Suggestion on change of role & responsibility of SBCO, Post GL integration - AISBCEU-CHQ

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ALL INDIA SAVINGS BANK CONTROL EMPLOYEES UNION
(Service union under Dept. of Posts)

CHQ UNION WEBSITE: http://www.aisbceu.blogspot.in/

[HQ- A-174 MAHESH NAGAR, 80FEET ROAD NEAR TONK FATAK, JAIPUR 302015 RAJASTHAN CIRCLE]

AJMER SINGH
PRESIDENT
PA, SBCO, PANIPAT HO  - 132103
HARYANA CIRCLE
CELL: 094667 68083                                    
Email: chhikara.ajmersingh@gmail.com		 BHARAT B. SHARMA
GENERAL SECRETARY
PA , SBCO, JAIPUR GPO-302001
RAJASTHAN CIRCLE
CELL: 9413453844
Email: sharmab311@gmail.com		 SURESH CHAND TRIPATHI
TREASURER
PA, SBCO, KUANRAGHAT HO
ANDHARA PRADESH CIRCLE
CELL: 94155 00031
Email:

CHQ LR NO: AISBCEU/Regarding input/suggestion on change of SBCO role /11-2019   DT: 06.12.2019

TO
Sh.Sachin Kishore
DDG [FS]
DAKBHAWAN, SANSADMARG
NEW DELHI–110001

Sub: Regarding input/suggestion on change of role & responsibility of SBCO, Post GL integration.

Ref: Dte. Lr. No:    FS Division  Dt.22.11.2019

A kind reference is invited to the letter under reference, wherein the competent authority has sought inputs/suggestions from the Heads of the Circles and other stake holders of the Department on change of role and responsibility of SBCO, Post GL integration.

Your honour self knows that this Union is constituted exclusively for the welfare and prosperity of the SBCO cadre and having a membership of more than 80% of the SBCO staff across the country.
This Union welcomes the action of the Directorate in calling the suggestions to make necessary modifications in the existing role and responsibility of the SBCO so to align the same with the changed environment i.e., post GL integration and to make it more potent and effective towards fraud prevention and detention.

Upon going through the terms of references given by the Directorate, it made it clear that Directorate wants to design the role of SBCO exclusively as a fraud prevention and detection agency for the Department of Posts.

Keeping in view of various transformational changes happened since the setting up of SBCO cadre, this Union would like to suggest the following modifications to the existing role as provided in SB order 14/2015 and consequent instructions from time to time.

1) At the time of setting up of the SBCO organization, the main functions assigned to the SBCO is to maintain control accounts of all the Savings Banks Schemes, to carry out percentage checks of vouchers and other items of work, to verify binder ledger balances periodically, to keep in its safe custody important records such as vouchers, undelivered pass books, list of transactions, silent accounts lists, interest cum silent accounts statements, various control registers, etc. , to check annual calculation of interest in SB/PPF/NSS accounts, Preparation of annual interest and silent accounts statements, to submit periodical returns to various authorities such as Postal Accounts Office, Divisional Office, Circle Office and Internal Check Organisation (SB) .    

2)  After the introduction of CBS/Finacle, the Directorate has redefined the role of the SBCO and released the fresh guidelines in the form of SB order 14/2015. It shall be appropriate to recollect the highlights of the said order.       
  1. A) The works which are discontinued:  
  1. a)Maintenance of the Register of Office wise [SB- 63/RD85] Balances.
  2. b)Maintenance of the Register of Non-cash transactions SB-62 [a]/85 [a]
  3. c)Checking of Non-cash Transactions
  4. d)Revival of Accounts pre 01.01.2003
  5. e)Reporting of Minus balance      
  6. f)Verification of binder balances    
  7. g)Checking of Annual Interest   
  8. h)Monthly progress Report                        
  9. i)Checking of Agents Commission bill 
  1. B)The works which are modified: 
  1. a)Maintenance of Statistical has confined for non-financial part.
  2. b)   Preparation of Interest statement is confined to grand summary only.
  3. c)Receipt of returns from the Sub-Accounts branch directly without the intervention of the SOSB branch of the HO.
  4. d)Submission of Copy of the statistical register (non financial if all Post Offices in CBS), Report of Silent Accounts (to be taken from Finacle Application), Annual Interest Summary, Details of interest adjustments to AO/DA (P). 
  1. C)The works which are continued without any modification: 
  1. a)Maintenance of objection Registers.
  2. b)   Maintenance of Register of Un-used Cheque Foils.
  3. c)   Maintenance of Register of Un-deliverable & spoilt Pass books.
  4. d)  Custody and preservation of records.
  5. e)  Register of vouchers given for enquiry
  6. D)The works which are newly added to the SBCO:  
  7. a)Receipt of returns from the Sub-Accounts branch and to attend for segregation of the records as per the scheme wise/Office wise.
  8. b)Generation of LOTs for each SOL and for each category of work for verification of vouchers.
  9. c)Generation of consolidations for each category of work using SETID for consolidations for verification of consolidations sent by the SPMs.
  10. d)Preparation of Grand summary of consolidated journal for each scheme of work and to tally them with Cash Book.
  11. e)Maintenance of Interest Adjustment Register. 
3) Many of the local officers of the Department are of the opinion that after introduction of the Finacle, the workload of the SBCO branch has been decreased drastically and some of them are even commenting that it is better to wind up the SBCO branch. As such this Union would like to compare the voucher checking work between the pre and post CBS environment.

General check of vouchers and checking of vouchers with reference to entries in the ledger cards as per D.G Posts letter No. 5-2/99-SB dated 5.3.2003 General check of vouchers and checking of vouchers as per SB order 14/2015 dated 19.10.2015 i) General check of vouchers
ii) Checking of Vouchers with System Generated LOTs as per Para 3(7) of Addendum-II of SB order 14/2015 dated 04.08.2016.
(i) All vouchers of payment in respect of withdrawals exceeding Rs. 5000/- at head and sub offices and Rs. 2500/- at ED sub offices and branch offices.
(ii) Warrants of payment of 20% of closed accounts of heavy amounts.
(iii) 4% of deposits in head and sub offices.
 Will remain continued as at present (a) All Closure vouchers of all schemes.
(b)  All RD & PPF Loan disbursement vouchers.
(c)   All vouchers of Savings, PPF and SSA of the amount of Rs.20000/- and above for LSG and above offices and all vouchers of Savings, PPF and SSA in respect of other offices irrespective of any amount.
d)   All new accounts opened vouchers for the amount of Rs.5 lakh and above.

SB Order 03/2018 stipulates that “100% of verification of SB transaction should be invariably done through MIS server by SBCO as prescribed.”

The above instructions categorically states that the Directorate has given much importance to closure of accounts of all types, Loans in respect of RD & PPF, all new accounts of 5 Lakhs and above  and 100 % verification of SB transactions.

4) Besides voucher checking another important work assigned to the SBCO is checking the daily/progressive totals of consolidation of each scheme with reference to the Cash Book on daily basis. In the pre CBS environment, the SOSB branch of the HO used to prepare the consolidations and tallied with the SO summaries and after tallying, the same along with daily returns are to be SBCO for further course of action. But, after the introduction of the Finacle, the SBCO has been entrusted to prepare the consolidations and tallying them with Cash Book.

But, with the introduction of the CSI, the Accounts branch of the HOs has discontinued the preparation of Cash Book across the country without any instructions from the Directorate. Likewise, no instructions/procedures were given to the SBCO to tally the consolidations in the absence of the Cash Book.

At the same time, DARPAN was also launched across the country to strengthen the rural base services by inducting the technology to the gross root level. Due to which, the consolidations are to be generated by the SBCO from two channels i.e, SDP Channel and BRN Channel.

Likewise, with the introduction of CSI, the generation of daily accounts was limited to each Profit center. In a nut shell, with the introduction of the different softwares like Finacle, CSI & RICT, the figures were split up and kept the SBCO such a position that it cannot carry out the tallying of the consolidated figures with Cash Book/CSI.

At this juncture, it is pertinent to refer point no 6 of DO letter no -116-22/2018-FS dated 21.12.2018 issued by Shri Sachin Kishore ji, DDG (FS) to all the Heads of the Circles “As regards strengthening of SBCO, relevant orders/instructions are issued from time to time. The roles/responsibilities of SBCO are likely to undergo considerable change after GL integration & revised/updated orders would issue once the GL integration is completed & made functional. Till such time, scheme wise consolidation of a SOL to be matched with CSI Daily report of the concerned Post Office by SBCO.”

But, in reality matching of scheme wise consolidation of a SOL with CSI Daily report is highly impracticable to a common SBCO official without any tool/software.

5) Your honour self knows that FSI (GL integration) was launched on PAN India basis on 16.10.2019 and it is learnt that the Finacle figures are being captured automatically without giving scope for manual intervention. Due to such secured provision, this Union believes that the work relating to checking of the daily/progressive totals of consolidation of each scheme with reference to the Cash Book /SAP shall be discontinued.

6) The Standard operating procedure (SOP) after implementation of GL integration between CBS and CSI transactions contained in SB order 09/2019 clearly stipulates that there is no role for the SBCO due to the automation of works in respect of accounting of cash pertaining to CBS/Finacle. All the CBS transactions, channel transactions, RSAO entries, interest booking and interest application, SOL transfer entries, Scheme transfer entries, GL transfer entries and RICT transactions will be accounted in the daily account in post GL Integration.

7) Para 5.3 of SB order 14/2015 deals with writing of Objections and maintenance of Objection Registers by the SBCO. Any irregularity noticed will be entered in clear and concise words in the Objection Register. Every irregularity should be brought to the notice of the Postmaster for necessary action. Supervisor SBCO will write to Head of Postal division in case of those objections where inquiry is required and those which are not settled within 30 days. But, in reality it is observed that majority of the Divisional Heads and Postmasters of the concerned HOs are not at all showing any interest in settlement of objections raised by the SBCO and thereby the objective of placing any irregularity under objection, lost its validity.

8) As per Para 1.7 of SB order 14/2015, Postmaster/APM/SPM will be held personally responsible for all transactions happened in the Finacle Office Accounts in the post office. They should be vigilant while verifying the transactions to see the Office Account Number used by the User.

Post to GL integration, the role of SBCO is confined to the following works:
Present nature of Work after SB Order 14/2015 Proposed Work in Centralized  SBCO Post GL Integration
Receipt of Returns
(All category deposit &  withdrawal vouchers)		 Only finacle Consolidation along with high value withdrawal vouchers(above Rs.50000/-), RD & PPF Loan disbursement vouchers,  and all types of Closure vouchers with SB-3/AOFs are to be sent to centralized SBCO on the next day by the Profit Centres. Consolidation supplied by the post offices should tally with Consolidation generated from finacle by SBCO. Number of vouchers sent with the bundle must be written on the face of the consolidation by the concerned post offices along with date stamp and signature.
Checking List of Transactions
 [SB 60/76]		 Such Vouchers has to be checked SOl/Profit Centre wise by SBCO by generating LOT form Finacle. In case of discrepancy, objection memo should be raised and sent to concerned PO for clarification through RO/Divn.Head
Consolidated Journal of all the Schemes Consolidated Journals sent by each office has to checked by SBCO with SBCO generated Consolidations from Finacle. In case of any manual entry/overwriting(without error note) OR other discrepancy OMs to be raised by SBCO and served through RO/Divn.Head
Checking of Vouchers:
i) General check of vouchers will be carried out as prescribed in para 5 of SB Order 14/2015.
ii)Checking of Vouchers with System Generated LOTs will be carried out as prescribed in para 5 0f SB Order 14/2015 for following type of vouchers:
(a)All types of closure vouchers

(b) All RD & PPF Loan disbursement vouchers.

(c) All vouchers of Savings, PPF and SSA of the amount     of Rs.20000/- and above for LSG and above offices and all vouchers of Savings, PPF and SSA in respect of other offices irrespective of any amount.
d) All new accounts opened vouchers for the amount of Rs.5 lakh and above.		 Checking of Vouchers: Closure & other vouchers sent with consolidation will be checked as prescribed in Point 1 above.
Vouchers other than closure vouchers will be checked during periodic inspection of HOs,  like done by (ICO) at present.
It is proposed that all investments & Payments (wdl, int., bonus etc.) in Small Savings has to be made through Savings account (POSB) only. Office accounts (Postmaster a/c etc.) should not be used for investment.
It should be started from a specific date with prospective effect. Old Cases will be closed in due time, so maturity/closure cases before this specific date should not be hampered.
Single KYC for POSB account opened should be used for all other purposes also. This will also reduce paper work and load on CPCs and preservation of records.
Vouchers(HO+SO) should be kept at HOs under custody of the Postmaster. The place left by SBCO branch can well be utilized for this purpose.
As less number of vouchers will be sent to centralized SBCO at RO, they will require less place for preservation of records.
Objection Register Will remain continued without any change. Rule13 Objection Register will remain continued post office wise, scheme wise, at centralized SBCO and OMs will be served through Divn.Head/PM. The settlement process should be done by the operative staff Postmaster/PAs and the admission of OMs only will be done by SBCO staff. The responsibility for pending OMs should be fixed with operative staff only.
Un-used Cheque Foils Continued as it is. Rule – 18
 To be kept with vouchers after cancellation by APM at HO. (To be checked during Inspection)
Un-deliverable & spoilt Pass Books Continued as it is. Rule – 19
 To be kept with vouchers after cancellation by APM at HO. (To be checked during Inspection)
Statistical Register Only non financial part will be continued. Rule – 20
 Reports from finacle only. SR format in finacle may need modifications.
Custody and preservation of Records Continued as it is (without LOT).
Rule – 25		 Only Consolidated journals, closure vouchers with AOF/SB-3  RD/, PPF loan vouchers and high value withdrawal vouchers preserved  at Centralized SBCO, other docs & vouchers at HOs under Sr.PM/PM. Preservation period of vouchers may be reduced to 3 years.
Submission of returns to AO& DAP * Only Statistical Register (non financial) and Interest Summary will be continued.*
Rule - 40
*This will be discontinued once CSI and FSI both are rolled out in all Post Offices.		  Will not be necessary if Centralized SBCO work under DAP itself.

Post GL integration CSI & FSI are both rolled out in post offices.
With the existing set up of SBCO, except the differences between the amounts noted on the voucher and available in Finacle, fraud detection is highly impossible and high number of the frauds post to Finacle supports the statement.

The role of field staff ie., Mail overseers/IPs/ ASPs/DHs became very crucial in fraud detection but  due to the BD targets, they are very lenient in this aspect and also escaping from the burden of subsidiary offenders due to the loopholes in the inspection questionnaires. This fact is also known to them and therefore highlighting the SBCO staff whenever frauds are taken place.  It is also known to very officer that forgery signatures cannot be detected with naked eyes.

From the above, this Union strongly believes that due to automation of accounting & tallying of figures and generation & posting of interest in SB/SSA/PPF/NSS accounts has decreased the purpose for which the SBCO is carved from the DA (P). Except a few works, majority of the works like Maintenance of Register of Un-used Cheque Foils, Maintenance of Register of Un-deliverable & spoilt Pass books, Custody and preservation of records, Register of vouchers given for enquiry, Maintenance of Interest Adjustment Register  can be manned by the Postal staff. 

If the Department is really decided to strengthen the Role of SBCO, change of Role in the function of work is not sufficient, first it should decide whether the auditing of POSB transactions can properly discharged by SBCO staff under the control of Divisional administration where they are treating the SBCO staff as sixth finger or adopt a new structure by the centralization of all SBCOs at Regional level under the control of Accounts officer.

At present the SBCOs are functioning under the control of Divisional Heads and their APAR are written by the Divisional Heads for which the SBCO staff could not attend their auditing work freely to raise objections in case of irregularities and it is one of the major reasons for happening frauds frequently in Savings Bank transactions.

In the present SBCO setup, the Divisional Heads are not following the Directorate instructions to provide manpower to SBCO staff and also giving much pressure to SBCO staff to settle the long pending objections to avoid adverse reports from the DPS/PMG/CPMG and they are very much interested to fix recovery and punishments in the frauds done by the sub/branch offices. This is one of the major reasons for happening frauds in all sub/branch offices.

Now as most of the SBCO units all over the country are suffering from acute shortage of staff , proper auditing work could not be achieved under present work structure in absence of  SOSB, Sub Account branch etc. SBCO staff has to undertake from finding irregularities in transactions through voucher checking, then raising OMs, then correspondences to HO/SOs (previously done by SOSB) up to settlement of OMs and sending various reports as & when asked for to higher authorities. More over as SBCO has to work under local administration, any other work assigned by the local administration (apart from which has been assigned by the Directorate) has to be carried out by the SBCOs.

If the Department is really interested to minimize the frauds, the SBCO staff should be identified as Auditor and they must be allowed to discharge their auditing work freely without any pressure from the local administration [Divisional Head] and their APARs must be written by the officers from Accounts cadre for the proper auditing of all Savings Bank transactions involving Crores of rupees pertaining to lakhs of Depositors.

Further, the following ground level realities/hardships and requests are to be considered by the competent authority.
  1. i) As per para no 14 of SB order 05/2016, The Directorate has issued many instructions to the Region/Divisional Heads to provide PA assistance, but it is not being implemented by majority of the Divisional Heads. They perhaps believe that giving instructions to the Postmaster itself is enough rather than its implementation.
  1. ii))Till now, the Directorate has not taken any action on the Regional/Divisional Heads for not carried out the Directorate instructions to provide additional man power due the implementation of new schemes of CBS, CSI/RICT and 100% voucher checking.
iii)  The Divisional Heads are very particular to victimize the SBCO staff in the fraud cases, that also during the verge of retirement without considering PAs requirement.
  1. iv)The work pattern as mentioned in the SB order 14/2015 mainly highlights the Supervisor -PA mode But, in many HOs, PA-PA model is in existence without Supervisor post. It should be find a solution to fill up all the Supervisory posts of LSG, HSG I & II to ensure the supervisory work.
  2. v) Many of the SBCO units across the country arerunning single handedlyand without regular Norm based LSG/HSG I & II Supervisors in more than 80% SBCOs.
  3. vi)Now only ad-hoc norms were issued.  Proper norms must be issued and the establishments of all SBCOs are to be reviewed and sufficient manpower has to be provided.
vii)  At present, for example the Units having four PAs with one Supervisor strength, the actual available PAs may be two, if any lapses are happened in the remaining vacant seats, the responsibility is fixed with the available ignorant two PAs and  they are punished with huge amount of recovery & some of them are punished at the time of retirement instead of punishing the Divisional Heads for not providing required PA Assistants as per the FS Division instructions. This attitude must be changed in the new Roll of SBCO setup. Otherwise, no one will secure the SBCO staff and ensure the POSB auditing works with reality.

Hence, this Union suggests winding up the SBCO branches from the HOs entirely and merging with DA (P), which is the mother organisation for auditing in the Department besides giving an option for the existing SBCO PAs to Postal side by protecting their inter seniority, as per their choice.

Thanking You Sir.
                                                                                            Yours faithfully,
(B.B. Sharma, General Secretary, AISBCEU]

Copy to:
  1. SH.ASHOK PAL SINGH, Member [Banking], Dak Bhawan, New Delhi=110001  for information. MAIL ID: memberbanking&hrd@indiapost.gov.in
  2. Shri.VINAYA PRAKASH SINGH, Sr.DDG, Vigilance & CVO, Dak Bhawan, New Delhi-110001. Mail ID:  cvo@indiapost..gov.
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