Executive Summary:
This circular clarifies and harmonizes Income Recognition, Asset Classification, and Provisioning (IRACP) norms across all lending institutions to ensure uniform implementation. It specifies due date requirements, clarifies SMA and NPA classifications, and addresses related aspects like 'out of order' status, interest payment-based NPA classification, and upgrading NPA accounts. Most instructions are effective immediately, except those in paragraphs 2, 8, 9 and 13.
Key Points / Main Content:
* **Due Date Specification:**
* Loan agreements must clearly specify exact due dates, repayment frequency, principal/interest breakup, and SMA/NPA classification dates.
* Borrowers must be informed of these details at loan sanction and upon subsequent changes.
* For fresh loans, compliance is required by December 31, 2021; for existing loans, compliance is required upon renewal/review.
* **SMA and NPA Classification:**
* SMA classification is based on continuous overdue days: SMA0 (up to 30 days), SMA1 (31-60 days), SMA2 (61-90 days).
* Borrower accounts must be flagged as overdue as part of day-end processes for the due date.
* SMA/NPA classification must be done as part of day-end processes for the relevant date.
* SMA classification applies to all loans, including retail loans, irrespective of exposure size (agricultural advances governed by crop season-based asset classification norms are exempt from this instruction).
* **Definition of 'Out of Order' (CCOD Accounts):**
* CCOD account is 'out of order' if:
* The outstanding balance exceeds the sanctioned limit/drawing power for 90 days continuously.
* There are no credits continuously for 90 days when the outstanding balance is less than the sanctioned limit/drawing power.
* Credits are insufficient to cover interest debited during the previous 90 days when the outstanding balance is less than the sanctioned limit/drawing power.
* **NPA Classification (Interest Payments):**
* For term loans, an account is NPA if interest applied at specified rests is overdue for more than 90 days.
* Effective from March 31, 2022.
* **Upgradation of NPA Accounts:**
* NPA accounts can be upgraded to standard assets only if the entire arrears of interest and principal are paid.
* Existing instructions apply for NPA accounts due to restructuring or non-achievement of DCCO.
* **Income Recognition (Loans with Moratorium):**
* Interest income can be recognized on accrual basis for standard accounts with interest moratoriums, subject to restructuring definitions.
* Existing norms apply to projects with DCCO deferment and gold loans for non-agricultural purposes.
* Capitalized interest during the moratorium period need not be reversed if the loan becomes NPA after the moratorium.
* **Consumer Education:**
* Lending institutions must provide consumer education on their websites and branches, explaining overdue dates, SMA/NPA classifications, and upgradation.
* Frontline officers must educate borrowers on these concepts during loan sanction/disbursal/renewal.
* Compliance is required by March 31, 2022.
Impact Analysis:
**Lending Institutions (Commercial Banks, Small Finance Banks, Local Area Banks, Regional Rural Banks, Primary Urban Cooperative Banks, State Cooperative Banks, District Central Cooperative Banks, All-India Financial Institutions, Non-Banking Financial Companies including Housing Finance Companies)**
* Impact: Must comply with the clarified and harmonized IRACP norms, including changes to due date specification, SMA/NPA classification processes, 'out of order' definitions, and NPA upgradation criteria.
* Action Required: Update loan agreements, internal systems, and processes to align with the new instructions. Implement consumer education initiatives. Ensure compliance with specified deadlines.
**Borrowers:**
* Impact: Will receive clearer loan terms regarding due dates, repayment schedules, and potential SMA/NPA classifications.
* Action Required: Understand the loan terms and implications of delayed payments on SMA/NPA classification. Review consumer education materials provided by lending institutions.
Key Entities Referenced
Reserve Bank of India (RBI): The central bank of India, which issued the circular.
Small Finance Banks: A type of bank included in the applicability of the circular.
Local Area Banks: A type of bank included in the applicability of the circular.
Regional Rural Banks: A type of bank included in the applicability of the circular.
Primary Urban Cooperative Banks: A type of bank included in the applicability of the circular.
State Cooperative Banks: A type of bank included in the applicability of the circular.
District Central Co operative Banks: A type of bank included in the applicability of the circular.
Non-Banking Financial Companies (NBFCs): Financial institutions to which the circular's instructions also apply.
RBI/2021-2022/125
DOR.STR.REC.68/21.04.048/2021-22 November 12, 2021
All Commercial Banks (including Small Finance Banks, Local Area Banks and Regional
Rural Banks) excluding Payments Banks
All Primary (Urban) Co-operative Banks/State Co-operative Banks/District Central Co-
operative Banks
All-India Financial Institutions (Exim Bank, NABARD, NHB and SIDBI)
All Non-Banking Financial Companies (including Housing Finance Companies)
Madam/Dear Sir,
Prudential norms on Income Recognition, Asset Classification and Provisioning
pertaining to Advances - Clarifications
Please refer to the Master Circular on Prudential norms on Income Recognition, Asset
Classification and Provisioning pertaining to Advances (IRACP norms) dated October 1,
2021. With a view to ensuring uniformity in the implementation of IRACP norms across
all lending institutions, certain aspects of the extant regulatory guidelines are being
clarified and/or harmonized, which will be applicable mutatis mutandis to all lending
institutions. Wherever references to circulars/instructions applicable to banks have been
made, other lending institutions may refer to instructions as applicable to them. All the
instructions in this circular, except those at paragraphs 2, 8-9 and 13, shall be effective
immediately from the date of this circular.
A. Specification of due date/repayment date
2. The extant instructions on IRACP norms specify that an amount is to be treated as
overdue if it is not paid on the due date fixed by the bank. It has been observed that duedates for repayments are sometimes not specifically mentioned in the loan agreements,
and instead a description of due dates is mentioned, leaving scope for different
interpretations. Henceforth, the exact due dates for repayment of a loan, frequency of
repayment, breakup between principal and interest, examples of SMA/NPA classification
dates, etc. shall be clearly specified in the loan agreement and the borrower shall be
apprised of the same at the time of loan sanction and also at the time of subsequent
changes, if any, to the sanction terms/loan agreement till full repayment of the loan. In
cases of loan facilities with moratorium on payment of principal and/or interest, the exact
date of commencement of repayment shall also be specified in the loan agreements.
These instructions shall be complied with at the earliest, but not later than December 31,
2021, in respect of fresh loans. In case of existing loans, however, compliance to these
instructions shall necessarily be ensured as and when such loans become due for
renewal/review.
B. Classification as Special Mention Account (SMA) and Non-Performing Asset
(NPA)1
3. The circular DBR.No.BP.BC.45/21.04.048/2018-19 dated June 7, 2019 on ‘Prudential
Framework for Resolution of Stressed Assets’ requires the lenders to recognize incipient
stress in borrower accounts, immediately on default, by classifying them as special
mention accounts (SMA). In order to remove any ambiguity, it is clarified that the intervals
are intended to be continuous and accordingly, the basis for classification of SMA
categories shall be as follows:
Loans other than revolving facilities Loans in the nature of revolving facilities like
cash credit/overdraft
SMA Sub- Basis for classification – SMA Sub- Basis for classification –
categories Principal or interest categories Outstanding balance remains
payment or any other continuously in excess of the
amount wholly or partly sanctioned limit or drawing power,
overdue whichever is lower, for a period of:
SMA-0 Upto 30 days
SMA-1 More than 30 days and SMA-1 More than 30 days and upto 60
upto 60 days days
SMA-2 More than 60 days and SMA-2 More than 60 days and upto 90
upto 90 days days
1 In case of NBFCs, the references to 90 days for SMA-2/NPA classification may be read as per the applicable norms
and also subject to the provisions of the circular DOR.CRE.REC.No.60/03.10.001/2021-22 dated October 22, 2021 on
‘Scale Based Regulation (SBR): A Revised Regulatory Framework for NBFCs’.4. In the above context, it is further clarified that borrower accounts shall be flagged as
overdue by the lending institutions as part of their day-end processes for the due date,
irrespective of the time of running such processes. Similarly, classification of borrower
accounts as SMA as well as NPA shall be done as part of day-end process for the relevant
date and the SMA or NPA classification date shall be the calendar date for which the day
end process is run. In other words, the date of SMA/NPA shall reflect the asset
classification status of an account at the day-end of that calendar date.
Example: If due date of a loan account is March 31, 2021, and full dues are not
received before the lending institution runs the day-end process for this date, the
date of overdue shall be March 31, 2021. If it continues to remain overdue, then
this account shall get tagged as SMA-1 upon running day-end process on April 30,
2021 i.e. upon completion of 30 days of being continuously overdue. Accordingly,
the date of SMA-1 classification for that account shall be April 30, 2021.
Similarly, if the account continues to remain overdue, it shall get tagged as SMA-
2 upon running day-end process on May 30, 2021 and if continues to remain
overdue further, it shall get classified as NPA upon running day-end process on
June 29, 2021.
5. It is further clarified that the instructions on SMA classification of borrower accounts
are applicable to all loans2, including retail loans, irrespective of size of exposure of the
lending institution.
C. Clarification regarding definition of ‘out of order’
6. Cash credit/Overdraft (CC/OD) account is classified as NPA if it is ‘out of order’. In
cases where the outstanding balance in the principal operating account is less than the
sanctioned limit/drawing power, the extant instructions, inter alia, stipulate that the
account should be treated as ‘out of order’ if there are no credits continuously for 90 days
as on the date of Balance Sheet or credits are not enough to cover the interest debited
during the same period. In order to avoid any ambiguity regarding determination of ‘out
2 Agricultural advances governed by crop season-based asset classification norms shall be exempt from this
instruction.of order’ status of CC/OD accounts on a continuous basis, it is clarified that an account
shall be treated as ‘out of order’ if:
i. the outstanding balance in the CC/OD account remains continuously in excess of
the sanctioned limit/drawing power for 90 days, or
ii. the outstanding balance in the CC/OD account is less than the sanctioned
limit/drawing power but there are no credits continuously for 90 days, or the
outstanding balance in the CC/OD account is less than the sanctioned
limit/drawing power but credits are not enough to cover the interest debited during
the previous 90 days period.
7. Accordingly, treatment of CC/OD accounts as ‘out of order’ on or after the date of this
circular shall be based on the above instructions.
D. NPA classification in case of interest payments
8. In terms of paragraph 2.1.3 of the Master Circular on IRACP norms dated October 1,
2021, in case of interest payments, an account is classified as NPA only if the interest
due and charged during any quarter is not serviced fully within 90 days from the end of
the quarter. In order to fully align with the 90 days delinquency norm as well as the
requirement to apply interest at monthly rests, the above instructions are modified as
under:
In case of interest payments in respect of term loans, an account will be classified
as NPA if the interest applied at specified rests remains overdue for more than 90
days.
9. These instructions shall be effective from March 31, 2022. Accordingly, in respect of
any borrower account which becomes overdue on or after March 31, 2022, its
classification as NPA shall be based on the account being overdue for more than 90 days.
E. Upgradation of accounts classified as NPAs
10. It has been observed that some lending institutions upgrade accounts classified as
NPAs to ‘standard’ asset category upon payment of only interest overdues, partialoverdues, etc. In order to avoid any ambiguity in this regard, it is clarified that loan
accounts classified as NPAs may be upgraded as ‘standard’ asset only if entire arrears
of interest and principal are paid by the borrower. With regard to upgradation of accounts
classified as NPA due to restructuring, non-achievement of date of commencement of
commercial operations (DCCO), etc., the instructions as specified for such cases shall
continue to be applicable.
F. Income recognition policy for loans with moratorium on payment of interest
11. In cases of loans where moratorium has been granted for repayment of interest,
lending institutions may recognize interest income on accrual basis for accounts which
continue to be classified as ‘standard’. This shall be evaluated against the definition of
‘restructuring’ provided in paragraph 1 of the Annex-1 to the above-mentioned ‘Prudential
Framework for Resolution of Stressed Assets’ dated June 7, 2019. However, income
recognition norms for loans towards projects under implementation involving deferment
of DCCO3 and gold loans for non-agricultural purposes4 shall continue to be governed as
per the existing instructions.
12. The extant instructions (compiled at paragraph 3.2 of the Master Circular on IRACP
norms dated October 1, 2021) require that once an account is classified as NPA, the
entire interest accrued and credited to income account in the past periods, must be
reversed to the extent it remains unrealised. It is clarified that if loans with moratorium on
payment of interest (permitted at the time of sanction of the loan) become NPA after the
moratorium period is over, the capitalized interest corresponding to the interest accrued
during such moratorium period need not be reversed.
3 The income recognition norms for projects under implementation involving deferment of DCCO shall be subject to
the instructions at paragraph 4.2.15 of the Master Circular on IRACP norms dated October 1, 2021, as updated from
time to time.
4 The income recognition norms for Loans against Gold Ornaments and Jewellery for Non-Agricultural End-uses shall
be subject to the instructions issued vide circular DBOD.No.BP.BC.27/21.04.048/2014-15 dated July 22, 2014 on the
subject, as updated from time to time.G. Consumer Education
13. With a view to increasing awareness among the borrowers, lending institutions shall
place consumer education literature on their websites, explaining with examples, the
concepts of date of overdue, SMA and NPA classification and upgradation, with specific
reference to day-end process. Lending institutions may also consider displaying such
consumer education literature in their branches by means of posters and/or other
appropriate media. Further, it shall also be ensured that their front-line officers educate
borrowers about all these concepts, with respect to loans availed by them, at the time of
sanction/disbursal/renewal of loans. These instructions shall be complied with at the
earliest, but not later than March 31, 2022.
Yours faithfully,
(Manoranjan Mishra)
Chief General Manager