What changed
RBI has mandated that all NEFT and RTGS transactions for foreign contributions to SBI's FCRA account must include a new transaction code (code 41 in field 6305 for NEFT, FCRA in PmtTpInf/CtgyPurp/Cd for RTGS) and donor details in specific formats. The change, effective March 15, 2023, requires banks to update their core banking or middleware systems to capture donor details (name, address, purpose, country, currency, amount) in the prescribed order, with separate formats for transactions with or without Legal Entity Identifier (LEI) details.
What it means for you
Banks must now ensure their systems can capture and transmit detailed donor information for every FCRA-related transaction via NEFT/RTGS. This adds compliance overhead but aligns with MHA's daily reporting needs. Non-compliance could lead to transaction failures or regulatory scrutiny, so banks need to test their system changes before the deadline.
What you must do
- Update core banking or middleware systems to include the new FCRA transaction code (code 41 in field 6305 for NEFT, FCRA in PmtTpInf/CtgyPurp/Cd for RTGS) by March 15, 2023.
- Configure the 7495 field (NEFT) and RmtInf/Ustrd tag (RTGS) to capture donor details in the prescribed format, using the appropriate format for transactions with or without LEI details.
- Test the new transaction flow with SBI's FCRA account to ensure donor data is transmitted correctly.
- Train operations and compliance teams on the new requirements to avoid errors in remitting foreign donations.
Who it affects
Member banks participating in NEFT and RTGS systems, Banks handling foreign donations to SBI's FCRA account, Operations and compliance teams at banks
What is the effective date for these changes?
The instructions are effective from March 15, 2023. Banks must have their system changes in place by this date.
What happens if we don't include the donor details in the required format?
The RBI circular does not specify penalties, but the MHA requires daily reporting of donor details. Missing or incorrect data could lead to transaction rejection or non-compliance with FCRA rules.
Do we need to include LEI details for all transactions?
No, LEI details are not required for all transactions. The circular provides separate formats for transactions with and without LEI details. If the transaction has LEI details, the format with LEI must be used.