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RBI Urges Enhanced Compliance from Banks and NBFCs for Financial Integrity

Introduction

Recent comments by the Reserve Bank of India (RBI) Governor have raised significant concerns regarding the adherence of financial institutions, specifically banks and non-banking financial companies (NBFCs), to regulatory standards. The emphasis on monitoring "value ratios, risk weights, and end-use" of loans underscores the importance of compliance to prevent improper allocation or speculative use of funds.

Concerns Over Non-Compliance

The Governor pointed out a troubling increase in home equity loans, commonly referred to as top-up housing loans. He expressed concerns that non-adherence to regulatory standards could lead to the misallocation of lent funds. Consequently, the RBI has urged regulated entities to closely monitor the end-use of these loans and maintain compliance.

Another critical issue highlighted is the growing disparity between deposit growth and credit growth, which could lead to structural liquidity challenges for banks and affect the deposit-credit ratio. The Governor has called for lenders to refine their underwriting processes and enhance monitoring of loans after they have been sanctioned. The effectiveness with which regulated entities respond to these warnings and address unethical practices remains uncertain.

Habitual Non-Compliance Observed

An analysis of the RBI's circulars reveals a concerning trend of persistent non-compliance among regulated entities, resulting in significant monetary penalties that ultimately impact the public. Such penalties indicate a troubling reality, as violations of regulatory guidelines are often unveiled only during random inspections by the RBI, which cannot consistently monitor all entities. Despite penalties, breaches of obligatory provisions persist.

Charter of Customer Rights

The RBI has established the Charter of Customer Rights, which mandates that regulated entities implement its principles fully:

  1. Right to Fair Treatment: Customers should be treated respectfully and without discrimination based on gender, age, religion, caste, or physical ability.
  2. Right to Transparency, Fair, and Honest Dealing: Financial service providers must present contracts that are clear and comprehensible, explicitly outlining key terms, conditions, and risks.
  3. Right to Suitability: Financial products must meet the customer’s needs based on their financial assessment.
  4. Right to Privacy: Customers' personal information must be safeguarded unless consent is provided or legal requirements necessitate disclosure.
  5. Right to Grievance Redress and Compensation: Customers should have an uncomplicated process for addressing grievances, with clear policies for compensation in case of errors or lapses.

Despite these outlined rights, compliance among banks and regulated entities is often lacking.

Regulatory Mandates and Compliance

On May 6, 2016, a press release from the Press Information Bureau of the Government of India reiterated the RBI’s commitment to safeguarding customers through regulations emphasizing the five fundamental rights mentioned above. Banks are required to develop a Customer Rights Policy either independently or as part of existing policies, subject to Board approval. Despite these regulations, compliance frequently falls short.

Furthermore, the RBI has released guidelines on the Fair Practices Code for Non-Banking Financial Companies (NBFCs), which detail necessary disclosures and recovery practices, revised to reflect the emergence of new NBFC categories and increased gold-based lending activities.

Grievances and Lack of Accountability

The Banking Ombudsman Scheme allows customers to submit complaints related to deficiencies in banking services. However, reports have indicated a lack of significant findings regarding depositor fraud by RBI-regulated entities in recent years. When instances of non-compliance surface, banks often respond with vague or evasive replies, leading to frustrations for complainants who feel unheard.

Key issues include:

  • “Reset Clause”: Unexpected changes in interest rates for fixed-rate loans by some banks.
  • “Exceptional Circumstances”: Need for clarity on the conditions under which banks can modify loan rates.
  • Broader Definition of Default: Default may extend beyond non-payment to include circumstances like divorce or litigation.
  • Disbursement Practices: Occasionally, funds are disbursed directly to builders instead of borrowers, which complicates situations if property possession is delayed.
  • Third-Party Assignments: Borrowers should understand agreements that allow third parties to assume loans.

Technology-Driven Compliance Monitoring

The RBI's circulars from January 2024 and November 2024 mandate the implementation of workflow-based, enterprise-level compliance monitoring systems for all regulated entities, with a deadline extended to April 30, 2025. Integration with the DAKSH portal for real-time oversight and reporting is also required.

Liquidity Coverage Ratio (LCR) Amendments

In April 2025, the RBI amended LCR norms to reduce the digital deposit buffer to 2.5% and rationalize the treatment of certain wholesale funding sources, effective from April 2026. These adjustments aim to strengthen banks’ liquidity resilience.

Non-Compliance and Regulatory Actions

Many banks and NBFCs continue to issue loans secured by immovable property without adequate precautions, often depending solely on the asset's value. Despite the issuance of various circulars on Fair Practices Codes, the level of compliance remains questionable, leaving borrowers at risk.

While lenders have the authority to recover dues, this must be in accordance with RBI directives and statutory regulations. It is crucial to scrutinize all banking documents to ensure alignment with existing laws and uphold constitutional rights, including the right to equality (Article 14), the right to live (Article 21), and the right to property (Article 300 A).

The RBI's circular dated August 7, 2004, which addresses deficiencies in loan sanctioning and monitoring, continues to be pertinent. Persistent issues contribute to the classification of accounts as Non-Performing Assets (NPAs).

Conclusion

The RBI's latest directives emphasize the need for enhanced compliance among banks and financial institutions. The regulatory framework delineates significant responsibilities for both lending institutions and borrowers, highlighting the critical importance of transparency and accountability throughout the financial sector.