Procedure for Acceptance of Deposits from Members

Acceptance of Deposits from Members

Applicable Sections
Sections 73 , 76A and 110 of the Companies Act, 2013

Applicable Rule
Companies (Acceptance of Deposits) Rules, 2014

Synopsis
Prohibition on acceptance of deposits from public : A company is prohibited to invite, accept or renew deposits from public. This prohibition would, however, not apply in case of banking company and non banking financial company and such other company as the Central Government may specify.

•It can, however, invite deposits from its members subject to passing of a resolution in general meeting, (such a resolution could be passed through postal ballot also) and subject to, inter alia, the conditions specified below:

(a) depositing such sum which shall not be less than fifteen per cent of the amount of its deposits maturing during a financial year and the financial year next following, and kept in a scheduled bank in a separate bank account to be called as deposit repayment reserve account. This account shall not be used by the company for any purpose other than repayment of deposits;

(b) providing such deposit insurance in such manner and to such extent as may be prescribed ;(c) certifying that the company has not committed any default in the repayment of deposits accepted eitherbefore or after the commencement of the Companies Act, 2013 or payment of interest on such deposits ;
And

(d) providing security, if any for the due repayment of the amount of deposit or the interest thereon including the creation of such charge on the property or assets of the company. Where a company does not secure the deposits or secures such deposits partially, then, the deposits shall be termed as“unsecured deposits’’.

Penal consequences : Section 76A inserted by the Companies ( Amendment) Act, 2015 provides for penal consequences for acceptance of deposits in contravention of the provisions of the Act. Accordingly when a company:

•(a) accepts, invites or allows another person to accept or invite on its behalf any deposit which is in contravention to the provisions specified in the Act or rules under it ; or
(b) fails to repay the deposit or any interest, either in part or whole, within the time specified in the Act, or further time allotted by a Tribunal, it shall be subject to certain penalties. The penalties include:

(i) a minimum fine of Rs one crore and a maximum of Rs 10 crore, in addition to the deposit or interest that is due; and
(ii) up to seven years imprisonment and fine between Rs 25 lakh to Rs two crore, or both, for every defaulting officer of the company;
If proved that the defaulting officer of the company did so willfully, he will be liable for the offence of fraud.

Procedure
1. Board meeting : A Board meeting shall be convened to decide about inviting deposits from members and the text of the advertisement to be published in the newspaper and to decide convening of general meeting

2. General meeting : The general meeting shall be convened to accord approval for invitation and acceptance of fixed deposits from members.

3. Form MGT-14 shall be filed with the Registrar within 30 days of passing the resolution.

4. Form and particulars of advertisements or circulars: The company inviting deposit shall issue a circular to all its members by registered post with acknowledgement due or speed post or by electronic mode in Form DPT-1. The circular may also be published in English language in an English newspaper and in vernacular language in a vernacular newspaper having wide circulation in the State in which the registered office of the company is situated.
Before the issue, a copy of the advertisement or circular is to be delivered to the Registrar not less than thirty days before the date of such issue. [rule 4]

5. Deposit insurance : The company inviting deposits shall enter into a contract for providing deposit insurance at least thirty days before the issue of the circular or advertisement or at least thirty days before
the date of renewal, as the case may be. [rule 5]
The companies may accept the deposits without deposit insurance contract till the 31st March, 2016 or till the availability of a deposit insurance product, whichever is earlier.

6. Creation of security : Company inviting secured deposits shall provide for security by way of a charge on its assets as referred to in Schedule III of the Act, excluding intangible assets of the company for the due repayment of the amount of deposit and interest thereon for an amount which shall not be less than the
amount remaining unsecured by the deposit insurance. [rule 6]

7. Appointment of trustee for depositors : No company shall issue a circular or advertisement inviting secured deposits unless the company has appointed one or more trustees for depositors for creating security for the deposits. The company shall execute a deposit trust deed in Form DPT-2 at least seven days before issuing the circular or circular in the form of advertisement. [rule 7]

8. Maintenance of liquid assets and creation of deposit repayment reserve account : Every company referred to in sub-section (2) of section 73 and every eligible company shall on or before the 30th day of April of each year deposit the sum as specified in clause (c) of sub-section (2) with any scheduled bank and the amount so deposited shall not be utilised for any purpose other than for the repayment of deposits.
The amount remaining deposited shall not at any time fall below fifteen per cent of the amount of deposits maturing, until the end of the current financial year and the next financial year. [rule 13]

9. Register of deposits: Every company accepting deposits shall maintain at its registered office one or more separate registers for deposits accepted or renewed, in which there shall be entered separately in the case of each depositor the particulars as specified under rule 14

10. Return of deposits to be filed with the Registrar : Every company accepting deposits from members, shall on or before the 30th day of June, of every year, file with the Registrar a return in Form DPT-3 alongwith the fee as provided in Companies (Registration Offices and Fees) Rules, 2014 and furnish the information contained therein as on the 31st day of March of that year duly audited by the auditor of the company. [rule 16]

BOARD RESOLUTION
(for inviting deposits from the members)
“RESOLVED THAT pursuant to the provisions of section 73 and all other applicable RESOLVED FURTHER THAT the Board of Directors or a Committee thereof be and is hereby authorised to amend the terms and conditions of the said scheme as and when required and to sign and execute deeds, applications, documents and writings that may be required on behalf of the Company and generally to do all such other acts, deeds, matters and things as may be necessary, proper and expedient or incidental for giving effect to this resolution.” provisions of the Companies Act, 2013 read with Companies (Acceptance of Deposit) Rules, 2014 as may be amended from time to time and clarifications/guidelines issued by the Central Government, and subject to the consent of the members of the company, consent of the Board of Directors of the Company be and is hereby accorded to invite and accept fixed deposits from the members within limits prescribed in the Act and overall borrowing limits of the Company, as approved by the members from time to time and the draft of the Circular for inviting / accepting Deposits from the Members and the terms and conditions contained therein and as given in the Explanatory Statement annexed hereto, be and the same is hereby approved.

GENERAL MEETING RESOLUTION
(for acceptance of deposits from members)
““RESOLVED THAT pursuant to the provisions of section 73 and all other applicable provisions of the Companies Act, 2013 read with Companies (Acceptance of Deposit) Rules, 2014 as may be amended from time to time and clarifications/guidelines issued by the Central Government, and subject to the consent of the members of the company, consent of the Board of Directors of the Company be and is hereby accorded to invite and accept fixed deposits from the members within limits prescribed in the Act and overall borrowing limits of the Company, as approved by the members from time to time and the draft of the Circular for inviting / accepting Deposits from the Members and the terms and conditions contained therein and as given in the Explanatory Statement annexed hereto, be and the same is hereby approved. section 73 and all other applicable provisions of the Companies Act, 2013 read with Companies(Acceptance of Deposit) Rules, 2014 as may be amended from time to time and clarifications/guidelines issued by the Central Government, consent of the members be and is hereby accorded to the Board of Directors of the Company to invite and accept fixed deposits from the members within limits prescribed in the Act and overall borrowing limits of the Company, as approved by the members from time to time and the draft of the Circular for inviting / accepting Deposits from the Members and the terms and conditions contained therein and as given in the Explanatory Statement annexed hereto, be and the same is hereby approved.”

“RESOLVED FURTHER THAT the Board of Directors or a Committee thereof be and is hereby authorised to amend the terms and conditions of the said scheme as and when required and to sign and execute deeds, applications, documents and writings that may be required on behalf of the Company and generally to do all such other acts, deeds, matters and things as may be necessary, proper and expedient or incidental for giving effect to this resolution.”


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