4. What is NBFC ?
From the text of sections 45-I (a), (c) & (f).
Non –banking financial Company means, which is engaged in-
financing
acquisition of shares, stocks, bonds, debentures or securities -
letting or delivering of any goods to a hirer
carrying on of any class of insurance business
managing, conducting or supervising, as a foreman, agent or in
any other capacity, of chits or kuries
collecting for any purpose or under any scheme or arrangement,
monies in lump sum or otherwise, by way of subscriptions or by
sale of units or in any other manner and awarding prizes or gifts,
whether in cash or kind or disbursing monies in any other way, to
persons from whom monies are collected or to any other person.
5. But doesn’t include-
Which carries as its principal business
Agricultural operations
Industrial activity
Purchase or sale of any goods (other than securities)
or the providing of any services
Purchase, construction or sale of immovable
property, so, however, that no portion of income of
the institution is derived from the financing of
purchases, constructions or sales of immovable
property by other persons
6. Requirement of Registration and Net Owned
Fund
Section 45-IA of RBI Act, 1934
No NBFC shall commence or carry on the business of non-
banking financial institution without-
• Obtaining a certificate of registration
and
• Having net owned fund
Notification No. DNBS. 132/CGM(VSNM)-99, DATED 20-
4-1999
Net owned fund to be 200 lakhs rupees for a NBFC which
commences the business of a non-banking financial
institution on or after 21st April, 1999 and 25 lakhs rupees for
whose application for certificate of registration under section
45-IA is submitted to RBI on or before 20th April, 1999.
7. Commencement of Business by
NBFC
RBI2013-14/46DNBS(PD)CC
No./344.03.02.001/2013-14
NBFC , which is in the Receipt of a COR from the
Bank must necessarily commence NBFCs Business
within six months of obtaining COR. If the Business
is not commenced by the company within a period
of six months , the COR shall stand withdrawn
automatically.
8. Computation of Net Owned Fund
(a) The aggregate of the paid-up equity capital and free reserves as disclosed
in the latest balance sheet of the Company after deducting therefrom
i . Accumulated balances of loss
ii. Deferred revenue expenditure
iii. Other intangible assets and
(b) further reduced by the amounts representing
(1) Investment of such company in shares of
i. Its subsidiaries
ii. Companies in same group
iii. All other Non-Banking Financial Companies
and
(2) The book value of debentures, bonds, outstanding loans and advances (including hire
purchase and lease finance) made to, and deposit with
i. Subsidiaries of such company and
ii. Companies in same group
To the extent such amount exceeds ten percent of (a) above
9. Principal Business Criteria
Press Release 99/1269 dated April 8, 1999
A company is treated as NBFC if its financial assets are
more than 50% of its total assets ( net of intangible
assets) and income from these financial assets is more
than 50% of the gross income.
Note :-
RBI/2011-12/446
DNBS (PD) CC.No.259/.03.02.59/2011-12
Investments in fixed deposits can not be treated as
financial assets and receipt of Interest Income from
fixed deposits with bank can not be treated as Income
from financial assets.
10. Exemption From The Provisions Of RBI Act,
1934
RBI/2013-14/38
DNBS.PD.CC.No.336/03.02.004/2013-1
Exemption has been provided to following :-
i. Housing Finance Institutions
ii. Merchant Banking Company
iii. Micro Finance Companies
iv. Mutual Benefit Companies
v. Government Companies
vi. Venture Capital Fund Companies
vii. Insurance/Stock Exchange/Stock Broker/Sub-Broker
viii.Others - Nidhi Companies, Chit Companies,
Securitisation & Reconstruction Companies, Mortgage
Guarantee Companies & Core Investment Companies
11. Exemption To Venture Capital
Fund
Provided VCF holding certificate of Registration of
SEBI and not holding or accepting public deposit.
12. Exemption To Micro Finance
Companies
Provided they are engaged in micro finance activities,
providing credit not exceeding Rs. 50,000 for a business
enterprise and Rs. 1,25,000 for meeting the cost of a
dwelling unit to any poor person for enabling him to
raise his level of Income and standard of living and
Licensed under section 25 of the Companies Act, 1956
And Not accepting public deposits
13. Exemption To Merchant Bankers
Provided it is registered with SEBI and carrying on
the business of merchant banker in accordance with
SEBI Merchant Banking (Rules), 1992.
Acquires securities only as a part of its merchant
banking business
Doesn’t carry on any other financial activity referred
to in section 45I(c) of RBI Act, 1934
Doesn’t accept or hold Public deposits
14. Reserve Fund
Section 45-IC
Every non-banking financial company shall create a
reserve fund and transfer therein a sum not less than
twenty percent of its net profit every year as disclosed
in the profit & loss account & before any dividend is
declared.
No appropriation of any sum from Reserve fund shall
be made except for the purpose as may be specified and
every such appropriation shall be reported within 21
days from the date of such withdrawal which for
sufficient cause may be extended by Bank.
15. Registration of NBFC
Application for a Certificate of Registration should be submitted to “The General
Manager/Deputy General Manager/ Department of Non-Banking Supervision,
Reserve Bank of India, Regional Office.”
Documents required to be enclosed to the application form-
1. Identification Particulars
2. Statement on prudential norms
3. Information about the management
4. Certified copies of Certificate of Incorporation and Certificate of Commencement
of Business.
5. A Board Resolution specifically approving the submission of the application and its
contents.
6. A copy each of the Profit & Loss Account & Audited Balance Sheet for the last 3
years or for such shorter period as are available ( for Companies already in
existence)
7. Certified copies of up-to-date Memorandum and Articles of Association of the
Company.
8. Business plan of the Company for the next three years giving details of its (a) thrust
of business; (b) market segment; and (c) projection of investments and income.
9. A company which is incorporated before January 9, 1997 and has net owned fund of
less than 25 lakhs as on the date of application, may also furnish a time- bound
program as how it proposes to attain the minimum net owned fund of Rs. 25 lakhs
16. Cancellation of Certificate of Registration
& Appeal against thereof
The Reserve Bank is empowered to cancel the
certificate of registration issued to any NBFC for
failure on the part of NBFC to fulfil conditions as laid
down under section 45-IA of the RBI Act, 1934.
A company, aggrieved by the Reserve Bank’s order of
rejection of application or cancellation of certificate
of registration may prefer an appeal to Central
Government within a period of 30 days.
18. Classification of NBFC
Based on Nature of
Business Based on Deposits
RBI2013-14/46DNBS(PD)CC
No./344.03.02.001/2013-14
• Asset Finance Company
• Investment Company
• Loan Company
• Infrastructure Company
• Core Investment
Companies-ND-SI
• Deposit Taking NBFC
(NBFC-D)
• Non-Deposit Taking NBFC
( NBFC-ND)
NBFC-ND having asset size
100 Cr. Or more as per latest
audited Balance Sheet of the
Company will be classified as
systemically important non-
deposit taking NBFC, in short
NBFC-ND.
19. Applicability of Rules, Regulations
& Directions
NBFC-D NBFC-ND
• Non-Banking Financial Companies
Acceptance of Public Deposits ( Reserve
Bank) Directions, 1998
• Non- Banking Financial ( Deposit
Accepting or Holding) Companies
Prudential Norms ( Reserve Bank)
Directions, 2007
• Non- Banking Financial Companies
Auditor’s Report ( Reserve Bank)
Directions, 2008
• Reserve Bank of India ( Non- Banking
Financial Companies) Returns
Specifications, 1997
• Non- Banking Financial Companies
( Deposit Accepting) ( Approval of
Acquisition or Transfer of Control)
Directions, 2009
• Miscellaneous Non- Banking Companies
( Reserve Bank) Directions, 1977
• Non- Banking Financial (
Non- Deposit Accepting or
Holding) Companies
Prudential Norms ((Reserve
Bank) Directions 2007
• Non- Banking Financial
Companies Auditor’s Report
(Reserve Bank) Directions,
2008
20. Returns to be filed by NBFC
RBI/2013-14/37
DNBS.PD.CC.No.335/03.10.042/2013-14
By Deposit Taking NBFC
By Non- Deposit Taking
NBFC
• NBS-1 Quarterly Returns On
Deposits
• NBS-2 Quarterly Return on
Prudential Norms
• NBS-3 Quarterly Return on
Liquid Assets
• NBS-4 Annual Return of critical
parameters by rejected company
holding deposits
• NBS-6 Monthly Return on
Exposure to Capital Market by
NBFC-D having Asset Size 100
Cr. Or more
• Audited Balance Sheet and
Auditor’s Report
For NBFC-ND-SI
• NBS-7 Quarterly Statement of
Capital Funds, Risk Weighted
ASSETS, Risk Asset Ratio etc.
• Monthly Return on Important
Parameters
• ALM Returns :
i. ALM-1 Statement of short term
dynamic liquidity-Monthly
ii. ALM-2 Statement of structural
liquidity-Half-yearly
iii. ALM-3 Statement of Interest
Rate Sensitivity-Half-YEARLY
iv. ALM-Yearly
21. Continued….
By Deposit Taking NBFC By Non- Deposit Taking
NBFC
Continued.. • Annual Certificate from
auditors.
• NBFC With FDI - half yearly
(ending March & September)
Certificate from Auditors.
• With Regard to Overseas
Investment- Quarterly Return
For NBFC ( more than 50 Cr.
But less than 100 Cr.) Quarterly
Return on basic information
• Branch office Return
22. Applicability of Certain Directions, Regulations,
Notifications on NBFC-ND-SI
• NBF ( Non- Deposit Accepting or Holding) Companies Prudential
Norms ( Reserve Bank) Directions, 2007
Para-8 Asset Classification
Standard Assets
Sub-Standard Assets
Doubtful Assets
Loss Assets
Para-9A Provision for Standard Assets
. 25% of the outstanding
• shall be shown seperately as contingent provision against standard assets.
Para-10 Disclosure in Balance Sheet
For every NBFC- provisions made as per Para 9 & 9A
For NBFC-ND-SI – 1. CRAR 2. Exposure to Real estate Sector 3. Maturity
Pattern of Asset & Liability
23. Continued…
Para 11- Constitution of Audit Committee
• By the NBFC having Assets of 50 cr. or more as per latest
audited balance sheet of the company.
• consisting of not less than three members of Board of
Directors.
Note:-Audit Committee constituted under section 292A of companies Act, 1956
shall be the Audit Committee for this purpose with the samre powers, functions &
duties as laid down under section 292A of Companies Act, 1956.
Para 12- Accounting Year
• Preparation of Balance Sheet & Profit & loss account as on March 31 every
year.
• For extension prior approval of RBI is necessary before approaching
Registrar of Companies.
• Finalization of Balance Sheet within 3 month from the date to which it
pertains.
24. Continued…
Para 13 Schedule to the Balance Sheet
Particulars have been given in the Annex.
Para 15 Submission of Certificate from Auditors
• Within one month from the finalization of Balance sheet and in any case not later than
December 30th of that year.
• Such Certificate shall also indicate the Asset Income pattern of the Company
Para 16 Requirement as to Capital Adequacy
• A minimum Capital Adequacy Ratio consisting of Tier I ( NOF) & Tier II Capital
• Not less than 15% of its aggregate Risk Weighted Assets on Balance Sheet and of Risk
Adjusted Value of off-balance sheet items.
Para 18 Concentration of Credit
• Lend to single borrower & single group of borrowers not exceeding 15% & 25% respectively
of its owned fund.
• Invest in the shares of another company or single group of companies not exceeding 15% &
25% respectively of its owned fund.
• Lend & Invest both not exceeding 25% or 40% of its owned fund to a single party or to a
single group of parties.
Subject to certain provisions as provided in the directions.
25. Continued…
Para 19 Information with regard to change
Information not later than one months from the occurrence of any change in:
(a) The Complete postal address, telephone number/s & fax number/s of the
Registered/corporate office;
(b) The Names & residential addresses of the directors of the company;
(c) The Names & official designation of its Principal officers;
(d) The names & office address of the auditors of the company;
(e) The specimen signatures of the officers authorized to sign on behalf of the
company
Para 20A NBFC Not To Be Partners In Partnership Firms
RBI/2012-13/526
DNBS.PD/CC.No.328/03.02.002/2012-13
Partnership Firms include LLPs & AOP.
Which had already contributed to the Capital of a LLPs /AOP are adviced to
seek early retirement.
26. Continued…
RBI2013-14/42 DNBS(PD)CC No./340.03.02.042/2013-14
FPC-Fair Practice Code
• The Board of Directors of NBFC should lay down the appropriate grievance
redressal mechanism within the organization to resolve disputes.
• All NBFC have to display the the following information at their branches/
places where business is transacted:
1. The name and contact details of grievance redressal officer
2. If complaint/dispute is not redressed within a period of one month, appeal
may be preferred to the office-in-charge of Regional office of DNBS of RBI.
3. FPC be put in place by all NBFC with the approval of Boards within one
months from the date of issue of circular.
4. NBFC will have the freedom of drafting the FPC, But in no way sacrificing
the spirit underlying the above guidelines.
5. The same shall be put on their web-site, if any.
27. Accounting for Taxes on Income-AS 22
RBI/2012-13/33
DNBS (PD). CC.No.290/03.02.001/2012-13
As creation of DTA ( Deferred Tax Asset) would give
rise to certain issues impacting the balance sheet of the
Company, It is clarified that the Regulatory treatment
to be given is as under :-
DTA will be treated as an intangible asset and should be
deducted from Tier I capital.
28. Core Investment Company
RBI /2012-13/30
DNBS (PD) CC No. 291 / 03.02.001/ 2012-13 July 2, 2012
The Bank had announced in the Annual Policy 2010-
2011 that companies which have their assets
predominantly as investments in shares for holding
stake in group companies but not for trading, and also
do not carry on any other financial activity, i.e., Core
Investment Companies, (CICs), justifiably deserve a
differential treatment in the regulatory prescription
applicable to Non-Banking Financial Companies
which are non deposit taking and systemically
important to this extent .
29. What is CIC ???
A non-banking financial company carrying on the business of
acquisition of shares and securities and which satisfies the following
conditions as on the date of last audited balance sheet :-
i. It holds not less than 90% of its assets in the form of investment in
equity shares, preference shares, bonds, debentures, debt or loans
in group companies;
ii. Its investments in equity shares (including instruments
compulsorily convertible into equity shares within a period not
exceeding 10 years from the date of issue) in group companies
constitutes not less than 60% of its net assets as mentioned in
clause ( i) above;
iii. It doesn’t trade in its investments in shares, bonds, debentures,
debt or loans in group companies except through block sale for the
purpose of dilution or disinvestment;
iv. It doesn’t carry on any other financial activity referred to in section
45-I(c ) & 45-I(f) of Reserve Bank of India Act, 1934 except
30. Continued…
(a) Investment in
i. Bank deposits’
ii. Money market instrument, including money market
mutual funds
iii. Government securities, &
iv. Bonds or debentures issued by group companies and
v. Issuing guarantee on behalf of group companies.
31. When CIC to be considered not carrying on the business of
acquisition of shares and securities???
Core Investment Companies (CICs) were not considered as carrying on
the business of acquisition of shares and securities in the following
circumstances, namely,
(I ) not less than 90% of their assets were in investments in shares for
the purpose of holding stake in the investee companies;
(ii) they were not trading in these shares except for block sale (to dilute
or divest holding);
(iii) they were not carrying on any other financial activities; and
(iv) they were not holding / accepting public deposits.
As such, companies fulfilling the above criteria were not required to
obtain Certificate of Registration (COR) from RBI under Section 45 IA
of the RBI Act 1934. it is very difficult to determine whether a company
has invested in the shares of another company for the purpose of
holding stake or for the purpose of trade. It was therefore decided that
investing in shares of other companies, even for the purpose of holding
stake should also be regarded as carrying on the business of acquisition
of shares in terms of Section 45I(c) (ii) of RBI Act.
32. Companies in the Group
Para 3(1)(b) of
N/No. DNBS.(PD)219/CGM(US)-2011 dated Jan. 5, 2011
Companies in the group means an arrangement involving
two or more entities related to each other through any of the
following relationship, viz., Subsidiary-parent (defined in
terms of AS 21), Joint Venture ( defined in terms of AS
27), Associate ( defined in terms of AS 23), Promoters –
Promotee (as provided in the SEBI ( Acquisition of
shares & takeover) Regulations 1997) for listed
companies, a related party ( defined in terms of AS
18)Common brand name and investment in equity
shares of 20% & above
33.
34. Revival of 1999 circular with additional
requirement
Recently in a circular is issued in 2006, the Press Release
was in a way revived from its ashes by the RBI, and a new
credential was given to it in the form of requirement of an
annual certificate to be given by the auditor of the NBFC in
support of commencement/continuance of business of
NBFI and fulfilling the criteria of “principal business”.
The Non-Banking Financial Companies Prudential Norms
(Reserve Bank) Directions, 2007 – (both deposit taking and
non-deposit taking), also reiterated the requirement of
obtaining auditors certificate with the addition that such
certificate shall also indicate the asset/income pattern of the
NBFC for making it eligible for classification as Asset
Finance Company, Investment Company or Loan Company.
35. Continued….
Such a certificate from the auditors was required to be
submitted with reference to the position of the
company as at the end of the financial year ended
March 31 and to be submitted latest by June 30 every
year.
36. Intention of RBI behind Auditor’s
certification
The Reserve Bank of India in the circulars issued by it in
this regard from time to time has also clarified the intent of
obtaining such annual certificate. It is a usual practice that
the RBI grants Certificate of Registration (CoR) to new
companies on the basis of their intention to engage in the
business of NBFI, however, such an intention may not have
materialized and the said company may not engage in
NBFI activity even though it holds CoR from the RBI. In
the case of an existing company which holds CoR to carry
on NBFI business, its business profile may have undergone
a change over a period of time and the criteria of principal
business may not be fulfilled anymore.
37. Continued…
Hence, it is possible, that there would be companies
holding the COR to commence/carry on the business
of NBFI without actually undertaking NBFI activity.
These companies continue to hold the COR even
though they are not required to hold the COR granted
by RBI. Thus, to ensure that only NBFCs which are
actually carrying out financial business as its principal
business holds COR, the requirement of annual
certification from the auditors have been brought in.
38. Are Assets –Income determining
factors???
There can be a case where a company runs several
businesses, and the income/asset attributable to none
of the business is over 50% - say, a company has
business X, 30%, business Y, 30% and business Z 40%.
Z is a financial business. As per RBI circular, this
company does not have principal financial business.
Does that mean the company does not have any
principal business at all?
39. Continued…
It is quite natural that the income of a company cannot
be stable year after year. Income may fluctuate and, the
income in a particular year may fall below 50%. Strictly
by the circular, a temporal decline in the income below
the required threshold disqualifies an NBFC from
carrying on business as such.
What implications will be ?
Deregistration/disqualification have?
Will the company stop what it was doing?
Will the company be required to surrender its COR?
40. Continued…
the next year the income level of the company rises above
50%. Does that mean the company should apply for
registration all over again? This sounds patently
unreasonable.
Conclusion
there is no ambiguity in the fact that it is the primary
activity carried on by the company which gives it a
character and although the figures reported in the balance
sheet reflects the business activity of the company, but the
same cannot be the sole criteria to determine the character
of a company. Judicially also, the Courts have put weight
age on the primary activity carried on by the company
rather than its assets and income to determine its true
character.
41. Some Judicial Pronouncements…
In Assistant Registrar of Companies v. H.C. Kothari and
Others (decided on 10.10.1991) the Madras High Court in a
case concerning section 372 of the Companies Act, 1956 (since
repealed) held that “an investment company is, therefore, a
company whose principal business is the acquisition of shares,
debentures or other securities. It is clear that the income derived
from the business is not the criteria. The test would rather be, as
to what the principal business of the company is. A balance
sheet should show what the principal business of the company
is.”
42. Another Case..
In D.C. Kothari and Another v. Assistant Registrar
of Companies (decided on 24.04.1992) , the Madras
High Court observed that the term “Principal
business” though not defined under the Act, as
commonly understood, it would mean the prime
business carried on by the company at the relevant
point of time and the major source of income, etc.
43. Continued…
The Income Tax Appellate Tribunal – (Ahmedabad) in Barkha
Investments And Trading Co. Pvt. Ltd. v. Income-Tax Officer
(decided on 07.10.1997)
wherein the Supreme Court said that, in the expression, “wholly or
mainly in the dealing in or holding of investments”, the word “
mainly” in that clause must necessarily take its colour from the word
“wholly” preceding that word in those provisions. In other words, the
company which comes within the scope of those provisions must be
one whose primary business must be in the dealing in or holding of
investments. If a company engages itself in two or more equally or
nearly equal important business activities, then it cannot be said that
the company’s business consists wholly or mainly in the dealing in a
particular thing. Further, even in a case where a company has more
than one business activity and one of its activities is more substantial
than the others, unless that activity is the primary activity of the
company, it cannot be said that that company is engaged in wholly or
mainly in any one of its business activities.
44. International Perspective…
California Code of Regulations, Title 18, reg 23183 sub-section
(a) defines a “financial corporation” as a corporation which
‘predominately’ deals in money or moneyed capital in
substantial competition with the business of national banks.
In Australian Revenue Ruling No. SD 246, it was observed that in
determining a person’s principal business, consideration will be
given to a number of factors including the number of transactions,
the amount of staff time spent, and the turnover in relation to each
business activity to determine what proportion each bears to the
total business. In general, consideration will not be given to figures
contained in a
company’s balance sheet or profit and loss account where such
activities are reported on a net basis. “Principal” does not
necessarily mean “more than 50%”. If a company conducts various
businesses, the largest of which is, say, 30% of its total business
activities, that 30% activity is its principal business.
45. Conclusion..
It is thus clear that the criteria laid down by the RBI to determine the
principal business based on asset-income has been applied in a
manner which could not have been the intention. The Circular has
specified such classification as guidance to the companies which are
not required to hold COR due to non-continuation of financial
business as a principal business. It cannot be used as a weapon to de-
register/ disqualify companies from holding their COR based on a
particular year’s financial statement. The circular, in any case, is only
a guidance issued by the RBI and cannot have the force of law. It must
be interpreted in a manner to uphold “substance over form” and not
to create hindrances in the business activity of the company on the
basis of their yearly results.
46. RBI/2013-14/36
DNBS (PD) CCNo.334/03.02.001/2013-14
In addition to the Report made by the Auditor under section 227 of
the Companies Act, 1956, the Auditor shall make a separate report
to the Board of Directors of the Company.
Matters which are be included in the Report have been
specified in “NBFC Auditor’s Report ( Reserve Bank)
Directions, 2008.”
In Case of NBFC- ND:-
i. Whether the Board has passed a resolution for non-
acceptance of Public Deposits;
ii. Whether the company has accepted the Public Deposits
during the relevant period/year;
iii. Whether company has complied with the prudential norms
relating to income recognition, accounting standards, asset
classification and provision for bad debt as applicable to it in
terms of Non- banking financial ( Non- Deposit Accepting or
Holding) Companies Prudential norms ( Reserve Bank)
Directions, 2007.
47. Reporting Requirement of
Auditors
Where in the Auditor’s Report, the statement if unfavourable or
qualified, the Auditor’s Report shall also state the reason for the
same.
Exception Report :-
An Exception Report shall be given where in the opinion of Auditor, the
company has not complied with :
• the provision of chapter III B of RBI Act, 1934; or
• The NBFC Acceptance of Public Deposits ( Reserve Bank) Directions, 1998;
or
• NBF( Deposit Accepting or Holding) Companies Prudential Norms (
Reserve Bank) Directions, 2007; or
• NBF ( Non- Deposit Accepting or Holding) Companies Prudential Norms (
Reserve Bank) Directions, 2007;
containing details about non compliance in respect of the Company to the
Regional office of Department of Non- Banking Supervision.
48. RBI/2013-14/44
DNBS (PD) CC.No.342/03.10.001/2013-14
In order to enable NBFC to adopt best practices and
greater transparency in their operations following
guidelines are proposed for all Deposit Taking NBFC
with deposit sixe of Rs.20 Cr. or more and all non-
deposit taking NBFC with asset size of Rs.100 Cr. &
above.
49. Continued….
• Constitution of Audit Committee :
Same as prescribed in Directions 2007 as per Para-11.
• Constitution of Nomination Committee :
NBFC-D with deposit size of Rs. 20 Cr. or above & NBFC-ND-SI
may form a Nomination Committee to ensure “Fit & Proper”
status of proposed/existing Directors.
• Constitution of Risk Management Committee :
The market risk for NBFC with deposit size of Rs.20 Cr. or
above & NBFC-ND-SI as on the date of latest audited balance
sheet is addressed by Asset Liability Management Committee
( ALCO) constituted to monitor the asset liability gap to
mitigate the risk associated.
50. Continued…
• Disclosure and Transparency
The following information should be put up by the
NBFC TO THE Board of Directors at regular
intervals as may be prescribed by the Board in this
regard :
Progress made in putting in place a progressive
risk management system, risk management policy
& strategy followed, conformity with corporate
governance standards viz. composition of various
committees, their roles & functions, Periodicity of
meetings etc.
