NBFC - Overview and

Regulatory Framework

B. Renganathan
 Non Banking Financial Company

 Non Banking Company and

 Carrying on the business (principal business) of

a financial institution within the meaning of
clause (c) and (f) to Section 45-I of the Reserve
Bank of India Act, 1934
Business of a Financial Institution includes:

 Making loans and advances,

 Acquisition of shares, stock, bonds, debentures, securities issued by
Government or other marketable securities, etc,
 Letting / delivering of goods to hirer under Hire Purchase
Agreement,
 Carrying on any class of insurance business,
 Chit business or
 Accepting Public Deposits under any Scheme / Arrangement.

 Commodities Trading???????????
But it does not include:
 Agricultural Operations or

 Industrial Activity or

 Purchase or sale of goods (other than

securities) or providing of any services or
 Purchase, construction or sale of

immovable property
 Registration of an NBFC

 Minimum Net Owned Fund of Rs. 200 Lacs and

 Certificate of Registration u/s 45-IA of the Reserve Bank

of India Act, 1934
Banks Vs NBFCs
Evolution of NBFCs
 Committees

 James Raj Committee -1974- ban on prize chit

and other schemes
 Chakravarthy Committee- 1984- review the
working of monetary system
 Vaghul Committee-1987- measures to widen
and deepen the money market
 Narasimhan Committee- 1991-compulsory
registration with RBI of all NBFCs
 Committees
 Dr. A.C. Shah Committee- 1992- bringing
reforms in NBFC sector
 Khanna Committee- 1995 – comprehensive
and effective supervisory framework for
NBFC
 Vasudev Committee- 1998- entry norms,
prudential norms, issues concerning
unincorporated bodies
 Malegam Committee- MFIs
NBFC – the famous indian story…..
 Regulatory Framework

 Chapter III B, III C and V of RBI Act, 1934

 RBI Directions
 RBI circulars, notifications, Guidelines
 Types of NBFCs

Classification of NBFCs:
 Loan Company,

 Investment Company,

 Asset Finance Company

 Infrastructure Finance Company( 11/02/2010)

These are further classified into accepting / not

accepting Public Deposits
 Classification of NBFCs

 NBFCs-
 Accepting Public Deposits
 Not accepting public deposits
 Systemic important NBFCs (asset size > Rs.100cr)
 Definitions

 ―Asset Finance Co.‖ (AFC)– Co./FI – financing of physical

assets supporting productive/economic activity such as
 - Automobiles, tractors, lathe machines, generator sets, earth moving and material
handling equipments, moving on own power and general purpose industrial
machines

 Investment Company means any company which is a financial

institution carrying on as its principal business the acquisition
of securities.
 ―Loan Company‖ – principal business – finance through
loans/advances – not includes AFC
 Criteria for ascertaining NBFC

The Company shall be treated as an NBFC if:

 Its financial assets>50% of its total assets (netted off by

intangible assets) and
 Income from financial assets>50% of its gross income
 (press release dated April 8, 1999)

Both the requirements should be fulfilled.

NBFC-ND-SI – >/= 100 cr – on attainment of asset size

of 100 Cr…effective date…. ??????
 Principal business- determination thereof
 Not quantifiable – intention of parties
 Numerical dimension cannot take away the primary
nature of business
 RBI-Asset & Income criteria (only by a circular – implied
only through Auditor‘s certificate)
 Judicial pronouncements

 Section 372 A- investment company-

acquisition of shares…test of principal
business
 Prime business carried at the relevant point in
time.
 Exemptions
 Housing Finance Company
 Merchant Banking company
 Micro finance companies
 Mutual benefit companies
 Government companies
 Venture capital fund companies
 Insurance companies
 Stock broking companies
 Stock exchanges
 Nidhi & chit companies
 Securitization & Reconstruction companies
 Mortgage Guarantee companies
Public Deposits
 Legislative Framework for Public Deposits

Prior to CA 2013
 Section 58A-58AAA of the Companies Act, 1956
 Companies (Acceptance of Deposits) Rules, 1975
 Non Banking Financial Companies Acceptance of Public
Deposits (Reserve Bank) Directions, 1998

Way forward
 Sections 71 -76 of the Companies Act, 2013
 The Companies (Acceptance of Deposits) Rules, 2014
 Non Banking Financial Companies Acceptance of Public
Deposits (Reserve Bank) Directions, 1998
Public Deposits???
Any receipt of money by way of deposit
or loan but does not include...

The definition conveys “what not to be

treated as Public Deposits”
 Companies Act, 2013

 Non applicability to NBFCs

 Sections 71-74 & 76
 Acceptance of Deposits

But beware of ??????????????

 Companies Act, 2013
 Applicability of Section 75

 Damages for fraud- liability under section 447

 Class Action suits

NBFCs accepting deposits
NBFCs – Accepting / Holding Public Deposits
(NBFC-D)

Legislative Frame work – RBI Act, 1934, RBI Directives on

Acceptance of Public Deposits, Prudential Norms, etc.
 Certificate of Registration (accepting/ holding Public

Deposits),
 Creation of Reserves,

 Maintenance of Liquid Assets and

 Credit rating

 CRAR – 12%

 Quantum of PDs
 Minimum credit rating
 Period of Deposit – 12 to 60 months
 Quantum of deposits.
 AFC (min. invst grading) – 4xNOF

 Loan & Investment Companies – 1.5xNOF

 Rate of Interest
 Limitation on payment of Brokerage
 Deposits through Advertisement.
 Register of Deposits
 Information in the director‘s report
 Safe Custody of approved securities
 Systemically important NBFCs – not accepting /
holding Public Deposits
(NBFC-ND-SI)
 Till February, 2007 NBFCs – ND were subject to minimal regulation

 Concept of NBFC-ND-SI and Prudential norms

 NBFCs-ND having an asset size of Rs. 100 crores or more as per the
latest audited balance sheet were recognized as Systemecially
important NBFCs – not accepting / holding Public Deposits

 Capital adequacy requirement (CRAR-12%) and concentration of

credit and investment were made applicable to them
NBFCs – with an asset size of Rs. 50 crores or more
but less than 100 crores & not accepting / holding
Public Deposits

September, 2008
 Definitions

 ―Owned Fund‖ – paid up equity capital, CCPS, free reserves,

share premium a/c, capital reserves representing surplus
arising out of sale proceeds of asset. Does not include –
revaluation reserves, accumulated loss balance, book value of
intangible assets and deferred revenue expenditure.

 ―Systematically important non-deposit taking NBFC‖ – NBFC

not accepting/holding PDs and having total assets of Rs. 100
cr and above.
 Definitions

 Tier I capital – owned fund as reduced by-

 Investment in shares of other NBFCs
 Shares, debentures, bonds, o/s loans & advances
 Hire purchase and lease finance made to & deposits with
subsidiaries/companies in the same group > 10% of the
owned fund
 Perpetual debt instruments issued by NBFC-ND- SI
upto 15% of aggregate Tier I
 Definitions

 Tier II capital –
 Preference shares (non-CCPS)
 Revaluation reserve (disc. Rate of 55%)
 General provisions and loss reserves to specified extent.
 Hybrid debt capital instruments.
 Subordinated debt
 Perpetual Debt instruments issued by NBFC-ND-SI in
excess of what qualifies under Tier I
Concentration of Credit norms
 existing limits under para 18
 Lending limits
 To a single borrower- 15% of Owned funds
 To a single group of borrowers- 25% of Owned funds
 Investment limits
 In the shares of a Single Company- 15% of Owned funds
 In the shares of single Group of Companies - 25% of Owned
funds
 Investment & Lending both
 To a single Company- 25% of Owned funds
 To a single group of companies- 40% of Owned funds
Infrastructure Companies
 Definition
Infrastructure Loans:
Credit facility by NBFCs to a borrower by way of
- Term loan/project loan/equity shares
- Long term funded facility to a borrower company engaged in:
Developing/Maintaining/Operating any infrastructure facility in
foll sectors:
• Road/Highway Project
• Port/Airport/Inland waterway
• Telecommunication services
• Industrial park/SEZ
• Educational institutions/hospitals
 IFCs

 Non deposit accepting company

 Deployment of minimum 75% of total assets
in infrastructure loans
 Net owned fund of Rs 300 cr or more
 Minimum credit rating of ‗A‘
 CRAR of 15%
 Minimum Tier I capital of 10%
 Certification by auditors
 Concentration of credit norms (concession/ relaxation to
IFC)
 In addition to the existing limits under para 18
 Lending limits
 To a single borrower by 10% of Owned funds
 To a single group of borrowers by 15% of Owned funds

Lending & Investment Limits

to a single borrower by 5% of owned funds
To a single group of borrowers by 10% of owned funds
Core Investment Companies.
 Business Model:
 Holding stake in Group companies & funding them
 Difficulty in ascertaining: only for holding/ trade
 absence of clarity in the system- investment only for
holding—business of acquisition of shares.
 has systemic implications on account of access to
Public Funds
 A different footing than others-constraints-Regulatory
Framework
 CICs
 Not less than 90% of its net assets in group companies –
(investment in equity, preference shares, bonds, debentures, debt or loans)

Not less than 60% in – equity or convertible within a period of 10

years to equity

Net Assets: Total assets—cash& bank balances, investment in money

market instruments, money market mutual funds, advance payment of
taxes, deferred tax)
 Only for holding.

 No trading( except for dilution or disinvestment)

 Not to carry on any other financial activity(except

investment in bank deposits, money market
insturments, government securities, bonds, debentures
of group companies—granting of laons to group
companies, issue of guarantees on behalf of group
companies)

 Not holding/accepting public deposits.

 Systemically important CIC
 CIC
 Total assets > Rs 100 crores
 Either individually or with other CICs in the Group
 Raises or holds public funds

 Total Assets: All assets appearing on the asset side

 Public Funds: funds raised through public deposits,
CPS, debentures, ICDs, bank finance –other than
 Instruments convertible into equity shares within a period not
exceeding 10 years
 CICs
 Certificate of Registration – CICs-ND-SI asset size >/= 100 crs

 Capital to Risk Assets Ratio – Adjusted Networth not

less than 30% of Risk weighted assets +risk adjusted
value of off-balance sheet items
 Leverage Ratio: Outside Liabilities =< 2.5xANW

 Exemptions: CICs fulfilling above ratios – exempt –

Min. NOF and Prudential Norms.
 Residuary NBFC

 NBFI- company
 Receives deposit under any scheme or arrangement
 By contribution or subscription/ sale of units /certificates/other
instruments
 And not :
 AFC
 HFC
 LC
 IC
 Insurance company
 Residuary NBFC

 Principal business: acceptance of deposits & investing in

approved securities
 FD- tenor -12 months to 84 months
 Maintain investments as per RBI directions + liquid assets
 Mobilisation and deployment different from other NBFCs
 Comply with Prudential Norms
 Micro Fiance companies

 Non deposit taking NBFC

 Minimum NOF –Rs 5 crs
 Not less than 85% of its net assets in ―qualifying assets‖
 Loan to a borrower whose rural household income is not

more than Rs. 60k/ urban household income not more than
Rs 1.2 lakhs
 Loan amount not to exceed Rs 50k
 Loan without collateral
 Tenure: >/=24 months…no prepayment penalty
 MFI

 Capital adequacy at 15%

 Asset classification & provisioning Norms
 Interest not to exceed 26%
 No penalty on delayed payment
 Mutual benefit company/Nidhi company

Fundamental Principal: to mobilise savings from members

Notified u/S 620A of the Companies Act, 1956
Members to be allotted atleast 10 shares
Lends money only to members
Only individuals to be members
No dealing with non members.
 Chit Funds

 Chit Funds Act, 1982.

 Regulated by State Governments
 Subscribers in a Group contribute installments
for a certain no of months
 Return of money –auctions / tender (provides a
ump sum to the needy)
 Money borrowed by a subscriber is against his
own future contribution
 Infrastructure Debt fund- NBFC

 Taking over loans extended to infrastructure

projects created through PPP route AND
 Completed one year of operations
 Tripartite agreements amongst IDF,
Concessionaire and the Project authority
 Sponsor- only NBFC- IFCs
 Minimum NOF –Rs 300 crs
 Existence for atleast 5 years
 Factors- NBFC
 ―Business of acquisition of Receivables or
financing by way loans or any other means‖
 Financial assets in Factoring - 75% of total
assets + income from Factoring -75% of gross
income.
 NOF- Rs. 5 crs
 Mortgage Guarantee Companies

 Providing guarantee to HFCs and banks on

behalf of home loan borrowers
 Invocation of guarantees– in case of default
 Mortgage Guarantee Company ( Reserve
Bank) Guidelines, 2008
 NOF – Rs. 100 crores
Special Auditor’s Report
Non Banking Financial Companies Auditor’s
Report (Reserve Bank ) Directions, 2008
 Applicable to every auditor of a NBFC
 Additional report to the Board of Directors on: (all NBFCs)
 If the NBFC has obtained CoR and contiunes to carry on the NBFC business
 NBFC continues to do such business based on income & asset pattern
 In case of AFCs- proper classification as such..
 NBFCs- accepting deposits
 Public deposits & other borrowings are within the limits and if in excess
regularized in the manner envisaged in the Directions
 Any default in repayment to Depositors
 Confirmation on whether minimum investment grade credit rating has been
obtained confirmation on any default in paying deposits
 Confirmation on compliance of prudential norms, capital adequacy , liquid
asset requirement
 Confirmation on compliance with furnishing various returns in time to RBI
Qualifications – reasons thereof to be stated
A separate report on such qualifications (non compliance on any of the Directions)
to be forwarded directly to RBI

NBFCs – not accepting deposits

 Resolution of board for not accepting deposits

 Has it accepted any deposits

 Confirmation on compliance with prudential norms

 In case of SI_ND_authentication of the capital adequacy ratio

 If the annual statement of capital funds , risk assets/exposures- furnished to

RBI in time.
 Certification by auditors

 Continuation as a NBFI
 Income/ asset pattern to be disclosed
NBFC – Other Business
 Entry into Insurance & Agency business – on
fee basis and without risk participation.
 Insurance business through a JV with risk
participation( no recourse to NBFC)

 Issue of Credit Card (including co-branded

credit cards.

 Distribution of Mutual Fund products.

Change in Management and Control
 Prior written permission of RBI:
 Acquisition through control
 Merger with another entity giving control to
the other entity
 Merger – transfer of ownership > 10%
 Merger under Companies Act.
 Change in Control/Management

 Public notice – 30 days prior to sale of/transfer of

ownership/ transfer of control.
 – by NBFC and transferor/transferee/jointly.
 Control – same as defined in SAST.
 To indicate – intention to sell/transfer, particulars of
the transferee, reasons thereto.
 Published in one leading national and local (place of
regd office of NBFC) vernacular language
newspaper.
 Exit option to Deposit holders.
 Change in Control/Management

 Transfer Vs further issue of shares????????

 Control through AoA!!!!!!!!!!

FDI & ODI- NBFCs
 FDI in NBFCs

 Automatic route – 100% FDI permitted in 18

activities.
 Approval route – Investment Companies.
 Minimum Capitalization norms.
 100% foreign owned NBFC – step down subsidiary NBFCs
without additional capital.
 JV NBFCs (less than 75% FDI) – setup by NBFC
subsidiaries complying with minimum capitalization.
 NBFC (Non Fund Based Activities) – No subsidiary
 Half yearly reporting..- Statutory Auditor‘s
Certificate
 Overseas Investments by NBFCs

 Prior approval from regulatory authorities in both

India and abroad.
 NOC from DNBS of RBI.
 Activities intended to be carried out by overseas
entity – to be clearly stated
 Direct investment permitted – activities approved
under FEMA.
 Core activity regulated by a financial regulator abroad
 ODI Limit Vs Para 18 ???
 Aggregate overseas investment </=100% of NOF
 Investment in single entity </= 15% of NOF
 Level of net NPA </= 5% of net advances
 NBFC- earning profits in the last 3 years
 Satisfactory regulatory compliance and servicing of
public deposits
 Annual certificate statutory auditors
Miscellaneous
NBFCs – Reserves
 Statutory Reserves – sec 45IC of RBI Act.
 Not less than 20% of the net profits

 Creation of Debenture Redemption Reserves

(DRR)
 Amendments

 Provision on standard assets:

 0.25% of the outstanding assets
 To be shown separately as ―contingent provision
against Standard Assets‖

 Submission of B/S and P/L Account:

 All NBFCs to finalize B/S within 3 months from
the date of finalization of B/S
 Amendments
 Not to be partners in Partnership Firm

 No NBFC (including those accepting public deposit) shall

contribute to capital of a firm or become a partner

 NBFC (including those accepting public deposit) which

had already contributed to the capital shall seek early
retirement from the firm
 Amendments

 Prohibition –loan against its own debentures &

shares
 Accounting Year- April to March
 Pledge of shares to NBFCs as collaterals– on
line reporting
 Only Group 1 securities as collaterals– loan> 5
lakhs
 Amendments

 Participation in Interest Rate Futures Exchanges as

clients
 Participation in Currency Futures Exchanges
 Credit Default Swaps: NBFCs permitted to buy credit
protection to hedge their credit risk against bonds
held
 NBFCs are ― credit Institutions” – Credit Information
Companies (Regulation) Act, 2005.
 Reporting of secondary market transactions of bonds–
on FIMMDA platform
 Amendments
 Registration of equitable mortgages with
Central Registry and with CERSAI.
 Amendments
 Prohibition on ---Lending against the security of its own
debentures
 Issue of only secured NCDs—including short term NCDs
 Security creation within a month– else proceeds to be kept in
Escrow Account (1 month Vs 4 months under the Indian
Registration Act)
Filings and Disclosures to RBI
 Filings / disclosures with RBI

 Deposit taking NBFCs

 Annual Report within 15 days of AGM,
 Certificate from Statutory Auditors that all the liabilities in respect of Deposits is
reflected in the B/S and the company is in the position to meet the same,
 Directors‘ Report to contain particulars on unclaimed matured deposits,
 Statutory Auditors Certificate on continuity of NBFI business,
 A copy of credit rating obtained on annual basis along with one of the half yearly return
on Prudential Norms,
 NBS 1 Annual Return on Deposits
 NBS 2 Half yearly return on prudential norms (within 3 months from the expiry of half
year),
 NBS 3 Quarterly Return on Liquid Assets (within 15 days from the close of the quarter),
 NBS 4 Monthly return of critical parameters by a company holding public deposits.
 NBS 5 Monetary and supervisory return by NBFC having public deposits of Rs. 20 Crore
and above.
 NBS 6 Monthly return on exposure to capital market (Companies having an asset size of
Rs. 100 crores or more)
 ALM - Half yearly return (PDs >/= 20 cr or asset size >/= 100 cr)
 Audited balance sheet and auditor‘s report.
 Filings / disclosures with RBI

 NBFC-ND-SI
 NBS 7 – An annual statement of capital funds, risk weighted assets, risk assets ratio

 Monthly Return on important financial parameters of NBFC-ND-SI

 ALM –NBS-1 – Monthly return on short term dynamic liquidity,

 ALM – NBS- 2 – Half yearly return on structural liquidity

 ALM – NBS- 3 – Yearly return on interest rate sensitivity,

 Statutory Auditors Certificate on continuity of NBFI business and

 Passing of Board Resolution for not accepting Public Deposits

 Filings / disclosures with RBI

 NBFCs – 100 cr. > asset size > 50 cr.

 Basic information like name of the company, address,

NOF. P&L during the last three years has to be submitted
quarterly by non-deposit taking NBFCs with the asset size
between Rs. 50 Cr and 100 Cr.

 Filing of Quarterly Return on important financial

parameters
Corporate Governance
 Audit Committee.
 Risk Management Committee – monitor asset
liability gap, strategize actions to mitigate risks.
 Nomination Committee – to ensure fit and proper
status of directors.
 Board – to be apprised of progressive risk
management system, policy and strategy followed.
 Rotation of partners of audit firm: Every 3 years….a
suugestion….
Fair Practices Code
 Guidelines on Fair Practices Code

 To be framed and approved by the BOD of

NBFCs
 Applications for Loans and their processing.
 Loan application forms – necessary info in the
interest of the borrower – enabling an informed
decision.
 System of giving acknowledgement and setting of
time frame for loan disposal
 Guidelines on Fair Practices Code

 Loan Appraisal
 NBFCs should
 – sanction letter containing amount of loan,
annualized rate of interest
 – Keep the acceptance of T&C by borrower on its
record.
 – Furnish copy of loan agreement with all
enclosures, to all borrowers at the time of
sanction/disbursement.
 Guidelines on Fair Practices Code

 Disbursement, and changes in T&C

 Notice to borrower in case of changes in any T&C.

 Recall/accelerate payment or performance to be in

consonance with Loan Agreement.

 Release of all securities on repayment of all

outstanding dues or realization thereof.
 Guidelines on Fair Practices Code

 General
 Refrain from intereference in affairs of the
borrower except for purposes of T&C in loan
agreement.
 Intimation of consent/objection – within 21 days of
request of transfer of borrowal account by the
borrower.
 No undue harassment, pestering at odd hours, use
of muscle power etc. for recovery.
 Guidelines on Fair Practices Code

 Grievance Redressal Mechanism

 To be set up by the BOD to resolve disputes.

 Periodic review of the compliance of the Fair

Practices Code.

 Reports of the review to be submitted to BOD at

regular intervals.
Issue of NCD Directions
 Issue of NCD directions

 ―Corporate‖ – Co. as per Companies Act, 1956. (including .

NBFCs)
 NCDs- debt instrument issued by any corporate (including
NBFCs)
 Tenure: not < than 90 days--- upto 1 year from the date and
limited to the period of credit rating
 Mode of issue: Private placement
 Denomination: Minimum Rs 5 lakh in value with a multiple of
Rs. 1 lakh
Eligibility Criteria
 Tangible Networth of atleast 4 Crores.

 WC limit, term loan – sanctioned – banks/all

India financial institutions.

 Corporate account – Standard asset.

Rating Requirement
 Corporate – Credit rating from any of
 CRISIL, CARE, ICRA, Fitch Ratings India Pvt.
Ltd.

 Min Rating – P2 of CRISIL or other

equivalent.
Maturity
 Maturity >= 90 days from date of issue.

 Put/Call Option if any – after 90 days from

issue.

 Total tenor =< Validity period of credit rating.

Limits and the amount of issue of NCDs

 Aggregate NCD issue not to exceed the lower

of–
 Limit approved by the board.

 Quantum to which the credit rating relates to.

 Issue to be completed within 2 weeks.

Procedure for Issuance
 Disclosure of financial information to prospective
investors. (standard market practice????)

 Auditors to certify – eligibility conditions met.

 Compliance to Co.‘s Act, SEBI reg and other

regulations.

 Debenture certificate – issued within prescribed

period.
Debenture Trustee
 Appt of Debenture Trustee for each NCD
issue.

 DT should be regd with SEBI DT regulations.

 DT shall submit all such info to RBI as it may

require from time to time.
Eligible Investors
 NCDs may be issued to –
Individuals, Banks, PDs, corporate bodies, insurance
companies, MFs, NRIs, FIIs.

 Investment by PDs and banks – subject to approval of

respective regulator.

 Invt. By FIIs – within prescribed limits by SEBI.

 Invt. By banks, PDs, FIs only in demat form.

Roles and Responsibilities
 Corporate – comply with guidelines and
procedures.

 Debenture Trustees –
 Within 3 days of closure, submission to RBI
- report on issuance details to RBI.
- quarterly report on o/s NCDs of upto 1year
maturity.
- report on defaults in repayment if any
Contd…

 Credit Rating Agencies –

 Adherence to code of conduct for CRAs as prescribed by

SEBI.

 Exercise fair discretion – determining validity of rating

assigned – on basis of strength of the issuer.

 Monitor the rating and revise if necessary from time to

time.
Impact…………
 No issue of debentures for less than 90 days
(curbing the widely prevalent practice!!!!!!!!)
 Issue of unsecured debentures- Deposits?? – Acceptance
of Deposit Rules to be complied??
 Debenture Trustee– why if unsecured????
 Violation of directions – penalties, debarring
from NCD market.
Private placement of NCDs- NBFCs
 Companies Act, 2013

 Section 42
 Rule 14 of The Companies (Prospectus and
Allotment of Securities) Rules, 2014
 RBI Circulars—
Last update—a bane (NBFCs)
 Validity of Offer document– 6 months from the date of Board
resolution
 Minimum investment by a single investor- Rs 25 lakhs or in
multiples of Rs 10 Lacs
 No investors- restricted to 49 and identified upfront
 End use to be stated
 Prohibition on lending to group companies, Associates (not
applicable to CIC)
 Resource plan to be in place by September 30, 2013.
 Companies Act, 2013 Vs RBI (for NBFCs)

 CA 2103- no restriction on the number of persons to

whom offer is made
 RBI- offer restricted to 49 persons

 CA 2013- multiple offers at the same time prohibited

 RBI- issue purely based on Resource Planning
policy
 CA 2013- minimum application size Rs 20000
 RBI- Rs 25 lakhs or in multiples of Rs 10 Lacs