HomeCirculars › RBI/2004-05/430

UCBs: Grandfathering of director guarantees clarified

No longer current — withdrawn, no replacement on file yet
Source: Reserve Bank of India · RBI/2004-05/430 · issued 19 Apr 2005 · ~1 min read
Quick answerRBI clarifies that UCBs need not unwind loans backed by director/relative guarantees made before October 1, 2003, but no new such guarantees are allowed after that date.

What changed

RBI issued a clarification on April 19, 2005, regarding an earlier circular from August 7, 2004, which had barred directors and their relatives from standing as sureties/guarantors for UCB loans. The clarification states that loans already sanctioned before October 1, 2003, with such guarantees can continue until maturity without being unwound. However, the ban on fresh borrowal arrangements with director/relative guarantees remains in full force.

What it means for you

UCBs can maintain existing loan portfolios with director/relative guarantees without disruption, avoiding immediate restructuring or recall. This grandfathering provision gives banks operational stability for legacy accounts. However, the strict prohibition on new guarantees from directors/relatives means UCBs must ensure all fresh lending complies with the ban, requiring robust credit appraisal and monitoring processes.

Historical instruction — do not use for current compliance. This is what was required at the time; it no longer reflects current RBI requirements. If no replacement rule is linked above, that only means none is recorded on our register yet — it does not prove no later applicable rule exists. Confirm on the official RBI source below.

What banks were required to do at the time

Who it affects

Primary (Urban) Co-operative Banks (UCBs), Directors and their relatives of UCBs, Borrowers with existing loans backed by director/relative guarantees

❓ Common questions

Regulatory timeline

Built from our lineage records — each fact carries its provenance; missing history simply is not shown (never guessed).

Can we still accept director guarantees for loans sanctioned before October 1, 2003?

Yes, such guarantees can continue until the loan matures. You do not need to unwind or replace them.

Does this clarification allow any new loans with director guarantees?

No. The ban on fresh borrowal arrangements with director/relative guarantees remains absolute. No new loans can be sanctioned with such guarantees.

📜 This document’s life story (1 recorded event, each backed by RBI’s own words)
Repealed by RBI/2025-26/100 — Consolidation of Regulations — Withdrawal of circulars (28 Nov 2025)
RBI’s words: “Official withdrawal register entry #2842: UBD(PCB).CIR.No.45/13.05.00/04-05 — "Loans and Advances to Directors etc. - Directors as Surety / Guarantors - Clarification - UCBs" dated April 19, 2005”
📜 Read the original circular — full text as issued by RBI
RBI/2004-05/430 UBD(PCB). CIR.No. 45/13.05.00/04-05 April 19, 2005 The Chief Executive Officers of All Primary (Urban) Co-operative Banks Dear Sir/Madam, Loans and advances to directors etc- directors as surety/gurantors- Clarification-UCBs Please refer to our circular UBD.PCB.CIR.10/13.05.00/04-05 dated August 7, 2004 advising UCBs that the directors and relatives cannot stand as surety/guarantor to the loans and advances (both secured and unsecured) sanctioned by the UCBs. 2.In this connection, we clarify that banks which have granted loans and advances against the guarantee/surety of the directors and/or their relatives prior to October 1, 2003 may not unwind the position and may continue with the guarantee /surety of the directors and /or their relatives till the maturity of the facility. However, as conveyed in our above circular no fresh borrowal arrangements should be allowed by UCBs with the guarantees/surety of their directors and /or their relatives. 3.Please acknowledge receipt to the concerned Regional Office of RBI. Yours faithfully, sd/- (N.S.Vishwanathan) Chief General Manager
Reproduced for reference with acknowledgment — Source: Reserve Bank of India · RBI/2004-05/430 · issued 19 Apr 2005. The plain-English explanation above is BankPulse’s own independent summary.
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Official RBI source: https://www.rbi.org.in/Scripts/NotificationUser.aspx?Id=2207&Mode=0 — Plain-English summary by BankPulse (bankpulse.ai), reviewed by our expert reviewer, CA Amit Jain. Independent platform, not affiliated with the Reserve Bank of India; is our own plain-English paraphrase, not RBI’s original wording.
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