RBI/2021-22/119

DoR.STR.REC.65/09.27.000/2021-22 November 02, 2021

The Managing Director/ Chief Executive Officers

All Primary (Urban) Co-operative Banks

Dear Sir/ Madam,

Master Circular- Guarantees, Co-Acceptances & Letters of Credit - UCBs

Please refer to our Master Circular DCBR. BPD (PCB) MC. No.8/09.27.000/2015-16
dated July 1, 2015 on the captioned subject (available at RBI website
https://rbi.org.in/). The enclosed Master Circular consolidates and updates all the
instructions / guidelines on the subject issued up to November 1, 2021 as listed in the
Annex.

Yours faithfully

(Manoranjan Mishra)
Chief General Manager

�व�नयमन �वभाग, केन्द्र�य कायार्लय, 12 माला,शह�द भगत�संह मागर्, फोटर् ,मुम्बई 400001
Department of Regulation 12th Floor, NCOB Shahid Bhagat Singh Marg, Fort, Mumbai- 400001
FAX NO. 0091-22-22701241 Tel. No.022-22601000 E-mail address [email protected]
�हंद� आसान है , इसका प्रयोग बढ़ाइए
 Contents

Master Circular- Guarantees, Co-Acceptances & Letters of Credit

1. Guarantees Page
No.
1.1 Issue of Guarantees 3
1.1.1 Broad Guidelines 3
1.1.2 Purpose 3
1.1.3 Maturity 3
1.1.4 Volume 3
1.1.5 Secured Guarantees 3
1.1.6 Unsecured Guarantees 4
1.1.7 Deferred Payment Guarantees 4
1.2 Guarantees in respect of Commodities covered under Selective 4
Credit Controls
1.3 Safeguards in Issuance of Guarantees 5
1.4 Payment under Bank Guarantees - Immediate Settlement of Cases 6
1.5 Delay in Obtaining Certified Copies of Judgments 6
1.6 Correspondence with Government Departments 7

2. Co-acceptance of Bills
2.1 Irregularities in Co-acceptance of Bills 7
2.2 Safeguards 8

3. Letter of Credit
3.1 Guidelines for Grant of LCs facility 8
3.2 LCs for Commodities Covered under Selective Credit Controls 9
3.3 Safeguards in Opening of LCs 9
3.4 Payment under LCs - Immediate Settlement of Claims 10

4. Other Common Guidelines

4.1 Credit Exposure Norms and Statutory / Other Restrictions on Non- 11
fund Based Limits

Annex 13
 Master Circular

Guarantees, Co-Acceptances & Letters of Credit - UCBs

1. Guarantees

1.1 Issue of Guarantees

1.1.1 Broad Guidelines

In view of the risks involved in the business of issuance of guarantees,

the Primary (Urban) Co-operative Banks (UCBs) should extend
guarantees within restricted limits so that their financial position is not
impaired. The banks should follow certain broad guidelines in respect of
their guarantee business as indicated in the following paragraphs.

1.1.2 Purpose

(i) As a general rule, banks may provide only financial guarantees and
not performance guarantees.

(ii) However, scheduled banks may issue performance guarantees on

behalf of their constituents subject to exercising due caution in the
matter.

1.1.3 Maturity

It would be desirable for UCBs to confine their guarantees to relatively

short-term maturities. Guarantees should not be issued for periods
exceeding ten years in any case.

1.1.4 Volume

The total volume of guarantee obligations outstanding at any time may

not exceed 10 per cent of the total owned resources of the bank
comprising paid up capital, reserves and deposits. Within the overall
ceiling, proportion of unsecured guarantees outstanding at any time may
be limited to an amount equivalent to 25% of the owned funds (paid up
capital + reserves) of the bank or 25% of the total amount of guarantees,
whichever is less.

1.1.5 Secured Guarantees

Banks should preferably issue secured guarantees. A secured

guarantee means a guarantee made on the security of assets (including
cash margin), the market value of which will not at any time be less than
the amount of the contingent liability on the guarantee, or a guarantee
fully covered by counter guarantee/s of the Central Government, State
Governments, public sector financial institutions and / or insurance
companies.
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 1.1.6 Unsecured Guarantees

Banks should avoid undue concentration of unsecured guarantee

commitments to particular groups of customers and / or trades. The
banks' Board of Directors should fix suitable proportions for issuance of
unsecured guarantees on behalf of any individual constituent so that
these guarantees do not exceed a -

(a) reasonable proportion of the total obligations in respect of

unsecured guarantees provided by the bank to all such constituents
at any time, and

(b) reasonable multiple of the shareholdings in the bank.

1.1.7 Deferred Payment Guarantees

(i) Banks should generally provide deferred payment guarantees

backed by adequate tangible securities or by counter guarantees of the
Central or the State Government or public sector financial institutions or
of insurance companies and other banks.

(ii) Banks, which intend to issue deferred payment guarantees on

behalf of their borrowers for acquisition of capital assets should ensure
that the total credit facilities including the proposed deferred payment
guarantees do not exceed the prescribed exposure ceilings.

(iii) The proposals for deferred payment guarantees should be

examined having regard to the profitability / cash flows of the project to
ensure that sufficient surpluses are generated by the borrowing unit to
meet the commitments as a bank has to meet the liability at regular
intervals in respect of the instalments due. The criteria generally followed
for appraising a term loan proposal for acquisition of capital assets
should also be applied while issuing deferred payment guarantees.

1.2 Guarantees in respect of Commodities covered under Selective

Credit Controls

UCBs should not issue, either to a Court or to Government, or any other

person, a guarantee on behalf of or on account of any importers guaranteeing
payment of customs duty and / or import duty, or other levies, payable in
respect of import of essential commodities without taking, as security for
issue of such guarantees, a cash margin equivalent to at least one half of the
amount payable under the guarantee. The term "essential commodities" shall
mean such commodities as may be specified by the Reserve Bank of India
from time to time.

4
1.3 Safeguards in Issuance of Guarantees

While issuing financial guarantees, banks should observe the following

safeguards:

(i) UCBs shall appraise the proposals for guarantees with the same diligence
as in the case of fund based limits and such assessments shall inter alia
factor in the presence of security, adequate margin, etc., or otherwise.

(ii) Bank guarantees should be issued in security forms serially numbered to

prevent issuance of fake guarantees.

(iii) Guarantees above a particular cut off point, as may be decided by each
bank, should be issued under two signatures in triplicate, one copy each for
the branch, beneficiary and Controlling Office / Head Office. It should be
binding on the part of the beneficiary to seek confirmation of the Controlling
Office / Head Office as well for which a specific stipulation be incorporated in
the guarantee itself.

(iv) The guarantees should not normally be allowed to the customers who
do not enjoy credit facilities with the banks but only maintain current
accounts. If any requests are received from such customers, the banks
should subject the proposals to thorough scrutiny and satisfy themselves
about the genuine need of the customers. Banks should be satisfied that
the customers would be in a position to meet the claims under the
guarantees, when received, and not approach the bank for credit facility in
this regard. For this purpose the banks should enquire into the financial
position of the customers, the source of funds from which they would be in
a position to meet the liability and prescribe a suitable margin and obtain
other security, as necessary. The banks may also call for the detailed
financial statements and Wealth-tax / Income-tax returns of the customer to
satisfy themselves of their financial status. The observations of the banks in
respect of all these points should be recorded in banks' books.

(v) Where the customers enjoy credit facilities with other banks, the
reasons for their approaching the bank for extending the guarantees should
be ascertained and invariably, a reference should be made to their existing
bankers with whom they are enjoying credit facilities.

(vi) Banks, when approached to issue guarantees in favour of other banks

for grant of credit facilities by another bank, should examine thoroughly the
reasons for approaching another bank for grant of credit facilities and satisfy
themselves of the need for doing so. This should be recorded in bank's
books.

When it is considered necessary to issue such guarantees, the banks

concerned should ensure that the relative guarantee document, beyond a
stipulated amount, should not be signed singly but by two authorised officials
jointly after obtaining proper sanction and authority and proper record of such
guarantee issued being maintained. The credit proposals should be
5
 subjected to usual scrutiny by the lending bank ensuring that the proposals
conform to the prescribed norms and guidelines and credit facilities are
allowed only if the bank is satisfied about the merits of the proposal and the
availability of another bank's guarantee should not result in a dilution of
the standards of evaluation of the proposal and financial discipline in
lending.

1.4 Payment under Bank Guarantees - Immediate Settlement of Cases

(i) Government of India and Reserve Bank of India have been receiving a
number of complaints on non-payment or delay in payment of bank
guarantees upon invocation.

(ii) The bank guarantee is a commitment made by the issuing bank to make
payment to the beneficiary (albeit at the behest of the bank's constituent).
Failure on the part of the bank to honour the claim legitimately made on it
projects a distorted picture of its functioning.

(iii) In fact some strictures were passed by Courts in the past against banks
for not honouring the guarantee commitments promptly. In this connection,
an extract of a judgment pronounced by the Hon'ble Supreme Court, in a
case on the issue of injunctions obtained by parties from courts restraining
payment of invoked guarantees is appended :

"We are therefore, of the opinion that the correct position of law is that
commitment of banks must be honoured free from interference by the
courts and it is only in exceptional cases, that is to say, in case of fraud
or in case where irretrievable injustice would be done, if bank guarantee
is allowed to be encashed, the court should interfere."

(iv) The UCBs should, therefore, honour bank guarantees issued by them
promptly on their invocation as reluctance on their part to honour
commitments in respect of invoked guarantees tend to bring the banking
system into disrepute.

1.5 Delay in Obtaining Certified Copies of Judgments

(i) The Ministry of Finance has advised that some of the Departments such
as Department of Revenue, Govt. of India, are finding it difficult to execute
judgments delivered by various courts in their favour as banks do not honour
their guarantees unless certified copies of the court judgments are made
available to them.

(ii) Keeping in view these difficulties, banks may follow the following
procedure:

(a) Where the bank is a party to the proceeding initiated by

Government for enforcement of bank guarantee and the case is decided
in favour of the Government by the Court, bank should not insist on
6
 production of certified copy of the judgment as the judgment order is
pronounced in open court in the presence of the parties / their counsels
and the judgment is known to the bank and a copy of the judgement is
available on websites of the Courts.

(b) In case the bank is not a party to the proceeding, a signed copy of
the minutes of the order certified by the Registrar / Deputy or Assistant
Registrar of the High Court duly attested to be true copy by Govt.
Counsel should be sufficient for honouring the obligation under the
guarantees unless the guarantor bank decides to file any appeal against
the order of the High Court.

1.6 Correspondence with Government Departments

(i) The Constitution of India states that all executive action relating to Union
of India shall be, and shall be stated to be, in the name of President of India.
However, the business of the Government of India is transacted through
several ministries / departments and even though documents such as
guarantees reflect the President of India as one of the parties,
correspondence is not to be exchanged with the President of India but with
concerned Government Ministry / Departments.

(ii) The banks should, therefore, ensure that any correspondence relating
to guarantees furnished by the banks in the name of the President of India
favouring the Government Departments should not be addressed to the
President of India causing avoidable inconvenience to the President's
Secretariat.

2. Co-acceptance of Bills

2.1 Irregularities in Co-acceptance of Bills

(i) Banks have been co-accepting bills of their customers. On many

occasions these bills turn out to be accommodation bills drawn by groups of
sister concerns on each other where no genuine trade transaction takes
place. Such bills on maturity are not honoured by the drawees and the banks
which have co-accepted the bills have to make payment of these bills
and thereafter, they find it difficult to recover the amount from the drawers /
drawees of bills. This happens because the financial position and capacity of
the parties to honour the bills, in the event of need, is not gone into by the
banks co-accepting the bills.

(ii) There have also been cases where the particulars regarding co-
acceptance of bills are not recorded in the bank's books with the result that
the extent of co-acceptance cannot be verified during inspections and the
Head Office becomes aware of the co-acceptance only when a claim is
received from the discounting bank.

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 2.2 Safeguards

In view of the above, banks should keep in view the following safeguards:

(i) While sanctioning co-acceptance limits to their customers, the need

therefore should be ascertained and such limits should be extended only
to their customers enjoying other limits with the bank.

(ii) Only genuine trade bills should be co-accepted and the banks should
ensure that the goods covered by bills co-accepted are actually received
in the stock accounts of the borrowers.

(iii) The valuation of the goods as mentioned in the accompanying invoice

should also be verified to see that there is no over valuation of stocks.

(iv) The banks should not extend their co-acceptance to house bills /
accommodation bills drawn by group concerns on one another.

(v) The powers to co-accept bills, beyond a stipulated limit, must be exercised
by two authorised officials jointly.

(vi) Proper records of the bills co-accepted for each customer should be
maintained so that the commitments for each customer and the total
commitments at a branch can be readily ascertained and these should be
scrutinised by internal inspectors and commented upon in their reports.

(vii) Proper periodical returns may be prescribed so that the BranchManagers

report such co-acceptance commitments entered into by them to the
controlling offices. Such returns should also reveal the position of bills that
have become overdue and which the bank had to meet under the co-
acceptance obligation. This will enable the controlling offices to monitor
such co-acceptances furnished by the branches and take suitable action in
time, in difficult cases.

3. Letters of Credit (LCs)

3.1 Guidelines for Grant of LCs Facility

UCBs should not normally grant LC facilities in respect of parties who

maintain only nominal current accounts. In case of borrowers maintaining
only current accounts, who approach for opening of LCs, banks should
invariably ascertain from the existing bankers of the borrowers the reasons
as to why they are not extending LC facilities to the concerned borrowers.
Banks should open LCs in respect of such parties only after making proper
enquiries in regard to the antecedents of the borrowers from the bankers with
whom the parties are enjoying main limits, their financial position and their
ability to retire the bills. They should also prescribe a suitable margin and
obtain other security, as necessary.

8
3.2 LCs for Commodities covered under Selective Credit Controls

There is no restriction for the banks in opening LCs for import of essential
items. However, banks are not permitted to open inland LCs, providing a
clause therein which would enable other banks to discount usance bills under
the LCs.

3.3 Safeguards in Opening of LCs

Before opening LCs, banks should ensure that :

(i) LCs are issued in security forms only;

(ii) Large LCs are issued under two authorised signatures where one of the
signatures for LCs should be from the Head Office / Controlling Office.
As the need for large LCs may not arise overnight, with the availability
of courier service, speed post service etc., this procedure may not result
in delay. In the LCs itself a column may be provided to indicate the
authority who had sanctioned it together with the particulars thereof;

(iii) LCs are not issued for amounts out of proportion to the borrowers'
genuine requirements and these are opened only after ensuring that the
borrowers have made adequate arrangements for retiring the bills
received under LCs out of their own resources or from the existing
borrowing arrangements;

(iv) where LCs are for purchase of raw materials, borrowers do notmaintain
unduly high inventory of raw materials in relation to the norms / past
trends. Where such LCs are to be opened on D/A basis, credit on the
relative purchase is duly taken into account for the purpose of working
out drawing power in cash credit accounts;

(v) in the case of borrowers having banking arrangements on a consortium

basis, the LCs are opened within the sanctioned limit on the basis of the
agreed share of each of the banks. Member-banks should not, however,
open LCs outside the sanctioned limits without the knowledge of the lead
bank / other banks;

(vi) if there is no formal consortium arrangement for financing the borrower,

LCs should not be opened by the existing bank or a new bank, without
the knowledge of the other banks;

(vii) LCs for acquisition of capital goods should be opened only after banks
have satisfied themselves about tying up of funds for meeting the relative
liability by way of providing for long term funds or term loans from
financial institutions / banks;

(viii) In no case, working capital limits should be allowed to be utilised for

retiring bills pertaining to acquisition of capital assets.

9
(ix) Banks should not extend any non-fund based facilities or additional /
ad-hoc credit facilities to parties who are not their (the bank's) regular
constituents for their production finance requirements; nor should they
discount bills drawn under LCs or otherwise for beneficiaries who are not
their regular clients. In case it becomes unavoidably necessary to provide
such a facility to a party not being a regular client, banks should invariably
seek the prior concurrence of the existing banker of the borrowers and also
make proper enquiries in regard to the antecedents of the borrowers, their
financial position and ability to retire the bills etc. in time.

(x) With effect from March 30, 2012 in case of bills drawn under LCs
restricted to a particular UCB, and the beneficiary of the LC is not a borrower
who has been granted regular credit facility by that UCB, the UCB concerned
may, as per their discretion and based on their perception about the credit
worthiness of the LC issuing bank, negotiate such LCs, subject to the
condition that the proceeds will be remitted to the regular banker of the
beneficiary of the LC. However, the prohibition regarding negotiation of
unrestricted LCs for borrowers who have not been sanctioned regular credit
facilities will continue to be in force.

(xi) UCBs negotiating bills as above, under restricted LCs, would have to
adhere to the instructions of the Reserve Bank / RCS or CRCS regarding
share linking to borrowing and provisions of Co-operative Societies Act on
membership

3.4 Payment under LCs - Immediate Settlement of Claims

(i) There have been a few instances where LCs were opened by officials
of banks in an unauthorised manner. In certain cases, the LCs transactions
were not recorded in the books of the branch by officials issuing them, while
in some other cases the amounts of LCs were much in excess of the
powers vested in them for the purpose. Subsequently when the banks
come to know about the fraudulent issue of LCs, they disclaim liability on
the ground that these are transactions involving a conspiracy / collusion
between the beneficiary and the constituent.

(ii) It may be appreciated that if the bills drawn under LCs are not
honoured, it will adversely affect the character of LCs and the relative bills as
an accepted means of payment. This could also affect the credibility of the
entire payment mechanism through banks and affect the image of the banks.
It is, therefore, necessary that all the banks should honour their commitments
under LCs and make payments promptly leaving no opportunity for any
complaints in this regard. Needless to say that banks should take suitable
action against the concerned officials as well as the constituents on whose
behalf the LCs are opened and the beneficiaries of LCs, if a criminal
conspiracy is involved.

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4. Other Common Guidelines

4.1 Credit Exposure Norms and Statutory / Other Restrictions on Non-

fund Based Limits

(i) UCBs are required to strictly observe exposure norms and statutory /
other restrictions prescribed for non-fund based limits (e.g. LCs, Guarantees,
Co-acceptances, etc.) as detailed in the Master Circular on 'Exposure Norms
and Statutory / Other Restrictions and other norms issued by RBI from time
to time.

(ii) The exposure ceilings and other restrictions particularly prescribed for

a) total credit exposure including non-fund based limits,

b) unsecured guarantees,

c) advances to bank's Directors,

d) loans and advances to relatives of Directors,

e) advances to nominal members,

must be strictly observed.

4.2 Banks should ensure that the systems evolved for recording the details of
off-balance sheet transactions are properly followed by all branches. These
records should be periodically balanced and internal inspectors should verify
the same and offer critical comments.

4.3 Banks should ensure that unauthorised LCs are not issued.

4.4 Banks must lay down clear instructions for their branch staff in respect of
loan accounts where such non-funded facilities become funded on account of
devolvement of bills covered under the bank's LCs or due to invocation of
guarantees issued by the bank. The banks must evolve proper guidelines to
ensure that, accounts where non-funded limits become "funded" are closely
monitored and goods covered under devolved bills remain under bank's control
/ hypothecation, particularly where malafides are suspected. In cases of goods
covered under import LCs, banks must also ensure immediate submission of
custom's copy of the Bill of Entry and take measures as prescribed in the
guidelines issued by Foreign Exchange Department.

4.5 A number of banks adopt the practice of parking the dues of the borrower
in respect of devolved LCs and invoked guarantees in a separate account which
is not a regular sanctioned facility. As a result, these are not reflected in the
principal operating account of the borrower. This renders application of the
prudential norms for identification of NPAs difficult. It is, therefore, advised that
11
if the debts arising out of devolvement of LCs or invoked guarantees are parked
in a separate account, the balance outstanding in that account also should be
treated as a part of the borrower's principal operating account for the purpose of
application of prudential norms on income recognition, asset classification and
provisioning.

4.6 Banks are encouraged to strengthen their information back up about the
borrowers enjoying credit facilities from multiple banks by obtaining declaration
from the borrowers about the credit facilities already enjoyed by them from other
banks. In the case of existing lenders, all the banks may seek a declaration from
their existing borrowers availing sanctioned limits of Rs.5.00 crore and above or
wherever, it is in their knowledge that their borrowers are availing credit facilities
from other banks and introduce a system of exchange of information with other
banks. Subsequently banks should exchange information about the conduct of
the borrowers' accounts with other banks at least at quarterly intervals. Banks
should also make use of CRILC or credit reports available from Credit Information
Companies. The banks should incorporate suitable clauses in the loan
agreements regarding exchange of credit information so as to address
confidentiality issues. Banks should also obtain regular certification by a
professional, preferably a Company Secretary, Chartered Accountant or Cost
Accountant regarding compliance of various statutory prescriptions that are in
vogue. The formats for collecting information from the borrowers, exchange of
information among banks and certification by a professional are furnished in our
circular UBD.PCB.No.36/13.05.000/2008-09 dated January 21, 2009 read with
circular UBD.PCB.No.59/13.05.000/2008-09 dated April 9, 2009.

4.7 Banks are exposed to various risks in every financial transaction including
commitments in the form of Guarantees, Co-acceptances, LCs etc. The
managements of UCBs have to base their business decisions on sound risk
management systems with the ultimate objective of protecting the interest of
depositors and stakeholders. It is, therefore, important that UCBs adopt effective
Asset-Liability Management (ALM) systems to address the issues related to
liquidity, interest rate and currency risks. Banks should invariably follow the ALM
guidelines issued by Reserve Bank in this regard.

12
 Annex

A. List of Circulars consolidated in the Master Circular

No. Circular No. Date Subject

1 UBD.(PCB)BPD.Cir.No.29/13.05.000/2 30-03-2012 Discounting of Bills byUCBs
011-12 – RestrictedLetters of Credit

2 UBD.BSD-I/8/12.05.00/2000-2001 09-11-2000 Frauds - Preventive

Measures
3 UBD.No.Plan.PCB.CIR.07/09.27.00/ 21-09-1999 Bank Guarantees
99-2000
4 UBD.No.Plan.(PCB)49/09.27.00/96-97 26-04-1997 Payment under bank
guarantee - Immediate
settlement of cases
5 UBD.No.DS.(PCB)DIR.4/13.03.00/96- 16-07-1996 Selective Credit Control
97 - Advances against
Sensitive Commodities
6 UBD.No.I&L/PCB/9/12.05.00/95-96 01-09-1995 Payment under bank
guarantees - Immediate
settlement of cases
7 UBD.Plan.Cir.SUB.1/09.27.00/94-95 18-10-1994 Issue of guarantees -
Guidelines to be followed by
the primary (urban) co-
operative banks
8 UBD.No.DS.CIR.PCB15/13.03.00/94- 15-09-1994 Selective Credit
95 Controls - Imported Sugar
9 UBD.No.(PCB)CIR.79/13.03.00/93-94 26-05-1994 Selective Credit
Controls - Imported Sugar
10 UBD.No.Plan.42/09.27.00-93/94 16-12-1993 Bank guarantee - Delay in
obtaining certified copies of
Judgements
11 UBD.No.POT.1/UB.58-92/3 03-07-1992 Payment under LCs -
Immediate settlement of
claims
12 UBD.P&O.763/UB.58-83/84 28-02-1984 Issue of guarantees - Co-
acceptance of bills etc. by
the urban co- operative
banks

13
 B. List of Other Circulars from which instructions relating to Guarantees,
Co-acceptances and LCs have also been consolidated in the Master Circular

No. Circular No. Date Subject

1. UBD.PCB.No.59/13.05.000/20 09-04-2009 Lending under consortium
08-09 arrangement / multiple banking
arrangements

2. UBD.PCB.No.36/13.05.000/20 21-01-2009 Lending under consortium

08-09 arrangement/ multiple banking
arrangements

3 UBD.PCB.Cir.12 & 17-09-2008 ALM guidelines

13/12.05.001/2008-09
4. UBD.BSD.No.IP.30/12.05.05/2 26-12-2002 Master Circular - Prudential Norms
002-03 - Income Recognition, Asset
Classification, Provisioning and
other related matters
5. UBD.No.DS(PCB).Cir.54/13.05 29-04-1995 Maximum limit on advances
.00/94-95
6. UBD.No.(PCB)DIR.5/13- 26-05-1994 Maximum Limit on Advances
05.00/93-94
7. UBD.No.DS(PCB)Cir.76/13.05. 26-05-1994 Maximum limit on advances -
00/93-94 Advances to Directors and their
relatives and to concerns in which
Directors or their relatives are
Interested
8. UBD.21/12:15:00/93-94 21-09-1993 Committee to enquire into various
aspects relating to frauds and
malpractices in banks primary
(urban) co- operative banks
9. UBD.(DC).104/R.1-86/87 25-06-1987 Guidelines for Assessment of
Working Capital Requirements,
Opening of LCs and Issue of
Guarantees

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