RBI's New ALM Directions for Urban Co-operative Banks

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Short Title and Commencement B. Applicability C. Definition Chapter II – Role of the Board A. Responsibilities of the Board B. Board approval of policies, limits, and reviews Chapter III – Asset Liability Management Governance A. Introduction B. ALM Information System C. ALM Organization D. ALM Process Chapter IV – Liquidity Risk Management A. Management of Liquidity Risk (also applicable to Level I UCB) B. Structural Liquidity Statement (SLS) C. Behavioural Patterns D. Short-term Dynamic Liquidity statement (also applicable for Level I UCB) E. Liquidity Adjustment Facility (LAF) and Marginal Standing Facility (MSF) for Scheduled UCB Chapter V – Currency Risk A. Management of Currency Risk (not applicable to Level 1 UCB) Chapter VI – Interest Rate Risk (IRR) Management A. Introduction B. Traditional Gap Analysis C. Interest Rate Sensitivity (IRS) statement D. Behavioural Patterns Chapter VII – Monitoring and Reporting A. Preparation and Review of Statements A.1 Scheduled UCB: A.2 Non-Scheduled UCB (excluding UCB in Level I): A.3 UCB in Level I: B. Regulatory Reporting and Periodicity of Returns B.1 Scheduled UCB: B.2 Non-Scheduled UCB (excluding UCB in Level I): B.3 UCB in Level I: Chapter VIII – Repeal and Other Provisions A. Repeal and Saving B. Application of other laws not barred C. Interpretations Annex–I: Structural Liquidity Statement - Scheduled UCBs Annex–II: Structural Liquidity Statement – Non-Scheduled UCBs Annex-III: Short-term Dynamic Liquidity statement–UCBs Annex–IV: Interest Rate Sensitivity Statement – Scheduled UCBs Annex–V: Interest Rate Sensitivity Statement – Non-Scheduled UCBs Annex-VI: Maturity Profile – Liquidity –Scheduled UCBs Annex-VII: Maturity Profile – Liquidity –Non-Scheduled UCBs Annex-VIII: Interest Rate Sensitivity – Scheduled UCBs Annex-IX: Interest Rate Sensitivity – Non-Scheduled Urban Co-operative Banks (UCBs) In exercise of the powers conferred by Section 35A, read with Section 56 of the Banking Regulation Act, 1949, and all other provisions / laws enabling the Reserve Bank of India (‘RBI’) in this regard, RBI being satisfied that it is necessary and expedient in the public interest so to do, hereby, issues the Directions hereinafter specified. Chapter I – Preliminary A. Short Title and Commencement 1. These Directions shall be called the Reserve Bank of India (Urban Co-operative Banks – Asset Liability Management) Directions, 2025. 2. These Directions shall become effective from the date of issue. B. Applicability 3. These Directions shall be applicable to Urban Co-operative Banks (hereinafter collectively referred to as 'UCBs' and individually as a 'UCB'). In this context, ‘Urban Co-operative Banks’ shall mean Primary Co-operative Banks as defined under section 5(ccv) read with Section 56 of the Banking Regulation Act, 1949. C. Definition 4. In these Directions, unless the context states otherwise, the terms herein shall bear the meaning assigned to them below: (1) ‘Defeasance periods’ is the time taken to liquidate the position on the basis of liquidity in the secondary market. (2) ‘Interest rate risk (IRR)’ is the risk where changes in market interest rates might adversely affect a UCB’s financial condition. (3) ‘Level I UCB’ , for the specific purpose of these Directions, shall mean: (i) UCB having deposits below ₹100 crore operating in a single district, (ii) UCB with deposits below ₹100 crore operating in more than one district will be treated as Level I provided the branches are in contiguous districts, and deposits and advances of branches in one district separately constitute at least 95 per cent of the total deposits and advances respectively of the UCB, and (iii) UCB with deposits below ₹100 crore, whose branches were originally in a single district, but subsequently became multi-district due to reorganisation of the district. 5. All other expressions unless defined herein shall have the same meaning as have been assigned to them under the Banking Regulation Act, the RBI Act, rules / regulations made thereunder, or any statutory modification or re-enactment thereto or as used in commercial parlance, as the case may be. Chapter II – Role of the Board A. Responsibilities of the Board 6. The Board shall be responsible for overall management of risks, as also for the formulation of risk management policy and procedures, setting prudential limits, and establishing mechanisms for audit, reporting, and review in respect of forex risk (not applicable to a Level I UCB), liquidity risk, and interest rate risk (IRR), . The Board shall also oversee the implementation of the ALM system, and periodically review its functioning. 7. The Board may delegate the above responsibilities to the Board of Management (BoM), if BoM has been constituted by a UCB as per Reserve Bank of India (Urban Co-operative Banks – Governance) Directions, 2025 . B. Board approval of policies, limits, and reviews 8. The Board shall approve the internal prudential limits for cumulative mismatches (running total) across all time buckets of Structural Liquidity Statement (SLS) for monitoring by a UCB. 9. The Board shall approve the volume, composition, holding / defeasance period, cut loss, etc., in respect of the Trading Book of a UCB. 10. The Board shall ensure that various statements as provided in Chapter VII are placed by the UCB before it. 11. The Board shall approve prudential limits on individual gaps of Interest Rate Sensitivity (IRS) statement, which shall be based on Total Assets, Earning Assets or Equity (not applicable to a Level 1 UCB). 12. The Board shall ensure that the IRS statement, along with the analysis of Gaps and Earnings at Risk (EaR), are placed before the Board, and Board / the Top Management shall formulate corrective measures and devise suitable strategies wherever needed, as per information on the IRR provided in the statement (not applicable to a Level 1 UCB). Chapter III – Asset Liability Management Governance 13. Guidelines in this Chapter shall not apply to a Level 1 UCB unless stated otherwise. A. Introduction 14. A UCB shall introduce an effective Asset Liability Management (ALM) system to address liquidity risk, IRR, and currency risk. 15. ALM, among other functions, provides a dynamic framework for measuring, monitoring and managing liquidity, interest rate, and foreign exchange (forex) risks. This involves assessment of various types of risks and altering balance sheet (assets and liabilities) items in a dynamic manner to manage risks. 16. These Directions shall serve as a benchmark. A UCB that has already implemented more sophisticated systems may continue using them. However, the UCB shall fine-tune its existing system to ensure compliance with the requirements set out in these Directions. A UCB shall also review its current Management Information System (MIS) and implement necessary enhancements as prescribed. Once the ALM system is stabilised and the UCB has gained sufficient experience, it shall prepare to transition to more sophisticated techniques for IRR management such as Duration Gap Analysis, Simulation, and Value at Risk. 17. A UCB shall implement its ALM process based on the following three pillars: (1) ALM Information Systems, comprising: (i) MIS. (ii) Timely availability, accuracy, adequacy, and expediency of information. (2) ALM Organisation, covering: (i) Structure and responsibilities. (ii) Level of Top Management involvement. (3) ALM Process, comprising: (i) Risk parameters. (ii) Risk identification. (i) Risk measurement. (ii) Risk management. (iii) Risk policies and procedures, prudential limits and auditing, reporting, and review. B. ALM Information System 18. The ALM framework has to be supported by risk policies and procedures, and prudential limits. Top Management of the UCB shall put in place a robust information system to ensure availability of timely, adequate, and accurate information. C. ALM Organization 19. A UCB shall constitute an Asset Liability Management Committee (ALCO), headed by the Chief Executive Officer (CEO) or the Secretary and consisting of the Top Management. The ALCO shall be responsible for ensuring adherence to the policies and limits approved by the Board and for deciding the business strategy, on the assets and liabilities sides, in alignment with the UCB’s business, and risk management objectives. The Board shall oversee the implementation of the system and periodically review its functioning. 20. The ALCO shall act as a decision-making unit responsible for balance sheet planning from risk-return perspective, including the strategic management of liquidity, interest rate, and forex risks. The future business strategy decisions of ALCO shall be based on the UCB’s views on current interest rates. As part of funding strategy, ALCO shall determine the source and mix of liabilities or sale of assets. The ALCO shall develop a view on future direction of interest rate movements and decide on funding mix between fixed v/s. floating rate funds, wholesale v/s. retail deposits, and short term v/s. long term deposits. 21. The business and risk management strategy of a UCB shall ensure that all operations remain within the limits and parameters set by the Board. The ALCO shall, inter-alia, consider key business issues such as pricing of deposits and advances, desired maturity profile, and mix of the incremental assets and liabilities. In addition to monitoring the UCB’s risk levels, the ALCO shall review the outcome of previous decisions and evaluate the progress made in their implementation. 22. The composition and size (number of members) of the ALCO shall depend on the size, level of business, and organisational structure of the UCB. The CEO or the Secretary shall head the ALCO, and the Heads of Investment, Credit and Strategy, Treasury, Risk Management, etc., can be its members, along with other members as deemed suitable. The Head of the Information Technology Division shall be an invitee. A UCB, at its discretion, may have Sub-committees and Support Groups. A UCB shall decide the frequency for holding meetings of the ALCO. 23. The ALM Support Groups, consisting of operating staff, shall be responsible for analysing, monitoring, and reporting the risk profiles to the ALCO. The Group shall also prepare forecasts (simulations) showing the effects of various possible changes in market conditions related to the balance sheet and recommend the action needed to adhere to UCB’s internal limits. D. ALM Process 24. The scope of ALM function shall include the following: (1) Liquidity risk management. (2) IRR management. (3) Trading (Price) risk management. (4) Funding and capital planning. (5) Profit planning and business projection. Chapter IV – Liquidity Risk Management A. Management of Liquidity Risk (also applicable to Level I UCB) 25. A UCB shall measure liquidity positions on an ongoing basis as also examine how liquidity requirements are likely to evolve under different assumptions / scenarios. The liquidity measurement may be undertaken through: (1) Stock approach: Analysing liquidity ratios such as credit deposit ratio, loans to total assets, loans to core deposits, and other similar ratios; and (2) Cash flow approach: Using maturity ladder as a standard tool for measuring the liquidity profile at selected maturity buckets. B. Structural Liquidity Statement (SLS) 26. Provisions of the following paragraphs excluding paragraphs 33 and 37 are applicable to a Level I UCB. 27. A Scheduled UCB and a non-Scheduled UCB shall prepare the SLS under static scenario without reckoning the future business growth, as per the reporting format provided in Annex-I and Annex-II of these Directions, respectively. 28. A UCB shall use the maturity profile, given in Annex-VI (for a Scheduled UCB) and Annex-VII (for a non-Scheduled UCB) of these Directions, to capture the future cash flows across following time buckets: (1) 1 to 14 days (2) 15 to 28 days (3) 29 days and upto 3 months (4) Over 3 months and upto 6 months (5) Over 6 months and upto 1 year (6) Over 1 year and upto 3 years (7) Over 3 years and upto 5 years (8) Over 5 years 29. A UCB shall classify all cash inflows and outflows in the maturity ladder according to the expected timing of cash flows. A maturing liability shall be a cash outflow while a maturing asset shall be a cash inflow. While determining the probable cash inflows / outflows, a UCB shall make assumptions according to its asset liability profile. 30. A UCB shall monitor its cumulative mismatches (running total) across all time buckets by establishing internal prudential limits with the approval of the Board. 31. Tolerance levels for mismatches shall be fixed, taking into account the asset-liability profile, nature of business, and future strategy. While the mismatches upto one year would be relevant since these provide early warning signals of impending liquidity problems, the main focus should be on short term mismatches. 32. For a non-Scheduled UCB (including Level I UCB), the negative mismatches (negative gap) in the 1-14 days, and 15-28 days time buckets shall, under normal circumstances, not exceed 20 per cent of the cash outflows in the respective time bucket. 33. A Scheduled UCB shall adopt a more granular approach to measurement of liquidity risk by splitting the first time bucket (1-14 days) in the SLS into three time buckets, viz., next day, 2-7 days, and 8-14 days. A Scheduled UCB shall ensure that the net cumulative negative mismatches during the next day, 2-7 days, 8-14 days, and 15-28 days buckets shall not exceed 5 per cent, 10 per cent, 15 per cent and 20 per cent of the cumulative cash outflows in the respective time buckets. 34. Investments in SLR securities and other investments shall be placed under the residual maturity buckets, corresponding to their remaining maturities. 35. A UCB maintaining securities in the Trading Book, kept distinct from other investments made for complying with the Statutory Reserve requirements and for retaining customer relationship, shall classify such securities under 1-14 days (split into next day, 2-7 days, and 8-14 days in case of a Scheduled UCB), 15-28 days, and 29-90 days’ time buckets, based on their defeasance periods, provided the trading book meets the following criteria: (1) Clearly defined composition and volume; (2) Restriction on maximum maturity/duration of the portfolio; (3) the holding period not exceeding 90 days; (4) Prescribed cut-loss limit; (5) Prescribed product-wise defeasance periods; and (6) Mark to market on a weekly basis with revaluation gains / losses recognised in the profit and loss account. 36. The ALCO of the UCB (Board in case of a Level I UCB) shall approve the volume, composition, holding / defeasance period, cut loss, etc., of the Trading Book. 37. A UCB with Authorised Dealer (AD) licence shall take into account the ₹ inflows and outflows on account of its forex operations while preparing the prescribed liquidity statements. C. Behavioural Patterns 38. Notwithstanding guidance provided in Annex-VI and Annex-VII of these Directions, a UCB which is better equipped to reasonably estimate the behavioural pattern of various components of assets and liabilities on the basis of past data / empirical studies shall classify them in the appropriate time buckets, subject to approval from the ALCO. D. Short-term Dynamic Liquidity statement (also applicable for Level I UCB) 39. A UCB shall estimate its short-term liquidity profile on the basis of business projections and other commitments for planning purposes, as per indicative format for Short-term Dynamic Liquidity statement in Annex-III . The statement can be used for monitoring dynamic liquidity over a time horizon spanning from 1 to 90 days. E. Liquidity Adjustment Facility (LAF) and Marginal Standing Facility (MSF) for Scheduled UCB 40. In order to provide an additional avenue for liquidity management, Liquidity Adjustment Facility (LAF) and Marginal Standing Facility (MSF) is extended to a Scheduled UCB which is Core Banking Solutions (CBS) enabled, have Capital to Risk-weighted Assets Ratio (CRAR) of at least 9 per cent, and is fully compliant with the eligibility criteria prescribed for LAF. 41. The terms and conditions for availing LAF and MSF would be as per the instructions issued by Financial Markets Operation Department (FMOD), Reserve Bank of India from time to time. 42. The list of such Scheduled UCBs which meet the eligibility norms to participate in LAF and MSF (Positive List), and of those Scheduled UCBs found ineligible (Negative List), shall be prepared by the Reserve Bank of India. 43. The Positive List will be reviewed by the Reserve Bank on an ongoing basis to ensure that the financial parameters are being complied with at all times. However, additions to the Positive List will be considered annually based on the financial position for the immediately preceding financial year as assessed by the Reserve Bank’s Inspection. Chapter V – Currency Risk A. Management of Currency Risk (not applicable to Level 1 UCB) 44. One of the dimensions of ALM is the management of currency risk. Mismatched currency position, besides exposing the balance sheet of a UCB to movement in exchange rates, also exposes it to country risk and settlement risk. 45. A UCB with AD license shall set Gap limits and adopt Value at Risk (VaR) approach to measure the risk associated with forex exposures. The open position limits together with the Gap limits shall form part of the risk management approach for the UCB’s forex operations. Chapter VI – Interest Rate Risk (IRR) Management 46. The provision of this Chapter shall not apply to a Level I UCB, unless stated otherwise. A. Introduction 47. IRR from ‘earnings perspective’ is the immediate impact of interest rate changes on UCB’s profits through changes in its Net Interest Income (NII). IRR from ‘economic value perspective’ is long-term impact of interest rate changes on UCB’s Market Value of Equity (MVE) or Net Worth as marked to market value of UCB’s assets, liabilities, and off-balance sheet positions get affected due to variation in market rates. The risk from the earnings perspective can be measured as changes in the NII or Net Interest Margin (NIM). 48. A UCB shall implement appropriate systems to measure and manage IRR, arising on account of deregulation of interest rates, and operational flexibility in pricing of assets and liabilities. 49. A UCB shall employ suitable analytical tools for the measurement and management of IRR. The UCB shall initially use the Traditional Gap Analysis (TGA) for measuring IRR. B. Traditional Gap Analysis 50. Under TGA, a UCB shall measure Gap or Mismatch risk by calculating Gaps, i.e., the difference between Rate Sensitive Assets (RSA) and Rate Sensitive Liabilities (RSL) over different time intervals as on a given date. 51. ‘Gap analysis’ is the measurement of mismatches between RSL and RSA, including off-balance sheet positions. A Gap Report shall be generated by grouping rate sensitive liabilities, assets, and off-balance sheet positions into time buckets according to residual maturity or next repricing period, whichever is earlier. 52. All investments, advances, deposits, borrowings, and other instruments that mature / have a cash flow or reprice within a specific time frame shall be treated as interest rate sensitive. 53. Repayments of loan instalments, including both principal and periodic payments, shall also be treated as rate sensitive if they are expected to be received within the time horizon. 54. Assets and liabilities that are linked to a reference rate that reprices at pre-determined intervals, shall be treated as rate sensitive at the time of contractual repricing. C. Interest Rate Sensitivity (IRS) statement 55. A UCB shall prepare the IRS statement, as per the reporting format provided in Annex-IV (Scheduled UCB) and Annex-V (non-Scheduled UCB) of these Directions. 56. A UCB shall report only ₹ assets, liabilities, and off-balance sheet positions in the IRS statement. 57. The rate sensitive assets, liabilities, and off-balance sheet positions shall be grouped into the following time buckets according to residual maturity or next repricing date, whichever is earlier: (1) Upto 3 months (2) Over 3 months and upto 6 months (3) Over 6 months and upto 1 year (4) Over 1 year and upto 3 years (5) Over 3 years and upto 5 years (6) Over 5 years (7) Non-sensitive 58. The various items of rate sensitive assets and liabilities, and off-balance sheet items shall be classified into time buckets as per guidance given in Annex–VIII (Scheduled UCB) and Annex-IX (non-Scheduled UCB). 59. A positive Gap (RSA > RSL) indicates potential benefit from rising interest rates, while a negative Gap (RSL > RSA) indicates potential benefit from declining interest rates. Gap Reports shall be used by the UCB to assess the extent of IRR and to formulate IRR mitigation strategies. 60. A UCB shall set prudential limits on individual Gaps with the approval of its Board, which shall be based on Total Assets, Earning Assets or Equity levels of the UCB. A UCB shall also work out Earnings at Risk (EaR) in terms of last year’s NII, or Net Interest Margin (NIM) aligned with its views on interest rate movements. 61. The IRS statement, along with the analysis of Gaps and EaR, shall be placed before the Board in its next meeting. The Top Management / Board shall formulate corrective measures and devise suitable strategies wherever needed, as per information on IRR provided in the statement. D. Behavioural Patterns 62. Notwithstanding the guidance provided in Annex-VIII and Annex-IX of these Directions, a UCB which is better equipped to reasonably estimate the behavioural pattern of various components of assets and liabilities on the basis of past data / empirical studies shall classify them in the appropriate time buckets based on the behavioural patterns, subject to approval from the ALCO. Chapter VII – Monitoring and Reporting A. Preparation and Review of Statements A.1 Scheduled UCB: Return Frequency Submission to Structural Liquidity Statement Daily Daily to the Top Management / ALCO Short-term Dynamic Liquidity Statement Daily ALCO / Top Management within 2 or 3 days from the close of the reporting Friday Interest Rate Sensitivity statement Monthly ALCO / Top Management within a month from the last reporting Friday A.2 Non-Scheduled UCB (excluding UCB in Level I): Return Frequency Submission to Structural Liquidity Statement Last reporting Friday of March / June / September / December ALCO / Top Management within a month from the close of the last reporting Friday Short-term Dynamic Liquidity statement Each reporting Friday ALCO / Top Management within 2 or 3 days from the close of the reporting Friday Interest Rate Sensitivity statement Last reporting Friday of March / June / September / December ALCO / Top Management within a month from the close of the last reporting Friday A.3 UCB in Level I: Return Frequency Submission to Structural Liquidity Statement Last reporting Friday of March / June / September / December Board within a month from the close of the last reporting Friday Short-term Dynamic Liquidity statement Last reporting Friday of March / June / September / December Board within a month from the close of the last reporting Friday B. Regulatory Reporting and Periodicity of Returns 63. A UCB shall refer to the Reserve Bank of India (Filing of Supervisory Returns) Directions – 2024 dated February 27, 2024 , for instructions with respect to periodicity and timelines of returns consolidated as under: B.1 Scheduled UCB: Return Periodicity Structural Liquidity Statement (ALM3) Fortnightly Short-term Dynamic Liquidity statement (ALM2) Fortnightly Interest Rate Sensitivity Statement (ALM1) Monthly B.2 Non-Scheduled UCB (excluding UCB in Level I): Return Periodicity Structural Liquidity Statement (ALM3) Quarterly Interest Rate Sensitivity Statement (ALM1) Quarterly B.3 UCB in Level I: Return Periodicity Structural Liquidity Statement (ALM3) Quarterly 64. A UCB shall submit the ALM returns correctly and within the prescribed time. It shall designate and authorise one or two senior official/s who shall be responsible for the correct compilation and timely submission of these returns and who shall be fully responsible for the information furnished therein. Such designated Authorised Reporting Official/s (ARO/s) shall liaison with the officials in the Department of Supervision (DoS), RBI. The names and designations of the ARO/s shall be indicated to the concerned Regional Office of DoS, RBI while forwarding these returns. Chapter VIII – Repeal and Other Provisions A. Repeal and Saving 65. With the issue of these Directions, the existing Directions, instructions, and guidelines relating to Asset Liability Management as applicable to Urban Co-operative Banks stand repealed, as communicated vide circular DOR.RRC.REC.302/33-01-010/2025-26 dated November 28, 2025 . The Directions, instructions and guidelines already repealed shall continue to remain repealed. 66. Notwithstanding such repeal, any action taken or purported to have been taken, or initiated under the repealed Directions, instructions, or guidelines shall continue to be governed by the provisions thereof. All approvals or acknowledgments granted under these repealed lists shall be deemed as governed by these Directions. Further, the repeal of these Directions, instructions, or guidelines shall not in any way prejudicially affect (1) any right, obligation or liability acquired, accrued, or incurred thereunder; (2) any, penalty, forfeiture, or punishment incurred in respect of any contravention committed thereunder; (3) any investigation, legal proceeding, or remedy in respect of any such right, privilege, obligation, liability, penalty, forfeiture, or punishment as aforesaid; and any such investigation, legal proceedings or remedy may be instituted, continued, or enforced and any such penalty, forfeiture or punishment may be imposed as if those Directions, instructions, or guidelines had not been repealed. B. Application of other laws not barred 67. The provisions of these Directions shall be in addition to, and not in derogation of the provisions of any other laws, rules, regulations, or directions, for the time being in force. C. Interpretations 68. 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Reproduced for reference with acknowledgment — Source: Reserve Bank of India · RBI/DOR/2025-26/285 · issued 28 Nov 2025. The plain-English explanation above is BankPulse’s own independent summary.

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