DISA 3.0 Project Report
DISA 3.0 Project Report
DISA 3.0 Project Report
DISA 3.0 Project Report on Information Systems audit of a Mutual Fund Systems - Disa Project Report - ProKhata
Table of Contents
1. Introduction
1.1. How Do Mutual Fund Works
1.2. About Mutual Fund Service System (MFSS)
1.3. Mutual Fund Service System
1.4. Orders Placing
1.5. Confirmation of order
1.6. Audit Engagement Team
2. Auditee Environment
2.1. Structure of Mutual Fund
2.2. Sponsor
2.3. Board of Trustees or Trustee Company
2.4. Asset Management Company (AMC)
2.5. Fund Accountant (generally outsourced)
3. Background
4. Situation
5. Scope and Terms of assignment
5.1. Scope:
5.2. Other terms and conditions
6. Logistics arrangements required
7. Methodology and Strategy adopted for the audit
8. Documents Reviewed
9. References
10. Deliverables
11. Audit Findings and Recommendations
12. Conclusion
12.1. Environmental Controls and Business Continuity plan
12.2. Further Action
13. DISA 3.0 Project Report on:
Introduction
A mutual fund is an open-end professionally managed investment fund that pools money
from many investors to purchase securities. Mutual fund investors may be retail or
institutional in nature. Mutual funds are often classified by their principal investments as
money market funds, bond or fixed income funds, stock or equity funds, hybrid funds, or
other. Funds may also be categorized as index funds, which are passively managed funds that
match the performance of an index, or actively managed funds. In India, mutual funds are
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regulated by Securities and Exchange Board of India, the regulator of the securities and
commodity market owned by the Government of India. The mutual fund industry in India is
growing at an exponential pace. The Indian mutual fund industry recorded an Average Assets
Under Management (AAUM) of Rs. 23.16 trillion as on February 28, 2019. The AUM of the
industry stood Rs. 5.09 trillion on February 28, 2009, which means the Indian mutual fund
industry has registered a more than 4 ½ fold increase in a period of 10 years.
There are as many as 44 AMFI (Association of Mutual Funds in India) registered fund houses
in India which together offer more than 2,500 mutual fund schemes. The wide array of funds
often make it a little difficult for investors to choose the best scheme for them. To ease this
process, we list out the 10 most popular mutual fund houses in India.
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1. The process begins when a fund house identifies a potential money- making opportunity in
the market subject to key risks.
2. The fund house then weighs the newly identified opportunity against existing investment
opportunities and analyses how it can add further value for current investors.
3. The fund house then appoints a fund manager who creates a portfolio of different asset
classes including equities, debt and money market securities. The asset allocation of the
scheme decides under which mutual fund category the scheme will fall – Equity Fund, Debt
Fund or Hybrid Fund.
4. The fund manager then compiles all the details including the scheme’s asset allocation, risk
level, etc in a document and files the draft with market regulator SEBI for its approval.
5. After receiving SEBI’s approval, the fund house makes the scheme available to the public for
subscriptions through a New Fund Offer (NFO). An NFO generally lasts for 7-10 days.
On the basis of the subscription period, mutual fund schemes can be classified as open-ended
and close-ended schemes. An open ended mutual fund scheme allows investors to enter and
exit the fund anytime even after the closure of the NFO period. Whereas, a close-ended fund
allows investors to enter into the scheme only during the NFO period and does not allow
them to exit it until maturity which is typically 3-4 years from the launch date.
1. After receiving the initial subscription, the fund manager manages the scheme actively or
passively depending on the scheme’s requirements as well as market/economic conditions.
2. A mutual fund investment provides earning to its investors in the form of dividend payouts
and capital gains.
An investor who wishes to subscribe or redeem units of a mutual fund scheme can now use
Mutual Fund Service System (MFSS) provided by NSE.
This service has been launched on November 30, 2009 at the hands of Mr C B Bhave,
Chairman, Securities Exchange Board of India (SEBI), on November 30, 2009.
Mutual Fund Service System (MFSS) is an online order collection system provided by NSE to
its eligible members for placing subscription or redemption orders on the MFSS based on
orders received from the investors.
Orders Placing
The MFSS will be available for Participants between 9 a.m. to 3 p.m.
The NSE MFSS shall facilitate entry of both buy and sell orders. In order to subscribe units,
member will be required to place buy orders. A member who wishes to redeem units of
mutual fund scheme will be required to place sell orders in the system. Participants can
choose between Physical mode and depository mode while putting their subscription /
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redemption requests on the MFSS. All orders shall be settled on order to order basis, on T+1
(working days).
Individuals, HUF and Body Corporate can participate in MFSS subject to completing the KYC
procedure. In case of a minor the guardian would have to be KYC compliant.
Confirmation of order
The system will generate an order confirmation slip for each order which includes time stamp
of the order being put on the system, on behalf of the investor. The order confirmation slip
which is generated by the system shall be given to the investor by the member and is the
conclusive evidence of the transaction.
To deal with the challenges arise in Mutual Fund Service System (MFSS) of (KAA Asset
Management Limited), they have appointed M/s AKA & Associates, a Firm of Chartered
Accountants, to review and audit of Information System in place and provide suitable
recommendations for improvements & best practices that can be adopted in the System
of Mutual Funds.
Our approach to selecting the right people for a project is to bring together the necessary
skills and experience for a particular assignment from the rich mix of skills and experience
available. The assignment will be executed by M/s AKA & Associates under the personal
supervision and lead by Mr K. M/s AKA & Associates is one of the leading practitioners in the
area of IS audit, comprising of the following main team members:
1. Mr K –Team leader (DISA qualified, having an experience of over 10years in IS audit). He has
worked on 10+ SAP Engagements across different industries like FMCG, Telecom, Chemicals,
Oil & Gas, Professional Services, Insurance etc., performing key leadership roles of
Program/Project Management.
2. Ms A, Mr A, Ms D, Mr M –Team members (All of the team members are DISA qualified and
are experts in the field of audit of software development projects for a period of 5-8 years and
have worked on various Projects providing SAP solutions for various aspects and other
statutory compliances.
The said team has handled various other projects concerning IS audits and have been into
consultation of Software Development Life Cycle, Migration Audits, Business Continuity
Management etc.
Auditee Environment
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Typically, a mutual fund is a trust that pools the savings of a number of investors who share
a common financial goal. The money collected is invested in capital market instruments
such as, shares, debentures and other securities and money market instruments. The
income earned through these investments and the capital appreciation realized is shared by
its unit holders in proportion to the number of units owned by them. A mutual fund offers
an opportunity to invest in a diversified, professionally managed basket of securities at a
relatively low cost.
Sponsor
The Sponsor(s) are those who establish the Mutual Fund Trust and the Asset Management
Company (AMC). They constitute the shareholders of the AMC.
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forms part of the overall expense ratio approved. The mutual fund’s assets belong to the
investors and are held in fiduciary capacity for them by trustees. The Trustee Company is the
epitome of corporate governance in mutual funds and the trustees are regarded essentially as
the front-line regulator. The Trustee Company is entrusted with the responsibility of holding
the property of the MF in trust for the benefit of the unit-holders.
The AMC is a corporate entity, which floats, markets and manages a mutual fund scheme and
in return receives a management fee paid from the fund corpus. The AMC is accountable to
the Trust for its actions. Regulation 25 of MF Regulations has laid down the AMC’s obligations.
In India, the Sponsor or the Trustee appoints the AMC through Investment Management
Agreement (IMA). The contents of IMA are given in the Fourth Schedule to the MF
Regulations. In terms of Regulation 24 of MF Regulations, no AMC can manage assets of more
than one Mutual Fund and in case AMC decides to undertake any other activity then it has to
satisfy SEBI that key personnel and infrastructure have been segregated activity-wise.
Fund Accountant is an entity handling the back office operations of the mutual fund for and
on behalf of the AMC, viz., services related to fund accounting, purchase processing, corporate
actions accounting, valuation and Net Asset Value (NAV) calculation, reporting and other
incidental services in respect of the Mutual Fund. An AMC, generally, enters into service level
agreement with Fund Accountant, if outsourced, which will clearly bring out the expectations
from the third party service providers. Periodically, these would be reviewed to reflect at all
times the business requirements currently in practice.
Background
The audit should be encompassing audit of systems and processes, inter- alia, related to
examination of integration of front office system with the back office system, fund accounting
system for calculation of net asset values, financial accounting and reporting system for the
AMC, Unit-holder administration and servicing systems for customer service, funds flow
process, system processes for meeting regulatory requirements, prudential investment limits
and access rights to systems interface.
Mutual Funds / AMCs are advised to conduct their systems audit on an annual basis by an
independent CISA / CISM qualified or equivalent auditor to check compliance of the provisions
of the circular
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Mutual Funds / AMCs are further advised to take necessary steps for the exception report. The
exception report should be placed for review to the Technology Committee before it placed to
the AMC & Trustee Board. Thereafter, exception observation report along with trustee’s
comments starting from the financial year April 2019 – March 2020 should be communicated
to SEBI within six months of the respective financial year. Further, System Audit Reports shall
be made available for inspection.
The circular is issued in exercise of powers conferred under Section 11 (1) of the Securities and
Exchange Board of India Act, 1992, read with the provisions of Regulation 77 of SEBI (Mutual
Funds) Regulations, 1996, to protect the interests of investors in securities and to promote the
development of, and to regulate the securities market
Situation
As the Mutual fund market have moved towards online Investment & Trading system for ease
of its investors by eliminating offline representative intervention for investing, buying or selling
of mutual funds and easy access for trading to its investors anywhere and everywhere it
implemented various security controls to secure its user data by maintaining Integrity,
confidentiality and availability by implementing specific controls as and where required.
KAA Mutual Fund is manned by around 2000 people. There are 220 applications running and
around 150 plus network devices like firewall, IDS, IPS, Router, Switches, Gateways etc. are
there along with 500 plus high end servers. Appropriate communication lines with all required
redundancies are present.
Information security risk management policy maintained by the enterprise is not updated and
not reviewed for the last three years. At the time of hiring the employees, no background
check is done and no documents are asked to submit. Hiring policies are not defined in line
with IT Operation.
Management says there are no issues with Access control mechanism. But, multiple failure
attempts by unauthorized users were found, it was informed to the senior management but
Management did not take any actions believing that these are just unsuccessful attempts
therefore no follow-up action is required.
Testing of Security patches for application servers were not being performed before deploying
into production environment. There are also issues with the management of backup tapes and
blank tapes.
Occasionally, huge rush is observed during the peak closing time of the market especially on
Friday. And server is seen experiencing down-time.
Any unusual activities observed by the IT Personnel are reported to CISO by following the
proper formal procedure designed by the top management.
No training is provided to employees like Mock drill of earthquake/ fire, safety program
classes to its staff. Since, management believes that these circumstances never appeared in the
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Scope:
KAA MF shall appoint one senior IT officer part of the implementation team and operation
head to co-ordinate for finalizing the initial work plan and shall continue to work with the
audit team as when required till the completion of assignment. The company shall make
available necessary systems, software, software resources and support facilities for completing
the assignment within the appointed time. During the course of audit the following resources
shall be made available:
1 2 Nodes with Read only access to extract reports from application.
2 One Laptop with Windows 10 / Microsoft office 2013.
3 Adequate seating and storage for the team.
4 Facilities and permissions to have discussion and seek informations from the IT department
as well as the different user departments members.
5 Permission to do penetration testing on the system
6 Permission to carry our Laptop with Computer Aided Audit tools installed to be used for our
data analysis.
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Documents Reviewed
While performing audit procedures, we reviewed the following documents:
➢ Organization structure Diagram.
➢ List of Hardware, Software and Application Software currently used by the client.
➢ Service Offer Agreement.
➢ Password Policy.
➢ Business Continuity Plan and Disaster Recovery Plan.
➢ Information Security Policy.
➢ Backup Procedures.
➢ User Creation, modification and deletion Policy.
➢ Various MIS reports and exception reports generated by the system.
➢ Information system asset registers
References
➢ ISO 27001
➢ COBIT 2019 Framework
➢ Guidelines and Circular issued by SEBI
➢ Information Technology Assurance Framework issued by ISACA
➢ GTAG (Global Technology Audit Guide) prepared by the Institute of Internal Auditors.
➢ Information Technology (Amendment) Act,2008.
➢ References to the ISA Study Materials issued and provided by ICAI
Deliverables
Our audit team has provided following deliverables to the company after
completion of assignment :-
a) Final IS Audit Report drafted in pursuance to ISACA and COBIT Framework stating that such
audit has been conducted as per the guidelines issued by SEBI in order to express an opinion
on effectiveness of operations and controls of Mutual Fund Systems
b) Executive Summary for senior management persons.
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c) Detailed finding and recommendations related to the IS Audit for continuity of sound and
stable information system, protection of mutual fund unit holders, market efficiency,
privatization and opening of markets, etc.
d) Meeting of IS Security needs
e) Assess risks, economy, efficiency and quality
The audit procedure conducted for this control objective was observation and confirmation. It
was observed that the information security risk management process was last reviewed by the
top management three years ago. Several management action plans might have become
irrelevant and outdated, which may now require changes. This could pose a high risk to
confidentiality, integrity, and availability of information assets. The recommendation for this
control objective is to define a process for information security risk management that should
be followed annually.
Human Resource Control
The audit procedure for this control objective was inquiry and inspection. It was observed that
background check procedures were not performed for all new joiners subject to hiring
documents of employees who are given authorized access to the Stock Brokers/ Depository
Participant’s critical systems, networks, and other computer resources. This may result in
serious consequences, such as fraud. The nonavailability of employees’ background may lead
to stringent supervision, monitoring, and access restrictions. This could pose a high risk to
confidentiality and availability of information assets. The recommendation for this control
objective is to define hiring policies in line with IT operations and perform background check
procedures for all new joiners.
Access Control
The audit procedure for this control objective was inspection, observation, and confirmation. It
was observed that many unauthorized user access attempts were found from system logs
which were attempted and failed multiple times. Unauthorized user access may even get
access to confidential data after trying multiple times. This could pose a high risk to
confidentiality and integrity of information assets. The recommendation for this control
objective is to implement access account lock policies after three failure attempts for all
accounts.
Patch Management Control
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The audit procedure for this control objective was observation and confirmation. It was
observed that testing of security patches is not carried out by IT personnel at regular intervals.
This may create a risk to production environment and other systems adversely. This could pose
a medium risk to confidentiality, integrity, and availability of information assets. The
recommendation for this control objective is to perform rigorous testing of security patches
before deployment into the production environment to ensure that the application of patches
does not impact other systems.
Backup Media Management Control
The audit procedure for this control objective was observations and confirmation. It was
observed that backup tapes are not leveled accurately externally and internally and stored in
humid conditions within the data center. Incorrect leveling will lead to incorrect processing
leading to data integrity issues. This could pose a medium risk to confidentiality, integrity, and
availability of information assets. The recommendation for this control objective is to check all
tapes for internal and external levels and store them in a secure condition in the offsite
premises.
Business Continuity Controls
The audit procedure for this control objective was business continuity policy documents MIS
reports. During peak closing time of the market, if the server experiences downtime due to a
large number of user login at the same point of time, it could pose a medium risk to integrity
and availability of information assets. In case of a prolonged or frequent service disruption,
customers may lose confidence resulting in loss of faith and goodwill. The recommendation
for this control objective is to install extra servers and workstations to manage workload
during peak hours. Appropriate physical and logical access controls also need to be
implemented on the same.
Governance Control
The audit procedure for this control objective was observation and inquiry. It was observed
that sometimes unusual activities detected by IT personnel may be too serious that immediate
actions might be required. There is a time lag between identification and reporting of unusual
activities and events to the CISO or to the senior management. Due to extreme reporting
procedures performed, it may lead to delay, but reporting of unusual activities and events to
the CISO is higher than usual. This could pose a high risk to availability of information assets.
Disaster Recovery Plan
The audit procedure for Disaster Recovery Plan included inspection and observation. The risk
ranking for this control objective is medium. During the audit, it was observed that the
company has never provided any sort of disaster-related training, such as mock drills for
earthquakes or fires, or safety program classes to its staff. Though the chances of a disaster are
very low in this region, if it were to happen, it would be very difficult to manage the situation.
Therefore, proper training must be given to employees as to how to respond to disasters, and
mock drills must be performed at least once a year.
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Conclusion
Based on the IS Audit review and findings, the overall conclusions on specific areas are as
Follows:-
Information security Risk Management Control
We have observed that the information security control in KAA Mutual Fund working
effectively. Further The areas where controls need to be strengthened are highlighted in Para
11 of our Report.
Access Controls, Application & Database Controls
Our review of Access controls at the IT Environment as implemented in KAA Mutual Fund
Company using Windows Server, Oracle and MFSS confirms that appropriate security and
access controls have been implemented by using related functions and features of the
software. Our test checks have revealed that systems of security and controls are reliable.
However, there are some cases of old investors accounts not Deactivated which does not have
any balances in their funds.
In addition, we found scope of improvement in the MFSS Software so that manual event
update can be avoided at Mutual Funds to prevent revenue leakage.
Also, there is missing data relating to periods when system was not available which have not
been updated in the revenue tables in database which may impact correct revenue recognition
& risk of revenue loss.
Our review of Environmental Controls and BCP implemented by KAA Mutual Fund Company
confirms that the business continuity plan is implemented and the staff is aware of various
disaster situations.
The power backup for IT Server and Air-conditioner can be improved.
One critical gap is absence of an alternate disaster recovery site and related documentation,
which should provide for back up and off-site location of application software, data files and
system software to facilitate their restoration following the recovery of critical application.
Further Action
We consider that the recommendations given in our IS Audit Report read together with audit
findings to this report would be very useful for facilitating business process controls of KAA
Mutual Fund Company and will aid in improving the effectiveness of the MFSS operations. We
would like to affirm that the matters included in this report are those which came to our notice
during our review by following normal Information System audit procedures by complying
with Globally Applicable Information Systems Auditing Standards, Guidelines and procedures
that apply specifically to Information system auditing issued by information systems audit and
control association, USA and Security and Control practices as outlined in COBIT- 2019 issued
by ISACA as adopted to KAA Company operations. Further on account of limitations of scope
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and time, we have used sample test and test check approach. Hence, certain areas, which are
outside the scope of review such as source code review, implementation control are not
covered.
About Us
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