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Additional disclosures under Scale Based Regulation for NBFCs Additional disclosures in

RBI Circular dated April 19, 2022 Annual Financial


Statements
[as per Scale Based
Effective for annual financial statements for year ending March 31, 2023 and onwards
Regulations (para 3.2.2.f)]

NBFC Base NBFC Middle NBFC Upper


Layer Layer Layer Corporate Governance
Report

Related Party Disclosure of Corporate Governance Other disclosures


Exposures Report (new)
Disclosure on modified
Disclosure (new) Complaints opinion, impact &
• (new) Breach of views
• Exposure to real • Related party – as • Received from • Listed NBFC: as per
estate sector covenant of loan
per Companies Act, customer SEBI LODR
availed/debt
• Exposure to capital 2013 and applicable • (new) Received from Regulations
securities
market accounting standard the office of • Unlisted NBFC: Items of income and
• (new) Divergence in expenditure of
• Sectoral exposure • Disclosures include: Ombudsman • As per formats Asset Classification exceptional nature
• (new) Intra-group Borrowings#, • (new) Top five given in this and Provisioning.
exposures deposits#, grounds of Circular which
advances#, • Based on the
complaints received includes Board &
• (new) Unhedged assessment by
investments#, from customers committees’ Breaches in covenants
foreign currency RBI/NHB including incidences of
purchase/sale of (indicative list has also composition
exposure & policies • Roadmap for default
assets, interest been provided) • Details of non-
to manage currency compliance with
paid/received, etc. compliances,
induced risk disclosure
# The outstanding at the penalties, etc.,
year end and the requirements of
shareholding of Divergence in asset
maximum during the year SEBI LODR (only for classification and
are to be disclosed. directors, no. of NBFC-UL)
meetings. provisioning.
These are additional disclosures and do not substitute disclosures
specified under other laws, regulations, or accounting and financial
reporting standards. However, if the disclosure is already covered in
other places the same may not be required to be repeated again. Vinod Kothari Consultants | finserv@vinodkothari.com

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