​RBI Enforces Strict Declarations and Limits on Rupee Forex Trading

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NEW DELHI — The Reserve Bank of India has tightened operating regulations for foreign exchange derivative markets to enhance market discipline, improve risk management systems, and deter speculative exposures. In a comprehensive circular issued on October 10, the banking regulator placed an immediate prohibition on rebooking cancelled rupee-linked foreign exchange derivative contracts, drastically lowered the limits for transactions executed without documented underlying exposure, and instituted cash reserve provisions for select high-value contracts. The measures require authorised dealer banks and institutional participants to overhaul their internal trade booking mechanisms, record-keeping standards, and statutory reporting frameworks. Central to the regulatory review is curbing market participants who book large-scale foreign currency derivatives under the guise of hedging regular corporate risk without presenting verifiable underlying documentation.

​Ban on Rebooking Cancelled Contracts

​Under the newly issued framework, authorised dealer banks are explicitly barred from allowing market users to rebook rupee-linked currency derivative contracts once those users have opted to cancel them following the issuance of the directives. This ban applies uniformly across both deliverable transactions, which entail the direct exchange of foreign currencies upon settlement, and non-deliverable trades that settle without foreign currency exchange. Regulatory provisions that permit contract extensions at expiry, known in institutional parlance as rollovers, will remain in effect. By differentiating between standard rollover procedures and outright trade cancellations, the central bank aims to eliminate recurring booking churn that could escalate systemic risks across over-the-counter currency desks.

​Sharp Reduction in Unhedged Trading Thresholds

​The regulator has slashed the transaction ceiling for rupee-linked derivative positions entered into without proof of underlying exposure from 100 million dollars to the equivalent of 5 million dollars. This revised 5 million dollar cap applies across all authorised dealers, compelling market participants to verify aggregate exposure before seeking forward contracts with multiple counterparties. The identical limit cut from 100 million dollars to 5 million dollars has also been mandated for exchange-traded currency derivatives, where the revised ceiling will apply cumulatively across all recognised domestic stock exchanges. Market authorities expect this synchronized curb across over-the-counter and exchange segments to curb unbacked speculative positioning in domestic foreign exchange trading.

​Mandatory Declarations and Cash Reserve Rules

​To plug documentary gaps, the central bank has mandated that authorised dealers obtain a formal written declaration from clients whenever a contract is booked to hedge a specific commercial risk. Within this declaration, users must affirm that they have not entered into overlapping transactions with another authorised dealer against that same underlying commercial exposure, shifting greater verification burdens onto dealer institutions. Alongside documentation reforms, the central bank introduced a Foreign Exchange Risk Reserve framework requiring authorised dealers to hold a 20 percent cash reserve with the Reserve Bank against rupee-linked contracts whose notional value exceeds the equivalent of 2 million dollars. Although exact operational modalities, calculation schedules, and deposit mechanics for the reserve mandate await further guidance from the official circular, the revised norms mandate full alignment of bank trading protocols and risk buffers.

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