What changed
RBI had previously issued ALM guidelines for non-scheduled UCBs in September 2008, promising separate instructions for return submission. This circular now specifies that until the OSS software is amended, banks must submit ALM statements in paper form. It also introduces the requirement to designate Authorized Reporting Officials (AROs) responsible for correct and timely submission.
What it means for you
Non-scheduled UCBs must continue manual reporting of ALM data quarterly, with no relief from compliance timelines. The designation of AROs signals RBI's intent to enforce accountability for data accuracy and timeliness. Banks should prepare for eventual migration to electronic OSS reporting once the software is ready.
What you must do
- Designate one or two senior officials as Authorized Reporting Officials (AROs) for ALM returns.
- Submit quarterly Statement of Structural Liquidity (and Interest Rate Sensitivity for Tier II) in paper form to the concerned RBI Regional Office within one month of quarter-end.
- Communicate names and designations of AROs to the Regional Office while forwarding returns.
- Place this circular before the Board of Directors in the next meeting.
- Acknowledge receipt of the circular to the Regional Office.
Who it affects
All non-scheduled Primary (Urban) Cooperative Banks, Tier I and Tier II non-scheduled UCBs, Senior management and compliance teams of these banks
What is the deadline for submitting ALM returns under this circular?
Returns must be submitted within one month from the end of each quarter (March, June, September, December).
Which statements are required for Tier I vs Tier II non-scheduled UCBs?
Tier II banks must submit both the Statement of Structural Liquidity and Interest Rate Sensitivity. Tier I banks need only the Statement of Structural Liquidity.
Who is responsible for the accuracy of these returns?
The designated Authorized Reporting Official(s) (AROs) are fully responsible for correct compilation and timely submission. Their names must be communicated to the RBI Regional Office.