Does an NBFC still file the old NBS returns?
No. An NBFC does not still file the NBS returns that a 2020 list set out, such as NBS-1 for deposit-taking companies or NBS-7 for a non-deposit systemically important company. Those names are not the current supervisory set. The Reserve Bank’s directions on filing of supervisory returns name DNBS returns, and the return depends on the NBFC’s layer.
What was the 2020 list?
The older list separated deposit-taking companies, which filed quarterly NBS returns on financials, prudential norms, and liquid assets, from non-deposit companies, which filed by asset size. It also listed asset-liability returns, a statutory auditor’s certificate, and a few special returns. Using that table now files the wrong form. A due date printed beside NBS-8 or NBS-9 in 2020 is not a date on the current calendar.
What is filed now?
The current returns are filed on the Reserve Bank’s supervisory portal. A base-layer company is not given the middle-layer or upper-layer set. A company that does not accept public deposits does not file a return whose only purpose is public deposits. Which of the current returns applies, including the annual auditor’s certificate, is on the returns page. This page does not reprint either the 2020 table or the full current list.
What does the certificate still require?
Section 45-IA still requires a certificate before the company commences or carries on the business of a non-banking financial institution. A new Investment and Credit Company shows Net Owned Funds of ₹10 crore. The older ₹2 crore figure is not the threshold for a fresh certificate. The company cannot take savings or current-account deposits, and an ordinary new certificate does not include permission to accept public deposits. How the certificate is obtained is on the NBFC page.
Frequently asked questions
Four questions cover NBS-1, who files what, the ₹10 crore fund, and lending before the certificate.
Is NBS-1 still the quarterly return?
No. NBS-1, NBS-2, and the other NBS numbers in the 2020 list are not the current supervisory set. The current returns are the DNBS returns the filing direction names for that NBFC’s layer.
Does every NBFC file the same forms?
No. A base-layer NBFC, a middle-layer NBFC, and an upper-layer NBFC are not given the same set. A company that does not take public deposits does not file a deposit return.
Can a new NBFC start with ₹2 crore of Net Owned Funds?
No. A fresh certificate for an Investment and Credit Company requires Net Owned Funds of ₹10 crore. The older ₹2 crore figure is not that threshold.
Can the company lend before the certificate?
No. Section 45-IA requires the certificate before the company commences or carries on the business of a non-banking financial institution.
Sources
A certificate of registration is section 45-IA of the Reserve Bank of India Act, 1934. Supervisory returns are now filed under the Reserve Bank’s directions on filing of supervisory returns, not under the 2020 NBS list.