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Dvara Analysis Weblog | Observe on RBI’s Immediate Corrective Motion Framework for Non-Banking Monetary Firms


Sowmini G Prasad
Dwijaraj Bhattacharya

The Immediate Corrective Motion Framework

On December 14, 2021, citing their rising dimension and interconnectedness, the Reserve Financial institution of India (RBI) issued the Immediate Corrective Motion (PCA) framework for Non-Banking Monetary Firms (NBFCs), proposed to return into impact from October 1, 2022[1]. The PCA framework applies to all deposit-taking NBFCs (NBFCs-D) and all non-deposit taking NBFCs (NBFCs-ND) within the Center, Higher, and Prime Layers, recognized beneath RBI’s new Scale Primarily based Rules[2]. It excludes NBFCs not accepting/not intending to simply accept public funds, Authorities Firms, Main Sellers, and Housing Finance Firms (HFCs). 

The PCA framework is meant to behave each as a supervisory instrument and a instrument for efficient market self-discipline to revive the monetary well being of the supervised entity in query. It proposes to trace the next indicators throughout three key areas – capital, asset high quality, and leverage (just for Core Funding Firms (CICs)).

There are three graded danger thresholds for every of the above indicators, and breach of any of those thresholds will lead to invocation of corrective actions beneath the PCA framework. These corrective actions embrace each necessary and discretionary actions that the RBI might prescribe and vary from remedial measures meant to focus on enchancment in particular monetary well being indicators to particular supervisory actions that permit RBI to advocate NBFCs for decision.

On this notice , we focus on how the present method of the PCA framework is inconsistent with the targets it seeks to attain. We argue that this method has led to 2 errors – the inclusion error and the exclusion error. Additional, we additionally argue that the PCA framework is an incomplete treatment.

Inclusion and Exclusion Errors

The inclusion error arises on account of RBI’s determination to oversee smaller NBFCs beneath the PCA framework, i.e., Center Layer NBFCs, which don’t pose any menace to the soundness of the monetary system. This represents a misutilisation of the RBI’s supervisory capability. However, the exclusion error arises because the RBI has left massive and interconnected HFCs and people (HFCs) with permission to simply accept retail deposits outdoors the scope of the PCA framework.

An Incomplete Treatment to Deal with Dangers

We additionally argue within the notice that the PCA framework is an insufficient treatment to handle the dangers originating from the NBFC sector. To really shield retail and unsophisticated time period depositors of NBFCs and make sure the least affect on systemic stability, along with the PCA framework, the RBI must also – a) take away the regulatory arbitrage that NBFCs-D proceed to have in comparison with NBFCs-ND and non-financial corporates, i.e., permission to entry retail buyer’s cash with a much less stringent public disclosure regime as in contrast that relevant for issuance of listed debt, and b) put in place a strong decision framework alongside the strains of a Decision Company (RC) as advisable by the Monetary Sector Legislative Reforms Fee (FSLRC) for resolving NBFCs-D and NBFCs within the Higher and Prime Layer.

The total notice is obtainable right here .

[1] See ‘Immediate Corrective Motion (PCA) Framework for Non-Banking Monetary Firms (NBFCs)’, December 14, 2021, Reserve Financial institution of India,

[2] See ‘Scale Primarily based Regulation (SBR): A Revised Regulatory Framework for NBFCs’, October 22, 2021, Reserve Financial institution of India,

Cite this Merchandise:


Sowmini Prasad, D. B. (2022). Observe on RBI’s Immediate Corrective Motion Framework for Non-Banking Monetary Firms. Retrieved from Dvara Analysis.


Sowmini Prasad, Dwijaraj Bhattacharya. “Observe on RBI’s Immediate Corrective Motion Framework for Non-Banking Monetary Firms.” 2022. Dvara Analysis.


Sowmini Prasad, Dwijaraj Bhattacharya. 2022. “Observe on RBI’s Immediate Corrective Motion Framework for Non-Banking Monetary Firms.” Dvara Analysis.



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