Early Recognition of Financial Distress, Prompt Steps for Resolution and Fair Recovery for Lenders: Framework for Revitalising Distressed Assets in the Economy

Please refer to theFramework for Revitalising Distressed Assets in the Economy (Framework)issued by the Reserve Bank on January 30, 2014. The framework covered in the guidelines, which would be fully effective from April 1, 2014, has outlined a corrective action plan that will incentivize early identification of problem account, timely restructuring of accounts which are considered to be viable, and taking prompt steps by lenders for recovery or sale of unviable accounts. In the background of the above, to the extent it is applicable to NBFCs, the following guidelines are issued to NBFCs.

The Reserve Bank of India has set up a Central Repository of Information on Large Credits (CRILC) to collect, store, and disseminate credit data to lenders as advised by the Bank in its Circular dated February 13, 2014 issued by the Department of Banking Supervision. All systemically important non-banking financial companies (NBFC-ND-SI), NBFCs-D and all NBFC-Factors, (Notified NBFCs, for short) shall be required to report the relevant credit information on a quarterly basisto CRILC once the XBRL reporting mechanism is established.

For more detail, please refer to out circular on Early Recognition of Financial Distress, Prompt Steps for Resolution and Fair Recovery for Lenders: Framework for Revitalising Distressed Assets in the Economy CC no. DNBS (PD) CC.No.371/03.05.02/2013-14 dated March 21, 20104.

NBFCs will receive ID & password from xbrlhelpdesk@rbi.org.in on Email id provided by them. NBFCs has to login into the system by using the Url given in email provided by xbrlhelpdesk@rbi.org.in.

1. Click on the link :https://125.18.33.234/orfsxbrl/customer/index.jsp

2. If you are facing some website security certificate error then click on Continue to this website

3. Login into system with ID, password & Bank code received from xbrlhelpdesk@rbi.org.in

Please make sure you change the password and update your profile after login for first time.

4. To download the return format, please click on Download Return Package

Then select the return type (Please download both the return) FORM NBFC CRILCFORM NBFC CRILC SMA 2 JLF Formation

It will some time as file size is around 21.3 MB (CRILC) & 19.9 MB (SMA-2)After downloading the file, it will ask to install the file (2003/2007 version)Please make sure following pre-requisite software is present on your system before running RBI Template installer. (Check the attachment on Installer Pre requisites & Installation Guides)- Very Important.

After completing installation, RBI template will be created on your desktop.

If you encounter any problem while installation, please refer to our Installation Guide & FAQs or you can send email on xbrlhelpdesk@rbi.org.in - Very Imp

Click on the CRILC template created on desktop.

The CRILC window template will get open.

If the above window does not appear, please refer to our Installation Guide & FAQs or you can send email on xbrlhelpdesk@rbi.org.in - Very Imp

Institution type: NBFCBanking working code: enter the working code assign to you (refer to mail received from xbrl)Bank Name: Click on Get Bank name, If some error occur, Copy the name of Company from the Sheet given CRILC and paste in Bank Name. Very Imp ( do not type the company name in your style/format).Report status: Provisional/Final ( Provisional means you can modify it afterward)Reporting Ref Date: 30 June/30 Sept/31 Dec/31 MarchThe system will automatically load Pan Master Nic Master & Bank Master& Group Master.The system will load the taxonomy.If system does not load the data , the just click ok button.You will get the Name of Institution & Report date automatically.

Report status: Audited/UnauditedNil Reporting : Yes/No ( if NBFCs does not have exposure more than Rs 5 cr to any company/individual, they can report as No)General Remarks: for any comments

NBFCs are required to report CRILC: Quarterly Data/information on: Large exposures of size Rs 5 crore and above Non-cooperative borrowers SMA-2 : Daily/as and when basis data/information on: SMA 2 borrowers [to be reported immediately on classification of the borrowers as SMA 2] Formation of Joint Lenders Forum (JLF)

The Guidelines require NBFCs to furnish credit information to CRILC on their borrowers having aggregate fund-based and non-fund based exposure of Rs. 50 million and above with them (including investment exposure) and above with them and the SMA status of the borrower. NBFCs are also required to furnish details of all current accounts of their customers with outstanding balance (debit or credit) of Rs 10 million and above. Banks are required to furnish details of Amount technically/prudentially written Off - Outstanding in memo/shadow heads, etc, for all the borrowers whos exposure is reported by any of the lender banks. In order to capture early warning signals of financial distress faced by borrowers, the Framework requires banks to report, among others, the Special Mention Accounts (SMA) status of the borrower to the CRILC. The guidelines also require NBFCs to furnish report information on Non-cooperative borrowersApart from reporting exposure details on quarterly basis, NBFCs have also been reporting details of their Special Mention Accounts-2 (SMA-2) on real time basis to CRILC. SMA-2 accounts are those where repayment of principal and or interest is due between 61-180 days. When a NBFCs reports a borrower as SMA-2 to CRILC, the system sends an auto flash to all other banks which are exposed to the account in order to enable banks to take actions as envisaged in the framework viz. forming Joint Lenders Forum (JLF) and finalising appropriate Corrective Action Plan (CAP) to deal with the emerging distress. Information on formation of JLFs are captured on as and when basis. Currently, there is no system of reporting change in status of accounts reported earlier as SMA-2 to CRILC.CRILC-Main (Quarterly Submission): This return comprises of four sections i.e. Section 1: Exposure to Large Borrowers ,Section 2 - Reporting of Technically/Prudentially Written-off Accounts ,Section 3 - Reporting of Balance in Current Account and Section 4: Reporting of Non cooperative Borrowers . All sections has to be reported together and reporting reference date has to be quarter ended date (June-30/Sept-30/Dec 31/March 31). Report status should be Provisional or Final as the case may be. Reporting currency should be Indian Rupees and reporting unit is lakhSection 1: Exposure to Large BorrowersThis section captures data in following 51 data fields.Capital Funds of the Bank (NBFCs): ( Rs in Lakh)Regulatory Capital (Tier-I and Tier-II Capital) of previous March:Capital Infusion during the period (April to date):Note: The regulatory capital as per extant guidelines on capital adequacy

1. PAN NumberPermanent Account Number (PAN) allotted by Income Tax Authorities as the unique identification string to ascertain borrower uniqueness. Existing Borrowers PAN Master can be downloaded from the XBRL portal and it contains all the PAN details of borrowers reported by the Bank & NBFCs.

Double Click on green cell to get the Pan Number Pop up. Then select the Pan Number of customer you want to add.

To add PAN details of new borrower, banks have to submit PAN details (either by bulk upload or single borrower) using an on-line form/system. The correctness of new PANs reported by banks is checked by the server by verifying from NSDL database and correct PAN will be added to PAN Master and bank will receive system generated mail with status of verification. In case of rejected PANs bank has to resubmit the correct details. Borrower name will populated automatically by selecting the PAN of borrower and vice-versa. In case of Proprietary firm, proprietors PAN and name to be reported and exposures will be reported in proprietors name.Currently system of adding the PAN details is not available for NBFCs.2. Borrower/Customer Name: This field is master based has one to one link with PANs of borrower as explained above. 3. Group CodeDouble Click on green cell to get the Borrower Group code Pop-up. Then select the Borrower Group code.

These fields are master based and approved group master can be downloaded from the XBRL portal. To add any new group bank has to upload the details in the portal and new group will be added to master after approval from Department of Banking supervision. While uploading new group bank has to ensure - Group Name should contain the word 'Group' as part of the name (e.g., ABC Group, XYZ Group, etc.) Group Master is maintained at RBI to ensure unique name of the group borrower across the system. The groups are not linked to the individual borrowers/PANs. Banks have to report the individual borrowers under a group as per their records maintained for group exposure monitoring. Individual borrower companies, which does not belong to any group should be reported under "Not belonging to any Group" with group code "Z9999" Under "Individual Companies under the Group", banks must give more than one companies names belonging to the group, irrespective whether the bank has exposure to these companies or not, to ensure that individual borrowers are not being added as a distinct group.Currently system of adding the Group Code is not available for NBFCs.4. Group NameThis field is master based has one to one link with Group Code of borrower as explained above5. Industry CodeDouble Click on green cell to get the Industry Code code Pop-up. The select the Borrower Industry Code

These fields are to be selected from pre-defined master and included in the Return upload package. (Master can be obtained by downloading return upload package from the portal). Borrower has to be classified under one of the industry based on the nature of the business and incase borrower has availed multiple facility different industry; industry of largest exposure should be selected. 6. Industry Name:This field is master based has one to one link with Industry Code of borrower as explained above

7. Sector CodeData for this field (private, Joint, Public-state Government etc) is to be selected from the pre-defied master (Master can be obtained by downloading return upload package from the portal).

8. Banking Arrangement: Data for this field (Sole, Multiple Arrangement, Consortium etc) is to be selected from the pre-defined master, based on type of arrangement.

9. Lead Bank Name: Data in this field required in case banking arrangement is Consortium (In case of option for banking arrangement is 3-Consortium 5-Sole and Consortium, 6-Multiple Arrangement and Consortium, 7-Sole; Consortium and Multiple Arrangement)10. Internal Rating: This filed refers to banks internal rating on borrowers credit worthiness. This data is to be entered as per banks internal rating. Composite rating of the borrowers should be reported. No comments or remarks should be added (i.e., only rating should be reported). In case the borrower is NOT rated, report 'UNRATED'

11. External Rating: This filed refers to banks internal rating on borrowers credit worthiness as assessed by external rating agencies like CRISIL etc. The rating used by the bank for capital adequacy compilation as per extant RBI guidelines on capital adequacy. No comments or remarks should be added (i.e., only rating should be reported).In case the borrower is NOT rated, report 'UNRATED'

12. Assets Classification: This field refers to asset classification as per the extent RBI Circular on Prudential norms on Income Recognition, Asset Classification and Provisioning pertaining to Advances. Data is to be selected from the pre-defined master.

13. Borrower Classified as Fraud/Wilful Default: Data is to be selected from the pre-defined master, as per the extent RBI Circular on Wilful Defaulters.

14. Special Mention Accounts(SMA):This field refers to SMA classification as per para 2.1 of Frame work on Stressed assets (SMA-0, SMA-1, SMA-2 and NA). This field applicable only if Assets Classification is Standard., SMA-0 [Principal or interest payment not overdue for more than 30 days but account showing signs of incipient stress], SMA-1 [Principal or interest payment overdue between 31-60 days], SMA-2 [Principal or interest payment overdue between 61-180 days], and Regular. In case of multiple overdues, worst overdue position should be reported.

15. In case SMA - O under SMA, the reasons thereof:This field is applicable only if SMA classification is SMA-0. Data is based on pre-deified master.

16. Fund based Exposure details

Limit Sanctioned Funded: This filed refers to total limit sanctioned for the borrower i.e aggregate of limit sanctioned for all fund based lending.

Amount Outstanding Funded: Facility wise amount outstanding as on date of reporting i. e Cash Credit/ Overdraft, Working Capital , Demand Loan, Inland Bills, Packing Credit ,Export Bills, Term Loan and Bills discounted in respect of sales on deferred payment basis. Other Funded Outstanding.

Total Funded Outstanding: Total of facility wise funded amount outstanding as on date of reporting and it is calculated field

Amount Eligible for netting from Funded Exposure: Amount that is eligible for netting from the funded exposure as per as per the extent RBI Circular on Prudential norms on Income Recognition, Asset Classification and Provisioning pertaining to Advances.

Funded Credit Exposure: Funded Credit Exposure should be equal or more than MINIMUM of (Funded Limit Sanctioned MINUS Amount Eligible for netting from Funded Exposure)Or(Total Funded Outstanding MINUS Amount Eligible for netting from Funded Exposure)

17. Non- Fund based Exposure details Limit Sanctioned Non Funded: This filed refers to total limit sanctioned for the borrower i.e aggregate of limit sanctioned for all non fund based lending.

Amount Outstanding Non Funded: Facility wise amount outstanding as on date of reporting i.e Letter of Credit, Guarantees,Acceptances, Foreign Exchange Contracts,Interest Rate Derivatives (incl FX Interest Rate Derivatives),Other Non-Funded Outstanding,

Total Non Funded Outstanding: Total of facility wise non-funded amount outstanding as on date of reporting and it is calculated field

Amount Eligible for netting from Non Funded Exposure: Amount that is eligible for netting from the non-funded exposure as per as per the extent RBI Circular on Prudential norms on Income Recognition, Asset Classification and Provisioning pertaining to Advances.

Non Funded Credit Exposure: Non-Funded Credit Exposure should be equal or more than MINIMUM of (Non-Funded Limit Sanctioned MINUS Amount Eligible for netting from Non-Funded Exposure)Or(Total Non-Funded Outstanding MINUS Amount Eligible for netting from Non-Funded Exposure)

18. Investment Exposure detailsTotal Investment Exposure: Investments in bonds/debentures issued by the borrower/obligor.

19. Other Calculated/derived data fields (calculated automatically) Total Limit Sanctioned to the Borrower: Sum of limit sanctioned funded and limit sanctioned non-funded.

Total Amount Outstanding (Funded + Non Funded): Sum of amount outstanding funded and amount outstanding non funded

Total Credit Exposure (TCE): Sum of funded credit exposure and non-funded credit exposure.

TCE as % of Capital Funds: Total credit exposure as % of capital fund (Regulatory capital up to March of previous year + capital infusion from April to date).

Total Exposure (TE): Sum of Total Credit Exposure and Total Investment Exposure.

TE as % of Capital Funds: Total exposure as % of capital fund (Regulatory capital up to March of previous year + capital infusion from April to date).

20. Miscellaneous fields

Of TE, Exposure through Overseas' Branches of Indian Banks: Out of total exposure, exposure of borrower (Indian or Overseas) has taken exposure(s) only from Overseas branch (es) of Indian bank.

Date from which Restructuring Scheme became effective, if any of the facility is restructured (DD/MM/YYYY): This detail to be given only for restructured accounts

Total Provisions Held For NPAs: This details of be given only for NPA accounts Of the Total Amount Outstanding (Funded and Non-Funded), Unsecured Amount Outstanding: Unsecured outstanding amount to be given.

Balance in Current Account: Balance in Current Account if any irrespective of debit (-)/credit (+) balance, should be reported.

Amount technically/prudentially Written Off - Outstanding in memo/shadow heads, etc: This includes technical/prudential write-offs, advances under collection account (AUCA), etc.

Date When Prudentially / Technically Written Off (DD/MM/YYYY): Date to be provided if any amount is entered in Amount technically/ prudentially Written Off - Outstanding in memo/shadow heads, etc.

To add the row:

Click on Add- ins, the click on iFile, then click on add row below

To delete the row, click on delete selected row

For Bulk Uploading of data, Use CRILC excel file , keying that required data then save the file.After that Click On Map RLC Excel to upload the file in CRILC.If there is error in uploading, please use add row below

Section 2 - Reporting of Technically/Prudentially Written-off AccountsThis section comprises 8 data fields and borrower whos exposure data is captured in Section 1: Exposure to Large Borrowers should not be repeated. (Related data is included in Section 1) PAN Number: As explained in Section 1: Exposure to Large Borrowers Borrower/Customer Name As explained in Section 1: Exposure to Large Borrowers Borrower Group Code: As explained in Section 1: Exposure to Large Borrowers Group Name: As explained in Section 1: Exposure to Large Borrowers Industry Code: As explained in Section 1: Exposure to Large Borrowers Industry Name: As explained in Section 1: Exposure to Large Borrowers Amount technically/prudentially Written Off - Outstanding in memo/shadow heads, etc As explained in Section 1: Exposure to Large Borrowers Date When Prudentially / Technically Written Off (DD/MM/YYYY): As explained in Section 1: Exposure to Large Borrowers

Section 3 - Reporting of Balance in Current Account:This section comprises 3 data fields and borrower whos exposure data is captured in Section 1: Exposure to Large Borrowers (Global Operations) should not be repeated. (Related data is included in Section 1).

Borrowers Current Account balance with more than 1.00 Crore should be reported irrespective of Debit Balance (-)/Credit Balance (+).

PAN Number: As explained in Section 1: Exposure to Large Borrowers Customer Name: As explained in Section 1: Exposure to Large Borrowers (Balance in Current Account: As explained in Section 1: Exposure to Large Borrowers.

Section 4: Reporting of Non cooperative BorrowersFor definitions of Non cooperative Borrowers please refer to our circular on Early Recognition of Financial Distress, Prompt Steps for Resolution and Fair Recovery for Lenders: Framework for Revitalising Distressed Assets in the EconomyCircular No. DNBS (PD) CC.No.371/03.05.02/2013-14 dated March 21, 2014This section comprises 8 data fields. PAN Borrower: As explained in Section 1: Exposure to Large Borrowers Borrower Name: As explained in Section 1: Exposure to Large Borrowers. Total Exposure: As explained in Section 1: Exposure to Large Borrowers. If same borrower is reported in Section 1, then amount under this column should match with corresponding amount in section 1. Total Amount Outstanding (Funded + Non Funded): As explained in Section 1: Exposure to Large Borrowers. If same borrower is reported in Section 1, then amount under this column should match with corresponding amount in section 1. Reasons for Categorising as Non - Cooperative Borrower: This field is pre-defied master based. By selecting other, any other reason (which is not pre-defined) can be entered. Full Name of Directors/ Partners/ Sole Proprietor: Minimum of one name is mandatory for each non-cooperative borrower. Director Identification Number. It is an unique Identification Number (Eight digit) allotted to an individual who is an existing director of a company or intends to be appointed as director of a company pursuant to section 266A & 266B of the Companies Act, 1956. This field is not mandatory. Status: This field is pre-defied master based. Details director such as Full Time, Non-executive, Independent, Govt. Nominee, etc is to be provided. This data is must against each Director Name.

Authorised SignatoryName

Designation

Mobile No.

Landline No.

E-mail Id

Please enter the name, designation, mob no, Land line no, Email id of person who is authorised to upload the document. After that you have to run the file.

To run the file click on Generate Instance Document. First click on Add-Ins, then iFile, then click on Generate Instance Document

Then system will run the file it will take some time depending upon the amount of data.

If there is no error while running the file, the system will prompt you to save the file as xml file. If there is error, the system will prompt to correct the error then only you can run the sheet.

It will ask to encrypt the file, then select the mode of encryption as encryption, the save the file.

To upload the file in CRILC. Log into the system. To upload returns, click on Upload ReturnsSelect reporting date and then report statusThen upload encrypted instance document,

Signed Using: Click on Symmetric EncryptionThen Click on upload button.After uploading the document, the system will report as Instance document has been uploaded successfully.To check the status of return, click on publish filingsThen select date, the click on return.

SMA-2 ReturnDownload the SMA-2 return & install return,

Click on Reporting of SMA 2 & or JLF.CRILC-SMA 2 and JLF Formation (Submission on 'as and when' basis): There will be two sections in this return which are to be submitted on as and when basis, i.e. whenever a large borrower's account becomes overdue for 61 days and/or a Joint Lenders Forum (JLF) is formed in respect of a SMA 2 classified borrower.General Information: Following general information is to be providedBank Code : Bank code as per Banks working code:Name of the Reporting Institution: Name of the reporting bank/AFI/Insurance companies.Reference Date of Return: Date for the reference of the return (Date of SMA2- data compilation)Reporting of SMA2 and/or JLF: One of the options from SMA2/Formation of JLF/Both are to be selected based on reporting. On selecting SMA2, Section 2 Formation of JLF will be inactive /hidden and on selecting Formation of JLF Section -1 SMA2 will be inactive /hidden. To be selected based on type of data to be reported.General Remarks: Any additional information can be added using a text box in this field.SMA2 Reporting: Section 1

PAN: PAN of borrower is to be provided as explained in CRILC-Main, Section 1: Exposure to Large Borrowers.Borrower Name: Name of borrower is to be provided as explained in CRILC-Main, Section 1: Exposure to Large Borrowers .Date when the Borrower Classified as SMA-2 (DD/MM/YYYY): Date when repayment of principal and or interest is overdue for 61 days.Amount Outstanding (Funded + Non-funded) when the Borrower Classified as SMA-2: Total outstanding amount (All facility clubbed together in case of multiple facilities) as on date of classifying as SMA2.Secured Amount (as per latest valuation): Total secured amount is to be provided (aggregate secured amount in case of multiple securities)Type of Security: This field is pre-defied master based. Type of security such Mortgage /Pledge / Hypothecation/ Government Guarantee is to be selected. By selecting other, any other type of security (which is not pre-defined) can be entered.Whether the Borrower was classified as SMA-1 during the past one year (Y/N) : To Be provided as per NBFCs records.If 'Y' for the column 'F', then dates (at most three dates) (dd/mm/yyyy) : To Be provided as per banks records.Remarks (up to 100 characters): In case bank wants to provide any additional information, same may be provided.SMA2 Reporting: JLF Formation: PAN: PAN of borrower is to be provided as explained in CRILC-Main, Section 1: Exposure to Large Borrowers. Borrower Name: Name of borrower is to be provided as explained in CRILC-Main, Section 1: Exposure to Large Borrowers. Date when the JLF was formed (DD/MM/YYYY): The date when all the members of the JLF have signed the agreement. Type of the JLF Member (Bank, FI, NBFC, Other): This field is pre-defied master based and Type of JLF member such as Bank/FI/NBFC/Others etc to be selected. Name of the JLF Members: All Names of the JLF members is to be given.(to be reported in multiple rows). Remarks: In case bank desires to provide any additional information, same can be added.

Authorised Signatory: Signatory information such Name, Designation, Mobile No., Landline No. E-mail Id etc are to be given in the sheet provided for the sameTo run the document,Click on Add ins, the click on iFile, then click on generate instance documentIf there is no error while running the file, the system will prompt you to save the file as xml fileTo upload the file in CRILC. Log into the system. To upload returns, click on Upload Returns as SMA-2Select reporting date, then report statusThen upload encrypted instance document,To check the status of return, click on publish filingsThen select date, the click on return.

Clarifications /precaution on various issues in CRILC-Main

1. Addition of new borrower PAN in the PAN Master: PANs may be rejected by the PAN verification module even if 'Borrower Name as per NSDL' and 'Borrower Name as per Bank' are apparently same because of space(s) between words/ full form or short form of the name, etc. In such cases, banks may re-submit PAN details copying the names (from the system generated PAN verification alert) provided in the column 'Borrower Name as per NSDL' (For copy-paste, please always use paste special => values).

2. Industry Classification: Incase borrower has multiple facilities with the bank, industry classification should be done based on largest facility. Industry classification Others to be used sparingly only in case of borrowers belongs to industry which is not listed in the master.

3.Limit Funded and Non Funded: In case, there is no distinct limit for funded & non-funded exposures and/or there is common limit for funded/non-funded exposures, the limit to be reported should be the maximum amount that can be availed by the borrower under funded facilities and/or non-funded facilities (typical example: Limit-Total=Rs.100, Limit-Funded=Rs.X, Limit-Non-Funded=Rs100-Rs.X).

4. Exempted Exposure reporting: a. Banks need not report their interbank exposures to CRILC including exposures to NABARD, SIDBI, EXIM Bank and NHB.b. Crop loans are exempted from such reporting. However, banks should report their other agriculture loans in terms of the above instruction

Clarifications /precaution on various issues in CRILC-SMA2/JLF Formation

1. JLF formation should be reported only by theconvener of JLF and not by other member banks.2. The SMA2 reporting is as and when basis, so, a borrower classified as SMA2 on a particular date shouldbe reported only once on the same day or next day. Repeated reporting of SMA2 status of a borrower would be required only if the borrower had got upgraded. 3. SMA2 classification is for the borrower and not account-wise. Incase borrower is classified as SMA2 on the basis of one account and if another account also over due for more than 60 days, reporting of SMA2 again for the same borrower is required only if earlier SMA2 classified account has been upgraded.4. JLF is to be formed within the 45 days from the (i ) the date of an account being reported as SMA-2 by one or more lender, or (ii) receipt of request from the borrower to form a JLF, with substantiated grounds, if it senses imminent stress.5. Banks are permitted to report their SMA-2 accounts and JLF formations on a weekly basis at the close of business on every Friday. If Friday happens to be a holiday, they will report the same on the preceding working day of the week. Incase bank desires to report before to reporting Friday; banks are permitted to do so to avoid accumulation of large number of SMA2 reporting for the last day.

Commonly observed problems/ mistakes in reporting CRILC-Main and CRILC-SMA2/JLF formation.CRILC-Main1. In Sec-1, Industry classification Others option to be used sparingly and it is observed more than 15 % borrowers accounts are classified as Others. In some occasions some well known borrowers are classified under Others.2. In Sec 3 balance in Current Account banks are reporting in actual instead in Rs. Lakh.3. Banks are changing the formatting /comments in the installer/excel file for importing data. This may happen due to cut and paste of data from other files. Banks are advised to use paste special => values, for copy-paste.4. While uploading banks have to use same option for Provisional /Final which has been captured while initiating the installer template.5. Before reporting banks should ensure PAN of the borrower is available in the RBI PAN Master to avoid validation failure at server level.CRILC-SMA2/JLF Formation.1. Banks are reporting SMA 2 status of the borrower with considerable delay. Delayed reporting of SMA2 may not serve the intended purpose.2. Banks are advised to have robust MIS system in place to avoid wrong reporting of SMA2 borrowers. Banks are responsible to wrong reporting of SMA2 classified borrowers.