What changed
RBI issued a master circular compiling all miscellaneous directions/instructions for NBFCs issued up to June 30, 2012 that were not covered in other master circulars. The circular provides a single reference document for NBFCs to ensure all current instructions are in one place.
What it means for you
NBFCs now have a consolidated source for miscellaneous regulatory instructions, reducing the need to track multiple circulars. Key requirements include ALM systems for NBFCs with asset base of Rs 100 crore or more (as per audited balance sheet as of March 31, 2001) or public deposits of Rs 20 crore or more, minimum net owned fund of Rs 200 lakh for deposit-taking NBFCs (as per topic 13), and half-yearly ALM return submission within one month of half-year end for deposit-taking NBFCs.
What you must do
- Review the consolidated list of 26 miscellaneous instructions and ensure compliance with each applicable item.
- Implement or update Asset Liability Management (ALM) system if your NBFC has asset base of Rs 100 crore or more (as per audited balance sheet as of March 31, 2001), or holds public deposits of Rs 20 crore or more.
- Submit half-yearly ALM returns to RBI within one month of the close of each half-year if you are a deposit-taking NBFC.
- Ensure deposit-taking NBFCs maintain minimum net owned fund of Rs 200 lakh as per the circular (topic 13).
- Update internal policies to reflect all consolidated instructions, including nomination rules, prudential norms, and reporting requirements.
Who it affects
All Non-Banking Financial Companies (NBFCs), Deposit-taking NBFCs, Non-deposit taking NBFCs with asset size between Rs 50 crore and Rs 100 crore, NBFCs engaged in equipment leasing, hire purchase finance, loan, investment, and residuary non-banking companies
Which NBFCs are required to implement the ALM system as per this circular?
NBFCs engaged in equipment leasing, hire purchase finance, loan, investment, and residuary non-banking companies with an asset base of Rs 100 crore or more (whether accepting public deposits or not) or holding public deposits of Rs 20 crore or more (irrespective of asset size) as per audited balance sheet as of March 31, 2001 must implement the ALM system.
What is the deadline for submitting the half-yearly ALM return?
The first ALM return as on September 30, 2002 was to be submitted to RBI within one month of the close of the relevant half-year. This half-yearly reporting cycle continues for deposit-taking NBFCs.
Does this circular apply to non-deposit taking NBFCs?
Yes, the ALM guidelines apply to all NBFCs irrespective of whether they accept or hold public deposits. However, the half-yearly reporting requirement initially applies only to NBFCs holding public deposits.