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Change in Single Master Form (SMF) on FIRMS Portal

Reserve Bank of India (‘RBI’) vide its Circular dated January 4, 2023, has streamlined the process of filing for reporting of Foreign Investment in India in Single Master Form (SMF) on FIRMS Portal.

Link: RBI/2022-23/160 A.P. (DIR SERIES) CIRCULAR NO. 22

On the introduction of the Single Master Form (SMF) on FIRMS Portal, stakeholders including Authorized Dealer Category-I banks (AD banks) will be benefited in many ways.

The object was to Rationalize the reporting system and change it to a technology-driven mechanism and simultaneously make it easy to identify and verification of information submitted by stakeholders and update the status on real-time basis.

All forms submitted with the requisite documents will be auto-acknowledged on the FIRM’s portal with a time stamp and an auto-generated e-mail will be sent to the applicant.

The detailed highlights of the process of assessment of the SMF are as follows:

  • The forms submitted within prescribed timelines will be verified by the AD Banks on the basis of the mandatory documents uploaded and ensure that it is in compliance as applicable;
  • The System will auto identify the delay in reporting, if any;
  • The Forms filed with a delay for a period not exceeding 3 years, the AD Banks will still approve or mark for resubmission in (case of defects) subject to payment of Late Submission Fee (LSF);
  • The Late Submission Fee (LSF) will be computed by the System online and e-mail will be sent to the applicant and concerned Regional Office (RO) of RBI informing the amount and the timeline for payment of the LSF;
  • On receipt of the LSF, the concerned RO will update the status on the Firms portal from his end and the status will also be e-mailed to the applicant;
  • The AD bank will also approve the forms filed with a delay for a period exceeding 3 years, subject to compounding of contravention. The applicant may thereafter approach RBI with their application for compounding.
  • The remarks of the AD Bank for rejection of forms, if any, will be updated on FIRMS portal. and will also be made available to the applicant through e-mail.

Conclusion:

The above changes will enable the stakeholders to file the form with either late submission fees up to 3 years or after compounding of contravention post 3 years.  The timeline has been specified for AD banks to verify forms submitted i.e, within five working days based on the uploaded documents which makes the process quick and efficient.

Disclaimer: This article has been carefully prepared, but it has been written in general terms and should be seen as broad guidance only. This article cannot be relied upon to cover the specific situation and you should not act, or refrain from acting, upon the information contained therein without obtaining specific professional advice. Please contact Affluence Advisory Private Limited to discuss these matters in the context of your particular circumstances. Affluence Advisory Private Limited, Its Partners, Directors, Employees, and agents do not accept or assume any liability or duty of care for any loss arising from any action taken or not taken by anyone in reliance on the information in this article or for any decision based on it.

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