Annual Compliance and filing of applicable returns for Non- Banking Financial Company- Account Aggregator (NBFC-AA).

• INTRODUCTION:

Account Aggregator (AA) network was introduced as a financial data-sharing system by Reserve Bank of India (RBI) when it issued the Master Direction viz Non-Banking Financial Company (NBFC) – Account Aggregator (Reserve Bank) Directions, dated September 02, 2016.

 

Account Aggregator (AA) is a Non-Bank Finance Company (NBFC) engaged in the business of providing the service of retrieving or collecting financial information pertaining to the customer. No financial information of the customer is retrieved, shared or transferred by AA framework without the explicit consent of the customer. AA transfers data from one financial institution to another based on an individual’s instruction and consent. Registering with an AA is fully voluntary for consumers.

 

A NBFC-AA shall be always considered in base layer for the purpose of reporting.

 

• PROGRESS UPDATE OF ACCOUNT AGGREGATOR: (AS ON 30.10.2024)

The Account Aggregator framework has been growing in market adoption across banking, securities, insurance, and pension sectors with the following developments:

• 112 Financial Institutions have gone live both as FIP and FIU.
• 56 Financial Institutions have gone live as FIP.
• 410 Financial Institutions have gone live as FIU.
• More than 2.2 billion financial accounts are enabled to share data on AA.
• 34 million users have linked their accounts on the AA framework.

 

• APPLICABLE RETURNS AND DUE DATE FOR FILING THE RETURN:        

Sr. No.	Return Name	Periodicity	Reference Date	Applicability
1.	DNBS02 –  Important Financial Parameters (NBFCs – BL).	Quarterly	31st  March/ 30th June/ 30th September/ 31st December	NBFCs in Base Layer.
2.	a.    DNBS04A- Short Term Dynamic Liquidity (STDL).	Quarterly	31st  March/ 30th June/ 30th September/ 31st December	NBFC-BL with asset size of ₹100 crore and above solely or at Group level.
	b.   DNBS04B-Structural Liquidity & Interest Rate Sensitivity.	Monthly	31st March/ 30th April/ 31st May/ 30th June/ 31st July/ 31st August/ 30th  September/ 31st October/ 30th November/ 31st December/ 31st January/ 28th or 29th February as Applicable	NBFC-BL with asset size of ₹100 crore and above solely or at Group level.
3.	DNBS10-Statutory Auditor Certificate (SAC) Return	Yearly	31st March
4.	DNBS13 – Overseas Investment Details	Quarterly	31st  March/ 30th June/ 30th September/ 31st December
5.	Form A Certificate	Annual	31st March

 

• ADDITIONAL NBFC COMPLIANCES IN REGARDS TO REGISTRATIONS FOR COMMENCEMENT OF OPERATIONS:

Sr. No.	Particular	Type of NBFC	Description	Due Date
1.	C-KYC Registration (CKYCR)	All regulated entities	Every regulated entity (comprising NBFCs) shall do KYC while disbursing loans/ creating account relationship.	Within ten days from the date of account relationship.
2.	Central Registry of Securitization Asset Reconstruction and Security Interest (CERSAI)	All Financial Institutions	–	–
3.	Financial Intelligence Unit (FIU- IND)	All regulated entities	Report certain transactions to FIU- IND agency mentioned under Rule 3 of PMLA Rules 2005	Within the 15th day of the Succeeding month & within 7 working days of being satisfied that the transaction is suspicious
4.	Credit Information Companies (CIC’s)   With all four CIC’s (RBI/DoR/2024-25/125 DoR.FIN.REC.No.55/20.16.056/2024-25 January 06, 2025) CRIF Transunion CIBIL Experian Equifax	All regulated entities	Shall get a Membership of Credit Information Companies	All Non-Banking Financial Companies Including Residuary Non- Banking Companies Must get registered with CIC and provide DATA without fail from the date of Commencement of Business
5.	ISO Certification (Recommended)		ISO 27001 for Information Security Management Systems to strengthen compliance.   ISO 9001 a globally recognized standard for quality management systems (QMS)

 

• OTHER REGULATORY REPORTINGS

Sr. No.	Particular	Type of NBFC	Description
1.	Centralized Information Management System (CIMS) Reporting-	To all NBFC’s	A cloud-based system launched by the Reserve Bank of India (RBI) to improve the efficiency of its regulatory reporting system.

 

• OPERATIONAL AND OTHER COMPLIANCES

Particular	Description	Duration	Due Date
Grievance Redressal Framework	Establish and maintain a grievance redressal mechanism.	Ongoing	Immediate reporting of customer grievances.
Legal Entity Identifier (LEI)	Maintain and renew LEI as required.	Ongoing	Renewal before expiration.
Suspicious Transaction Reporting	Report suspicious transactions to FIU-IND under PMLA guidelines.	As required	Immediately upon detection.
IT Security Compliance	Ensure data protection under IT Act and adhere to ISO 27001 standards.	Ongoing	Regular audits and updates required.

 

• APPLICABLE COMMITTEES FOR NBFC-AA:
• Audit Committee

An Account Aggregator shall constitute an Audit Committee, consisting of not less than three members of its Board of Directors.

 

• Nomination Committee

An Account Aggregator shall form a Nomination Committee consisting of not less than three members of its Board of Directors to ensure ‘fit and proper’ status of proposed/ existing directors.

 

• Risk Management Committee

The account aggregator shall establish a well-documented risk management framework which shall include

1. A sound and robust technology risk management framework;
2. Strengthening system security, reliability, resiliency, and recoverability; and
3. Deploying strong authentication to protect access to customer data and systems.

 

• Yearly compliance of :

1. Net owned fund;
2. Know your customer policy ALM policy and;

• Review of other applicable policies and approval of the same by board.

 

• PLACE OF RENDERING SERVICE:

The place of rendering services generally shall be our office situated at Off No. 106, B- Wing, Sr. No. 55, Sukhniwas, Mangalwar Peth, Pune-411011, Maharashtra, India.

 

• PROFESSIONAL FEES:

The professional fees for the above cited assignment shall be:

Sr. No.	Particular	Amount (in INR)
1.	Regular reporting to the Reserve bank of India Pertaining to Department of Non- Banking supervision (DNBS)	Shall be Discuss in Meeting
2.	Various Registrations under ·         C-KYC ·         CERSAI ·         FIU-IND ·         CIC’S ·         ISO Certification (Recommended)

*GST @18% shall be applicable;

Out of pocket expenses and Government fees upon certification registration shall be at actuals.

 

• TERMS AND CONDITIONS:
• Assigner shall nominate specific person(s) for co-ordination and shall provide relevant data support in concern assignment Mr. Pramod Ladda and Mr. Aadarsh Singh will be assigned person.
• All the payments should be made in the name of “Ladda Bhutada & Associates”.
• All the disputes shall be subject to Pune Jurisdiction.
• Termination of this contract requires 30 days’ notice.
• Any fee estimate agreed with you is necessarily based on the assumption that the information required for our work is made available in accordance with agreed timetables, and that your key executives and personnel are available during the course of our work. If delays or other unanticipated problems which are beyond our control occur this may result in additional fee for which invoices will be raised.
• This proposal is limited to activities mentioned in the scope in this proposal. Any other work will be charged based on mutual discussion.

 

“Our priority is Client’s satisfaction and we believe in maintaining healthy and long-term relations with our clients.”

In case of any explanation /information needed, please feel free to contact us.

Thanking you and assuring best professional services

 

Sd/-

PRAMODKUMAR R. LADDA

Company Secretary & Insolvency Professional

LADDA BHUTADA & ASSOCIATES.