PPB Module BChapter Notes4–6 Marks Expected

Finance to MFIs / Co-Lending Arrangements with NBFCs

Principles & Practices of Banking | Module B · Chapter 38

Chapter 37 covered Agricultural Finance under Priority Sector Lending. This chapter expands the credit ecosystem — covering how banks fund NBFCs and MFIs, the regulatory boundaries for such funding, the Co-Lending Model (CLM) for priority sector delivery, and RBI's Scale Based Regulation (SBR) framework for NBFCs.

By Bankopedia.co.inUpdated 2026JAIIB PPB · Module B

📌 Why This Chapter Matters in JAIIB

Expect 4–6 questions from this chapter. Key focus areas: NBFC exposure caps (single NBFC: 20% Tier I; group: 25% Tier I; gold loan NBFC: 7.5% Tier I+II, extendable to 12.5% for infrastructure); NBFC-MFI qualifying assets ≥ 85% of net assets; first cycle loan ≤ ₹75,000; subsequent ≤ ₹1,25,000; margin cap(10% for large MFIs >₹100 cr portfolio; 12% for others); CLM — NBFC must retain ≥ 20% share; all CLM transactions through escrow; on-lending PSL cap: 5% of total PSL (averaged across 4 quarters); SBR 4 layers (BL → ML → UL → TL; TL ideally empty).

Key Facts & References — Chapter 38 at a Glance

NBFC-MFI Min NOF:₹5 crore (₹2 crore for North-Eastern Region)

Qualifying assets threshold:≥ 85% of net assets

First cycle loan ceiling:₹75,000

Subsequent cycle ceiling:₹1,25,000

Max household income — rural:₹1,25,000 per annum

Max household income — urban:₹2,00,000 per annum

Total indebtedness ceiling:₹1,25,000 (education & medical excluded)

Loan tenure (>₹30,000):Not less than 24 months; prepayment without penalty

Max multi-lender:Not more than 2 NBFC-MFIs to same borrower

Margin cap — large MFI:10% (portfolio >₹100 crore)

Margin cap — others:12%

Processing charges:Maximum 1% of gross loan amount

Single NBFC exposure:Max 20% of bank's Tier I capital

Group of connected NBFCs:Max 25% of bank's Tier I capital

Gold loan NBFC exposure:Max 7.5% Tier I + Tier II (up to 12.5% for infrastructure on-lending)

On-lending PSL cap:5% of total PSL, averaged across 4 quarters

CLM NBFC minimum share:Minimum 20% of individual loans retained on NBFC books

CLM escrow:All bank-NBFC transactions routed through escrow account with bank

CLM complaint resolution:Within 30 days of complaint registered with NBFC

SBR layers:BL (Base) → ML (Middle) → UL (Upper) → TL (Top); TL ideally empty

Background — NBFCs & Microfinance

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38.1 Non-Banking Finance Companies (NBFC)

An NBFC is a company registered under the Companies Act engaged in loans and advances, acquisition of securities, leasing, hire purchase, insurance, or chit business — but not institutions whose principal business is agriculture, industrial activity, purchase/sale of goods, providing services, or sale/purchase/construction of immovable property.

▸Competitive edge: superior understanding of regional dynamics.
▸Well-developed collection systems and personalised services.
▸Lower transaction costs, quick decision-making, prompt service.
▸Housing Finance Companies (HFCs) are specialised NBFCs providing housing credit.

38.2 Microfinance & NBFC-MFIs

Microfinance provides small loans and financial services to poor and low-income households to promote financial inclusion, increase income levels, and improve living standards.

▸Delivered through SCBs, SFBs, RRBs (direct + through BCs and SHGs).
▸Cooperative banks, NBFCs, and MFIs registered as NBFCs.
▸9 NBFC-MFIs have been licenced to start universal/small finance banks.
▸NBFC-MFIs hold ~30%+ share of India's microfinance sector.

38.3 Bank Finance to NBFCs — General Framework

Bank borrowings are a major source of funds for NBFCs including NBFC-MFIs. This widens the reach of institutional credit to sectors/areas not fully covered by banks. Most aspects of bank financing to NBFCs have been deregulated; RBI has issued separate guidelines for collaborative lending (Co-Lending Model).

Bank Finance to NBFCs — Eligibility, Restrictions & Exposure Caps

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38.3.1 NBFCs Registered with RBI

Banks may extend need-based working capital facilities and term loans to all NBFCs registered with RBI engaged in infrastructure financing, equipment leasing, hire-purchase, loan, factoring, and investment activities. All NBFCs (including HFCs) must register with RBI except the following exempted categories:

▸(i) Micro Finance Companies (subject to conditions)

▸(ii) Asset Reconstruction Companies (registered under SARFAESI 2002)

▸(iii) Nidhi Companies

▸(iv) Mutual Benefit Companies

▸(v) Chit Companies (under Chit Funds Act, 1982)

▸(vi) Merchant Banking Companies (subject to conditions)

38.3.2 Activities NOT Eligible for Bank Credit to NBFCs

✗ Bills discounted/rediscounted by NBFCs

Exception: Banks may rediscount bills from NBFCs arising from sale of commercial vehicles, two-wheelers, and three-wheelers — provided bills are drawn by manufacturer on dealers and represent genuine transactions.

✗ Investments of NBFCs in shares/debentures

Both current and long-term investments in any company/entity.

✗ All types of loans to subsidiaries/group entities

Loans and advances by NBFCs to their subsidiaries, group companies, or entities.

✗ Bridge loans / interim finance

Banks should not grant bridge loans of any nature against capital/debenture issues or pending raising of long-term funds.

✗ Collateral security of shares

Shares and debentures cannot be accepted as collateral for secured loans to NBFCs.

38.3.3 Restriction on Guarantees for Placement of Funds with NBFCs

Banks should not execute guarantees covering inter-company deposits/loans, thereby guaranteeing refund of any type of deposits/loans accepted by NBFCs/firms from other NBFCs/firms, irrespective of source (including trusts and institutions). Guarantees should not be issued to indirectly enable placement of deposits with NBFCs.

Exception: Banks can provide partial credit enhancement (PCE) to bonds issued by NBFC-ND-SIs and HFCs.

38.3.4 Prudential Ceilings for Exposure of Banks to NBFCs

Category	Exposure Ceiling
Single NBFC (excluding gold loan companies)	Maximum 20% of the bank's Tier I capital
Group of connected NBFCs / group of connected counterparties with NBFCs	Maximum 25% of the bank's Tier I capital
Single NBFC predominantly lending against gold jewellery (≥50% of financial assets)	Maximum 7.5% of Tier I + Tier II capital; up to 12.5% if additional exposure is for on-lending to infrastructure sector
NBFCs with gold loans ≥50% of total financial assets (aggregate)	Banks must have an internal sub-limit within the overall NBFC limit

On-Lending Model & NBFC-MFI Definition & Prudential Norms

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38.4 Bank Loans to NBFCs for On-Lending

Banks can extend loans to NBFCs for the purpose of on-lending to the priority sectors. This mode is not applicable to RRBs, UCBs, SFBs, and LABs.

(a) Loans to MFIs (NBFC-MFIs, Societies, Trusts, etc.)

Banks other than SFBs may extend credit to registered NBFC-MFIs and other MFIs (Societies, Trusts) which are members of RBI-recognised SROs for the sector, for on-lending to individuals and members of SHGs/JLGs. Eligible for priority sector classification.

(b) Loans to NBFCs (other than MFIs)

Bank credit to registered NBFCs for on-lending is eligible for priority sector classification under respective categories, subject to specified conditions.

Bank credit to HFCs approved by NHB for refinance, for on-lending for purchase/construction/reconstruction of individual dwelling units or for slum clearance/rehabilitation — eligible as priority sector.

(d) Cap on On-Lending

Bank credit to NBFCs (including HFCs) for on-lending under (b) and (c) should be within 5% of total priority sector lending, averaged across four quarters.

38.5.1 Definition — NBFC-MFI

An NBFC-MFI is a non-deposit taking NBFC (other than a company licensed under Section 8 of the Companies Act, 2013) that fulfills:

(a) Minimum Net Owned Funds:₹5 crore (₹2 crore for NBFCs registered in the North-Eastern Region)

(b) Qualifying Assets Share:Not less than 85% of net assets must be 'qualifying assets'

Qualifying Asset — Ceiling on Loan Amounts:Maximum ₹75,000 (first cycle) and ₹1,25,000 (subsequent cycles)

Qualifying Asset — Household Income Ceiling:Borrower with annual income not exceeding ₹1,25,000 (rural) or ₹2,00,000 (urban/semi-urban)

Qualifying Asset — Total Indebtedness:Maximum ₹1,25,000. Education and medical expenses excluded.

Qualifying Asset — Tenure:Not less than 24 months for loans above ₹30,000; prepayment without penalty

(d) Restriction on Micro-finance:An NBFC not qualifying as NBFC-MFI may extend micro-finance loans not exceeding 10% of total assets

38.5.2 MFIs Exempted from Registration with RBI

MFIs fulfilling all three of the following are exempted:

▸(i) Licensed under Sec. 8 of the Companies Act, 2013 (Sec. 25 of the 1956 Act)
▸(ii) Providing credit not exceeding ₹50,000 for a business enterprise and ₹1,25,000 for a dwelling unit to any poor person
▸(iii) Does not accept public deposits as defined in RBI Directions

38.5.3 Prudential Norms for NBFC-MFIs

(a) Capital Adequacy

Applicable CRAR norms as prescribed by RBI from time to time.

(b) Asset Classification

▸Standard asset: No default perceived; normal risk.
▸Non-performing asset: Interest/principal overdue ≥ 90 days.

▸Aggregate loan provision ≥ higher of: 1% of outstanding loan portfolio, OR
▸50% of aggregate instalments overdue > 90 days & < 180 days, and 100% of instalments overdue ≥ 180 days.
▸CRGFTLIH-guaranteed NPAs: No provision for guaranteed portion.

Pricing, Multiple-Lending, Fair Practices & NBFC-MFI as Channelising Agent

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38.5.4 Membership of CIC

Every NBFC-MFI must be a member of all Credit Information Companies (CICs), provide timely and accurate data to them, and use data available with CICs.

38.5.5 Pricing of Credit

Margin cap — large MFIs:Maximum 10% (portfolio exceeding ₹100 crore)

Margin cap — others:Maximum 12%

Interest rate charged:Lower of: (a) cost of funds + margin cap above, OR (b) average base rate of 5 largest commercial banks × 2.75

Processing charges:Not more than 1% of gross loan amount

Insurance cost:Recover only the actual cost; administrative charges per IRDA guidelines

38.5.6 Multiple-Lending, Over-Borrowing & Ghost-Borrowers

(i) Lending to individuals

NBFC-MFIs can lend to individuals — whether or not a member of JLG/SHG.

(ii) Membership restriction

A borrower cannot be a member of more than one SHG/JLG.

(iii) Lender limit

Not more than two NBFC-MFIs shall lend to the same borrower.

(iv) Moratorium

Moratorium before the first instalment must be at least equal to the frequency of instalments.

(v) Loans in violation

Loans given in violation of regulations to be recovered only after all prior loans are paid.

38.5.7 Fair Practices Code (FPC) for NBFC-MFIs

The Fair Practices Code for NBFCs is applicable to NBFC-MFIs in addition to the specific MFI Code of Conduct prescribed by RBI/SRO.

38.5.8 Monitoring of Compliance

Both NBFC-MFIs themselves and banks lending to NBFC-MFIs shall monitor compliance. All NBFC-MFIs must become a member of at least one SRO recognised by RBI and comply with its Code of Conduct.

38.6 NBFC-MFI — Channelising Agent for Special Government Schemes

NBFC-MFIs can act as channelising agents under special schemes of Central/State Government agencies — leveraging their last-mile reach for government-sponsored financial inclusion programmes.

Co-Lending Model (CLM)

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In November 2020, RBI revised its guidelines for co-origination as the Co-Lending Model (CLM) — aimed at improving credit flow to the priority sector with greater operational flexibility. Banks take their share of individual loans on a back-to-back basis.

CLM Applicability & Exclusions

▸Available to: All banks except SFBs, RRBs, UCBs, and LABs.
▸Excluded: Foreign banks (including WOS) with less than 20 branches.
▸Prohibited: Banks cannot enter CLM with an NBFC belonging to the promoter group.
▸Permitted with: All registered NBFCs including HFCs — based on a prior agreement.

38.7.1 Basic Aspects of CLM

NBFC minimum share:NBFCs must retain a minimum of 20% share of individual loans on their books

Master Agreement:One Master Agreement covering all terms, conditions, and responsibilities of both parties

Option (i) — Mandatory sharing:Bank agrees to mandatorily take its share of the individual loans on a back-to-back basis

Option (ii) — Discretionary sharing:Bank retains the right to reject individual loans after due diligence; akin to a direct assignment transaction

38.7.2 Customer Related Issues

(i)NBFC shall be the single point of interface for customers.

(ii)NBFC shall enter into a loan agreement with the borrower detailing features and roles of both the NBFC and bank.

(iii)Details of the arrangement to be disclosed to customers and their consent obtained.

(iv)All-inclusive interest rate to be agreed upon by both lenders as per applicable guidelines.

(v)Guidelines on customer service and fair practices code for both banks and NBFCs apply.

(vi)NBFC must generate a single unified statement of the customer account through information sharing.

(vii)Suitable arrangement must be in place to resolve any borrower complaint registered with the NBFC within 30 days.

38.7.3 Other Operational Aspects

(i)The co-lending bank and the NBFC shall each maintain individual borrower accounts for their respective exposures.

(ii)The Master Agreement shall clearly specify the manner of appropriation between the co-lenders.

(iii)All transactions (disbursements/repayments) between the bank and NBFC relating to CLM shall be routed through an escrow account maintained with the bank.

(iv)Each lender shall adhere to its share of the loan account under applicable IRAC and provisioning requirements, and report to Credit Information Companies.

(v)The bank's share of assets in its books should be without recourse to the NBFC.

Scale Based Regulation, Chapter Summary & Flashcards

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38.8 Framework for Scale Based Regulation (SBR) for NBFCs

RBI put in place a revised regulatory framework for NBFCs effective October 01, 2022. The SBR framework encompasses capital requirements, governance standards, and prudential regulation based on size, activity, and perceived riskiness.

Layer	Abbreviation	Key Note
Base Layer	NBFC-BL	Largest in number; lowest perceived risk; lighter regulation
Middle Layer	NBFC-ML	SPD and IDF-NBFC always remain here; higher regulation
Upper Layer	NBFC-UL	Systemically important; near-bank regulation; identified by RBI
Top Layer	NBFC-TL	Ideally expected to be empty; extreme supervisory concern

38.8.2 Categorisation of NBFCs Carrying Out Specific Activity

▸NBFC-ICC, NBFC-MFI, NBFC-MGC could lie in any of the layers (BL, ML, or UL).
▸SPD (Standalone Primary Dealer) and IDF-NBFC will always remain in the Middle Layer.
▸Government-owned NBFCs shall be placed in Base Layer or Middle Layer.

Chapter 38 in 6 Lines

NBFCs have a competitive edge in regional reach, quick decisions, and lower transaction costs; banks can extend working capital and term loans to all registered NBFCs for eligible activities.
Prohibited bank finance to NBFCs: bills discounting (barring CV/2W/3W exceptions), investments in shares/debentures, loans to subsidiaries, bridge loans, and advances against shares as collateral.
NBFC exposure caps: single NBFC 20% Tier I; group 25% Tier I; gold loan NBFC 7.5% Tier I+II (extendable to 12.5% for infrastructure); on-lending PSL cap: 5% of total PSL averaged across 4 quarters.
NBFC-MFI: min NOF ₹5 cr (NE: ₹2 cr); qualifying assets ≥85%; first cycle ≤₹75,000, subsequent ≤₹1,25,000; max household income ₹1,25,000 rural / ₹2,00,000 urban; total indebtedness ≤₹1,25,000; margin cap 10%/12%; max 2 NBFC-MFIs to same borrower.
Co-Lending Model (CLM, Nov 2020): NBFC retains ≥20% of individual loans; all transactions through escrow with bank; NBFC is single interface for customer; complaints resolved within 30 days; not applicable to SFBs, RRBs, UCBs, LABs, or foreign banks with <20 branches.
SBR Framework (effective Oct 2022): 4 layers — BL (lightest regulation) → ML (SPD/IDF always here) → UL (near-bank regulation) → TL (ideally empty); NBFC-ICC/MFI/MGC can be in any layer; govt-owned NBFCs in BL or ML.

Flashcards — Chapter 38

1. What are the four categories of activities in which banks can extend working capital and term loans to NBFCs?▼

Infrastructure financing, equipment leasing, hire-purchase, loan, factoring, and investment activities — subject to RBI guidelines.

2. Name any four categories of NBFCs exempted from registration with RBI.▼

(i) Micro Finance Companies (ii) ARCs under SARFAESI (iii) Nidhi Companies (iv) Mutual Benefit Companies. Also: Chit Companies and Merchant Banking Companies.

3. Can banks finance the investments of NBFCs in shares and debentures?▼

No. Investments of NBFCs — both current and long-term in any company/entity by way of shares, debentures, etc. — are not eligible for bank credit.

4. What is the single NBFC exposure ceiling for banks (excluding gold loan companies)?▼

Maximum 20% of the bank's Tier I capital.

5. What is the exposure ceiling for a group of connected NBFCs?▼

Maximum 25% of the bank's Tier I capital.

6. What is the exposure ceiling for a gold loan NBFC (≥50% of financial assets in gold loans)?▼

Maximum 7.5% of Tier I plus Tier II capital. Can go up to 12.5% if the additional exposure is for on-lending to the infrastructure sector.

7. What is the on-lending PSL cap for bank credit to NBFCs/HFCs?▼

Bank credit to NBFCs (including HFCs) for on-lending should be within 5% of total priority sector lending, averaged across four quarters.

8. What is the minimum Net Owned Fund requirement for an NBFC-MFI?▼

₹5 crore (₹2 crore for NBFCs registered in the North-Eastern Region).

9. What percentage of net assets must be qualifying assets for an NBFC-MFI?▼

Not less than 85% of net assets must be qualifying assets.

10. What are the loan amount ceilings for a qualifying asset under NBFC-MFI norms?▼

Maximum ₹75,000 for the first cycle and ₹1,25,000 for subsequent cycles.

11. What is the household income ceiling for a qualifying asset (rural)?▼

Annual income not exceeding ₹1,25,000 for rural households; ₹2,00,000 for urban and semi-urban households.

12. How many NBFC-MFIs can lend to the same borrower simultaneously?▼

Not more than two NBFC-MFIs shall lend to the same borrower at any time.

13. What is the margin cap for a large NBFC-MFI (portfolio > ₹100 crore)?▼

Maximum 10% — the difference between the rate to the borrower and the cost of funds.

14. What is the maximum processing charge an NBFC-MFI can levy?▼

Not more than 1% of the gross loan amount.

15. What is the minimum share that an NBFC must retain on its books under the Co-Lending Model?▼

Minimum 20% of the individual loans on its own books.

16. Name the two options available to a bank under the Master Agreement in CLM.▼

(i) Mandatory Sharing — bank commits to mandatorily take its share back-to-back. (ii) Discretionary — bank retains the right to reject individual loans after due diligence (akin to direct assignment).

17. Who is the single point of interface for customers under CLM?▼

The NBFC is the single point of interface for customers.

18. Within how many days must a complaint registered by a borrower with the NBFC be resolved under CLM?▼

Within 30 days of the complaint being registered.

19. How should all bank-NBFC transactions (disbursements/repayments) under CLM be routed?▼

Through an escrow account maintained with the bank.

20. Name the four layers of the SBR framework for NBFCs.▼

NBFC-BL (Base Layer), NBFC-ML (Middle Layer), NBFC-UL (Upper Layer), NBFC-TL (Top Layer). The Top Layer is ideally expected to be empty.

21. Which NBFCs always remain in the Middle Layer under SBR?▼

SPD (Standalone Primary Dealer) and IDF-NBFC always remain in the Middle Layer.

22. When did the SBR framework for NBFCs become effective?▼

October 01, 2022.

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