CORAA

NBFC / CIC Registration with RBI

CARO 2020 · Clause (xvi) · Statutory basis: Section 143(11) Companies Act 2013

Registration requirements under Section 45-IA of RBI Act; CIC compliance.

Reporting requirement

Report whether (a) the company is required to be registered under Section 45-IA of the Reserve Bank of India Act, 1934 and if so, whether the registration has been obtained; (b) the company has conducted any Non-Banking Financial or Housing Finance activities without a valid Certificate of Registration (CoR); (c) the company is a Core Investment Company (CIC) as defined in the regulations made by RBI; (d) the Group has more than one CIC as part of the Group.

What to verify before signing

  • Section 45-IA RBI Act threshold check (NBFC criteria)
  • CoR from RBI on file; activity matches CoR
  • CIC test under Master Direction — Investments in shares ≥ 90% of net assets; ≥ 60% in group
  • Aggregate group structure check for multiple CICs

Sample observation — applicable

Sample observation — not applicable

(a) The Company is not required to be registered under section 45-IA of the Reserve Bank of India Act, 1934. (b) The Company has not conducted any Non-Banking Financial or Housing Finance activities. (c) The Company is not a Core Investment Company (CIC) as defined in the regulations made by the Reserve Bank of India. (d) There is no Core Investment Company within the Group (as defined in the Core Investment Companies (Reserve Bank) Directions, 2016) and accordingly, reporting under this clause is not applicable.

Related standards

Section 45-IA RBI Act 1934RBI Master Directions on NBFCs
On CORAA
Clause (xvi) auto-populates from the underlying ledger work in CORAA’s Reporting hub. Each observation traces back to the transactions that triggered it. Pair with our CARO 2020 Checklist template for the full audit-report annexure.

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