1. WHAT IS KYC?
 Strategic Difference between selling FMCG and
banking products.
 Relationship of Endurance in Finance. (Repaying
excess credits in account requires Integrity!)
 Recent lessons. (CHEQUE DROPPING IN
BOXES, OMBUDSMAN, ACCOUNT NUMBER,
MASS ACCOUNTS)
 Importance of Introduction. (NO COPIES ---
ORIGINAL PROOF NEEDS TO BE VERIFIED)
 Soliciting ---- Changing Trends.
 CODE OF COMMITMENT.

2. CODE OF COMMITMENT
 Key Commitments
 Information
 Advertisements marketing & sales
 Privacy and Confidentiality
 Collection of Dues
 Complaints Grievances & feedback
 Products & services
 Protecting accounts

3. STARTING A NEW BANK
1.Your friends and you mobilize some capital and
you want to start a bank. Can you open a
Cooperative bank, or a schedule bank or a private
bank? If not why not; if yes how?
2. You are NEW PRIVATE sector scheduled bank.
You select a person above 65 and recommend for
CHAIRMAN post. In another case you select
banker with shady past but now very good. In
another case you select a non banker but MBA
professional. Will these selections be approved?

4. CENTRAL BANKER &
BANKING.
 Why a Regulator?
 Central Office/Corporate Office/Head
Office functions and setups.
 Control by onsite & offsite supervision by
RBI.
 CAMELS Model.
 Audits and inspection & Central Vigilance.
Detection and prevention of frauds.

5. INVESTMENTS & BRANCH.
1.You have fulfilled CRR and SLR criteria promptly.
Since you have a chain of customers who provide
large interest free current account funds, you do
not wish to go for high risk lending at all.
Therefore you want to invest everything in Gilt
Edged Securities. Can you do it?
2. You want to open a branch in Foreign or locally.
Can you do it at your will?

6. ORGANIZATIONAL
MANAGEMENT:
 Organizational setups of older Commercial
banks
 Technology based setups - Reduction in
tiers.
 Branch functions and managerial role.
 Regional and Zonal setups and functioning.
 Customer Loyalty & Bank viability.
(VERMA COMMITTEE inadequacy)

7. BRANCH & HO.
 Your branch is highly deposit oriented. How your
branch’s performance will be evaluated as it will
definitely incur loss?
 Your branch is inadequately staffed. When asked,
HO says you are having non-remunerative
business. How will you identify and eliminate?
 Your branch is highly loans oriented. But a lot of
them are previously granted NPA loans. Though
your branch is making profits HO says it is
inadequate. How do you justify your
performance?
 Your insurance pay outs are not quite consistent
with the entire bank’s claims ---- what are the
solutions.

8. TECHNICAL ASPECTS.
 Asset Liability management (ALCO) and matching.
 Treasury Management,
 Credit Deployment and
 Interest spread, Non-fund based income,
 Portfolio Management.
 NPA management.
 Mergers and acquisitions --- recent cases.
 IT and ATM accounts and inter-branch
reconciliation. CBS ---- what it does?

9. MANAGING HR.
 HR functions –
 Practical knowledge
 Personal touch in service.
 Motivation through placement – constraints.
 Unions and their roles.

10. INCENTIVES.
1. To motivate staff can you pay commission for
opening deposit or loan account to your staff
members?
2. Can you give gift schemes for attracting
deposits/ loans?
3. Can you do picking lottery prizes for depositors?
4. Can you run a CHIT scheme in a bank?
5. Can you build a hotel, as a banker? If not your
bank’s training college has lodging and boarding
facilities. Can you let it out and account income?

11. GOVERNMENT SCHEMATIC
LENDING:
 Agricultural credits,
 Priority sector products,
 Micro Credit and Self help Groups.
 Risk mitigation through DICGC or self –
insurance concepts.

12. CERTAIN SCHEMES
 1. Integrated Rural Development Program (IRDP)
 The Scheme was launched in 1978‑79 in 2300 selected blocks of the
country and was extended to the whole of country with effect from
2.10.1980. It envisaged number of financing schemes for village
industries, small business, transport and agro ‑based avocations.
 2. Service Area Approach (SAA)
 The Lead Bank Schemes introduced in December 1969 emphasized on
Regional Credit Plan. However, the modified version of the same
came into effect from 1.4.1989, wherein each Bank had to take up
specified area for looking after the credit needs and thus serving the
area in its entirety.

13. SCHEMES CONTINUED
3.Model Village Project (MVP)
Commercial Banks adopted villages for all its credit
requirements.
4. Small Scale Industries Finance (SSI ‑ Finance)
Commercial Banks were compulsorily required to
achieve the targets fixed for small scale industry
financing for each Bank as a whole.
5. Tiny Sector Finance (TSF)
Financing very small business by the Commercial
Banks.
6. Differential Rate of Interest Scheme (DRI)
Government would pay the subsidized portion of the interest
for certain very small/weak business loans.

14. Schemes ----
 7. 20 Point Economic Programs
A detailed Economic Program worked out by
the Government for helping small business
and other priority sectors.
 8. Scheme for Providing Self‑ employment
to Educated Unemployed Youths (SEUY)
 Promotion of self‑employment among
educated young people – thus improving
small businesses and industries.

15. SCHEMES CONTINUED
9. Self-employment Program for the Urban Poor
(SEPUP)
Similar to (SEUY) but liberalized towards urban poor
youth.
10. Scheme of Urban Macro Enterprise
Very small business enterprises' promotion.
11. Transport Operators Priority Lending
Small transport operators running independent business
being helped in lending.
Apart from the above centrally conceived schemes there are
schemes which have been specifically conceptualized and
implemented at certain Bank levels like NEDA scheme
(New Entrepreneur Development Agency) of Indian Bank
wherein the entrepreneur of a small business is not required
to bring even the margin money.

16. PROJECT AND
PLANTATION LOANS:
 Rubber
 Coffee.
 Tea.
 Coca.
 Cardamom.
 Farm & Diary Projects. Etc.
DEVELOPMENT & SCHEMES. Many such
schemes were formed by NABARD with exclusive
financial modeling.

17. MANAGING SECURITIES AND
DOCUMENTATION
 Insurance and safe keeping.
 Attrition in the value of securities.
 Principles of Dual control.
 Prevention from time barring.
 Practical tips.
 Risks in Blank Documents.

18. NPA & BAD ASSETS
STRATEGIC MANAGEMENT.
 Persuasion.
 Trade-offs (Time value of Money)
 Securitization law.
 Re-phasing. Window dressing?
 ARC.
 Legal and other measures.
 Debt Recovery tribunal.

19. ALLIED ACTIVITIES
 Insurance and bank-assurance,
 Mutual Funds,
 Factoring,
 Merchant banking outfits.
 Credit Cards
 Venture Funds.

20. OTHER INSTITUTIONS.
 Specialized and Term Lending and
Development Banks (IDBI, SIDBI, IFCI,
EXIM BANK, NABARD, NHB)
 RRB, SFC, SIDC
 IBA, IIB.
 Scope of the Institutions
 International position in respect of
Development Banking.

21. Banking Products --- Deposits
 Deposit ---- Demand & Time!
 Time Deposit --- Cumulative & Non
 Recurring.
 Annuity Type.
 Demand: SB & Current
 Hybrid.
 CD (& CP)

22. Lending ---
 Working Capital Products. ---- OD & Bills.
 Term Loans -----
 Project Loans
 Export & Import Loans.
 Agricultural & Allied Loans.
 Small Loans.
 Cards & Structured Loans.

23. BILLS OPERATIONS
 What is a bill? USANCE & DEMAND!
 Bills discounting.
 Bills purchase.
 Bills collection
1. Inward Bills.
2. Outward Bills.

24. Bills Finance vs. Simple
Overdraft
Point of comparison. Bills Finance. Simple Overdraft.
Nature It is Self-diluting. It is a Continuing liability.
Flexibility to borrowers Not much. There is flexibility as the borrower
can withdraw at any time and repay
within the stipulated period.
Security Only credit worthiness is checked. Accorded against approved
securities like shares, NSC’s, Life
Insurance Policies etc.
Charges Only discounting at the initial stage Interest charged on running
itself. balance of utilized amount. And
commitment charges are payable
against unutilized balance
Purpose Specified in bill Not specified.
Chance of misuse Goods covered may not be It is inconvenient to the banks and
resalable at times & Chances of hampers credit planning &High by
kite-bills. getting credit in excess and double
financing.

25. Definition Of Bill Discounting
While discounting a bill, the Bank buys the bill
(i.e. Bill of Exchange or Promissory Note) before
it is due and credits the value of the bill after a
discount charge to the customer's account. The
transaction is practically an advance against the
security of the bill and the discount represents the
interest on the advance from the date of purchase
of the bill until it is due for payment.

26. Why Bill Discounting?
 Bills discounting is a tool of funding
working capital requirements in any firm or
company.
 Any firm or company requires two types of
capital for smooth functioning of business
viz fixed capital and working capital.
 Example…….

27. Bill Discounting
1
2
Drawer Drawee
3
4 5 6
Banker
1. Drawer sells the goods to the drawee (2) Drawer draws the bill on the drawee
3. Drawee accepts the bill (4) Drawer presents it to banker
5. Banker credits the amount to drawer (6) At maturity, payment is made by
Payee.

28. Condition’s For Bill
Usually, the BankDiscounting
may want some conditions to be
fulfilled to be able to discount a bill:
 A bill must be a usance bill
 It must have been accepted and bears at least two
good signatures (e.g. of reputable individuals,
companies or banks etc.)
 The Bank will normally only discount trade bills
 Where a usance bill is drawn at a fixed period after
sight the bill must be accepted to establish the
maturity

29. Features
Following are the salient features of bill
Discounting:
 Discount Charge
 Maturity
 Ready Finance

30. Bill of Exchange
 Itis a negotiable instrument and one of the means
of Bill discounting.
 Definition: A bill of exchange “is an instrument in
writing containing an unconditional order, signed
by the maker, directing a certain person to pay a
certain sum of money only to, or to the order of, a
certain person or to the bearer of the instrument.”
(Sec 5 Negotiable Instrument Act)

31. Bill of Exchange
 Payable to order on demand
Mumbai September 17, 2xxx
On demand please pay Mr. Abhishek or order the sum of
Rupees Twenty Five Thousand only.
Rs. 25000
Mr. Menon Atul Jadhav
Pune

32. Types of Bill
Types of Bill
Nature of Geographic
Time Based Red Bill Other Bills
Liability Based
•supply Bill
•Documentary
With Without Accommoda Bill
Usance Bill Demand Bill Inland Foreign Bill •TradeBill
Recourse Recourse tion or Kite
•Ambiguous Bill
•Escrow Bill

33. Letter of Credit
A document, issued by a bank per
instructions by a buyer of goods,
authorizing the seller to draw a specified
sum of money under specified terms,
usually the receipt by the bank of certain
documents within a given time.

34. Letter of Credit
 Red Clause Letter of Credit:
Red Clause Letters of Credit provide the seller
with cash prior to shipment to finance production
of the goods. The buyer's issuing bank may
advance some or all of the funds. The buyer, in
essence, extends financing to the seller and incurs
the risk for all advanced credits.

35. Letter of Credit
 Standby Letter of Credit
This credit is a payment or performance guarantee
used primarily in the United States. They are often
called non-performing letters of credit because
they are only used as a backup should the buyer
fail to pay as agreed. Thus, a stand-by letter of
credit allows the customer to establish a rapport
with the seller by showing that it can fulfill its
payment commitments.

36. Legal Aspects
Banks are the financial institution which are
protected by law ,by Securitization act and
Debt Recovery Tribunal (DRT). In case of a
default banker needs to serve a notice and
then they can seize the necessary assets
which as been kept as security.

37. Difference b/w
Bill discounting Factoring
It is also called invoice
It is also called invoice discounting.
Factoring.
In this parties are drawer, In this the parties are
drawee and payee. Client, factor and debtor.
It is narrow in scope. It is broad in scope.
It is sort of borrowing from It is management of book
Commercial bank. debts.
Maximum time is 3 months. Maximum time is 6 months
Grace time is 3 days. Grace time not given.
Negotiable instrument act
There is no specific act
applies.
Provision of advance
No such provision is available.
Payment of book debt is available.

38. Accounting Treatment
In Respect of Bill of Exchange:
• Separately treated in Books of Drawer
Bills receivable Account Dr
To Acceptor Account
(with face value of the bill drawn and accepted)
• Books of Acceptor
Drawer’s Account Dr
To Bills payable Account
(with the face value of bill accepted)
 Separately treated in
– Books of Drawer
– Books of Acceptor

39. Books of Drawer
 Cash (or Bank) Account Dr (with
the net amount of the bill, i.e.,
the face value of the bill .
less the Amount of discount)
 Discount Account Dr
(with the amount of discount)
 To Bills receivable Account Cr
(With the face value of the bill)
Books of Acceptor
 No entry will be passed in the books of the acceptor
for the discounting of the bill, because he is not at
all affected by the discounting of the bill.

40. RISK MANAGEMENT
 Formation of Committee.
 Effective MIS & Specialized Staff.
 MIS should be Organization Specific.
 Asset Liability Matching. (ALCO)
 Market Variables.
 Credit Risk.

41. MANAGING CREDIT RISK
 Counter party risk.
 Measurement of risk through credit
rating/scoring;
 Quantifying the risk through estimating expected
loan losses i.e. the amount of loan losses that
company would experience over a chosen time
horizon (through tracking portfolio behavior over
5 or more years) and unexpected loan losses i.e.
the amount by which actual losses exceed the
expected loss. (Standard Deviation)

42. Credit Risk Managing
• Risk pricing on a scientific basis;
and
• Controlling the risk through effective
Loan Review Mechanism and portfolio
management.

43. TOOLS OF CREDIT RISK
MANAGEMENT
 Credit Approving Authority.
 PRUDENTIAL LIMITS
 Stipulate benchmark like current/debt equity,.
 Single/group borrower limits
 Substantial exposure limit
 Maximum exposure limits to industry, sector etc.
 Companies may consider maturity profile of the
loan book

44. COMPREHENSIVE RISK
RATING POLICY
 Based on MIS
 Identifying risk elements
 Give them scores in point scales.
 Weighted Averaging depending on risk
ranked parameters
 Based on track record of self and others.
 Periodic revision necessary.

45. UN-HEDGED FOREX
EXPOSURE RISK
 When Foreign exchange exposure is
exposed it should be either hedged or the
un-hedged portion must be considered for
quantification of probable loss.
 Hedging Instruments when used as trading
items, they should also be considered for
risk evaluation.

46. RISK PRICING.
 Itis fundamental tenet in Management.
 Expected probability and default should
decide the price.
 However collaterals also need be
considered while pricing.
 Risk Return Tangle is fundamental to any
management decision.

47. RISK ADJUSTED CAPITAL &
PRICING
 RAROC
 PROVIDING FOR ADEQUATE
CAPITAL BASED ON RISK ADJUSTED
ASSETS
 ALSO CONSIDER COMPETITOR
 EXIT THE PARTICULAR SEGMENT OF
BUSINESS IF UNAFFORDABLE

48. OTHER RISKS
 Investment Risk.
 Off Balance Sheet Exposure Risk.
 Inter-corporate Exposure risk.

49. RISKS
 MARKET RISK( Liquidity, Interest Rate,
Exchange Rate, Commodity Price, Equity Index)
 LIQUIDITY RISK (Funding, Time, Call , Risks)
 Basis Risk (Volatile Markets)
 Option Risk.
 Yield Curve Risk.
 Price Risk.
 Reinvestment & Resale Risk.

50. RISKS
 InterestRate Risk.
 Trading RISK & VAR.
 Transfer Pricing (Including Funds –FTP)
 VAR approach to Foreign Exchange Risk.
 Capital Market Risk.
 Operational Risk its Control.
 Risk Aggregation and Capital allocation

51. PRACTICAL BANKER
1. When you pay a CHEQUE, where the signature is forged but could
not be detected while verifying, can you get a legal protection?
2. A CHEQUE when bounced without funds, can a holder of the same,
who is not the direct payee, but an endorsee sue the original
signatory/drawer of the CHEQUE?
3. You bounce a CHEQUE by mistake though the customer had funds
in the account. The customer sues YOUR bank for very large
amount of damages, though the CHEQUE amount is very small.
Can the customer succeed in the case?
4. In a loan account there are dues both of interest and installments.
When a customer remits some part amount, does not mention as to
whether it is for the interest or for the installment. You have
appropriated the same for interest and intimated the customer, the
customer does not raise objection but at the time of closing the final
account raises dispute and says that it was meant for interest, will
the customer succeed?

52. PRACTICAL BANKER
5. A Brigadier of Army asks for cash payment of open DD
without identification stating that it is on Demand? How ill
you convince?
6. A CHEQUE is endorsed in favor of three persons in
succession. All have apparently signed and it is bearer.
Can you pay cash?
7. A CHEQUE or DD crossed plain, account payee and Not
Negotiable. Discuss Significance. A customer brings a DD
crossed NOT negotiable endorsed in his/her favor. Can
you collect the DD on behalf of the Customer?
8. A CHEQUE drawn in favor of a Ltd. company is bearer.
Can you pay cash? Will the position change if the amount
is above 20000/=

53. PRACTICAL BANKER
9. A CHEQUE is six months old dated. Can you pay
cash, if the customer is well known?
10. From Reliance Mobile Co., a bank obtained PDC
and discounted the same ---- is it in order?
11. A customer has sufficient balance in account.
Wants his CHEQUE to be marked as good for
payment. Can you do?
12. A CHEQUE is not in the appropriate stationery.
But properly drawn and you know that your
customer has drawn it. Can you pay, can the
customer later on sue you for negligence?

54. COUNTERFEIT NOTES & FRAUDS
13.Your cashier tracks a Counterfeit note. The customer says
“let us burn it – I will give another one” --- what will you
do?
14.Your safe kept cash bundle has a counterfeit note—
detected while paying --- what will you do?
15.PWD engineer invokes your Bank’s Guarantee. When you
verify the register, the BG is not in the records. But clearly
bears the previous manager’s signature--- what will you
do?
16.A leading personality says that the previous manager has
been holding the FD receipts; but while leaving, when
verified was found deficient. The VIP feels that the
previous man has taken undue advantage of the fact that
the money was number 2. What will you do?

55. PRACTICAL BANKER
17. A DD is presented for payment; but you have not received the issue
advice for the same form the issuing branch. The DD is for very high
value. To verify when you ring up the branch it is found that the
particular STATE has declared holiday under NI act. The payment is
demanded urgently. Even the signature of the drawing officer is new.
The new signatures are yet to be FASCIMILATED. What will you
do?
18. Pro-notes are time-barred in three years. But your loan to a customer
exceeds three years and you know that if the loan is not renewed
within three years the pro-note would be time-barred. Your customer
suggests that you can enter into an agreement with him stating that the
pro-note executed by him in bank’s favor would not be time barred as
he is agreeing to it. Would you bite it?
19. Your customer has borrowed and the surety has co-obliged the pro-
note. The original borrower loses his assets and you are filing suit
against the surety only. In court the surety alleges that he is only surety
and the main borrower is let off. What will court do?

56. PRACTICAL BANKER
 20. In a paying in slip the customer fills his account
number wrongly and the name is not quite legible. You
have accepted the same without seeing it properly. Based
on the wrong account number you pass credit to the
account and the other fellow draws the amount and closes
the account. After sometime, your customer your customer
comes with the counterfoil, which is easily readable and
demand payment/ proper credit to his account. You argue
that he should have written the account number correctly
and since he has erred he should suffer the loss. He goes to
court. Who will succeed?

57. MODEREN BANKER!!
A CHEQUE drawn on your bank has been
received at another far off place in a totally
different bank --- they are sending a fax
giving the scanned image of the CHEQUE
and ask you to pay the amount through
electronic exchange kept in place by the
CENTRAL BANKER ---- Discuss the
implications! Is there a law to Govern this?

58. CORE BANKING SOLUTION
Banking Earlier
 Changing face of Banking
 Manual ledger environment
 Delay in MIS / Data
 Many legacy systems
 Customer Service
 Compilation of financial information as a
Bank

59. Core Banking
 Remove various legacy systems
 End to end financial solutions
 Better customer service
 Easy compilation of financial data
 Access of data / financials from any point
 Scalability – better solutions
 Single Vendor

60. Advantages
 More structured products
 New Delivery Channels
 Customer Relationship management
 Risk Management

61. Players
 INFOSYS - FINACLE
 I-Flex - Universal Banking Solution
 THEMINOS
 People soft Technologies

62. UBS – System Structure
Database
At
Central Point
Branch

63. UBS
 FCR – Supports Retail Application
 FCC – Supports Wholesale Banking
 Access through telecom lines from any place with
centralized database
 Branch level user and customer information -
Database
 Online updating of debits / credits – Centralized
database
 Information availability online through other
channels like E-net / ATM / Mobile etc.

64. Information Exchange
 Branch functions are performed by accessing centralized database
through workstation connected to Branch server, which in turn speaks
to Centralized Database.
 Branch server has both FCR application and local branch database,
which stores local branch transactions.
 Branch server communicates with UBS production servers at
Centralized location on an online basis and ensures both local branch
database and production database are in sync.
 To communicate with production servers, branch server is configured
with production server IP Addresses and ports.
 Users from the branch connect through browser based application or
CITRIX
 FCR branch application connects to the production database using
ODBC and Application server using COM server of the branch.

65. Information Exchange
 Non branch functions which are regular operations
oriented are done through Host which is directly connected
to the centralized database.
 To communicate with production servers CITRIX
application is used

66. WORKING CAPITAL GAP
TANDON COMMITTEE
1. Working Capital gap = Current Assets – (Current
Liabilities- Bank limit for Working Capital)
 Maximum 75% of the identified gap can be financed.
Rest of the gap to be financed by own funds or on long-
term basis as a term loan.
 15 industries were basically identified, which covers
cotton, jute, rubber, pharmaceuticals, cement, engineering,
automobile industries etc.
 The norms cover limits of Raw materials, Semi-finished
products, finished products & receivables.

67. METHODOLOGY OF
FINANCING
I Method is financing for WC up to 75% of the
gap identified as above. Excess was converted as
TL.
 II Method envisages financing up to 75% of the
net current assets only.
 III Method envisages financing of core current
assets up to the full extent and rest of the 25%
needs to be financed through own resources
MIS statements were considered mandatory and
defaults would attract penalty interest over and
above of the contracted rate.

68. CHORE COMMITTEE
RECOMMENDATIONS
 As per this, all banks were directed in December
1980 that Method 2 should be applied for all
accounts where the working capital limit is
Rs50lakhs and above.
 Different types of advances, cash credit, loan and
bills types to continue.
 Bifurcation of cash credit limit into demand loan
and fluctuating cash credit portions - not favored.
 Seasonal Credits studied in detail analyzed.

69. NAYAK COMMITTEE
 Preference to village industries, tiny industries and
other small-scale units in that order.
 TANDON Committee will not apply for working
capital credit limits up to Rs50lacs from the
banking system for the above category.
 25% of the output value should be computed as
WC requirement, of which at 4/5th should be
provided by Banking Sector, the remaining 1/5th,
representing borrower's contribution towards
margin money for the WC

70. VAZ COMMITTEE
 VAZ committee has extended the concept of
NAYAK committee to all business
enterprises
 This is deviation to previous committees!

71. WORKING CAPITAL
MANAGEMENT
 It is complicated at the international level
because:
 a. Some countries do not have the
concept of working capital.
 b. Receivables and payables are in multi-
currencies.
 c. Credit terms vary internationally.

72. Methods to manage working
capital – 1 Inventory Mgt
i. 1 A good inventory management system-
some of the techniques of inventory control are:
 a) Just-In-Time (JIT): Its applicability depends
upon the country.
 b) ABC Analysis
 c) EOQ- Balancing inventory carrying cost
against unit order cost.
 d) Reorder Level.

73. 2 Managing Receivables
 Credit scoring model can be devised (for internal
transactions)
 Only rated clients (for big transactions of MNC’s)
 Taking security (when risky)
 Debt period analysis i.e. within 3 months, between 3 and 6
months, above 6 months etc.
 Offer a discount for immediate settlement.
 For a depreciating currency, calculate a discount and offer
it immediately.
 Forfaiting is a technique to manage receivables as the
rights of an unpaid seller may not be applicable in every
country.

74. 3 Cash Management
Tools for cash management:
EOQ for cash = 2AO
C
Where A= Annual requirement;
O= Opportunity cost; C= Carrying cost.

75. Bills Finance and Simple
overdrafts.
 CC
 OD
 Bills
 Goods Loan
 Acceptance Bills
 Export & Import Bills etc.

76. Current Current Assets
Ratio -----------------------
Current Liabilities + Provisions
Quick CA - Inventories
Ratio ---------------------
CL – OD

77. Newer Ratio?
 Compare Average Current Liability To
Monthly Cash Flows
 Going Concern Approach & Gone Concern
Approach