Why Financial market players are not availing benefits of Central Know Your Customer (CKYC) database?

What is CKYC?

Probably some senior persons in the banking industry are aware of the formation of Central KYC registration agency in 2011 and its role etc.

CKYC stands for Central KYC which is a centralised repository which allows storage of personal information of the customer centrally. Earlier, when a customer went to a financial institution for buying any product, KYC (Know Your Customer) was needed to be done each time for each product and with each institution (company) separately. With Central KYC or CKYC “Know Your Customer” (KYC) norms are completed centrally once, all financial institutions can access them and use them and with that things were expected to change.

The Central KYC (CKYC) process allows all the records of customers to be stored digitally which will, in turn, help financial entities to avoid re-doing KYC for each customer. By accessing data available with Central Registry of Securitization and Asset Reconstruction and Security Interest in India (CERSAI) each financial institution can find out whether the customer is KYC compliant or not, retrieve their KYC data, and by doing so make their internal process seamless by taking this KYC data and not asking the customer for the same. This ensures that the customer is not bothered each time by asking the same set of information or documents repeatedly. Financial institutions that are regulated by RBI, SEBI, IRDA & PFRDA tie-up with CERSAI to perform CKYC.

Section 73 of the Prevention of Money Laundering Act, 2002, gave the central government the authority to frame various rules and regulations to curb down on the black money. With this authority, the Central Government introduced CKYC to ensure one KYC for individuals

CKYC was first announced by the Government of India in the 2012-13 Union Budget and went live in July 2016. Central KYC (CKYC) is managed by The Central Registry of Securitization and Asset Reconstruction and Security Interest in India (CERSAI). So, with CKYC, once your KYC is done, it does not need to be done again Central KYC Registry CKYC registry is the centralized repository of records for the customers in financial services.

The Central Registry of Securitisation Asset Reconstruction and Security Interest (CERSAI) is the supreme body that manages the CKYC registry.

CKYC ensures that inter-usability of KYC records and data making sure that the consumer does not have to do KYC each time when opening a financial relationship with an entity. You can do CKYC with a bank, the insurance company, Mutual Fund Company, a stockbroker, an NBFC etc. To do your Central KYC process, you can approach any Mutual Fund distributor (provided they are regulated by SEBI), visit the office of a Mutual Fund house or can even approach a registrar. With a correctly filled CKYC form, photocopies of the required documents need to be attached. The form and documents then have to be physically verified and attested. For this, an in-person verification (IPV) needs to be carried out. For NRI (Non-Resident Indians) investors, they are authorised to attest the KYC documents and carry out an in-person verification (IPV) when they are in India.

CERSAI assigns KYC Identification Number (KIN) to an eligible application within 4-5 working days of its submission. An SMS is sent to registered mobile number along with an email as soon as the KYC Identification Number or KIN is generated for a KYC account.

Types of CKYC Accounts There are three types of accounts in the CKYC form:

1. Normal KYC account For normal KYC account, you can submit any of the six official documents as proof of identity. Those documents are PAN card, Aadhaar card, Driving licence, Voter Id, Passport, and NREGA Job Card.

2. Simplified or Low-Risk KYC Account This type of account holders are the ones who cannot submit any of the above mentioned six officially valid documents (OVD) and are classified as “low risk” by banks. Such customers often face problems in submitting identity proof or residence proof while doing a KYC process. Such customers can do CKYC by submitting any one of the following: A proof of identity with photo issued by the state/central government departments, public sector undertakings (PSUs), statutory/regulatory authority, public financial institutions and scheduled commercial banks. Letter with a duly attested photo of the person issued by a gazetted officer. Such type of accounts will have a prefix ‘L’ to it.

3. Small account Individuals who do not possess any kind of officially valid documents can open a small account with banks. These accounts can be opened by submitting a self-attested photograph along with a signed application. These accounts are initially valid for 12 months and can be extended for another 12 months if the customer produces a document that shows that they have applied for any one of the officially valid document. These types of KYC accounts come with a prefix of ‘S’.

Thus, the mechanism of Central KYC (CKYC) was brought into to make life easier for customers. by completing CKYC process with any bank, Mutual Fund, or any insurance company, one will be KYC compliant, and subsequently, one does not have to do this process again anywhere. Central KYC (CKYC) will store all the customer information at one central server that is accessible to all the financial institutions.

Central KYC (CKYC) seeks other additional details of the customer like maiden name, the name of mother, in the case of minors details of related persons, proof of permanent address where the local or corresponding address is not same etc. Behind CKYC, there is  CERSAI- Central Registry of Securitization Asset Reconstruction and Security Interest. As mentioned earlier CERSAI is an online security interest registry of the country. It is authorized by the Central Government of India to act as a governing body and perform the duties of the Central KYC Records Registry under the PMLA (Prevention of Money-Laundering) rules, 2005. This includes receiving, storing, guarding, and retrieving the KYC records of an investor in the digital form.

We will go one step back and see what is the difference between Normal KYC, eKYC and CKYC:

KYC: KYC means Know Your Customer. This is the normal and regular process carried out in the Financial sector industry. Any financial institution to authenticate the identity of an investor/customer verification is done based on submission of a correctly filled KYC form along with required documents. It is then followed by an In-Person Verification(IPV), a process which verifies the documents and identity of the person for which KYC is being done.

eKYC:

Electronic KYC or eKYC is a KYC process done with the help of the Aadhaar Card of the customer. During the eKYC process, the verification of the identity of the customer can be done by either of the following two methods:

1. One Time Password (OTP). The investor will receive an OTP on their registered mobile number. On successful verification, the investor is entitled to invest up to INR 50,000 per year per Mutual Fund House.

2. Biometric verification With the help of biometric verification (thumb or retina scan), an investor can invest without any limitations. CKYC OR Central KYC CKYC is the new single platform KYC for all financial products. It is a one-time process that one needs to undergo. A Change for a Better Future There are some issues with the introduction of Central KYC (CKYC) like technical glitches in registration, the slow handover of data to CERSAI etc. Moreover, this process seems to replace both Aadhaar and PAN identification. Also, with the requirement of disclosure of information such as mother’s name, maiden name etc. investors need to go through the whole KYC process again. But to look on the brighter side, the Central KYC (CKYC) registry has been set up to spread the culture of saving and transparent investments.

CKYC:

As stated in the beginning process which required KYC to be completed for each product or with every institution now needs to be done only once. All the data gathered from eKYC process is uploaded on the central database created for the purpose by KRA Registration Agency (KRAs). It eliminates waste of time, resources, money and manpower, making the system more efficient.

How one would know if one has CKYC?

CKYC  unique KYC identifier is 14-digit KYC Identification Number (KIN) or a CKYC number which is mainly linked with ID proof / PAN

The client should not be compelled to providing KYC documents again. It’ll merely search with your PAN in the KRA database and download the copies of the document previously uploaded by broker X. If your address hasn’t changed, you may proceed with your account opening by only giving your bank account details (bank account details aren’t part of KYC) and signing the forms.

The modern world is such that people want things to happen in a matter of a few minutes. The old process of starting a financial relationship with a financial company was tedious and you had to submit KYC documents. With the introduction of CKYC registry, the documentation process should have become simpler, quicker and, most importantly safer.

While there were some early issues in the year 2016, it was hoped that with time should have been sorted out making CKYC or central KYC a standard practice for the industry and In the long run, this will benefit the industry and the consumer most importantly.

What prompted me to write this article:

My recent experience about CKYC & concern 

Recently I spoke to one bank’s branch who had no clue about the existence of any guidelines issued by their corporate office to accept CKYC download data instead of doing paper-based KYC. Request to accept just done CKYC (KIN was provided) was not accepted and had to undergo full/proper KYC.

The government wanted CKYC for individuals in the first phase. The very purpose of introducing a mechanism, setting up CERSAI formulating technological processes of registering / uploading,  modifying and downloading the KYC data with the due legal backing to the whole mechanism would be futile if financial institutions, as well as clients, continue to have no clue about the existence of this mechanism. 

I had also written to RBI to insist upon banks to start using CKYC data by issuing an exclusive circular. I had also written to the Ministry of Finance/Govt of India to take up the matter Financial Stability Development Council (FSDC)” for coordination with other financial sectors regulators.

I am aware that banks pass on the data to their regional /corporate office that with the support of customised software upload information on the website of CERSAI.

I know even coop banks do collect CKYC data and upload it. Unless the database is rich and current it will not be useful. To avoid duplications cases where CKYC number (KIN) is assigned and is within one year from the date on which it is being used no subsequent upload needed). I am of the view that unless all banks are forced to implement by a given deadline (date) it will not get implemented and the system will not derive its fruits.

The success of the system would depend on the rich database, its seamless upload and retrieval mechanism, and cost (minimal fees for upload/updating and download) of such data.

Apart from this the financial sector employees at banks, insurance sector, SEBI regulated entities should make more and more use of this database to provide comfort with its clients, in terms of reduction in customer on-boarding time and stationary cost, convenience etc.

I have seen that unless there is a regulatory push no new things move. I wish RBI, IRDA, PFRDA push for its use by banks and their regulated entities for the system to enjoy the benefits of mechanism.

I do not know whether I miss something as I could not see any RBI’s directions/circulars directing banks to make use of this database to reduce hardship to customers.

I understand that SEBI regulated entities like some MFs are following this mechanism (which started at the behest of SEBI). For others as of now from utility, ease and duplication point of view, CKYC it is as good as scrap.

In many banks I have noticed the following restrictive practices also:

customer A and customer B have a joint account and want to open another joint account in the reverse B with A or a new account in single name of A or B, branch staff call for photograph/s and ID and address proof again for their records about this account and again upload at ‘CERSAI’ platform.  Many branches of bank insist re-submission of KYC documentation at their branch through there is a valid KYC of the customer/s at some other branch (and has required data in the bank’s database).

To avoid duplication RBI may issue detailed directions to banks to high light the fact that it is a ‘Know Your Customer (KYC)’ and not ‘Know Your Account’ meaning account wise separate customer identification and address confirmation.  

I reiterate unless the bank branches are categorically told to comply CKYC directions nobody will follow. Further, a close follow-up is required by all the regulators to see that the government’s directions are followed in letter and spirit.

I appeal to regulators to take strict action (as 95% of banks, FI’s are doing fresh KYC/ Re-KYC each time). CKYC database can address the problem of RE-KYC or KYC update (Re-KYC) to a major extent.

To ensure the success CKYC the mechanism one should start using it aggressively for downloads as well. Otherwise, a big database that has been built over years, updated etc would otherwise be another white elephant.

Though I am not the very hopeful success of this CKYC system (that has some serious flaws) in banking and insurance segment, having gone ahead all along with this and spent considerable time, money, resources and energy with continued on-going costs (without using it) for last many years, before giving it up one should do serious attempts to make it a success.

I think this subject can as well go at “Financial Stability Development Council (FSDC)” as it is a matter of inter-regulatory coordination.

Financial sector clients and e media, Print media should increase awareness and assert the Govt, Financial segment Regulators as to why they are wasting the national resources, money, time around the mechanism that had been built in and run for over many years.