The Reserve Bank - Integrated Ombudsman Scheme, 2021 (RB-IOS, 2021/ the Scheme) was launched on November 12, 2021. It integrates the erstwhile three Ombudsman schemes of RBI namely, (i) the Banking Ombudsman Scheme, 2006; (ii) the Ombudsman Scheme for Non-Banking Financial Companies, 2018; and (iii) the Ombudsman Scheme for Digital Transactions, 2019. These schemes had limited and different grounds of complaints and limited coverage of REs, apart from jurisdiction related restrictions. RB-IOS, 2021 provides for cost-free redress of customer complaints involving deficiency in services rendered by entities regulated by RBI, if not resolved to the satisfaction of the customers or not replied to within a period of 30 days by the RE.

In addition to integrating the three existing schemes, the Scheme also includes under its ambit additional REs, namely, Non-Scheduled Primary (Urban) Co-operative Banks with a deposit size of ₹50 crore and above and Credit Information Companies. The Scheme adopts ‘One Nation One Ombudsman’ approach by making the RBI’s Ombudsman mechanism jurisdiction neutral.

RB-IOS, 2021 covers all commercial banks, Non-Banking Financial Companies (NBFCs), Payment System Participants, most Primary (Urban) Cooperative Banks, and Credit Information Companies. The REs covered under the RB-IOS, 2021 are listed under Question 11.

A Deputy Ombudsman is a senior officer appointed by RBI to assist the RBI Ombudsman (refer Question 4) in matters of resolution of complaints and in handling certain complaints and the functions entrusted under the Scheme. The Deputy Ombudsman endeavors to promote settlement of a complaint by agreement between the complainant and the RE through facilitation or conciliation or mediation and dispose complaints as discussed in Question 24.

RB-IOS, 2021 has simplified the processes, centralized the receipt of physical and email complaints, brought more REs under its ambit, done away with limited grounds of complaints and difference jurisdictions of Ombudsmen and now all complaints involving deficiency in service are covered under RB-IOS. Complainants can lodge their complaints against an RE on the 24x7 online CMS portal at https://cms.rbi.org.in/ or send their complaint in email/physical form to CRPC (refer Question 16). Salient benefits for the complainant arising from the RB-IOS with upgraded CMS portal are as under:

1. Simplification in the process of filing the complaint on CMS portal;

2. A complaint can be filed on CMS portal/ CRPC from anywhere in the country irrespective of the address of the complainant, RE or branch involved;

3. One address and one email for lodging of physical/ email complaints from anywhere in the country;

4. Automatic acknowledgement to the complainant on registration of online complaint;

5. Facility for real-time tracking of the status of complaint;

6. Convenience from ‘One Nation One Ombudsman’ approach;

7. Facility for online submission of additional documents on the CMS itself;

8. Detailed letter intimating decision/ closure of complaint;

9. Facility for online and voluntary feedback submission by the complainant regarding redress provided by RBI.

Centralised Receipt and Processing Centre (CRPC) has been set up at RBI, Chandigarh for receiving complaints through physical mode (letter/post). The CRPC undertakes initial scrutiny and processing of these complaints, uploads them on CMS, which are then assigned to Offices of RBI Ombudsmen (ORBIOs) or CEPCs for redressal. Please refer to Question 15 and 16 for further details.

Presently, Offices of RBI Ombudsmen (ORBIOs) are functioning from 22 locations across India. However, the complainants need not contact/ approach any specified ORBIO for filing a complaint under the RB-IOS, 2021. The complaints lodged directly online through CMS Portal (https://cms.rbi.org.in) are automatically allocated to different RBI Ombudsmen for redressal upon registration of the complaint. Physical and email complaints are processed and entered in CMS for further processing, after seeking further information/ details, if missing, from the complainant.

The following REs of RBI are covered under the RB-IOS, 2021:

(i) Banks: All commercial banks, including Public Sector Banks, Private Sector Banks, Foreign Banks, Local Area Banks, Small Finance Banks, Payment Banks, Regional Rural Banks, Scheduled Primary (Urban) Co-operative Banks and Non-scheduled Primary (Urban) Co-operative Banks with deposit size of ₹50 Crore and above, as on the date of the audited balance sheet of the previous financial year;

(ii) NBFCs registered with RBI: All Non-Banking Financial Companies (excluding Housing Finance Companies) which (a) are authorized to accept deposits; or (b) have customer interface, with an assets size of ₹100 crore and above as on the date of the audited balance sheet of the previous financial year;

Note: Core Investment Companies, Infrastructure Debt Fund-Non-banking Financial Companies, Non-Banking Financial Companies-Infrastructure Finance Companies, companies in resolution or winding up / liquidation, or any other NBFC specified by RBI are excluded from the ambit of the RB-IOS, 2021.

(iii) System Participants: All Payment System Participants - banks as well as non-banks regulated by RBI are covered under the RB-IOS, 2021. These entities issue Prepaid Payment Instruments (PPIs) and facilitate transactions over National Electronic Funds Transfer (NEFT) / Real Time Gross Settlement (RTGS) / Immediate Payment Service (IMPS) / Unified Payments Interface (UPI) / Bharat Bill Payment System (BBPS) / Bharat QR Code / *99# mobile transaction service using Unstructured Supplementary Service Data (USSD) / Aadhaar Enabled Payment System (AePS), etc.

(iv) Credit Information Companies: All Credit Information Companies as defined in the Companies Act, 2013 (18 of 2013) and granted a Certificate of Registration under sub-section (2) of section 5 of the Credit Information Companies (Regulation) Act, 2005 (30 of 2005).

The list of entities, periodically updated, covered under the RB-IOS, 2021 is available at https://cms.rbi.org.in/cms/assets/Documents/RBIO_English_Portal.pdf.

All complaints involving ‘deficiency in service’ on the part of the RE, except for those listed under Question 14 below are handled under the RB-IOS, 2021. ‘Deficiency in service’ has been defined in RB-IOS, 2021 as ‘any shortcoming or inadequacy in any financial service, which the Regulated Entity of RBI is required to provide statutorily or otherwise, which may or may not result in financial loss or damage to the customer’.

Certain types of complaints which are classified as non-maintainable complaints due to various reasons as indicated below are not covered under RB-IOS, 2021:

1. Complaints which are filed directly with the Ombudsman without first being taken up with the RE concerned, in writing.

2. Complaints which have been lodged with the RE, but a period of 30 days has not elapsed from such date of lodgment of the complaint with the RE, except for complaints for which the complainant has received a reply from the RE, and is not satisfied with the reply.

3. Complaint made after one year from the date of receipt of the reply of the RE or, where no reply is received, later than one year and 30 days after the date of the representation to the RE;

4. Complaints which have been already dealt with by Ombudsman/ CEPC or those under process/pending on the same cause of action and for similar relief (whether received from the same complainant or along with one or more complainants) with the RBIO;

5. Complaints related to the commercial decision of the RE. For example: grant of a loan;

6. Complaints related to any dispute between a vendor and a RE;

7. Complaints addressed to other authorities and not directly addressed to Ombudsman;

8. Complaints raising general grievances against the management or executives of RE;

9. Complaints pertaining to a dispute in which action initiated by a RE is in compliance of the orders of a statutory or law enforcing authority;

10. Complaints in which the alleged deficiency in the service relates to an entity not regulated by RBI;

11. Complaints related to the disputes between REs;

12. Complaints related to any dispute involving employee-employer relationship of RE;

13. Complaints pending before any Court, Tribunal or Arbitrator or any other forum or authority; or, settled or dealt with on merits, by any Court, Tribunal or Arbitrator or any other forum or authority, whether or not received from the same complainant or along with one or more of the complainants/parties concerned;

14. Complaints that are abusive or frivolous or vexatious in nature;

15. Complaints made after the expiry of the period of limitation prescribed under the Limitation Act, 1963, for such claims;

16. Complaints with incomplete details and those that are not specific/actionable in nature;

17. Complaints lodged through an advocate (except where the advocate himself is the aggrieved person);

18. Complaint in the nature of offering suggestions or seeking guidance or explanation.

For redress of his grievance, the complainant must first approach the concerned RE. If the RE does not respond within a period of 30 days after lodgment of the complaint or rejects the complaint wholly/partly or if the complainant is not satisfied with the response/resolution given by the RE, the complainant can lodge his complaint under the RB-IOS, 2021.

Approaching the RBI Ombudsman without first lodging a complaint with the RE or doing so before 30 days after lodging the complaint, if there is no response from the RE, would make the complaint non-maintainable under RB-IOS, 2021.

It may be noted that the complaint should be made to the RBI Ombudsman not later than one year after receiving the reply of the RE or, in cases where no reply is received, not later than one year and 30 days after the date of the representation to the RE.

A complaint can be filed through any of the following methods:

1. Online - on CMS portal of RBI at https://cms.rbi.org.in.

2. Physical complaint (letter/post) in the form as specified in Annexure ‘A’ in the Scheme to “Centralised Receipt and Processing Centre, 4th Floor, Reserve Bank of India, Sector -17, Central Vista, Chandigarh - 160017”.

3. Complaints with full details (please refer to Question 17 below) can be sent by email (crpc@rbi.org.in).

The complainant is required to provide the following details

1. Name of the complainant, age and gender;

2. Full postal address of the complainant with personal e-mail ID, mobile number (mandatory to receive notifications), and landline number (if available);

3. Name and address of the branch or office of the RE against which the complaint is filed;

4. Complete facts giving rise to the complaint, including, transaction date and details, the details of the complainant’s account number, debit card or credit card number to the extent that they are relevant to the subject matter of the complaint;

5. Date and details of the representation submitted to the RE for redressal of grievance and reply, if any, received from the RE;

6. The nature and extent of the loss caused to the complainant; and

7. The relief sought; along with

8. Declaration that the complaint is not non-maintainable as per Clause 10 of the RB-IOS 2021.

Note: The complainant shall submit, along with the complaint, copies of the relevant documents supporting the complaint.

After a complaint gets successfully registered, it is assigned a complaint number. An acknowledgement indicating this complaint number is sent to the complainant through SMS on the mobile number and through e-mail at the email id provided at the time of filing the complaint. The status of the complaint can be checked by using the mobile number and the complaint number (received on the mobile) through the following link: https://cms.rbi.org.in.

The status of the complaint can also be ascertained by the complainant from the Contact Centre at CRPC, Chandigarh by contacting the toll-free number 14448.

The speed of redress depends on a number of factors like complexity of the case, timely submission of documents by the RE, volume of complaints in Ombudsman offices etc.

However, under the new System, CMS sends instant notifications to the complainant and RE and functions as single point reference for all complaint related communication for both parties, thereby obviating undue delays. All other things remaining the same, complaints lodged on CMS directly with all details get speedier redress.