A diagram of the organizational structure of a credit institution. The hierarchy and powers of the divisions of the credit institution.
Typical organizational structure of a credit institution
Credit organization Is a legal entity that, in order to generate profit as the main purpose of its activities, on the basis of a special permit (license) of the Bank of Russia, has the right to carry out banking operations provided for
Types of credit institutions:
- Bank - a credit institution that has the exclusive right to carry out in aggregate the following banking operations:
- attraction of funds of individuals and legal entities into deposits,
- placement of these funds on their own behalf and at their own expense on the terms of repayment, payment, urgency,
- opening and maintaining bank accounts of individuals and legal entities.
- Non-bank credit institution - a credit institution that has the right to carry out certain banking operations provided. The permissible combinations of banking operations for these organizations are established by the Bank of Russia.
Branch of a credit institution- this is its separate subdivision located outside the location of the credit institution and carrying out on its behalf all or part of the banking operations provided for by the license of the Central Bank of the Russian Federation issued to the credit institution. In accordance with, the credit institution (branch) has the right to open internal structural divisions (VSP)- additional offices, credit and cash offices, operational offices, operational cash desks outside the cash center. Additional office (DO)- can carry out all banking operations or part of them provided for by the license of the Central Bank of the Russian Federation for the credit institution or branch that created it. It opens only in the territory where the Bank itself or its branch is located. Operations Office (OO)- has the right to carry out all or part of the banking operations provided for by the license issued by the credit institution to carry out banking operations (regulations on the branch). It can be opened anywhere. In the event that the PA is located outside the territory subordinated to the territorial institution of the Bank of Russia supervising the activities of the credit institution (branch) opening an operational office, then it not entitled:
- carry out transactions (including transactions at the expense of clients) for the purchase and (or) sale of foreign currency both in cash and in non-cash form on the interbank and exchange currency markets;
- carry out transactions (including transactions at the expense of clients) on the purchase and (or) sale of securities and other financial assets related to the acceptance of financial risks by the credit institution (there is an exception)
- provide loans (credits) to credit institutions, as well as place deposits and other funds with credit institutions;
- receive loans (credits), attract deposits and other funds from credit institutions;
- open and maintain correspondent accounts of credit institutions (branches);
- open correspondent accounts with credit institutions (branches) to carry out transactions;
- issue bank guarantees;
- to accept and (or) avalify bills.
Credit and cash office (KCO)- carries out operations for the provision of funds to small and medium-sized businesses and individuals, as well as for their return (loan repayment), provides cash services to legal entities and individuals, accepts cash in the Russian Federation and foreign currency for making transfers on behalf of an individual persons without opening a bank account (BFB transfers) are also entitled to carry out operations with foreign currency and checks established. It can be opened anywhere. Carries out only those operations from the listed ones, which are provided for by the regulation on the branch. Operating cash desk outside the cash register (OKVKU)- has the right to carry out cash transactions with legal entities and individuals, to carry out BFB transfers, also has the right to carry out transactions with foreign currency and checks established. OKVKU can be opened on any territory. ADVICE: If it is written in a regulatory document of the Bank of Russia that an administrative document is issued by a Credit Organization, then this means that an order / order / regulation must be developed and issued in the GO for all its GSPs and Branches, if it is written that the administrative document is issued in the Credit Organization, in the Branch / VSP, respectively, everyone develops and publishes already at home. In practice, it is better that the main Regulations and administrative documents concerning the organization of work as a whole are published in the GO, in order to ensure uniformity of work. If the administrative documents relate to the appointment of responsible persons, or determine the composition of the commissions, then Branches and VSP can appoint employees independently.
A selection of the most important documents on demand Operational office(regulations, forms, articles, expert advice and much more).
Articles, comments, answers to questions: Operational office
As follows from the materials of the case, Muzychenko AND.C. expressed his explicit consent to write off funds from the current account in order to fulfill credit obligations. So, from clause 4 of the consent to a loan dated December 2, 2012 it follows that I.S. gave an acceptance in advance for the fulfillment of the Bank's requirements (including payment requests) - for writing off any amounts of arrears (loan amount, accrued interest and forfeit (penalty)) in an amount corresponding to the Bank's request from accounts with the Bank opened in additional and operational offices, as well as in the branches of the Bank in regions other than the region where the loan was granted, if the Bank exercises the right, if funds are insufficient to fully repay the debt, to write off the funds in the available amount in order to partially fulfill these obligations. Clause 2.3 of the loan agreement dated May 12, 2014 contains the previously given by I.S. Muzychenko. acceptance to write off funds from his accounts opened with the creditor bank until the full fulfillment of obligations.
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As follows from the materials of the case, Muzychenko AND.C. expressed his explicit consent to write off funds from the current account in order to fulfill credit obligations. So, from clause 4 of the consent to a loan dated December 2, 2012 it follows that I.S. gave an acceptance in advance for the fulfillment of the Bank's requirements (including payment requests) - for writing off any amounts of arrears (loan amount, accrued interest and forfeit (penalty)) in an amount corresponding to the Bank's requirement from accounts with the Bank opened in additional and operational offices , as well as in the branches of the Bank in regions other than the region where the loan is granted, if the Bank exercises the right, if funds are insufficient to fully repay the debt, to write off the funds in the available amount in order to partially fulfill these obligations. Clause 2.3 of the loan agreement dated May 12, 2014 contains the previously given by I.S. Muzychenko. acceptance to write off funds from his accounts opened with the creditor bank until the full fulfillment of obligations.
Normative acts: Operational office
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9.5.1. The operational office can be located both in the territory subordinated to the territorial institution of the Bank of Russia that supervises the activities of the credit institution (branch) that opens the operational office, or outside such territory within the federal district, on the territory of which the head office of the credit institution (branch) is located. opening an operational office.
Internal structural unit of a credit institution or its branch is a subdivision located outside their location and carrying out banking operations on behalf of the credit institution, the list of which is established by the regulations of the Bank of Russia, under the license of the credit institution.
The types (forms) of possible internal structural divisions are established by acts of the Bank of Russia.
The authority of a branch of a credit institution to make a decision on opening an internal structural unit should be provided for by the statute on the branch of a credit institution (parts 8-10, article 22 of the Law on Banks and Banking Activities).
In this regard, it is possible to highlight the general differences between the internal structural divisions of credit institutions:
a) from branches and representative offices - the fact that they can be opened not only directly by credit institutions, but also by their branches;
b) from branches - the fact that the list of operations that they can carry out is limited not only by the license of the credit institution, but also by the regulations of the Bank of Russia.
In addition, the internal structural divisions of credit institutions do not provide for the opening of correspondent subaccounts, but only personal accounts for the account of a credit institution or its branch.
There are also differences that are already characteristic of each type (form) of an internal structural unit separately.
A credit institution or its branch, provided that the credit institution does not have a ban on opening branches, has the right to open the following internal structural divisions:
Additional offices;
Operating offices;
Credit and cash offices;
Operational cash desks outside the cash register;
Exchange offices;
Other internal structural divisions provided for by the regulations of the Bank of Russia. In particular, banks or their branches have the right to open mobile points of cash transactions operating on the basis of a motor vehicle (PPKO).
1. Additional office may not be located outside the territory of the territorial institution of the Bank of Russia supervising the activities of the respective credit institution (branch).
The additional office is entitled to carry out all or part of the banking operations provided for by the license issued by the credit institution for banking operations (branch regulations).
2. Operational office may be located both in the territory subordinated to the territorial institution of the Bank of Russia that supervises the activities of the credit institution (branch) opening an operational office, or outside such territory, but within the same federal district.
The operational office is entitled to carry out all or part of the banking operations provided for by the license issued by the credit institution for banking operations (branch regulations).
However, in relation to an operational office located outside the territory subordinated to the territorial institution of the Bank of Russia that oversees the activities of a credit institution (branch) that opens an operational office, restrictions are imposed on the performance of certain operations. For example, such operational offices are not entitled to:
Carry out transactions for the purchase and sale of foreign currency;
Provide loans to credit institutions, place deposits and other funds with credit institutions, as well as receive such loans and attract deposits;
Open and maintain correspondent accounts of credit institutions (branches), as well as open such accounts themselves in other credit institutions;
Issue bank guarantees;
Accept and avalify bills.
These operating offices also have limited transactions for the purchase and sale of securities.
3. Credit and cash office may be located outside the territory under the jurisdiction of the territorial institution of the Bank of Russia supervising the activities of the credit institution (branch) that created it.
The credit and cash office has the right to carry out:
ü operations for the provision of funds to small businesses and individuals, as well as for their return (repayment);
ü cash services for legal entities and individuals;
ü Acceptance of cash currency of the Russian Federation and foreign currency for making a transfer on behalf of an individual without opening a bank account.
The credit and cash office is also entitled to carry out banking operations provided for exchange offices with foreign currency in cash and checks, the nominal value of which is indicated in foreign currency.
4. Operational cash desk outside the cash register may be located outside the territory subordinated to the territorial institution of the Bank of Russia supervising the activities of the respective credit institution (branch).
The operating cash desk outside the cash register has the right to carry out the same operations as credit and cash offices, except for lending to small businesses and individuals.
5. Exchange office may be located outside the territory subordinated to the territorial institution of the Bank of Russia supervising the activities of the credit institution (branch) that opened it.
The following types of operations can be carried out in exchange offices:
ü purchase and sale of foreign currency in cash;
ü exchange of one foreign currency for another (conversion);
ü exchange of banknotes of a foreign state;
ü replacement or purchase of damaged banknotes of foreign countries;
ü Acceptance of banknotes of foreign states for submission for examination;
ü buying and selling checks denominated in foreign currency;
ü payment of checks;
ü Acceptance of cash foreign currency and currency of the Russian Federation for crediting to the accounts of individuals using payment cards;
ü issue of cash foreign currency and Russian currency from the accounts of individuals using payment cards;
ü Acceptance of cash foreign currency and Russian currency for making transfers from the Russian Federation on behalf of an individual without opening a bank account and a number of other operations.
Data on all the above structural divisions of credit institutions are entered by the Bank of Russia into the Book of State Registration of Credit Institutions.
The date of opening an additional office, a credit and cash office, an operating office, an operating cash desk outside the cash center is the date the credit institution sends a notification to the Bank of Russia. From that date, internal structural divisions have the right to carry out banking operations and transactions delegated to them.
An exchange office has the right to start work only after receiving a positive opinion from the Bank of Russia on the compliance of its premises for carrying out transactions with valuables to the requirements established by the regulations of the Bank of Russia.
By opening these internal structural divisions, a credit institution, either directly or through its branches, can create an extensive customer service network.
Internal structural divisions of a credit institution include: additional, operational and credit and cash offices, operational cash desks outside the cash center.
The procedure for opening banking divisions is regulated by:
Article 22 “Branches, Representative Offices and Internal Structural Subdivisions of a Credit Organization” of the Federal Law “On Banks and Banking Activities”;
Instruction of the Central Bank of the Russian Federation of April 2, 2010 No. 135-I (previously - No. 109-I of January 14, 2004) "On the procedure for the Bank of Russia to make a decision on state registration of credit institutions and issuance of licenses for banking operations" (hereinafter - Instruction No. 135-I)
Additional office- internal structural unit of the bank or its branch. Can carry out banking operations or part of them, provided for by the license of the Central Bank for the credit institution or branch that created it. It opens only on the territory of the same settlement where the bank itself or its branch is located.
Credit and cash office- internal structural unit of the bank or its branch. Carries out operations for the provision of funds to small businesses and individuals and their return (repayment), as well as cash services for legal entities and individuals. This definition can be found in the Bank of Russia Instruction No. 135-I.
Operational cash desk outside the cash register- the internal structural unit of the bank, which provides only cash services to the population: receiving and issuing deposits, receiving utility and other payments from individuals, buying and selling securities (Instruction No. 135-I).
By Ordinance No. 1794-U of February 21, 2007, the Bank of Russia gave credit institutions the right to open a new type of internal structural unit - an operational office.
The office can carry out all or part of the banking operations provided for by the Central Bank's license for the financial institution (branch) that created it. Subdivisions located outside the territory of the institution of the Bank of Russia, which controls the activities of the credit institution (branch), have a number of restrictions on the implementation of operations. For example, they are not entitled to carry out transactions for the purchase and sale of foreign currency in the interbank and exchange currency markets, securities and other financial assets associated with the adoption of financial risks by the bank, etc.
Unlike an additional office, operational cash desks outside the cash office, credit-cash and operational offices can be located outside the department of the territorial institution of the Bank of Russia, which oversees the activities of the bank (branch) that opened this subdivision.
It should also be noted that, according to the order of the Central Bank No. 2423-U, from October 1, 2010, all exchange offices were transferred to the status of internal structural divisions (with the exception of a mobile point of cash transactions) or closed.
There are many troubling moments in the current state of the Russian banking system. This is both the excessive consolidation of the main players and the desire to leave the market of large foreign bankers. And the total number of banks in Russia is declining. However, the remaining players staked on development and are gradually increasing their presence in the regions.
Professional banking resource Bankir.ru conducted a study among Russian bankers on the principles of development of territorial networks of banks. In their opinion, the industry is returning to a stage of active growth. The reviving retail banking requires expansion. Credit organizations today need personnel, space, real estate. Everyone has different strategies for building a branch network - from aggressive to conservative. However, it is obvious to the market that banks are aiming at growth and capture of new territories.
Where to go
Among the most active players are representatives of the largest Russian state-owned banks and regional bankers, which are not ready to give up their positions in the local markets well-known to them. For example, Vyacheslav Vorobiev, Deputy President - Chairman of the Management Board, Director of the VTB24 Network Department, said: “In 2010, we opened 55 offices, 90% of them in large cities with a population of more than 500,000 people”. The size of VTB24's sales network in the largest Moscow market has reached 90 offices. The largest growth in the VTB24 network in 2010 was in Moscow, where the bank opened 13 offices. There are five offices in St. Petersburg. Four offices in Yekaterinburg, Samara, Chelyabinsk. “As of the beginning of this year, we have 530 branches in 203 cities,” noted V. Vorobiev. "Now our services are available to 71% of the urban population of Russia in 69 regions." VTB24 has ambitious plans for this year - to open 70 points of sale.
Among the energetic regionals is Express-Volga Bank. At the end of last year, the number of its branches doubled - from 30 to 60, and in the first half of this year the target was announced - 100 branches. Another regional SKB-Bank has achieved all-Russian coverage. Today SKB-Bank is present in 96 cities of Russia in 35 constituent entities of the Federation. The new strategy for expanding the network was also adopted by Pervobank. Today it serves clients in 33 offices in nine Russian cities: Samara and the Samara Region, Moscow, St. Petersburg, Ulyanovsk, Orenburg and Tarko-Sale (Yamalo-Nenets Autonomous District).
It is worth noting also Metcombank, OTP Bank, First Republican Bank, Moscow Renaissance Credit.
The development strategies of bank offices depend on the "origin" of the banks. As a rule, regional credit organizations first develop within their region, and then expand their expansion to neighboring regions, focusing primarily on regional capitals, and then on large cities. Large banks, which form their strategies from Moscow, immediately focus on cities with a population of over one million, and later on to the periphery.
The development paradox: the priority in choosing a direction for all players is the presence of the economic potential of the region, and not the presence / absence of banking services. That is, bankers are ready to compete with each other for an economically active region, and not to pile up new areas with undeveloped infrastructure.
Many bankers agree with this opinion. For example, in the opinion of Oleg Shemyakov, Head of the Marketing Department of Interkommerts Bank, the bank is not very interested in regions with a low development of banking services. After all, the payback period of a branch in underdeveloped regions often stretches over several years.
Another important development factor is the presence of strong managers in the region. The priority is given to regions in which specialized higher education is well developed.
In terms of the number of bank offices, the Central and Volga Federal Districts are in the lead. Proceeding from banking strategies, one should hardly expect rapid development in the most backward North Caucasian and Far Eastern districts. The Siberian, Ural, Southern and Northwestern Federal Districts look more promising.
What units are needed
Bankers again start not from market expectations, but from their own development strategy. Large banks prefer to open regular divisions. This allows you to be closer to the client.
Regional banks are more focused. For example, Svyaz-Bank is increasing the number of points of sale in order to be closer to individual customers.
VTB24 is expanding its network for the same reasons. Large formats have already been opened in all regions of VTB24 presence. One sales office has 120,000-140,000 inhabitants. This is much better than three years ago. Now the benchmark is taken for high network density in cities with high potential. If necessary, VTB24 creates additional backup points in areas where a large client base has already been formed, and the existing office is overloaded. The main formats that have been opened in the last two years are standard departments with four to six workplaces, an area of 150-250 sq. m. At the same time, the format of a standard branch has changed significantly: the client area and the 7 x 24 area have expanded, the number of ATMs has significantly increased.
Medium-sized banks use all network formats, starting from business objectives in a given territory, development prospects and achieved results. For example, Bank PRB began to develop its regional network by opening full-fledged branches. In the process of development, efficient and successful branches were supplemented with a network of branches, and ineffective ones were transformed into “lightweight formats” of business - operational offices. Bank Express-Volga believes that the format of a classic additional office is optimal. The same format is called the most promising in the university-bank, Chelyabinvestbank. SKB-Bank also considers an operational office to be a quite suitable format. Primsotsbank prioritizes an additional office and a branch.
B&N Bank stands for a more flexible approach: a reasonable compromise is needed in building a network. It all depends on the specific goals. If the goal is to expand the network in the same city or constituent entity of the Russian Federation, then an additional office. If the goal is to enter new constituent entities of the Russian Federation, then through a representative office, which will subsequently grow either into a branch or into an operational office.
However, to date, the undisputed leader among all banking formats are additional offices, followed by operating cash desks. Meanwhile, it is in these segments that a drop in quantity has been observed over the past six months. At the same time, the number of credit and cash offices and operational offices is growing.
What if the calculation was not justified?
An open banking unit falls short of the required level of efficiency. What to do? Firstly, it can be closed (however, bankers use this method less and less), secondly, it can be sold, and thirdly (by the way, this method is most relevant now), the division is either transferred or restarted in the same or a different format ... It happens that a point is ineffective for a long period, and all methods of business development do not work in it. In this case, the PRB, for example, tries to improve the economy by bringing costs to the size of the business, changing the format of the territorial division (a branch turns into an opera office, KCO, etc.). An extreme step is when bankers are closing down ineffective divisions.
There are known stories of not closure, but the transfer of a division dictated by the development of the banking business in a particular region. For example, BKF Bank closed a branch in Krasnoyarsk last year, but opened in Novosibirsk.
There are also more optimistic tasks: the existing point is temporarily closed in order to reformat it into the next format in the hierarchy. This story is remembered at SKB Bank: in Krasnoyarsk, a representative office was transformed into an operational office. Representative offices have less authority and can carry out a limited number of transactions. Having received convincing results of work in this city, SKB-Bank decided to transform its representative offices into full-fledged offices. Smolensk Bank temporarily suspended the work of one of the offices to expand its functionality. Before the transformation, there was only one cash desk for clients and only one teller could help them carry out the necessary banking operations. Over time, queues began to appear, there was clearly not enough specialists to service everyone who contacted this office.
In connection with the active reduction in the total number of banks and the redistribution of their assets and divisions among the remaining players, there is another reason for the closure of banking divisions - internal competition. Thus, the branch network of Bank Solidarnost, after merging in 2008 into a group with Bank Potential (Togliatti), which was taken over for reorganization, has doubled. Some additional offices of the two banks began to compete on the same sites. Therefore, in 2008-2010. the branch network was systematically optimized, five points had to be cut.
When it comes to closing its divisions, VTB24 prioritizes cost optimization. During the crisis, this approach was the most reasonable. As a result, 34 offices that did not correspond to the formats of a retail bank were closed. However, VTB24 acted not only with tough methods. For a third of its offices, VTB24 has reduced the rental rate by almost 20% and continues to negotiate with lessors to reduce the rates. The total savings from the reduction in rental rates on an annualized basis amounted to almost 100 million rubles.
In general, the cost of renting premises for banking divisions is an increasingly significant factor. In a number of cases, especially during a crisis, it is the high rent that can lead to the closure of an additional office.
The number of bank offices in the federal districts of Russia
The structure of territorial divisions of banks