PA-13: Audit, reporting and change control
Paragraph-level professional implementation page for Payment Aggregators.
Finin2min Summary — in 2 Minutes
PA-13 — Audit, reporting and change control. Submit statutory/system audit, cyber incident, escrow and regulator returns and pre-clear material changes.
Official source and legal ownership
Paragraph-wise Finin2min interpretation
Legal trigger
Submit statutory/system audit, cyber incident, escrow and regulator returns and pre-clear material changes.
Control owner
Business identifies the event; Compliance confirms law; Operations/Technology executes; Independent review tests evidence.
Evidence
Official source snapshot, policy/SOP, system rule, customer/transaction record, maker-checker log, exception approval and regulatory acknowledgement.
Failure consequence
Customer harm, reporting defect, prudential misstatement, supervisory observation, monetary penalty, restriction or remediation.
Practical example
Implementation and evidence controls
- Freeze the applicable entity class, product, transaction date and official instrument version.
- Map every control to its legal owner, enabling provision, responsible function, evidence and escalation route.
- Retain Board/committee approval, policy version, system configuration, maker-checker evidence, exception approval and regulatory filing acknowledgement.
- Re-test the control after an amendment, product change, outsourcing change, merger, customer-risk reclassification or supervisory observation.
Practical Q&A
What is the first test for Audit, reporting and change control?
Confirm entity, product, event date, official paragraph and any stated exception.
Can a portal or system acceptance cure a legal defect?
No. Technical processing does not override the substantive Direction.
What should be retained for review?
The official source version, legal mapping, calculation or decision record, approvals, communications and filing evidence.