What changed
RBI issued a master circular compiling all existing instructions on returns to be submitted by NBFCs (excluding RNBCs) as of June 30, 2012. The circular lists specific returns for deposit-taking NBFCs, NBFC-ND-SI, and other NBFCs, along with their periodicity and due dates. It also includes requirements for annual auditor certificates and FDI compliance certificates.
What it means for you
NBFCs now have a single reference document for all return submission requirements, reducing confusion from multiple circulars. Compliance teams must ensure timely submission of NBS-1, NBS-2, NBS-3, NBS-4, NBS-6 (for those with total assets of Rs 100 crore and above), and ALM returns (for those with public deposits over Rs 20 crore or asset size over Rs 100 crore) for deposit-taking NBFCs, and NBS-7A, monthly financial parameters, and ALM returns for NBFC-ND-SI. Non-deposit-taking NBFCs with assets between Rs 50 crore and less than Rs 100 crore must submit quarterly financial parameters. Failure to meet due dates could attract regulatory action.
What you must do
- Review the master circular and update your internal compliance calendar with all return due dates.
- Ensure deposit-taking NBFCs file NBS-1, NBS-2, NBS-3, NBS-4, NBS-6 (if total assets are Rs 100 crore and above), and half-yearly ALM returns (if public deposits over Rs 20 crore or asset size over Rs 100 crore) as per schedule.
- Ensure NBFC-ND-SI file NBS-7A, monthly financial parameters, and ALM returns (ALM1 monthly, ALM2/ALM3 half-yearly).
- For NBFCs with assets between Rs 50 crore and less than Rs 100 crore, submit quarterly financial parameters return.
- Submit annual auditor certificate by March end and half-yearly FDI compliance certificate if applicable.
Who it affects
All deposit-taking NBFCs (NBFCs-D), Systemically important non-deposit-taking NBFCs (NBFCs-ND-SI), Non-deposit-taking NBFCs with asset size between Rs 50 crore and Rs 100 crore, NBFCs with foreign direct investment (FDI)
What is the due date for NBS-1 return?
NBS-1 is due within 15 days from the end of each quarter, i.e., by April 15, July 15, October 15, and January 15.
Which NBFCs need to submit ALM returns?
Deposit-taking NBFCs with public deposits over Rs 20 crore or asset size over Rs 100 crore must submit half-yearly ALM returns. NBFC-ND-SI must submit ALM1 monthly, and ALM2/ALM3 half-yearly.
What is the annual certificate requirement for all NBFCs?
All NBFCs must submit an annual certificate, certified by statutory auditors, by end of March each year, confirming they are engaged in NBFI business requiring a Certificate of Registration and showing asset/income pattern for classification.