HomeCirculars › RBI/2011-12/322

RBI Extends IPC Risk Norms for Custodian Banks

No longer current — replaced by RBI Updates IPC Rules for T+1 Settlement Cycle
Source: Reserve Bank of India · RBI/2011-12/322 · issued 27 Dec 2011 · ~2 min read
Quick answerRBI has extended the existing risk mitigation measures for Irrevocable Payment Commitments (IPCs) issued by custodian banks to stock exchanges on behalf of Mutual Funds and FIIs, until further review. The rules cover inalienable rights over securities, 50% risk reckoning, and capital treatment.

What changed

The circular confirms that the existing IPC risk mitigation measures, originally outlined in earlier circulars from September 2010, October 2010, and October 2011, will continue to be in force until further review. No new requirements or modifications have been introduced; the current framework is simply extended.

What it means for you

Banks issuing IPCs must continue to adhere to the existing conditions, including the requirement for custodian banks to have an inalienable right over securities (unless pre-funded), and the 50% risk reckoning based on assumed price movements. Capital must be maintained on the CME exposure with a 125% risk weight, and IPCs are treated as financial guarantees with a 100% CCF. This provides regulatory stability but no relief from existing compliance burdens.

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

All Scheduled Commercial Banks (excluding RRBs) acting as custodian banks, Mutual Funds and Foreign Institutional Investors (FIIs) using IPC facilities, Stock exchanges receiving IPCs from custodian banks

❓ Common questions

Regulatory timeline

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

What is the key condition for issuing an IPC without an inalienable right clause?

If the transaction is pre-funded, meaning clear INR funds are in the customer's account or, for FX deals, the bank's nostro account is credited before IPC issuance, the inalienable right clause is not required.

How is the Capital Market Exposure (CME) calculated on T+1?

CME is 50% of the settlement amount at end-of-day on T+1, assuming a 20% price drop on each of T+1 and T+2 plus a 10% buffer. If margin is paid in cash, CME is reduced by the margin amount; if paid in securities, CME is reduced by margin minus the exchange-prescribed haircut.

Does this circular introduce any new requirements?

No, it only extends the existing risk mitigation measures from previous circulars until further review. All previous conditions remain unchanged.

📜 This document’s life story (2 recorded events, each backed by RBI’s own words)
Superseded by RBI Updates IPC Rules for T+1 Settlement Cycle
RBI’s words: “Please refer to circular DBOD.Dir.BC.68/13.03.00/2011-12 dated December 27, 2011”
Repealed by RBI/2025-26/100 — Consolidation of Regulations — Withdrawal of circulars (28 Nov 2025)
RBI’s words: “Official withdrawal register entry #1387: DBOD.Dir.BC.68/13.03.00/2011-12 — "Banks' Exposure to Capital Market - Issue of Irrevocable Payment Commitments (IPCs)" dated December 27, 2011”
📜 Read the original circular — full text as issued by RBI
RBI/2011-12/322 DBOD.Dir.BC. 68 /13.03.00/2011-12 December 27, 2011 All Scheduled Commercial Banks (excluding RRBs) Dear Sir / Madam Banks' Exposure to Capital Market - Issue of Irrevocable Payment Commitments (IPCs) Please refer to our circulars No.DBOD.Dir.BC.46/13.03.00/2010-11 dated September 30, 2010, DBOD.Dir.BC.52/13.03.00/2010-11dated October 28, 2010  and DBOD.Dir.BC.43/13.03.00/2011-12 dated October 31, 2011 wherein banks issuing Irrevocable Payment Commitments (IPCs) to various Stock Exchanges on behalf of Mutual Funds and FIIs had been advised to adopt the following risk mitigation measures: Only those custodian banks, who have a clause in the Agreement with their clients which gives them an inalienable right over the securities to be received as pay out in any settlement, would be permitted to issue IPCs. However, in cases where transactions are pre-funded i.e. there are clear INR funds in the customer’s account and, in case of FX deals, the bank’s nostro account has been credited before the issuance of the IPC by custodian banks, the requirement of the clause of inalienable right over the security to be received as pay out in the agreement with the clients will not be insisted upon. The maximum risk to the custodian banks issuing IPCs would be reckoned at 50%, on the assumption of downward price movement of the equities bought by FIIs/ Mutual Funds on the two successive days from the trade date (T) i.e., on T+1 and T+2, of 20% each with an additional margin of 10% for further downward movement. Accordingly the potential risk on T+1 would be reckoned at 50% of the settlement amount and this amount would be reckoned as CME at the end of T+1 if margin payment / early pay in does not come in. In case there is early pay in on T+1, there will be no Capital Market exposure. By T+1, we mean ‘end of day’ (EOD) as per Indian Time.  Thus, funds received after EOD as per Indian Time, will not be reckoned as early pay-in on T+1. CME will have to be computed accordingly. In case margin is paid in cash on T+1, the CME would be reckoned at 50% of settlement price minus the margin paid. In case margin is paid on T+1 by way of permitted securities to FIIs / Mutual Funds, the CME would be reckoned at 50% of settlement price minus the margin paid plus haircut prescribed by the Exchange on the securities tendered towards margin payment. The IPC will be treated as a financial guarantee with a Credit Conversion Factor (CCF) of 100.    However, capital will have to be maintained only on exposure which is reckoned as CME and the risk weight would be 125% thereon. 2.  It has now been decided that the above mentioned arrangements will continue to be in force until further review. Yours faithfully, (P. R. Ravi Mohan) Chief General Manager
Reproduced for reference with acknowledgment — Source: Reserve Bank of India · RBI/2011-12/322 · issued 27 Dec 2011. 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=6903&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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