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Non-Banking Financial Companies (NBFCs) | BBA DAVV Notes

Study material and explanations for Unit 3

Non-Banking Financial Companies (NBFCs)

Traditional commercial banks often have rigid documentation requirements, strict credit scores, and lengthy loan approval cycles. As a result, millions of small truck operators, rural farmers buying second-hand tractors, and urban street vendors cannot obtain bank credit. Non-Banking Financial Companies (NBFCs) fill this vital economic space through fast, flexible, and customized financing.


1. What is an NBFC?

A Non-Banking Financial Company (NBFC) is a company registered under the Companies Act, 1956/2013 and regulated by the Reserve Bank of India under the RBI Act, 1934 (Chapter III-B). It engages in the business of loans and advances, acquisition of shares/stocks/bonds, leasing, hire-purchase, insurance, or chit business.

The Principal Business Test (50-50 Rule)

An entity qualifies as an NBFC only if its financial assets constitute more than 50 percent of its total assets, and income from financial assets constitutes more than 50 percent of its gross income.


2. Core Differences: Commercial Banks vs NBFCs

This is one of the most frequently asked questions in university exams:

Basis of Distinction Commercial Banks Non-Banking Financial Companies (NBFCs)
Incorporation Under Banking Regulation Act, 1949 Under Companies Act, 1956/2013
Demand Deposits Can accept demand deposits (Savings & Current accounts) Cannot accept demand deposits (can only accept term deposits if licensed)
Cheque Book Facility Forms part of the payment & settlement system; can issue cheques on themselves Cannot issue cheques drawn on themselves; not part of payment clearance
Deposit Insurance Depositor funds insured up to Rs. 5 lakhs by DICGC No DICGC insurance cover available for NBFC deposits
Cash Reserve Ratio (CRR) Mandatory maintenance of CRR with RBI Not required to maintain CRR
Regulatory Supervision Directly supervised with high compliance overhead Supervised under RBI’s Scale-Based Regulation framework

3. Classification of NBFCs

NBFCs are classified based on liabilities, systemic importance, and activities:

                  ┌───────────────────────────────────────────────┐
                  │              NBFC CLASSIFICATION              │
                  └───────────────┬───────────────────────────────┘
                                  │
                 ┌────────────────┴────────────────┐
                 ▼                                 ▼
      [ BY LIABILITY TYPE ]              [ BY ACTIVITY TYPE ]
      • Deposit-Taking (NBFC-D)           • Investment & Credit Co (ICC)
      • Non-Deposit Taking (NBFC-ND)      • Infrastructure Finance (IFC)
      • Systemically Important (ND-SI)    • Microfinance Institutions (MFI)
        (Asset size >= Rs. 500 crores)    • Housing Finance Cos (HFC)
                                          • NBFC-Factors

Modern RBI Scale-Based Regulation (SBR) Framework

In 2021, the RBI introduced a four-tier Scale-Based Regulation based on size, leverage, and interconnectedness to prevent systemic crises:

  1. Base Layer (NBFC-BL): Non-deposit taking NBFCs with asset size below Rs. 1,000 crores, peer-to-peer (P2P) lending platforms, and account aggregators. Lightest regulatory burden.
  2. Middle Layer (NBFC-ML): Deposit-taking NBFCs irrespective of asset size, and non-deposit NBFCs with asset size of Rs. 1,000 crores and above. Subject to stricter capital adequacy and corporate governance.
  3. Upper Layer (NBFC-UL): The top 15 to 20 systemically significant NBFCs identified by RBI based on quantitative scoring (e.g., Bajaj Finance, Tata Capital, Cholamandalam). Governed by bank-like prudential norms and mandatory stock listing timelines.
  4. Top Layer (NBFC-TL): Reserved by RBI for extreme risk; currently kept vacant, to be populated if an upper-layer NBFC creates systemic instability.

4. Major Specialized Types of NBFCs in India

  1. Investment and Credit Company (ICC): Financing commercial activity through loans/advances and acquiring corporate securities (e.g., Bajaj Finance, Shriram Finance).
  2. Infrastructure Finance Company (IFC): Deploys at least 75 percent of its total assets in infrastructure loans (e.g., Power Finance Corporation - PFC, REC Limited).
  3. Micro Finance Institutions (NBFC-MFI): Provides collateral-free microloans to low-income rural and urban households up to specified annual income thresholds.
  4. Housing Finance Companies (HFC): Principal business is financing the purchase and construction of residential plots and homes (e.g., LIC Housing Finance, PNB Housing). Regulated by RBI.
  5. NBFC-Factor: Principal business involves acquiring trade receivables and discounting commercial invoices under the Factoring Regulation Act.

5. Role of NBFCs in Economic Development

  1. Last-Mile Financial Delivery: Extends credit into remote rural, semi-urban, and unorganized trading clusters where traditional bank branches do not exist.
  2. Financing MSMEs & Small Entrepreneurs: NBFCs rely on innovative cash-flow assessments and localized relationship models rather than rigid collateral rules.
  3. Automobile & Commercial Vehicle Boom: Over 70 percent of second-hand trucks, commercial three-wheelers, and tractors in India are funded by NBFCs (Shriram Finance, Mahindra Finance).
  4. Consumer Durable Financing: Point-of-sale no-cost EMIs for smartphones, laptops, and refrigerators (e.g., Bajaj Finserv EMI cards) have transformed Indian retail consumption.
  5. Infrastructure Development: Institutions like PFC, REC, and IRFC finance electric power grids, renewable solar parks, and railway rolling stock.

6. Regulatory Reforms & Lessons from the IL&FS Crisis

In 2018, the sudden default of Infrastructure Leasing & Financial Services (IL&FS) exposed severe Asset-Liability Mismatch (ALM) in the NBFC sector:

  • NBFCs had borrowed short-term money (Commercial Paper of 3 to 6 months) and invested it in long-term infrastructure projects (10 to 15 years).
  • When short-term paper could not be rolled over, a liquidity freeze struck the market.
  • RBI’s Corrective Actions: Mandated the maintenance of a Liquidity Coverage Ratio (LCR), tighter loan concentration limits, appointment of Chief Risk Officers (CRO), and rigorous PCA (Prompt Corrective Action) frameworks for large NBFCs.

7. Summary for BBA Exams

  • NBFCs are registered under the Companies Act and governed by RBI Act (Chapter III-B).
  • Key differences from banks: Cannot accept demand deposits (savings/current), cannot issue cheques drawn on themselves, no DICGC insurance.
  • 50-50 Principal Business Test: 50% assets and 50% income must be financial.
  • Modern RBI framework: Scale-Based Regulation (Base, Middle, Upper, Top Layers).
  • NBFCs drive economic growth via last-mile vehicle finance, MSME credit, and consumer EMIs.