Our Response to RBI’s Draft Omnibus Framework for recognising Self-Regulatory Organisations (SROs) for Regulated Entities (REs)
In this blogpost, we present our comments primarily to the former, but significantly implicating the latter. We include both frameworks since they cover similar subject matter – the creation of an SRO.
RBI’s ‘Financial Stability Reports’ and Stress Testing Methodologies
Analysing the contents of the Reserve Bank of India’s biannual FSRs and the methodology of the RBI’s supervisory stress tests reveals that there is scope for improvement, specifically regarding the continuity in the tracking of certain risk drivers, the extent of commentary on the information, and aspects of stress tests.
Note on RBI’s Prompt Corrective Action Framework for Non-Banking Financial Companies
In this note, we discuss how the current approach of the PCA framework is inconsistent with the objectives it seeks to achieve.
RBI must accommodate fintech innovations, not ban them
An RBI Working Group has suggested that lending service providers be disallowed from providing credit enhancements such as FLDG (first-loss-default-guarantee). However, a risk-proportionate regulation of FLDG could address its risks, while allowing the ecosystem to benefit from innovation.
Comments on RBI’s Draft Master Direction on Minimum Capital Requirements for Operational Risk
In our response, we commend and highlight the more risk sensitive methodology and the corresponding disclosures outlined in the draft guidelines. However, we also point out that not including conduct risk under operational risk is a major lacuna.
Why RBI’s Decision to Mandate Core Banking Solutions May Hurt NBFCs
The RBI’s Scale Based Regulation (SBR): A Revised Regulatory Framework for NBFCs mandates a Core Banking Solution (CBS) for all NBFCs with more than 10 branches
Brief Commentary on RBI’s Final Guidelines on Securitisation of Standard Assets
In this post, based on our earlier comments on the draft guidelines, we analyse whether the highlighted issues have been addressed and also highlight few other potentially impactful changes that are contained in the new framework.
RBI’s Resolution Frameworks: A Case for Extension and Amendment
In this blog post, we answer the first two questions. In the next post, we shall present a principle-based approach that the RBI may adopt, thus answering the third question of how the current regulations should be amended or augmented to enhance their efficacy.
Our Response to RBI’s Consultative Document on Regulation of Microfinance
In this blog post, we present a summary of our response to the consultative document.
Our Response to RBI’s Discussion paper on Revised Regulatory Framework for NBFCs – A Scale-Based Approach, 2021
In this blog post, we share our responses submitted to the RBI to the questions posed in the discussion paper
