What changed
RBI reviewed and expanded the checklist of documents required for NBFC registration applications to make it more exhaustive. Five distinct checklists have been uploaded on the RBI website, tailored to different NBFC types: general NBFCs, NBFC-MFIs (new and existing), NBFC-Factors, and CIC-ND-SIs. For conversions from an existing NBFC to NBFC-MFI or NBFC-Factor, the applicant need not fill the online form; a company letterhead application with the original COR and checklist documents suffices until the COSMOS system is updated.
What it means for you
NBFCs must now submit a more detailed set of documents upfront, which should reduce back-and-forth and speed up registration. The separate checklists mean each entity type must carefully follow its specific list. Conversion applicants get a simpler process for now, but must respond to any additional document requests within one month or risk having their application returned.
What you must do
- Download the correct checklist from RBI website for your NBFC type before preparing the registration application.
- Ensure all documents listed in the applicable checklist are included; the list is indicative, so be prepared for additional requests.
- For conversion to NBFC-MFI or NBFC-Factor, submit a letter on company letterhead with original COR and all checklist documents, not the full online form.
- Respond to any RBI request for further documents within one month to avoid application being returned.
Who it affects
All NBFCs (excluding RNBCs), NBFC-Micro Finance Institutions (NBFC-MFIs), NBFC-Factoring Institutions (NBFC-Factors), Core Investment Companies (CICs)
Do I need to fill the online application form if I am converting my existing NBFC to an NBFC-MFI?
No, for now you can apply on company letterhead with the original Certificate of Registration and all documents from the relevant checklist. This arrangement will continue until the COSMOS online application is updated.
What happens if RBI asks for additional documents beyond the checklist?
You must respond within one month. If you fail to do so, your application and all submitted documents will be returned, and you will need to submit a fresh application.
Are the checklists exhaustive?
No, they are indicative. RBI may call for any further documents it deems necessary to verify eligibility for registration.