HomeCirculars › RBI/2013-14/541

Exposure Norms for Standalone Primary Dealers

Current · Source: Reserve Bank of India · RBI/2013-14/541 · issued 27 Mar 2014 · ~2 min read
Quick answerRBI exempts standalone PDs' clearing exposure to Qualifying CCPs from the 25% single-counterparty limit, effective April 1, 2014, to promote central clearing of OTC derivatives.
The rule, in the simplest words
How it plays out — a real example

Ravi, a risk manager at a standalone PD in Mumbai, is checking the firm's exposure to CCIL (a Qualifying CCP). He sees that the clearing exposure—money tied up in trades and the default fund—is ₹50 crore. Because of the new RBI rule, he can exclude this ₹50 crore from the 25% single-counterparty limit, freeing up room for other business. He still keeps an eye on the PD's investment in CCIL's capital, which stays within the limit.

What changed

RBI has allowed standalone PDs to exclude clearing exposure to a Qualifying CCP (QCCP) from the 25% of net owned funds single-borrower limit. This interim measure aims to encourage central clearing of standardized OTC derivatives. Other exposures to QCCPs, like capital investments, remain within the existing ceiling.

What it means for you

For standalone PDs, this reduces capital constraints when clearing through recognized CCPs like CCIL, NSCCL, ICCL, or MCX-SXCCL. It incentivizes use of central counterparties for OTC derivatives, aligning with global standards. PDs must still monitor total credit risk, including non-QCCP exposures, within prudential limits.

What you must do

Who it affects

Standalone Primary Dealers (PDs), Clearing Corporation of India Ltd. (CCIL), National Securities Clearing Corporation Ltd. (NSCCL), Indian Clearing Corporation Ltd. (ICCL), MCX-SX Clearing Corporation Ltd. (MCX-SXCCL)

❓ 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 new exposure limit for QCCP clearing exposure?

Clearing exposure to a Qualifying CCP (QCCP) is exempted from the 25% of net owned funds single-counterparty limit, effective April 1, 2014.

Which CCPs are currently recognized as QCCPs?

CCIL is recognized by RBI, while NSCCL, ICCL, and MCX-SXCCL are recognized by SEBI as QCCPs, subject to ongoing compliance with CPSS-IOSCO principles.

What happens if a CCP loses its QCCP status?

If a regulator withdraws QCCP status, the CCP becomes a non-QCCP, and all exposures to it must fall within the 25% single-counterparty limit.

📜 Read the original circular — full text as issued by RBI
RBI/2013-14/541 IDMD.PCD.12/14.03.05/2013-14 March 27, 2014 All Standalone Primary Dealers (PDs) Dear Sir / Madam Exposure norms for standalone PDs Please refer to the circular IDMD.PDRD.N0 19/03.64.00/2010-11 dated July 27, 2010 updated vide circulars IDMD.PCD.No.1652/14.03.05/2010-11 dated November 11, 2010 and IDMD.PCD.No.718/14.03.05/2012-13 dated September 3, 2012 . 2. With a view to promote central clearing of standardised OTC derivative products through a Central Counter Party (CCP), it has been decided that as an interim measure, a standalone PD’s clearing exposure to a Qualifying CCP (QCCP) will be kept outside of the exposure ceiling of 25 per cent of its net owned funds applicable to a single borrower/counterparty. 3. Reserve Bank would consider revised framework on PDs’ exposure to QCCP depending on international consensus in this regard. 4. Revised guidelines on exposure norms for standalone PDs are detailed in Annex . The present guidelines shall supercede all existing instructions issued to standalone PDs in this regard. 5. The revised guidelines shall be effective from April 1, 2014. Yours faithfully (K.K Vohra) Pr. Chief General Manager Encl: As above Annex Exposure norms for standalone PDs The exposure ceiling limits would be 25 percent of latest audited Net Owned Funds (NOF) in case of a single borrower/counterparty and 40 percent of NOF in case of a group borrower. The ceilings on single /group exposure limit would not be applicable where principal and interest are fully guaranteed by the Government of India. PDs should include credit risk exposures to all other categories of non-Government securities including investments in mutual funds, commercial papers, certificate of deposits, positions in OTC derivatives not settled through Qualifying CCP (QCCP) etc. to compute extent of credit exposure to adhere to the prescribed prudential limits. Clearing exposure to a QCCP will be kept outside of the exposure ceiling of 25 per cent of its NOF applicable to a single counter party. Clearing exposure to QCCP would include trade exposure and default fund exposure as defined in the guidelines on capital requirements for PDs’ exposure to central counterparties issued vide Circular IDMD.PCD.11/14.03.05/2013-14 dated March 27, 2014. Other permissible exposures to QCCPs such as investments in the capital of CCP etc. will continue to be within the existing exposure ceiling of 25 per cent of NOF to a single borrower/counterparty. However, all exposures of a PD to a non-QCCP should be within the exposure ceiling of 25 per cent. Presently, there are four CCPs viz. Clearing Corporation of India Ltd. (CCIL), National Securities Clearing Corporation Ltd. (NSCCL), Indian Clearing Corporation Ltd. (ICCL), and MCX-SX Clearing Corporation Ltd. (MCX-SXCCL) that are subjected, on an ongoing basis, to rules and regulations that are consistent with CPSS-IOSCO Principles for Financial Market Infrastructures. While the CCIL has been granted the status of a QCCP by the Reserve Bank, the other three CCPs have been granted the status of QCCP by SEBI. It may also be mentioned that the status of a CCP as a QCCP may change in future, if a regulator/supervisor of the CCP withdraws the status of QCCP. After withdrawal of the status of a QCCP, the CCP will be considered a non-QCCP and exposure norms as applicable to non-QCCPs would be applicable.
Reproduced for reference with acknowledgment — Source: Reserve Bank of India · RBI/2013-14/541 · issued 27 Mar 2014. The plain-English explanation above is BankPulse’s own independent summary.
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Who does what — compliance checklist
🏦 Branch Manager
  • Update internal exposure tracking systems to separate QCCP clearing exposure from the 25% single-counterparty limit.
⚙️ Operations
  • Review and revise credit risk policies to reflect the exemption for QCCP clearing exposure while keeping other exposures within limits.
💻 IT / Systems
  • Ensure all QCCP exposures (trade and default fund) are documented as per the March 27, 2014 capital requirements circular.
📜 Compliance
  • Monitor the QCCP status of CCPs regularly, as withdrawal of status would revert exposure to non-QCCP norms.
Grouped from the action items above — a single circular may involve more than one team.
Worked example & action-note template

Example: if you are a Branch Manager at a bank this circular applies to (Standalone Primary Dealers (PDs), Clearing Corporation of India Ltd. (CCIL), National Securities Clearing Corporation Ltd. (NSCCL), Indian Clearing Corporation Ltd. (ICCL), MCX-SX Clearing Corporation Ltd. (MCX-SXCCL)), your first concrete step on “Exposure Norms for Standalone Primary Dealers” is: “Update internal exposure tracking systems to separate QCCP clearing exposure from the 25% single-counterparty limit.” (RBI issued this 27 Mar 2014).

  1. Circular: RBI/2013-14/541 -- Exposure Norms for Standalone Primary Dealers
  2. Issued: 27 Mar 2014
  3. Action required: Update internal exposure tracking systems to separate QCCP clearing exposure from the 25% single-counterparty limit.
  4. Action required: Ensure all QCCP exposures (trade and default fund) are documented as per the March 27, 2014 capital requirements circular.
  5. Action required: Review and revise credit risk policies to reflect the exemption for QCCP clearing exposure while keeping other exposures within limits.
  6. Action required: Monitor the QCCP status of CCPs regularly, as withdrawal of status would revert exposure to non-QCCP norms.
  7. Owner: ____________ Target date: ____________
  8. Board/committee approval needed? Y / N
  9. 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.

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Official RBI source: https://www.rbi.org.in/Scripts/NotificationUser.aspx?Id=8808&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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