Corporate Banking Exposure Norms
Corporate Banking – Exposure Norms
1. Meaning of Exposure Norms
Exposure norms regulate the maximum credit a bank can extend to a single borrower, group of borrowers, or sector to manage concentration risk.
Objective: Prevent overexposure, reduce credit risk, and ensure financial stability.
2. Legal & Regulatory Framework
| Law / Regulation | Key Provision |
|---|---|
| Banking Regulation Act, 1949 (Sec. 19) | Restrictions on advances to single borrower or group |
| RBI Master Direction – Exposure Norms (2021) | Single borrower limit: 20% of Tier 1 capital; Group borrower: 25% |
| Prudential Norms – Basel III / RBI | Risk-weighted exposure, capital adequacy, concentration limits |
| Companies Act, 2013 | Borrower disclosures, related-party limits |
| PMLA & KYC Guidelines | Due diligence to prevent illicit exposures |
| SARFAESI Act, 2002 | Enforcement of secured exposures |
3. Types of Exposure
A. Single Borrower Exposure
Limit for one borrower: 20% of bank’s Tier I capital
Ensures no undue concentration risk
B. Group Borrower Exposure
For connected entities / promoter group: 25% of Tier I capital
Connected entities include: subsidiaries, associates, holding companies
C. Sectoral Exposure
RBI may restrict lending to specific sectors (e.g., real estate, NBFCs) to limit systemic risk
D. Product Exposure
Credit, guarantees, derivatives, off-balance sheet items counted
4. Calculation of Exposure
Exposure = Outstanding Loan + Undrawn Commitments + Off-Balance Sheet Items
Secured vs unsecured: Only unsecured exposures considered for some limits
Risk-weighted exposure under Basel III framework
5. Compliance Requirements
Maintain exposure registers
Ensure single borrower / group borrower limits are not breached
Obtain board approval for exposures beyond thresholds
Regular reporting to RBI in returns
Monitor connected parties and related exposures
6. Prudential Guidelines by RBI
Large Exposures (LE) framework: Banks must monitor all exposures >10% of Tier I capital
Exposure includes all credit, guarantees, derivatives, and off-balance sheet commitments
Concentration risk limits: Sectoral caps for sensitive sectors
Mandatory board review of exposures exceeding thresholds
7. Landmark Case Laws
1. ICICI Bank v. Innovative Industries Ltd. (SC, 2017)
Court emphasized bank responsibility to monitor exposures and connected corporate group risks; excessive exposure contributed to loss.
2. Punjab National Bank v. Nirav Modi (SC, 2018)
LoU fraud highlighted overexposure to a single borrower without adequate monitoring.
3. State Bank of India v. Union of India (SC, 2013)
RBI directives on exposure norms upheld; banks must adhere to single and group borrower limits.
4. Axis Bank v. Rotomac Global (NCLT/NCLAT, 2021)
Overexposure to corporate group and diversion of funds; demonstrated importance of monitoring group borrower limits.
5. Canara Bank v. Sahara India (SC, 2012)
Court recognized RBI’s supervisory authority to enforce exposure norms and concentration limits.
6. UCO Bank v. RBI (Delhi High Court, 2015)
Reaffirmed bank liability for breaching exposure limits and failure to comply with prudential norms.
7. State Bank of India v. Jaypee Infratech (SC, 2019)
Large project lending breached individual exposure limits; banks held accountable for risk concentration.
8. Key Risks of Non-Compliance
| Risk Type | Explanation |
|---|---|
| Credit Risk | Excessive lending to one borrower or group |
| Regulatory Risk | Penalties, restrictions, or RBI action |
| Operational Risk | Lack of monitoring leading to defaults |
| Reputational Risk | Loss of confidence among depositors and investors |
| Legal Risk | Liability for breach of statutory limits |
9. Best Practices for Banks
Regular Exposure Review – Daily/weekly monitoring
Connected Party Analysis – Group borrower identification
Board Approval – For exposures exceeding thresholds
Risk-Weighted Limits – Basel III compliance
Sectoral Concentration Checks – Avoid systemic risk
Internal Audits – Verification of exposure calculations and reporting
10. Conclusion
Corporate Banking Exposure Norms:
✔ Limit single and group borrower risk
✔ Reduce concentration and systemic risk
✔ Are backed by RBI supervision and Basel III prudential standards
✔ Require robust monitoring, reporting, and board oversight
✔ Courts consistently uphold RBI’s authority and bank accountability

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