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System Audit Report - Format

(TO BE ON THE LETTERHEAD OF THE SYSTEM AUDITOR)


DATE:

NAME OF TRADING MEMBER:

SYSTEM AUDIT REPORT FOR THE PERIOD FROM JULY 01, 2009 TO JUNE 30, 2010

Part A

Controls / Processes Test Case Results, Auditor’s


Observations Risk
& Control
Risk
The installed CTCL system features Risk Management Tools Results Opinions
are as prescribed by the NSE. • Should allow for risk management of the
orders placed and online risk monitoring
of the orders being placed.

CTCL Version
The installed CTCL system parameters • Order Gateway Version
are as per NSE norms • Risk Administration / Manager Version
• Front End / Order Placement Version

Location Confirmation for DMA Whether order routing server for DMA is located
in India. Provide address of the DMA server
location
The installed DMA system features are Risk Management Tools
as prescribed by the NSE. • Should allow for risk management of the
orders placed and online risk monitoring
of the orders being placed.
Results Opinions
Trading Process
The installed CTCL system allows Client ID Verification
for placing of trades only for Only duly authorized client’s orders are
authorized clients allowed to be placed.

Proprietary order entry mechanism


Order entry for Pro types of orders is executed
through specific user ids.

Risk Management
The installed CTCL system is Order Parameters
capable of assessing the risk of the There is online risk assessment of all orders
client as soon as the order comes in placed through the CTCL system.
and informs the client of
acceptance/rejection of the order
Controls / Processes Test Case Results, Auditor’s
Observations Risk
& Control
Risk
within a reasonable period.

Order /Trade Limit Controls Only orders that are within the parameters
The installed CTCL system provides specified by the risk management systems are
a system based control facility on allowed to be placed
the trading limits of the clients and
exposures taken by the clients
including set pre-defined limits on
the exposure and turnover of each
client.

Order Reconfirmation Facility The system has a manual override facility for
The installed CTCL system provides allowing orders that do not fit the system
for reconfirmation of orders which based risk control parameters
are larger than that as specified by
the member’s risk management
system.

Execution of Orders / Order Logic Order Numbering Methodology


The installed CTCL / DMA system If the system is enabled for internet trading the
provides a system based control system has an internal unique order numbering
facility over the order input process system

Order Matching
The system does not have any order matching
function and all orders are passed on to the
exchange trading system for matching

Whether Broker is using similar logic/


priorities as used by Exchange to treat DMA
client orders.

Whether DMA orders are having unique flag/


tag as specified by the Exchange.
Application Access Control Access controls Results Opinions
The installed CTCL / DMA system • The system allows access to only
provides a system based access authorized users
control over the CTCL / DMA • The system has a password mechanism
server as well as the risk which restricts access to authenticate
management and front end dealing users.
applications while providing for • The DMA system has appropriate
security authority levels to ensure that the limits
can be setup only by persons authorized
Session Security by the risk / compliance manager
The installed CTCL system provides
for session security for all sessions Session Security
established with the CTCL server • The system uses session identification
by the front end application. and authentication measures to restrict
sessions to authorized user only.
Controls / Processes Test Case Results, Auditor’s
Observations Risk
& Control
Risk
• The system uses session security
Database Security measures like encryption to ensure
The installed CTCL system has confidentiality of sessions initiated.
sufficient controls over the access to
and integrity of the database Database Security
• The access to the CTCL database is
allowed only to authorized users /
applications.
• The CTCL database is hosted on a
secure platform.
Encryption • The CTCL database stores the user
The installed CTCL system uses names / passwords securely.
confidentiality protection measures
to ensure session confidentiality. Session Encryption
• The system uses SSL or similar session
confidentiality protection mechanisms
• The system uses a secure storage
mechanism for storing of usernames and
passwords.
• The system adequately protects the
confidentiality of the users’ trade data.
The installed CTCL system provides a The installed CTCL systems has a provision for Results Opinions
system based event logging and system On-line surveillance and risk management as per
monitoring facility which monitors and the requirements of NSE and includes
logs all activities / events arising from • Number of Users Logged In / hooked on
actions taken on the gateway / database to the network incl. privileges of each
server, authorized user terminal and
transactions processed for clients or
otherwise and the same is not The installed CTCL systems has a provision for
susceptible to manipulation. off line monitoring and risk management as per
the requirements of NSE and includes reports /
logs on
• Number of Authorized Users
• Activity logs
• Systems logs
• Number of active clients
The installed CTCL system has an Approved Users Results Opinions
User Management system as per the • Only users approved by the NSE are
requirements of the NSE. allowed to access the CTCL system and
documentation regarding the same is
maintained in the form of
 User Approval Application
 Copy of User Qualifications

User Creation
New CTCL User IDs are created as per the
CTCL guidelines.

User ID
Controls / Processes Test Case Results, Auditor’s
Observations Risk
& Control
Risk
All users are uniquely identified through issue
of unique CTCL ids.

User Disablement
Users not compliant with the Exchange
Requirements are disabled and event logs
maintained

User Deletion
Users are deleted as per the NSE guidelines

Reissue of User Ids


User Ids are reissued as per the NSE
guidelines.

Locked User Accounts


Users whose accounts are locked are unlocked
only after documented unlocking requests are
made.
The installed CTCL system The installed CTCL system’s uses passwords for Results Opinions
Authentication mechanism is as per the authentication.
guidelines of the NSE
The password policy / standard is documented.

The system requests for identification and new


password before login into the system.

The installed CTCL system’s Password features


include
• The Password is masked at the time of
entry.
• System mandated changing of password
when the user logs in for the first time.
• Automatic disablement of the user on
entering erroneous password on three
consecutive occasions.
• Automatic expiry of password on expiry
of 14 calendar days.
• System controls to ensure that the
password is alphanumeric (preferably
with one special character), instead of
just being alphabets or just numerical.
• System controls to ensure that the
changed password cannot be the same as
of the last password
• System controls to ensure that the Login
id of the user and password should not
be the same.
• System controls to ensure that the
Password should be of minimum six
characters and not more than twelve
Controls / Processes Test Case Results, Auditor’s
Observations Risk
& Control
Risk
characters.
• System controls to ensure that the
Password is encrypted at members end
so that employees of the member cannot
view the same at any point of time.

Results Opinions
Vendor Certified Network diagram Date of submission of network diagram to NSE

(Only in case of change in network setup,


member need to submit revised scanned copy
network diagram along with this report)

Verify number of nodes in diagram with actual

Verify location(s) of nodes in the network

Are adequate provisions in respect of physical


Physical Security security of the hardware / systems at the hosting
location and controls on admission of personnel
into the location (audit trail of all entries-exits at
location etc.)?

The Installed CTCL systems backup Are backups of the following system generated Results Opinions
capability is adequate as per the files maintained as per the NSE guidelines?
requirements of the NSE for • At the CTCL server/gateway level
overcoming loss of product integrity. • Database
• Audit Trails
• Reports

At the CTCL user level


• Market Watch
• Logs
• History
• Reports
• Audit Trails

Are backup procedures documented?

Are backup logs maintained?

Have the backups been verified and tested?

Are the backup media stored safely in line with


the risk involved?
Controls / Processes Test Case Results, Auditor’s
Observations Risk
& Control
Risk
Are there any recovery procedures and have the
same been tested?

Part B

Controls / Processes Test Case Results, Auditors


Observations & Opinion
control Risk
The installed CTCL system Main Features Results Opinions
features are as prescribed by Price Broadcast
the NSE. The system has a feature for receipt of price
broadcast data
Order Processing : The system has a feature :
• which allows order entry and confirmation
of orders.
• which allows for modification or
cancellation of orders placed
Trade Confirmation
The system has a feature which enables
confirmation of trades

The installed CTCL system Gateway Parameters


parameters are as per NSE • Trader ID
norms Market Segment - CM
• CTCL ID
• IP Address
• (NSE Network)
• VSAT ID
• Leased Line ID
Market Segment – F&O
• CTCL ID
• IP Address
• (NSE Network)
• VSAT ID
• Leased Line ID
Market Segment – CDS
• CTCL ID
• IP Address
• (NSE Network)
• VSAT ID
• Leased Line ID

Results Opinions
Execution of Orders / Order Order Entry
Controls / Processes Test Case Results, Auditors
Observations & Opinion
control Risk
Logic The system has order placement controls that
The installed CTCL allow only orders matching the system parameters
system provides a system to be placed.
based control facility over
the order input process Order Modification
The system allows for modification of orders
placed.

Order Cancellation
The system allows for cancellation of orders
placed

Order Outstanding Check


The system has a feature for checking the
outstanding orders i.e. the orders that have not yet
traded or partially traded.

Trades Information Trade Confirmation and Reporting Feature


The installed CTCL Should allow confirmation and reporting of the
system provides a system orders that have resulted in trade
based control facility over
the trade confirmation
process

Settlement of Trades Margin Reports feature


The installed CTCL Should allow for the reporting of client wise /
system provides a system user wise margin requirements as well as payment
based reports on contracts, and delivery obligations.
margin requirements,
payment and delivery
obligations

Results Opinions
Additional Access Control Extra Authentication Security
Security • The systems uses additional authentication
The installed CTCL measures like smart cards, biometric
system provides a dual authentication or tokens etc.
factor authentication • The system has a second level of password
system for access to the control for critical features
various CTCL
components.

To ensure information Does the organization’s documented policy and Results Opinions
security for the Organisation procedures include the following policies and if so
in general and the installed are they in line with the NSE requirements?
CTCL system in particular • Information Security Policy
policy and procedures as per • Password Policy
the NSE requirements must • User Management and Access Control
be established, implemented Policy
and maintained.
Controls / Processes Test Case Results, Auditors
Observations & Opinion
control Risk
• Network Security Policy
• Application Software Policy
• Change Management Policy
• Backup Policy
• BCP and Response Management Policy
• Audit Trail Policy

Does the organisation follow any other policy or


procedures or documented practices that are relevant.

Does the Organisation have a Is there any documentation on Business Continuity / Results Opinions
suitable documented Business Disaster Recovery / Incident Response?
Continuity or Disaster
Recovery or Incident Does a BCP / DRP plan exist?
Response process
commensurate with the If a BCP/DRP plan exists, has it been tested?
organisation size and risk
profile to ensure a high Are there any documented incident response
degree of availability of the procedures?
installed CTCL system
Are there any documented risk assessments?

Does the installation have a Call List for


emergencies maintained?

How will the organization Network / Communication Link Backup


assure customers prompt • Is the backup network link adequate in case
access to their funds and of failure of the primary link to the NSE?
securities in the event the • Is the backup network link adequate in case
organization determines it is of failure of the primary link connecting the
unable to continue its CTCL users.
business in the primary • Is there an alternate communications path
location between customers and the firm.
• Is there e an alternate communications path
between the firm and its employees.
• Is there an alternate communications path
with critical business constituents, banks
and regulators?
The CTCL system has been Copy of Undertaking provided regarding the CTCL Results Opinions
installed after complying with system as per relevant circulars
the various NSE circulars
Copy of application of approval for Internet Trading,
if any

Insurance The insurance policy of the Member covers the


additional risk of usage of CTCL and or Internet
Trading

To ensure system integrity Planned Changes Results Opinions


and stability all changes to Are changes to the installed CTCL system made in a
Controls / Processes Test Case Results, Auditors
Observations & Opinion
control Risk
the installed CTCL system planned manner?
are planned, evaluated for Are they made by duly authorized personnel?
risk, tested, approved and
documented. Risk Evaluation Process
Is the risk involved in the implementation of the
changes duly factored in?

Change Approval
Is the implemented change duly approved and
process documented?

Pre-implementation process
Is the change request process documented?

Change implementation process


Is the change implementation process supervised to
ensure system integrity and continuity

Post implementation process


Is user acceptance of the change documented?

Unplanned Changes
In case of unplanned changes, are the same duly
authorized and the manner of change documented
later?

In case of members self developed CTCL system


SDLC documentation and procedures if the installed
CTCL system is developed in-house.
Results Opinions
How will the organization System Failure Backup
assure customers prompt Are there suitable backups for failure of any of the
access to their funds and critical system components like
securities in the event the • Gateway / Database Server
organization determines it is • CTCL router
unable to continue its • Network Switch
business in the primary
location Infrastructure breakdown backup
Are there suitable arrangements made for the
breakdown in any infrastructure components like
• Electricity
• Water
• Air Conditioning

Primary Site Unavailability


Have any provision for alternate physical location of
employees been made in case of non availability of
the primary site

Disaster Recovery
Are there suitable provisions for Books and records
Controls / Processes Test Case Results, Auditors
Observations & Opinion
control Risk
backup and recovery (hard copy and electronic).

Have all mission-critical systems been identified and


provision for backup for such systems been made?

Are documented practices Day Begin Results Opinions


available for various system
processes Day End

Other system processes


• Audit Trails
• Access Logs
• Transaction Logs
• Backup Logs
• Alert Logs
• Activity Logs
• Retention Period
• Misc

Is a log of success / failure of Day Begin


the process maintained
Day End

Other system processes

In case of failure, is there an Details of the various response procedures incl. for
escalation procedure Access Control failure
implemented? Day Begin failure
Day End failure
Other system Processes failure

Access Control As given in Area (e) Results Opinions

Firewall Is a firewall implemented?

Anti virus Is a malicious code protection system implemented?


If Yes, then
• Are the definition files up-to-date?
• Any instances of infection?
• Last date of virus check of entire system
PART - C

Sr. Area of Audit Compliance Remarks (if


“No”)
No. Part C

1 Whether the required details of all the CTCL ids created in the CTCL server of the YES / NO
trading member, for any purpose (viz. administration, branch administration, mini-
administration, surveillance, risk management, trading, view only, testing, etc) and
any changes therein, have been uploaded as per the requirement of the Exchange?
If no, please give details

2 Whether all the CTCL user ids created in the CTCL server of the trading member YES / NO
have been mapped to 12 digit codes on a one-to-one basis and a record of the same is
maintained?
If no, please give details

3 All the audit recommendations given in relation to the system audit certificate for the YES / NO
year ended June 30, 2009 have been duly implemented. IF NOT, please give details

All DMA orders are routed through electronic/automated risk


4 YES / NO/
management systems of the broker to carry out appropriate validations of all risk
parameters before the orders are released to the Exchange. NA

DECLARATION:

I) All the branches where CTCL facility is provided have been audited and ONE consolidated
report has been submitted for all segments.

II) All the audit recommendations given in relation to the system audit certificate for the year ended
June 30, 2009 have been duly implemented. If not, the same have been reported hereunder.

1)
2)

III) There is no conflict of interest with respect to the member being audited. If any such instance
arises, it shall be brought to the notice of the Exchange immediately before undertaking the audit.

_______________________________

Signature

(Name of the Auditor & Auditing firm)

CISA/CISSP/ISA Reg. No. :

Date:

Place:

Stamp/Seal:
SUMMARY SHEET

NAME OF THE AUDIT FIRM : ____________________________________________________

Sr. Area of Audit Compliance Compliance Report


No. Reference
Part A Part B
S/M/W S/M/W

1 Are existing features and system parameters


implemented in the CTCL system in place at the
member’s premises

2 Are input, processing and output controls in


respect of CTCL operations adequate

3 Is the application security commensurate to the


size and nature of application

4 Is Event logging and system monitoring


observed.

5 Are User management norms defined and NA


observed

6 Are Password policy/standards defined and NA


observed

7 Are working processes in adherence with the


policies and procedures defined
NA

8 Is the Network managed adequately in relation to


size and nature of operations and are necessary
controls present NA

9 Are Change management and version controls


documented and practiced? NA

10 Are Backup systems present, of adequate size NA


and are procedures for backup prescribed

11 Is there a Business continuity and disaster


recovery plan in place and made known to all NA
employees
NA
12 Is documentation for system processes
maintained
13 Are Security features such as access control,
network, firewalls and virus protection present NA
and updated regularly

14 Is there any other area/aspect which in the


auditors opinion is not complied with and which
is significant and material in relation to the size NA
and the nature of the operations

Note: Process Area Controls Evaluation Criteria

Control Evaluation Criteria Description

Strong The controls are defined as Strong if the following criteria are met
Implemented controls fully comply with the stated objectives and
no material weaknesses are found.

Medium The controls are defined as Medium if the following criteria are met
Implemented controls substantially comply with the stated
objectives and no material weakness result in substantial risk
exposure due to the non-compliance with the criteria
Compensatory controls exist which reduce the risk exposure to
make it immaterial vis-à-vis the non-compliance with the criteria.

Weak The controls are defined as Weak if the following criteria are met
Implemented controls materially fail to comply with the stated
control objectives.
Compensating controls fail to reduce the risk so as to make it
immaterial vis-à-vis the non-compliance with the compliance
criteria.

( To be on the letter head of the AUDITOR)


Date :

To,

CTCL Department

National Stock Exchange of India Limited

Exchange Plaza, Bandra-Kurla Complex,

Bandra (E), Mumbai – 400 051

This is to certify that the following are the list of applications for which the system audit has been

Conducted by me/ us for the trading member <TM code> < TM Name> for the year ended June 30, 2010.

S.No Name of the application Version Type of the product Developed by Vendor Name
(CTCL/IBT/DMA/Algo)

Signature

(Name of the Auditor & Auditing firm)

CISA/CISSP/ISA Reg. No. :

Date:

Place:

Stamp/Seal:

( To be on the letter head of the MEMBER)


Date :

To,

CTCL Department

National Stock Exchange of India Limited

Exchange Plaza, Bandra-Kurla Complex,

Bandra (E), Mumbai – 400 051

Following are the list of applications which has been approved by Exchange as on June 30,2010..

S.No Name of the application Version Type of the product Developed by Vendor Name
(CTCL/IBT/DMA/Algo)

Yours faithfully,

Signature

Name, Designation

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