank's work, and the second controls the work of the first.

Considering the bank as a kind of production (which also includes divisions performing control functions - this is their production), we can say that internal audit is a division performing production functions. At the same time, the internal control service carries out both production and organizational functions(creating control mechanisms).

The structural organization of the internal control service can be carried out in two ways.

First. The internal control service includes an internal control unit, internal audit, a risk management unit, as well as a number of other analytical and control units of the bank. In fact, we are talking about a multifunctional department that should cover various aspects of the bank's activities.

Second. The internal control service is created as a separate structural unit of the bank, interacting with other control units. With this option, the internal control service must be endowed with appropriate powers and rights.
The choice of a structural organization primarily depends on the characteristics of the bank, the availability of appropriate resources, and established business practices.

Internal control in the bank.

A number of problems may arise in the activities of the internal control service in connection with the established regulatory framework of the Bank of Russia. For example, international control practice presupposes the presence of compliance control in all areas of the bank’s activities. In principle, compliance controllers conduct inspections in all areas of banking activities. However, in the Russian banking system, compliance control (the activities of the compliance controller) is regulated only in the work of the bank in the financial market (Instruction of the Bank of Russia dated July 7, 1999 No. 603-U). It seems that it would be more logical to cancel this Directive, but to supplement Regulation No. 509, expanding the functions of the internal control service by implementing compliance control over the entire set of bank operations.

A few words on the draft Code of Corporate Conduct developed by the Federal Securities Commission and issues of internal control.

Assessing the state of corporate governance requires a special multidimensional system for assessing the activities of the subject of management. In this regard, the system of internal control over the financial and economic activities of the entity is of great importance. The draft Code provides for the creation of a special body - the control and audit service - responsible for conducting daily internal control. However, its main task, according to the project, is audit support of the subject. In our opinion, this body must first of all create an internal control mechanism that can most effectively ensure the reliability of the activities of the subject of management. And within the framework of this mechanism, the internal audit system should function as an integral, but not the only part of the internal control system.

The draft Code very superficially describes the functions of the control and audit service, the principles of interaction of this body with other divisions of the entity, as well as with external auditors. The functions of the Audit Commission are not sufficiently developed in the new version of the Law “On Joint Stock Companies”, which came into force on January 1, 2002. Therefore, the Bank of Russia Regulation “On the Organization of Internal Control in Banks” No. 509, in our opinion, more fully reveals the tasks and functions service organizing internal control, compared to Ch. 8 “Control over the financial and economic activities of the company” of the draft Code. This concerns, in particular, the absence of such functions of the control and audit service as monitoring the compliance of the subject’s activities with the legislation of the Russian Federation, the creation of technology for controlling business processes, increasing its efficiency, the possibility of laundering proceeds from crime, as well as functions within preliminary, current and subsequent control. The developers of the draft Code did not take into account Bank of Russia Regulation No. 509, which is based on international principles for organizing internal control and recommendations of the Basel Committee. As a suggestion, we can recommend that the authors of the draft adapt some aspects of Regulation No. 509 for Ch. 8 of the draft Code.

Internal control over the bank's branch network.

Operations of branches are carried out within the limits and restrictions established by the parent organization. In particular, the activities of a branch are limited by the regulations on branches and the general power of attorney of the manager to carry out active operations (by type of activity and counterparties), as well as by the cost of funds raised and the volume of operations performed (limits). The limits on operations of branches with various types of financial instruments are established by the collegial body of the parent organization. At the same stage, business planning of the branches' activities is carried out. In the future, monitoring of the progress of the branches’ implementation of business plans should be carried out on an ongoing basis. In addition, the preliminary control stage involves mandatory coordination with the interested divisions of the bank of all developed regulations that directly affect the activities of branches.

Current control over the operations of branches by the parent organization is not implemented in real time. As a result, the parent organization cannot promptly (during the operation) monitor such violations as exceeding limits on certain types of transactions and branches carrying out transactions and operations not authorized by the parent organization.

Most violations are usually detected during follow-up monitoring. This is control of accounting and operational work, including cash register. It is carried out by the employees of the branch divisions themselves on the basis of Part 3 of the Accounting Rules No. 61 in two directions: complete control of the correct reflection of all transactions performed during the operating day in the accounting registers and verification of the work of employees based on quarterly plans. At the same time, based on the results of inspections, branches send certificates to the internal control service. These are audits of the activities of branches, which are carried out by the internal audit unit, including verification of the elimination of deficiencies identified by previous audits. Once a reporting year, internal audit units must conduct comprehensive audits of branches.

In addition, during subsequent control, all reports of inspections of the activities of branches by state control bodies (territorial institutions of the Bank of Russia, the State Tax Service, funds) are taken into account, copies of which branches are required to send to the internal control service.

In addition to the above, it is desirable to have in the branches of the internal control group subsidiaries of the internal control service, whose task includes regular thematic inspections of the branches’ activities, as well as, at the stage of preliminary control, participation in the coordination of internal regulations of the branches. The reports of these groups are sent to the internal control service of the parent organization.

If a branch operates on a self-supporting basis, then control over its activities by the parent organization should be more strict. It should cover the execution by branches of limits on transactions, counterparties and financial instruments, balance sheet accounting (its compliance with actually completed transactions and payments, i.e. compliance with synthetic and analytical accounting data, as well as accounting (compliance with the requirements of the Central Bank of the Russian Federation and other regulatory government organs).

In order to minimize risks, limits are set on all unsecured transactions of a bank branch with counterparties: on unsecured transactions in the financial market, when lending to corporate clients, on transactions with financial instruments (bills, bonds, etc.), on the issuance of guarantees, sureties and trust servicing of client funds, as well as individual limits on authorized persons of branches. Branch internal control services must carry out subsequent supervision over the implementation of limit discipline, and
also for the correct and effective operation of ongoing control mechanisms in this area.

The internal control service of the bank's parent organization must organize interaction with territorial internal control units and develop internal regulations regulating the procedure for such interaction. It is necessary that territorial internal control groups be independent of the branch management. This will eliminate the possibility of influence of the branch management on their activities; however, the above also applies to the internal control service of the parent organization. It is desirable that she have the opportunity to “access” the bank’s Supervisory Board.

A separate problem is the organization of control over separate structural divisions of bank branches ( additional offices and operating cash desks outside the cash desk). This is the prerogative of branch managers. At the same time, managers are guided by the provisions of regulations governing the procedure for carrying out operations in various areas of banking activities and organizing control over their implementation, as well as internal documents that take into account the specifics of a particular branch in relation to the activities of separate structural divisions. All procedures described in these documents must meet the requirements of Part 3 of the Accounting Rules for Credit Institutions located on the territory of the Russian Federation, No. 61 dated June 18, 1997.

Control over the activities of separate structural divisions of branches should be carried out both by employees of these divisions. and on the part of the branch by employees of territorial divisions of the internal control service.

In separate structural divisions of branches, subsequent control of accounting and operational work, including cash, should also be carried out, providing for regular checks by employees of accounting and operational departments of the activities of other employees. It is carried out by employees of the divisions of the internal control service of branches, and in the absence of such in branches - by employees of branches - in the areas of their activity.

In the latter case, certain difficulties arise due to the likelihood, on the one hand, of a biased assessment, and on the other, possible errors due to increased employment of employees.

Current control is carried out by the heads of separate structural divisions, as well as the heads of specialized departments during banking operations. At the same time, the main problem of organizing effective control is the unclear division of functions and the inability to minimize the risk of a conflict of interest due to a shortage of personnel in a separate structural unit.

Internal control at the stage of strategic planning and forecasting.

Strategic planning and forecasting are also the field of activity of the internal control service.
The main object of the internal control system at this stage is the state of internal bank analytical work: taking into account the impact on the effectiveness of the current and future development of the bank of possible changes in the macroenvironment, external risks (political, country, regional, industry, etc.).

At the stage of preliminary control, supervision is carried out over the completeness, composition and timeliness of updating the source databases, on the basis of which the analytical and functional divisions of the bank carry out a prospective assessment and forecast of the situation. The subject of preliminary control is also the existing procedure for promptly and systematically informing the bank’s governing bodies about the conclusions and proposals of analytical services on current situation, on forecasts for the development of the situation in the relevant market segments and in the economy as a whole, in the field of regulatory support for banking activities.

For this purpose, comprehensive and thematic inspections of these units are carried out for the presence of necessary tools, procedures and technical means to conduct an adequate analysis and bring it to the attention of responsible persons involved in the preparation and adoption of relevant decisions.

Current control requires periodic checks of the fulfillment of tasks of analysis and forecasting of the situation and timely notification of the bank's governing bodies.

In the process of current control, the system for monitoring the competitiveness of the quality and cost of products offered by the bank is checked in the functional divisions of the bank. In addition, the timeliness of the response of these divisions to the actions of competitors, as well as to changes in economic conditions in the non-financial sector, is assessed.

Subsequent control comes down to comparative analysis conclusions and recommendations of analytical units and the actual development of the situation, as a result of which an appropriate assessment is given.

A separate function of the internal control service is participation in the coordination of internal bank regulations and procedures with interested divisions of the bank. This work precedes preliminary control, since it determines the algorithm of employee actions and control mechanisms designed to prevent violations in these actions.

At the same time, the internal control service should pay attention to the sufficiency of such control mechanisms. It is clear that all internal bank regulations must be checked for compliance with the regulations of the legislation of Russia, the Central Bank and international acts and documents.

In conclusion, I would like to note that the result of the functioning of the bank’s internal control system should be the organization of continuous and constant control over banking and administrative and economic activities. The list of the above problems that arise during such an organization is far from complete. For example, the problems of corporate governance and the control carried out within its framework are currently not resolved for a number of reasons (lack of appropriate state legislation and experience of corporate governance in Russia, poor transparency of accounting (due to the fact that the transition to IFRS standards will take place only in 2004 d) and traditions of widespread provision of it to third parties, etc.).

A.A. ARSLANBEKOV-FEDOROV,
expert of the Internal Control Service of Vneshtorgbank, candidate economic sciences, Master of Business Administration.

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With all the variety of models of internal control systems, determined by the strategic and tactical goals of each specific bank, the formation of an internal control system is often associated with the problem of misunderstanding by managers at different levels of bank management of the goals and role of the internal control service and the internal audit service, as well as the replacement of one concept with another.

The identification of the internal control service with a fiscal and supervisory authority capable of interfering in the operational activities of the bank not only does not contribute to the formation of an effective internal control system, but also creates social tension in the team, contributing to the growth of operational risks of ongoing operations and financial activities the bank as a whole.

According to the definitions of the Basel Committee, the internal audit service is an element of the internal control system (in Russian terminology an analogue is often used - the concept of internal control service) - it carries out constant (regular) monitoring of the effectiveness of internal control. The employees of this unit are operationally independent, adequately trained and competent.

In Russian scientific and journalistic literature, the concepts of “internal control service - ICS” and “internal audit service - IAS” are interpreted differently, and often one concept is replaced by another.

In the works of V.I. Ovinova SVK replaces SVA. ICS is a separate structural unit that defines and implements methods, methods and types of checks on the effectiveness of the activities of the bank's functional divisions, compliance by employees with legislative and regulatory acts, performance standards and norms of professional ethics, internal documents regulating the activities of the bank in order to identify violations and develop recommendations for them elimination with subsequent monitoring.

The main objectives (subgoals) are:

• - study and assessment of the sufficiency and effectiveness of the internal control system adopted by the bank;
• - control over the accuracy and reliability of data and financial reports; control over the banking capital assessment system;
• - checking compliance with legal and regulatory requirements, rules of conduct;
• - conducting special investigations, etc.

IN AND. Ovinov believes that the internal control system should not take part in ongoing control, reduce preliminary control to a minimum and carry out subsequent control as much as possible; only in this case is it possible to avoid a conflict of interest. If ICS specialists take part in monitoring operational activities, then it should not be considered as current, since it is almost always of a targeted nature (based on the information received about the non-compliance of the operation with internal procedures and documents to confirm or refute this information).

A similar situation arises when establishing requirements for the participation of the internal control system in checking compliance with legal and regulatory requirements of internal bank regulations and other internal documents. The ICS must give its opinion on the quality of the documents, but this cannot be considered as participation in the preliminary control of operations that will be carried out on the basis of this document, or as ongoing control over the correct execution of this regulation. This should be considered as subsequent control: an assessment of the compliance of a document already prepared for signing, carefully worked out and endorsed by the relevant services, with the established requirements.

The participation of the internal control system in regulating the risks of banking activities is the establishment of an independent system of risk control assessments in order to develop certain recommendations for making management decisions aimed at minimizing risks and reducing losses. But ICS specialists should not participate in the risk regulation process in order to avoid conflicts of interest.

Approaches to the organization and functioning of the internal control and internal audit service in the works of A.A. Arslanbekova-Fedorov does not correspond to V.I. in certain positions. Ovinov. One of the main differences is the clear distinction and separation of the functions of the internal audit and internal control services.

Internal audit service and internal control service according to the position of A.A. Arslanbekava-Fedorova are the leading departments that must ensure the functioning of a full-fledged internal control system in the bank within the framework of the main goals defined by the Basel Committee, and conduct regular monitoring of the effectiveness of internal control.

Based on the above, the main efforts of the internal control service should be directed to the following main aspects of the bank’s activities as a high-tech organism:

• - control over the creation of a unified technological structure for conducting all kinds of operations by the bank;
• - control over the compliance of the bank’s actual practice with its technological structure (formalized in the form of internal regulations, orders, instructions, regulations, methods, procedures);
• - control over the adequacy of accounting within the framework of a single technological structure, as well as the creation and effective functioning of mechanisms for subsequent control of bank operations;
• - control over the compliance of internal regulatory and methodological documents with the requirements of legislation and regulations of regulatory government bodies.

Taking this into account, we can say that the main goal of the internal control service is to control the construction of a unified technological structure in all areas of the bank’s activities in a constantly changing external environment, and the main object of control is the creation and debugging, and subsequently maintaining it up to date a unified technological structure introduced in business turnover bank at all levels of its activities.

Within the framework of the existing goal, individual tasks can be distinguished:

• - development (together with other divisions of the bank involved in a specific technological process) of unified and standard rules and algorithms, internal regulatory and methodological documents, their implementation, application, modification and cancellation;
• - subsequent control over the unification and standardization of internal regulatory and methodological documents;
• - control over the degree of adaptation of the bank’s internal regulatory documents to the constantly changing conditions of the external environment;
• - control over the comprehensive effective formalization of all processes that constitute the essence of the bank’s activities;
• - monitoring the continuity of technological chains across all processes of the bank’s activities.

The internal control service is a specific banking unit that occupies a special position both in terms of its position in the bank’s structure and the role that this service plays. Being a purely cost-intensive division, the internal control system often pays for its existence so much that it can be placed on a par with the most profitable divisions of the bank.

To differentiate the functions between the Internal Control Service and the Internal Audit Service, it is first necessary to make a clear distinction between the internal control system and the internal control service. The internal control system covers all operations and all hierarchical levels of the bank’s work, the second organizes the work of the first (essentially creates a system, provides it with all methodological and regulatory documents, coordinates the interaction between divisions of the system) and controls it, while at the same time being part of this system. Those. The internal control service performs both production (control) and organizational functions. The internal audit service is a unit that performs only production (control) functions. The audit is designed to solve primarily the problems of ensuring subsequent control, i.e. identification of errors and abuses after operations based on data on its implementation (audit trail). Internal audit must check the entity (the bank division being inspected) for compliance of its activities with legal norms, activities in the field of anti-money laundering, as well as carry out a practical audit of activities within the framework of preliminary, current and subsequent control. Internal control is obliged, first of all, to provide such conditions and algorithms for conducting operations that make abuses and errors impossible or difficult to implement.

The internal control service can be structurally organized in two ways.

In the first case it may include internal control and internal audit units, a risk management unit, as well as a number of other analytical and control units of the bank. Those. in fact, a multifunctional department is being created.

In the second case, the internal control service can be created as a separate structural unit within the bank, interacting with other control units.

The choice of option depends on the characteristics of the bank; the main directions of work of the internal control system will be determined depending on the organizational structure of the bank and the priorities of its activities. However, in both cases, the goals, functions and methods of operation of the internal control system must be essentially identical and not violate the technological structure of the bank.

Arsnbekov-Fedorov’s point of view is based on the concept of internal control defined by the Basel principles, which makes it consonant with the requirements of Bank of Russia Regulation No. 242-P dated December 16, 2003.

Bank of Russia Regulation No. 242-P dated December 16, 2003 classifies the internal control service (internal audit) as part of the system of internal control bodies and defines this service as a structural division of the bank created to exercise internal control and assist the management bodies of the credit institution in ensuring effective functioning credit organization.

IN international practice the term “internal control service” is not used. At the same time, in the internal control system, as separate units, there are either internal audit departments (USA) or internal control departments (France). Many Russian banks are characterized by duplication of activities between internal audit structures and internal control services. The problem is caused by the introduction of Regulation No. 509 after the actual creation of internal audit departments (services) in many Russian credit institutions. Since the recommendations of the Basel Committee do not contain the concept of internal control department (service), and in international practice, internal control and internal audit departments are synonymous, the presence of a separate internal audit unit if there is an internal control service in the bank can be considered unnecessary or not always justified, despite on the differences in the views of Russian analysts.

In most Russian banks that have created an internal control (audit) department, its functions are currently often limited to monitoring the correctness of accounting and compliance with the requirements of external and internal regulatory documents, as well as carrying out inspections of various areas of banking activities and bank divisions. However, after the Bank of Russia's instructions No. 242-P dated December 16, 2003 came into force, approaches to the creation, functions, goals and objectives of the internal control and internal audit service began to change significantly and move closer to international standards and requirements. In modern world banking practice, a much broader understanding has developed internal audit goals. Its main mission is defined as assisting the bank in achieving its goals through a comprehensive assessment of internal management systems, risk management and control and providing recommendations to improve their effectiveness.

The need to develop appropriate modern trends the functions of internal audit (internal control service) for Russian banks that intend to move closer to international standards of activity in the coming years are determined by the following factors: such a function exists in all well-known Western banks; its presence in banks was officially recommended in July 2000 by the Basel Committee on Banking Supervision.

The main tasks of the bank’s internal control service include:

• - study and assessment of the sufficiency and effectiveness of the internal control system adopted by the bank;
• - control over the application and effectiveness of the risk management procedure and risk assessment methodology;
• - checking the reliability of the functioning of internal control systems over the use of automated information systems;
• - control over the accuracy and reliability of data and financial reports;
• - checking the methods used to ensure the safety of property;
• - assessment of the economic feasibility and effectiveness of the operations performed;
• - checking compliance with legal and regulatory requirements, rules of conduct.

The organization of the internal control service should be based on the following principles: underlying the modern concept of internal audit: continuity, independence, objectivity, competence, complexity.

The internal control service must be independent of the operations being audited and the daily control process. This means that this division has in the bank autonomous status and performs its tasks while maintaining objectivity and impartiality. He is given the right to solve his problems according to own initiative(according to the established plan) in all divisions and areas of the bank’s activities and freely report on their findings and assessments to management. The principle of independence presupposes that the internal control service carries out its activities under the direct control of the board of directors or the bank’s audit committee (if one exists). The head of the internal control service must have the right to directly contact the board of directors, the chairman of the board of directors, and members of the audit committee in accordance with the rules set out in the bank’s document regulating the activities of this service. Reports may result from actions taken by bank management that are contrary to legal and regulatory requirements.

The internal control service, in turn, must also be assessed by an independent party, if this is provided for in the bank’s charter (for example, external auditors, the bank’s audit committee).

The status and powers of the internal control service in the bank are determined by the charter (in accordance with the requirements of the law) and are established by the relevant document, which must contain a description of the goals and objects of internal control, the status of the unit, the rights and responsibilities of its employees, and the accountability of the head of the unit. This document is drawn up and periodically revised and approved by the board of directors of the bank. The document gives the division the right of initiative and allows direct access to any bank employee, inspections of any types of activities and divisions, as well as access to any documents, files and data of the bank, including management information, if this is related to the performance of the tasks of the division. The document must also include conditions for involving the unit in consulting and solving other special problems. It is advisable to communicate the contents of the mentioned document to all bank employees in order to avoid conflicts and misunderstandings during inspections.

The department must be objective and impartial in its activities. Objectivity and impartiality imply that the internal control function tries to avoid any conflict of interest. Therefore, the duties of department employees should be rotated periodically. Newly hired employees who previously performed any duties in the bank should not check the transactions that they carried out in the recent past. Impartiality requires service personnel not to become involved in the bank's operations or the selection and implementation of controls, since otherwise they would have to accept responsibility for this, which could impair their independence of judgment.

The bank's management may request the opinion of the internal control service on certain issues related to compliance with the principles of internal control (for example, when considering the prospects for reorganizing the bank, the internal control system, information systems, before commencing important or risky operations), but the bank's management is responsible for the final decision .

The importance of the professional competence of an individual employee and the entire department cannot be overestimated. The professional competence of each service employee, his motivation and constant training are prerequisites for the successful operation of the entire internal control service. Professional competence can be assessed by taking into account the ability to collect, examine, evaluate information and report results. In addition, it is necessary to take into account the increasing technical complexity of banking operations and the variety of tasks solved by the internal control service. Knowledge and experience deserve special attention. The unit must be competent enough to examine all activities of the bank. Advanced training should be mandatory for internal control systems employees. This can be facilitated by the participation of employees in seminars conducted by supervisory authorities and training centers, and constant independent study of newly adopted regulations and amendments to them. The professional competence of each employee must be systematically maintained. All department employees must have sufficient and up-to-date knowledge to carry out verification procedures.

The most important responsibility of the internal control system is to carry out regular inspections of the activities of bank divisions. Checks must be systematic. During the audit, it is necessary to study the processes and functions of the unit being audited from start to finish, i.e. trace a banking transaction from its inception to the financial reporting stage.

Inspections must be planned and carried out in such a way that, firstly, they do not create inconvenience for employees of the inspected units (sitting constantly in the inspected units), and secondly, do not allow the activities of the unit to fall out of the scope of attention of the internal control service. Setting inspection deadlines depending on the frequency and number of violations identified during previous inspections is also not justified, since in this case a unit that does not commit violations for some time falls out of the scope of attention of inspectors.

When conducting inspections, all results must be carefully documented and work materials retained. Documentation of inspection results is a necessary requirement for the internal control system. Bank of Russia Regulation No. 242-P dated December 16, 2003 leads to the advisability of developing methods for conducting inspections of divisions (taking into account the specific characteristics of each and the bank as a whole).

The final inspection document is an act. According to the requirements of the Bank of Russia Regulations dated December 16, 2003, the inspection report must contain the following information:

• - the number of the act, the date of its preparation, the inspecting unit and the employees who carried out the inspection, the unit being inspected. The purpose of the check is a list of issues to be checked;
• - data on the volume of inspected operations in the department, a list of inspected items characterizing the scope of the inspection; complete information is provided on violations, allowing, when reading the report, to see the essence of the detected violation, promptly reproduce the results of the investigation and determine the person responsible for performing this operation.
• - conclusions based on the results of the inspection, deadlines for eliminating deficiencies, if possible, signatures of the parties from the inspecting unit (performers of the inspection), from the inspected unit (responsible for carrying out the operations being inspected).

If the party being verified does not agree with the comments and conclusions contained in the act, it draws up a protocol of disagreements, in which it sets out its vision of the problem for each controversial position. In this case, the act is signed with the note “taking into account the protocol of disagreements.”

The last stage of any audit is monitoring the actions of the audited unit to eliminate the identified deficiencies. Without such control, the meaning of conducting inspections is lost and the performance discipline of both those being inspected and those inspecting is reduced. The materials of this stage must be documented and stored together with the inspection materials.

The constant interaction of the internal control system with internal opponents during banking operations has a positive effect on all bank personnel without exception. This applies to top management, collegial bodies, and performers. The decisions made inevitably become more specific, their formulations are clearer and more verifiable, and technological chains become more structured.

A separate function of internal control is participation in the coordination of internal bank regulations and procedures. This work actually represents preliminary control, since in the course of it, on the one hand, algorithms for the actions of workers are determined, on the other hand, as if in contrast to the first, algorithms for the functioning of control mechanisms designed to prevent violations of these rules.

The internal control service, participating in the approval of draft internal bank regulations and procedures, must study the presence and sufficiency of these control mechanisms, and then the compliance of the actions of bank employees described in the drafts with the requirements of regulations, i.e. perform the already mentioned functions themselves (check for compliance and monitor the presence of proper controls). All agreed upon documents must be checked for compliance with legal norms, legal acts Bank of Russia and international acts.

A number of problems are associated with the organization internal control at the level of strategic planning and forecasting, which is also partly within the competence of the internal control service.

The organization of the internal control system at the level of strategic planning and forecasting is to limit the impact of external factors and conditions when external risks arise (political, country, industry and others), which are identified, assessed and controlled by the bank based on the analysis. The main object of the internal control system at this level is the state of internal bank analytical work from the point of view of taking into account the impact of possible changes in the macroenvironment on the effectiveness of the current and future development of the bank.

At the stage of preliminary control, the internal control system supervises the completeness, composition and timeliness of updating the source databases, on the basis of which the analytical and functional divisions of the bank carry out a prospective assessment and forecast of the situation. The subject of preliminary control is also the existence of a procedure for promptly and systematically informing the bank’s governing bodies about the conclusions and proposals of analytical services on the current situation, about forecasts for the development of the situation in the relevant market segments and in the economy as a whole, in the field of regulatory support for banking activities.

For this purpose, comprehensive and thematic inspections of these units are carried out to determine the availability of the necessary tools, procedures and technical means to conduct an adequate analysis and bring it to the attention of responsible persons involved in the preparation and adoption of relevant decisions.

Current control is carried out by organizing periodic checks of the execution of analysis tasks, forecasting the situation by responsible employees and structural divisions of the bank and timely communication of conclusions and proposals of an analytical nature to the bank’s governing bodies.

In the process of current control, the presence in the functional divisions of the bank of a system for monitoring the competitiveness of the quality and cost of products offered by the bank on the market is monitored, comparing them with similar services of other credit organizations. In addition, the timeliness of the response of functional units to the actions of competitors, as well as to changes in economic conditions in the non-financial sector, is assessed.

Subsequent monitoring comes down to a comparative analysis of the conclusions and recommendations of analytical units and the actual development of the situation. The result of subsequent monitoring is the preparation of appropriate conclusions and proposals for compliance this direction bank activities.

It should be noted that the role of the internal control service is constantly increasing, since information about it has become one of the criteria for the financial stability of the bank, determining the possibility of the bank joining the deposit insurance system.

Features of the production and consumption of cultural values ​​have allowed culturologists to identify two social forms of cultural existence : mass culture and elite culture.

Mass culture is a type of cultural product that is produced in large volumes every day. It is assumed that mass culture is consumed by all people, regardless of place and country of residence. Mass culture - this is culture Everyday life, presented to the widest audience through various channels, including media and communications.

Mass culture (from lat.massa- lump, piece) - a cultural phenomenon of the 20th century, generated by scientific and technological revolution, urbanization, the destruction of local communities, and the blurring of territorial and social boundaries. The time of its appearance is the middle of the 20th century, when the media (radio, print, television, recording and tape recorder) penetrated into most countries of the world and became available to representatives of all social strata. In the proper sense, mass culture first manifested itself in the United States at the turn of the 19th and 20th centuries.

The famous American political scientist Zbigniew Brzezinski liked to repeat a phrase that became commonplace over time: “If Rome gave the world law, England parliamentary activity, France culture and republican nationalism, then the modern United States gave the world a scientific and technological revolution and mass culture.”

The origins of the widespread dissemination of mass culture in the modern world lie in the commercialization of all social relations, while the mass production of culture is understood by analogy with the conveyor belt industry. Many creative organizations (cinema, design, TV) are closely associated with banking and industrial capital and are focused on producing commercial, box office, and entertainment works. In turn, the consumption of these products is mass consumption, because the audience that perceives this culture is the mass audience of large halls, stadiums, millions of viewers of television and movie screens.

A striking example of mass culture is pop music, which is understandable and accessible to all ages and all segments of the population. It satisfies the immediate needs of people, reacts to and reflects any new event. Therefore, examples of mass culture, in particular hits, quickly lose relevance, become obsolete and go out of fashion. As a rule, mass culture has less artistic value than elite culture.

The purpose of mass culture is to stimulate consumer consciousness among the viewer, listener, and reader. Mass culture forms a special type of passive, uncritical perception of this culture in a person. It creates a personality that is quite easy to manipulate.

Consequently, mass culture is designed for mass consumption and for the average person; it is understandable and accessible to all ages, all segments of the population, regardless of level of education. Socially, it forms a new social stratum, called the “middle class”.

Mass culture in artistic creativity performs specific social functions. Among them, the main one is illusory-compensatory: introducing a person to the world of illusory experience and unrealistic dreams. To achieve this, mass culture uses such entertainment types and genres of art as circus, radio, television; pop, hit, kitsch, slang, fantasy, action, detective, comic, thriller, western, melodrama, musical.

It is within these genres that simplified “versions of life” are created that reduce social evil to psychological and moral factors. And all this is combined with open or hidden propaganda of the dominant way of life. Mass culture is more focused not on realistic images, but on artificially created images (image) and stereotypes. Today, the newfangled “stars of artificial Olympus” have no less fanatical fans than the old gods and goddesses. Modern mass culture can be international and national.

Peculiaritiespopular culture: accessibility (understandable to everyone) of cultural values; ease of perception; stereotyped social stereotypes, replicability, entertainment and fun, sentimentality, simplicity and primitiveness, propaganda of the cult of success, a strong personality, the cult of the thirst for owning things, the cult of mediocrity, the conventions of primitive symbols.

Mass culture does not express the refined tastes of the aristocracy or the spiritual quest of the people; the mechanism of its distribution is directly related to the market, and it is predominantly a priority for metropolitan forms of existence. The basis for the success of mass culture is people's unconscious interest in violence and eroticism.

At the same time, if we consider mass culture as a spontaneously emerging culture of everyday life, which is created ordinary people, then its positive aspects are its orientation towards the average norm, simple pragmatics, and appeal to a huge readership, viewing and listening audience.

Many cultural scientists consider elite culture as the antipode of mass culture.

Elite (high) culture - culture of the elite, intended for the highest strata of society, those with the greatest capacity for spiritual activity, special artistic sensitivity and gifted with high moral and aesthetic inclinations.

The producer and consumer of elite culture is the highest privileged layer of society - the elite (from the French elite - the best, selected, chosen). The elite is not only the clan aristocracy, but that educated part of society that has a special “organ of perception” - the ability for aesthetic contemplation and artistic and creative activity.

According to various estimates, approximately the same proportion of the population – about one percent – ​​has remained consumers of elite culture in Europe for several centuries. Elite culture- This is, first of all, the culture of the educated and wealthy part of the population. Elite culture usually means particular sophistication, complexity and high quality of cultural products.

The main function of elite culture is the production of social order in the form of law, power, structures of social organization of society, as well as the ideology that justifies this order in the forms of religion, social philosophy and political thought. Elite culture presupposes a professional approach to creation, and the people who create it receive special education. The circle of consumers of elite culture is its professional creators: scientists, philosophers, writers, artists, composers, as well as representatives of highly educated strata of society, namely: regulars of museums and exhibitions, theatergoers, artists, literary scholars, writers, musicians and many others.

Elite culture is distinguished by a very high level of specialization and the highest level of social aspirations of the individual: love of power, wealth, and fame is considered the normal psychology of any elite.

In high culture those are tested artistic techniques, which will be perceived and correctly understood by wide layers of non-professionals many years later (up to 50 years, and sometimes more). For a certain period of time, high culture not only cannot, but must remain alien to the people; it must be sustained, and the viewer must mature creatively during this time. For example, the paintings of Picasso, Dali or the music of Schoenberg are difficult for an unprepared person to understand even today.

Therefore, elite culture is experimental or avant-garde in nature and, as a rule, it is ahead of the level of perception of it by an averagely educated person.

As the level of education of the population increases, the circle of consumers of elite culture also expands. It is this part of society that contributes to social progress, therefore “pure” art should be focused on meeting the demands and needs of the elite, and it is precisely this part of society that artists, poets, and composers should address with their works. The formula of elite culture: “Art for art’s sake.”

The same types of art can belong to both high and mass culture: classical music is high and popular music is mass, Fellini’s films are high and action films are mass. S. Bach's organ mass belongs to high culture, but if it is used as a musical ringtone on a mobile phone, it is automatically included in the category of mass culture, without losing its belonging to high culture. Numerous orchestrations have been produced

Bach performances in the style of light music, jazz or rock do not at all compromise high culture. The same applies to the Mona Lisa on the packaging of toilet soap or its computer reproduction.

Features of elite culture: focuses on “people of genius”, capable of aesthetic contemplation and artistic and creative activity, there are no social stereotypes, deep philosophical essence and non-standard content, specialization, sophistication, experimentalism, avant-garde, complexity cultural values for the understanding of an unprepared person, sophistication, high quality, intellectuality.

Conclusion.

1. From the point of view of scientific analysis, there is no more complete or less complete culture; these two types of culture are culture in the full sense of the word.

2. Elitism and mass character are only quantitative characteristics related to the number of people who are consumers of artifacts.

3.Mass culture meets the needs of people as a whole, and therefore reflects the real level of humanity. Representatives of elite culture, creating something new, thereby maintain a fairly high level of general culture.