The most common regulatory compliance failures GP advises on are: KYC and AML non-compliance (most frequently penalised); NBFC prudential norms failures (concentration limits, capital adequacy, NPA recognition); interest rate and fair practices code violations; outsourcing guideline breaches; and IT systems and cybersecurity directive non-compliance.
For entities placed under RBI's Prompt Corrective Action framework, GP advises on the remediation plan required to exit PCA and the legal challenge where PCA imposition is based on incorrect data. For licence cancellation — the most drastic RBI action — GP files an immediate writ petition before the Bombay High Court seeking a stay.
Preparation for and response to RBI statutory inspections — Annual Financial Inspections for banks, periodic on-site inspections for NBFCs and payment companies. GP advises on document preparation, management of inspector queries, and preparation of the compliance report. Prompt and complete responses to RBI inspection findings are the most effective way to avoid escalation to Show Cause Notices and monetary penalties.
Pre-inspection compliance gap analysis — a systematic review of compliance with applicable RBI Master Directions, Basel norms, and entity-specific requirements. GP identifies compliance gaps and advises on remediation before RBI inspectors arrive. A pre-inspection audit that corrects failures before the RBI inspection significantly reduces the risk of adverse findings.
Compliance advisory for NBFCs on the NBFC Master Directions 2023 — covering capital adequacy, concentration limits, NPA recognition, provisioning, corporate governance, KYC, AML, and IT systems. GP advises NBFCs on their compliance position under each chapter and on the regulatory returns required. Upper and middle layer NBFCs face significantly more demanding requirements than base layer NBFCs.
Advisory for banks and NBFCs placed under RBI's Prompt Corrective Action framework — the tool that restricts dividends, branch expansion, and remuneration when financials deteriorate. GP advises on the remediation plan to demonstrate improvement on PCA metrics and exit the framework, and on the legal challenge where PCA imposition is based on incorrect financial data.
Where RBI has cancelled or proposes to cancel an entity's banking licence or NBFC registration, GP files an immediate writ petition before the Bombay High Court. A licence cancellation has devastating immediate consequences — the entity cannot conduct business and deposits are frozen. GP files the stay application within 24-48 hours of the cancellation order.
Compliance advisory for payment aggregators, payment banks, and prepaid instrument issuers on the Payment and Settlement Systems Act 2007 — authorisation requirements, net worth and escrow obligations, grievance redressal, and compliance reporting. For entities whose payment system authorisation has been cancelled, GP files an urgent High Court challenge.
Cooperative banks are regulated by both RBI (banking operations under the Banking Regulation Act) and the Registrar of Cooperative Societies (cooperative governance under the MCS Act). Compliance for cooperative banks must address both frameworks simultaneously — an RBI governance finding may also trigger Registrar action.
For FEMA violations identified during an RBI inspection, RBI acts as the Compounding Authority. GP prepares compounding applications presenting complete disclosure, the circumstances, and mitigating factors. Voluntary and complete compounding applications consistently produce lower penalties than those filed under ED pressure.
For banks and NBFCs with significant NPA exposures, GP advises on recovery through SARFAESI action, DRT applications, and IBC proceedings — and defends regulated entities against borrower challenges before the Debt Recovery Appellate Tribunal. The regulatory compliance and NPA recovery practices are integrated.
GP's RBI practice covers every stage — pre-inspection compliance gap analysis, inspection response, SCN reply, and penalty challenge before the Bombay HC. Understanding how each stage affects the next is the core of effective RBI regulatory defence.
RBI regulation differs significantly for scheduled commercial banks, cooperative banks, NBFCs, and payment system operators. GP's regulatory compliance advisory is calibrated to the specific regulatory category of each client — not generic advice that misses entity-specific requirements.
A licence cancellation order requires an immediate legal response — the writ petition and stay application must be filed before the cancellation takes full effect. GP has a protocol for emergency RBI enforcement responses that allows a writ petition to be filed and heard within 48 hours of a cancellation order.
Defended a Mumbai NBFC that received an RBI SCN following an Annual Inspection, alleging KYC failures across 2,400 accounts and NPA mis-classification of 18 accounts. Proposed penalty: Rs.3.2 crore. GP's SCN reply accepted the KYC failures (genuine, from a legacy system), presented remediation steps already taken, and contested the NPA mis-classification with credit files and regulatory guidance. RBI imposed a final penalty of Rs.80 lakh — confined to KYC failures only, accepting GP's position on the NPA classification.
Filed an emergency writ for a Maharashtra urban cooperative bank whose banking licence was cancelled by RBI, freezing 180 depositor accounts. GP filed within 36 hours, seeking a stay on three grounds: inadequate opportunity to respond, failure to consider the capital restoration plan submitted six weeks earlier, and disproportionate harm to depositors from immediate cancellation. The HC stayed the cancellation and directed RBI to consider the capital restoration plan before making a final order.
Advised a Delhi payment aggregator following an RBI inspection that identified an escrow shortfall and grievance redressal timing failures. GP conducted a compliance audit, prepared the compliance report with full disclosure and a remediation plan, and implemented remediation within the proposed timeframe. RBI accepted the report and did not issue an SCN — closing the matter at the compliance report stage without penalty.
The RBI regulatory compliance practice covers banks, NBFCs, payment system operators, and cooperative banks — providing pre-inspection compliance advice, inspection response management, SCN replies, and emergency litigation.
For matters at the intersection of RBI regulation and FEMA — the most common dual-regulator scenario — GP's FEMA practice provides the integrated advisory from a single team.
How to structure an RBI SCN reply that reduces the penalty by accepting genuine failures and contesting characterisations that overstate the non-compliance.
Read Insight →KYC, NPA, and governance failures that dominate RBI NBFC inspection reports — and the remediation steps that prevent escalation to SCN.
Read Insight →Whether you need pre-investigation advice, are responding to a regulator notice, or are defending enforcement action — speak to GP today.