RBI’s Proactive Measures to Safeguard Against Indirect Loan Risks

In a pivotal regulatory update, the Reserve Bank of India (RBI) has issued stringent guidelines for banks and non-banking financial companies (NBFCs) regarding their investments in Alternative Investment Funds (AIFs). The central bank’s latest directive, aimed at curtailing the practice of “evergreening” of loans, marks a significant shift in the regulatory landscape of India’s financial sector.

Understanding the New Norms

The RBI’s circular, effective immediately, lays down several key provisions:

  1. Restriction on Investment in Certain AIF Schemes: Regulated entities (REs), encompassing banks and NBFCs, are now prohibited from investing in AIF schemes that have directly or indirectly invested in debtor companies. A debtor company is defined as one where the RE has a current or previous loan or investment exposure in the preceding 12 months.
  2. Mandatory Liquidation of Investments: If an RE has existing investments in an AIF scheme that subsequently invests in a debtor company, the RE must liquidate its investment within a 30-day window from the date of such downstream investment.
  3. Provisioning for Non-Compliance: In scenarios where REs fail to liquidate their investments within the prescribed timeframe, they are mandated to make a 100% provision on such investments.
  4. Impact on Capital Funds: Investments by REs in the subordinated units of any AIF scheme following a ‘priority distribution model’ are subject to full deduction from the RE’s capital funds.

The Rationale Behind the Move

This regulatory overhaul by the RBI is primarily aimed at preventing the evergreening of loans, a practice where lenders indirectly finance their debtors by investing in funds that then lend to these debtors. This circular motion of funds can obscure the actual financial health of the borrowers and create a false sense of security in the financial system.

The RBI’s action comes in response to instances where banks and NBFCs replaced direct loan exposures to borrowers with indirect exposures through investments in AIFs. Such practices, if unchecked, pose significant risks to the transparency and stability of the financial system.

Implications for the Financial Sector

This new framework is expected to bring about a more transparent and risk-averse investment strategy among banks and NBFCs. While it may initially constrain the liquidity flow to AIFs, experts believe that in the long run, it will foster a more robust and transparent lending environment.

Expert Opinions

Financial analysts and industry experts have largely welcomed the move, highlighting its importance in maintaining the integrity of the financial system. However, some have expressed concerns about the potential short-term impacts on fund flows to AIFs and the broader implications for investment strategies of REs.


The RBI’s stringent norms are a proactive step towards safeguarding the financial system against opaque and risky investment practices. By tightening the rules around AIF investments, the RBI is reinforcing its commitment to financial stability and transparency.



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