Banks rush to implement ‘standing instructions’ system, but may still miss deadline, BFSI News, ET BFSI

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Banks and payment aggregators are rushing to meet the October 1 deadline for implementing a new system for standing instructions for recurring online transactions as the Reserve Bank of India is not likely to extend it. Banks are sending communications to customers saying that they will not process recurring payments, and customers will have to make payments directly to merchants.

“In compliance with the regulatory requirements, we are currently building a solution to seamlessly manage all your domestic standing instructions for recurring payments. This solution will be available soon for you. Starting October 1, any existing standing instruction for domestic and international recurring transactions on your card account will not be processed. We request you to make these payments directly to the service providers to avoid any interruptions,” American Express said in a recent message to customers.

How does the new system work?

Under the proposed system, as a risk mitigating and customer facilitation measure, the card-issuing bank will have to send a pre-transaction notification to the cardholder, at least 24 hours before the actual charge or debit to the card. While registering e-mandate on the card, the cardholder shall be given the facility to choose a mode among available options (SMS, email, etc.) for receiving the pre-transaction notification from the issuer. On receipt of the pre-transaction notification, the cardholder shall have the facility to opt-out of the particular transaction or the e-mandate. For transactions above Rs 5000, banks will also be required to send one time passwords to customers.

What is a standing instruction?

A standing instruction is a service offered to customers of a bank, wherein regular transactions that the customer wants to make are processed as a matter of course instead of initiating specific transactions each time.

This service relates to transactions like renewing subscription to over-the-top (OTT) platforms, newspapers and magazines, and utility bill payments.

The issue

Large lenders and payment entities including State Bank of India, Citi, HDFC, Axis, HSBC, Visa and Mastercard had asked the RBI to postpone the deadline for putting in place a new system to alert customers on ‘standing instruction’ transactions.

The banks were asked to set up the system by March 31, 2021.

The lenders also wanted RBI to exclude transactions against pre-existing standing instructions and those with international merchants from the new conditions for e-mandates on cards for recurring transactions.

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E-mandate processing: Banks, payment aggregators rush to meet deadline for recurring online transactions

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Banks and payment aggregators are scrambling to meet the October 1 deadline for standing instructions for recurring online transactions. Many banks are sending communications to customers saying that they will have to make payments directly to merchants.

“In compliance with the regulatory requirements, we are currently building a solution to seamlessly manage all your domestic standing instructions for recurring payments. This solution will be available soon for you. Starting October 1, any existing standing instruction for domestic and international recurring transactions on your card account will not be processed. We request you to make these payments directly to the service providers to avoid any interruptions,” American Express said in a recent message to customers.

American Express did not respond to an e-mail query from BusinessLine on the issue.

While a number of other banks are also working to comply with the norms, some are sending similar messages to customers.

Working to meet deadline

“This time around, the RBI norms will have to be met. But what may happen is that the existing standing instruction will become invalid and, as and when any issuer is ready, the customer can sign up for any new registration. There will be a period when the customer will have to pay the merchant directly. All of us are ensuring suitable customer communication and working to meet the deadline,” explained a banker.

As the new standing instruction will not get registered immediately, there may be one or two bill cycles that the merchant and consumer will have to take care of, he said.

The RBI had, in March, extended the deadline for banks to comply with norms for processing recurring online transactions by six months to September 30.

To make online transactions secure, the RBI has introduced an additional factor authentication for cards, wallets, prepaid instruments and UPI during registration and first transaction (with relaxation for subsequent transactions up to a limit of ₹5,000), as well as pre-transaction notification and facility to withdraw the mandate. However, many banks had failed to comply with the earlier deadline of March-end following which the RBI had decided to extend the deadline to prevent any inconvenience to the customers.

Bharat Panchal, Chief Risk Officer – India, Middle East and Africa, FIS, said banks are prepared to meet the deadline for standing instruction for recurring payments. But there are many in the ecosystem and some of them may not be prepared.

Other payment options

“Technically, there is not a significant challenge in implementing it. The infrastructure is available but just need to be extended. In case, customers are unable to do standing instruction for recurring payments on their credit cards, they still have a number of options such as UPI Autopay, BharatBill Pay, net banking and e-wallets,” he said.

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BCs emerging as predominant delivery channels for banks to expand last mile outreach: RBI study

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From being an alternate model, the Business Correspondent (BC) model is emerging as the predominant delivery model for banks to expand their last mile outreach in unserved/ underserved areas of the country, per a Reserve Bank of India (RBI) study.

The number of BCs across the country have grown at a compounded annual growth rate (CAGR) of 13.05 per cent to 11,76,221 as at March-end 2020 from 6,37,029 as at March-end 2016. However, the number of branches/ banking outlets in villages have only increased at a CAGR of 2.29 per cent to 58,042 as at March-end 2020 from 51,830 as at March-end 2016.

“Over the years, the BC model has assumed greater prominence over the traditional brick and mortar branches. Increasingly, the access to banking services in rural areas, particularly in the unserved/ underserved parts, is being provisioned through BC outlets,” according to the study by RBI officials Sushmita Phukan, Saju Thomas Punnoose, Abhishek Kumar, Dineshkumar S and Abhishek Kumar.

Retail agents

BCs are retail agents engaged by banks for providing banking services at locations other than a bank branch/ATM. BCs perform a variety of activities which include identification of borrowers, collection and preliminary processing of loan applications including verification of primary information/data, collection of small value deposit, disbursal of small value credit, and recovery of principal/ collection of interest.

They also undertake sale of micro insurance/ mutual fund products/ pension products/ other third party products and receipt and delivery of small value remittances/ other payment instruments. “While the growth in number of rural branches remained subdued during the review period (2016-2020), there was a significant growth in BC outlets in both villages and urban pockets providing formal financial services at the doorstep of large number of unserved/ underserved population,” the study, published in RBI’s latest monthly bulletin, said.

Also read: Banks should embrace digitisation to ensure govt schemes reach needy: FM Nirmala Sitharaman

The study noted that about 56 per cent of total Basic Savings Bank Deposit Accounts (BSBDAs) and 65 per cent of General Credit Cards (GCCs) were channelled through BCs. While BCs of public sector banks (PSBs) dominated the deposit space, private sector banks (PVBs) accounted for a major share in GCCs through BCs.

During the review period, the total transactions routed through BC outlets increased considerably both in terms of volume as well as value, the authors said.

Financial inclusion

Through the review of FIP data furnished by banks (PSBs, PVBs and Regional Rural Banks/RRBs) over the five years (2016- 2020), the study observed that the dominance of PSBs has continued in the financial inclusion space.

PSBs accounted for about 56 per cent of total rural branches in 2020. They were also predominantly present in the rural areas accounting for 60 per cent of total BC outlets in villages in 2020. “Similarly, of the total BSBDAs, the contribution of PSBs remained over 70 per cent during the review period. Further, among the credit products, KCCs were channeled mainly through PSBs, which accounted for 58 per cent of the total number of KCCs (Kisan Credit Cards) in 2020,” the authors said.

As PSBs continued to maintain their hold, the authors underscored that PVBs too registered a higher growth in both access and usage indicators during the review period.

The study noted that there was a growth in BC outlets in villages for PVBs with the growth being significantly high for the northeastern, eastern and central regions, surpassing the growth of PSBs and RRBs together. PVBs also significantly improved their tally of urban BC outlets during the five years with their share growing from 77 per cent in 2016 to 97 per cent in 2020, the authors said.

On similar lines, contribution of PVBs in the total number of BC agents too grew exponentially from 37 per cent in 2016 to 80 per cent in 2020.

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Bad Bank to solve Rs 2 lakh crore bad loans, take NPAs off banks’ books; here’s how it will work

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Finance Minister Nirmala Sitharaman on Thursday announced that the Union government will guarantee Rs 30,600 worth of security receipts issued by the National Asset Reconstruction Company.

The Bad Bank is finally here, after a decade of discourse. It aims to help clean up banks’ books by taking over Rs 2 lakh crore bad loans. If it works as intended, Bad Bank may help cut system-wide bank NPAs (non-performing assets) by over 1%, and help recover some of bad debts too, analysts say. The National Asset Reconstruction Company (NARCL), as it is officially named, will acquire banks’ bad debt to resolve or liquidate. It will buy these stressed assets for a mix of cash, and government-guaranteed security receipts.

Finance Minister Nirmala Sitharaman on Thursday announced that the Union government will guarantee Rs 30,600 worth of security receipts issued by the National Asset Reconstruction Company (NARCL). “NARCL will acquire stressed assets through 15% cash payment to banks based on valuation and the rest 85% will be given as security receipts,” Nirmala Sitharaman said. The government-backed security receipts can only be invoked on resolution or liquidation.

What is NARCL? Why is it needed?

The National Asset Reconstruction Company (NARCL) was proposed by the Finance Minister in her Union Budget speech. NARCL, popularly known as Bad Bank, will function as an asset reconstruction company set up by banks to resolve stressed assets for smoother functioning. Public sector banks will have 51% ownership in NARCL. The bad bank intends to resolve stressed loan assets above Rs 500 crore each.

How the Bad Bank will work

Bad loan transfer: NARCL will take over bad loans worth Rs 2 lakh crore from banks, of which Rs 90,000 crore will be taken over in the first phase. The Ministry of Finance said that NARCL will acquire bad loans from banks for a mutually agreed-upon value (understandably, a net value after a haircut). NARCL will pay 15% of the agreed net value of the bad debt upfront in cash and the remaining 85% in form of security receipts. The banks would use this 15% cash upfront to reverse the debt write down. As for the security receipts for the remaining 85%, the bank would redeem those when the bad bank resolves or liquidates the bad debt; or, the bank may also trade these securities for cash.

Provision write-back: “These loans are fully provided in the books of the bank. The upfront cash received, 15% of the written-down value, would be reversed while the provisions for the balance (value of security receipts) are unlikely to be reversed even if it is fully provided,” analysts at Kotak Securities wrote in a note. “The larger release of provisions, if any, would be made as and when the cash is received on sale of these receipts or redemption of security receipts. The government guarantee on SRs can enable trading of these securities,” Kotak Securities added.

Government guarantee: The security receipts issued by NARCL are backed by the Union government guarantee. The government guarantee will cover any shortfall between the face value of the receipts and the actual realisation value of the bad loan.

Resolution is key

“How efficiently the professionals are resolving the stressed assets is to be monitored. One can argue that bad bank is likely to become a warehouse for stressed loans without expected recovery as it will be difficult to find buyers for legacy assets,” ICICI Securities said in a note. The Resolution of the proposed Rs 2 lakh crore of legacy stressed assets will lower GNPLs (gross non performing loans) by more than 2%, the note said. The estimated realisable value of 18% will lead to provisioning write-back of Rs 36,000 crore. “Through successful execution of phase-1, one can expect near term NPA reduction of >1% and NPA recoveries equivalent to 10bps of system credit,” ICICI Securities said.

Why is government guarantee needed?

The government said that resolution mechanisms of dealing with a backlog of NPAs typically require a backstop from the Government. “This imparts credibility and provides for contingency buffers. Hence, a Government Guarantee of up to Rs 30,600 crore will back Security Receipts (SRs) issued by NARCL. The guarantee will be valid for 5 years. The condition precedent for invocation of guarantee would be resolution or liquidation,” the finance ministry said.

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Banks geared for card tokenisation

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Banks indicate they are well prepared for the card tokenisation system and emphasise it will not impact customers. While lenders expect it to be a smooth transition, there could be some initial friction as consumers and merchants adapt to the new system.

“This move by the Reserve Bank of India will enhance card security framework for digital transactions. With tokenisation, a card specific token is generated. Going forward that token can be used for all online transactions. This will ensure enhanced security. In case of any data breach or hacking attempt at the merchant’s end, the customer’s card details will still be protected,” said Sanjeev Moghe, EVP and Head-Cards and Payments, Axis Bank, adding that the lender is prepared for tokenisation.

RBI clarifies

The Reserve Bank of India has (RBI) said that contrary to some concerns, there would be no requirement to input card details for every transaction under the tokenisation arrangement.

“HDFC Bank, ICICI Bank and SBI Cards already have the card tokenisation system in place for online transactions, while few players have device-based tokenisation (SBI Cards with Samsung) for contactless NFC payments,” said a recent statement by Emkay Global.

HSBC India, in April, had announced that it has collaborated with Google Pay and VISA to enable secured tokenisation on its credit cards.

“The RBI has addressed all concerns. With the growing popularity of e-commerce, this step is welcome,” said another banker, adding that there could be some amount of adaptation required for customers. “Customers will not have to tap in their 16 digit card number every time they make a purchase,” he said.

Mandar Agashe, Founder, Managing Director and Vice-Chairman, Sarvatra Technologies also said the current situation is similar to when PIN was introduced for every transaction. It took a lot of effort but we have the lowest PIN-based frauds in the world, he pointed out.

“Merchants have to be ready to purge all the customer card data and get the token from the individual banks. Banks are also getting ready. There will be some level of friction at the back end if some bank is not ready. So, those customers may face inconvenience if the issuing bank doesn’t give the token to the merchant on time; then, the customer has to enter the card data every time,” he said.

Emkay Global stated the mandatory tokenisation of cards and resultant customer inconvenience in the initial phase may deter cardholders from making low-value online card payments and may push them to other payment modes such as UPI and wallets.

“However, it would alleviate security concerns in online transactions; thus, it will be a long-term positive for the card industry,” it said.

The RBI, in March 2020, had stipulated that authorised payment aggregators and the merchants onboarded by them should not store actual card data. The deadline is set for January 1, 2022, post which no entity in the card transaction or payment chain, other than the card issuers and/or card networks, shall store the actual card data.

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Banks look to resolve large assets even as NARCL gets set up

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The process of setting up the bad bank, securing a guarantee from the government and finally getting the institution off the ground could take some time, bankers expect. In the meantime, they are trying to maximise recoveries in as many cases as possible.

Banks are continuing with their regular practice of putting up large stressed assets for sale to asset reconstruction companies (ARCs) and other investors even as the process for setting up the National Asset Reconstruction Company (NARCL) has been set in motion. The possibility of quicker and better-yielding resolutions in some assets is the reason behind this, according to bankers and other industry executives.

“We are exploring our options in cases where we think there is a possibility of achieving quicker resolution outside the NARCL. Also, many of the assets which are being canvassed separately for sale to ARCs are not part of the list of assets identified for transfer to the NARCL,” a senior executive with a mid-sized private bank said.

The process of setting up the bad bank, securing a guarantee from the government and finally getting the institution off the ground could take some time, bankers expect. In the meantime, they are trying to maximise recoveries in as many cases as possible.

KSK Mahanadi Power, Sathavahana Ispat, Srinagar Banihal Expressway, MSP Metallics, Sew Infrastructure and Coastal Energen are among the assets for which lenders are running the resolution process. There are also instances of one-time settlement deals as in the case of Jindal India Thermal Power.

Nirmal Gangwal, managing partner, Brescon & Allied Partners, said sales to ARCs and strategic investors are parallel processes and the NARCL process will be an additional one which will also come in handy. “The setting up of NARCL is an ongoing process. In the meantime, if the outlook for some sector suddenly turns positive or there is interest for an asset from an ARC or a strategic investor, bankers would like to explore whatever is good for them,” he said.

Pricing could be another reason why banks are choosing the auction route for resolution. An industry executive who spoke on condition of anonymity said that the pricing in case of transfers to NARCL will be quite low. “Banks may be getting 40-50% recovery in some of these sales, whereas in NARCL they just get 10 cents to a dollar and that too not in a full-cash deal,” the executive said.

Most deals between banks and ARCs nowadays are all-cash deals where the entire amount goes directly into the bank’s profit. “So, the NARCL is actually meant for cases where lenders are unable to find a resolution or where they feel there is a need for warehousing for some time,” the executive said.

Some cases understood to be under consideration for transfer to the NARCL list are already undergoing insolvency proceedings such as Amtek Auto, Castex Technologies, JP Infra, Videocon Oil Ventures and Lavasa Corporation.

NARCL has recently applied for a licence to the Reserve Bank of India (RBI) after raising Rs 149 crore as paid-up capital from its constituent banks. Lenders have identified 22 stressed accounts, worth around Rs 89,000 crore, to be transferred to NARCL in the first phase.

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Regulatory forbearance has reduced immediate capital requirements for Banks: Fitch

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Regulatory forbearance has reduced the Indian banking sector’s need for fresh core capital to meet minimum regulatory capital requirements up to the financial year ending March 2025 (FY25), according to Fitch Ratings latest base-case assumptions.

However, under the global credit rating agency’s stress case scenario, it estimates that State banks would require an aggregate of $50 billion in fresh equity capital over the period to FY25 to maintain their CET1 ratios above the regulatory minimum of 8 per cent.

The lower system level fresh capital requirement of $27 billion nets out the capital surplus among private banks. The stress scenario incorporates less benign assumptions about the economic outlook.

Also read: RBI aligns deposit-taking norms for HFCs with NBFCs

Fitch Ratings observed that the system capital requirements are lower than under its 2020 estimates, but this partly reflects the effects of regulatory forbearance and is unlikely to create near-term upward momentum for Indian banks’ Viability Ratings.

In 2020, Fitch had estimated higher capital needs for the system (mostly the state banks) of $15 billion and $58 billion under moderate and high stress scenarios, respectively. These stress tests assumed recognition of asset-quality stress over a two-year period.

The agency’s updated assessment, covering a four-year period, reflects the key role of regulatory forbearance in suppressing immediate capital requirements by deferring timely recognition of asset-quality stress and giving banks time to build capital buffers.

Fitch underscored that delayed IFRS (International Financial Reporting Standards) implementation means that Indian banks’ capacity to make pre-emptive provisions is quite limited, being guided by incurred instead of expected losses.

Deferred recognition of stress will thus dampen credit costs for Indian banks, supporting their capacity to generate capital internally through profits. “This, coupled with continued delays in full implementation of the Basel III capital conservation buffer, will contain capital needs for the banking sector, including the State banks, in our opinion,” Fitch said in a report on “Capital Estimates for Indian Banks”.

The agency said its updated capital findings also reflect a significant amount of equity raised by private banks since the onset of the Covid-19 pandemic, its expectation of modest credit growth, and its forecasts for India’s economic recovery.

NPL ratio

As per Fitch’s assessment, the estimated peak non-performing loan (NPL) ratio of 9.7 per cent by FY25 under its latest base case is below its previous moderate stress case estimate of 13.4 per cent.

This primarily reflects a more gradual unwinding of restructured loans into bad loans after FY22 (over two-three years, giving customers more time to pay) coupled with the agency’s reassessment of lower stress in certain key segments, such as retail.

Fitch expects banks’ operating profitability to improve until FY23 in light of the deferred credit costs.

Stable net interest margins (NIM), low funding costs and treasury gains have supported banks’ pre-provision operating profitability, offsetting the effects of low credit growth.

Loan growth

The agency views loan growth and risk appetite as key determinants of the sector’s capital needs.

Fitch believes that banks with more vulnerable capitalisation positions will hesitate to deploy capital for growth, instead preserving it to deal with the impact of asset stress as it emerges in the future.

The agency assessed that State banks’ core capitalisation is lower than that of private banks, and its base case assumes their loan growth will average 4 per cent in FY22-FY25, lower than the system credit growth of 6.7 per cent.

However, there is a risk that their credit growth could exceed this, if policymakers influence lending decisions.

Large and mid-sized private banks should be able to withstand stress better, given their significantly stronger core capital buffers (CET1: 16.4 per cent versus 10.4 per cent for State banks in FY21).

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Will banks clamp down on cryptocurrency transactions again?, BFSI News, ET BFSI

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Banks which had started processing cryptocurrency transactions after RBI clarification may be again shying away from virtual currencies.

The country’s largest lender, State Bank of India, has blocked the receipt of funds by crypto bourses on its UPI platform. The bank has told payment processors to disable SBI UPI for crypto merchants, according to a report.

With this, traders cannot buy Bitcoin or any cryptocurrency by transferring funds via UPI, as none of the processors which handle funds for

exchanges will be unable to receive money sent for crypto purchases on their SBI accounts.

The largest domestic crypto bourse, WazirX, has already been impacted by the decision, with the processing agency following the directive of SBI. Industry circles said payment processors may stop accepting payment for other exchanges as well, unless SBI does a rethink.

With UPI blocked, many traders on WazirX are using one of the e-wallet services to transact.

But due to wallet charges and limits on fund transfer, traders prefer UPI in the absence of other payment modes like credit and debit cards, NEFT (national electronic fund transfers) and net banking.

After SBI’s decision, many banks may be reluctant to onboard crypto merchants on their respective UPI platforms.

The RBI decision

After the Reserve Bank of India told banks that they no longer can use the regulator’s 2018 circular prohibiting dealings in virtual currencies, as the direction has been struck down by the Supreme Court, banks were allowing crypto transactions.

Lenders including HDFC Bank, ICICI Bank and Axis Bank are allowing transactions in virtual currencies through the UPI platform.

According to crypto exchanges, more banks are now warming up to them and several channels are available for customers to buy crypto assets.

Till June this year banks were sending official notices to many customers warning them of curbs, including permanent closure of accounts.

Lenders were asking customers to clarify the nature of transactions and warning credit card users that transactions of virtual currency will lead to suspension/cancellation of card.

While trading in cryptocurrency is not illegal as per existing Indian laws, individual institutions can enforce their terms based on their risk assessment.

A grey area

Despite the boom, cryptocurrencies are in a grey area in India, with the Reserve Bank hostile towards it and the government unsure about its prospects.

There is no legislation or regulatory code yet to govern the crypto ecosystem, leading to confusion among customers, businesses and financial institutions providing banking services.

In 2018, the Reserve Bank of India barred financial institutions from supporting crypto transactions, which the Supreme Court overturned in 2020. The government has circulated a draft bill outlawing all cryptocurrency activities, which has been under discussion since 2019.

The RBI asked banks not to cite its 2018 circular and clarified that banks can do their own KYC for crypto clients. With this, banks are now reassessing the situation, but several banks currently lack the technical expertise to make a supervisory assessment on these transactions.



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Bank of England urges banks to wait out EU pressure over euro clearing, BFSI News, ET BFSI

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Banks should hold their nerve in the face of European Union pressure to shift euro derivatives clearing from London to the bloc, Bank of England Governor Andrew Bailey said on Tuesday.

Since Britain fully left the EU last December, the bloc has asked banks to move euro clearing from London, which accounts for the bulk of activity, to Frankfurt.

So far, banks and their customers have put on a united front against relocating clearing, saying it would bump up costs by splitting markets.

Bailey said banks were waiting rather than shifting euro positions as a June 2022 deadline looms when temporary permission for London clearers to serve EU customers ends.

“The right thing to do is to wait for the moment. The cost of moving and fragmenting are too large,” Bailey told a Bloomberg event.

“While waiting is sensible from the point of view of the banks, it puts the responsibility on the authorities to sort the thing out,” Bailey said.

However, negotiations with the EU at the present time have not been particularly intense, but the BoE was happy to give EU regulators the assurances they need, he said.

“If they want to take a decision to break the system up, then it’s important to consider the risks to financial stability that come with fragmentation.”

Clearers in the United States already have EU permission to serve customers in the bloc.

“We could see some clearing of euro instruments switch to New York from London if this does not get sorted out,” NatWest bank chairman Howard Davies told the same event.



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No a/c freeze till Dec for want of KYC, BFSI News, ET BFSI

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MUMBAI: The RBI on Monday reiterated that until December 2021, banks cannot freeze accounts if the customer has not done a periodic KYC (know your customer) update. The central bank said this while cautioning the public not to fall prey to fraudulent messages seeking bank details for KYC updation purposes.

The RBI said it has been receiving complaints/reports about customers falling prey to frauds being perpetrated in the name of KYC updation. The RBI asked the public not to share key information like account details or passwords with unidentified persons or agencies under threat of account freeze. Many customers have avoided visiting branches during the pandemic, which has provided fraudsters an opportunity to use KYC as a reason to engage with customers.“The usual modus operandi in such cases include receipt of unsolicited communication, such as, calls, SMSs, emails urging him/her to share certain personal details, account / login details/ card information, PIN, OTP, etc or install some unauthorised/ unverified application for KYC updation using a link provided in the communication,” it said.

The RBI also said that it has made the process of KYC updation much simpler. The directions on simplified process comes in the wake of banks asking customers to fill multiple sheets of all-in-one document merely to get a periodic proof of address and identity. The central bank on Monday said that NBFCs and payment system operators seeking to obtain Aadhaar e-KYC authentication licence can submit the application with the RBI.

In May 2019, the finance ministry had come out with a detailed procedure for processing of applications (under the PML Act) for use of Aadhaar authentication services by entities other than banking companies.

“Accordingly, non-banking finance companies (NBFCs), payment system providers and payment system participants desirous of obtaining Aadhaar Authentication license — KYC User Agency (KUA) ;icense or sub-KUA license (to perform authentication through a KUA), issued by the UIDAI, may submit their application to this department for onward submission to UIDAI,” the RBI said in a circular. The RBI has also provided the format of the application.



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