Submission of Records by Banks to Statutory Authorities

Banks and other financial institutions are required to submit various returns, many of which are statutory under the RBI Act of 1934, the Banking Regulation Act of 1949, FEMA 1999, the SEBI Act of 1992, Income Tax 1961, etc. Submission frequency of these returns varies from daily, weekly, fortnightly, monthly, quarterly, half-yearly, and annual.

Regulatory reporting is a fundamental aspect of banking operations. It involves the meticulous preparation and timely submission of periodic reports to regulatory authorities, which are instrumental in monitoring and supervising the functioning of banks.

Regulatory Reports to be submitted to RBI:

Payment of dividend, Report on issue of Subordinated Debt, raising of Upper Tier II Capital, Perpetual Debts and Equity Capital (Qualified Institutional Placements-QIP, Preferential issue to Promoters, GDR issue) together with copy of document, Form I, II, III    (operational guidance for DEA Fund scheme), Monthly Statement on Gold Monetisation Scheme, 2015, Statement of Gold and Silver imported during the month, Return on exposures to QCCP, Monthly Return on Aggregate Resources Raised, Return on Large Exposure, Ind AS proforma, Format for interim reporting to Reserve Bank of India – BC Outlets, PSU Investment statement, Statement of Merchant Acquiring Business of RRBs, Proforma Ind AS Financial Statement for AIFIs, Statement of shareholding (Restrictions on holding shares), Non-banking Asset,                                                                                                   

Some of the above returns are to be submitted in hard copies. The following returns are submitted in hard copies.

1. A yearly return certified by the statutory auditor and to be submitted by banks in original within one month from the date of completion of their annual audit     (Hard copy and e-mail),
2. Reporting of Long term Advance,
3. Statement on default in Merchanting Trade Transactions (MTT) AD category,
4. Issuances of NCDs having original maturity of up to one year need to be reported,          
5. Details of dividends declared during the financial year and other details
6. The borrowers are required to report actual ECB transactions through Form ECB- 2 Return through the AD Category I bank on a monthly basis to reach DSIM within seven working days from the close of the month to which it relates. Changes, if any, in ECB parameters should also be incorporated in Form ECB 2 Return.
7. Whole Bank Long Form Audit Report (LFAR) and Compliance thereof.
8. Half-Yearly Review of Investment Portfolio, A half-yearly review (as of March 31 and September 30) of the investment portfolio will be undertaken by the banks that have been placed before their Boards within two months, i.e., by end-May and the end of November. A copy of the review report put up to the Bank’s Board, should be forwarded to the Reserve Bank (concerned Regional Office of DBS, RBI) by May 15 and November 15 respectively.
9.           Proforma for reporting details of profits remitted to Head Office by foreign banks operating in India,     
10. Monthly return claiming a refund from the DEA Fund (Original hardcopy to be submitted by the 15th of the succeeding month to which the claim pertains) Form II Hard copy, Certificate of reconciliation of balances for the Half Year ended June/December to be submitted by banks not later than July 31 and January 31 Form III.    

Banks and financial institutions are required to submit CRILC Reporting for Stressed Assets. Under CRILC reporting, banks must furnish information about borrowers with aggregate exposures of INR 5 crore or more, categorizing them as standard, sub-standard, doubtful, or loss assets. The aim is to facilitate early identification and timely resolution of stressed assets within the banking system. Strict quarterly reporting deadlines are set by the RBI, with non-compliance leading to penalties. The banks need to submit the data on large exposures within 30 days from the end of the quarter through the eXtensible Business Reporting Language (XBRL) reporting platform of RBI. Compliance with CRILC reporting is paramount for banks to maintain their regulatory standing and avoid penalties.

Suspicious Transaction Reports (STRs) are a critical regulatory reporting requirement for Indian banks. These reports are filed when transactions are suspected to be related to illegal activities such as terrorism financing or money laundering. STRs should be filed as soon as a reasonable suspicion arises.

Indian banks are also required to engage in SLR (Statutory Liquidity Ratio) and CRR (Cash Reserve Ratio) reporting. To monitor compliance of maintenance of statutory reserve requirements viz. CRR and SLR by the Scheduled Commercial Banks (SCBs), the Reserve Bank of India has prescribed statutory returns i.e. Form A Return (for CRR) under Section 42(2) of the Reserve Bank of India (RBI) Act, 1934 and Form VIII Return (for SLR) under Section 24 of the Banking Regulation Act, 1949. The reports should be submitted fortnightly.

 Asset classification reporting is a crucial regulatory requirement for Indian banks. It involves categorizing assets based on their credit quality and risk level. Banks should report the figures of NPAs to the Regional Office of the Reserve Bank at the end of each year within two months from the close of the year in the prescribed proforma.

In addition, a large number of returns are submitted through soft copies on various electronic platforms. For example, Form-X – statement of assets and liabilities [CIMS] and Balance Sheet of SCBs (Sec. 31 of the BR Act, 1949) through EDSP. The reporting banks need to submit the IBS return through the Electronic Data Submission Portal (EDSP). The EDSP requires user credentials for login. A detailed guideline on IBS is available on EDSP. The link for EDSP is https://dbie.rbi.org.in/EDSP.

Regulatory reporting to the Income Tax department:

Any transaction exceeding Rs 10 lakh in a savings bank account or Rs 50 lakh in a current bank account in a financial year should be disclosed to the Income Tax department. Deposits above Rs 2 lakh in a single transaction also fall under scrutiny. Banks should ensure that records of TDS are collected and remitted to the income tax department. TDS may be on account of interest paid on deposits, salary paid to employees, and pension paid to bank’s pensioners, etc.’ The reporting formats contain detailed guidelines on the compilation and manner/procedure of submission of Tax Deducted at Source (TDS).

Regulatory reporting to SEBI

In terms of SEBI circular RBTI ( G I Series) Circular No.1(95-96) dated April 21, 1995, all Bankers to Issues are required to submit quarterly reports for each quarter of the year and annual report for each financial year in respect of their activities of Bankers to Issues in prescribed formats. It was also required to submit quarterly reports within 3 weeks of the last day of the quarter and the annual report within 2 months of the close of the financial year. A copy of the aforesaid Circular was once again forwarded to the Banks vide our letter No. PMD/SU/2715/98 dated May 26, 1998, for necessary compliance. The pdf/excel files containing the quarterly report shall be sent to  email id    bti@sebi.gov.in  with the title  “Quarterly report submitted by aaa for the quarter ended xxx yyyy” where aaa represents the name of the  Banker to the  Issue,  xxx represents the month at the end of the quarter and yyyy represents the year.

SEBI has reviewed various reports currently submitted by ‘Designated Depository Participants (DDPs)’ and Custodians for ease of compliance reporting and regulatory purposes.  Post review, SEBI has vide Circular SEBI/HO/AFD/ AFD-SEC-2/P/CIR/2024/8 dated January 25, 2024, notified that the following reports appended below, shall henceforth be submitted on the SEBI Intermediary Portal (SI Portal) by DDPs and Custodians.

The SEBI’s new reporting formats pertain to information submitted by the FPIs to the DDPs and Custodians.  The DDPs and Custodians shall upload the data for February 2024 on the SI portal by the 15th of March, 2024, and thereafter for every month. Similarly, for the quarter ending March 2024, the reports shall be uploaded by the 15th of April, 2024.

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