Overview for Post certificate of registration compliance by NBFC

After the RBI grants the certificate of registration to an NBFC, certain registration requirements need to be fulfilled by NBFC to keep operating its business.

RBI has mandated to NBFC that apart from obtaining COR from the RBI, every NBFC must get itself registered with certain other Authorities like CERSAI, IU, FIU-IND, etc, to reduce the chances of fraud and money laundering.

Mandatory Post certificate of registration Compliances

CERSAI Registration:

CERSAI stands for Central Registry of Securitisation Asset Reconstruction and the Security Interest of India. After obtaining the certificate of registration from RBI, the NBFC shall proceed to register itself with CERSAI.

The mandatory registration requirement of NBFC with CERSAI post-issuance of COR is just because that the NBFC can file the security interest created concerning any equitable mortgage, immovable property, hypothecation, or any other property as may be prescribed by the RBI for NBFC.

The objective of CERSAI is to detect the fraud or any fraudulent activity and report and take action on the same.

Registration with CIC

CIC stands for “Credit information Company”. Post issuance of COR, It is mandatory for every NBFC to register the company with all the CIC’s to provide the credit data of its customers in a standardized format.

Currently, there are four CIC's registered in India i.e. Credit Information Bureau (India) Limited (CIBIL), Equifax Credit Information Services Private Limited (Equifax), Experian Credit Information Company of India Private Limited (Experian), and CRIF High Mark Credit Information Services Private Limited (CRIF).

So all the NBFC’s post-issuance of COR must get themselves registered with all these Credit information companies and provide the credit data of all its customers.

FIU – IND Registration:

FIU – IND stands for financial intelligence Unit. After the issuance of the Certificate of registration of NBFC, NBFC must get itself registered with FIU –IND as a reporting entity (RE) and also designate one person as Principal Officer (PO) of the company.

The registration with FIU – IND is mandated for all NBFC, so that the NBFC shall report the Cash transactions report and suspicious transaction reports as may be prescribed.

Information Utility registration:

Every NBFC after issuance of COR must also get itself registered with information utility and also provide the relevant details as may be required.

CKYC Registration:

Every NBFC post-issuance of COR must also get registered with the central KYC to gather records of the customers KYC. CKYC is a registry that maintains all the information about the customers of the NBFC and other financial institutions.

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Frequently Asked Questions (Faq)

  • Whether NBFC or the borrower will report the creation of security interest with CERSAI?

    It is the responsibility of the NBFC having COR to report the creation of Security interest with CERSAI.

  • Within How much time the NBFC must start its business after the issuance of certificate of registration?

    The NBFC must start its business as soon as possible, but no later than 6 months after issuance of certificate of registration.

  • Is it mandatory for NBFC to register with all the CIC’s post-issuance of certificate of Registration?

    Yes, RBI has mandated that the NBFC shall now register itself with all the CIC’s.

  • What are the consequences of Non-Compliances or delays in Post issuance of certificate of registration compliances by NBFC?

    Ans The RBI has the power to cancel the license of NBFC in case the NBFC does not comply or makes a delay in compliance Post issuance of certificate of registration.

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