Current · Source: Reserve Bank of India · RBI/2011-12/332 · issued 30 Dec 2011 · ~2 min read
Quick answerRBI has flagged that some NBFCs are violating the 2010 NCD Directions by privately placing NCDs with maturity under 90 days. All NBFCs must ensure NCDs with original maturity up to one year strictly comply with those Directions.
The rule, in the simplest words
NBFCs cannot issue NCDs that mature in less than 90 days through private placement; this breaks the 2010 rules. (NCDs are a type of loan that the NBFC gives to investors, like a promise to pay back money with interest.)
Any NCD that has a first maturity (original) of up to one year must follow the 2010 NCD Directions. (Original maturity is the first time the loan is due.)
NBFCs must check all their current NCDs that are due within a year to make sure they follow those rules. (Compliance means making sure all paperwork and rules are followed.)
They must stop issuing new NCDs that mature in less than 90 days unless the RBI specifically allows it. (Private placement means selling to a few chosen investors.)
The treasury, legal, and compliance teams need to update their checklists and get training on the 2010 NCD rules. (A checklist is a list of things to check before doing something.)
How it plays out — a real example
A treasury officer named Rahul at City NBFC is preparing a new NCD issue. He reads the RBI notice and realizes the proposed 60‑day NCD would violate the 2010 Directions. Rahul cancels the plan, reviews the existing 8‑month NCDs, and schedules a training session for his team to ensure all future issuances meet the RBI guidelines.
What changed
RBI observed that certain NBFCs raised funds via private placement of NCDs with maturity less than 90 days, which contravenes the Issuance of Non-Convertible Debentures (Reserve Bank) Directions, 2010. The central bank has now explicitly reminded all NBFCs that NCDs with original maturity up to one year fall under that 2010 framework and must be issued in full compliance.
What it means for you
NBFCs can no longer use sub-90-day NCDs as a loophole to bypass the 2010 Directions. Lenders relying on such short-term instruments for liquidity management will need to restructure their funding mix. This reinforces RBI's intent to bring all short-term NCD issuance under a uniform regulatory umbrella, potentially increasing compliance costs for smaller NBFCs.
What you must do
Review all outstanding NCDs with original maturity under one year to ensure they comply with the 2010 Directions.
Immediately stop issuing NCDs with maturity less than 90 days via private placement unless explicitly permitted.
Update internal compliance checklists to flag any NCD issuance with maturity up to one year for pre-approval under the 2010 framework.
Train treasury and legal teams on the specific requirements of the 2010 NCD Directions.
Who it affects
All NBFCs including RNBCs, Treasury departments of NBFCs, Compliance officers at NBFCs, Debt capital market teams arranging NCD private placements
❓ Common questions
Does this circular ban all NCDs with maturity below 90 days?
The circular does not impose a blanket ban but states that issuing NCDs with maturity less than 90 days via private placement violates the 2010 Directions. NBFCs must follow those Directions for any NCD with original maturity up to one year.
What are the 2010 NCD Directions that NBFCs must follow?
The circular refers to the Issuance of Non-Convertible Debentures (Reserve Bank) Directions, 2010 dated June 23, 2010, issued by RBI's Internal Debt Management Department. NBFCs should refer to that document for detailed compliance requirements.
Are RNBCs also covered by this circular?
Yes, the circular is addressed to all NBFCs including RNBCs (Residuary Non-Banking Companies), so the same compliance expectations apply to them.
📜 Read the original circular — full text as issued by RBI
RBI/2011-12/332
DNBS.CC.PD.No.255/03.10.01/2011-12
December 30, 2011
To
All NBFCs (Including RNBCs)
Dear Sir,
Issuance of Non-Convertible Debentures (NCDs)
It has come to the notice of the Reserve Bank that some NBFCs have raised funds under private placement by issuing NCDs of maturity less than 90 days. This is in clear violation of Issuance of Non-Convertible Debentures (Reserve Bank) Directions, 2010 dated June 23, 2010 issued by Internal Debt Management Department, Reserve Bank of India.
2. All NBFCs may note that the issue of NCDs of original or initial maturity up to one year are governed under the above mentioned Directions and these Directions may be followed for meticulous compliance.
Yours faithfully
(C.R. Samyuktha)
Chief General Manager
Reproduced for reference with acknowledgment — Source: Reserve Bank of India · RBI/2011-12/332 · issued 30 Dec 2011. The plain-English explanation above is BankPulse’s own independent summary.
Example: if you are a Compliance officer at a bank this circular applies to (All NBFCs including RNBCs, Treasury departments of NBFCs, Compliance officers at NBFCs, Debt capital market teams arranging NCD private placements), your first concrete step on “RBI Cracks Down on NBFCs Issuing Ultra-Short NCDs” is: “Review all outstanding NCDs with original maturity under one year to ensure they comply with the 2010 Directions.” (RBI issued this 30 Dec 2011).
Circular: RBI/2011-12/332 -- RBI Cracks Down on NBFCs Issuing Ultra-Short NCDs
Issued: 30 Dec 2011
Action required: Review all outstanding NCDs with original maturity under one year to ensure they comply with the 2010 Directions.
Action required: Immediately stop issuing NCDs with maturity less than 90 days via private placement unless explicitly permitted.
Action required: Update internal compliance checklists to flag any NCD issuance with maturity up to one year for pre-approval under the 2010 framework.
Action required: Train treasury and legal teams on the specific requirements of the 2010 NCD Directions.
Owner: ____________ Target date: ____________
Board/committee approval needed? Y / N
Evidence filed in compliance register on: ____________
Built only from this circular’s own published fields — not legal advice; always confirm against the official RBI source.
💬 Banker Discussion
Discuss this circular with fellow bankers — reply, upvote what helps, report what doesn’t belong. Be professional; no client data. Views are the commenter’s own, not BankPulse’s.
BankPulse Compliance Evidence Pack — generated 03 Aug 2026 · status cross-checked against RBI’s official withdrawal register (refreshed weekly). Official RBI source: https://www.rbi.org.in/Scripts/NotificationUser.aspx?Id=6913&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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