What changed
Earlier, only Company Secretaries could certify compliance for borrowers with multiple bank credit facilities. Now, Chartered Accountants and Cost Accountants are also acceptable certifiers. The prescribed format (Annex III – Part I & II) has been updated based on IBA feedback.
What it means for you
UCBs get more flexibility in sourcing compliance certifications, reducing dependence on a single professional category. This can speed up credit processing and lower costs for borrowers. The revised format ensures standardized, comprehensive reporting on statutory compliance, shareholding, and related-party transactions.
What you must do
- Update internal lending policies to accept certifications from Company Secretaries, Chartered Accountants, and Cost Accountants.
- Replace old Annex III format with the modified version enclosed in this circular for all consortium/multiple banking borrowers.
- Train credit and compliance teams on the new certification requirements and the updated diligence report format.
- Ensure borrowers submit the diligence report at intervals as prescribed in the earlier circular dated January 21, 2009 (e.g., half-yearly as per the report template).
Who it affects
All Primary Urban Co-operative Banks (UCBs), Borrowers availing credit under consortium or multiple banking arrangements, Chartered Accountants, Cost Accountants, and Company Secretaries providing certification services
Can we still accept certifications from Company Secretaries?
Yes, Company Secretaries remain eligible. The circular adds Chartered Accountants and Cost Accountants as additional acceptable certifiers.
Do we need to use the new Annex III format immediately?
Yes, the revised format (Part I & II) is enclosed with this circular and must replace the earlier version for all new and ongoing certifications.
Does this apply to all borrowers or only those under consortium arrangements?
This applies to borrowers enjoying credit facilities from multiple banks, including consortium and multiple banking arrangements, as specified in the earlier circular dated January 21, 2009.