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state the reasons for such unfavourable or qualified statement, as the case may
                                        be.  Where  the  auditor  is  unable  to  express  any  opinion  on  any  of  the  items
                                        referred to in paragraph 3 above, his report shall indicate such fact together with
                                        reasons therefor.
                                Exception Report
                                    •  2. Obligation of auditor to submit an exception report to the Bank
                                           o  (I) Where, in the case of a non-banking financial company, the statement
                                               regarding  any  of  the  items  referred  to  in  paragraph  3  above,  is
                                               unfavourable or qualified, or in the opinion of the auditor the company
                                               has not complied with:
                                                   -  the provisions of Chapter III B of RBI Act (Act 2 of 1934); or
                                                   -  Non-Banking Financial Companies Acceptance of Public Deposits
                                                      (Reserve Bank)  Directions, 2016; or
                                                   -  Non-Banking  Financial  Company  –  Non-Systemically  Important
                                                      Non-Deposit  taking  Company  (Reserve  Bank)  Directions,  2016
                                                      and  Non-Banking  Financial  Company  -  Systemically  Important
                                                      Non-Deposit  taking  Company  and  Deposit  taking  Company
                                                      (Reserve Bank) Directions, 2016.

                                        It shall be the obligation of the auditor to make a report containing the details of
                                        such unfavourable or qualified statements and/or about the non-compliance, as
                                        the case may be, in respect of the company to the concerned Regional Office of
                                        the Department of Nonbanking Supervision of the Bank under whose jurisdiction
                                        the registered office of the company is located as per first Schedule to the Non-
                                        Banking  Financial  Companies  Acceptance  of  Public  Deposits  (Reserve  Bank)
                                        Directions, 2016.

                                    •  The  duty  of  the  Auditor  under  sub-paragraph  (I)  shall  be  to  report  only  the
                                        contraventions  of  the  provisions  of  RBI  Act,  1934,  and  Directions,  Guidelines,
                                        instructions referred to in sub-paragraph (1) and such report shall not contain any
                                        statement with respect to compliance of any of those provisions

          QNO     Exception Report                           Old Course – (N16E, M20M, SM21, M21E, N21M,N22M)
          523.000  TITANIUM CNO—NBFC.320                                                  New Course – (SM23)
                  What are the obligations of auditor to submit Exception Report to RBI in case of nonbanking financial
                  companies?
                                                               OR
                  Kammo & Co LLP, a firm of Chartered Accountants, was appointed as auditor of an NBFC. The audit work
                  has  been  completed.  The  audit  team  which  was  involved  in  the  fieldwork  came  across  various
                  observations  during  the course  of  audit  of  this  NBFC  and  have  also  limited  understanding  about  the
                  exceptions which are required to be reported in the audit report. They would like to understand in detail
                  regarding the obligations on the part of an auditor in respect of exceptions in his report so that they can
                  conclude their work. Briefly explain.
          Answer  Exception Report
                      Obligation of auditor to submit an exception report to the Bank.
                      ➢  Where,  in  the  case  of  a  non-banking  financial  company,  the  statement  regarding  any  of
                         the items referred to in paragraph 3 above, is unfavourable or qualified, or in the opinion of the
                         auditor the company has not complied with:
                             •  the provisions of Chapter III B of RBI Act (Act 2 of 1934); or
                             •  Non-Banking  Financial  Companies  Acceptance  of  Public  Deposits  (Reserve  Bank)
                                  Directions, 2016; or
                             •  Non-Banking  Financial  Company  –  Non-Systemically  Important  Non-Deposit  taking
                                 Company  (Reserve  Bank)  Directions,  2016  and  Non-Banking  Financial  Company  -
                                 Systemically  Important  Non-Deposit  taking  Company  and  Deposit  taking  Company
                                 (Reserve Bank) Directions, 2016.

                           It  shall  be  the  obligation  of  the  auditor  to  make  a  report  containing  the  details  of  such
                           unfavourable or qualified statements and/or about the non-compliance, as the case may be, in
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