Was there a CVC guidelines breach at PNB's Brady House branch in Mumbai from where the fraudulent 'Letter of Undertakings' was issued? The Central Vigilance Commission (CVC) has a clear guideline on job rotations within a bank. In view of this, it is being asked why Deputy Manager Gokulnath Shetty, allegedly the main facilitator in the Rs. 11,400 crore fraudulent act, was kept in the foreign exchange department looking after the import section from March 31, 2010, till he retired on May 31, 2017. Was it because the bank paid so little attention to its international banking/ forex department that it was devastatingly short of professionals in the field that it couldn't, and didn't, find Shetty's replacement to effect the necessary job rotation? The other puzzling question is why the internal audit failed to do reconciliation of the Nostro accounts of PNB held with the overseas branches of Indian banks.