Learn RBI supervision in detail, including RBS, SPARC, CAMELS, PCA, UCB and NBFC supervision, enforcement, money markets, G-Secs, forex and financial-market regulation.
RBI Supervision: Complete Guide to Bank, NBFC, UCB and Financial-Market Oversight
The Reserve Bank of India’s role in India’s financial system goes far beyond setting monetary policy.
It also regulates financial institutions, supervises regulated entities, enforces regulatory requirements and develops financial markets.
For examination purposes, the distinction between regulation, supervision and enforcement is one of the most important ideas to understand.
Regulation establishes the framework within which financial entities operate. Supervision examines whether individual entities comply with that framework and whether their risk management is adequate. Enforcement addresses violations through appropriate action.
The Reserve Bank’s supervisory architecture has evolved considerably. The older compliance-oriented CAMELS approach has been replaced for Scheduled Commercial Banks by a risk-based framework known as SPARC — Supervisory Program for Assessment of Risk and Capital.
At the same time, RBI supervises different categories of entities through differentiated approaches, including commercial banks, NBFCs, UCBs and other RBI-regulated institutions.
What is RBI Supervision?
Supervision is the process through which regulatory rules and norms are enforced at the individual-entity level.
This differs from regulation.
Regulation establishes rules applicable to market participants generally, whereas supervision assesses the behaviour, risk profile and compliance of specific institutions.
The intensity of supervision depends on the perceived risk of the entity.
The ultimate objectives are:
- depositor protection
- safety and soundness
- financial stability.
Why Does RBI Supervise Banks?
Banks are structurally vulnerable because they undertake:
- maturity transformation
- liquidity transformation
- leverage.
They may fund long-term illiquid assets with short-term liabilities.
They are also central to payment systems and monetary-policy transmission.
A banking failure can therefore affect depositors, other financial institutions and the real economy.
Supervision helps ensure that banks comply with regulations and maintain appropriate:
- risk culture
- governance
- internal controls
- solvency.
Regulation vs Supervision
This distinction is frequently tested.
Regulation asks:
What rules should financial institutions follow?
Supervision asks:
Is this particular institution following the rules and managing its risks properly?
Regulation therefore has a system-wide character.
Supervision is entity-specific.
This also explains why supervision can be differentiated according to an institution’s risk profile.
Evolution from CAMELS to Risk-Based Supervision
Historically, RBI’s banking supervision used the CAMELS framework.
CAMELS stands for:
- Capital Adequacy
- Asset Quality
- Management
- Earnings
- Liquidity
- Sensitivity to Market Risk.
In India’s implementation, however, the final “S” represented Systems and Control.
The framework relied on annual on-site examinations supported by off-site surveillance.
The global financial crisis exposed weaknesses in such relatively uniform approaches.
Financial institutions were becoming more complex, while supervisory resources remained limited.
The logical response was to allocate supervisory resources according to risk.
The K.C. Chakrabarty Committee recommended movement toward risk-based supervision, which RBI implemented from 2013 onwards.
The PDF states that Scheduled Commercial Banks are now under the RBS framework and the earlier CAMELS framework is no longer in vogue for them.
SPARC — RBI’s Risk-Based Supervisory Framework
RBI’s RBS framework is known as:
Supervisory Program for Assessment of Risk and Capital — SPARC
Unlike CAMELS, SPARC is:
- risk-based
- forward-looking
- proactive
- dynamic.
Its three principal objectives are:
- differentiated supervision based on risk profile;
- concentration on materially significant risks;
- improvement of risk-management systems and controls.
How Does Risk-Based Supervision Work?
RBS evaluates two dimensions.
Risk of failure
This considers:
- inherent risk
- controls
- governance
- oversight
- capital.
Impact of failure
This considers the institution’s importance to the wider financial system.
Thus, a large systemically important bank may receive greater supervisory attention than a much smaller bank even if both appear financially sound.
Off-Site and On-Site Supervision
RBI combines off-site surveillance with on-site examination.
Off-site supervision
RBI analyses:
- returns
- financial statements
- business plans
- group structures
- internal audit
- external audit observations
- macroeconomic conditions
- market intelligence.
Its purpose is to identify risk areas and determine where on-site examination should concentrate.
On-site examination
Supervisors investigate identified risks directly.
They examine:
- policies
- processes
- controls
- regulatory reporting
- Board oversight
- risk management
- internal audit
- compliance.
Therefore:
Off-site = risk discovery; on-site = detailed verification.
Senior Supervisory Manager
One of SPARC’s important features is the Senior Supervisory Manager, or SSM.
The SSM acts as a single supervisory point of contact within RBI for the bank.
The SSM develops a deep understanding of:
- the bank
- its operations
- its risk profile
- its controls.
This helps make supervision more continuous and coherent.
Prompt Corrective Action
PCA is a structured early-intervention mechanism.
It was introduced in:
December 2002
The revised framework was notified in 2017 and revised again in 2021, becoming effective from 1 January 2022.
For Scheduled Commercial Banks, the revised framework monitors:
- capital
- asset quality
- leverage.
The relevant indicators include:
- CRAR/Common Equity Tier 1 ratio
- Net NPA ratio
- Tier 1 leverage ratio.
SFBs, Payments Banks and RRBs are excluded from the SCB PCA framework described in the PDF.
Supervision of Urban Co-operative Banks
UCBs operate within India’s distinctive dual-regulation architecture.
The RBI regulates their banking functions.
Co-operative authorities retain responsibility for specified administrative/management matters.
UCBs are subject to:
- on-site inspection
- off-site surveillance
- prudential regulation
- governance requirements
- capital requirements
- cyber-security requirements.
The revised framework categorises UCBs into four tiers based primarily on deposits.
The tiers range from:
Tier 1 → Tier 4
with Tier 4 comprising UCBs having deposits above ₹10,000 crore.
The PDF also describes differentiated net-worth and CRAR requirements.
Supervision of Rural Co-operative Banks
The rural short-term co-operative credit structure is:
State Co-operative Bank → District Central Co-operative Bank → PACS
RBI regulates StCBs and DCCBs.
NABARD supervises them.
PACS fall outside RBI’s banking-regulation framework as described in the PDF and are regulated by State Governments.
This division is a favourite conceptual distinction:
RBI = regulation; NABARD = supervision.
NBFC Regulation and Supervision
NBFCs provide bank-like financial intermediation without being banks.
Their importance comes from their ability to:
- reach underserved borrowers
- provide last-mile credit
- innovate
- diversify financial risks.
But their interconnectedness can transmit stress to the wider financial system.
RBI therefore applies a scale-based framework.
The four layers are:
- Base Layer
- Middle Layer
- Upper Layer
- Top Layer.
The Top Layer is intended to remain empty except in circumstances of substantial systemic risk.
Principal Business Criteria for NBFCs
A company generally falls within the NBFC framework if both of the following exceed 50%:
- financial assets as a proportion of relevant total assets;
- income from financial assets as a proportion of gross income.
Therefore:
Financial assets > 50% + financial income > 50%
Both conditions matter.
NBFC Digital Innovation
RBI has created regulatory frameworks for emerging models including:
NBFC-P2P
Connects borrowers and lenders through a platform.
NBFC-AA
Facilitates consent-based aggregation of financial information.
These demonstrate an important regulatory philosophy:
Regulation should permit innovation while controlling systemic, consumer and operational risks.
RBI Enforcement
Enforcement is the third component of the oversight architecture.
Regulation → Supervision → Enforcement
The Enforcement Department was established on:
3 April 2017
to create a more structured and separate enforcement function.
Its mandate subsequently expanded to several RBI-regulated entities and payment-system operators.
Enforcement action is based on principles such as:
- materiality
- proportionality
- intent
- consistency
- predictability.
It is primarily concerned with monetary-penalty violations and is not a substitute for consumer grievance redressal.
RBI and Financial Markets
RBI’s financial-market responsibilities cover:
- money market
- G-Sec market
- forex market
- related derivatives.
SEBI broadly regulates the equity market.
RBI combines:
market development + regulation
to improve market depth, transparency, resilience and integrity.
Money Market
The money market deals in short-term financial assets.
Key segments include:
- Call Money
- Notice Money
- Term Money
- Repo
- CP
- CD
- NCDs.
Remember:
Call = 1 day
Notice = 2–14 days
Term = 15 days–1 year
Government Securities Market
The G-Sec market determines the risk-free benchmark rate and provides the foundation for the fixed-income market.
Central Government issues:
- Treasury Bills
- dated securities.
State Governments issue:
- State Government Securities.
The G-Sec market is crucial for:
- government borrowing
- monetary operations
- collateral
- liquidity
- yield-curve formation.
Forex Market
India’s exchange-rate evolution can be remembered as:
Par value → Basket peg → Managed float
Important milestones:
- 1978 — intra-day forex trading
- 1991 — exchange-rate adjustment
- 1992 — LERMS
- 1993 — unified market-determined exchange rate
- 1994 — current-account convertibility.
The modern market contains:
- spot
- forwards
- swaps
- options
- currency futures
- currency options.
Final Conceptual Framework
The entire Part 1 can be compressed into one architecture:
Regulation
↓
Supervision
↓
Risk discovery
↓
Risk-based assessment
↓
Early intervention / PCA
↓
Enforcement where violations occur
while simultaneously:
Money Markets + G-Sec Markets + Corporate Bonds + Forex + Derivatives
support:
Liquidity + Price Discovery + Monetary Transmission + Capital Formation + Risk Management
That is the conceptual backbone connecting Chapters 8–12.
Part 1 Rapid Revision — 30 Facts You Must Know
- DoS = Department of Supervision.
- Regulation = rules; supervision = entity-specific enforcement.
- BFS established November 1994.
- DoS carved from DBOD in December 1993.
- Unified DoS restored in November 2019.
- Basel Core Principles first published September 1997.
- Latest revision mentioned = September 2012.
- 29 Basel supervisory principles.
- CAMELS was the earlier supervisory model.
- SCB RBS implemented from 2013.
- SPARC = Supervisory Program for Assessment of Risk and Capital.
- SSM = single supervisory contact.
- CIMS replaced OSMOS in June 2023.
- CRILC introduced in 2014.
- CFR operational from 20 January 2016.
- DAKSH launched 6 October 2022.
- PCA introduced December 2002.
- Revised SCB PCA effective 1 January 2022.
- UCBs have four tiers.
- UCB Tier 1 CRAR = 9%; Tier 2–4 = 12%, as stated.
- RRB/StCB/DCCB supervisory distinction: NABARD supervises specified rural institutions.
- NBFC PBC = both financial assets >50% and financial income >50%.
- NBFC SBR = Base/Middle/Upper/Top.
- NBFC-AA = consent-based financial-data aggregation.
- NBFC-P2P = lending platform, not own-book lender.
- EFD established 3 April 2017.
- Call/Notice/Term = 1 / 2–14 / 15 days–1 year.
- CP unsecured; NCD secured.
- FAR introduced March 2020.
- LEI = 20-character identifier.
CHAPTER 8 — SUPERVISION OF COMMERCIAL BANKS
Priority: EXTREME
Chapter 7 dealt primarily with regulation. Chapter 8 deals with supervision.
The distinction is fundamental:
Regulation = making the rules.
Supervision = enforcing and assessing compliance with those rules at entity level.
The PDF defines supervision as the enforcement of rules and regulations and the identification of loopholes or areas where regulatory reinforcement may be required. RBI supervises commercial banks in India as well as branches of Indian banks abroad.
8.1 Regulation vs Supervision
| Regulation | Supervision |
|---|---|
| Lays down rules/norms | Enforces rules/norms |
| System-wide | Entity-specific |
| Applies uniformly to market participants | Intensity depends on perceived risk |
| “What are the rules?” | “Is this entity following them?” |
Memory trigger
Regulation writes the rulebook; supervision checks the player.
Both ultimately pursue:
- depositor protection
- financial stability.
8.2 Why supervise banks?
Banks:
- perform maturity and liquidity transformation;
- are highly leveraged;
- have asset-liability mismatches;
- support critical payment systems;
- receive liquidity/depositor-support mechanisms.
These characteristics create the possibility of:
- excessive risk-taking;
- deterioration in balance sheets;
- bank failures;
- systemic instability.
A failed banking system can impair financial intermediation between savers and borrowers and damage the real economy.
Therefore, supervision ensures that banks comply with rules in letter and spirit, while their risk culture and governance do not threaten solvency.
8.3 Evolution of Banking Supervision
Pre-1990s
Supervision was largely an adjunct to regulation.
Focus included:
- licensing
- pricing of banking services
- interest-rate administration
- credit
- reserve requirements
- liquid-asset requirements.
Post-1991
The balance-of-payments crisis and banking-sector reforms changed the supervisory approach.
Supervision moved:
Intrusive micro-level intervention → broader prudential supervision
This coincided with:
- interest-rate deregulation
- private ownership
- adoption of Basel standards
- movement toward international best practices.
8.4 Important Committees/Working Groups
Know the chronology:
| Year | Committee / Group | Key theme |
|---|---|---|
| 1995 | S. Padmanabhan Working Group | On-site supervision |
| 2001 | Vipin Malik Working Group | Consolidated accounting/supervision |
| 2004 | Shyamala Gopinath group | Systemically important financial intermediaries/financial conglomerates |
| 2012 | K.C. Chakrabarty High-Level Steering Committee | Supervisory processes |
| 2018 | Sudarshan Sen group | FinTech and digital banking |
| 2021 | Jayant Kumar Dash group | Digital lending |
8.5 Basel Core Principles
The Basel Committee on Banking Supervision (BCBS) originally published its Core Principles for Effective Banking Supervision in:
September 1997
They became a benchmark for countries assessing their supervisory systems.
The latest revision mentioned in the PDF was:
September 2012
with 29 core principles.
These address:
- supervisory powers/responsibilities
- supervisory expectations of banks
- corporate governance
- risk management
- compliance with supervisory standards.
8.6 Five Attributes of Good Supervision
The IMF note cited by the PDF identifies five qualities.
1. Intrusive
Supervisor should deeply understand:
- business model
- risk culture
- governance.
2. Sceptical but proactive
Supervisors should question banks even during good times.
3. Comprehensive
Supervision should include:
- subsidiaries
- off-balance-sheet structures
- peripheral risks.
4. Adaptive
Supervisors must continually upgrade skills as financial innovation changes.
5. Conclusive
Supervisory findings must be followed through to their logical conclusion.
Memory
I-S-C-A-C
Intrusive – Sceptical – Comprehensive – Adaptive – Conclusive
8.7 Ability vs Will to Act
Good supervision needs two supporting pillars.
Ability to act
Requires:
- legal authority
- resources
- clear strategy
- robust internal setup
- effective relationship with other regulators.
Will to act
Requires:
- clear mandate
- operational independence
- accountability
- skilled staff
- healthy industry relationship
- effective relationship with bank boards.
8.8 RBI’s Institutional Supervisory Structure
RBI’s statutory supervisory authority derives from:
- RBI Act, 1934
- Banking Regulation Act, 1949.
Section 35 of BR Act
Inspection of banks verifies whether the conditions attached to their banking licence continue to be fulfilled.
Board for Financial Supervision — BFS
Established:
November 1994
It is a sub-committee of RBI’s Central Board.
Objective:
Dedicated and integrated supervision of credit institutions.
It covers:
- scheduled commercial banks
- urban co-operative banks
- financial institutions
- NBFCs.
Composition
- RBI Governor → Chairman
- Deputy Governor in charge of banking supervision → Vice-Chairman
- other Deputy Governors → ex-officio members
- four non-official Central Board directors → co-opted members for two years.
DoS acts as Secretariat.
BFS normally meets monthly and deliberates supervisory issues, including bank ratings.
8.9 Department of Supervision
Before 1993:
DBOD handled banking supervision and regulation.
In:
December 1993
the Department of Supervision was carved out to separate supervisory functions from regulatory functions.
It was subsequently divided into:
- Department of Banking Supervision — DBS
- Department of Non-Banking Supervision — DNBS
- Department of Co-operative Bank Supervision — DCBS.
In:
November 2019
these supervisory functions were reintegrated into a unified:
Department of Supervision (DoS)
to address:
- size
- complexity
- interconnectedness
- systemic risk
- supervisory arbitrage
- information asymmetry.
A College of Supervisors was established for specialised training.
8.10 CAMELS
Before the shift to risk-based supervision, banks were supervised using:
CAMELS
C — Capital Adequacy
A — Asset Quality
M — Management
E — Earnings
L — Liquidity
S — Sensitivity to Market Risk
However, in India’s CAMELS framework:
S = Systems and Control
The approach involved:
- annual on-site examination
- off-site surveillance.
It primarily assessed financial condition, solvency and liquidity.
The PDF identifies a major weakness:
It was essentially a single-size-fits-all approach and struggled to keep pace with innovation.
8.11 Risk-Based Supervision — RBS
The global financial crisis strengthened the case for risk-based supervision.
Why?
Reason 1
Banking became more complex.
Reason 2
Supervisory resources are scarce.
Therefore:
Resources must be concentrated where risks are greatest.
The K.C. Chakrabarty Committee recommended movement from compliance-based supervision to a risk-based approach.
Implementation began:
2013 onwards
The PDF states that all Scheduled Commercial Banks are now under RBS and the erstwhile CAMELS framework is no longer in vogue for them.
8.12 What is RBS?
Risk-Based Supervision is an ongoing process in which:
- risks of a bank are assessed;
- appropriate supervisory plans are designed;
- those plans are implemented.
It identifies material/critical risks and assesses:
- the bank’s ability to manage them;
- vulnerability to adverse outcomes.
Two fundamental objectives
- Safety and soundness of individual banks + depositor protection
- Financial-system stability
8.13 RBS vs Compliance-Based Supervision
Both involve:
- on-site examination
- off-site data analysis.
But RBS adds:
- structured risk identification
- risk quantification
- assessment of risk-management systems
- interaction between different risks
- proportional allocation of supervisory resources
- early identification of emerging risks.
The key difference
Compliance-based:
“Did you follow the rule?”
Risk-based:
“What can go wrong, how serious is it, and are your controls/capital sufficient?”
8.14 SPARC
RBI’s RBS framework is called:
SPARC — Supervisory Program for Assessment of Risk and Capital
CAMELS
- performance-based
- reactive
- point-in-time.
SPARC
- risk-based
- forward-looking
- proactive
- dynamic.
Three key objectives of SPARC
- Differentiated supervision
- Focus on high-risk areas
- Improve bank risk-management systems, oversight and controls
8.15 Two Dimensions of RBS
RBS considers:
Dimension 1 — Risk of failure
Based on:
- inherent risks
- entity-level controls
- governance
- oversight
- available capital.
Dimension 2 — Impact of failure
Considers:
How important is the bank/group to the overall financial system?
Brilliant exam formulation
Risk of failure × Impact of failure = supervisory attention
8.16 Off-site vs On-site Supervision
Off-site
Uses:
- returns
- data
- documents
- management discussions
- financial information.
Purpose:
Identify key risk areas and determine where on-site investigation is required.
On-site
Conducted by supervisors at the bank.
Examines:
- processes
- products
- policies
- regulatory reporting
- controls
- Board oversight
- risk management
- internal audit
- regulatory compliance
- accounting standards.
Memory
Off-site discovers. On-site verifies.
8.17 Senior Supervisory Manager — SSM
A key SPARC feature.
Purpose:
Single point of supervisory contact for a bank within RBI.
The SSM develops deep knowledge of the bank through:
- off-site monitoring
- on-site examination
- continuous engagement.
8.18 Types of Supervisory Approaches
1. Full Scope Supervision — FS
Most detailed/intrusive.
Covers:
all material risks.
2. Select Scope Supervision — SS
Off-site supervision dominates.
On-site work focuses on critical operations.
Examples:
- IT/cyber risks in private banks
- compliance in SFBs.
3. Thematic Assessment — TA
Examines a specific theme across a group/all banks.
Examples:
- asset quality
- cyber risk.
4. Targeted Scrutiny — TS
Specific issue based on:
- supervisory intelligence
- market intelligence.
8.19 SAKAR
Supervisory Assessment of KYC/AML Risks
A risk-based KYC/AML supervisory framework was implemented for SCBs in:
2020–21
It uses:
- KYC/AML-specific data templates
- risk indicators
- risk profiling
- focused on-site assessments.
It was extended to selected:
- UCBs
- NBFCs.
8.20 Micro Data Analysis — MDA
RBI receives data dumps from banks covering:
- customer level
- account level
- transaction level.
These are analysed for:
- compliance
- banking ethics
- best-practice implementation.
Results can be passed to SSM teams for further examination and Risk Assessment Reports.
8.21 Advanced Supervisory Analytics Group — ASAG
Uses:
- AI
- machine learning
- SupTech.
Purpose:
- forward-looking risk assessment
- standardisation
- scalable data collection/analysis
- reducing excessive dependence on manual analysis while retaining human judgement.
Applications include:
- supervisory-data validation
- social-media insights
- Board oversight assessment
- management analysis
- fraud-vulnerability assessment
- market/operational/concentration risks.
8.22 Grouping of Banks
RBI uses differentiated supervision.
Banks are grouped based primarily on:
market share of reported assets
Supervisory intensity generally rises with the category, but can be modified depending on the actual risks of an entity.
8.23 CIMS and CRILC
CIMS
The earlier:
OSMOS — Off-site Monitoring and Surveillance System
was replaced by:
CIMS — Centralised Information Management System
in:
June 2023
CIMS collects returns with various periodicities:
- weekly
- fortnightly
- monthly
- quarterly
- half-yearly
- annual.
CRILC
Central Repository of Information on Large Credits
introduced in:
2014
It collects credit information on large borrowers.
It helps:
- reduce information asymmetry
- improve credit appraisal
- support supervisors
- support policymaking.
8.24 Central Fraud Registry — CFR
Operational since:
20 January 2016
It is a searchable central database used by banks to identify fraud risks.
Banks are expected to use CFR information for:
- credit-risk management
- fraud-risk management.
8.25 Cyber Security Supervision
A dedicated:
Cyber Security & IT Examination Cell — CSITE
was established in:
June 2015
An Expert Panel on Cyber Security and IT Examination preceded this.
The RBI subsequently issued comprehensive cyber-security guidance and further instructions covering:
- digital-payment security
- IT outsourcing
- IT governance.
IT examination focuses on
- IT governance
- third-party service providers
- IT assurance
- technology investment
- fintech technological agility
- emerging technologies
- cyber hygiene.
8.26 DAKSH
RBI’s advanced supervisory monitoring system:
DAKSH
was launched on:
6 October 2022
It is a web-based end-to-end workflow platform.
It supports:
- supervisory compliance monitoring
- communication
- inspection planning/execution
- cyber-incident reporting
- MIS reporting.
8.27 Early Warning Indicators
At the macro level, indicators include:
- credit-to-GDP ratio
- debt-service ratios.
At the bank level:
- stress testing
- capital planning
- asset-quality review
- liquidity monitoring.
A new EWI framework was developed/back-tested in:
2022–23
and uses 18 significant ratios.
8.28 Prompt Corrective Action — PCA
PCA was introduced in:
December 2002
Purpose:
Early intervention when banks breach specified prudential conditions.
Originally, trigger areas included:
- capital adequacy
- asset quality
- profitability.
Possible actions included restrictions on:
- dividend payments
- new business
- fresh deposits.
Revised PCA Framework
Revised:
April 2017
Again revised in:
2021
Effective:
1 January 2022
Applicable to Scheduled Commercial Banks, including foreign banks through branches/subsidiaries, but excluding:
- SFBs
- Payments Banks
- RRBs.
Key areas:
- Capital
- Asset Quality
- Leverage
Indicators:
- CRAR / Common Equity Tier 1 ratio
- Net NPA ratio
- regulatory minimum Tier 1 leverage ratio.
PCA actions
Mandatory/discretionary actions can concern:
- dividends
- branch expansion
- provisioning
- special audits
- business-process reengineering
- governance
- high-risk exposures
- loan review
- derivatives
- staff training
- capital expenditure.
8.29 Stress Testing
RBI issued stress-testing guidelines in:
December 2013
Stress testing became mandatory for banks.
Banks must be able to withstand at least:
baseline shocks
The supervisory framework subsequently moved from a single-factor to a multi-factor model.
Factors include:
- inflation
- GDP growth
- exchange rate
- unemployment
plus bank-specific/idiosyncratic factors.
8.30 Supervisory Outcomes
Three major outputs:
1. Risk Assessment Report — RAR
Focuses on:
unexpected losses.
2. Inspection Report — IR
Covers expected losses through:
- regulatory-operations/compliance review
- capital review.
3. Conduct of Business Assessment
Covers:
- customer conduct
- market conduct.
8.31 Cross-Border Supervision
International banks create risks in both:
- host countries
- home countries.
Therefore, supervisory cooperation is essential.
RBI conducts on-site examinations of Indian bank branches abroad.
It also cooperates with foreign supervisors.
Supervisory Colleges
RBI has established colleges for six major internationally active Indian banks:
- State Bank of India
- Bank of Baroda
- Bank of India
- ICICI Bank
- Axis Bank
- Punjab National Bank.
Purpose:
- information exchange
- supervisory cooperation
- understanding group-wide risk
- better supervision.
8.32 Financial Conglomerates — IRF
The:
Inter-Regulatory Forum — IRF
for Financial Conglomerates was established in:
August 2012
under the FSDC Sub-Committee.
It follows a:
lead regulator principle
Members include:
- RBI
- SEBI
- IRDAI
- PFRDA
- NHB.
Purpose:
- coordinated supervision
- information sharing
- emerging-risk identification
- systemic-risk assessment.
CHAPTER 8 — CORE MEMORY CHAIN
CAMELS
↓
1991 crisis + Basel
↓
Risk-based supervision
↓
2013 implementation
↓
SPARC
↓
Off-site risk discovery
↓
Targeted on-site examination
↓
SSM
↓
CIMS + CRILC
↓
CFR + cyber supervision
↓
DAKSH + EWI
↓
PCA + stress testing
↓
RAR + IR + Conduct
↓
Cross-border supervision
CHAPTER 9 — REGULATION AND SUPERVISION OF CO-OPERATIVE BANKS
Priority: VERY HIGH
Co-operative banks are important because they combine:
co-operative structure + banking activity + dual regulatory architecture.
9.1 Co-operative Principles
The co-operative movement is based on:
- community camaraderie
- mutual help
- democratic decision-making
- open membership.
9.2 History
5 February 1889
Anyonya Sahakari Mandali
was formed at Baroda, Gujarat.
1904
Co-operative Societies Act.
The:
Kancheepuram Co-operative Credit Society
became the first credit society registered under this Act.
1919
Co-operation was transferred from Central Government to Provincial States.
9.3 Characteristics of Co-operative Institutions
They generally have:
- focused geographical area
- democratically elected Board
- borrowing linked to membership/shareholding
- one member, one vote
- restrictions on lending to non-members, subject to specified exceptions
- unlisted/untraded shares.
Critical principle
One member = one vote
regardless of number of shares.
9.4 Co-operative Credit Societies vs Co-operative Banks
Constitutional division:
- Co-operative societies → State List
- Banking → Union List
Therefore, ordinary co-operative societies are outside RBI’s banking regulatory purview.
A co-operative credit society mainly:
mobilises deposits from its own members and lends to members.
When appropriately licensed to undertake banking business, it functions as a:
co-operative bank
and can accept public deposits.
9.5 Legal Framework
The Banking Regulation Act became applicable to co-operative societies in:
March 1966
through insertion of:
Section 56 / Part V
This is commonly referred to as the BR Act, 1949 as applicable to co-operative societies.
This produced dual control.
Government / cooperative authority
Handles administrative aspects such as:
- registration
- recruitment
- liquidation.
RBI
Handles:
banking aspects
under the BR Act.
Some matters involve concurrent powers.
9.6 2020 Amendment
The Banking Regulation (Amendment) Act, 2020 sought to strengthen RBI’s oversight over co-operative banks concerning:
- management
- capital
- audit
- liquidation.
It enabled UCBs to raise capital through:
- shares
- debentures
- similar securities,
subject to RBI approval/conditions.
RBI also received powers concerning:
- removal of directors
- appointment of additional directors
- Board supersession, after consultation with State Government in specified cases
- exemptions from specified provisions.
9.7 Which Co-operative Banks Does RBI Regulate?
UCBs
RBI regulates + supervises
StCBs
RBI regulates + NABARD supervises
DCCBs
RBI regulates + NABARD supervises
SCARDBs and PCARDBs
Outside RBI’s regulatory/supervisory purview as described in the PDF.
9.8 Definition of UCB
Section 5(ccv) of the BR Act defines UCB as a co-operative society, other than a PACS, satisfying conditions including:
- principal object/business is banking;
- paid-up share capital and reserves ≥ ₹1 lakh;
- bye-laws do not permit admission of another co-operative society as a member.
9.9 UCB Growth and Consolidation
When BR Act provisions became applicable in 1966:
- around 1,100 UCBs
- deposits = ₹167 crore
- advances = ₹153 crore.
Liberal licensing later increased the number.
From:
1,311 UCBs in 1993
to:
2,104 in 2003
But almost one-third of newly licensed UCBs became financially unsound within a short period.
Consequently, fresh licensing was stopped after the comprehensive policy decision of 2004–05.
As on:
31 March 2024
the PDF states:
1,472 UCBs
after mergers, conversions and licence cancellations.
9.10 TAFCUB
RBI entered into MoUs with governments from:
2005
and established:
TAFCUB — Task Force for Co-operative Urban Banks
at State level.
A Central TAFCUB was established for multi-State UCBs.
It identifies:
- potentially viable UCBs
- non-viable UCBs.
Possible outcomes:
Viable
revival
Non-viable
merger / conversion into society / liquidation as last resort.
9.11 UCB Reforms
Important measures include:
- voluntary transition of UCBs into SFBs — 2018
- Board of Management in addition to Board of Directors — 2019
- PSL target increased from 40% to 75% in graded manner
- tighter exposure norms
- at least 50% of aggregate loans/advances to comprise small-value loans, to be achieved in phases.
9.12 UCB Cyber Security
The RBI’s:
Technology Vision for Cyber Security: 2020–2023
was released in:
September 2020
It had five pillars:
- governance oversight
- useful/appropriate technology investment
- regulation and supervision
- collaboration
- IT/cyber-security skills.
9.13 UCB Regulatory Powers
RBI regulates:
- branch licences
- area-of-operation expansion
- CRR/SLR
- capital adequacy
- income recognition
- asset classification
- provisioning
- exposure norms
- PSL targets
- Second Schedule inclusion
- governance.
9.14 UCB Services
UCBs may undertake various services including:
- specialised branches
- currency chests
- ATMs
- mobile/internet banking
- RTGS/NEFT
- NDS-OM access
- current accounts/SGL accounts with RBI
- insurance/mutual fund distribution
- PFRDA Point-of-Presence
- BC/BF arrangements
- prepaid instruments
- demat-related facilities.
Scheduled UCBs have access to:
- LAF
- MSF.
9.15 Four-Tier UCB Framework
Based on deposits as per audited balance sheet on 31 March immediately preceding the financial year:
| Tier | Deposit size |
|---|---|
| Tier 1 | Unit/salary-earner UCBs regardless of deposits + other UCBs up to ₹100 crore |
| Tier 2 | >₹100 crore to ₹1,000 crore |
| Tier 3 | >₹1,000 crore to ₹10,000 crore |
| Tier 4 | >₹10,000 crore |
A bank moving to a higher tier may receive a glide path of up to:
3 years
to meet higher requirements.
9.16 UCB Net Worth
Tier 1 single-district UCB
Minimum net worth:
₹2 crore
All other UCBs
Minimum:
₹5 crore
For those below the requirement:
- 50% by 31 March 2026
- full requirement by 31 March 2028
as stated in the PDF.
9.17 UCB CRAR
Tier 1
Minimum:
9% of RWAs
Tier 2–4
Minimum:
12% of RWAs
Phased target for Tier 2–4 UCBs below 12%:
- 10% by March 2024
- 11% by March 2025
- 12% by March 2026.
9.18 UCB PCA
The revised PCA framework for UCBs was issued:
26 July 2024
Applicable to:
Tier 2, Tier 3 and Tier 4 UCBs
except UCBs under All Inclusive Directions.
Tier 1 UCBs were not covered but were subject to enhanced monitoring.
Effective:
1 April 2025
Key monitoring areas:
- Capital
- Asset Quality
- Profitability
Indicators:
- CRAR
- Net NPA ratio
- net profit.
Exit from PCA requires:
- no threshold breaches for four continuous quarterly financial statements, one audited annual statement;
- RBI supervisory comfort and sustainable financial improvement.
9.19 UCB Standard-Asset Provisioning
On:
24 April 2023
RBI harmonised provisioning norms.
| Category | Provision |
|---|---|
| Agriculture & SME | 0.25% |
| CRE | 1.00% |
| CRE-RH | 0.75% |
| Other standard advances | 0.40% |
Tier 1 UCBs previously at 0.25% for other standard advances were allowed to move to 0.40% in a staggered manner by 31 March 2025.
9.20 Rural Co-operative Structure
Long-term structure
- SCARDB → State level
- PCARDB → district/block level
These serve long-term agricultural-credit requirements and are outside RBI’s regulatory purview as stated.
Short-term structure
Three-tier structure:
StCB → DCCB → PACS
PACS
The PDF states there are:
more than 95,000 PACS
and they are not regulated by RBI because they fall outside the BR Act’s scope.
They are regulated/monitored by State Governments.
StCBs and DCCBs:
RBI regulation + NABARD supervision
CHAPTER 10 — REGULATION AND SUPERVISION OF NBFCs
Priority: EXTREME
NBFCs perform bank-like functions without being banks.
They are particularly important because they:
- provide last-mile credit
- serve segments underserved by banks
- diversify financial risks
- innovate in financial products.
The challenge is:
Innovation + resilience
The PDF notes that there are over 9,000 NBFCs, making supervision complex.
10.1 Definition of NBFC
Under Section 45-I(f) of the RBI Act, an NBFC includes:
- a financial institution that is a company;
- a non-banking institution that is a company whose principal business involves receiving deposits or lending;
- other specified non-banking institutions notified by RBI with Central Government approval.
10.2 Financial Institution
Section 45-I(c) covers activities including:
- lending/financing
- acquisition of securities
- leasing
- hire-purchase
- insurance
- chit business
- collection of money.
But entities whose principal business is:
- agriculture
- industrial activity
- trading in goods
- services
- sale/purchase/construction of immovable property
are excluded from the financial-institution definition as described.
10.3 Principal Business Criteria — PBC
A company is treated as an NBFC if both tests are satisfied:
Asset test
Financial assets:
more than 50% of total assets, excluding fixed deposits and after specified adjustments.
Income test
Income from financial assets:
more than 50% of gross income
Both must be satisfied.
The concept was clarified through RBI’s press release dated:
8 April 1999.
Memory
50–50 test, but BOTH must cross 50%.
10.4 Shadow Banking / NBFI
The FSB originally defined shadow banking as:
credit intermediation involving entities/activities outside the regular banking system.
In:
October 2018
FSB replaced the term “shadow banking” with:
Non-Bank Financial Intermediation — NBFI
to emphasise resilience and the forward-looking nature of the framework.
10.5 Three NBFI Measures
NBFI
Broadest measure of non-bank financial entities.
OFIs
Subset excluding:
- central banks
- banks
- public financial institutions
- insurance corporations
- pension funds
- financial auxiliaries.
Narrow NBFI measure
Entities involved in bank-like credit intermediation involving risks such as:
- maturity transformation
- liquidity transformation
- leverage
- imperfect credit-risk transfer
- regulatory arbitrage.
10.6 NBFC Exemptions
Certain NBFC-like entities are regulated by other authorities.
To avoid dual regulation, RBI exempts categories regulated elsewhere.
| Entity | Other regulator |
|---|---|
| AIFs | SEBI |
| Merchant banking | SEBI |
| Stock brokers | SEBI |
| Stock exchanges | SEBI |
| Insurance companies | IRDAI |
| Nidhi companies | MCA |
| Chit companies | State Governments |
10.7 Type I vs Type II NBFC-ND
Type I
- does not accept public funds
- does not intend to accept them
- no customer interface
- does not intend to have one.
These receive less intensive scrutiny.
If they later want public funds/customer interface:
approval from Department of Regulation is required.
Type II
Accepts/intends to accept public funds and/or has/intends customer interface.
10.8 Scale-Based Regulation — Four Layers
RBI’s SBR framework was issued:
October 2021
Effective:
1 October 2022
Four layers:
- NBFC-BL — Base Layer
- NBFC-ML — Middle Layer
- NBFC-UL — Upper Layer
- NBFC-TL — Top Layer
The Top Layer is intended to remain empty unless systemic risk rises substantially.
Memory
Base → Middle → Upper → Top
Risk rises as you climb.
10.9 Base and Middle Layer
Non-deposit-taking NBFCs:
- asset size < ₹1,000 crore → Base Layer
- ₹1,000 crore or more → Middle Layer
However, activity can place an NBFC in Base or Middle irrespective of size.
Deposit-taking NBFCs are at least in:
Middle Layer
because of public-deposit sensitivity.
10.10 Upper Layer
The top ten eligible NBFCs by asset size are included in the Upper Layer.
Other NBFCs may also be specifically identified based on:
- parameters
- scoring methodology
- systemic importance.
Top Layer is reserved for situations of substantial systemic-risk increase.
10.11 Major NBFC Categories
NBFC-ICC
Investment and Credit Company
Activities:
- lending
- physical-asset financing
- securities acquisition.
Gold-loan companies can fall here where gold lending represents at least 50% of financial assets.
NBFC-IFC
Infrastructure Finance Company
Infrastructure loans:
at least 75% of total assets
CIC
Core Investment Company
At least:
90% of net assets in group-company investments/loans
and:
60% of net assets in equity/equity-like group investments.
10.12 Other NBFC Categories
IDF-NBFC
Refinances completed infrastructure projects.
NBFC-MFI
Collateral-free small loans.
At least:
75% of total assets in microfinance loans.
NBFC-Factors
Factoring/receivables financing.
Mortgage Guarantee Companies
Mortgage guarantees for housing loans.
NOFHC
Non-Operative Financial Holding Company used for setting up new private-sector banks.
NBFC-AA
Account Aggregator.
NBFC-P2P
Peer-to-peer lending platform.
HFC
Housing Finance Company.
SPD
Standalone Primary Dealer.
10.13 Account Aggregator
NBFC-AA retrieves, consolidates and presents financial information of customers with:
explicit consent
It does not conduct ordinary customer transactions.
The system is based on:
- standardised data
- encryption
- APIs
- consent architecture
- audit trails.
Core idea
AA = data sharing with consent, not lending.
10.14 P2P Lending
NBFC-P2P:
connects borrowers and lenders electronically.
The platform itself:
does not lend from its own books / take the underlying credit risk.
The PDF states there were:
26 registered NBFC-P2P platforms as of 31 March 2024.
10.15 ARCs
Asset Reconstruction Companies are registered under:
Section 3 of SARFAESI Act, 2002
They acquire and deal with financial assets sold by banks/FIs and play a role in NPA resolution.
Minimum NOF:
- increased from ₹2 crore → ₹100 crore in April 2017
- increased further to ₹300 crore in October 2022, to be achieved by March 31, 2026.
10.16 NBFC Regulatory History
RBI obtained regulatory/supervisory powers over NBFCs through:
Chapter III-B of RBI Act — 1963
The 1996 CRB Capital failure became an important watershed.
Following the Shah Committee recommendations, 1997 amendments introduced/strengthened:
- compulsory RBI registration
- minimum NOF
- liquid-asset requirements
- reserve fund
- RBI directions
- special audit
- prohibition on deposits/asset alienation
- winding-up powers
- nomination facility
- restrictions on unincorporated deposit-taking
- penalties.
10.17 1999 NOF
NOF requirement for fresh registration increased from:
₹25 lakh → ₹2 crore
in 1999.
10.18 2014 NBFC Framework
Key changes included:
- minimum NOF for legacy NBFCs = ₹2 crore
- harmonisation of deposit rules
- systemic-significance threshold increased from ₹100 crore to ₹500 crore
- differentiated regulation according to public funds/customer interface
- harmonisation of asset classification with banks for specified NBFCs
- stronger corporate governance requirements.
10.19 2019 Strengthening
RBI obtained additional powers to:
- prescribe different NOF levels
- remove directors, excluding government-owned NBFCs
- supersede Boards, excluding government-owned NBFCs
- remove/debar auditors for up to 3 years
- resolve NBFCs through amalgamation/reconstruction/splitting
- call group-company information and inspect group companies.
10.20 HFCs and IBC
The Finance (No.2) Act, 2019 amended the NHB Act and transferred:
HFC registration and regulation → RBI
The PDF also states that from:
November 2019
RBI became entrusted with insolvency-resolution processes of NBFCs, including HFCs, under the relevant IBC framework.
10.21 NBFC Prudential vs Conduct Regulation
Prudential regulation
Includes:
- capital adequacy
- borrower exposure
- income recognition
- asset classification
- provisioning
- LTV
- leverage
- public deposits.
Conduct regulation
Includes:
- Fair Practices Code
- KYC.
10.22 NBFC vs Bank — Key Comparison
| Area | Base-layer NBFC | Middle/Upper NBFC | Banks |
|---|---|---|---|
| Legal basis | RBI Act, Ch. III-B | RBI Act, Ch. III-B | BR Act |
| Capital | No CRAR; leverage framework | CRAR requirements | Basel III framework |
| Credit concentration | Internal Board policy in BL | Prescribed limits | Large exposure framework |
| LCR | Specified NBFCs | Wider applicability | Commercial banks |
| KYC/AML/CFT | Similar broad norms | Similar | Similar |
| NSFR | Not applicable | Not applicable per table | Applicable as stated |
10.23 Ind AS and NBFCs
NBFCs transitioned to Ind AS according to the roadmap.
The PDF states:
- net worth ≥ ₹500 crore → 1 April 2018
- net worth ≥ ₹250 crore and other listed NBFCs → 1 April 2019
Ind AS introduces concepts including:
- Expected Credit Loss
- Other Comprehensive Income
- symmetric fair-value accounting.
RBI issued regulatory guidance in:
March 2020
to improve consistency and comparability.
10.24 NBFC Supervision — Five-Pronged Framework
RBI’s supervisory framework includes:
- On-site inspections
- Off-site monitoring
- Market intelligence
- Statutory auditors’ exception reports
- Stakeholder interaction
10.25 Sachet Portal
Launched:
4 August 2016
Purpose:
Help public and regulators identify unauthorised deposit-taking.
Public can:
- submit information
- upload advertisements
- ask queries
- lodge complaints.
It also connects regulators and supports coordination against unauthorised deposit collection.
10.26 SBR Changes — NOF
For specified NBFCs:
NBFC-ICC
₹2 crore → ₹5 crore by March 31, 2025 → ₹10 crore by March 31, 2027.
NBFC-MFI
₹5 crore → ₹7 crore → ₹10 crore.
NER exception:
₹2 crore → ₹5 crore → ₹10 crore.
NBFC-Factors
₹5 crore → ₹7 crore → ₹10 crore.
For:
- P2P
- AA
- no-public-funds/no-customer-interface NBFCs
NOF remains:
₹2 crore
No change in specified minimums for:
- IDF
- IFC
- MGC
- HFC
- SPD.
10.27 NBFC NPA Norm
Under SBR, NPA classification moves to:
more than 90 days overdue
for all NBFC categories.
Base Layer glide path:
- 150 days by March 31, 2024
- 120 days by March 31, 2025
- 90 days by March 31, 2026.
10.28 NBFC-UL Capital
NBFC-ML and NBFC-UL must undertake:
ICAAP — Internal Capital Adequacy Assessment Process
It assesses capital needs against:
- credit risk
- market risk
- operational risk
- residual risks.
NBFC-UL must maintain:
CET1 ≥ 9% of RWA
and is also subject to leverage requirements and differential standard-asset provisioning.
10.29 NBFC Compensation
NBFCs are required to establish:
Nomination and Remuneration Committee — NRC
Compensation should consider risk.
Variable pay can include:
- deferral
- malus
- clawback.
10.30 NBFC PCA
Effective:
1 October 2022
based on financial position on/after March 31, 2022.
Applies to:
- all deposit-taking NBFCs except government companies;
- specified non-deposit NBFCs in Middle/Upper/Top Layers.
Exclusions include:
- no-public-funds/no-intention entities
- government companies
- Primary Dealers
- HFCs.
For NBFC-D and NBFC-ND:
Capital + Asset Quality
Indicators:
- CRAR
- Tier I Capital Ratio
- NNPA.
For CICs:
Capital + Leverage + Asset Quality
CHAPTER 11 — ENFORCEMENT IN RBI
Priority: VERY HIGH
Think of oversight as:
Regulation → Supervision → Enforcement
Regulation
Creates framework.
Supervision
Checks compliance.
Enforcement
Acts when non-compliance is detected.
11.1 Why was EFD created?
Previously monetary penalties were distributed across regulatory/supervisory departments.
This was inconsistent with international best practice of separating:
supervision from enforcement.
A Supervisory Enforcement Framework was approved in:
2016
The:
Enforcement Department — EFD
was established on:
3 April 2017
Initially focused on Scheduled Commercial Banks.
Its mandate subsequently expanded to:
- UCBs
- NBFCs
- HFCs
- CICs
- Payment System Operators.
11.2 EFD Mandate Expansion — Chronology
3 April 2017
EFD established.
3 October 2018
Enforcement over:
- co-operative banks
- NBFCs
brought under EFD.
9 August 2019
HFC regulation/enforcement transferred to RBI.
28 June 2022
CIC enforcement added.
1 April 2023
PSS Act monetary penalties/compounding transferred to EFD.
11.3 Important Exception
Enforcement under:
- FEMA
- Government Securities Act
continues with respective regulatory/supervisory departments for the matters described in the PDF.
11.4 EFD Regional Offices
Established:
May 2019
at:
- Ahmedabad
- Chennai
- Kolkata
- Mumbai
- Nagpur
- New Delhi.
11.5 Enforcement Policy
The Enforcement Policy Framework was:
- drafted in 2017
- revised after mandate expansion
- approved by BFS on 25 September 2019
- placed before Central Board on 13 December 2019.
Principles:
- materiality
- proportionality
- intent
- consistency
- predictability
- risk focus.
More serious/systemically significant violations attract stronger action.
11.6 What Enforcement Policy Does NOT Do
It deals primarily with:
monetary-penalty violations.
It does not:
- handle individual consumer grievances;
- substitute for supervisory compliance;
- automatically cover non-monetary supervisory actions.
Exam trap
Enforcement ≠ grievance redressal
11.7 Materiality
Actionable violations depend on:
- fact of violation
- materiality.
Materiality considers:
- extent
- frequency
- seriousness.
Seriousness considers:
- absolute amount
- proportion to business size
- repeat/persistent violations
- false compliance.
11.8 Enforcement Process
Enforcement is:
quasi-judicial
and follows principles of natural justice.
Process:
Show Cause Notice
↓
Reasonable opportunity to be heard
↓
Adjudication
↓
Speaking order
The Adjudication Committee can consist of:
- three Executive Directors at Central Office, including ED-in-charge of EFD;
- or Regional Director + two Senior Officers at Regional Office, as applicable.
Penalty is determined according to:
- proportionality
- intent
- mitigating factors
within statutory maximum limits.
11.9 Enforcement Philosophy
Enforcement produces:
- monetary deterrence
- reputational deterrence
- demonstration effect on other entities.
The PDF notes that current laws empower RBI to impose monetary penalties on regulated entities rather than directly on individuals responsible for violations.
Enforcement can be:
Formal/ex-post
- compliance enforcement
- monetary penalties.
Informal/ex-ante
- clarifications
- cautionary advice.
CHAPTER 12 — DEVELOPMENT AND REGULATION OF FINANCIAL MARKETS
Priority: EXTREME
This is a very large chapter conceptually.
The Indian financial markets broadly include:
- Money market
- Government Securities market
- Foreign Exchange market
- Equity market.
The system historically developed within a bank-centric financial system.
After financial-sector reforms in the early 1990s, market development accelerated.
12.1 Who Regulates Which Market?
SEBI
Broadly regulates:
Equity market
RBI
Regulates:
- Money market
- Government Securities market
- Foreign Exchange market
- related derivatives markets, including credit derivatives.
Key point
RBI performs both:
Developmental + Regulatory roles
Development:
orderly growth.
Regulation:
prudential + conduct rules for integrity/stability.
12.2 Market Development Objectives
RBI’s reforms seek to:
- improve capital raising
- reduce onshore/offshore segmentation
- broaden participation
- promote innovation
- strengthen market infrastructure
- ensure fair conduct
- improve resilience.
12.3 Market Representative Bodies
Important bodies:
- FIMMDA
- FEDAI
- PDAI.
They have supported:
- market development
- self-regulation
- codes of conduct
- broker oversight
- arbitration.
RBI also facilitated:
Financial Benchmarks India Private Limited — FBIL
established jointly by:
- FIMMDA
- FEDAI
- IBA.
FBIL administers key benchmarks for:
- money market
- G-Sec
- forex
- derivatives.
12.4 CCIL
Established:
2001
Operations began:
February 2002
Clearing Corporation of India Ltd — CCIL
provides clearing/settlement infrastructure for:
- G-Secs
- money market
- foreign exchange.
It later expanded into:
- CCP-based settlement
- trade repository for OTC forex, interest-rate and credit derivatives.
12.5 FMRD
A dedicated:
Financial Markets Regulation Department — FMRD
was created to focus on market development and regulation.
12.6 Money Market
Money market deals with:
short-term financial assets close substitutes for money.
It balances:
- short-term demand for funds
- short-term supply of funds.
Therefore it is crucial for:
- liquidity management
- monetary-policy transmission.
12.7 Money Market Development
RBI:
- removed interest-rate ceilings on inter-bank call/notice money in 1989
- introduced instruments such as:
- T-Bills
- CDs
- CP
- Repo
between 1986 and 1992.
Other reforms included:
- DFHI in 1988
- primary/satellite dealers
- market-determined rates
- stronger money-market/forex-market linkage.
Important committees:
- Chakravarty — 1985
- Vaghul — 1987
- Narasimham — 1991 and 1998.
12.8 Money Market Infrastructure
Important systems:
- NDS-Call
- CROMS
- TREPS
- STP
- RTGS
- CCIL.
Participants include:
- commercial banks
- co-operative banks
- PDs
- insurance companies
- mutual funds
- NBFCs
- other permitted entities.
SFBs, PBs and RRBs were also allowed participation in:
- Call Money
- Notice Money
- Term Money.
12.9 Call, Notice and Term Money
These are uncollateralised transactions.
Call Money
1 day
Notice Money
2–14 days
Term Money
15 days to 1 year
Transactions occur:
- OTC
- NDS-Call.
Memory
Call = 1
Notice = 2–14
Term = 15–365
12.10 Repo Market
Repo:
short-term collateralised borrowing against securities.
From borrower perspective:
Repo
From lender perspective:
Reverse Repo
RBI repos are:
LAF-Repo
Market participant repos are:
Market Repo
Eligible market-repo securities include:
- Central/State Government securities
- T-Bills
- CP
- CDs
- debt ETFs
- listed corporate bonds/debentures.
12.11 Tri-Party Repo
A third party acts between borrower and lender.
The:
Tri-Party Agent
helps with:
- collateral selection
- payment
- settlement
- custody
- collateral management.
12.12 Commercial Paper and NCD
Commercial Paper — CP
Unsecured money-market instrument.
NCD
Secured money-market instrument
with original/initial maturity up to one year.
Eligible issuers include:
- companies
- NBFCs/HFCs
- InvITs/REITs
- AIFIs
- certain ₹100 crore+ net-worth corporates
- other permitted entities.
Minimum credit rating:
A3
as assigned according to the applicable SEBI rating framework described in the PDF.
Trades are reported to:
F-TRAC of CCIL.
12.13 Certificate of Deposit — CD
A CD is:
negotiable + unsecured money-market instrument.
Issued by:
- Scheduled Commercial Banks including RRBs/SFBs
- eligible AIFIs.
Bank CD maturity
7 days to 1 year
AIFI CD maturity
1 year to 3 years
Banks/AIFIs cannot grant loans against CDs unless RBI specifically permits.
12.14 Government Securities Market
The G-Sec market is crucial because it determines:
risk-free interest rates
G-Sec yields become benchmarks for pricing other financial assets.
It is also fundamental to:
- public borrowing
- monetary policy
- fixed-income markets
- collateral
- liquidity management.
12.15 Central vs State G-Secs
Central Government
Issues:
- Treasury Bills
- dated securities/bonds.
State Governments
Issue:
State Government Securities — SGS
only bonds/dated securities.
Dated securities have maturity:
more than 1 year
The PDF states tenor can currently extend up to:
50 years.
12.16 Why G-Secs Matter for Monetary Policy
G-Secs provide:
- high-quality collateral
- yield-curve benchmarks
- liquidity
- monetary-operation infrastructure.
Virtually all monetary operations are connected with the G-Sec market.
Therefore:
Efficient G-Sec market → efficient monetary transmission.
12.17 G-Sec Market Development
Major reforms:
- abolition of automatic monetisation
- primary auction process
- FRBM Act, 2003
- auction calendars from April 2002
- electronic auctions
- When-Issued trading in 2006
- short selling from February 2006
- product diversification.
Instruments introduced include:
- floating-rate bonds
- capital-indexed bonds
- inflation-indexed bonds
- STRIPS
- Sovereign Gold Bonds
- savings bonds.
12.18 NDS-OM
Negotiated Dealing System – Order Matching
is an anonymous screen-based order-matching platform owned by RBI and operated by CCIL.
It supports trading in:
- Central Government securities
- SGS
- special securities
- Treasury Bills.
Settlement is STP-based and flows to CCIL for guaranteed settlement.
Anonymity protects market integrity and facilitates large transactions without distorting market sentiment.
12.19 RBI Retail Direct
The:
RBI Retail Direct Scheme
was introduced to make G-Secs easier for retail investors.
A mobile application was launched in:
May 2024
to facilitate access.
12.20 FPI Investment in G-Secs
The:
Medium-Term Framework — MTF
was introduced in:
2015
It provides a predictable framework for FPI investment in rupee debt.
FPI limits are reviewed:
half-yearly
The PDF describes limits including:
- 6% for Central Government Securities
- 2% for State Government Securities,
as percentages of relevant outstanding stock in the framework described.
12.21 VRR
Voluntary Retention Route
introduced in:
2019
Purpose:
Encourage long-term FPI debt investment through greater operational flexibility and specified regulatory exemptions.
12.22 FAR
Fully Accessible Route
introduced:
March 2020
Allows eligible non-residents to invest in specified Government of India dated securities without specified macroprudential limits/investment ceilings.
It operates alongside:
- MTF
- VRR.
Memory
MTF = predictable framework
VRR = voluntary retention/flexibility
FAR = fully accessible specified G-Secs
12.23 When-Issued Trading
WI trading allows trading in G-Secs:
after announcement but before actual issuance.
Benefits:
- extends distribution period
- allows market absorption
- improves price discovery
- reduces auction uncertainty.
12.24 STRIPS
Separate Trading of Registered Interest and Principal of Securities
Separates:
- coupon payments
- principal repayment
into individually tradable instruments.
Introduced:
April 2010
Revised directions in 2018 broadened eligibility to fixed-coupon GOI securities meeting specified SLR and transferability conditions.
Memory
STRIPS = one bond becomes many cash-flow pieces.
12.25 G-Sec Securities Lending and Borrowing
Permitted in:
2023
Purpose:
- deepen liquidity
- improve price discovery
- support special-repo activity
- allow investors to earn from idle securities.
Eligible lenders:
entities authorised to undertake G-Sec repos.
Eligible borrowers:
entities authorised for G-Sec short sales.
12.26 Corporate Bond Market
A strong corporate bond market:
- diversifies funding away from banks
- provides long-term capital
- gives institutional investors long-term assets
- spreads financial risk
- supports financial stability.
SEBI is the primary regulator of the corporate bond market.
RBI regulates aspects involving:
- banks/RBI-regulated entities
- FPI investment
- corporate-bond repo
- credit derivatives.
12.27 Corporate Bond Market Measures
RBI has:
- permitted long-term bank bonds for infrastructure/affordable housing
- encouraged bank/PD participation
- increased FPI access
- introduced corporate-bond repo
- introduced DvP for OTC corporate bonds in 2009
- required reporting of trades
- enabled CDS
- permitted partial credit enhancement.
12.28 Credit Default Swaps — CDS
CDS enables hedging of:
credit risk
RBI permitted CDS in:
December 2011
and revised directions in 2022.
Eligible market makers include specified:
- commercial banks
- standalone PDs
- NBFCs with minimum NOF ₹500 crore and required approval
- permitted AIFIs
- other authorised institutions.
Retail users may buy protection only for:
hedging underlying exposure
while non-retail users have broader permitted purposes.
12.29 Partial Credit Enhancement — PCE
Banks may provide PCE as:
non-funded subordinated facility
in the form of an:
irrevocable contingent line of credit.
It is drawn if cash flows are insufficient to service bonds.
Effect:
PCE → better perceived credit quality/rating
RBI prescribes limits on individual and aggregate bank PCE.
12.30 Interest Rate Derivatives
1999
- Interest Rate Swaps — IRS
- Forward Rate Agreements — FRA
introduced to deepen markets and hedge interest-rate risk.
2011
Futures on 91-day T-Bill.
2016
- futures based on other money-market instruments/rates
- rupee interest-rate options.
2018
Swaptions introduced.
2019
Consolidated Rupee Interest Rate Derivatives Directions.
Permitted instruments include:
- FRA
- IRS
- European IROs
- caps
- floors
- collars
- reverse collars
- swaptions
- specified structured derivatives.
12.31 Offshore FCS-OIS
In 2022, authorised market-makers with AD Category-I licences and standalone PDs were allowed to participate in:
offshore Foreign Currency Settled Overnight Indexed Swap — FCS-OIS
with non-residents and market makers through:
- India branches
- foreign branches
- IFSC Banking Units.
12.32 Forex Market Evolution
India moved through:
Par value → Basket peg → Managed float
The forex market began in:
1978
when banks were permitted intra-day trading.
July 1991
Two-step exchange-rate adjustment.
March 1992
LERMS — Liberalised Exchange Rate Management System
Dual exchange-rate system:
- 60% at market rate
- 40% at RBI official rate.
March 1993
Unified market-determined exchange rate.
August 1994
Current-account convertibility.
Memory
78 → 91 → 92 → 93 → 94
Market trading → crisis adjustment → LERMS → unified rate → current-account convertibility
12.33 Forex Market Growth
Average daily forex turnover:
approximately USD 3 billion in 2001
to:
approximately USD 53 billion in 2022
according to the BIS Triennial Survey cited in the PDF.
12.34 NDF Market
The offshore INR derivative market is dominated by:
Non-Deliverable Forwards — NDFs
These are largely OTC offshore.
Important centres mentioned:
- Singapore
- Hong Kong
- London
- Dubai
- New York.
12.35 Forex Instruments
The Indian forex market includes:
- Spot
- Cash
- Tom
- Forwards
- FX swaps
- Currency swaps
- FX options
- exchange-traded currency futures/options.
12.36 FX-Retail
RBI facilitated:
FX-Retail
through CCIL in:
2019
Purpose:
- transparent pricing
- competition
- better pricing for retail users
- reduce transaction costs.
It operates on an anonymous, order-driven basis for USD/INR.
12.37 FX Derivatives and Underlying Exposure
Historically, access to OTC INR-linked forex derivatives was tied to documentary evidence of an underlying exposure.
Purpose:
Promote genuine hedging and limit speculative use.
In 2020, the framework unified resident/non-resident hedging facilities and permitted hedging of:
- contracted exposures
- anticipated exposures.
It also allowed freer cancellation/rebooking.
The PDF notes a USD 100 million OTC facility without underlying-exposure evidence, subject to the framework.
A user-classification framework was also introduced for complex derivatives.
12.38 ETCDs
For Exchange-Traded Currency Derivatives:
- SEBI prescribes position limits.
- AD Category-I banks may act as trading/clearing members subject to prudential requirements.
From February 2018, residents and FPIs could take INR-related currency positions up to:
USD 100 million equivalent
across INR currency pairs and exchanges, under the framework described.
12.39 Forex Market-Making Limits
AD banks must operate within:
- NOOPL — Net Overnight Open Position Limit
- AGL — Aggregate Gap Limit
These are fixed by the Board within prescribed regulatory limits.
12.40 Rupee Derivatives at IFSCs
In 2020, AD Category-I banks operating IBUs could offer:
INR Non-Deliverable Derivative Contracts
to non-residents.
Further expansion occurred:
- 2023 → resident non-retail users for hedging
- January 2024 → all residents for hedging.
Objective:
Develop onshore NDF markets and improve hedging flexibility.
12.41 Unauthorised Forex Trading
Residents may transact in forex only for permitted transactions and through:
- authorised persons
- authorised ETPs
- recognised stock exchanges, according to applicable rules.
RBI began publishing an:
Alert List
of entities/platforms not authorised for forex trading.
Critical exam point:
Absence from the Alert List does NOT mean an entity is RBI-authorised.
The list is explicitly stated to be non-exhaustive.
12.42 Market Abuse Regulation
Introduced:
2019
Covers:
- market manipulation
- benchmark manipulation
- misuse of information
- similar misconduct.
Objective:
fair + open + transparent markets with high ethical standards.
12.43 Electronic Trading Platforms — ETP
RBI introduced ETP authorisation directions in:
2018
Objectives:
- transparency
- lower transaction time/cost
- audit trails
- risk controls
- better monitoring.
Both new and existing ETPs must obtain RBI authorisation under the framework.
12.44 Legal Entity Identifier — LEI
LEI is:
20-character unique alphanumeric identifier
for parties to financial transactions globally.
Implemented in:
June 2017
initially for non-individual participants in OTC:
- rupee interest-rate derivatives
- foreign-currency derivatives
- credit derivatives.
Expanded in 2018 to broader RBI-regulated money, G-Sec and forex transactions.
Phased implementation was completed in:
2020.
12.45 OTC Derivatives — Market Makers
2021 directions aimed to:
- establish principle-based regulation
- remove overlaps
- accommodate sophistication of derivative markets.
They address:
- governance
- risk management
- customer suitability
- appropriateness.
For non-centrally cleared OTC derivatives, RBI requires exchange of:
- initial margin
- variation margin
to mitigate counterparty credit risk.
12.46 Financial Benchmark Administration
The PDF identifies key benchmarks including:
- USD/INR Reference Rate
- Treasury Bill Rates
- Government Securities valuation
- State Government Securities valuation
- MMIFOR.
A comprehensive risk-based regulatory framework for RBI-regulated financial benchmarks was implemented in:
December 2023
Financial Benchmark Administrators must maintain:
- governance
- oversight
- controls
- transparency
- conflict-of-interest safeguards.
MASTER COMPARISON — CHAPTERS 8–12
| Topic | Key takeaway |
|---|---|
| Regulation | Makes rules |
| Supervision | Enforces/assesses rules at entity level |
| CAMELS | Earlier supervisory model |
| RBS | Current SCB supervisory approach |
| SPARC | RBI’s RBS framework |
| SSM | Single supervisory contact |
| PCA | Early corrective intervention |
| CIMS | Centralised supervisory-return system |
| CRILC | Large-credit information |
| CFR | Central fraud database |
| DAKSH | Advanced supervisory workflow |
| UCBs | RBI regulation/supervision |
| StCB/DCCB | RBI regulation + NABARD supervision |
| PACS | Outside RBI banking regulation |
| NBFC | Bank-like financial intermediary, not a bank |
| PBC | Financial assets >50% + financial income >50% |
| NBFC SBR | Base → Middle → Upper → Top |
| NBFC-P2P | Platform, not own-book lending |
| NBFC-AA | Consent-based financial-data aggregation |
| EFD | RBI enforcement |
| Enforcement | Primarily monetary-penalty framework |
| Money market | Short-term funds |
| G-Sec market | Risk-free benchmark/yield curve |
| Corporate bonds | Diversifies funding away from banks |
| Forex | Managed float framework |
| NDF | Offshore non-deliverable INR derivative |
| FAR | Fully Accessible Route |
| VRR | Voluntary Retention Route |
| STRIPS | Separates coupon/principal |
| LEI | 20-character transaction-party identifier |
| ETP | RBI-authorised electronic trading platform |
HIGH-YIELD “DO NOT CONFUSE”
1. CAMELS vs SPARC
CAMELS = old, compliance/condition-oriented
SPARC = current RBS, forward-looking and risk-focused
2. Regulation vs Supervision vs Enforcement
Regulation → rules
Supervision → compliance/risk assessment
Enforcement → consequences for violations
3. Off-site vs On-site
Off-site → discover
On-site → verify/investigate
4. PCA vs Enforcement
PCA = supervisory corrective intervention
Enforcement = action for identified regulatory violations
5. UCB vs PACS
UCB = banking institution under RBI banking regulation
PACS = outside RBI banking regulation under the framework described
6. StCB/DCCB
RBI = regulation
NABARD = supervision
7. NBFC vs Bank
NBFCs perform bank-like financial intermediation but are governed primarily through the RBI Act/other applicable frameworks rather than the same BR Act framework applicable to banks.
8. NBFC-P2P vs NBFC-AA
P2P = connects lenders and borrowers
AA = aggregates financial data with consent
9. MTF vs VRR vs FAR
MTF → predictable FPI debt framework
VRR → long-term retention + flexibility
FAR → specified G-Secs accessible without specified macroprudential limits
10. CP vs NCD
CP = unsecured
NCD = secured
11. Call vs Notice vs Term
Call = 1 day
Notice = 2–14 days
Term = 15 days–1 year
12. Repo vs Market Repo
LAF Repo = RBI ↔ financial entity
Market Repo = market participant ↔ market participant
MASTER CHRONOLOGY — CHAPTERS 8–12
1889 — Anyonya Sahakari Mandali
↓
1904 — Co-operative Societies Act
↓
1919 — Co-operation transferred to Provinces
↓
1949 — Banking Regulation Act
↓
1963 — RBI obtains NBFC powers under Chapter III-B
↓
1966 — BR Act made applicable to co-operative societies
↓
1978 — Indian banks permitted intra-day forex trading
↓
1985 — Chakravarty Committee
↓
1986–92 — Major money-market instruments introduced
↓
1988 — DFHI
↓
1989 — Call/notice money interest-rate ceilings removed
↓
1991 — BoP crisis; banking reform; exchange-rate adjustment
↓
1992 — LERMS
↓
1993 — Unified market-determined exchange rate; DoS created
↓
1994 — BFS established; current-account convertibility
↓
1997 — Basel Core Principles; NBFC regulatory strengthening
↓
1999 — PBC clarification; NBFC NOF ₹25 lakh → ₹2 crore; IRS/FRA
↓
2001 — CCIL established
↓
2002 — CCIL operations; PCA introduced
↓
2006 — Basel II; WI trading; G-Sec short selling
↓
2010 — STRIPS
↓
2011 — CDS; 91-day T-Bill futures
↓
2012 — IRF for financial conglomerates
↓
2013 — RBS implementation begins; stress-testing guidelines
↓
2014 — CRILC; UCB/financial-sector reforms; LCR
↓
2015 — MTF for FPIs
↓
2016 — EFD; CFR; Sachet; differentiated bank licensing
↓
2017 — revised Basel/RBI frameworks; LEI; EFD regional structure later
↓
2018 — ETP; VRR later; stronger cyber framework
↓
2019 — NBFC statutory strengthening; FX-Retail; FAR later; market-abuse framework
↓
2020 — SBR preparation; forex-hedging framework; FAR; COVID-era changes
↓
2021 — SBR framework; SPARC; governance/capital changes
↓
2022 — SBR effective; DAKSH; FCS-OIS; NDDC expansion; NBFC PCA
↓
2023 — benchmark framework; G-Sec securities lending; green/other financial-market developments
↓
2024 — Retail Direct mobile app; revised forex hedging; INR NDDC expansion; UCB PCA framework
↓
2025 — UCB PCA framework effective, as stated in PDF
