INTRODUCTION
The Reserve Bank of India (RBI) has issued Master Direction on “Filing of Supervisory Returns” for Supervised Entities on 27th February, 2024 to strengthen the regulatory framework for Non-Banking Financial Companies (“NBFCs’). This direction has created a single reference for all Supervisory Returns and to harmonize the timelines for filing of returns Reserve Bank of India (“RBI”) have rationalized and consolidated all relevant instructions into Single Master Direction. This article provides an overview of the applicable returns to be filed by the NBFCs, Timelines for submission of the Returns, etc.
- APPLICABLITY OF THIS MASTER DIRECTION
These Directions shall Apply to the following entities as per paragraph 2.1 of the Master Direction:
-
- All Commercial Banks excluding Regional Rural Banks. Commercial Banks include Public Sector Banks (PSBs), Private Sector Banks (PVBs), Small Finance Banks (SFBs), Payment Banks (PBs), Local Area Banks (LABs) and Foreign Banks (FBs).
- All Primary (Urban) Co-operative Banks.
- Select All India Financial Institutions (Exim Bank, NABARD, NHB, SIDBI and NABFID).
- All Non-Banking Financial Companies [excluding Housing Finance Companies (HFCs)] and all Asset Reconstruction Companies (ARCs).
**Regional Rural Banks, Housing Finance Companies (HFCs), and all Asset Reconstruction Companies (ARCs) are excluded from the purview of this circular.
- DEFINITIONS
- Supervisory Returns refer to all periodic / ad-hoc data submitted to RBI in formats prescribed from time to time, irrespective of the technology platform, periodicity and the mode of submission.
- CRILC refers to a database, i.e., Central Repository of Information on Large Credits (CRILC) as specified in the framework ‘Early Recognition of Financial Distress, Prompt Steps for Resolution and Fair Recovery for Lenders.
- CIMS refers to an online platform, i.e., Centralised Information Management System of the RBI for return submission, data dissemination and other related purposes.
- TIMELINE FOR SUBMISSION OF RETURNS
| RETURN NAME | APPLICABLITY | PERIODICITY | REFRENCE DATE | DUE DATE |
| DNBS01-Important Financial Parameters | i. NBFC – Upper Layer (NBFCUL),
ii. NBFC – Middle Layer (NBFC-ML) [except NBFC Core Investment Companies (CICs)] |
Quarterly
|
31st March
30th June 30th September 31st December |
|
| DNBS02 – Important Financial Parameters (NBFCs – BL)[1] | NBFCs in Base Layer [except Peer-to-Peer Lending platform Companies (NBFC – P2Ps)] | Quarterly | 31st March
30th June 30th September 31st December |
|
| DNBS03- Important Prudential Parameters | i. NBFC-UL,
ii. NBFC -ML [except NBFCCICs] |
Quarterly | 31st March
30th June 30th September 31st December |
|
| DNBS04A- Short Term Dynamic Liquidity (STDL) – Quarterly | i. NBFC-UL,
ii. NBFC-ML [except Standalone Primary Dealers (SPDs)], and iii. NBFC-BL with asset size of ₹100 crore and above solely or at Group level, [excluding Type-I NBFCs, and NonOperative Financial Holding Companies (NOFHCs), P2Ps, AAs, and Mortgage Guarantee Companies] |
Quarterly | 31st March
30th June 30th September 31st December |
|
| DNBS04B-Structural Liquidity & Interest Rate Sensitivity – Monthly | i. NBFC-UL,
ii. NBFC-ML [except Standalone Primary Dealers (SPDs)], and iii. NBFC-BL with asset size of ₹100 crore and above solely or at Group level, [excluding Type-I NBFCs, and NonOperative Financial Holding Companies (NOFHCs), P2Ps, AAs, and Mortgage Guarantee Companies] |
Monthly | 31st March
30th April 31st May 30th June 31st July 31st August 30th September 31st October 30th November 31st December 31st January 28th or 29th February as applicable |
Within 15 days of the subsequent month |
| DNBS07 – ARCs Important Financial Parameters | Asset Reconstruction Company | Quarterly | 31st March
30th June 30th September 31st December |
|
| DNBS08 – CRILC-Main (NBFCs) | i. NBFC-UL,
ii. NBFC -ML (except NBFCCICs), and iii. NBFC-BL which are NBFCICC, NBFC-MFI, NBFC-Factors having asset size of ₹500 crore and above solely or at Group level |
Monthly | 31st March
30th April 31st May 30th June 31st July 31st August 30th September 31st October 30th November 31st December 31st January 28th or 29th February as applicable |
Within 15 days of the subsequent month |
| DNBS09-CRILC Weekly – RDB return | i. NBFC-UL,
ii. NBFC -ML (except NBFCCICs), and iii. NBFC-BL which are NBFCICC, NBFC-MFI, NBFC-Factors having asset size of ₹500 crore and above solely or at Group level |
Weekly | Friday of the Week | |
| DNBS10-Statutory Auditor Certificate (SAC) Return | All NBFCs and ARCs | Yearly | 31st March | Within 5 working days from the date of signing of the Auditor’s report in terms of Section 134 of the Companies Act, 2013, but not later than 31st December of the same year in any case. |
| DNBS11-CICs – Important Financial Parameters | NBFC-CICs | Quarterly | 31st March
30th June 30th September 31st December |
|
| DNBS12-CICs – Important Prudential Parameters | NBFC-CICs | Quarterly | 31st March
30th June 30th September 31st December |
|
| DNBS13 – Overseas Investment Details | All NBFCs | Quarterly | 31st March
30th June 30th September 31st December |
|
| DNBS14- P2Ps- Important Financial & Prudential Parameters | NBFCs- Peer-to APeer Lending platform Companies (NBFCs-P2P) | Quarterly | 31st March
30th June 30th September 31st December |
|
| Form A Certificate | All NBFCs | Yearly | 31st MArch | Within one month from the date of appointment of Statutory Auditor (SA). |
CONCLUSION
RBI has simplified the return filings for NBFCs. The RBI’s Master Direction has brought clarity and consistency to the return filings. Timely submission of these returns along with the accurateness is very essential to ensure regulatory compliances. A proactive approach, including maintenance of compliance calendar and staying updated with RBI guidelines will help the NBFCs to meet these obligations efficiently.
Note:
[1] The DNBS-02 return for the quarter ending March must be filed in two stages. The Unaudited DNBS-02 is required to be filed within 21 days from the end of quarter, while the audited one is required to be filed within 5 working days from the date of completion of audit process.
Author Bio
