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RBI’s Guidelines for NBFC MFI
       December 2011




       Riskpro, India


              1
RBI now regulates MFI industry
   A Sub-Committee of the Central Board of the Reserve Bank (Chairman: Shri Y. H.
    Malegam) was constituted to study issues and concerns in the MFI sector
   RBI has introduced Micro Finance Institutions(MFIs) as a new category of Non Banking
    Financial Companies (NBFC).
   The RBI said that NBFC-MFI will have the following features
         Will be a non Deposit taking NBFC.
         Have minimum net owned funds of Rs 5 crores
         Not less than 85% of its net assets being under qualifying assets.
   A major move to regulate a very sensitive financing sector
   Aims at ensuring consumer protection



                                        Definition of NBFC - MFI
    An NBFC-MFI is defined as a non-deposit taking NBFC(other than a company licensed under Section
    25 of the Indian Companies Act, 1956) that fulfils the following conditions:

    i. Minimum Net Owned Funds of Rs.5 crore (Rs 2Cr for certain MFIs)
    ii. Not less than 85% of its net assets are in the nature of “qualifying assets.”




                                                           2
Regulatory Requirements for MFI
    Comply with Corporate Governance regulation for NBFC
    Investments in Information Technology for better control, procedures and reduced costs
    All NBFC MFI need to comply with following Regulatory Requirements.
         Maintain net owned funds of Rs 5crores.
         Capital adequacy of 15% of aggregated risk weighted assets


    Asset Classification
         Standard asset - No default
         Nonperforming – Interest/principal payment has remained overdue for over 90 days


        85% of lending activity to be of High Quality for investor protection.
     85%            Such “Good loans” comply with following.
1.   Borrower’s annual income : Rural area - Less than Rs 60,000 /Urban less than Rs 1,20,000
2.   Total Loan : Max Rs. 50,000
3.   Tenure : Minimum 2 years for loans over Rs 15,000
4.   No prepayment penalty
5.   Lending without collateral;
6.   Repayment of instalments (weekly, fortnightly or monthly instalments) at the choice of the borrower
                                                       3
Consumer protection under MFI Regulations
   All NBFC-MFIs shall maintain an aggregate margin cap of not more than 12%.
   NBFC-MFIs shall not collect any Security Deposit/ Margin
   Standard form of loan agreement
   Not more than two NBFC-MFIs should lend to the same borrower
   All sanctioning and disbursement of loans should be done only at a central location and more than
    one individual should be involved in this function


Transparency of Interest Rates
   Interest on individual loans will not exceed 26% per annum
   Processing charges shall not be more than 1 % of gross loan amount
   Effective rate of interest charged by the NBFC-MFI should be prominently displayed in all its offices
   No penalty charged on delayed payment
   Loan card (similar to a Bank pass book) with details provided to each Borrower


Recovery
   Ensure Code of Conduct and systems are in place for recruitment, training and supervision of
    recovery staff
   Recovery only at Central office. If Borrower fails to appear there, then recovery at office/residence

                                                         4
Who is Riskpro… Why us?


                 ABOUT US                                                    MISSION
   Riskpro is an organisation of member firms
    around India devoted to client service                   Provide integrated risk management
    excellence. Member firms offer wide range                 consulting services to mid-large sized
    of services in the field of risk management.              corporate /financial institutions in India
   Currently it has offices in three major cities           Be the preferred service provider for
    Mumbai, Delhi and Bangalore and alliances                 complete Governance, Risk and Compliance
    in other cities.                                          (GRC) solutions.
   Managed by experienced professionals with
    experiences spanning various industries.




         VALUE PROPOSITION                                            DIFFERENTIATORS
   You get quality advisory, normally delivered
    by large consulting firms, at fee levels                  Risk Management is our main focus
    charged by independent & small firms
                                                              Over 200 years of cumulative experience
   High quality deliverables
                                                              Hybrid Delivery model
   Multi-skilled & multi-disciplined organisation.
                                                              Ability to take on large and complex projects
   Timely completion of any task                              due to delivery capabilities
   Affordable alternative to large firms                     We Hold hands, not shake hands.

                                                      5
Risk Management Advisory Services

           Basel II/III Advisory               Corporate Risks                            Information Security
              Market Risk                        Enterprise Risk Assessment                IS Audit
              Credit Risk                        Fraud Risk                                Information Security
              Operational Risk                   Risk based Internal Audit                 IT Assurance
              ICAAP                              Operations Risk                           IT Governance
                                                  Forensic services
SERVICES




           Operational Risk                    Governance                                 Other Risks
              Process reviews                    Corporate Governance                      Business/Strategic Risk
              Policy/ Process Review             Business Strategic risk                   Reputation Risk
              Process Improvement                Fraud Risk                                Outsourcing Risk
              Compliance Risk                    Forensic Accounting                       Contractual Risk




                              Training                                              Recruitment
                      Banking – E Learning                                        Virtual Risk Managers
                      Corporate Training                                          Full Time Risk Professionals
                      Regular Risk Management Training                            Part time Risk Professionals
                      Online Training material
                                                                                   Risk Managers on call – free
                      Workshops / Events




                                                            6
Contacts and Office Locations
Corporate           Mumbai                         Delhi                       Bangalore
                    Manoj Jain                     Rahul Bhan                  Casper Abraham
                    Director                       Director                    Director
                    M- 98337 67114                 M- 99680 05042              M- 98450 61870
  info@riskpro.in
                    manoj.jain@riskpro.in          rahul.bhan@riskpro.in       casper.abraham@riskpro.in
  www.riskpro.in
                    Shriram Gokte                  Raj Sawhney
                    Principal - Information Risk   Principal – Business Risk
                    M- 98209 94063                 M- 99711 03510
                    shriram.gokte@riskpro.in       raj.sawhney@riskpro.in

Ahmedabad           Pune                           Agra
Maulik Manakiwala   M.L. Jain                      Alok Kumar Agarwal
Associate Firm      Principal – Strategy Risk      Associate Firm
M - 91 9825640046   M- 9822011987                  M- 99971 65253
                    mljain@riskpro.in
Gourav Ladha
Sap Risk Advisory
M- 97129 52955




                                                THANKS
                                                      7

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Riskpro Risk Alert: RBI regulates MFI

  • 1. RBI’s Guidelines for NBFC MFI December 2011 Riskpro, India 1
  • 2. RBI now regulates MFI industry  A Sub-Committee of the Central Board of the Reserve Bank (Chairman: Shri Y. H. Malegam) was constituted to study issues and concerns in the MFI sector  RBI has introduced Micro Finance Institutions(MFIs) as a new category of Non Banking Financial Companies (NBFC).  The RBI said that NBFC-MFI will have the following features  Will be a non Deposit taking NBFC.  Have minimum net owned funds of Rs 5 crores  Not less than 85% of its net assets being under qualifying assets.  A major move to regulate a very sensitive financing sector  Aims at ensuring consumer protection Definition of NBFC - MFI An NBFC-MFI is defined as a non-deposit taking NBFC(other than a company licensed under Section 25 of the Indian Companies Act, 1956) that fulfils the following conditions: i. Minimum Net Owned Funds of Rs.5 crore (Rs 2Cr for certain MFIs) ii. Not less than 85% of its net assets are in the nature of “qualifying assets.” 2
  • 3. Regulatory Requirements for MFI  Comply with Corporate Governance regulation for NBFC  Investments in Information Technology for better control, procedures and reduced costs  All NBFC MFI need to comply with following Regulatory Requirements.  Maintain net owned funds of Rs 5crores.  Capital adequacy of 15% of aggregated risk weighted assets  Asset Classification  Standard asset - No default  Nonperforming – Interest/principal payment has remained overdue for over 90 days 85% of lending activity to be of High Quality for investor protection. 85% Such “Good loans” comply with following. 1. Borrower’s annual income : Rural area - Less than Rs 60,000 /Urban less than Rs 1,20,000 2. Total Loan : Max Rs. 50,000 3. Tenure : Minimum 2 years for loans over Rs 15,000 4. No prepayment penalty 5. Lending without collateral; 6. Repayment of instalments (weekly, fortnightly or monthly instalments) at the choice of the borrower 3
  • 4. Consumer protection under MFI Regulations  All NBFC-MFIs shall maintain an aggregate margin cap of not more than 12%.  NBFC-MFIs shall not collect any Security Deposit/ Margin  Standard form of loan agreement  Not more than two NBFC-MFIs should lend to the same borrower  All sanctioning and disbursement of loans should be done only at a central location and more than one individual should be involved in this function Transparency of Interest Rates  Interest on individual loans will not exceed 26% per annum  Processing charges shall not be more than 1 % of gross loan amount  Effective rate of interest charged by the NBFC-MFI should be prominently displayed in all its offices  No penalty charged on delayed payment  Loan card (similar to a Bank pass book) with details provided to each Borrower Recovery  Ensure Code of Conduct and systems are in place for recruitment, training and supervision of recovery staff  Recovery only at Central office. If Borrower fails to appear there, then recovery at office/residence 4
  • 5. Who is Riskpro… Why us? ABOUT US MISSION  Riskpro is an organisation of member firms around India devoted to client service  Provide integrated risk management excellence. Member firms offer wide range consulting services to mid-large sized of services in the field of risk management. corporate /financial institutions in India  Currently it has offices in three major cities  Be the preferred service provider for Mumbai, Delhi and Bangalore and alliances complete Governance, Risk and Compliance in other cities. (GRC) solutions.  Managed by experienced professionals with experiences spanning various industries. VALUE PROPOSITION DIFFERENTIATORS  You get quality advisory, normally delivered by large consulting firms, at fee levels  Risk Management is our main focus charged by independent & small firms  Over 200 years of cumulative experience  High quality deliverables  Hybrid Delivery model  Multi-skilled & multi-disciplined organisation.  Ability to take on large and complex projects  Timely completion of any task due to delivery capabilities  Affordable alternative to large firms  We Hold hands, not shake hands. 5
  • 6. Risk Management Advisory Services Basel II/III Advisory Corporate Risks Information Security  Market Risk  Enterprise Risk Assessment  IS Audit  Credit Risk  Fraud Risk  Information Security  Operational Risk  Risk based Internal Audit  IT Assurance  ICAAP  Operations Risk  IT Governance  Forensic services SERVICES Operational Risk Governance Other Risks  Process reviews  Corporate Governance  Business/Strategic Risk  Policy/ Process Review  Business Strategic risk  Reputation Risk  Process Improvement  Fraud Risk  Outsourcing Risk  Compliance Risk  Forensic Accounting  Contractual Risk Training Recruitment  Banking – E Learning  Virtual Risk Managers  Corporate Training  Full Time Risk Professionals  Regular Risk Management Training  Part time Risk Professionals  Online Training material  Risk Managers on call – free  Workshops / Events 6
  • 7. Contacts and Office Locations Corporate Mumbai Delhi Bangalore Manoj Jain Rahul Bhan Casper Abraham Director Director Director M- 98337 67114 M- 99680 05042 M- 98450 61870 info@riskpro.in manoj.jain@riskpro.in rahul.bhan@riskpro.in casper.abraham@riskpro.in www.riskpro.in Shriram Gokte Raj Sawhney Principal - Information Risk Principal – Business Risk M- 98209 94063 M- 99711 03510 shriram.gokte@riskpro.in raj.sawhney@riskpro.in Ahmedabad Pune Agra Maulik Manakiwala M.L. Jain Alok Kumar Agarwal Associate Firm Principal – Strategy Risk Associate Firm M - 91 9825640046 M- 9822011987 M- 99971 65253 mljain@riskpro.in Gourav Ladha Sap Risk Advisory M- 97129 52955 THANKS 7