Objective
Non-Banking Financial Companies (NBFCs) are directed by Reserve Bank of India to submit various returns w.r.t., to their deposit acceptance, prudential norms compliance, ALM etc. within a specified timelines in accordance with various Master Directions. NBFC Compliances and Returns are comprehensive and require time-bound reporting, so as to avoid penal action by RBI. This is an effort to consolidate the Compliances to provide a handy guide for all Compliance Officers, CFOs, Company Secretaries, to have a holistic view of compliance filing dates across various applicable laws, along with Regulating documents for NBFC Industry.
Yearly Filings/Intimations
| S. No. | Particular | Description | Applicability | Filling Dates | Regulating Document |
|---|---|---|---|---|---|
| 1. | DNBS10 | Statutory Auditor Certificate (SAC) Return for Continued Regulatory Compliance | All NBFC and ARC | 31st December | Master Direction – Reserve Bank of India (Filing of Supervisory Returns) Directions, 2024 |
| 2. | DNBS02 | Financial Details like Components of Assets and Liabilities, Prudential Norms | NBFC-BL |
|
Master Direction-RBI (Filing of Supervisory Returns) Directions, 2024 |
| 3. | Schedule- I Return | Details of public deposits, category wise distribution of housing loan to individual or state or union territories | HFC | 30th June | Master Circular- Returns HFC |
| 4. | Statutory Auditor Certificate | Statutory auditor certificate (SAC) return on certificate of registration as housing finance company | HFC | 30th June | Master Circular- Returns HFC |
| 5. | FAFT Compliance Certificate | For Compliance with the Norms specified by RBI, in respect of Investment from FATF non-compliant jurisdictions | HFC | 30th June | Master Circular- Returns HFC |
| 6. | Declaration | Board resolution for not accepting/ holding any public deposit | NBFC - ICC | 30th April | Master Direction- NBFC- Acceptance of Public Deposit Direction, 2016 |
| 7. | Declaration | Board Resolution for Acquisition of Shares/ Securities of its own Group / Holding/ Subsidiary Companies | Company which has acquired shares/ securities of its own group / holding/ subsidiary companies | 30th April | Master Direction- NBFC-Acceptance of Public Deposit Direction, 2016 |
| 8. | Form A Certificate | Regarding appointment of Statutory Central Auditor (SCA)/ Statutory Auditor (SA) | All NBFCs | 21st April | Master Direction – Reserve Bank of India (Filing of Supervisory Returns) Directions, 2024 |
Half-Yearly Filings/Intimations
| S. No. | Particular | Description | Applicability | Filling Dates | Regulating Document |
|---|---|---|---|---|---|
| 1. | Statement on Interest Rate Futures (IRF) Transaction | NBFC Participating in Interest Rate Future Exchanges for hedging their underlying exposures | NBFC including HFC participating in interest rate future exchanges |
|
Master Direction- Scale Based Regulation, Master Circular- Returns HFC |
| 2. | Schedule-II Return | Information on various Prudential Norms i.e., Capital Adequacy, Asset Classification, Provisioning Net Owned Funds etc. | HFC |
|
Master Circular- Returns HFC |
| 3. | ALM-II | Statement of Structured Liquidity and Interest Rate Sensitivity | HFC taking deposit and all non-deposit taking HFC with asset size of Rs. 100 cr. And above |
|
Master Circular- Returns HFC |
| 4. | FDI– SAC | Compliance with the terms and conditions of foreign direct investment (FDI)-SAC | HFC having Foreign Direct Investment |
|
Master Circular- Returns HFC |
Quarterly Filings/Intimations
| S. No. | Particular | Description | Applicability | Filling Dates | Regulating Document |
|---|---|---|---|---|---|
| 1. | Annex X | Report on Pledged Securities in their favor by the borrowers for availing loans | NBFC having asset size of Rs. 100 cr. And above |
|
Master Direction- Scale Based Regulation |
| 2. | Notification/Email | Statement to Communicate Principal and interest, EMI amount, number of EMIs left | All NBFC including HFC |
|
Master Direction – HFC, Master Direction- Scale Based Regulation |
| 3. | Report on Total Exposure | Having Assumed Exposures against borrowers in excess of the normal exposure limits | All NBFC |
|
Master Direction- Scale Based Regulation |
| 4. | Statement | Statement for Change in Directors as per Fit and Proper Criteria | NBFC-ML, NBFC-UL, HFC |
|
Master Direction- Scale Based Regulation, Master Direction- HFC |
| 5. | DNBS01 | Financial Details, viz. Components of Assets and Liabilities, Profit and Loss Account, Exposure to Sensitive Sectors | NBFC-UL, NBFC-ML except NBFC-CIC |
|
Master Direction – Reserve Bank of India (Filing of Supervisory Returns) Directions, 2024 |
| 6. | DNBS03 | Important Prudential Parameters- Contains prudential norms, e.g., capital adequacy, provisioning etc. | NBFC-UL, NBFC-ML except NBFC-CIC |
|
Master Direction – Reserve Bank of India (Filing of Supervisory Returns) Directions, 2024 |
| 7. | DNBS04A | Statement on Short Term Dynamic Liquidity (STDL) contains data on Asset Liability Mismatches (ALM) and Interest Rate Sensitivity (IRS), liquidity risk of exposures | NBFC-UL, NBFC-ML(except NBFC-SPD), NBFC-BL with asset size of ₹100 crore and above solely or at Group level, excluding Type-I NBFCs, and NOFHC, P2Ps, AAs, and Mortgage Guarantee Companies |
|
Master Direction – Reserve Bank of India (Filing of Supervisory Returns) Directions, 2024 |
| 8. | DNBS07 | ARCs Important Financial Parameters- contains data on assets and liabilities, assets acquired from Banks/FIs, acquisition cost, trusts formed, recovery status of acquired assets etc. | ARC |
|
Master Direction – Reserve Bank of India (Filing of Supervisory Returns) Directions, 2024 |
| 9. | DNBS13 | Return on Overseas Investment details for all NBFCs having overseas investment | All NBFCs |
|
Master Direction – Reserve Bank of India (Filing of Supervisory Returns) Directions, 2024 |
| 10. | Notification/Email | Communicating Particulars of Public Deposit to Respective Branches | HFC |
|
Master Direction- HFC |
| 11. | Annexure VI | Report on Detection and Impounding of Counterfeit Notes | HFC |
|
Master Direction- HFC |
| 12. | Schedule-III Return | Details on Statutory Liquidity Ratio (SLR), structural liquidity & interest rate sensitivity | HFC |
|
Master Circular- Returns HFC |
| 13. | Schedule-IV Return | Financial details viz. Components of Asset and Liability, Profit and Loss Account, Exposure to Sensitive Sector | HFC |
|
Master Circular- Returns HFC |
| 14. | ALM-I | Statement on Short Term Dynamic Liquidity (STDL) | HFC taking deposit and all non-deposit taking HFC with asset size of Rs. 100 cr. And above |
|
Master Circular- Returns HFC |
| 15. | 20- Major Exposure Return | Details of large borrowers | HFC |
|
Master Circular- Returns HFC |
| 16. | Broad Liquidity Return | Details of liability and asset of large HFC | Deposit taking HFC irrespective of asset size |
|
Master Circular- Returns HFC |
| 17. | Overseas Investment Report | Report on overseas investment details | Deposit and non-deposit taking HFC |
|
Master Circular- Returns HFC |
| 18. | Periodic Report | Analysis of complaints on activities of internal ombudsman | Internal Ombudsman of Regulated Entity |
|
Master Direction- RBI (Internal Ombudsman for Regulated Entities) Directions, 2023 |
| 19. | FMR IV | Capture the updated information report on dacoities / robberies / theft / burglaries using online Portal | All NBFCs (including HFC) in UL, ML, BL (with asset size of Rs. 500 crore and above) |
|
Reserve Bank of India (Fraud Risk Management in NBFCs) Directions, 2024 |
| 20. | DNBS02 | Important Financial Parameters | NBFC-BL except NBFC – P2P |
|
Master Direction – Reserve Bank of India (Filing of Supervisory Returns) Directions, 2024 |
| 21. | Appendix VI-A | Public Disclosure on the soundness of Entities liquidity risk management framework and liquidity position | All NBFC |
|
Master Direction – Scale Based Regulations |
| 22. | DNBS 11 | CICs Important Financial Parameters | NBFC - CICs |
|
Master Direction – Reserve Bank of India (Filing of Supervisory Returns) Directions, 2024 |
| 23. | DNBS 12 | CICs Important Prudential Parameters | NBFC - CICs |
|
Master Direction – Reserve Bank of India (Filing of Supervisory Returns) Directions, 2024 |
| 24. | DNBS 14 | P2P- Important Financial & Prudential Parameters | NBFC - P2Ps |
|
Master Direction – Reserve Bank of India (Filing of Supervisory Returns) Directions, 2024 |
| 25. | Financial Soundness Indicators (FSI) | Consolidated Financial Soundness Indicators (FSI) to International Monetary Fund (IMF) | All NBFC and ARC (except HFC) |
|
Master Direction – Reserve Bank of India (Filing of Supervisory Returns) Directions, 2024 |
Monthly Filings/Intimations
| S. No. | Particular | Description | Applicability | Filling Dates | Regulating Document |
|---|---|---|---|---|---|
| 1. | Annex XXV | Reporting of Large Exposure | NBFC – UL | By end of each month | Master Direction-Scale Based Regulation |
| 2. | Annex XIX | Information of borrowers whose secured assets is possessed | All NBFC including HFC | By end of each month | Master Direction-Scale Based Regulation, Master Direction- HFC |
| 3. | DNBS04B | Return on Structural Liquidity & Interest Rate Sensitivity | NBFC-UL, NBFC-ML except Standalone Primary Dealers, and NBFC-BL with asset size of ₹100 crore and above solely or a Group level, excluding Type-I NBFC, and NOFHC, P2P, AA, and Mortgage Guarantee Companies | Within 15 days from end of each month | Master Direction – Reserve Bank of India (Filing of Supervisory Returns) Directions, 2024 |
| 4. | DNBS08 | CRILC main return | NBFC-UL NBFC-ML (except NBFC-CIC), and NBFC-BL which are NBFC-ICC, NBFC-MFI, NBFC-Factors having asset size of ₹500 crore and above solely or at Group level | Within 15 days of end of month | Master Direction – Reserve Bank of India (Filing of Supervisory Returns) Directions, 2024 |
| 5. | Annexure XVII | Information on willful default of 25 lakh or above to credit information company | HFC | By 15th of subsequent month | Master Direction-HFC |
| 6. | Schedule –V | Capture trend in loans and advances, borrowings, asset quality, interest rate structure | HFC | Within 10 days from end of month | Master Circular- Returns HFC |
| 7. | Report on Cash Transaction (CTR) | Report on Cash Transaction (CTR) to FIU India | All NBFC | By 15th of succeeding month | Master Direction - Know Your Customer (KYC) Direction, 2016 |
Weekly Filings/Intimations
| S. No. | Particular | Description | Applicability | Filling Dates | Regulating Document |
|---|---|---|---|---|---|
| 1. | DNBS09- CRILC RBD | NBFCs having aggregate exposure of ₹5 crore and above to a single borrower reported in SMA-0 for the week | NBFC-UL, NBFC -ML except NBFC-CICs, and NBFC-BL which are NBFC-ICC, NBFC-MFI, NBFC-Factors having asset size of ₹500 crore and above solely or at Group level | On or before Wednesday of the following week | Master Direction – Reserve Bank of India (Filing of Supervisory Returns) Directions, 2024 |
| 2. | LCR Return | Capture Liquidity Coverage of the HFC | HFC taking deposit, all non –deposit taking HFC with asset size of Rs. 5000 cr. And above | Within 5 days from the week ending on Friday | Master Circular- Returns HFC |
Event-Based Filings/Intimations
| S. No. | Particular | Description | Applicability | Filling Dates | Regulating Document |
|---|---|---|---|---|---|
| 1. | Annex II | Report Name of Directors Classified as Wilful Defaulters | AIFI, Bank, NBFC which has granted a credit facility to Borrower | In case of Wilful default | Master Direction on Treatment of Wilful Defaulters and Large Defaulters, 2024 |
| 2. | NA | Intimate about removal of name of wilful defaulter from List of Wilful Defaulters to CIC | Lenders or ARC | Within 30 days from the date when outstanding amount falls below Rs. 25 lakh or notified by RBI | Master Direction on Treatment of Wilful Defaulters and Large Defaulters, 2024 |
| 3. | Annex I, Annex II | Submit Details of Guarantors who have failed to honor their commitments | Entities regulated by RBI or Lenders | In case of Wilful default | Master Direction on Treatment of Wilful Defaulters and Large Defaulters, 2024 |
| 4. | Fraud Monitoring Return | Report incidents of fraud in individual fraud cases, irrespective of amount involved | NBFC including HFC | Not later than 14 days from date of classification of incident/ account as fraud | Reserve Bank of India (Fraud Risk Management in NBFC's) Directions, 2024 |
| 5. | FMR IV | Report instances of theft, burglary, dacoity and robbery including attempted cases | NBFC including HFC | Not later than 7 days from their occurrence | Reserve Bank of India (Fraud Risk Management in NBFC's) Directions, 2024 |
Abbreviations
| SAC | Statutory Auditor Certificate |
| DNBS | Department of Non-Banking Supervision |
| NBFC-ND-SI | Non-Deposit taking Systemically Important |
| NBFC | Non-Banking Financial Company |
| HFC | Housing Finance Company |
| LCR | Liquidity Coverage Ratio |
| CRILC | Central Repository of Information on Large Credits |
| SMA | Special Mention Account |
| NBFCs-D | Non-Banking Financial Company taking deposit |
| NBFC-CIC | Non-Banking Financial Company- Core Investment Company |
| ALM | Asset Liability Management |
| NOFHCs | Non-Operative Financial Holding Company |
| NBFC-BL | Non-Banking Financial Company- Base Layer |
| NBFC-ML | Non-Banking Financial Company- Middle Layer |
| NBFC-UL | Non-Banking Financial Company- Upper Layer |
| FAFT | Financial Action Task Force |
| SPD | Standalone Primary Dealers |
| MGC | Mortgage Guarantee Companies |
| ARC | Asset Reconstruction Companies |
| RBI | Reserve Bank of India |
| AIFI | All India Financial Institution |
| CIC | Credit Information Companies |
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Disclaimer
The information provided in this article is intended for general informational purposes only and should not be construed as legal advice. The content of this article is not intended to create and receipt of it does not constitute any relationship. Readers should not act upon this information without seeking professional legal counsel.
