CC BY
65
UDC 336.02
MODERN ASPECTS OF ACCOUNTING POLICIES FORMATION OF THE CREDIT ORGANIZATION, REFLECTION OF STRATEGIC AND TACTICAL PROBLEMS OF BANK DEVELOPMENT IN IT
Logvinskaya N.M., Post-graduate student
Financial university at the Government of the Russian Federation, Moscow, Russia
E-mail: [email protected]
ABSTRACT
The basic purpose and the main task of the chosen accounting policies is to reflect activity of the credit organization in the most adequate way, to represent full, objective and reliable information about it. The solution of this task will allow the credit organization, on the basis of the received financial reports, to make right administrative decisions, to estimate a financial position objectively, to put before it the right priorities, allowing increasing efficiency of business. Besides, the credit organization with accurately thought over accounting policies can position itself on international, and in domestic market, as the organization of the international level with a potential of a sustainable development.
KEY WORDS
Accounting policies; Credit organization; Bank; Accounting; Accounting regulation; IFRS, Document flow.
The main objective which is realized by the credit organizations during development and formation of accounting policies is a determination of uniform set of ways of conducting accounting. As a rule, ways of primary supervision and registration of the facts of financial and economic activity, receptions of the organization of document flow are approved, the order of processing of registration information, methods of application of accounts of accounting, ways of generalization of the facts of activity of the organization, methods of group and methods of conducting accounting is organized. The introduction in action of the new normative document — Provisions of Bank of Russia of 16.07.2012 No. 385-P "About rules of conducting accounting in the credit organizations located in the territory of the Russian Federation" (further — Situation No. 385-P) became the main event of 2013 for accountants of the credit organizations. This document replaces earlier operating Regulation of Bank of Russia of the same name of 26.03.2007 No. 302-P (further — Regulation No. 302-P) by which since January, 2008 accounting in banks was regulated. In four years of action of this Regulation fifteen editions, specifying or expanding an order of carrying out and registration of bank operations were accepted. Changes were made generally in connection with a tendency of rapprochement of rules of the Russian accounting and International Financial Reporting Standards. As a result the account in banks became more transparent for analysts and users of financial information, having at the same time expanded possibilities of banks on application of rules of the account in the concrete credit organization.
Therefore the bank accounting policies becomes more and more important internal normative document. In this regard acceptance in 2012 became timely also. The Bank of Russia Regulations from 19.06.2012 No. 383-P "About rules of implementation of money transfer" replaced the Bank of Russia Regulation from 03.10.2002 No. 2-P "About clearing settlements in the Russian Federation".
MATERIALS AND METHODS OF RESEARCH
Goal of research was the studying of the main changes concerning formation of accounting policies of the credit organizations in 2013 in connection with coming into the force of the new normative document — The Bank of Russia Regulations from 16.07.2012
No. 385-P "About rules of conducting accounting in the credit organizations located in the territory of the Russian Federation".
Research objectives are the following:
- studying of the operating normative legal regulation system regulating accounting in the credit organizations;
- development of classification of users of the accounting information provided by the credit organization;
- statement of tactical and strategic problems of development of bank;
- identification of the main changes concerning accounting policies in the credit organizations.
In the course of research domestic and foreign experience of such scientists as Getman G.V., Robin Joyce, V.S. Heendriksen, etc. was generalized. Normative legal acts with use of a monographic method of research are analysed.
RESULTS AND DISCUSSIONS
The main objective of accounting, throughout all history of its existence is a definition of the financial result received as a result of activity of the enterprise. Round any enterprise there is a set of economic interests which want to estimate its profit one way or another, to estimate assets and potential that leads to justification of various methodological and methodical approaches to creation of the account. On the other hand, information represented in financial reports, unambiguously has to be understood and perceived by the trained users, otherwise it is impossible to build partner relationship between the enterprises and the organizations. For the purpose of accounting reduction in the ordered system, the state regulates this sphere of action in a legislative way. The international organizations which develop the international standards, the principles, the provision of maintaining the account, with the purpose to unify methods of maintaining the account and financial statements are created. As a result, accounting needs to be given to uniformity and compliance to the certain established norms and rules. Rapprochement of the national account with world practice of conducting accounting is one of the main conditions of effective occurrence of Russia on the international markets of the capital. As a reference point, for domestic accounting the International Financial Reporting Standards (IFRS) were chosen.
In Russia, for the credit organizations till 1997, approach to conducting accounting was rigidly regulated. Now, the state tries to create the conditions combining rational state regulation and independence of the organizations directed by accounting, in combination with the principles of IFRS. Fixing of set of ways of conducting accounting is regulated by accounting policies of the organization. Therefore, value of accounting policies, now, is not challenged as approaches to conducting registration process changed from the state.
The credit organizations independently form accounting policies on the basis of the legislation of the Russian Federation, being guided by federal and industry standards.
The four-level system of the documents, regulating conducting accounting in the Russian Federation, is based on International Financial Reporting Standards. The similar system can as be applied to regulation of conducting accounting in commercial bank till 2013. Conditionally it could be divided into the following 4 levels:
It was possible to carry the following regulations to the first level: Civil code of the Russian Federation; The federal law "About accounting"; Laws and other acts; Presidential decrees of the Russian Federation; Resolutions of the Government of the Russian Federation.
The normative documents which are carrying out the methodological management of accounting belonged to the second level. These documents were approved at the request of the Government of the Russian Federation by the Ministry of Finance, for all organizations, except for insurance and credit. The methodological management of accounting in the credit organizations was carried out by Central bank of the Russian Federation.
It was possible to refer the methodological recommendations explaining applications of separate provisions and documents of higher level to the third level.
It was possible to refer the internal documents of the credit organization approved by Orders on the credit organization, including accounting policies to the fourth level.
In connection with the introduction in action of the Federal law No. 402-FZ from 06.12.2012r. "About accounting", accounting is regulated by the Legislation of the Russian Federation to which the Law "About Accounting" and other laws belongs. Besides, article 21 of the Law "About Accounting" establishes the following levels of regulation of accounting in the organization: federal standards; industry standards; recommendations in the field of accounting; standards of the economic subject. The systematized levels of conducting accounting in the credit organizations are given in the Table 1.
Table 1 - Levels of regulation of accounting of the credit organizations
n/n Document type Approved by Specific features Usage in credit organization
1 Federal Laws The RF President Extends the actions to all economic subjects, including to Central bank of the Russian Federation. Are considered when forming accounting policies Obligatory for application
2 Federal standards Ministry of Finance of the Russian Federation, Central bank of the Russian Federation Establish special requirements to accounting. Are considered when forming accounting policies. Obligatory for application
3 Industry standards Central bank of the Russian Federation Establishes features of application of federal standards in activity of the credit organizations, including book of accounts and an order of its application. Obligatory for application
4 Recommendations in the field of accounting The Ministry of Finance of the Russian Federation, Central bank, Tax inspection, other public authorities, the selfregulating organizations interested in regulation of accounting. Explain application of federal and industry standards, extend the best practices of the organization of the account, a procedure of internal control. Are applied on a voluntary basis.
5 Standards of the economic subject. Head of the subject, Order Is established by independently credit organization. Accounting policies, regulations, instructions, technological schemes belong to such standard. Obligatory for application by all divisions of the economic subject, including branches and representations.
The accounting policies of the credit organization allow solving the following tactical problems:
The optimization of fiscal charges providing opportunity, in the years of successful work of the organization to pay the maximum sums of taxes, including on account of next years, and during the difficult periods - minimum. Certainly, thus means, exclusively lawful ways of regulation of fiscal charges;
Minimization of tax risks;
The maximum approach of the account in bank to the MFSO standards, for formation of financial statements within MFSO with the minimum labor expenses;
Choice of ways of maintaining registers of accounting.
Realization of objectives will allow reducing tax burden, tax risks.
Competently made accounting policies will allow to regulate many processes of business, to use the rights provided to business by the government, and as a result, - to save time, forces, money.
The accounting policies have to allow resolving the following issues:
1 . Methodological.
To which it is possible to refer:
• Principles and qualitative characteristics;
• Qualification of assets and obligations;
• Criteria of importance;
• Assessment and calculation;
• Recognition of the income and expenses.
2 . Organizational and technical.
It is possible to refer to them:
• Working book of accounts;
• Order of maintaining the analytical account on a number of accounts;
• Document flow (primary documents, an order and frequency of formation of documents on papers, technology of collecting and information processing, the reporting);
• Order of settlement of mutual debt between branches of the credit organization;
• Organization of registration service;
• Organization of system of internal control;
• Order of carrying out inventory;
• Other decisions necessary for the accounting organization.
In the presence of an ambiguity or a contradiction in acts or normative documents, it is necessary to think over accurately the content of justifications of ways of conducting the accounting, approved as accounting policies of bank. Therefore it is necessary to provide: confirmation of contradictions and ambiguity of provisions of normative documents; impossibility to solve contradictions by permission of collisions and consequently, impossibility of an unambiguous choice of a way from presented in normative documents;
absence of similar norms in IFRS; the description of the developed way, or the chosen
way from containing in normative documents on the basis of treatment of the legislation
(application of professional judgment); confirmation of compliance of the developed way to managing conditions, branch specifics, the principles of the Russian system of conducting accounting confirmation of compliance of the developed way to managing conditions, branch specifics, the principles of the Russian system of conducting accounting.
With IFRS satisfies information needs of foreign investors, foreign partner banks, and the international payment systems. It is realized by transformation of the Russian accounting reports that is a regrouping of articles of the balance sheet, the profit and loss report and other databases.
The accounting policies of the credit organization fix an order of maintaining the financial account. Within accounting policies, the credit organizations, develop and claim: accounting policies for the taxation of the credit organization; accounting policies on drawing up financial statements according to IFRS.
Conducting management accounting is, as a rule, fixed by separate orders. It is connected with that indicators of management accounting often change, or the main software allowing from the financial account to scoop necessary information for operational management is improved.
Let's consider the main changes in the accounting rules, reflected in accounting policies of the credit organization.
For the analysts comparing editions of Regulation No. 302-P and Regulation No. 385P, it has to be obvious that at minor changes of terminology the methodology of carrying out and reflection of some bank operations significantly changed. New Regulation No. 385-P does not contain direct references that it is developed on the basis of federal laws from10.07.2002 No. 86-FZ "About Central bank of the Russian Federation (Bank of Russia)" and from 06.12.2011 No. 402-FZ "About accounting" (further — the Law on accounting).
Thus, Regularion No. 385-P is the independent normative document making own demands to the account in the credit organizations.
So, the Law on the accounting, coming into force since January 1, 2013 and the replacing Federal law of 21.11.1996 No. 129-FL "About accounting", does not contain the obligatory requirement about the signature of the chief accountant on financial records while Regulation No. 385-P specifies that the unsigned chief accountant or the public officials authorized by it settlement and cash documents, the financial and credit liabilities issued by documents, are considered invalid and should not be accepted to execution.
Due to the adoption of Law about accounting in Regulation No. 385-P functions and responsibility of the head and the chief accountant of the credit organization are specified. If earlier for the accounting organization, observance of the legislation of the Russian Federation when performing bank operations responsibility was assigned to the head of bank, according to present edition the head of bank is responsible for the organization of conducting accounting and storage of documents of accounting. The chief accountant bears responsibility for formation of accounting policies, conducting accounting, timely submission of full and authentic accounting reports, provides compliance of carried-out operations to the legislation of the Russian Federation, and also to regulations of Bank of Russia, control of movement of property and implementation of obligations. Functions and responsibility of the chief accountant remained the same.
At the statement of forms of registration documents it must be kept in mind that the credit organization independently develops forms of the primary registration documents applied to registration of operations, except for the forms provided by regulations of Bank of Russia, and the forms containing in albums of unified forms of primary registration documentation.
Requirements which need to be considered when developing normative documents by interfilial calculations are expanded: they have to consider not only a procedure of payments with the branches (structural divisions), but also an order of settlement of mutual debt and the accounting of intra bank requirements and obligations between branches of the credit organization or between head office of the credit organization and branches. Obligatory requirements of the regulator are stated in new characteristics of balance accounts 30301, 30302, 30305, 30306.
The working book of accounts approved by the credit organization has to provide those balance accounts which will be used by it in the account. Since the beginning of 2013 new balance accounts will be entered into Book of accounts and names already operating are changed, other order of reflection of transactions of these or those balance accounts is applied.
So, for example, the name of balance account 30220 "Means of clients on incomplete settlement operations" is changed to "The incomplete money transfers, the clients charged off bank accounts". The characteristic of the account is changed, on the debit of the account the sums of the listed money transfers, including incomplete calculations with operators of services of payment infrastructure, accounts according to the accounting of intra bank requirements and obligations for transfers of clients are reflected. The concept of date of carrying out payment is cancelled.
Changes concerned accounts 30221 (30222) "Incomplete calculations of the credit organization". Now they are called "Incomplete transfers and calculations of the credit organization". The characteristic of accounts is connected taking into account incomplete transfers and calculations for own payments of the credit organization, including for the operations connected with transfers of cash money between the credit organizations.
Besides, these balance accounts were included in the list of pair accounts of the credit organization the balance on which can change on the opposite. Account 30223 "Means of clients on incomplete settlement operations at implementation of calculations through divisions of Bank of Russia" changed the name to "Incomplete transfers and calculations for bank accounts of clients at implementation of calculations through divisions of Bank of Russia". The requirement about existence of means is removed from the characteristic of the account on correspondent account; requirements to the analytical account providing obtaining information on each transfer are changed.
Accounts 30232 (30233) "Incomplete calculations for the operations made with use of payment cards" changed the name to "Incomplete calculations with operators of services of payment infrastructure". In characteristics of accounts there is no reference to Position of Bank of Russia from 24.12.2004 No. 266-P "About cash cards emission and about the operations made with use of payment cards", on the account the sums of incomplete calculations with operators of services of payment infrastructure on the accepted and sent money transfers, including with use of electronic instruments of payment, and to transfers without the bank account opening, the accepted and paid money by calculations by the electronic money, mistakenly enlisted to clients or mistakenly written off from customer accounts are reflected. These balance accounts since January 1, 2013 are entered in the list of pair accounts.
New balance accounts are:
- 30235 "Accounts for cash service of the credit organizations (branches) which is carried out not in a place of opening of correspondent accounts (sub-accounts)" for the accounting of the funds transferred by the credit organization (branch) from correspondent account (sub-account) for receiving cash money if cash service is carried out not in a place of opening of correspondent account (sub-account);
- 30236 "The incomplete transfers which have arrived from payment systems and on correspondent accounts" for the accounting of the sums of the money transfers which are subject to execution on the basis of orders of participants of payment system — payers, and also the amount of transfers credited on correspondent account (except correspondent accounts in Bank of Russia), but not listed (enlisted) in the same day to destination.
Considerable changes happened on balance accounts 30301, 30302, 30305, 30306 which since January 1, 2013 also have other names, reflected operations and requirements to the analytical account. Payments of clients of the credit organization are separated from calculations between divisions of the most credit organization; the order of settlement of mutual debt is specified.
The greatest changes were undergone by balance account 409 "Means in calculations". However with former names and characteristics there were balances accounts 40903, 40906, 40907, 40908. The order of reflection of transactions of other balance accounts of the second order changed radically; there was a new correspondence of accounts.
When writing accounting policies the accountant needs to study and the new correspondence of accounts offered by the regulator in Regulation No. 385-P, including use of again entered balance accounts or changes of names and characteristics already existing.
One of the main questions of accounting policies is the statement of an order of carrying out payments.
The credit organizations approve the internal documents containing: order of drawing up orders; order of performance of procedures of reception to execution, a response, return (cancellation) of orders; order of orders execution.
Along with regulator approved forms in Regulation No. 383-P by documents, banks independently develop and include in the accounting policies forms which can be presented as in electronic form, and on paper. For each form of clearing settlements the existence of a number of the documents being the order on carrying out payment and the settlement document is supposed. The choice is rather wide that the credit organization could take into account level of automation and the organizational features to state a procedure of payments.
CONCLUSIONS
The changes made to rules of accounting by Regulation No. 385-P, generally concern settlement operations. The accounting policies for 2013 have to be made taking into account these changes, and also the requirements in Regulation No. 383-P. Wider use in the accounting of accounts of incomplete calculations, the accounting of requirements and obligations of the credit organization for payments of clients is connected with procedures of
reception and execution of orders of clients, a recoverer of money or the bank itself which are fixed by Regulation No. 383-P.
In comparison with the previous Regulation No. 2-P, the regulator made some essential changes to a procedure of payments
First, the new concept is implemented — the order on carrying out payment. As its originator can act both the client, and the credit organization, and also the recoverer of money providing information on write-off of money directly in bank or the client (for example, the receipt on payment of utilities). Forms of such documents can be different therefore the credit organization has to define forms of documents which will be used as the order when carrying out payments, except those forms of orders which are defined by Regulation No. 383-P.
Payment orders, collection orders, payment requirements, payment warrants, and also other orders (for example, statements, notices, notices, the statements made for collecting money, orders about receiving cash money from the bank account of the legal entity, the order for total amount can reckon with the register made by the credit organization itself) are considered as orders.
Secondly, the bank defines, within what form of clearing settlements these or those orders will be applied:
- calculations by payment orders;
- calculations for the letter of credit;
- calculations by collection orders;
- calculations by checks;
- calculations in the form of money transfer on request of the recipient of means (direct debiting);
- calculations in the form of transfer of electronic money.
Thirdly, the bank defines the settlement (payment) document according to which payment will be made: payment order, collection order, payment requirement, payment warrant, bank warrant. The list and form of these documents on paper are established by Regulation No. 383-P, except the bank warrant which form is approved by the Indication of Bank of Russia from 11.12.2009 No. 2360-U "About the Order of drawing up and application of the bank warrant". In electronic form these documents have to contain necessary information for payment implementation — the obligatory requisites determined by Regulation No. 383-P.
Let's afford the statement that the credit organization is a big accounts department. Practically each employee of the credit organization, except for cleaners, and programmers and top managers, it is possible to carry to registration workers safely. All of them deal with accounts, primary documents and registration registers. Therefore, competently and thoroughly thought over and made accounting policies of the credit organization have huge influence on operability of this organization. Huge value of accounting policies of the credit organization is indisputable.
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