Compliance Under FEMA & RBI for September 2020

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CS Lalit Rajput
CS Lalit Rajput
Company Secretary having 5 years of post-qualification experience in the Compliance Management Services industry by serving Corporates including Listed Companies, Corporate Secretarial Firms, and LLP.

Dear Reader!

This article contains various Compliance requirements under RBI and FEMA. Compliance means “adhering to rules and regulations.” Compliance is a continuous process of following laws, policies, and regulations, rules to meet all the necessary governance requirements without any failure.


Applicable Laws/Acts


Due Dates


Compliance Particulars


Forms / (Filing mode)







(last extended)

Annual Return on Foreign Liabilities and assets

The FLA return is required to be submitted by the companies who have received Foreign direct investment (FDI) and/or made Foreign direct investment abroad in the previous year(s) including the current year



FLA Return







Monthly Basis

External Commercial Borrowings

Borrowers are required to report all ECB transactions to the RBI on a monthly basis through an AD Category – I Bank in the form of ‘ECB 2 Return’.

ECB 2 Return




Not later than 30 days from the date of issue of Capital instrument

FC-GPR is a form filed when the Indian company receives the Foreign Direct Investment and the company allots shares to a person resident outside India. Form FC-GPR




With in 60 days of receipt/ remittance of funds or transfer of capital instruments whichever is earlier. Reporting of transfer of shares and other eligible securities between residents and non-residents and vice- versa is to be made in Form FC-TRS.

The onus of reporting shall be on the resident transferor/ transferee.




Form FC-TRS.




within 30 days from the date of receipt of the amount of consideration. A Limited Liability Partnership receiving amount of consideration and acquisition of profit shares is required to submit a report in the Form FDI LLP-1  






within 60 days from the date of receipt of funds in A Limited liability Partnership shall report disinvestment/ transfer of capital contribution or profit share between a resident and a non resident (or vice versa)  




within 30 days from the date of allotment of capital instruments The domestic custodian shall report the issue/ transfer/ of sponsored/ unsponsored depository receipts Downstream statement -Form DI

Compliances under FEMA / RBI

Important Updates:

Procedure for revision of current year FLA return:

The reporting entity need to take approval from RBI in case of revision of duly submitted current year FLA return. Visit → Login to FLAIR → Click “Please click here to get the approval to fill revised FLA form for current year” → select “Year” → Click “Request”. After sending request to RBI through FLA portal, entities need to wait for at least one working day for approval. Entities can check the status of their request in “Multiple Year Enable Screen” under menu on the left corner. Once approved by RBI, the entity can revise FLA return for current year.

RBI monetary policy key highlights

  • No change in repo rate, economic growth to contract in first half of fiscal year
  • the Reserve Bank of India has already reduced the repo rate by a total of 115 basis points.
  • the Reserve Bank of India (RBI) has decided to keep the repo rate unchanged at 4%
  • The central bank also allowed lenders to restructure corporate and MSME loans as well as raised the limit of loans that can be availed against gold ornaments and jewellery.
  • additional liquidity of Rs 10,000 crore at repo rate to NABARD and NHB
  • the RBI allowed stressed MSME borrowers to restructure debt if their loans were classified as ‘standard’ as on 1 March 2020.
  • the RBI has increased the permissible loan to value ratio (LTV) for loans sanctioned against pledge of gold ornaments and jewellery for non-agricultural purposes from 75 per cent to 90 per cent till 31 March 2021
  • RBI Circulars / Notifications: (01.08.2020 to 31.08.2020)
 S. N.  Particulars of the Circulars  Link
1 System-based asset classification – UCBs Click here
2 Reserve Bank announces constitution of an Expert Committee Click here
3 Foreign Exchange Turnover Data: June 29 – July 03, 2020 Click Here


4 Results of Auctions State Development Loans of 9 State Governments / Union Territories – Full Auction Result Click Here
5 Overseas Direct Investment for July 2020 Click Here
6 Underwriting Auction for sale of Government Securities for ₹30,000 cr on August 14, 2020 Click Here
7 Directions under Section 35 A of the Banking Regulation Act, 1949 (AACS) – Bhagyodaya Friends Urban Co-operative Bank Ltd., Warud, Distt. Amravati, Maharashtra – Extension of Period  

Click here

8 584th Meeting of Central Board of the Reserve Bank of India Click here
9 RBI releases framework for authorisation of pan-India Umbrella Entity for Retail Payments Click Here
10. Reserve Bank invites comments on the draft framework for recognition of a Self-Regulatory Organisation (SRO) for Payment System Operators  

Click Here

11. Minutes of the Monetary Policy Committee Meeting August 4 to 6, 2020 Click Here
12 New Definition of Micro, Small and Medium Enterprises – clarifications  

Click here

13 RBI Announces Special Open Market Operations (OMOs) of Simultaneous Purchase and Sale of Government of India Securities  

Click here

14 It is Time for Banks to Look Deeply Within: Reorienting Banking Post-Covid (Keynote Address by Shri Shaktikanta Das, Governor, Reserve Bank of India – Delivered at the Unlock BFSI 2.0 with Business Standard on Thursday, August 27, 2020)  


Click Here

15 Annual Report for the year 2019-20 Click Here
16 Submission of returns under Section 31 of the Banking Regulation Act, 1949 (AACS) – Extension of time  

Click Here

17 Ad-hoc/Short Review/Renewal of Credit Facilities  

Click Here

18 RBI launches the September 2020 round of the Inflation Expectations Survey of Households



Click Here

19 Sovereign Gold Bond Scheme 2020-21 Series VI-Issue Price



Click Here

20 Directions issued to the Rupee Co-operative Bank Ltd., Pune, Maharashtra – Extension of Period  

Click Here

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