Same-Day Requests at a Semi-Urban Branch
On a Monday morning, the manager of a semi-urban branch receives three requests. First, a resident customer wants to remit USD 40,000 to a Canadian university for her son's tuition; the branch is not an authorised dealer branch. Second, a customer who has held a locker for two years wants to add her daughter as nominee; the locker clerk says nomination is compulsory and refuses to accept the form. Third, a customer reports an unauthorised UPI debit of ₹18,000 that occurred ten days earlier; the teller says the bank can act only if the customer reports within three days. The branch's compliance officer is on leave, and the manager must decide what can be done the same day, what must be referred, and what must be corrected in the branch's stated positions. The manager also has to record the decisions in the branch's complaint register.
1. Evaluate each of the three requests and state what the branch can and cannot do.
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1. USD 40,000 education remittance. The amount is within the Liberalised Remittance Scheme limit of USD 250,000 per financial year for a resident individual, assuming no other LRS remittances and valid purpose documentation. However, this branch is not an authorised dealer, so it cannot process the remittance itself. The correct action is to explain the LRS position, refer the customer to an AD Category-I branch or bank, and list the documents needed-passport, university offer letter, fee schedule, and the prescribed remittance form. Do not accept the application and hold it, because that creates a misleading expectation.
2. Locker nomination. The clerk is wrong. RBI's locker directions do not make nomination compulsory, but a customer who wishes to add a nominee must be allowed to do so. The branch should accept the nomination form, verify the customer's identity, update the locker record, and give an acknowledgement. If a customer declines nomination, the branch may obtain a declaration but cannot refuse locker service on that ground alone.
3. Unauthorised UPI debit. The teller's three-day statement is also wrong as a blanket rule. The customer can report later; delay may affect the liability determination, but it does not extinguish the complaint. The branch must register the complaint, acknowledge it with a reference number, preserve the transaction logs, and route it to the bank's unauthorised-transaction and chargeback process under the RBI customer-protection framework. Do not promise zero liability at the counter; explain that the bank will investigate.
2. Identify the compliance errors in the branch's stated positions and explain the correction for each.
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Error 1: Treating locker nomination as compulsory. This misstates the RBI locker framework and can lead to a wrongful refusal of service. Correction: withdraw the refusal, accept the nomination, train the locker clerk, and record the correction in the branch's complaint/feedback log.
Error 2: Telling the UPI customer that only a three-day report is valid. The three-working-day threshold is relevant to the zero-liability regime in the RBI unauthorised electronic transaction framework, not to whether a complaint can be filed. Correction: register the complaint even though ten days have passed, investigate, and apply the applicable liability rules based on the facts. The branch should not deter a customer from reporting.
Error 3: Risk of handling an LRS remittance without AD authorisation. If the branch processed the remittance itself, it would breach the authorised-dealer framework. Correction: refer the customer to an AD Category-I branch and do not issue any undertaking that the remittance has been accepted. Record the referral so that the customer's visit is not repeated unnecessarily.
3. Set out the same-day action plan the branch manager should follow and the records to maintain.
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Remittance: Give the customer a written referral to the nearest AD Category-I branch, confirm that USD 40,000 is within the LRS annual limit subject to verification, and provide a checklist of documents. Do not collect the remittance form at this branch.
Locker: Apologise for the incorrect advice, accept the nomination form, verify identity, update the locker record, and issue an acknowledgement. Brief the locker clerk on the optional nature of nomination.
UPI complaint: Register the complaint with a timestamp and reference number, give the customer a copy, preserve the UPI transaction ID and bank logs, initiate the chargeback/unauthorised-transaction workflow, and explain the investigation process without promising a specific liability outcome.
Records: Enter all three items in the complaint/instructions register, note the staff briefing, and flag the UPI case to the fraud/operations team. If the customer's UPI complaint later escalates, the branch should be able to show that it acted promptly despite the ten-day delay.