Sponsored
Introduction: Non-Banking Financial Companies (NBFCs) operate within a regulatory framework governed by the Reserve Bank of India (RBI). To ensure adherence to regulations, NBFCs must comply with various filings and timelines outlined by the RBI. This article serves as a consolidated guide for NBFC compliance officers, CFOs, and company secretaries, offering insights into the regulatory landscape and essential filings required for regulatory compliance.
NBFC: A Non-Banking Financial Company (NBFC) is a company registered under the Companies Act, 1956 engaged in the business of loans and advances, acquisition of shares/stocks/bonds/debentures/securities issued by Government or local authority or other marketable securities of a like nature, leasing, hire-purchase, insurance business, chit business but does not include any institution whose principal business is that of agriculture activity, industrial activity, purchase or sale of any goods (other than securities) or providing any services and sale/purchase/construction of immovable property. A non-banking institution which is a company and has principal business of receiving deposits under any scheme or arrangement in one lump sum or installments by way of contributions or in any other manner, is also a non-banking financial company (Residuary non-banking company).
OBJECTIVE
Non-Banking Financial Companies (NBFCs) are directed by Reserve Bank of India to submit various returns w.r.t., to their deposit acceptance, prudential norms compliance, ALM etc. within a specified timelines in accordance with various Master Directions. NBFC Compliances and Returns are comprehensive and require time-bound reporting, so as to avoid penal action by RBI. This is an effort toconsolidate the Compliances to provide a handy guide for all Compliance Officers, CFOs, Company Secretaries, to have a holistic view of compliance filing dates across various applicable laws, along withRegulating documents for NBFC Industry.
ABBREVIATIONS
| SAC | Statutory Auditor Certificate |
| DNBS | Department of Non-Banking Supervision |
| NBFC-ND-SI | Non Deposit taking Systemically Important |
| NBFC | Non-Banking Financial Company |
| HFC | Housing Finance Company |
| FAFT | Financial Action Task Force |
| NBFC-UL | Non-Banking Financial Company- Upper Layer |
| NBFC-ML | Non-Banking Financial Company- Middle Layer |
| NBFC-BL | Non-Banking Financial Company- Base Layer |
| NOFHCs | Non-Operative Financial Holding Company |
| LCR | Liquidity Coverage Ratio |
| CRILC | Central Repository of Information on Large Credits |
| SMA | Special Mention Account |
| ALM | Asset Liability Management |
| NBFCs-D | Non-Banking Financial Company taking deposit |
| NBFC-CIC | Non-Banking Financial Company- Core Investment Company |
YEARLY FILINGS/INTIMATIONS
| S.No. | Particulars | Description | Applicability | Filling Dates | Regulating Document |
| 1. | DNBS10 | Statutory Auditor Certificate (SAC) Return for Continued Regulatory Compliance | All NBFC and ARC | 31st December | Master Direction– Reserve Bank of India (Filing of Supervisory Returns) Directions, 2024 |
| 2. | DNBS02 | Financials details like components of assets and liabilities, prudential norms | Non Deposit Taking Non -NDSI | 30th May | Master Direction-NBFC Returns |
| 3. | Schedule- I Return | Details of public deposits, category wise distribution of housing loan to individual or state or union territories | HFC | 30th June | Master Circular-Returns HFC |
| 4. | Statutory Auditor Certificate | Statutory auditor certificate(SAC) return on certificate of registration as housing finance company | HFC | 30th June | Master Circular-Returns HFC |
| 5. | FAFT Compliance Certificate | For Compliance with the Norms specified by RBI, in respect of Investment from FATF non-compliant jurisdictions | HFC | 30th June | Master Circular-Returns HFC |
| 6. | Declaration | Board resolution for not accepting/ holding any public deposit | NBFC – ICC | 30th April | Master Direction-NBFC- Acceptance of Public Deposit Direction, 2016 |
| 7. | Declaration | Board Resolution for Acquisition of Shares/ Securities of its own Group /Holding/ Subsidiary Companies | Company which has acquired shares/ securities of its own group /holding/ subsidiary companies | 30th April | Master Direction-NBFC- Acceptance of Public Deposit Direction, 2016 |
| 8. | Form – A Certificate | Regarding appointment of Statutory Central Auditor(SCA)/ Statutory Auditor (SA) | All NBFCs | 21st April | Master Direction– Reserve Bank of India (Filing of Supervisory Returns) Directions, 2024 |
HALF-YEARLY FILINGS/INTIMATIONS
|
S. No. |
Particulars | Description | Applicability | Filling Dates | Regulating Document |
| 1. | Statement on Interest Rate Futures (IRF) Transaction | NBFC Participating in Interest Rate Future Exchanges for hedging their underlying exposures | NBFC including HFC participating in interest rate future exchanges |
|
Master Direction-Scale Based Regulation, Master Circular-Returns HFC |
| 2. | Schedule-IIReturn | Information on various Prudential Norms i.e., Capital Adequacy, Asset Classification, Provisioning Net Owned Funds etc. | HCF |
|
Master Circular-Returns HFC |
| 3. | ALM-II | Statement of Structured Liquidity and Interest Rate Sensitivity | HFC taking deposit and all non-deposit taking HFC with asset size of Rs.100 cr. And above |
|
Master Circular-Returns HFC |
| 4. | FDI– SAC | Compliance with the terms and conditions of foreign direct investment (FDI)-SAC | HFC having Foreign Direct Investment |
|
Master Circular-Returns HFC |
QUARTERLY FILINGS/INTIMATIONS
S. No. |
Particulars |
Description |
Applicability |
Filling Dates |
Regulating Document |
1. |
Annex X |
Report on Pledged Securities in their favour by the borrowers for availing loans |
NBFC having asset size of Rs. 100cr .And above |
30th June30th September31st December31st March |
Master Direction-Scale Based Regulation |
2. |
Notification /Email |
Statement to Communicate Principal and interest, EMI amount, number of EMIs left |
All NBFC including HFC |
30th June30th September31st December31st March |
Master Direction– HFC, Master Direction- Scale Based Regulation |
3. |
Report on Total Exposure |
Having Assumed Exposures against borrowers in excess of the normal exposure limits |
All NBFC |
30th June30th September31st December31st · March |
Master Direction-Scale Based Regulation |
4. |
Statement |
Statement for Change in Directors as per Fit and Proper Criteria |
NBFC-ML, NBFC-UL, HFC |
15th July15th October15th January15th April |
Master Direction-Scale Based Regulation, Master Direction-HFC |
5. |
DNBS01 |
Financial Details, viz. Components of Assets and Liabilities, Profit and Loss Account, Exposure to Sensitive Sectors |
NBFC-UL,NBFC-ML except NBFC-CIC |
21st July21st October21st January21st April |
Master Direction– Reserve Bank of India (Filing of Supervisory Returns) Directions, 2024 |
6. |
DNBS03 |
Important Prudential Parameters- Contains prudential norms, e.g.,capital adequacy, provisioning etc. |
NBFC-UL, NBFC-ML except NBFC-CIC |
21st July21st October21st January21st April |
Master Direction– Reserve Bank of India (Filing of Supervisory Returns)Directions, 2024 |
7. |
DNBS04A |
Statement on Short Term Dynamic Liquidity (STDL) contains data on Asset Liability Mismatches (ALM)and Interest Rate Sensitivity(IRS), liquidity risk of exposures. |
NBFC-UL,NBFC-ML(except NBFC-SPD), NBFC-BL with asset size of ₹100 crore and above solely or at Group level, excluding Type-I NBFCs, and NOFHC,P2Ps, AAs, and Mortgage Guarantee Companies |
21st July21st October21st January21st April |
Master Direction– Reserve Bank of India (Filing of Supervisory Returns) Directions, 2024 |
8. |
DNBS07 |
ARCs Important Financial Parameters- contains data on assets and liabilities, assets acquired from Banks/FIs, acquisition cost, trusts formed, recovery status of acquired assets etc. |
ARC |
21st July21st October21st January21st April |
Master Direction– Reserve Bank of India (Filing of Supervisory Returns) Directions, 2024 |
9. |
DNBS13 |
Return on Overseas Investment details for all NBFCs having overseas investment |
All NBFCs |
21st July21st October21st January21st April |
Master Direction– Reserve Bank of India (Filing of Supervisory Returns) Directions, 2024 |
10. |
Notification/Email |
Communicating Particulars of Public Deposit to Respective Branches |
HFC |
10th July10th October10th January10th April |
Master Direction-HFC |
11. |
Annexure VI |
Report on Detection and Impounding of Counterfeit Notes |
HFC |
7th July7th October7th January7th April |
Master Circular-Returns HFC |
12. |
Schedule-III Return |
Details on Statutory Liquidity Ratio (SLR),structural liquidity &interest rate sensitivity |
HFC |
15th July15th October15th January15th April |
Master Circular-Returns HFC |
13. |
Schedule-IV Return |
Financial details viz. Components of Asset and Liability, Profit and Loss Account, Exposure to Sensitive Sector |
HFC |
15th July15th October15th January15th May |
Master Circular-Returns HFC |
14. |
ALM-I |
Statement on Short Term Dynamic Liquidity (STDL) |
HFC taking deposit and all non-deposit taking HFC with asset size of Rs.100 cr. And above |
10th July10th October10th January10th April |
Master Circular-Returns HFC |
15. |
20- Major Exposure Return |
Details of large borrowers |
HFC |
10th July10th October10th January10th April |
Master Circular-Returns HFC |
16. |
Broad Liquidity Return |
Details of liability and asset of large HFC |
Deposit taking HFC irrespective of asset size |
10th July10th October10th January10th April |
Master Circular-Returns HFC |
17. |
Overseas Investment Report |
Report on overseas investment details |
Deposit and non-deposit taking HFC |
15th July15th October15th January15th April |
Master Circular-Returns HFC |
18. |
Periodic Report |
Analysis of complaints on activities of internal ombudsman |
Internal Ombudsman of Regulated Entity |
10th July10th October10th January10th April |
Master Direction-RBI (Internal Ombudsman for Regulated Entities) Directions, 2023 |
19. |
FMR4 |
Capture the updated information report on dacoities / robberies / theft /burglaries |
NBFC-UL, NBFC -ML, and NBFC-BL which are NBFC-ICC,NBFC-MFI, NBFC-Factors having asset size of ₹500crore and above |
21st July21st October21st January21st April |
Master Direction –Reserve Bank of India (Filing of Supervisory Returns)Directions,2024Master Direction -monitoring of frauds in NBFCs (reserve bank) directions, 2016 |
20. |
DNBS02 |
Important Financial Parameters |
NBFC-BL except NBFC– P2P |
15th July15th October15th January15th April |
Master Direction– Reserve Bank of India (Filing of Supervisory Returns)Directions, 2024 |
21. |
Appendix VI-A |
Public Disclosure on the soundness of Entities liquidity risk management framework and liquidity position |
All NBFC |
31st March30th June30th September31st December |
Master Direction– Scale Based Regulations |
22. |
DNBS 11 |
CICs Important Financial Parameters |
NBFC – CICs |
|
Master Direction– Reserve Bank of India (Filing of Supervisory Returns) Directions, 2024 |
23. |
DNBS 12 |
CICs Important Financial Parameters |
NBFC – CICs |
|
Master Direction– Reserve Bank of India (Filing of Supervisory Returns) Directions, 2024 |
24. |
DNBS 14 |
P2P- Important Financial &Prudential Parameters |
NBFC – P2Ps |
|
Master Direction– Reserve Bank of India (Filing of Supervisory Returns) Directions, 2024 |
25. |
Financial Soundness Indicators(FSI) |
Consolidated Financial Soundness Indicators (FSI)to International Monetary Fund(IMF) |
All NBFC and ARC (except HFC) |
|
Master Direction– Reserve Bank of India (Filing of Supervisory Returns) Directions, 2024 |
MONTHLY FILINGS/INTIMATIONS
| S. No. | Particulars | Description | Applicability | Filling Dates | Regulating Document |
| 1. | Annex XXV | Reporting of Large Exposure | NBFC – UL | By end of each month | Master Direction-Scale Based Regulation |
| 2. | Annex XIX | Information of borrowers whose secured assets is possessed | All NBFC including HFC | By end of each month | Master Direction-Scale Based Regulation, Master Direction-HFC |
| 3. | DNBS04B | Return on Structural Liquidity & Interest Rate Sensitivity | NBFC-UL,NBFC-ML except Standalone Primary Dealers ,and NBFC-BL with asset size of ₹100 crore and above solely or a Group level, excluding Type-I NBFC, and NOFHC, P2P, AA, and Mortgage Guarantee Companies | Within 15days from end of each month | Master Direction– Reserve Bank of India (Filing of Supervisory Returns) Directions, 2024 |
| 4. | DNBS08 | CRILC main return | NBFC-ULNBFC-ML (except NBFC-CIC),and NBFC-BL which are NBFC-ICC,NBFC-MFI,NBFC-Factors having asset size of ₹500crore and above solely or at Group level | Within 15days from end of each month | Master Direction– Reserve Bank of India (Filing of Supervisory Returns) Directions, 2024 |
| 5. | Annexure XVII | Information on wilful default of 25 lakh or above to credit information company | HFC | By 15th of subsequent month | Master Direction-HFC |
| 6. | Schedule –V | Capture trend in loans and advances, borrowings, asset quality, interest rate structure | HFC | Within 10days from end of month | Master Circular-Returns HFC |
| 7. | Report on Cash Transaction(CTR) | Report on Cash Transaction (CTR) to FIU India | All NBFC | By 15th of succeeding month | Master Direction -Know Your Customer (KYC)Direction, 2016 |
WEEKLY FILINGS/INTIMATIONS
| S. No. | Particulars | Description | Applicability | Filling Dates | Regulating Document |
| 1. | DNBS09-CRILC RBD | NBFCs having aggregate exposure of ₹5 crore and above to a single borrower reported in SMA-0 for the week | NBFC-UL, NBFC –ML except NBFC-CICs, and NBFC-BL which are NBFC-ICC,NBFC-MFI,NBFC-Factors having asset size of ₹500crore and above solely or at Group level | On or before Wednesday of the following week | Master Direction– Reserve Bank of India (Filing of Supervisory Returns) Directions, 2024 |
| 2. | LCR Return | Capture Liquidity Coverage of the HFC | HFC taking deposit, all non –deposit taking HFC with asset size of Rs.5000 cr. And above | Within 5days from the week ending on Friday | Master Circular-Returns HFC |
Conclusion: Adhering to NBFC compliances is crucial for maintaining regulatory compliance and avoiding penal actions by the RBI. By understanding the regulatory requirements and diligently following the prescribed timelines for filings and intimations, NBFCs can navigate the compliance landscape effectively. Stay informed, stay compliant, and ensure the smooth operation of your NBFC within the regulatory framework.
Sponsored
Kindly Refer to
Privacy Policy &
Complete Terms of Use and Disclaimer.
Author Bio
