28-5-29

This paper is abstract, but there are still some gaps in the implementation process. In order to implement the "three lines of defense" construction, give full play to the supervisory function of the lines of defense at all levels, and truly form a mutual control mechanism of * * * management and joint monitoring, the author discusses how to further strengthen the "three lines of defense".

Three lines of defense are an important measure to build an internal supervision and prevention system, strengthen the internal supervision and restraint mechanism, effectively improve the internal prevention ability, effectively prevent business risks, and curb all kinds of violations and cases. It is also an important means of internal control management of rural credit cooperatives at present. The city's rural credit cooperatives have achieved certain results in their operation for nearly three years. However, there is still a certain gap in the implementation process. In order to implement the construction of "three defense lines", give full play to the supervisory function of defense lines at all levels, and truly form a mutual control mechanism of joint efforts to monitor and control, the author talks about how to further strengthen the construction of "three defense lines".

first, the status quo of the "three lines of defense" of rural credit cooperatives

Objectively speaking, rural credit cooperatives have continuously improved and strengthened internal control management in recent years, established and improved a series of management systems, especially in strengthening the construction of the "three lines of defense", repeatedly revised and formulated the inspection contents and assessment methods of each line of defense, but there are still omissions and weak links in the implementation, supervision, assessment and accountability of each line of defense.

(a) the status quo of a line of defense

1. There is a blind spot in the system construction. First, some credit cooperatives have not refined the assessment methods. Although the credit union has introduced various assessment methods, the credit union mostly decomposes the assessment of business objectives to the branches under its jurisdiction, ignoring the refinement of internal control assessment and the refinement of those responsible for internal and external work; The second is to emphasize the establishment of the system and neglect the formulation of procedures or lack of operability. Because the system of the union is partly instructive and framed, most credit cooperatives have not been refined according to their own management needs. They only emphasize "what to do" and ignore "how to do it". Some have established but have no specific operation content, which makes some employees think that "the result is more important than the process". Abuse of "cat theory" leads to such irregularities as reverse operation, "acting first" and handling business beyond authority, which are often seen in practical work.

2. Institutional learning has not been implemented. Some credit cooperatives write it on paper, talk about it on their lips and stick it on the wall, but they don't seriously prescribe the right medicine and fail to implement it. Some post personnel do not have the ability to adapt to risk prevention and internal control. Most clubs only pay attention to the operational skills of business personnel, ignoring the study of laws and regulations, which inevitably leads to "free play" in their work and "dancing on the crater" of risk prevention, resulting in many problems that cannot be discovered in time and blocked in time. For example, some loan officers lack professional knowledge and legal knowledge, sign contracts at will, and ignore the limitation of action and execution when collecting loans, resulting in the loss of credit cooperatives' rights and funds.

3. if you don't follow the rules, you will repeat them. Mainly reflected in the disregard of the rules and regulations of credit cooperatives, there are orders and prohibitions; There are policies on the top and countermeasures on the bottom; Human feelings are greater than the system. First, the counter personnel are not in place to restrict and control each other. If no monitoring measures are taken for abnormal cash withdrawals in account management,

it is common that large cash withdrawals are not handled according to the specified purposes, some agencies fail to conduct timely approval, and some of them are registered in the large payment register for one or several days, which lacks the ability to identify the authenticity and legality of customers' funds sources. Bank-enterprise reconciliation is not handled according to the regulations, and most of the accountants of credit cooperatives are responsible for both bank-enterprise reconciliation and accounting treatment, losing supervision and restraint. Tellers and tellers did not check the compliance and completeness of the day's transaction with the teller's flow on the same day, and did not cross-check or check the cash and the empty voucher tail boxes between tellers. Second, credit management is not in place. For example, the credit file management is not standardized, the "three-check system" is a mere formality, the same borrower has multiple credit subjects, and it is difficult to implement the first responsible person system. In the "three-check system", the pre-loan investigation is the key link of risk control, which requires investigators to go deep into the enterprise to check the account books and vouchers, verify the relevant data, understand the products, production, operation and management of the enterprise, and make comprehensive analysis and research through a large number of data to form an objective, fair and decision-making conclusion. However, it is precisely at this "point" that the loan officers cannot make in-depth investigations and are not relevant. Only according to the relevant written materials provided by the enterprise, the report data provided by the enterprise can be easily collected and used, extracted and integrated according to the requirements of credit management, and superficial articles are made. The conclusion made by such a pre-loan investigation report makes the loan lose security. As the key link of risk control, post-loan inspection requires credit personnel to go deep into the enterprise to monitor its economic activities and capital flow, and carefully analyze its loan risk changes. However, credit officers have relaxed the follow-up management of many loan enterprises. Because they don't have enough time to get to know the situation, they can't keep abreast of the changes in the production and operation of enterprises. Post-loan management is mainly to meet the needs of daily system inspection. This inspection is the shift of enterprise report data and a written reflection made by impression, which can't truly reflect the actual situation of enterprises and loses the real significance of post-loan inspection, which is the main reason for the failure of loan early warning mechanism. Then there is the credit rating of small farmers. Most credit cooperatives listen to the opinions of village heads or account managers when granting credit, resulting in information asymmetry.

4. Pay more attention to task completion than system implementation. Some credit cooperatives can't establish a correct outlook on performance, and often violate the rules and regulations for the short-term interests of credit cooperatives. For example, some credit cooperatives carry out illegal operations such as top name, impersonation and pseudonym in order to complete credit loans for small farmers; In order to complete the deposit task, some clubs use private funds to avoid interest tax as bait; Others don't insist on saving real-name registration system and open savings accounts in violation of regulations; Some people are afraid of offending customers, and they take large amounts of cash in one day. In order to control the incidence of non-performing loans, some credit cooperatives actively adjust the loan term when the borrower is not present to handle the formalities of extension or loan repayment, which has laid a curse for the maintenance of creditor's rights.

5. Supervision and inspection are not in place

The managers of grass-roots credit cooperatives have the following problems in their duty inspection: First, they are unfamiliar with business. Some branch leaders have been engaged in credit management for a long time and are not familiar with the new business system. They don't know where to check and how to start. The second is not to perform their duties seriously. In order to cope with the inspection by the Associated Press, some agency administrators or afterwards supervisors simply copied the last audit manuscript, but did not really check the important business of authorized credit, so they directly marked √ on the teller's running list to show the check, which made it impossible to find out the irregularities and major risk problems in business operation and management in time. In addition, the lead accountant only randomly checked the branch, and the problems reflected were not timely or comprehensive, resulting in operational risk hazards; Third, the rectification and investigation of the problems found in the audit are not in place. During the supervision and inspection at all levels, the director, the accountant in charge and the person in charge of the branch failed to confirm the facts of the problems detected at all levels, and put forward rectification opinions. Most of them stayed in words, and the continuous supervision and rectification and follow-up inspection were not in place. Some of them were afraid of offending people because of their feelings, and they did not dare to impose financial penalties on serious problems or repeated problems. Often, they rolled into small things, so that violations of discipline could not be investigated in time, which encouraged the responsible person to take chances and caused problems.

(2) The management status of the three lines of defense

1. The inspection method is outdated. This is a * * * problem of three lines of defense supervision: First, the scientific and technological content of supervision means is not high. Not giving full play to the role of the new generation integrated business system; The inspection method is single, mostly "intermittent" inspection, lacking continuity and comprehensiveness. The second is to check that there is no depth. The reaction is more in shallow examination and less in deep excavation; * * * There are many sexual problems and few individual problems; There are more business inspections and less behavior investigations; Many problems are found and few loopholes are blocked (which leads to a vicious circle of repeated investigations, repeated crimes, repeated corrections and repeated corrections).

2. There are blind spots in the supervision of functional departments. Due to the rural credit cooperatives' wide coverage and rapid development of new business, and the limited number of inspectors in functional departments, most of the supervision projects are special. In addition to dealing with the special inspection of the municipal cooperatives, some cooperatives implement quarterly joint inspections. Due to the tight time and wide scope, such inspections are only general and the results are not deep. The items required by the department for special inspection on a quarterly basis have not been effectively implemented, such as agency business, fixed assets, abnormal transaction handling and inquiry, debt-paying assets, supervision of new large loans and their funds, off-balance sheet business, especially written-off loans and central bank bill replacement, and so on.

3. Risk cannot be effectively identified. At present, the focus of audit supervision of rural credit cooperatives is to implement system inspection and case investigation. Little attention is paid to the deep-seated contradictions in the operation of rural credit cooperatives (such as asset quality, capital operation, financial situation, etc.) and the financial risks that endanger the survival of credit cooperatives. Most credit cooperatives are only satisfied with the "separation of examination and loan" in the decision-making process, but they lack the means of credit risk and transaction risk management and monitoring, so they cannot carry out effective early warning management. The identified risks can't be accurately evaluated and effectively controlled, and the prominent performance is that the monitoring means and measures are inappropriate and can't play a role. For example, for the risks of group customers and affiliated enterprises, credit cooperatives cannot obtain comprehensive and accurate information and accurately evaluate the degree of risks because of the complex relationship and multi-head credit granting. Once the risks are exposed, they will bear huge losses.

4. The auditors are not full-time, which can't meet the requirements of sequential audit. Auditors should not only undertake the outgoing audit and term audit of senior managers (all loan households are checked internally and externally one by one in the audit), but also undertake the re-supervision work of their own offices, cope with various special inspections of higher-level banks and some special work in various functional departments and offices. In addition, some auditors were dispatched to the municipal union for inspection many times within one year, and the audit and supervision of some unions were not separated, so the discipline inspection and supervision work, especially the petition work, occupied a certain period of time, which made it impossible to take care of both internal and external work. However, the associated press with many outlets has more than 1 outlets per auditor. After practice, the existing auditors can't achieve the sequential audit and supervision of the whole process, let alone analyze the "process" of business operation and find out the reasons. In the inspection, the rationality of credit business, financial revenue and expenditure and internal management is generally and routinely checked at most, and it is difficult to find deep-seated loopholes in management and internal control.

5. There is a blind spot in the audit re-supervision. Because the audit department and functional departments are in parallel positions, it is difficult to establish the independence and detachment of re-supervision. As a result, the audit object of rural credit cooperatives at present is only grass-roots business organizations, and rarely involves the business and management departments of credit management, financial management and logistics support of the union organs. Even if they are involved, they are only a mere formality. However, the above departments actually undertake important functions such as large loan approval, financial expenditure review, capital construction and bulk goods procurement, and they will inevitably "pick sesame seeds" without supervision and inspection at the same level. The audit proposal sent by individual departments and offices is also difficult to implement.

II. Precautionary measures

(1) Further strengthen and improve the supervision and restriction mechanism of the first line of defense

The first line of defense is the fundamental guarantee of the "three lines of defense" and is the most critical link, which is mainly controlled from the aspects of system standardization, mutual supervision of counter personnel, supervision of the host accountant, and supervision of the director and deputy director of the credit cooperative and the person in charge of the branch.

1. Formulating a standardized, scientific, strict and perfect internal control system is the most effective means to implement preventive measures in advance. The first is to formulate an examination system. It is necessary to conduct regular examinations on the study of various systems and relevant laws and regulations for a period of time, and urge them to master the operating procedures and the initiative and consciousness of operating in compliance with laws and regulations; The second is to integrate and refine the system. On the one hand, the credit cooperatives should extract the core contents of the relevant management system of the credit cooperatives and integrate them into a concise, cohesive and supporting reference book, one for internal and external service, which is convenient for memory and operation. On the other hand, supplement and improve various systems. Part of the system of the union is instructive and framework. Grass-roots credit cooperatives should work out operational management methods according to the specific responsibilities of various post personnel, and work out specific operational procedures on how to do it on the basis of clear what to do. There are two categories: one is the technical system and rules of business operation; The other is the system and method of business restriction and supervision. During the supervision and inspection, credit cooperatives carefully check and verify the strictness, efficiency and completeness and rationality of mutual restriction and coordination among business links, and monitor the process lines, risk points and restriction points throughout the process around business flow, capital flow and control flow to eliminate monitoring blind spots. Summarize and reflect on the hidden dangers and problems found, and put forward constructive suggestions to further improve the internal control system, so that the internal control system will be more and more perfect, and it will continue to be comprehensive, rigorous, precise and effective, and achieve a new round of higher-level pre-audit control; The third is quantitative assessment. On the one hand, it is clear about the specific responsibilities of the personnel in each position, and it is programmed, standardized and accountable for the management of the personnel in each position, combining responsibility, power and benefit for performance appraisal, and implementing management such as elimination and admonition. On the other hand, we can consider the unified management of the sponsoring accountant in the receiving area, and change it to the appointment system. The salary and performance pay will be assessed by the association, so that the sponsoring accountant is responsible for both the association and the credit union. Fully reflect its independence in performing its duties.

2. Timely control and mutual supervision and restriction are the keys to the implementation of in-process control. First, strengthen mutual supervision and restriction among personnel in various positions. The whole process of accounting treatment should be implemented in advance, in the process and in post supervision, that is, supervision in advance-when accepting business, the counter personnel should carefully review the legality, authenticity, completeness of procedures and accuracy of data; In-process supervision-recheck the accounting vouchers, account table contents and data, and review and recheck all the accounts, books, certificates, data and tables handled by the agency one by one. Payment vouchers without recheck shall not be paid, statements shall not be submitted, and documents shall not be issued. Post supervision —— To recheck the accounting accounts that have been processed, it is necessary to ensure that all tellers' business operations must be reviewed in a timely and uninterrupted manner afterwards. During the inspection, the handling process of important businesses, including the special business of authorization and credit granting in the teller's flow, should be supervised, and problems should be corrected in time; The second is to pay attention to regular checking of accounts. It is necessary to adhere to the standard of "six conformity" and do a good job of regular check. Establish and improve the external reconciliation system, and check different accounts daily or regularly according to regulations. For farmers' loans and savings deposits, the method of annual check should be adopted. Farmers' loans should be checked one by one, and savings accounts should be checked once a year, and accounts should be established one by one.

3. Strengthen the supervision and inspection of front-line managers. First, the managers of credit cooperatives have a good understanding. Take the initiative to overcome the idea of "being a good guy" and "being afraid of offending others", dare to face difficulties and boldly exercise the supervision function of a line of defense, and the inspected object should also be recognized in place, and inspection and supervision should be treated as a safeguard measure to find problems in time and enhance their "immunity"; Second, focus on strengthening the management of credit, savings, accounting, inter-bank and other important positions involving money, accounts and their operators. We must pay great attention to those who have abnormal behaviors and remind them.