Chairmen of Indian Banks need to take note that an important compliance deadline is falling due on October 31, 2011.

Before that date, according to RBI circular of April 29, 2011, Banks need to put in place compliance measures under the recommendations of G Gopalakrishna Working Group.

By that time Banks need to have their IT Strategy Committee, Risk Management Committee and IT Steering committee in place.

The IT Strategy committee is to be chaired by an independent Director and the committee should consist of at least two directors including an independent director. The Risk management committee is at the executive level and the sterring committee would be at the business unit level.

It would also be advisable for Banks to immediately designate a CISO who can coordinate with the Chief Risk Officer and CIO and start the implementation activity.

Preferably Banks should have completed their first “Gap Anaysis” study by that time.

Even before the deadline of October 31, two other minor mile stones at the end of Q2 and Q3 are to be recognized. The Board need to have a quarterly review of the GGWG implementation and it would be necessary for Banks to take some action before June 30 2011 and follow up by September 30 2011.

I hope Bank Chairmen and Company Secretaries have already initiated action in this regard.

If necessary Banks should consider appointing appropriate consultants to guide the top management in the process of compliance.

Ujvala Consultants Pvt Ltd (promoted by Naavi)  is the first consultancy organization in India to have an exclusive offering on GGWG compliance for Bankers and offers its services to other Bank IS audit firms and also directly to Banks. Since the time available for the first milestone is short, Chairmen of Banks may need to call an emergency Board meeting if required to discuss the compliance issues.

Naavi of www.naavi.org

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