Resolution Framework on COVID19 related stress 2.0

FAQ on MSME Restructuring

FAQ on MSME Restructuring

1. Whether this Restructuring is applicable to all MSME borrowers?

No, MSME borrowers who are standard as on March 31, 2021 and only if the aggregate exposure of such borrowers is not more than Rs 50 crore from the entire banking system can avail this facility. Further, the unit should be GST registered unit and registration in Udyam portal with correct NIC code is compulsory.

2. My unit is an MSME unit and is coming under the exempted category for GST registration, whether my account is eligible for restructuring without GST registration?

Yes, if your account is in the exempted category and is classified as MSME, your account is eligible for restructuring under this scheme. This shall be determined on the basis of exemption limit obtaining as on March 31, 2021.

3. How I have to apply for the availing such benefits?

You can provide an application to your parent branch with required documents for processing of the file.

4. Is it my right to get my accounts restructured as per RBI’s scheme?

You have the right to apply for restructuring of your loans availed from the bank. But it is Bank’s sole discretion to decide on whether the same is to be allowed or not. The decision of the Bank in this case will be based on the commercial viability of the unit and the proposal submitted by you.

5. If I am giving a plain paper application without any further documents, will the same be considered as request for restructuring and whether invocation will be given in that basis?

Invocation will be provided based on the plain paper application submitted by you. But further submission of documents as required by the bank should be completed within 5 days from the date of your application. Non submission of required data/documents by you within the above stipulated time line will be considered as enough reason for declining your request.

6. Whether the classification of MSME is based on new definition of MSME?

Yes, an account is treated as MSME based on the new definition of MSME in terms of the Gazette Notification S.O. 2119 (E) dated June 26, 2020.

7. Whether my account will be downgraded to NPA upon restructuring of my loans.

No, as a one-time measure, your account will not be classified as NPA upon restructuring under this scheme.

8. My account is already restructured under RBI MSME restructuring circular (DOR.No.BP.BC/4/21.04.048/2020-21 dated August 6, 2020; DOR.No.BP.BC.34/21.04.048/2019-20 dated February 11, 2020;  DBR.No.BP.BC.18/21.04.048/2018-19 dated January 1, 2019 or circular DOR.No.BP.BC/3/21.04.048/2020-21 dated August 6, 2020). Whether I am eligible for restructuring under the present scheme.

No, the accounts which are already restructured in terms of the aforesaid circulars, are not eligible for further restructuring. But reassessment of working capital facilities, reassessment of drawing power etc. can be undertaken by the bank.

9. Whether there will be any processing fees/other charges upon restructuring?

Yes, there will be processing charges that will be charged by the bank on a case to case basis. The Rate of Interest also will be fixed at the time of restructuring based on the risk assessment of the borrower.

10.  What is Invocation of restructuring? If restructuring in my account is invoked, whether it is definite that I will get the restructuring done?

The restructuring shall be treated as invoked when the lending institution and the borrower agree to proceed with the efforts towards finalising a restructuring plan to be implemented in respect of such borrower.

It is not necessary that the restructuring will be sanctioned/allowed by the bank if invocation is done. As, invocation is done based on the basic eligibility and the restructuring package will be allowed based on the commercial viability of the proposal. Thus, invocation is just a nod from the Bank that the Bank will be looking into the commercial viability of the proposal and if found eligible for restructuring, the same may be considered.

11. Is there any last date for application for such restructuring?

The borrower has to give an application to the bank on or before September 15, 2021 with full set of documents required by the bank for processing of such proposals. Any application after the mentioned date will be considered for invocation on the sole discretion of the bank. Further, no application will be invoked after September 30, 2021 in any case.

12. Will opting for the restructuring package have an impact on my credit bureau report?

As per regulatory guidelines, your loan/credit facility will be reported to the credit bureau as “Restructured”. 

Please note that as per regulatory guidelines, restructuring has to be reported at a borrower level to the credit bureaus and hence all the facilities / loans of the borrower with the bank will be classified and reported as “Restructured” even if the borrower has taken restructuring for only one loan

 

13. What is implementation of Restructuring?

A restructuring package will be considered as implemented only if;

  • All documentation is completed/security perfection etc. is completed.
  • All the changed terms and conditions are effected in the books of the bank and the borrower.

Such implementation has to be completed within 90 days from the date of invocation failing which the restructuring package will become invalid and cannot be availed further.

 

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