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RBI Directions on Filings of Supervisory Returns

The Reserve Bank of India has issued Master Directions on the ‘Filing of Supervisory Returns’ by all Supervised Entities on February 27, 2024. In this article, we will focus on the changes applicable to NBFCs. It has provided a summary of changes to the existing circulars / Directions introduced, a list of circulars/notifications repealed with the issuance of these Directions w.r.t supervised entities, a list of applicable returns to be filed, alternate timelines for submission of select Returns, details of online portals for submission of returns by Supervised Entities.

Let’s start by familiarizing ourselves with several terms that are used frequently in the Master direction.

Supervised Entities:

Entities which are being governed under this Master direction are referred to as Supervised Entities.

  1. Commercial Banks* – Public Sector Banks (PSBs), Private Sector Banks (PVBs), Small Finance Banks (SFBs), Payment Banks (PBs), Local Area Banks (LABs) and Foreign Banks (FBs).
  2. Primary (Urban) Co-operative Banks.
  3. All India Financial Institutions (Exim Bank, NABARD, NHB, SIDBI and NABFID).
  4. Non-Banking Financial Companies engaged in the business of financial institutions as contained in clause (f) of Section 45 I of the RBI Act, 1934*

*Note: Regional Rural Banks, Housing Finance Companies (HFCs)], and all Asset Reconstruction Companies (ARCs) are excluded from the ambit of this circular.

Supervisory Returns refer to all periodic/ad-hoc data submitted to RBI in formats prescribed from time to time.           

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., Centralized Information Management System of the RBI for return submission, data dissemination and other related purposes. The Circular has provided timelines for submission of returns w.r.t each of the supervised entities specifically under Annexure III.

We will focus on submission of returns by NBFCs under this Article.

This circular repeals Master Direction- Non-Banking Financial Company Returns (Reserve Bank) Directions, 2016 dated September 29, 2016.

As per RBI’s notification DoR.FIN.REC.No.45/03.10.119/2023-24 dated October 19, 2023 (Master Direction – Reserve Bank of India (Non-Banking Financial Company – Scale Based Regulation) Directions, 2023), the Regulatory structure for NBFCs shall comprise of four layers. Accordingly, the schedule of returns for NBFCs has been revised to reflect the applicability of these four layers and the revised framework. The revised applicability is as follows:

Return Name

Periodicity

Reference Date

Timeline for submission

DNBS10 Statutory Auditor’s Certificate (SAC) Return

The certificate shall be based on audited books of accounts of the applicable entity, for the preceding financial year.

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 December 31st of same year, in any case]. 

All NBFCs

 

Form A Certificate

The certificate to be submitted by NBFCs regarding appointment of Statutory Central Auditor (SCA)/ Statutory Auditor (SA) in prescribed format as mentioned in the RBI’s notification on ‘Appointment of Statutory Central Auditors (SCAs)/Statutory Auditors (SAs) of Commercial Banks (excluding RRBs), UCBs and NBFCs (including HFCs)’

Yearly

31st March [Within one month from the date of appointment of Statutory Central Auditor (SCA) / Statutory Auditor (SA)].

All NBFCs

 

Also Read UNIFORM NBFC REGULATIONS FOR ALL SCALE-BASED REGULATIONS (SBR)

Return Name

Periodicity

Reference Date

Applicability

DNBS01

The return contains components of assets and liabilities, profit and loss account, exposure to sensitive sectors, sectoral credit, etc. 

Quarterly 

31st March/ 

30th June/ 

30th September/ 

31st December 

NBFC – Upper Layer (NBFC-UL), 

NBFC – Middle Layer (NBFC-ML) [except NBFC-Core Investment Companies (CICs)] 

DNBS02 

The return contains financial details, viz. components of assets and liabilities, profit, and loss account etc. as well as for complying with various prudential norms.

Quarterly 

31st March/ 

30th June/ 

30th September/ 

31st December 

NBFCs in Base Layer [except Peer-to-Peer Lending platform Companies (NBFC – P2Ps)] 

DNBS03 

The return contains prudential norms, e.g., capital adequacy, provisioning etc.

Quarterly 

31st March/ 

30th June/ 

30th September/ 

31st December 

NBFC-UL, 

NBFC -ML [except NBFC-CICs]  

DNBS04A

Return on Short Term Dynamic Liquidity

Quarterly 

31st March/ 

30th June/ 

30th September/ 

31st December 

NBFC-UL, 

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 Non-Operative Financial Holding Companies (NOFHCs), P2Ps, AAs, and Mortgage Guarantee Companies] 

DNBS04B

Return on Structural Liquidity and Interest Rate Sensitivity.

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 

NBFC-UL, 

 

NBFC-ML [except Standalone Primary Dealers (SPDs)], and 

 

NBFC-BL with asset size of ₹100 crore and above solely or at Group level, [excluding Type-I NBFCs, and Non-Operative Financial Holding Companies (NOFHCs), P2Ps, AAs, and Mortgage Guarantee Companies]

DNBS08 CRILC-Main (NBFCs) 

The return contains certain credit information in respect of borrowers who are having aggregate exposure of ₹5 Crore and above with NBFCs

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 

NBFC-UL, 

NBFC -ML (except NBFC-CICs), and 

NBFC-BL which are NBFC-ICC, NBFC-MFI, NBFC-Factors having asset size of ₹500 crore and above solely or at Group level 

DNBS09-CRILC Weekly – RDB return.

NBFCs may report certain information on large borrowers (having aggregate exposure of ₹5 crores and above with them), in case they do not have large borrower with default move-in/ move-out positions, it shall submit a ‘NIL’ return.

Weekly

Friday of the Week 

NBFC-UL, 

NBFC -ML (except NBFC-CICs), and 

NBFC-BL which are NBFC-ICC, NBFC-MFI, NBFC-Factors having asset size of ₹500 crore and above solely or at Group level 

DNBS11-CIC’s 

Quarterly 

31st March/ 

30th June/ 

30th September/ 

31st December 

NBFC-CICs 

DNBS12-CICs – Important Prudential Parameters

Quarterly 

31st March/ 

30th June/ 

30th September/ 

31st December

NBFC-CICs 

DNBS13 – Overseas Investment Details 

Quarterly 

31st March/ 

30th June/ 

30th September/ 

31st December

All NBFCs 

DNBS14- P2Ps– Important Financial & Prudential Parameters 

Quarterly 

31st March/ 

30th June/ 

30th September/ 

31st December

NBFCs- Peer-to-Peer Lending platform Companies (NBFCs-P2P) 

FMR – I (Report on Actual or Suspected Frauds) 

On occurrence of such event

As and when the fraud is detected. 

(Within three weeks from the Reference Date.)

NBFC-UL, 

NBFC -ML, and 

NBFC-BL which are NBFC-ICC, NBFC-MFI, NBFC-Factors having asset size of ₹500 crore and above 

FMR – III (Update of Form FMR-I) 

This return captures progress report on frauds of large value and it is to be filed as and when any development occurs in FMR-I details.

On occurrence of such event

As and when any development occurs in FMR-1 details.

(Immediate).

NBFC-UL, 

NBFC -ML, and 

NBFC-BL which are NBFC-ICC, NBFC-MFI, NBFC-Factors having asset size of ₹500 crore and above

FMR – IV (Report on Dacoities / Robberies / Theft / Burglaries) 

This return captures consolidated information on dacoities/robberies/theft/ burglaries.

Quarterly 

31st March/ 

30th June/ 

30th September/ 

31st December 

(Within 15 days from the Reference Date).

NBFC-UL, 

NBFC -ML, and 

NBFC-BL which are NBFC-ICC, NBFC-MFI, NBFC-Factors having asset size of ₹500 crore and above 

RBI has introduced various online portals for filing of all the applicable online returns by the SEs. Each SE is provided with a Super User Credential with defined access rights who, in turn, can create other users (with different roles such as Maker and Checker) for their entity with required access rights. Entities can monitor the status of their returns’ submission on the portal. Form A Certificate is to be submitted by NBFC’s in physical form.

Disclaimer: This article provides general information existing at the time of preparation and we take no responsibility to update it with the subsequent changes in the law. The article is intended as a news update and Affluence Advisory neither assumes nor accepts any responsibility for any loss arising to any person acting or refraining from acting as a result of any material contained in this article. It is recommended that professional advice be taken based on specific facts and circumstances. This article does not substitute the need to refer to the original pronouncement

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