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List of Policies For NBF Cs

The document is a comprehensive checklist of policies required for Non-Banking Financial Companies (NBFCs) in India, detailing various governance frameworks, audit policies, risk management strategies, and compliance requirements. It includes sections on accounting standards, statutory auditor guidelines, investment policies, and digital lending regulations, among others. Each policy is marked for implementation, indicating the need for adherence to regulatory standards set by the Reserve Bank of India and other governing bodies.
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0% found this document useful (0 votes)
10 views9 pages

List of Policies For NBF Cs

The document is a comprehensive checklist of policies required for Non-Banking Financial Companies (NBFCs) in India, detailing various governance frameworks, audit policies, risk management strategies, and compliance requirements. It includes sections on accounting standards, statutory auditor guidelines, investment policies, and digital lending regulations, among others. Each policy is marked for implementation, indicating the need for adherence to regulatory standards set by the Reserve Bank of India and other governing bodies.
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
Available Formats
Download as PDF, TXT or read online on Scribd
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List of Policies for NBFCs


S. No. Section/ Particulars Tick if
Clause apply
Implementation of Indian Accounting Standards March 13, 2020
1. Annex 1, 1 Governance Framework

2. 1 (a) Business Model*

3. 1(a) Portfolios*

4. 1(b) Policy for Sales

5. 1(c) Board approved methodologies for computation of Expected
Credit Losses (ECL)

Guidelines for Appointment of Statutory Central Auditors (SCAs)/Statutory Auditors (SAs) of
Commercial Banks (excluding RRBs), UCBs and NBFCs (including HFCs) April 27, 2021
6. 4.2 Policy for Statutory Auditors by Board/Local Management
Committee (LMC)*

7. 10 Statutory Audit Policy and Appointment Procedure* (Should be
published on the website)

Technical Guide on Audit of Non-Banking Financial Companies
8. Policies For Asset Classification And Provisioning

9. 5.6 Board-Approved Policy For Money Market Operations

10. 5.17 Accounting Policy On Modification And Derecognition Of
Financial Assets

11. 5.19 Investment Policy

12. 5.43 Illustrative Accounting Policy

13. 5.29 Accounting Policies Of Subsidiaries/Associates ☐
14. 5.44 Financial Asset Acquisition Policy ☐
15. 5.44 Revenue Recognition Policy ☐
16. 6.2 Investment Policy Describing The Nature Of Treasury ☐
Operations
17. 6.2 Liquidity Risk Management Policy

18. 6.3 Information Technology General Controls (ITGC) ☐
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List of NBFC Policies

19. 6.8 IT Governance, IT Policy, Information & Cyber Security, IT ☐


Operations, IS Audit, Business Continuity Planning and IT
Services Outsourcing.
20. 6.10 Valuation Policies, And the Conformity of The Valuation Model ☐
With Those Policies, Consistent With The Guidelines Issued By
The Concerned Regulating Authority.
21. 6.24 Lending Policy ☐
22. 7.2 Fit & Proper Status of Directors Policy* ☐
23. 7.4 Policy Defining the Role of Chief Compliance Officer ☐
24. 8.6 KYC Policy with regard to Customer Identification Procedures ☐
and Acceptance Policy.
25. Appendix
A
Policy For Treasury Business ☐
26. Appendix
A
Remuneration Policies ☐
27. Code of Conduct for its Dealers ☐
28. Treasury Risk Management Policy ☐
29. Credit Policy ☐
30. Foreclosure Policies ☐
31. Repossession Policies (policy for recovering outstanding ☐
principal and interest through legal proceedings, such as
foreclosure or repossession)
32. Policies to Manage Currency-Induced Risk (Regarding Foreign ☐
Currency)
33. Derivative
s
Risk Management Policies Pertaining to Derivatives ☐
34. Policies For Hedging And/ Or Mitigating Risk And Strategies ☐
And Processes For Monitoring The Continuing Effectiveness Of
Hedges/ Mitigants
35. Accounting Policy for Recording Hedge And Non-Hedge ☐
Transactions; Recognition Of Income, Premiums And Discounts;
Valuation of Outstanding Contracts; Provisioning, Collateral
And Credit Risk Mitigation
Master Direction - Reserve Bank of India (Prudential Regulations on Basel III Capital
Framework, Exposure Norms, Significant Investments, Classification, Valuation and Operation
of Investment Portfolio Norms and Resource Raising Norms for All India Financial Institutions)
Directions, 2023 September 21, 2023
36. 7.5.3 (ii) Investment Policies ☐
37. 8.10 Valuation Policy ☐
38. (v) Collateral Management Policies ☐
39. 15.3.3.4 Policies for Broad Business Objectives ☐
40. 15.3.3.6 Internal Controls Management Policies ☐
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41. 16.2.3 Counterparty Credit Risk Management Policies, Processes And ☐


Systems
42. 16.3 Internal Policies, Systems and controls to identify, measure, ☐
monitor, manage, control and mitigate its risk concentrations in
a timely manner
43. 16.7 Liquidity Risk Management Policy ☐
44. 16.11
17.7
Disclosure Policies ☐
45. 16.13 Compensation policies ☐
46. Annex-13,
V
Risk Management policy ☐
47. Annex-13, Capital Management Policy ☐
IX
48. Table DF-
6
Credit Risk Mitigation Policy ☐
49. 19.2.1 (i) Refinancing Policy* ☐
50. 20.1 Exposure Policy* ☐
51. 21.10 Policies for Determining Connectedness Among ☐
Counterparties*
52. 27.1 Bridge Loans and Internal Finance Policy* ☐
53. 27.3.1 Policy on Exposures to InvITs* ☐
54. 33.1 Investment Policy* ☐
Master Circular – Basel III Capital Regulations May 12, 2023
55. 5.10.1 Valuation Policy*

56. 7.3.2 (v) Collateral Management Policies ☐
57. 10.1 Internal Capital Adequacy Assessment Process (ICAAP) * ☐
58. 12.3.3.1 Risk Management Policies* ☐
59. 13.2.3 Counterparty Credit Risk Management Policies ☐
60. Annex 14
- IX
Capital Management Policy ☐
61. Table DF-
3
Credit Risk Management Policy

Guidelines on Digital Lending September 02, 2022
62. 5.3 Digitally Signed Documents (on the letter head of the RE) viz., ☐
KFS, summary of loan product, sanction letter, terms and
conditions, account statements, privacy policies of the
LSPs/DLAs with respect to borrowers data, etc.
63. 5.7 Privacy Policy ☐
64. 9 Data Privacy Policies and Storage Systems ☐
65. 11.2 Policy Guidelines regarding the storage of customer data ☐
including the type of data that can be stored
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66. 12 Comprehensive Privacy Policy for DLAs and LSPs engaged by ☐


REs
Guidelines on Default Loss Guarantee (DLG) in Digital Lending June 08, 2023
67. 12.1 Policy before entering into any DLG Arrangement* ☐
68. 11 Disclosures Requirements (LSPs with whom they have a DLG ☐
arrangement shall publish on their website the total number of
portfolios)
Framework for Compromise Settlements and Technical Write-offs June 08, 2023
69. 1 Policies for Undertaking Compromise Settlements*

Prudential Framework for Resolution of Stressed Assets June 7, 2019
70. 9 Policies for Resolution of Stressed Assets, including the ☐
Timelines for Resolution*
Fair Lending Practice - Penal Charges in Loan Accounts August 18, 2023
71. Lending Policy ☐
72. Key Fact Statement ☐
Responsible Lending Conduct – Release of Movable / Immovable Property Documents on
Repayment/ Settlement of Personal1 Loans September 13, 2023
73. 5 Policies and Procedures for Customer Information ☐
Master Circular - Fair Practices Code July 01, 2015
74. III Policy is in place with regard to Code of Conduct by Field Staff ☐
and systems for their Recruitment, Training and Supervision*
75. C (i) Policy for Lending Against Gold* ☐
Foreign Exchange Management (Overseas Investment) Directions, 2022 August 22, 2022
76. 27 (3) Policy laying down the Requirements or Documents or ☐
information to be obtained by their branches to ensure
compliance with said provisions of FEMA
Guidelines on Compensation of Key Managerial Personnel (KMP) and Senior Management in
NBFCs April 29, 2022
77. 1 Compensation Policy* ☐
78. 3 Compensation Policy of Key Managerial Personnel ☐
Master Direction - Know Your Customer (KYC) Direction, 2016 February 25, 2016 Updated as
on January 04, 2024
79. 4(a) Know Your Customer(KYC)policy duly approved by the Board of ☐
Directors
(a) Customer Acceptance Policy;
(b) Risk Management;
(c) Customer Identification Procedures (CIP); and
(d) Monitoring of Transactions
80. 9 Customer Acceptance Policy ☐
81. 17 ii Policy Delineating a Robust Process of Due Diligence for ☐
Dealing with Requests for Change of Mobile Number in such
Accounts*

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82. 38 Internal KYC Policy* ☐


83. 63(j) KYC/AML Policies and Procedures ☐
84. 64 (b) (ii)
(d)
Intermediary RE shall have Effective Risk-Based Policies and

Procedures regarding Wire Transfer
85. 64 (b) (iii) Risk-Based Policies and Procedures Regarding Wire Transfer
(b)

Master Direction - Reserve Bank of India (Financial Statements of All India Financial
Institutions - Presentation, Disclosure and Reporting) Directions, 2016 June 23, 2016
86. 2 Significant Accounting Policies ☐
87. 3.8.3 (i)
(c)
Policies for Hedging and / or Mitigating Risk and Strategies ☐
88. 3.8.3 (i) Accounting Policy for Recording Hedge and Non-Hedge ☐
(d) Transactions
Master Direction on Information Technology Governance, Risk, Controls and Assurance
Practices November 7, 2023
89. 4 (c) Enterprise-Wide Risk Management Policy ☐
90. 4 (c) Operational Risk Management Policy ☐
91. 8(b)(i) IT Policy ☐
92. 13 Change and Patch Management Policy ☐
93. 14 Data Migration Policy ☐
94. 22 Risk Management Policy ☐
95. 24 Information Security Policy ☐
96. 24 Cyber Security Policy ☐
97. 24 (a) Cyber Crisis Management Plan ☐
98. 27 Cyber Incident Response Plan ☐
99. 27 Recovery Management Policy ☐
100. 28 Business Continuity Plan ☐
101. 28 Disaster Recovery Plan ☐
102. 30 IS Audit Policy ☐
103. 26 Vulnerability Assessment/Penetration Testing ☐
104. 25 (b) Acceptable Use Policy ☐
105. 19 Access Management Policy ☐
106. 8(b)(i) Bring Your Own Device Policy ☐
107. 26 (f) Cloud Security Policy ☐
108. 16 Cryptography Policy ☐
109. 17(a) Data Processing Policy ☐
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110. 17(b) Data Transfer Policy ☐


111. 8(b)(i) Electronic Transactions Policy ☐
112. 8(b)(i) Encryption Policy

113. 9(e) Hardware Purchasing and Software Upgradation Policy ☐
114. 8(b)(i) Incident Management Policy ☐
115. 8(b)(i) IT Administration Policy ☐
116. 8(b)(i) IT Emergency Management Policy ☐
117. 12(e) IT Service Agreement Policy ☐
118. 12 IT Vendor Management Policy ☐
119. 8(b)(i) Mobile Device Encryption Policy ☐
120. 10 Outsourcing Policy ☐
121. 18 Physical Security Policy ☐
122. 24(b)(ii) Security Awareness and Training Policy ☐
123. 9(e) Software Purchasing Policy ☐
124. 9(e) Use of Software Policy ☐
125. 10 Vendor Risk Assessment Process ☐
Master Direction - Non-Banking Financial Company – Non-Systemically Important Non-
Deposit taking Company (Reserve Bank) Directions, 2016 September 01, 2016, Updated as on
August 29, 2023
126. 10 (1) (i) Investment Policy ☐
127. 11 Policy on Demand/ Call Loans ☐
128. 37 (2) (b) Loan Policy Including the Verification of The Ownership of Gold ☐
129. 29A(3) Policy on Penal Charges ☐
130. 30A(1)(i) Policy Framework About the Possible Impact of Change In ☐
Interest Rate On The Loan Leading to Changes In EMI
131. Annex II
C
Liquidity Risk Management Policies

132. 5.1.3 Prudential Norms on Change in Ownership of Borrowing ☐
Entities
133. B (i) Lender Shall Frame Different Sets of Policies for Borrowers ☐
Belonging to Different Sectors Within The SME
134. Annex VII
(2) (xii)
Policy For Refinancing and Restructuring of Loans ☐
135. Annex
XIV (1)
Board Approved Policy Regarding Undertaking Mutual Funds ☐
Distribution
(ii)
136. Annex
XVII (1)
Board Approved Policy for Resource Planning ☐
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137. Annex Policy Is Put in Place for Timely Provision of Credit Information ☐
XVIII 2.2 To And Access To Credit Information From CRILC
138. Annex
XIX 5.1
Outsourcing Policy ☐
139. Annex XX Board Approved Policies That Clearly Articulate and Document ☐
Their Business Models and Portfolios
Reserve Bank of India – Master Direction on Minimum Capital Requirements for Operational
Risk June 26, 2023
140. Annex 2, Policy For Loss Data Identification, Collection And Treatment ☐
1.1.1
141. Annex-3 Operational Risk Policy ☐
Master Direction on Outsourcing of Information Technology Services April 10, 2023
142. 9 IT Outsourcing Policy ☐
143. 17 IT Risk Assessment Policy ☐
144. 20 a) Board-Approved Policy and Appropriate Service Level ☐
Arrangements/ Agreements with its Group Entities
145. 22 a) Outsourcing of IT Services Policy ☐
146. Appendix Documented Cloud Adoption Policy
1, 4

147. Appendix Information Security Policy ☐
1, 6 (d)
Master Direction on Issuance and Operation of Prepaid Payment Instruments October 11,
2017 (Updated as on November 17, 2020)
148. 7.2 PPI issuers shall have a clear laid down Policy, duly approved by ☐
their Board, for issuance of various types / categories of PPIs
and all activities related thereto
149. 7.11 a) Co-Branding Arrangement shall be as per the Board approved ☐
policy of the PPI issuer
150. 14 Risk Management Policy regarding PPI ☐
151. 15.2 Board Approved Information Security policy for the Safety and ☐
Security of the Payment Systems
152. 16.2 Customer Protection and Grievance Redressal Policy regarding ☐
PPI
153. 16.4.8 Policy for Complaint Resolution* ☐
154. 16.4.9 Policy for Customer Protection*

Prudential norms on Income Recognition, Asset Classification and Provisioning pertaining to
Advances – Clarifications November 12, 2021
155. F Income Recognition Policy for Loans with Moratorium on ☐
Payment of Interest
Master Circular - Prudential norms on Income Recognition, Asset Classification and
Provisioning pertaining to Advances October 1, 2021
156. 3.1 Income Recognition Policy ☐
157. 9.1 Policies for Resolution of Stressed Assets* ☐
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Master Direction – Reserve Bank of India (Non-Banking Financial Company – Scale Based
Regulation) Directions, 2023 October 19, 2023 (Updated as on November 10, 2023)
158. 28 Policy On Demand/Call Loans ☐
159. 29 Investment Policy ☐
160. 37.2.2 Loan Policy ☐
161. 45.14.1 Policy For Lending Against Gold ☐
162. 37.3 Policy For Standardization of Value of Gold ☐
163. 40 Policy On Grant of Loans to Directors, Senior Officers And ☐
Relatives Of Directors*
164. 45.3.3 Policy on Penal Charges or Similar Charges on Loans* ☐
165. 45.5.1.(iv) Policy Policies and Procedures for Customer Information* ☐
166. 45.6 Reset Of Floating Interest Rate on Equated Monthly

Instalments (EMI) Based Personal Loans
167. 83 Policy For Internal Capital Adequacy Assessment Process ☐
(ICAAP)
168. 90.1 (i) Risk Management Policy ☐
169. 91.6 Policy In Respect of Exposures to A Single Party/A Single Group ☐
of Parties
170. 95.2 Policies To Safeguard the Independence of The CRO Chief Risk ☐
Officer
171. 96 Policy For Fit and Proper Criteria’ For the Directors ☐
172. 99.1 Compensation Policy* ☐
173. 105 Policy For Licensing as Authorised Dealer- Category II ☐
174. 110.5.2 (ii) Policy Approved by Its Board To Determine The Existence Of A ☐
Group of Connected Counterparties
175. 113 Listing & Disclosures Policy ☐
176. 114.1 Board Approved Policy ☐
177. 120 Lending Policies ☐
178. Annex II Board Approved Policy for Business Model & Portfolios ☐
179. B (i) Policies For Borrowers Belonging to Different Sectors Within ☐
The SME
180. Annex VI Liquidity Risk Management Policy, Strategies and Practices ☐
181. Annex
XIII 5.1
Outsourcing Policy ☐
182. Annex
XIII 6.1
Policy and Service Level Agreements/Arrangements* ☐
183. Annex XV
1
Policy for Resource Planning*

184. Annex
XVIII1 (ii)
Policy Regarding Undertaking Mutual Funds Distribution* ☐
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185. Annex XX Policy Perpetual Debt Instruments (PDI) ☐


5.2
186. Annex
XXII
Accounting Policies Regarding Key Areas of Operations at One ☐
Place Along With NTA In Their Financial Statements. A
Suggestive List Includes – Basis of Accounting, Transactions
Involving Foreign Exchange, Investments - Classification,
Valuation, Etc., Advances And Provisions Thereon, Fixed Assets
And Depreciation, Revenue Recognition, Employee Benefits,
Provision For Taxation, Net Profit, Etc.
*Applicable Upon Middle Layer
187. Annex
XXII,
Risk Management Policies Pertaining to Derivatives ☐
3.3.3
188. Annex
XXII,
Policy on Dealing with Related Party Transactions on Its ☐
Website And Also In The Annual Report
4.3.2
Master Direction - External Commercial Borrowings, Trade Credits and Structured Obligations
March 26, 2019 (Updated as on December 22, 2023)
189. 8.1 Risk Management Policy, for ECB ☐
*Board Approval mandatory.

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