COVID-19 Relaxation for Companies

On account of COVID – 19 being declared a worldwide pandemic by the World Health Organization, several countries have taken a slew of drastic measures to combat the spread of the virus. The alarming rise in the number of cases in India actioned the Central Government into implementing a nationwide lock-down. Further, taking cognizance of the disruptions in operations, logistics as well the workforce caused by the lock-down, the Ministry of Corporate Affairs, Government of India (“MCA”), the market regulatory – Securities and Exchange Board of India (“SEBI”) and the central bank – Reserve Bank of India (“RBI”) announced several relaxations in regulatory and statutory compliances that have to be undertaken by the companies to enable them to tide over this period of disruption caused by COVID-19. In this article, we have discussed the various relaxations permitted to companies for business continuity during this period by the MCA, SEBI and RBI.

1. Relaxations
2. Ministry of Corporate Affairs

1. Relaxation of requirements under Section 173 of the Companies Act, 2013 and Rule 4 of the Companies (Meeting of Board and its Powers) Rules, 2014

Section 173 of the Companies Act, 2013 mandates that a minimum of 4 board meetings have to be held in a year with a gap of not more than 120 days between any two meetings. Such meetings may be attended by the directors either in person or through video conferencing or other audio visual means which are capable of recording and recognising the participation of the directors and recording and storing the proceedings of such meetings along with date and time.

However, there are certain matters which cannot be dealt with in any meeting held through video conferencing. Rule 4 of the the Companies (Meeting of Board and its Powers) Rules, 2014 provides that the following matters cannot be dealt with in any meeting held through video conferencing  or other audio visual means:

a – Approval of the annual financial statements;

b – Approval of the Board’s report;

c – Approval of Prospectus;

d – Audit Committee Meetings for consideration of financial statement including consolidated financial statement if any, to be approved by the board under section 134(1) of the Act;

e – Approval of the matter relating to amalgamation, merger, demerger, acquisition and takeover etc.

The MCA vide notification dated March 19, 2020, amended the above rule such that from the commencement of the Companies (Meetings of Board and its Powers) Amendment Rules, 2020 till June 30, 2020, the meetings on matters referred to above, may be held through video conferencing or other audio visual means in accordance with rule 3 of the Companies (Meeting of Board and its Powers) Rules, 2014.

Further, MCA has provided a one-time relaxation, allowing an additional 60 day gap in between two board meetings till September 30, 2020, such that the maximum gap between two consecutive meetings of the board shall stand extended from 120 days to 180 days.[1]

2. Exemption from the requirement of Independent Director Meeting

The Companies Act, 2013 mandates that the independent directors of a company shall hold at least one meeting in a financial year, without the attendance of non-independent directors and members of management.[2] However, MCA vide a general circular has provided that in case the independent director is unable to hold such a meeting, it shall not be viewed as a violation.

3. Extension of deadline for depositing the amount in the Deposit Repayment Reserve Account

Section 73(2)(c) of the Companies Act, 2013 read with rule 13 of the Companies (Acceptance of Deposits) Rules, 2014 provides that the company shall deposit an amount equivalent to not less than 20% of the deposits maturing during the following financial year and kept in a scheduled bank in a separate bank account called the deposit repayment reserve account on or before April 30 of each year. The due date for creating this reserve for the financial year 2020-21 has been extended to June 30, 2020.[3]

4. Inclusion of spending funds on tackling COVID-19 as a CSR activity

Section 135 of the Companies Act, 2013 mandates that every company with a net worth of Rupees 500 Crore or more, or turnover of Rupees 1000 crore or more or a net profit of Rupees 5 crore or more during the immediately preceding financial year shall spend at least 2% of the average profits of the company made during the 3 immediately preceding financial years to undertake activities as provided in the corporate social responsibility policy of the company which includes activities as specified in Schedule VII of the Companies Act, 2013.

The MCA vide General Circular no. 10/2020 dated March 23, 2020[4] has clarified that any activity related to COVID-19 relating to the promotion of health care, including preventive health care, sanitation and disaster management shall constitute as CSR activity.

Further, the MCA vide an office memorandum dated March 28, 2020[5] has clarified that any contribution made by the company to the Prime Minister’s Citizen Assistance and Relief in Emergency Situations Fund (PM Cares Fund) shall qualify as an admissible expenditure towards fulfilling their CSR obligations under Section 135 of the Companies Act, 2013.

5. Deferment of applicability of the Companies (Auditor’s Report) Order, 2020

The Companies (Auditor’s Report) Order, 2020 shall now be made applicable from the financial year 2020-2021 instead of being applicable from the financial year 2019-2020 to ease the burden on companies and their auditors.[6]

6. Extension of deadline to invest or deposit at least 15% of the debentures maturing during the year

Rule 18 of the Companies (Share Capital and Debenture) Rules, 2014 provides that the company shall invest or deposit on or before April 30, a sum which shall not be less than 15% of the amount of its debentures maturing during the year, ending on March 31. The due date for investing or depositing such amounts before April 30, 2020 has been extended to June 30, 2020.[7]

7. Extension from filing a declaration for commencement of business

Section 10A of the Companies Act, 2013 provides that a company incorporated on or after November 2, 2018, having a share capital shall not commence any business or exercise any borrowing powers unless a declaration is filed by a director within a period of 180 days of the date of incorporation of the company. The MCA has provided an additional 180 days to file the declaration. [8]

8. Exemption from Minimum Residency Requirements

Section 149 of the Companies Act, 2013 provides that every company shall have at least one director who stays in India for a total period of not less than 182 days during the financial year. MCA vide it’s circular dated March 24, 2020 has done away with the minimum residency requirement for the financial year 2019-20.

9. Introduction of the Companies Fresh Start Scheme, 2020 (“Company Scheme”) and modification of the LLP Settlement Scheme, 2020 (“LLP Scheme”)

The MCA vide General Circular no. 13/2020[9] and General Circular no. 12/2020[10] passed the LLP Settlement Scheme and Companies Fresh Start Scheme, 2020 allowing waiver of late fees for any delay in filing of any e-forms with the Registrar of Companies between April 1, 2020 and September 30, 2020. The Schemes, apart from giving longer timelines for companies and LLPs to comply with various filing requirements under the Companies Act 2013 and LLP Act, 2008 respectively, significantly reduce the related financial burden on them, especially for those with long standing defaults. Both the Schemes also contain provisions for giving immunity from penal proceedings, including against imposition of penalties for late submissions and also provide additional time for filing appeals before the concerned Regional Directors against the imposition of penalties, if already imposed.

10. Raising the minimum default limit under the Insolvency and Bankruptcy Code, 2016

The MCA vide its notification dated March 24, 2020 has raised the limit of minimum amount of default from Rs 1 Lakh to Rs 1 Crore.[11]

11. Insolvency and Bankruptcy Board of India (Insolvency Resolution Process for Corporate Persons) (Third Amendment) Regulations, 2020

The period of lockdown imposed by the Central Government in the wake of COVID-19 shall not be counted while calculating the timelines for an activity in relation to the corporate insolvency resolution process.[12]

12. Possible Suspension of provisions of the Insolvency and Bankruptcy Code, 2016

The Finance Ministry announced on March 24, 2020 that the Government of India may consider suspending Section 7, 8 and 9 of the Insolvency and Bankruptcy Code, 2016 which relates to the initiation of Corporate Insolvency Proceedings by financial creditors, operational creditor and corporate applicants. Such relaxation has not yet been implemented.

The relaxations set out under sub-paragraphs 10, 11 and 12 of paragraph A above comes as a relief to debt stricken companies who may have otherwise gone into insolvency. However, given the disruption in operations brought about due to this lock-down, it is likely that the situation of debt-ridden companies would only worsen during this period. Further, it is also likely that more companies may fall within the ambit of “defaulters” on account of disruptions in business. Hence, when the relaxations are removed, it is likely that India may witness an influx of cases against potentially insolvent companies.

B – Stamp Duty

1. The Ministry of Finance vide notification dated March 30, 2020 has postponed the effective date of enforcement of the Indian Stamp (Collection of Stamp-Duty through Stock Exchanges, Clearing Corporations and Depositories) Rules, 2019 from April 1, 2020 to July 1, 2020.[13]

C – Securities and Exchange Board of India

1. Relaxation from compliances with provisions under SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015 (“LODR”): SEBI circulars dated March 19, 2020[14], March 23, 2020[15] and March 26, 2020[16]

1. Relaxation in regulatory filings for REITs and InvITs

SEBI vide it’s circular dated March 23, 2020[17] has extended the due date for all regulatory filings and compliances for the period ending March 31, 2020 by 1 month over and above the timelines prescribed under SEBI (Real estate Investment Trusts) Regulations, 2014 and SEBI (Infrastructure Investment Trusts) Regulations, 2014.

2. Extension of deadline to implement circular on stewardship code

SEBI vide circular no. CIR/CFD/CMD1/168/2019 dated December 24, 2019 introduced a Stewardship Code for all Mutual Funds and all categories of AIFs, in relation to their investment in listed equities. The Code which was supposed to come into effect from April 1, 2020 shall now be implemented on July 1, 2020.[18]

3. Relaxation in compliance with requirements pertaining to Mutual Funds[19]

4. Relaxation from compliance with certain provisions of the SAST Regulations, 2011[20]

Regulation 30 of the SEBI (Substantial Acquisition of Shares and Takeovers) Regulations, 2011 provides that every person who (together with persons acting in concert) holds 25% or more of shares or voting rights in a target company and the promoter of every company (together with persons acting in concert) are required to disclose their aggregate shareholding and voting rights held in a listed company as of March 31, each year. The due date for making this disclosure has been extended to June 1, 2020.

Further Regulation 31 of the SEBI (Substantial Acquisition of Shares and Takeovers) Regulations, 2011 provides that the promoter of every company (together with persons acting in concert) is required to declare that on a yearly basis that he has not made any encumbrance on the shares held by him, directly or indirectly, other than those already disclosed during the financial year. The due date for making this disclosure has been extended to June 1, 2020.

5. Relaxation from compliance with certain provisions issued under SEBI (Credit Rating Agencies) Regulations, 1999

SEBI has permitted credit rating agencies to not consider non-payment of principal/ interest or any rescheduling of payment of debt obligations by the issuer as a default until the period of moratorium granted by the RBI, i.e. May 31, 2020.[21] Further an extension of 30 days is being granted for making annual and semi-annual disclosures by CRAs on its website for the period ended March 2020 and a relaxation has been granted from the timelines for rating actions/ issue of the press release by the credit rating agencies stipulated vide SEBI circular dated June 30, 2017.

6. Continuation of Phase II of Unified Payments Interface with Application Supported by Block Amount

SEBI vide circular number  SEBI/HO/CFD/DCR2/CIR/P/2019/133 dated November 08, 2019, had extended the timeline for implementation of Phase II of Unified Payments Interface with Application Supported by Blocked Amount (“UPI ASBA”) till March 31, 2020. However, SEBI has further extended the continuation of the current Phase II of the UPI ASBA till further notice and it was further clarified that the modalities for the implementation of the Phase III of the UPI ASBA would be notified at a later date. [22]

7. Relaxation in processing of documents pertaining to FPIs

In terms of Operational guidelines for Foreign Portfolio Investors (FPIs) & Designated Depository Participants (DDPs) issued under Securities and Exchange Board of India (FPI) Regulations, 2019, FPI applicants shall submit duly signed application form (including KYC details) and supporting documents and applicable fees. Further, copies of all the KYC documents submitted by the applicant should be accompanied by originals for verification. In case the original of any KYC document is not produced for verification, then the copies should be properly attested by entities authorized for attesting the documents. SEBI has made the following relaxations applicable till June 30, 2020[23]:

a – DDPs & Custodians may consider and process the request(s) for registration/ continuance/ KYC / KYC review & any other material change on the basis of the scanned version of signed documents (instead of originals) and copies of documents which are not certified, received from

• e-mail IDs of their Global Custodians/existing clients where these details are already captured in records or
• e-mail IDs of new clients received from domains which are duly encrypted with Transport–layer security (TLS) or similar encryption or the documents are password protected.

b – These documents may be uploaded on KRAs. The other intermediaries may rely on said documents.

DDPs & Custodians shall ensure to obtain the original and/or certified documents (as applicable normally) within 30 days from June 30, 2020.

8. Relaxation in compliance with requirements pertaining to Portfolio Managers

SEBI vide circular dated March 30, 2020[24] has extended the timelines for the following by two months:

a – Monthly reporting to SEBI by Portfolio Managers for the periods ending March 31, 2020 and April 30, 2020.

b – Applicability of SEBI Circular SEBI/HO/IMD/DF1/CIR/P/2020/26 dated February 13, 2020 on ‘Guidelines for Portfolio Managers’.

9. Relaxation in compliance with requirements pertaining to AIFs and VCFs

SEBI vide it’s circular dated March 30, 2020[25], has extended the due date for regulatory filings for alternate investment funds and venture capital funds for the periods ending March 31, 2020 and April 30, 2020 by 2 months, over and above the timelines prescribed under SEBI (Alternative Investment Funds) Regulations, 2012 and circulars issued thereunder.

D – Reserve Bank of India

1. RBI COVID-19 Regulatory Package

RBI vide it’s circular dated March 27, 2020[26] has released the following relaxation to borrowers and lending institution:

a – Rescheduling of Payments – Term Loans and Working Capital Facilities

The RBI has permitted all commercial banks including regional rural banks, small finance banks and local area banks, co-operative banks, all-India Financial Institutions, and NBFCs to grant a moratorium of 3 months on payment of all installments falling due between March 1, 2020 and May 31, 2020 in respect of al term loans.[27] The interest will, however, continue to accrue on the outstanding portion of the term loans during the moratorium period.

Further, all commercial banks are also permitted to defer the recovery of interest applied in respect of all working capital facilities sanctioned in the form of cash credit/overdraft during the period from March 1, 2020 upto May 31, 2020. The accumulated accrued interest shall be recovered immediately after the completion of this period.

Given that the lock-down has resulted in a disruption of business in what have been deemed as “non-essential” services and such businesses do not have steady revenue stream during this period, the servicing of payments towards term loans and working capital facilities may be an additional burden on such companies in addition to resuming regular business.

b – Easing of Working Capital Financing

The commercial banks may recalculate the drawing power by reducing the margins and/or reassessing the working capital cycle, in respect of working capital facilities sanctioned in the form of cash credit/overdraft. This relief shall be effectuated upto May 31, 2020.

c – Classification as Special Mention Account (SMA) and Non-Performing Asset (NPA)

Any relief granted in terms of point ‘a.’ or ‘b.’ shall not lead to the downgrading of the borrower’s asset classification or qualify as any default.

d – Wherever the exposure of a lending institution to a borrower is Rupees 5 Crore or above as on March 1, 2020, the bank shall develop an MIS on the reliefs provided to its borrowers which shall inter alia include borrower-wise and credit-facility wise information regarding the nature and amount of relief granted.

2. RBI- Seventh Bi-monthly Monetary Policy Statement, 2019-20 Resolution of the Monetary Policy Committee (“MPC”)

RBI announced that the MPC at its meeting had decided to reduce the policy repo rate under the liquidity adjustment facility (“LAF”) by 75 basis points to 4.40% from 5.15%. The marginal standing facility and the bank rate is reduced to 4.65% from 5.40%. Further, upon the widening of the LAF corridor, the reverse repo rate under the LAF shall stand reduced by 90 basis points to 4.0%.

3. Cash Reserve Ratio

The RBI has announced its decision to reduce the Cash Reserve Ratio (CRR) of all banks by 100 basis points from 4.00 percent to 3.00 percent of their Net Demand and Time Liabilities (NDTL) with effect from the reporting fortnight beginning March 28, 2020 for a period of one year, ending on March 26, 2021[28] and has decided to reduce the minimum daily maintenance of the Cash Reserve Ratio from 90 percent of the requirement to 80 percent effective from the fortnight beginning March 28, 2020. This is a one-time dispensation available up to June 26, 2020[29].

4. Maintenance of Statutory Liquidity Ratio

Further, RBI has decided to raise the borrowing limit of Scheduled Banks (excluding Regional Rural Bank) under the MSF scheme from 2 percent to 3 percent of their Net Demand and Time Liabilities (NDTL) outstanding at the end of the second preceding fortnight with immediate effect. The enhanced limit will be applicable up to June 30, 2020.[30]

5. Extension in period of realization of export proceeds

The Export Regulations require that the full export value of goods, software or services exported from India must be realised within 9 months from the date of export. Following an amendment to the Export Regulations and by its notification of 1 April 2020, the RBI has extended the period of realisation of export proceeds to 15 months from 9 months in respect of all exports made up to 31 July 2020.[31]

6. RBI has decided to defer the implementation of Net Stable Funding Ratio guidelines by six months. These guidelines will now come into effect from October 1, 2020 as against April 1, 2020.[32]
7. RBI to enable the smoother implementation of the LEI system in non-derivative markets, extended the timeline for implementation of Phase III from March 31, 2020 to September 30, 2020 for entities with a net worth up to Rs. 200 Crore.[33]
8. RBI has amended the Master Direction on Risk Management and Inter-bank Dealings dated July 6, 2016, to bring it in line with the permit given to banks in India which operate International Financial Services Centre (IFSC) Banking Units (IBUs) to participate in the Non-Deliverable Forward Market with effect from June 1, 2020. The amendments include[34]:
9. The definition of a Non-deliverable derivative contract (NDDC) has been inserted to mean a foreign exchange derivative contract involving the Rupee, entered into with a person not resident in India and which is settled without involving the delivery of Rupee.

a – The definition of a Non-deliverable derivative contract (NDDC) has been inserted to mean a foreign exchange derivative contract involving the Rupee, entered into with a person not resident in India and which is settled without involving the delivery of Rupee.

b – Banks in India having an Authorised Dealer Category-1 license under FEMA, 1999, and operating International Financial Services Centre (IFSC) Banking Units (IBUs) shall be eligible to offer NDDC involving the Rupee, or otherwise, to persons not resident in India. Banks can undertake such transactions through their IBUs or through their branches in India or through their foreign branches (in case of foreign banks operating in India, through any branch of the parent bank).

c – Authorised dealers having an IFSC Banking Unit (IBU) may transact in NDDCs with other AD Category 1 banks having IBUs and banks overseas. Banks can undertake such transactions through their IBUs or through their branches in India or through their foreign branches (in case of foreign banks operating in India, through any branch of the parent bank).

1. Conclusion

This pandemic has had a major impact on the global economy and reports by experts suggest that the economic disruption caused by COVID-19 is much harsher than the financial crisis in 2008, given the abrupt halt in production. With the uncertainty looming in front of us due to the pandemic, these exemptions and relaxations come as a much needed and timely step in order to assist companies and ensure their smooth functioning. However, given the disruptions that such businesses would have gone through during the lock-down, and the time it would take for the companies to resume post completion of lock-down, it is also essential at this stage to consider the impact of removing such relaxations once business resumes as usual.

• Banks in India having an Authorised Dealer Category-1 license under FEMA, 1999, and operating International Financial Services Centre (IFSC) Banking Units (IBUs) shall be eligible to offer NDDC involving the Rupee, or otherwise, to persons not resident in India. Banks can undertake such transactions through their IBUs or through their branches in India or through their foreign branches (in case of foreign banks operating in India, through any branch of the parent bank).

Authorised dealers having an IFSC Banking Unit (IBU) may transact in NDDCs with other AD Category 1 banks having IBUs and banks overseas. Banks can undertake such transactions through their IBUs or through their branches in India or through their foreign branches (in case of foreign banks operating in

[1] MCA General Circular no. 11/2020 dated March 24, 2020 on “Special Measures under the Companies Act, 2013 and Limited Liability Partnership Act, 2008 in view of the COVID-19 outbreak”.

^[2] Para VII, Schedule IV, Companies Act, 2013.

[3] MCA General Circular no. 11/2020 dated March 24, 2020 on “Special Measures under the Companies Act, 2013 and Limited Liability Partnership Act, 2008 in view of the COVID-19 outbreak”.

^[4] MCA General Circular no. 10/2020 dated March 23, 2020 on “Clarification on spending of CSR funds for COVID-19”.

[5] MCA Office Memorandum no. CSR-05/1/2020-CSR-MCA dated March 28, 2020 on “Clarification on contribution to PM CARES Fund as eligible CSR activity under item no. (viii) of the Schedule VII of Companies Act, 2013”.

[6] MCA Order S.O. 1219(E) dated March 24, 2020.

[7] MCA General Circular no. 11/2020 dated March 24, 2020 on “Special Measures under the Companies Act, 2013 and Limited Liability Partnership Act, 2008 in view of the COVID-19 outbreak”.

[8] MCA General Circular no. 11/2020 dated March 24, 2020 on “Special Measures under the Companies Act, 2013 and Limited Liability Partnership Act, 2008 in view of the COVID-19 outbreak”.

[9] MCA General Circular no. 13/2020 dated March 30, 2020 on “LLP Settlement Scheme, 2020-Modification-reg.”.

[10] MCA General Circular no. 12/2020 dated March 30, 2020 on “Companies Fresh Start Scheme, 2020”.

[11] MCA Notification S.O. 1205(E) dated March 24, 2020.

[12] MCA Notification No. IBBI/2019-20/GN/REG059 dated March 29, 2020.

[13] Ministry of Finance Notification G.S.R. 226(E) dated March 30, 2020.

[14]SEBI Circular no. SEBI/HO/CD/CMD1/CIR/P/2020/38 dated March 19, 2020 on “Relaxation from compliance with certain provisions of the SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015 due to the COVID -19 virus pandemic”.

[15]SEBI Circular no.  SEBI/HO/DDHS/ON/P/2020/41 dated March 23, 2020 on “Relaxation from compliance with certain provisions of the SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015 and SEBI circulars due to the COVID -19 virus pandemic”.

[16]SEBI Circular no. SEBI/HO/CFD/CMD1/CIR/P/2020/48 dated March 26, 2020 on “ Further relaxations from compliance with certain provisions of the SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015 (LODR) and the SEBI circular dated January 22, 2020 relating to Standard Operating Procedure due to the COVID -19 virus pandemic”.

[17]SEBI Circular no. SEBI/HO/DDHS/CIR/P/2020/42 dated March 23, 2020 on “Relaxation from compliance to REITs and InvITs due to the COVID -19 virus pandemic”.

[18]SEBI Circular no. SEBI/HO/CFD/CMD1/CIR/P/2020/55 dated March 30,2020 on “Extension of deadline for implementation of the circular on Stewardship Code for all Mutual Funds and all categories of AIFs due to the COVID–19 pandemic”.

[19]SEBI Circular no. SEBI/HO/IMD/DF3/CIR/P/20 dated March 23, 2020 on “Relaxation in compliance with requirements pertaining to Mutual Funds”.

[20]SEBI Circular no. SEBI/HO/CFD/DCR1/CIR/P/2020/49 dated March 27, 2020 on “Relaxation from compliance with certain provisions of the SEBI (Substantial Acquisition of Shares and Takeovers) Regulations, 2011 due to the COVID-19 pandemic”.

[21] SEBI Circular no. SEBI/ HO/ MIRSD/ CRADT/ CIR/ P/ 2020/ 53 dated March 30, 2020 on “Relaxation from compliance with certain provisions of the circulars issued under SEBI (Credit Rating Agencies) Regulations, 1999 due to the COVID-19 pandemic and moratorium permitted by RBI”.

[22]SEBI Circular no circular number SEBI/HO/CFD/DIL2/CIR/P/2020/50 dated March 30,2020 on Continuation of Phase II of Unified Payments Interface with Application Supported by Block Amount”.

[23]SEBI Circular no. SEBI/HO/FPI&C/CIR/P/2020/056 dated March 30, 2020 on “Temporary relaxation in processing of documents pertaining to FPIs due to COVID-19”.

[24]SEBI Circular no. SEBI/HO/IMD/DF1/CIR/P/2020/57 dated March 30,2020 on “Relaxation in compliance with requirements pertaining to Portfolio Managers”.

[25]SEBI Circular no. SEBI/HO/IMD/DF1/CIR/P/2020/58 dated March 30, 2020 on “Relaxation in compliance with requirements pertaining to AIFs and VCFs”.

[26] SEBI Circular no. RBI/2019-20/186 dated March 27, 2020 on “COVID-19 – Regulatory Package”.

[27] Instalment for this purpose includes (i) principal and/or interest components; (ii) bullet repayments; (iii) equated monthly instalments; and (iv) credit card dues.

[28] RBI Circular no. RBI/2019-20/191 dated March 27, 2020 on “Maintenance of Cash Reserve Ratio (CRR)”.

[29] RBI Circular no. RBI/2019-20/192 dated March 27, 2020 on “Section 42(1) of the Reserve Bank of India Act, 1934 – Change in Daily Minimum Cash Reserve Maintenance Requirement”.

[30] RBI Circular no. RBI/2019-20/189 dated March 27, 2020 on “Section 24 of the Banking Regulation Act,1949 – Maintenance of Statutory Liquidity Ratio (SLR) – Marginal Standing Facility (MSF)”.

[31] RBI Press Release dated April 1, 2020 on “RBI announces further measures for dealing with the COVID-19 pandemic”.

[32] RBI Circular no. RBI/2019-20/187 dated March 27, 2020 on “Basel III Framework on Liquidity Standards –

Net Stable Funding Ratio (NSFR)”.

[33] RBI Notification RBI/2019-20/185 dated March 27, 2020 on “Legal Entity Identifier: Extension of Deadline”.

[34] RBI Circular no. RBI/2019-20/193 dated March 27, 2020 on “Risk Management and Inter-bank Dealings- Participation of Banks in Offshore Non-Deliverable Rupee Derivative Markets”.