Libertatem Magazine Issue 1 | Page 11

(iii) Multilateral financial institutions (iv) Export Credit Agencies, (v) Suppliers of Equipment, (vi) Foreign Collaborators and (vii) Foreign Equity Holders (other than erstwhile Overseas Corporate Bodies). Restrictions: 1. Utilization for on-lending or investment in capital market or acquiring a company (or a part thereof) in India by a corporate, investment in real estate sector, for working capital and repayment of existing Rupee loans. 2. Issuance of guarantee, standby letter of credit, letter of undertaking or letter of comfort by banks, FIs and NBFCs from India relating to ECB. 3. The borrower has the option to offer security against the ECB. Creation of charge over immoveable assets and financial securities, such as shares, in favour of the overseas lender is subject to FEMA regulations and ECB guidelines. APPROVAL ROUTE Features: Proposals falling under the category include:1. On lending by the EXIM Bank for specific purposes (case to case basis). 2. Banks and financial institutions which had participated in the textile or steel sector restructuring package as approved by the Government. 3. ECB with minimum average maturity of 5 years by NBFC to finance import of infrastructure equipment for leasing to infrastructure projects. 4. Infrastructure Finance Companies (IFCs) i.e. NBFCs, categorized as IFCs, by RBI (beyond 50% of their owned funds) for on-lending to the infrastructure sector as defined under the ECB policy and subject to compliance of certain stipulations. 5. Foreign Currency Convertible Bonds (FCCBs) by Housing Finance Companies. 6. Special Purpose Vehicles (SPV) or any other entity notified by the RBI, set up to finance infrastructure companies / projects exclusively. 7. Financially solvent Multi-State Co-operative Societies engaged in manufacturing. 8. SEZ developers for providing infrastructure facilities within SEZ. 9. Eligible Corporate under automatic route other than in the services sector viz. hotels, hospitals and software sector can avail of ECB beyond USD 750 million per financial year. 10. Corporate in the service sector for availing ECB beyond USD 200 Mn. per financial year. 11. Cases falling outside the purview of the automatic route limits and maturity indicated, etc. Restrictions: Most of the restrictions for accessing funds through this route are the same as those of the Automatic Route. Some of these have undergone certain changes, especially those related to this route, since the new RBI guidelines came into effect in 2013. The same has been discussed in the next section. CHANGES As it can be observed from the above details, the Indian companies are under heavy restrictions when borrowing funds from foreign lenders. Though, in the new circular issued by the Reserve Bank of India in 2013 some of the restrictions have been relaxed. Some of them are analysed in this section: 1. End use of ECB: previously, ECB could only be availed in for financial investments. But as per the new RBI circular, this restriction has been drastically relaxed. The permissible use of ECB now also includes using it for “general corporate purposes”. The new RBI guidelines allow the use of such ECB towards repayment of buyer’s debt, supplier’s debt and 25% of ECB to be utilized towards repayment of existing rupee debt, only if ECB is accessed through the approval route. This, still, is subject to certain restrictions as levied by the RBI: