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JC - Legal Updates - Non-individual borrowers to obtain LEI Codes

Legal Updates

29 Apr 2022

Non-individual borrowers to obtain LEI Codes

The Reserve Bank of India (“RBI”) has, vide a notification issued in April 2022, amended the existing guidelines on Legal Entity Identifier (“LEI”) as follows:

1)   The guidelines shall be extended to Primary (Urban) Co-operative Banks and Non-Banking Financial Companies.

2)  Further, non-individual borrowers, having aggregate exposure of INR 50,000,000/- or above from Scheduled Commercial Banks (excluding Regional Rural Banks), Local Area Banks, Small Finance Banks and Primary (Urban) Co-operative Banks are required to obtain LEI codes as per the timeline provided below:

Total Exposure

LEI to be obtained on or before

Above INR 250,000,000/-

30th April 2023

Above INR 100,000,000/-, up to INR 250,000,000/-

30th April 2024

INR 50,000,000/- and above, up to INR 100,000,000/-

30th April 2025

3)   Borrowers who fail to obtain such LEI codes from an authorized Local Operating Unit shall not be sanctioned any new exposure or be granted renewal / enhancement of existing exposure. Departments / agencies of the Central and State Governments are exempted.

4)   The term “Exposure” shall include all fund based and non-fund based (credit as well as investment) exposure of banks/FIs to the borrower. Aggregate sanctioned limit or outstanding balance, whichever is higher, shall be reckoned for the purpose. Lenders may ascertain the position of aggregate exposure based on information available either with them, or CRILC database or declaration obtained from the borrower.

Reserve Bank of India - Notifications (rbi.org.in)

For any further information, please contact Mr. Vedanarayanan Lakshmanan (ved.lakshmanan@jclex.com), Mr. Ankit Sinha (ankit.sinha@jclex.com), Mr. Saurabh Sharma (saurabh.sharma@jclex.com), Ms. Rupul Jhanjee (rupul.jhanjee@jclex.com) or Ms. Teza Jose (teza.jose@jclex.com).