Home India Reserve Bank of India COVID-19 – Regulatory Package...
Date: 2020-03-27 Category: Not Applicable State: Union Government Country: India

COVID-19 – Regulatory Package

Issued by Reserve Bank of India · Not Applicable

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Executive Summary & Key Takeaways

Executive Summary: This circular from the Reserve Bank of India, dated March 27, 2020, outlines regulatory measures to mitigate debt servicing burdens caused by the COVID-19 pandemic and ensure business continuity. It permits lending institutions to grant a moratorium on term loan payments and defer interest recovery on working capital facilities between March 1, 2020, and May 31, 2020. The circular also addresses the easing of working capital financing and classification of Special Mention Accounts (SMA) and Non-Performing Assets (NPA). Key Points / Main Content: Rescheduling of Payments: * Lending institutions can grant a three-month moratorium on term loan installments falling due between March 1, 2020, and May 31, 2020. * The repayment schedule and residual tenor of such loans will be shifted by three months after the moratorium. * Interest will continue to accrue on the outstanding loan amount during the moratorium period. * Recovery of interest applied to working capital facilities (CCOD) can be deferred from March 1, 2020, to May 31, 2020. * Accumulated accrued interest shall be recovered immediately after the completion of the deferment period. Easing of Working Capital Financing: * Lending institutions may recalculate the drawing power for CCOD facilities by reducing margins or reassessing the working capital cycle until May 31, 2020. * This relief is contingent on the lending institutions satisfying themselves that the same is necessitated on account of the economic fallout from COVID19. * Accounts provided relief under these instructions shall be subject to subsequent supervisory review. Classification as SMA and NPA: * Moratorium/deferment/recalculation of drawing power will not be treated as a concession or change in terms due to the borrower's financial difficulty. * Asset classification downgrade will not occur solely due to these measures. * The asset classification of term loans and the SMA status of working capital facilities will be determined based on revised due dates and terms. * Rescheduling of payments will not qualify as a default for supervisory reporting or reporting to Credit Information Companies (CICs). Other Conditions: * Lending institutions must frame Board-approved policies for providing the reliefs, including objective criteria for granting relief under paragraph 4, and disclose them publicly. * For borrower exposures of ₹5 crore or above as of March 1, 2020, banks must develop an MIS on the reliefs provided. * The instructions in this circular are effective immediately. Impact Analysis: Lending Institutions (All Commercial Banks, Small Finance Banks, Local Area Banks, Regional Rural Banks, Cooperative Banks, All India Financial Institutions, NBFCs including Housing Finance Companies): * Impact: Permitted to provide moratoriums and deferments, recalculate drawing power, and must adhere to the specified guidelines for asset classification and reporting. * Action Required: Frame Board-approved policies, implement the measures outlined in the circular, develop MIS for exposures above ₹5 crore, and ensure proper communication and implementation down the line. Borrowers: * Impact: Eligible for moratoriums on term loans, deferment of interest on working capital facilities, and potential recalculation of drawing power, which may ease their debt servicing burden. * Action Required: Contact their lending institutions to understand the available reliefs and comply with the terms and conditions. Credit Information Companies (CICs): * Impact: Required to ensure that actions taken by lending institutions do not adversely impact the credit history of the beneficiaries. * Action Required: Adjust their reporting mechanisms to reflect the regulatory reliefs provided without negatively impacting borrowers' credit scores.

Key Entities Referenced

Reserve Bank of India: The central bank of India, the primary regulator mentioned in the document. COVID-19: The Coronavirus Disease 2019 pandemic, the crisis that prompted the regulatory package. Small Finance Banks: A type of bank in India that furthers financial inclusion by providing savings vehicles and credit to small businesses, small and marginal farmers, micro and small industries, and other unorganized sector entities. Regional Rural Banks: Government backed banks operating at regional level in India All-India Financial Institutions: Financial institutions that operate at the national level in India. Non-Banking Financial Companies: A financial institution that provides banking services without meeting the legal definition of a bank. Prudential Framework for Resolution of Stressed Assets Directions, 2019: A framework issued by the Reserve Bank of India for the resolution of stressed assets. Credit Information Companies: Companies that collect credit information about borrowers and provide it to lenders.
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भारतीय �रजवर् ब�क __________________RESERVE BANK OF INDIA _________________ www.rbi.org.in RBI/2019-20/186 DOR.No.BP.BC.47/21.04.048/2019-20 March 27, 2020 All Commercial Banks (including Small Finance Banks, Local Area Banks and Regional Rural Banks) All Primary (Urban) Co-operative Banks/State Co-operative Banks/ District Central Co-operative Banks All All-India Financial Institutions All Non-Banking Financial Companies (including Housing Finance Companies) Madam / Dear Sir, COVID-19 – Regulatory Package Please refer to the Statement of Development and Regulatory Policies released on March 27, 2020 where inter alia certain regulatory measures were announced to mitigate the burden of debt servicing brought about by disruptions on account of COVID-19 pandemic and to ensure the continuity of viable businesses. In this regard, the detailed instructions are as follows: (i) Rescheduling of Payments – Term Loans and Working Capital Facilities 2. In respect of all term loans (including agricultural term loans, retail and crop loans), all commercial banks (including regional rural banks, small finance banks and local area banks), co-operative banks, all-India Financial Institutions, and NBFCs (including housing finance companies) (“lending institutions”) are permitted to grant a moratorium of three months on payment of all instalments1 falling due between March 1, 2020 and May 31, 2020. The repayment schedule for such loans as also the residual tenor, will be shifted across the board by three months after the moratorium period. Interest shall continue to accrue on the outstanding portion of the term loans during the moratorium period. 1 Instalments will include the following payments falling due from March 1, 2020 to May 31, 2020: (i) principal and/or interest components; (ii) bullet repayments; (iii) Equated Monthly instalments; (iv) credit card dues.3. In respect of working capital facilities sanctioned in the form of cash credit/overdraft (“CC/OD”), lending institutions are permitted to defer the recovery of interest applied in respect of all such facilities during the period from March 1, 2020 upto May 31, 2020 (“deferment”). The accumulated accrued interest shall be recovered immediately after the completion of this period. (ii) Easing of Working Capital Financing 4. In respect of working capital facilities sanctioned in the form of CC/OD to borrowers facing stress on account of the economic fallout of the pandemic, lending institutions may recalculate the ‘drawing power’ by reducing the margins and/or by reassessing the working capital cycle. This relief shall be available in respect of all such changes effected up to May 31, 2020 and shall be contingent on the lending institutions satisfying themselves that the same is necessitated on account of the economic fallout from COVID-19. Further, accounts provided relief under these instructions shall be subject to subsequent supervisory review with regard to their justifiability on account of the economic fallout from COVID-19. Classification as Special Mention Account (SMA) and Non-Performing Asset (NPA) 5. Since the moratorium/deferment/recalculation of the ‘drawing power’ is being provided specifically to enable the borrowers to tide over economic fallout from COVID-19, the same will not be treated as concession or change in terms and conditions of loan agreements due to financial difficulty of the borrower under paragraph 2 of the Annex to the Reserve Bank of India (Prudential Framework for Resolution of Stressed Assets) Directions, 2019 dated June 7, 2019 (“Prudential Framework”). Consequently, such a measure, by itself, shall not result in asset classification downgrade. 6. The asset classification of term loans which are granted relief as per paragraph 2 shall be determined on the basis of revised due dates and the revised repayment schedule. Similarly, working capital facilities where relief is provided as per paragraph 3 above, the SMA and the out of order status shall be evaluated considering the 2application of accumulated interest immediately after the completion of the deferment period as well as the revised terms, as permitted in terms of paragraph 4 above. 7. The rescheduling of payments, including interest, will not qualify as a default for the purposes of supervisory reporting and reporting to Credit Information Companies (CICs) by the lending institutions. CICs shall ensure that the actions taken by lending institutions pursuant to the above announcements do not adversely impact the credit history of the beneficiaries. Other Conditions 8. Lending institutions shall frame Board approved polices for providing the above- mentioned reliefs to all eligible borrowers, inter alia, including the objective criteria for considering reliefs under paragraph 4 above and disclosed in public domain. 9. Wherever the exposure of a lending institution to a borrower is `5 crore or above as on March 1, 2020, the bank shall develop an MIS on the reliefs provided to its borrowers which shall inter alia include borrower-wise and credit-facility wise information regarding the nature and amount of relief granted. 10. The instructions in this circular come into force with immediate effect. The Board of Directors and the key management personnel of the lending institutions shall ensure that the above instructions are properly communicated down the line in their respective organisations, and clear instructions are issued to their staff regarding their implementation. Yours faithfully, (Saurav Sinha) Chief General Manager-in-Charge 3

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