Technical Guide on Internal Audit of Treasury ... - CAalley.com

The Treasury Dealing Room
(vi) Rules should be framed for prompt investigation of complaints
against dealers and malpractices by brokers and reporting to FEDAI
and RBI’s Department of Banking Supervision.
e) Dealing Hours - All dealers should be aware of the bank's normal trading
hours, cut-off time for overnight positions and rules governing after hours
and off-site trading (if allowed by the bank).
f) Security and Confidentiality - All dealers should be aware of the bank's
requirements in respect of maintaining confidentiality over its own and its
customers' trading activities as well as the responsibility for secure
maintenance of access media, keys, passwords and PINS.
g) Staff Rotation and leave requirements - All dealers should be aware of
the requirement to take at least one period of leave of not less than 14
days continuously per annum, and the bank's internal policy in regards to
staff rotation.
h) Customer/User Appropriateness and Suitability Policy - Banks usually
have a ‘Customer/User Appropriateness and Suitability Policy’ in place
for transacting in complex treasury instruments such as, derivatives. The
objective of such policy is to protect the bank against the credit,
reputation and litigation risks which may arise on account of ‘misselling’
products to users who may not understand the nature of the risks
inherent in these transactions or products. All front office sales team or
dealers, must be aware of and be educated about such policy. Sales
dealers should conduct proper due diligence regarding ‘user
appropriateness and suitability’ of products before offering derivative
products or other complex treasury instruments to users.
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