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ALL COMPLIANCE FOR NBFC ASSET SIZE LESS THAN 100 CRORES (SMALL NBFC) || THE LEGAL TIME ||


RBI Returns applicable for Base Layer NBFCs with asset size of less than ₹100 crore.

"Master Direction - Reserve Bank of India (Filing of Supervisory Returns) Directions - 2024" issued by the Reserve Bank of India on February 27, 2024. All the existing returns in the XBRL Portal have been discontinued and have been replaced by a new CIMS Portal. As per the latest direction, all NBFCs are required to submit their supervisory returns through the CIMS Portal.


What is CIMS Portal?

CIMS refers to an online platform, i.e., Centralized Information Management System of the RBI for return submission, data dissemination and other related purposes.

The framework categories NBFCs in Base Layer (NBFC-BL), Middle Layer (NBFC-ML), Upper Layer (NBFC-UL) and Top Layer (NBFC-TL) and gives the methodology to identify the NBFCs in the Upper Layer as per their asset size and scoring methodology.


RBI Returns applicable for Base Layer NBFCs with asset size of less than ₹100 crore.

Sl.

No

Name of Return

Periodicity

Reference date

Existing

Timelines

Revised Timelines

1.

DNBS02 - Important

Financial Parameters

(NBFCs – BL)

Quarterly

31st March/

30th June/

30th September/

31st December

Frequency -

Annual

Within

60 days from

Reference Date

Within 21 days

from Reference Date

2.

DNBS10-Statutory

Auditor Certificate (SAC)

Return

Yearly

31st March

One month from the date of

finalisation of

Balance Sheet.

Not later than

31st December

Within 5 working days from the date of signing

of the Auditor’s report in

terms of section 134 of the Companies Act,

2013, but not later than

December 31st of same

year, in any case.

3.

DNBS13 - Overseas

Investment Details

Quarterly

31st March/

30th June/

30th September/

31st December

Within 15 days from the Reference Date

Within 21 days from the Reference Date


4.

Form A Certificate

Annual

31st March

--

Within one month from

the date of the appointment

of Statutory Central

Auditor (SCA) /

Statutory Auditor (SA).

5.

Financial Soundness

Indicators (FSI)

Quarterly

31st March/

30th June/

30th September/

31st December

--



As the XBRL portal is no longer available, all NBFCs must now submit their applicable returns on the CIMS Portal within the given time frame. The RBI has warned of strict action, which could even result in the cancellation of certificates in extreme cases.

Major change: The frequency for submission of DNBS02 return, which is applicable to Base Layer NBFCs, has been changed from Annual to Quarterly.



FAQ


1. What are RBI Returns for Base Layer NBFCs?

- RBI Returns are regulatory reports that Base Layer Non-Banking Financial Companies (NBFCs) with asset sizes less than ₹100 crore are required to submit to the Reserve Bank of India (RBI) to ensure compliance with supervisory guidelines.


2. What is the significance of the Master Direction issued by the RBI?

- The Master Direction outlines the guidelines and requirements for NBFCs regarding the submission of supervisory returns, ensuring uniformity and adherence to regulatory standards.


3. What is the CIMS Portal, and how does it relate to NBFCs?

- The CIMS Portal, or Centralized Information Management System, is an online platform introduced by the RBI for NBFCs to submit their supervisory returns, facilitating efficient data management and regulatory oversight.


4. How are NBFCs categorized by the RBI, and why is it important?

- NBFCs are categorized into Base Layer, Middle Layer, Upper Layer, and Top Layer based on their asset size and operational layers. This categorization helps in determining the regulatory requirements applicable to each category.


5. Which specific supervisory returns are applicable to Base Layer NBFCs with asset sizes less than ₹100 crore?

- For Base Layer NBFCs, returns such as DNBS02, DNBS10, DNBS13, Form A Certificate, and Financial Soundness Indicators (FSI) are applicable, with revised timelines for submission as per the latest RBI direction.


6. What are the revised timelines for the submission of DNBS02 return for Base Layer NBFCs?

- The frequency for submission of DNBS02 return has been changed from annual to quarterly, with a revised timeline of within 21 days from the reference date.


7. What actions could NBFCs face for non-compliance with the new submission requirements?

- The RBI has warned of strict action, including potential cancellation of certificates, for NBFCs failing to comply with the new reporting guidelines on the CIMS Portal.


8. Could you explain the major change regarding the frequency for submission of DNBS02 return?

- The major change involves shifting the frequency of submission of DNBS02 return from annual to quarterly, reflecting the RBI's emphasis on more frequent reporting for Base Layer NBFCs.


9. What is the Form A Certificate, and when is it required to be submitted by NBFCs?

- The Form A Certificate is required to be submitted annually within one month from the date of appointment of Statutory Central Auditor (SCA) or Statutory Auditor (SA) for Base Layer NBFCs.


10. Are there any penalties specified for NBFCs failing to adhere to the new reporting guidelines on the CIMS Portal?


- Yes, the RBI has warned of strict penalties, including potential cancellation of certificates, for NBFCs failing to adhere to the new reporting guidelines on the CIMS Portal, underscoring the importance of compliance.


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