The Chairman / Chairman & Managing Director/ Managing Director / Chief Executive Officer of Public Sector Banks, Private Sector Banks/ Foreign Banks (Excluding RRBs and LABs)
Central Repository of Information on Large Credits (CRILC) – Revision in Reporting
1. Please refer to DBS.Dir.OSMOS.No.3327/33.01.001/2013-14 dated September 11, 2013 along with a Directive of even date issued under Section 27(2) of BR Act 1949 introducing the “Central Repository of Large Common Exposures-Across Banks” by subsuming the erstwhile Form A return on Large Borrowers (Rs 100 million and above) in the quarterly off-site return on Large Credit. Banks have since submitted the revised Return for the quarter ended September 2013. Subsequently, RBI has issued the final Guidelines on “Early Recognition of Financial Distress, Prompt Steps for Resolution and Fair Recovery for Lenders: Framework for Revitalising Distressed Assets in the Economy” on January 30, 2014 which would be fully effective from April 1, 2014. The Guidelines, inter-alia, envisaged creation of a CRILC by RBI to collect, store, and disseminate credit data to banks.
2. According to para 1.4 of the Guidelines, the Framework will be fully effective from April 1, 2014. Hence banks must put in place necessary system and infrastructure, as also carry out necessary tests for correct outputs, well before the due date to effectively implement the Framework. In the meanwhile, we advise that the reporting format of the Return for the quarter ended December 2013 quarter has undergone revision. The revised format with explanatory footnotes on the new items including Special Mention Account 2 (SMA-2) were forwarded to the banks vide our e-mail message dated January 30, 2014. The revised format of the Return is enclosed. In addition to our earlier communications on the subject and in the light of the final Guidelines it is now advised as under:
2.1 Submission of the Return for the quarter ended December 2013
As you are aware, submission of data for the quarter ended December 2013 has been kept in abeyance vide our e-mail message dated January 16, 2014 pending revision of the XBRL installer to incorporate new data requirements in the light of the Discussion Paper for revitalising distressed assets of the economy. Banks had also been advised to be ready with the data including the new data elements for submission at short notice. The revised XBRL installer for submission of December 2013 data would be available on the secured server from February 14, 2014. Banks are advised to submit the return for the quarter ended December 2013 within 10 working days from the date when the new installer is deployed i.e. latest by February 26, 2014.
2.2 Threshold amount for Reporting of Large Exposure
The Guidelines require banks to furnish credit information to CRILC on their borrowers having aggregate fund-based and non-fund based exposure of ` 50 million and above with them. Presently the threshold limit for reporting large credit in the return is ` 100 million and above. The PAN Master is required to be revised in order to capture exposure of ` 50 million and above. The OSMOS Division would be approaching all the banks to furnish PAN details of their borrowers having fund based and / or non fund based exposure of ` 50 million and above. Banks are therefore advised to be ready with the correct PAN details duly authenticated from Income Tax records. The new reporting threshold amount would be effective from the quarter ended June 2014 onwards.
2.3 Reporting of SMA-2 Accounts
The Guidelines require banks to report, among others, the SMA status of the borrower to the CRILC. To enable banks to report SMA-2 accounts, the revised XBRL installer will contain two sheets – Sheet 1 for regular reporting on quarterly basis and Sheet 2 for reporting SMA 2 account. The Sheet 2 will be frequency neutral i.e. this sheet can be accessed whenever a bank desires to report a borrower as SMA-2. Since the mechanism for creation of Joint Lenders’ Forum (JLF) and formulation of Corrective Action Plan (CAP) are critically dependent on reporting of SMA-2 to CRILC, banks need to put in place proper MIS and reporting system so that they can report SMA-2 category account to the CRILC on the 61st day itself. The newly introduced second sheet for SMA-2 can be accessed from April 1, 2014.
2.4 Reporting of Current Account Balance
The Guidelines require banks to report outstanding current account balance of their customers (debit or credit) of ` 10 million and above. In this context, it is clarified that for the purpose of reporting in the Return banks should report outstanding Current Account balance of any client whose name appears in the PAN Master of the Return irrespective of the fact whether the client has availed any exposure (fund based and or non-fund based) or not from the bank.
It is reiterated that all banks should take utmost care about data accuracy and integrity while submitting the data on large credit to RBI, failing which penal action, as per provisions of the Banking Regulation Act, 1949 could be invoked.
(P.R. Ravi Mohan) Chief General Manager- In Charge