Appendix 2 Assessment of Working Capital Requirement:: (A) Justification For Estimated / Projected Sales
Appendix 2 Assessment of Working Capital Requirement:: (A) Justification For Estimated / Projected Sales
/ZO)
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APPENDIX 2
Annexure - 1
ASSESSMENT OF WORKING CAPITAL REQUIREMENT:
In case of existing units, while accepting the projected Sales/Turnover, the past trends in sales should be
carefully analyzed.
In case of new units, the demand for the product vis-à-vis orders in hand etc. must be properly examined.
Normally, if actual margin available is lower than the minimum required, MPBF is restricted as per margin available.
This scenario require detailed analysis as to what impact it will have on business projections / manufacturing capacity,
as the borrower shall continue to face liquidity crunch, ultimately leading to gap in drawing power. . In such a
scenario, borrower should bring in deficit up front as a pre-condition and submit CA certificate to this effect,
to the satisfaction of disbursing authority.
(Estimated / projected holding levels of each item to be compared with past actual levels and justification/ reasons for
variations to be given. Justification for level of creditors should include comments on credit available under LC(DA), if
any)
The cash budget system envisages providing of working capital by the bank based on the peak deficit
projected as per the cash flow statement. This is applied to certain seasonal industries such as tea and sugar
and to specific industry such as Information Technology and Software etc. Besides, sanctioning authority
may apply the cash budget system where they feel this system is more appropriate as in case of construction
contractors.
The cash budget is basically a simple projection of cash account – usually month wise indicating cash
receipts and cash payments/disbursements. The net gap i.e. peak cash deficit shall be the required working
capital from the Bank. The availment of Working Capital Limit or Drawing Power, shall be regulated
according to accepted monthly cash budget which should be drawn on realistic assumptions. For e.g.,
A sample Performa of cash budget is given as under. The items under the Receipts and Payment head would
vary depending upon the type of industry/advance.
Cash Budget:
Month or quarter
Receipts
Cash sales
From debtors
Capital / Margin
Contribution
Other Income
Total `A’
Payments
Cash Purchases
To creditors
Wages & Salaries
Power/Elec Charges
Transport, packings
Rent, Rates etc.
Bank/Interest charges
Dividend
Taxes
Capital Expenditure
Total `B’
Working Capital Gap*
*working capital gap, which is higher than four time of capital receipts, represent excess borrowing, necessitating
additional margin requirement to be brought upfront.
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Annexure - 2
(Rs. in _____)
For Raw Material Inland Foreign
1. Estimated Purchases against L/C
2. Lead Time (No. of Days)
3. Usance Period (No. of Days)
4. Total No. of Days (2+3)
5. No. of Cycles in a Year (365/Total No. of Days)
6. L/C requirement (1 / 5 )
Additional Information
Others
(Proper justification for LC limit should be given As per circular no. I.D.CIRCULAR NO. 1580
Date: 19.07.2005 regarding Strengthening of Appraisal & Monitoring of Non-Funded Facilities.)
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Annexure -3
iii) Others
(Proper justification for BG limit should be given As per circular no. I.D.CIRCULAR NO. 1580
Date: 19.07.2005 regarding Strengthening of Appraisal & Monitoring of Non-Funded Facilities.)
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Annexure - 4
(a) Details of Project: ( also covering Location of the Project – SEZ etc, Tax Holiday Zone , Benefits
/ incentives if any.)
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i) Power:
ii) Water:
iii) Labour:
iv) Effluents disposal:
v) Availability of Raw Material:
vi) Means of transportation (both procurements / supplies) in case of large projects / infra projects /
refineries etc like railways sidings / pipe lines etc and approval thereof.
(k) Projected Profitability, Projected Balance Sheet and Cash Flow Statement to be commented
upon:
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Repayment Schedule :
(l) Calculation of DSCR (for the period covering repayment period of TL)
(In case of existing Term Loans DSCR be given for residual period)
(Rs. in Crore)
Particulars Year Year Year Year Total
Net Profit
Depreciation
Other non-cash expenses
Interest on Term Loan
Total funds available for debt servicing (A)
Term Loan Installments
Interest on Term Loan
Total Debt obligation (B)
Net DSCR (A / B)
AVERAGE NET DSCR
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Annexure - 5
VARIOUS UNDERTAKINGS TO BE OBTAINED FROM THE BORROWER ON LETTER PAD
(As applicable according to the constitution of the borrower / to be discussed with the borrower before
stipulating any undertaking)
The borrower shall undertake:
1. To maintain deposits (unsecured loans) by family members, friends & relatives or directors / partners at
estimated / projected level, treated as quasi capital or part of net working capital, during the currency of the
Bank’s advance.
2. That the names of Borrower or its Directors/Partners or Guarantors do not figure in any list of defaulters
circulated by RBI or any bank and Financial Institution nor the names of partners/directors appear in
caution list issued by RBI/CIBIL/ECGC etc.
3. That name of the borrowing identity or any of its promoters/guarantors has not been declared as willful
defaulter by any of the Bank / Financial Institutions.
4. That the Bank has the right to share credit information as deemed appropriate with Credit Information
companies (CICs) or any other institution as approved by RBI from time to time.
5. That in case of consortium/syndication/multiple banking arrangement, the Bank may share the related
information as per RBI norms or as per mutual consent among bankers.
6. That in case of default in repayment of the loan/advances or in the payment of interest thereon or any of
the agreed installment of the loan on due date(s) by the borrowers, the Bank has an unqualified right to
disclose or publish the borrowers’/units’ name and its directors / partners / proprietor as defaulter / willful
defaulter in such manner and through such medium as the bank in its absolute discretion may think fit.
7. That in the event of default in repayment to our Bank or if cross default has occurred, the Bank will have the
right to appoint its nominee on the Board of Directors of the borrower to look after its interests.
8. That in stressed situation or restructuring of debts, the regulatory guidelines provide for conversion of debt
to equity. The bank shall the right to covert loan to equity or other capital in accordance with the regulatory
guidelines.
9. To deal exclusively with our Bank/member banks.
10. To declare dividend only after obtaining approval from the Bank [in case of default in payment of
interest/installments of Term Loan].
11. Not to pay any consideration, in whatever form, to the guarantors/guaranteeing directors, either directly or
indirectly (except without prior approval of the Bank) for guaranteeing the credit limits sanctioned by the
Bank. [Similar undertaking shall also be obtained from the guarantors.]
12. Not to obtain any financial assistance from any other source without express approval of the Bank in
writing.
13. Not to effect any change in promoter directors or in the core management team nor any merger/
acquisition/ amalgamation shall be done without express permission of the Bank in writing.
14. Not to extend finance to associate concerns during the currency of the Bank’s advance without the Bank’s
prior written consent.
15. Not to effect any adverse change in the company’s capital structure.
16. Not to implement any scheme of expansion/modernization/diversification/ renovation (except normal capex)
or sell any fixed assets during any accounting year, except under such scheme, which has already been
approved by the Bank.
17. Not to Invest in shares/debentures or lend or advance funds to or place deposits with any other concern
except normal trade credit or security deposits in the normal course of business or advances to employees.
18. Not to undertake guarantee obligations on behalf of any other company, firm or person without the Bank’s
prior permission in writing.
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19. Not to effect any upward change in the remuneration payable to the directors either in the form of sitting
fees or otherwise. (In case of any default in payment of interest / installment)
20. Not to create any further charge, lien or encumbrance over the assets and properties of the company / firm,
charged / to be charged to the Bank, in favour of any other bank, financial institution, Company, firm or
person.
21. To confine its entire banking business relating to activity including deposit, bill business, foreign exchange
business to our bank / the member banks of the consortium (as the case may be). In case of Multiple
Banking Arrangement, pro-rata share of the banking business shall be routed through our Bank.
22. To keep the Bank informed of the happening of any event likely to have a substantial effect on their profits
or business.
23. To maintain adequate books and records which should correctly reflect their financial position and scope of
operations and should submit to the Bank at regular intervals such statements as may be prescribed by the
Bank in terms of RBI instructions issued from time to time or otherwise. The borrower shall give an
undertaking that the Bank reserves the right to periodically inspect their records and books of accounts to
ensure the correctness of information furnished by them.
24. To submit Audited Financial Statements etc. to the Bank within the stipulated period of time. The borrower
will be liable to pay penal interest in case of any delay in submission thereof.
25. (In cases where the latest audited financial statements of the borrower are not available and the
assessment has been made based on the Provisional financial statements certified by the Company’s
Statutory Auditor)
That the adverse variation between Provisional and Audited financial statements shall not be more than 5%
in respect of Sales, Networth, Networking capital, unsecured loans (treated as quasi-equity) and the bank
has the right to charge additional interest @ 1% p.a. or recall the limit
26. (In case of new borrowers, the following additional undertaking to be obtained):
I / we undertake that none of our associate/group concerns is classified as willful defaulter by any other
Bank/Financial Institution.
I/ we undertake that I/ we shall not induct any person, who is a director on the Board of a Company
which has been identified as willful defaulter and further undertake that in case, such a person is found
to be on Board of Borrower Company, I /we would take expeditious and effective steps for removal of
any such person from the Board of the Company within 30 days of such fact coming to notice.
I/ we undertake to furnish appropriate undertaking /affidavits/ certificates as the Bank may require from
time to time certifying that the funds comprising of entire amount of loan/ facility/sum due/ amount
outstanding in the account have been used exclusively for the purpose for which they were obtained and
the same have not been diverted / siphoned off and no misrepresentation of any kind has been made or
accounts falsified or any fraudulent transaction has been carried out.
I /we undertake that upon identification of aforesaid account as a willful defaulter on account of any of
the reasons stated above including any similar reason as stated above, I / we would be debarred from
availing bank finance for floating new ventures for a period of 5 years from the date the name of willful
defaulter is disseminated in the list of willful defaulters by RBI. I/ we agree that in case of any false
/wrong information, the Bank may consider any legal proceedings, civil or criminal, as may be
necessary, including publishing of my/ our names alongwith photos in newspaper/ CIBIL records / other
credit information Bureau.
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Annexure - 6
GENERAL COVENANTS/ TERMS & CONDITIONS TO BE STIPULATED & APPLICABLE TO ALL
FACILITIES
(To be discussed with the borrower before stipulating Terms & Conditions)
1. Registration with Central Registry of Equitable Mortgage created
The branch shall register mortgage with Central Registry within 30 days of creation of the mortgage.
Modification of the charge on the property should also be registered with Central Registry as per
latest guidelines prescribed from time to time. CERSAI registration charges to be recovered from the
borrower.
2. Obtaining Latest Valuation Report
Branch shall obtain from an approved valuer latest valuation reports of the properties charged to the
Bank. The valuation report should show the market, realizable and insurable value of the properties.
3. Obtaining Title Clearance & Non-encumbrance Certificate
Legal opinion, Non-encumbrance certificate in respect of property to be mortgaged as primary /
collateral security shall be obtained in the prescribed format and effective & valid mortgage shall be
created before disbursement of credit facilities, unless otherwise permitted by the sanctioning
authority.
4. Comprehensive Insurance of Securities
All the securities charged to the Bank, movable or immovable, shall be kept comprehensively
insured with ‘Agreed Bank Clause’.
5. Obtaining Undertaking for Payment of Tax
An undertaking shall be obtained from the owners of the properties mortgaged to the Bank that there
are no arrears of tax including interest leviable thereon under various provisions of Income Tax Act,
against them.
6. Recovery of Process fee/ Upfront Fees and other charges
Process fee, documentation charges and other charges shall be recovered as per schedule of
charges subject to concessions approved if any. Sanction shall be conveyed to the borrower only
after recovery of processing/ upfront fee as per guidelines of the Bank. The Bank reserves the right
to withdraw the concessions granted (if any) without assigning any reason.
7. Statutory / Regulatory Permissions
All statutory and/or regulatory permissions from local or other competent authorities shall be
obtained by the branch/borrower (as applicable).
8. NOC from other Banks
NOC from other banks from whom the company is enjoying/sanctioned credit facilities shall be
obtained and necessary security/charge creation, documentation formalities to be completed.
9. Registration of Charge with ROC
The charge shall be got duly registered/ modified (as applicable) with the Registrar of
Companies within the prescribed time limit.
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Annexure - 7
Collateral Security
Margin
Insurance The assets created out of banks’ advance (besides promoter’s
contribution) shall be insured for full value by the borrower / branch
and all expenses in this regard (including timely renewal of the
insurance cover) shall be borne by the borrower.
Rate of Interest/ …………% (Bank’s spread) over Base Rate (present BR of the bank
Penal Interest is …..%) which works out to ……% at present with monthly rests,
subject to changes in BR/ Spread from time to time. Penal Interest
@ 2 % p.a. over & above the normal rate on overdrawn portion shall
be charged.
Term of Sanction One year
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drawing power.
b) Valuation of stocks to be done at cost/invoice/ market price, whichever is lower.
c) D.P. shall not be allowed against the following:-
i. Obsolete Stocks
ii. Stocks released to the borrower against trust receipt in case of Letter of Credit
established on DA basis till the bills are retired by the borrower.
iii. Debtors more than _______ days old.
iv. Book debts of associate / group concerns, except those arising out of genuine
trade transactions.
v. Unpaid creditors, to be netted off against the value of stocks
vi. Drawing Power shall be calculated strictly in accordance with the guidelines in
force.
4. Drawings would be regulated as per MPBF based on the QIS returns subject to the
availability of drawing powers.
5. All the assets charged/to be charged to the Bank to be kept fully insured at all times
against all risks (FRSD, Burglary, comprehensive risks etc.) and original Insurance cover
note/policy in the name of the Bank a/c borrower firm/Company with Banks
Hypothecation clause to be lodged with the bank.
6. Inspection of stocks / unit visit shall be undertaken as per periodicity fixed by the Bank or
as and when warranted. The bank has the right of deputing its officials/person(s) (like
qualified auditors or management consultants or technical experts) duly authorized by the
bank to inspect the unit, assets, books of accounts/records etc. from time to time,
charges for which shall be debited to the borrower.
7. The bank shall appoint stock auditors for complete checking of the account as per policy
of the Bank, cost of which to be borne by the borrower.
8. QUARTERLY INFORMATION SYSTEM: For working capital limits above Rs. 5.00
crores, the borrower shall submit QIS I, II & III statements as follows:
a) QIS I (showing estimates) is required to be submitted one week preceding the
commencement of the quarter to which it relates.
b) QIS II (showing performance) within six weeks from the close of the quarter to which
the statement relates, and
c) QIS III ( half yearly operating statement) within two months from the close of the half
year.
9. Detailed age wise Book Debt statement to be submitted along with stock statement every
month. CA certified book debt statement with age wise classification to be submitted on
quarterly basis. The borrower shall certify that the book debts have arisen out of genuine
trade transactions and no credit facility has been availed against these book debts from
any other source.
10. CC limit to be used for business purposes only and Bank has the right to recall the limit
and take other punitive measures to protect interest of the Bank in case of any violation.
11. Credit In Accounts: In such cases, where remittances by the borrower are pooled with
one bank/consortium leader, an express consent from that bank/lead bank should be
obtained for immediate transfer of our bank’s share of recovery to us.
12. Delayed submission of stock/book debt statement, shall attract penal interest @1%.
Delayed submission of MSOD/QIS, also attract penal interest of 1% p.a. in addition to
above.
13. In the event of non submission of stock/book debt statements for 3 months continuously,
Drawing Power will be withdrawn and the limit shall be recalled.
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Nature of Facility Clean Bills Purchase
Limit
Purpose
Security Third party cheques / Demand Drafts
Collateral Security
Margin
Rate of Interest / Penal Interest …………% (Bank’s spread) over Base Rate (present BR of the bank is …..%)
which works out to ……% at present with monthly rests, subject to changes in
BR/ Spread from time to time. Commercial rate of interest shall be charged from
the date of purchase till the Bank remains out of funds, in case the cheque /
Demand draft are returned unpaid.
Commission/other charges As per Bank’s schedule of charges
Term of Sanction One year
Any other condition
Other terms & conditions:
1. Self-drawn cheques and of associates concerns
Advance shall not be allowed against
a) Post dated/ self drawn cheques
b) Cheques drawn by allied/sister concerns
c) Cheques above Rs.5000 at any one time in case the borrower
deals in sensitive commodities.
2. Drawee Sub-limit
Suitable sub limit for each drawee to be fixed.
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Nature of facility Foreign Documentary Bill Purchased (FDBP)/ Foreign Usance
Documentary Bill Purchased (FUDBP) / FCBRD
Limit
Security Foreign Documentary Demand/Usance Bill having maximum
usance of ____days accompanied by Airway Bills/Bill of Lading
evidencing shipment of goods dealt in by the borrower and drawn
under irrevocable letter of credit / Confirmed orders.
Collateral Security
Margin
Rate of Interest/ As per RBI directives/Head Office guidelines issued from time to
Penal interest time.
Commission/other charges As per Bank’s schedule of charges.
Special conditions Advance against confirmed orders shall not exceed Rs. ……..
within the overall bills limit of Rs……..
Any other condition
Other terms & conditions:
1. Authenticity of LC / order – verification
The bills shall be negotiated/purchased/discounted after verifying the authenticity of the
confirmed order/ Letter of Credit.
2. ECGC Policy
The bills shall be negotiated/purchased/discounted only after the borrower has obtained
from ECGC (unless otherwise waived) Comprehensive Policy in case of Export against
orders.
3. Buyer-wise ECGC Limit
Single party liability shall not exceed the buyer-wise limit approved by ECGC wherever
ECGC Policy has been obtained. Further, it shall be ensured that exporter is regular in
declaring export shipments and making payment of premium to ECGC.
4. Political Risk cover of ECGC
In case, bills are drawn under Letter of Credit, necessary cover from ECGC shall be
obtained by the borrower to cover political risks wherever warranted, depending upon the
country of Export.
5. Credit Report on drawees
Credit Report on the drawees shall be obtained from their bankers / reputed agencies like
Dun & Bradstreet periodically in case the bills are drawn against confirmed orders.
6. End-use of facility
Proceeds of the bills shall be utilized for adjustment of the Packing Credits wherever
granted.
7. Premium on ECGC – WTPSC coverage
Advance shall be covered under ECIB – WTPSG obtained by the Bank from ECGC and
the premium shall be borne by the bank.
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Collateral Security
Purpose
Margin (1) Financial : …..%
(2) Performance : …..%
Margin shall be kept in the shape of unencumbered duly discharged
FDRs/CDRs. Interest on FDRs/CDRs shall not be released during
the currency of guarantee facility.
Beneficiary(ies)
Period of Guarantee Not to exceed __________months/ years.
Commission and all Commission and other charges shall be recovered at the time of
charges issuance of guarantee as per the Bank’s schedule of Service Charges
as amended from time to time, unless otherwise permitted by
sanctioning authority. In case the guarantee period is extended, the
commission for the extended period shall also be recovered.
Commission shall be recovered for the claim period if any.
Term of Sanction One year
Any other condition
Other terms & conditions:
1. Mandatory clause in BG
The Bank Guarantee form shall incorporate the following clause:
“Notwithstanding anything contained herein:
(i) Our liability under this Bank Guarantee shall not exceed Rs.______ only;
(ii) This Bank Guarantee shall be valid up to _______; and
(iii) We are liable to pay the guaranteed amount or any part thereof under this Bank
Guarantee only and only if you serve upon us a written claim or demand on or
before________ (date of expiry of Guarantee).”
2. Specific & unequivocal BG
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Guarantees issued shall be specific and unequivocal as regards
i) Amount; ii) Period iii) Beneficiary iv) Purpose.
3. Type of Guarantees not to be issued
The following type of guarantees shall not be issued:-
a) Guarantees having unlimited validity/ maturity of more than 10 years except in favour
of courts backed by 100% margin.
b) Guarantees in respect of deposits/ loans received by any person/ Non- Banking
Finance Companies from any source.
4. Onerous clause in BG
The Bank Guarantee issued by the Branch shall not contain any onerous clause or
liability for payment of interest. As far as possible, it should be issued on the 'Model
Form' as approved by the Bank. If deemed necessary, the guarantee format may be got
vetted from the Legal Retainer at Regional Office.
5. Export Guarantees
In case of Export guarantees, the same shall be covered under ECGC’s advance
payment guarantee/export performance guarantee or as per rules of ECGC and the
relative ECGC premium to be borne by the borrower. The borrower shall comply with the
formalities for obtaining due coverage and all relative charges/fees of ECGC to be borne
by the borrower.
6. Charge over current assets as applicable
(Where stipulated as per terms of sanction and agreed to by the borrower or as agreed
by the consortium)- The borrower will be required to execute hypothecation agreement
extending charge over the company’s current assets to the extent of guarantee limit as a
cover for all guarantees issued and/or to be issued by the bank on behalf of the borrower.
7. Recovery of claim from beneficiary
The borrower shall give an irrevocable letter of authority to the bank for debiting their
account straightaway with the amount of claims received from the beneficiary plus
incidental charges.
8. No commitment to allow any additional credit limit
Guarantees will be issued by the bank on behalf of the borrower without in any manner
implying a commitment to allow additional credit facilities to the borrower for payment of
claims against guarantees.
9. Demand and recover margin
The Bank shall be entitled at any time during the currency of the guarantee, to demand
and recover margin to the extent of 100% of the guarantees and in case of default in
payment by the borrower of the margin so demanded, the Bank reserves its right to
recover such margin by debiting any of the borrower’s accounts and such debit shall be
recoverable from the borrowers as their dues.
10. Foreign BG – Compliance of RBI guidelines
In case of Foreign Bank Guarantee, all Exchange control guidelines of RBI relating to
issuance of such guarantees shall be complied with.
11. Takeover of BG outstanding by other Bank
In case any guarantee is outstanding and the account is taken over by some other bank,
the securities shall be released only after obtaining 100% margin or Guarantee of that
bank containing a specific clause that their liability under the said guarantee shall exist till
the original Guarantee Bond is received or a release letter from the beneficiary is
received by PSB.
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Annexure - 8
PUNJAB & SIND BANK
SN PARTICULARS REMARKS
1. Name of the Borrower/ Applicant
2. Existing / Proposed Activity
3. Type of borrower for which due diligence is done.
(New / Existing)
4. Banking Arrangement
(Sole / Consortium/ Multiple Banking Arrangement
/ Joint Lending Arrangement)
5. Promoter(s), Guarantor(s) and Group, if any
6. Experience of the Promoter(s) in the line of
existing/ proposed activity
7. Details of Existing Banker(s) and dealing since
8. Securitisation of statement of Bank account of the
borrower for at least 6 months to ascertain
conduct of account like volume of transactions vis-
à-vis unit’s turnover, continuous/ frequent
overdrawing, frequent returning of cheques,
repayment irregularity etc.
9. Observation on scrutiny done in :-
CIBIL / other credit information bureau
report,
RBI defaulters list
RBI caution list
ECGC-Specific Approval List,
Credit Report of existing banker(s)
Caution list issued by PSB (defaulters /
settled cases / declined cases etc.)
10. Observations made by external rating agencies in
the Credit Risk Rating Report of the borrower
(where available)
11. Verification of ROC records
(Through website: www.mca.gov.in)
12. Observation on Tax Registration/ Tax payments
by the borrower such as PAN/ TAN / Service Tax/
VAT/ Excise Duty registrations (as applicable).
(Tax payment as applicable to the borrower in the
past shall be scrutinized for being in line with the
business activity of the borrower.)
13. Comments on Unit / Office visit conducted
14. Names of market reference contacted & their Name Name of the Relation /
opinion (with relation to the borrower / promoter/ of the firm/ company/ Connection, if
group companies) person Promoter(s)/ any, with the
Guarantor(s) borrower
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15. (In case of existing/fresh sanctions of Rs 5 Crore
& above)
Whether CRILIC report has been verified and if
there are any adverse remarks regarding same.
We have undertaken the due diligence on the applicants/ borrowers from the sources as mentioned above
and are satisfied about their credentials/ credit-worthiness.
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Annexure - 9
The RBI guidelines for financing to infrastructure sector and compliance of the same are
given hereunder:
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S RBI Guidelines Compliance
N
2. For takeout finance
a. In case of Substantial Takeout (more than 50% of the
outstanding loan by value):
i. Such loans should be 'standard' in the books of the
existing banks, and should have not been restructured in
the past;
ii. Such loans should be substantially taken over (more than
50% of the outstanding loan by value) from the existing
financing banks / financial institutions; and
iii. The repayment period should be fixed by taking into
account the life cycle of the project and cash flows from
the project.
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S RBI Guidelines Compliance
N
envisaged for the project. The term loan could supplement the
budgetary resources if such supplementing was contemplated
in the project design.
6. Classification of advances (secured/ unsecured) granted for
road projects under Public-Private Partnership (PPP):
In case of PPP projects, the debts due to the lenders may
be considered as secured to the extent assured by the
project authority in terms of the Concession Agreement,
subject to conditions stipulated by RBI in its master circular
on prudential norms.
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The Bank’s policy guidelines for financing to infrastructure sector and compliance of the same are
given hereunder:
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Annexure- 10
The RBI guidelines for financing to Commercial Real Estate and compliance of the same are given hereunder:
RBI Guidelines Compliance
1. Construction activities not eligible for bank credit:
Extending finance for fund based or non fund based
facilities to private builders for acquisition of land even as
a part of cost of project is not permitted. However, the
cost of land would form integral part of the total cost of
the project.
Branches should not grant finance for construction of
buildings meant purely for Government/Semi-
Government offices, including Municipal and Panchayat
offices.
Loans cannot be extended to Government entities where
the loans are envisaged to be repaid out of budgetary
allocations.
2. Obtaining clearances from Regulatory Authorities.
It must be ensured that before release of funds, various
clearances from regulatory authorities have been
obtained. The facility may, however, be sanctioned
subject to the condition that the same shall be released
only after obtaining necessary clearances from the
competent authority.
The Bank’s Policy guidelines for financing to Commercial Real Estate and compliance of the same are given
hereunder:
Bank’s Policy guidelines Compliance
1. Margin Requirement:
The margins on advances would be minimum of
40% but could be reduced to 25% only in case of
urban projects allotted/ auctioned by the Govt.
development agencies like DDA, NOIDA, GDA, PUDA
etc.
Particulars Status
Name of the project
Cost of project envisaged at the start of project
Actual cost incurred on the project
In case of major increase in the cost of project, reasons in
detail along with source of finance of additional cost
COD envisaged originally
COD achieved on
If COD achieved with delay or yet to be achieved, reasons
thereof
Particulars Status
Name of the project
Cost of Project
Name of Banker
Amount of borrowings
Present status of the project
Whether the same is running as per schedule, if not
reasons thereof
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Annexure – 11
The RBI guidelines for Restructuring cases and compliance of the same are given hereunder:
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The Bank’s policy guidelines for Restructuring cases and compliance of the same are given hereunder:
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Annexure - 12
The RBI guidelines for Inter Bank Participations (with risk sharing or without risk sharing)
and compliance of the same are given hereunder:
RBI Guidelines Compliance
I) Applicability:
a) With risk sharing: Can be issued by scheduled
commercial banks. However, RRBs can also issue
IBPC to scheduled commercial banks against their
priority sector advances.
b) Without risk sharing: Can be issued by scheduled
commercial banks (excluding RRBs) only.
II) Eligibility:
a) With risk sharing:
Only those accounts which are ‘Standard’ assets
with the issuing bank with no overdue in relation
to principal/ interest/ other charges.
External rating should not be below ‘BBB’/P3 or
equivalent as per Basel II norms,
The Bank shall not participate in any externally
unrated account.
b) Without risk sharing:
Only those accounts which are ‘Standard’ assets
with the issuing bank.
Issuing bank should have CRAR not less than
9% for nationalized banks and 12% for private
commercial banks / foreign banks operating in
India.
III) Period/tenor:
a) With risk sharing: The minimum period of
participation will be 91 days while the maximum
period will be 180 days.
b) Without risk sharing: The maximum period of
participation will be 90 days.
IV) Amount:
a) With risk sharing:
The aggregate amount of such participation in any
account should not exceed 40 per cent of the
outstandings in the account at the time of issue
(within prudential exposure ceiling to individual
borrower/ group).
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RBI Guidelines Compliance
During the currency of the Participation the
aggregate amount of Participation should be
covered by the outstanding balance in the account.
In case the outstanding balance falls short of the
participation outstanding, the Issuing bank will
reduce the Participation to the extent necessary and
if need be, issue Participation for smaller amounts.
V) Rate of interest:
a) With risk sharing:
To be decided by the issuing and participating
banks based on Credit Risk of borrower and
prevailing market conditions.
Payable on monthly basis.
b) Without risk sharing:
To be decided by the issuing and participating
banks based on our Bank’s liquidity position and
prevailing market conditions.
Payable on monthly basis.
VI) Transferability:
a) With risk sharing:
Participation is not transferable.
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The Bank’s policy guidelines for IBPC and compliance of the same are given hereunder:
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Annexure -13
The RBI Guidelines for transfer/ takeover of borrowal accounts from one bank to another bank and
compliance of the same are given hereunder:
The Bank’s policy guidelines for transfer/ takeover of borrowal accounts from one bank to another bank and
compliance of the same are given hereunder:
SN Bank’s Policy guidelines Compliance
1 Minimum Credit Rating:
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5 Restriction on Borrowal Accounts to be taken over from other
banks:
If the borrowal account to be taken over by the Bank belongs to the
banks where any of its ED or CMD has worked earlier then such cases,
irrespective of amount, shall be sanctioned only by the Board of Directors
with specific reasons justifying the need for taking over such accounts
Monitoring System of takeover Accounts
(i.) Credit Audit of account with total exposure of Rs.2.00 crore and
above be got conducted as per extant guidelines of the Bank.
(ii.) Stock Audit is to be got done before disbursement/takeover of
facilities by external auditors where cash credit exposure exceeds
Rs.50.00 lac. For exposure less than Rs.50.00 lac, Branch incumbent
to verify the stocks and place on record his report having
checked/verified the stocks as per extant guidelines of the bank.
(iii.) For cases with exposure of Rs.3.00 crore and above, Zonal Manager
or any other officer deputed from ZO to visit the unit periodically.
Compliance of (i) and (iii) above is to be followed for the first two
years of takeover and normal guidelines with regard to credit
monitoring will be followed there after.
6 Other Due Diligence to be undertaken:
The Borrowal account should be classified as Standard Asset
with the existing Bank in terms of RBI extant guidelines on
IRAC and running regular on the date of takeover. No
restructured account is to be taken over by the Bank.
Borrowers which are in existence and earning profit for the
preceding 3 years.In respect of accounts, which are in
existence for a period of less than three years, the unit
should have earned cash profit during 1st year of commercial
production and from the 2nd year onwards, unit should have
earned net profit. However, in such cases one audited
Balance Sheet should be available before hand. For
assessing the criteria of cash profit in the first year of
commercial production, the working of 12 months should be
reckoned.
The net worth of the unit should be positive as per last
audited Balance sheet and should not be less than 75% of its
peak net worth during the preceding 3 years.
The name of borrowal account/promoters/guarantors should
not appear in RBI/CIBIL’s defaulter list /caution list /willful
defaulters list
None of the Borrowal/Group concerns accounts should have
been settled under any OTS scheme of the Banks/FIs.
The outstanding for take over account be taken from the
transferor bank and amount be remitted directly subject to
release and transfer of all the securities charged to them
directly to our bank
A brief note from borrower giving details of his Bankers in the
previous five years and reasons for switching over from
present Banker to our bank be obtained and analysed in right
perspective of spirit of banking. After analyzing the facts
given by the party and synchronizing the same with prevailing
Banking practice, RBI/Bank’s guidelines and organizational
goals, Branch Manager to put on record justification report for
taking over the account by the Bank.
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Annexure - 14
The RBI guidelines for financing to Non Banking Finance Companies (NBFCs) and
compliance of the same are given hereunder:
SN RBI Guidelines Compliance
1 NBFCs eligible for bank finance:
All NBFCs registered with RBI as well as NBFCs not
requiring registration as per RBI guidelines.
2 Activities of NBFCs not eligible for bank finance:
The Bank will not finance to NBFC undertaking the activities
like:
loans and advances to their subsidiaries, group
companies / entities.
Investments, both of current and long-term nature, in
any company/ entity by way of shares, debentures, etc.
Unsecured loans / inter-corporate deposits to / in any
company.
lending to individuals for subscribing to IPO and for
purchase of shares from secondary market.
Bills discounted / rediscounted by NBFCs, except for
rediscounting of bills discounted by NBFCs arising from
sale of Commercial vehicles (including light commercial
vehicles), Two wheeler and three wheeler vehicles,
subject to certain specified conditions.
3 Benchmark Financial Ratio:
The benchmark financial ratios applicable to NBFCs are as
under:
Minimum CRAR for Deposit/ Non-Deposit taking
systemically important NBFCs is 15%.
Tier I CRAR for Captive NBFCs shall be atleast 12%
from the time of registration.
Minimum Tier I CRAR for NBFCs predominantly
engaged in lending against Gold will be 12% by
01.04.2014.
NBFCs predominantly engaged in lending against Gold
should strictly comply to the following regulatory
restrictions:
o The Loan-to-Value (LTV) ratio not exceeding 60 per
cent for loans against collateral of gold jewellery.
o NBFCs should not grant any advance against
bullion/primary gold & gold coins.
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SN RBI Guidelines Compliance
4 Other Prohibitions:
No Bridge loans/ interim finance to be extended.
No advance against collateral security of shares to
NBFCs:
No guarantees to be extended for placement of funds
with NBFCs.
Bank can extend financial assistance to NBFCs involved
in factoring business provided the criteria stipulated by
RBI for such companies is complied which inter-alia
include deriving atleast 50% of their income from
factoring activity and receivable purchased/ financed
shall form atleast 50% of the assets of the factoring Co.
The Bank’s policy guidelines for financing to Non Banking Finance Companies (NBFCs) and
compliance of the same are given hereunder:
SN Bank’s Policy guidelines Compliance
1 Exposure to NBFC
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Annexure - 15
COMPLIANCE OF RBI/BANK’S POLICY GUIDELINES ON
SECURITIZATION/ POOL PURCHASE
The RBI Guidelines for financing Securitisation Companies and compliance of the same are
given hereunder:
SN RBI Guidelines Compliance
1 Assets Eligible for Securitization/ Pool Purchase:
As per RBI guidelines, in a single securitization
transaction/ Pool purchase, the underlying assets
should represent the debt obligations of a
homogeneous pool of obligors. Subject to this
condition, all on-balance sheet standard assets except,
the following, are eligible for securitization by the
originators:
Revolving credit facilities (e.g. Cash Credit accounts,
Credit Card receivables etc.)
Assets purchased from other entities
Securitization exposures (e.g. Mortgage-backed/asset-
backed securities)
Loans with bullet repayment of both principal and
interest. However, loans with tenor up to 24 months
extended to individuals for agricultural activities (as
defined by Rural Planning and Credit Department of
the Reserve Bank of India, in the Master Circular -
Lending to Priority Sector) where both interest and
principal are due only on maturity and trade
receivables with tenor up to 12 months
discounted/purchased by banks from their borrowers
will be eligible for securitization. Further, only those
loans/ receivables will be eligible for securitization
where a borrower (in case of agricultural loans) /a
drawee of the bill (in case of trade receivables) has
fully repaid the entire amount of last two
loans/receivables (one loan, in case of agricultural
loans with maturity extending beyond one year) within
90 days of the due date.
2 Securitization Activities/ Exposures Not Permitted:
As per RBI guidelines, banks in India including their
overseas branches, are not permitted to undertake the
securitization activities or assume securitization
exposures as mentioned below.
Re-securitization of Assets: A re-securitization
exposure is a securitization exposure in which the risk
associated with an underlying pool of exposures is
tranched and at least one of the underlying exposures
is a securitization exposure. In addition, an exposure
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SN RBI Guidelines Compliance
to one or more re-securitization exposures is a re-
securitization exposure. This definition of re-
securitized exposure will capture Collateralized Debt
Obligations (CDOs) of Asset Backed Securities,
including, for example, a CDO backed by Residential
Mortgage-Backed Securities (RMBS).
Synthetic Securitizations: A synthetic securitization
is a structure with at least two different stratified risk
positions or tranches that reflect different degrees of
credit risk where credit risk of an underlying pool of
exposures is transferred, in whole or in part, through
the use of funded (e.g. credit-linked notes) or
unfunded (e.g. credit default swaps) credit derivatives
or guarantees that serve to hedge the credit risk of the
portfolio. Accordingly, the investors’ potential risk is
dependent upon the performance of the underlying
pool.
Securitization with Revolving Structures (with or
without early amortization features): These involve
exposures where the borrower is permitted to vary the
drawn amount and repayments within an agreed limit
under a line of credit (e.g. credit card receivables and
cash credit facilities).Typically, revolving structures
will have non-amortizing assets such as credit card
receivables, trade receivables, dealer floor-plan loans
and some leases that would support non-amortizing
structures, unless these are designed to include early
amortization features. Early amortization means
repayment of securities before their normal contractual
maturity. At the time of early 27 amortization there are
three potential amortization mechanics: (i) Controlled
amortization; (ii) Rapid or non-controlled
amortization; and (iii) Controlled followed by a
subsequent (after the completion of the controlled
period) non-controlled amortization phase.
3 Minimum Holding Period (MHP) of Securitized / Pool
Assets:
Minimum Holding Period will be defined with reference to
the number of installments to be paid prior to securitization.
Minimum Holding Period applicable to various loans
depending upon the tenor and repayment frequency
Minimum Holding Period will be counted from the date of
full disbursement of loans for an activity/purpose;
acquisition of asset (i.e., car, residential house etc.) by the
borrower or the date of completion of a project, as the case
may be.
The Minimum Holding Period will be applicable to
individual loans in the pool of securitized loans.
Minimum Holding Period will not be applicable to loans
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SN RBI Guidelines Compliance
with tenor up to 24 months extended to individuals for
agricultural activities (as defined by Rural Planning and
Credit Department of the Reserve Bank of India, in the
Master Circular - Lending to Priority Sector) where both
interest and principal are due only on maturity and trade
receivables with tenor up to 12 months
discounted/purchased by banks from their borrowers will
be eligible for securitization.
The Bank will invest in only those securitization assets /
purchase pool assets where the originators have fulfilled the
criteria of Minimum Holding Period of securitized assets in
its Book as per RBI guidelines.
4 Minimum Retention Requirement in Securitized /Pool
Assets:
The Bank will invest in only those securitization assets /
purchase pool assets where the originators have fulfilled the
criteria of Minimum Retention Requirement in securitized/
pool assets Book as per RBI guidelines.
Minimum Retention Requirement applicable to various
loans depends upon the tenor of loan as specified in RBI
guidelines.
The MRR should not be reduced either through hedging of
credit risk or selling the retained interest. The MRR as a
percentage of unamortized principal should be maintained
on an ongoing basis except for reduction of retained
exposure due to proportionate repayment or through the
absorption of losses. The form of MRR should not change
during the life of securitization.
MRR will have to be maintained by the entity which
securitizes the loans. In other words, it cannot be
maintained by other entities which are treated as
‘originator’. "Originator" refers to a bank that transfers
from its balance sheet a single asset or a pool of assets to an
SPV as a part of a securitization transaction and would
include other entities of the consolidated group to which the
bank belongs.
In the case of long term loans, the Minimum Retention
Requirement may also include a vertical tranche of
securitized paper in addition to the equity/subordinate
tranche, to ensure that the originating banks have stake in
the performance of securitized assets for the entire life of
the securitization process.
The MRR should represent the principal cash flows.
Therefore, banks’ investment in the Interest Only Strip
representing the Excess Interest Spread/ Future Margin
Income, whether or not subordinated, will not be counted
towards the MRR.
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The Bank’s policy guidelines for financing to Securitisation Companies and compliance of
the same are given hereunder:
SN Bank’s Policy guidelines Compliance
1 Other Conditions to be Met Before Taking Exposure in
Securitisation of Assets:
Originating company should be rated Minimum “AA” from
a RBI approved rating agency and that rating should be
reviewed on an annual basis.
In case of Non Priority Sector, the Pool should be
necessarily rated minimum “A” with RBI Approved rating
agency, and that rating should be thereafter reviewed on an
annual basis. However, in case of pools under Priority
Sector, the condition of rating may be waived.
To cover Credit & Liquidity risks, the bank may undertake
the Credit Rating exercise and/or Loss Ratio Evaluation
through a Rating agency of the Pool and ensuring
compliance of the Minimum Retention Requirement
(MRR) on an ongoing basis. Probability of default (PD)
and Loss Given Default (LGD) history of individual
segment (Car, Home, etc.) of the pool to be obtained from
originator duly certified by their CA to assess the overall
risk.
The default rate (ultimate losses) of the pool as per Loss
Ratio Evaluation report of the approved rating agency
should be less than the default rate of our bank for the
similar portfolio. The losses at the pool level could be
additionally impacted because of geographic concentration,
geography-specific performance, and stress caused by any
economic, political, legal, or force majeure risks/events. In
such a situation, the estimated ultimate losses could be
more than the ultimate losses estimated for the pool.
Originating company should be in the same line of business
for minimum 5 years.
The loan to value (LTV) for Auto loan (only new car )and
for Mortgage loan as per RBI guidelines.
Pool should not contain any Non Performing account
Pricing of the Pool will depend on the IRR of the pool,
interest rate scenario and other market conditions.
The total exposure on Pool Assets shall not exceed at any
point of time 10% of the total advances of the Bank.
Proposal relating to Securitisation of Assets will be dealt at
HO only.
The originator or its Agent would act as collection and
Service agent of the pool and would continue to hold PDCs,
Securities, Documents etc. on behalf of the assignee and
would receive and collect all the amounts falling due from
the underlying borrowers from time to time and enforce
obligation of the borrowers and all securities created by
them. For these services, the collection & service charges
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SN Bank’s Policy guidelines Compliance
payable for Priority Sector pools would be negotiable on
case to case basis for non priority sector pools , upfront
charges for the entire period of pool shall be maximum upto
Rs.10000/.
The “securitisation of assets Portfolio” will be built up
through Direct Assignment of Cash flows and the
underlying Securities. And shall be reviewed at yearly
intervals. The performance of the pool of assets purchased /
assigned directly in favour of the Bank shall be reviewed
periodically and if there is any short fall in collections,the
same shall be made good through credit / liquidity
enhancements provided by the originator.
All securitization transaction shall be in conformity with
regulatory compliance which includes SARFAESI Act
2002 and RBI guidleines o the subject. The regulatory
norms for capital adequacy, valuation, profit/loss on sale of
assets, income recognition and provisioning for originators
and service providers like credit enhancers, liquidity
support providers as well as investors as also the
accounting treatment for securitisation transactions and
disclosure norms as enunciated by RBI shall be followed
strictly.
2 Transactions Involving Transfer of assets through Direct
Assignment of Cash Flows and the underlying Securities –
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Annexure - 16
The Bank’s Policy guidelines for financing to capital market and compliance of the same are
given hereunder:
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Appendix 3
Along with the details mentioned in the new loan appraisal note format, following General
guidelines to be kept in mind at the time of preparing appraisal note are as follows:
General
Comments on performance should capture/ assess in essence the company’s business
model Performance should be with specific focus on activity levels, PBDIT, profits and
profitability ratios.
Key elements of the company’s business model that differentiates it from its peers and
contribute to its success are to be commented upon.
Actual sales should be compared to the sales of the last year as well as estimated/
projected sales submitted earlier and reasons for decrease in sales from last year and
variations from the estimated/ projected sales.
The current year estimates and its acceptability with due justification. Justification for
accepting the estimated sales to be given based on sales achieved till date during the
current year, capacity expansion, orders in hand etc.
If the sales exceeded industry trends or otherwise –reasons for the same. Strategies for
achieiving the estimated/ projected level of sales. Segmental analysis of sales.
Customerwise analysis of sales – if relevant (order book position may be given in an
annexure if required)
Profitability - On similar lines as above
Liquidity - To include comment on the current ratio, debtors ageing analysis. Adverse
features pointed out in the Stock and Receivables Audit. If any, and its impact on liquidity to
be commented upon.
Paid Up capital/ TNW
In case there is movement in paid up capital, reasons viz. issue of fresh capital, issue of
bonus shares, conversion of FCCB into equity, buy back of shares, etc. should be
mentioned. In case of issue of fresh capital, premium amount, if any, IPO or private
placements, should be mentioned. There should be comment whether the company is
making provisions for redemption of FCCB on due date. Comments on residual period of
preference shares should be given.
Share Application Money is to be included in TNW if it is supported by an undertaking to
convert it into Paid up Capital within a given time frame, however the date of conversion
of the amount in to PUC to be mentioned in such case. Also, stipulation for conversion to
be made for release of new limits. A copy of board resolution along with a copy of
applicable form filed with ROC to be obtained.
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In case of partnership/proprietorship firm, stipulation is to be made that the firm would
maintain the capital at the actual/estimated level during the currency of advance.
In case of infusion of fresh capital / share premium specific sources be explained
The overdue amount “if any” under different types of facilities must be mentioned
alongwith duration of irregularity, since when irregular, the month / quarter to which the
overdue pertains.
The confirmation of compliances of pre-disbursement conditions must be given.
In case where renewal has been done on the basis of provisional Balance Sheet, a
condition for submission of audited B/S should be stipulated alongwith time frame. On
receipt of Audited Balance sheet, the same should be compared with Provisional
Balance sheet and variations, if any, should be discussed in the note.
iii. Concession in ROI/ Service Charges - Whenever concession in ROI / other charges has
been recommended, detailed justification should be given.
iv. External Rating - In case, the borrower has been externally unrated, reasons for remaining
unrated must be clearly mentioned alongwith the action taken for getting the account
externally rated giving timeframe for getting the account rated.
v. Project Loans:
Name of the agency which has appraised the project / done TEV study must be
mentioned.
“Physical Progress” vis-à-vis “the projections” made must be captured in the process
note. The progress of completion in percentage terms must be indicated. In case of
variation, detailed reasons must be furnished in the process note.
The position of time overrun vis-à-vis time schedule envisaged for each stage of
completion must also be given.
The “Financial Progress” vis-à-vis the projections made must be captured in terms of
the borrower contribution brought in and the corresponding D/E ratio, cash flows
actually generated vis-à-vis estimates.
ix. Loss/ Haircut to the Bank - Loss haircut suffered by the Bank on account of Compromise/
Writeoff/ references to CDR, including Recompense clause, in respect of exposures on
Companies including companies floated by Groups/ Asssociates/ Related parties/ Directors/
Guarantors to be commented upon.
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x. Changes in Covenants - Whenever approval is sought for changes in key covenants like
borrowers constitution, substitution/ release of security, Substitution / release of personal
guarantee of promoter etc., the detailed justification should be furnished and the impact of
the change on Bank’s exposure should be discussed in the note.
xi. Investment in group Concerns - Wherever investment in group concerns is done by the
borrower, the same should be explained alongwith key financials of the investee companies.
xii. LC For Capital Expenditure - Where LCs have been opened for capital expenditure, the
status of procurement of equipment purchased under the LC must be indicated alongwith
the arrangement for retiring the documents under LC on due date.
xiii. Latest tax Return - The date of the latest returns filed and assessments completed with
regard to the income tax for borrower / constituents must be clearly indicated.
xiv. Unit Visit - The date of last unit visit must be reported in the process note alongwith
observations of the visiting officials.
The date of last consortium meeting held should be reported alongwith deliberations held
and decisions arrived at.
Position of disbursement of facilities by co-lenders (wherever applicable) should be
given.
If other banks are not taking up their respective shares, reasons for the same must be
mentioned clearly.
Position of sanction by other banks must be commented.
xvi. Security:
In case of primary / collateral security, the type of charge held by the Bank must be
clearly reported viz., 1st exclusive charge, 1st pari-passu charge, 2nd pari-passu charge
etc.
Where collateral is shared between more than one lender, total value of the collateral
should be shown alongwith our share in the value of collateral (amount as well as
percentage).
In case the value of property / security is reported, the same shall be with reference to the
latest valuation, giving the date of valuation report.
Compliance of guidelines as contained in legal audit policy issued by H.O. Inspection
Deptt. to all Zones vide mail dated 27.02.2015 and H.O. L& R Cir. No. 183 to be ensured.
xvii. Approval from various Authorities - Proposal for sanction of credit facility for different
businesses / projects require different approvals from various regulatory / statutory and
other authorities which may vary depending upon the type of business done, the stage of
implementation at which the approval is required etc. Accordingly, the process note should
show the status of the clearances / approvals obtained / to be obtained. Indicative list of
clearances include Land/ Site availability, Environmental and Costal Regulation Zone
clearance, NOC from Pollution Control Board, Stack height clearance, Forest clearance,
Power connection, Water connection, Chief Controller of Explosives from Petroleum and
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PUNJAB & SIND BANK – New Appraisal Note Format (H.O./ZO)
…………………………………………………………………………………………………………………
Explosives Safety Organisation, NOC form Defence, Rail Route Clearance, Customs
landing Permit, Permission from the State Government for extraction of boulders from
quarry, License from Inspector of Factories or other competent Authority for setting up
Batching Plant, Permission from State Government for cutting of trees, Any other
permission/ clearances required under applicable laws for the specific proposal clearance.
xviii. Formatting - All figures should be Right justified and the amount should be mentioned `
Crore uniformly throughout the process note.
xix. Rate of Interest - Rate of interest charged by other Bank should be clearly brought out and
Date of reset of ROI (if applicable) should be given.
xx. Total borrowings of Borrower and Group from Banking system - The total borrowings
of borrower and the group to whom they belong to must be ascertained and mentioned
xxi. Other Directions - Any other information as directed by the Bank’ Circular/ Board / RBI
from time to time shall also be provided in the Process Note.
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