Spurhan Financial Services Private Ltd, is registered as a Non-Banking Financial Company (NBFC) as per the requirements of Reserve Bank of India (RBI). Neyo, its Company Secretary is a proactive professional and endeavou
CS Professional · Environmental, Social and Governance (ESG) Principles and Practice · PYQS · June 2026
Spurhan Financial Services Private Ltd, is registered as a Non-Banking Financial Company (NBFC) as per the requirements of Reserve Bank of India (RBI). Neyo, its Company Secretary is a proactive professional and endeavours to ensure compliance well within timelines. He came across the guidelines on Corporate Governance for NBFCs issued by the RBI under its Master Directions, about the requirements to appoint Chief Risk Officer (CRO). He informed Muthu, the Managing Director of the Company about these provisions and requirements to appoint CRO, considering that the Company was registered as a NBFC. Muthu, contended that the requirements to appoint CRO, may not apply to the Company, as it has been in operations since last five years only. Advise Neyo, on the requirements to appoint CRO as per the RBI guidelines.
Answer & Explanation:
With the increasing role of NBFCs in direct credit intermediation, there is a need for NBFCs to augment risk management practices. While Boards of NBFCs should strive to follow best practices in risk management, NBFCs with asset size of more than ₹5000 Crore shall appoint a Chief Risk Officer (CRO) with clearly specified role and responsibilities. The CRO is required to function independently so as to ensure highest standards of risk management. The NBFCs shall strictly adhere to the following requirements with respect to appointment of CRO: The CRO shall be a senior official in the hierarchy of NBFC and shall possess adequate professional qualification/ experience in the area of risk management. The CRO shall be appointed for a fixed tenure with the approval of the Board. The CRO can be transferred/ removed from his post before completion of the tenure only with the approval of the Board and such premature transfer/ removal shall be reported to the Department of Non-Banking Supervision of the regional office of the Bank under whose jurisdiction the NBFC is registered. In case the NBFC is listed, any change in incumbency of the CRO shall also be reported to the stock exchanges. The Board shall put in place policies to safeguard the independence of the CRO. In this regard, the CRO shall have direct reporting lines to the MD & CEO/ Risk Management Committee (RMC) of the Board. In case the CRO reports to the MD & CEO, the RMC/ Board shall meet the CRO without the presence of the MD & CEO, at least on a quarterly basis. The CRO shall not have any reporting relationship with the business verticals of the NBFC and shall not be given any business targets. Further, there shall not be any 'dual hatting' i.e. the CRO shall not be given any other responsibility. The CRO shall be involved in the process of identification, measurement and mitigation of risks. All credit products (retail or wholesale) shall be vetted by the CRO from the angle of inherent and control risks. The CRO's role in deciding credit proposals shall be limited to being an advisor. In NBFCs that follow committee approach in credit sanction process for high value proposals, if the CRO is one of the decision makers in the credit sanction process, the CRO shall have voting power and all members who are part of the credit sanction process, shall individually and severally be liable for all the aspects, including risk perspective related to the credit proposal.
Topics: Financial Sector Governance, Risk Management
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