Circular No. 14/2019/TT-NHNN Amending and Supplementing Certain Articles in Circulars Regarding the Regular Reporting System of the State Bank of Vietnam

CIRCULAR

Amending and supplementing certain articles in the Circulars stipulate on regular reporting requirements of the State Bank of Vietnam 

Pursuant to the Law on the State Bank of Vietnam dated June 16, 2010;

Pursuant to the Law on Credit Organizations dated June 16, 2010;

Pursuant to the Law Amending and Supplementing Certain Articles of the Law on Credit Institutions dated November 20, 2017;

Pursuant to Decree No. 09/2019/NĐ-CP dated January 24, 2019 of the Government stipulating the reporting system of administrative agencies;

Pursuant to Government Decree No. 16/2017/NĐ-CP dated February 17, 2017 on the functions, tasks, powers, and organizational structure of the State Bank of Vietnam;

At the proposal of the Director of the Office of the State Bank of Vietnam;

The Governor of the State Bank of Vietnam issues this Circular to amend and supplement certain provisions in of the Circulars stipulating the regular reporting requirements of the State Bank of Vietnam.

Article 1. Amending and supplementing the regulations on reporting requirements

1. Amending and supplementing the reporting requirements for credit information activities pursuant to Circular No. 16/2010/TT-NHNN dated June 25, 2010, issued by the Governor of the State Bank of Vietnam guiding the implementation of Government Decree No. 10/2010/NĐ-CP dated February 12, 2010, on credit information activities (hereinafter referred to as Circular No. 16/2010/TT-NHNN), as follows:

Clause 17 of Circular No. 16/2010/TT-NHNN (amended and supplemented by Clause 6 of Article 1 of Circular No. 27/2014/TT-NHNN dated September 18, 2014, issued by the Governor of the State Bank of Vietnam regarding the amendment and supplementation of certain provisions of Circular No. 16/2010/TT-NHNN) shall be amended and supplemented as follows:

"Article 17. Reporting on credit information activities

1. Credit information companies shall directly send or send through postal services to the State Bank of Vietnam (the Banking Supervision Department) the following written reports:

a) Quarterly and annual financial statements as prescribed by law;

b) Report on business operations according to Form No. 06/TTTD issued together with this Circular;

c) Emergency report when major IT incidents occur (such as software/hardware failure; network system attacks causing the system to become unreliable and operate abnormally) according to Form No. 07/TTTD issued together with this Circular.

d) Report according to Form No. 07/TTTD issued together with this Circular when any of the following changes occur:

- Management personnel;

- Number of credit institutions, foreign bank branches committed to providing credit information;

- Agreement on the process of collecting, processing, storing, and providing credit information between the credit information company and credit institutions, foreign bank branches that have committed;

- Information infrastructure.

2. Time limit for submitting reports:

a) Reports specified in point a and b, Clause 1 of this Article shall be submitted regularly quarterly and annually as follows:

- Quarterly report sent before the 20th day of the month immediately following the quarter being reported;

- Annual report on business operations sent before February 15 of the year immediately following the year being reported;

- Annual financial report must be audited and sent before April 15 of the year immediately following the year being reported;

b) Reports specified in point c, Clause 1 of this Article must be reported immediately on the day the incident occurs. If the incident occurs on a weekly holiday or public holiday, it should be reported on the first working day after the holiday.

c) Reports specified in point d, Clause 1 of this Article must be submitted within seven working days from the date of change.

3. Time for finalizing report data:

a) For reports specified in point a and point b, Clause 1 of this Article, the data closing time for each reporting period corresponds to the accounting period as prescribed by the Accounting Law.

b) For reports specified in point c and point d, Clause 1 of this Article, the data closing time for the report is determined based on the specific content required to be reported when it arises or when there is a change."

2. Amending and supplementing the reporting requirements for ATM operation status pursuant to Circular No. 36/2012/TT-NHNN dated December 28, 2012, issued by the Governor of the State Bank of Vietnam on the provision, management, operation, and ensuring the safety of automatic teller machines (hereinafter referred to as Circular No. 36/2012/TT-NHNN), as follows:

Article 10 of Circular No. 36/2012/TT-NHNN (amended and supplemented by Clause 4, Article 1 of Circular No. 44/2018/TT-NHNN dated December 28, 2018 issued by the Governor of the State Bank of Vietnam to amend and supplement certain articles of Circular No. 36/2012/TT-NHNN) is amended and supplemented as follows:

 "Article 10. Information and Reporting

1. Payment service providers, State Bank branches in the area where ATMs are deployed and installed shall be responsible for reporting to the State Bank of Vietnam as follows:

a) Reporting in accordance with the regulations of the State Bank of Vietnam on statistical reporting systems applicable to credit institutions and foreign bank branches, and when required by competent authorities under the law;

b) Reporting on ATM operations for the first six months of the year and annual reports as follows:

- Method of sending and receiving reports: The report shall be prepared in writing and sent to the State Bank of Vietnam (Payment Department) through one of the following methods: direct submission, postal service, or the electronic mail system of the State Bank;

- Data closing date: from December 15 of the year prior to the reporting period to June 14 of the reporting period for the six-month report, and from December 15 of the year prior to the reporting period to December 14 of the reporting year for the annual report.

- Deadline for submitting the report: no later than July 15 of the reporting year for the six-month report, and no later than January 15 of the following year for the annual report.

- Outline of the report according to Form No. 4 (for payment service providers) and Form No. 5 (for State Bank branch) issued together with this Circular.

2. Payment service providers shall be responsible for reporting to the State Bank (Payment Department) as follows:

a) Reporting on upgrading the ATM system in writing, directly submitted or via postal service, at least 10 days before the upgrade implementation date.

b) Reporting on abnormal issues arising in the ATM system: Upon discovering any abnormal issues that may cause risks or security breaches in their own ATM system and in other payment service providers' ATM systems, payment service providers shall notify the State Bank via email address[email protected]within 24 hours regarding the contents including the time of occurrence, description of the incident, impact, risks in their own ATM system and in other payment service providers' ATM systems, cause of the incident, and measures taken. At the same time, they shall prepare a written report and submit it directly or via postal service within three working days from the date of notification to the State Bank of Vietnam."

3. Amending and supplementing the reporting system on the commercial bank's operational network as stipulated in Circular No. 21/2013/TT-NHNN dated September 9, 2013 issued by the Governor of the State Bank of Vietnam on the commercial bank's operational network (hereinafter referred to as Circular No. 21/2013/TT-NHNN) as follows:

Clause 2, Article 28 of Circular No. 21/2013/TT-NHNN is amended and supplemented as follows:

"2. Every six months and annually, prepare a written report and submit it directly or via postal service to the State Bank (Bank Inspection and Supervision Authority) and the State Bank branch where the commercial bank's headquarters is located, containing the contents specified in Appendix No. 02 issued together with this Circular. Among which:

a) Reporting deadline:

- The mid-year report: no later than July 31 each year.

- The annual report: no later than January 31 of the following year.

b) The data cut-off time for each reporting period corresponds to the accounting period as prescribed in the Accounting Law."

4. Amending and supplementing the reporting system on cash security work as stipulated in Circular No. 01/2014/TT-NHNN dated January 6, 2014 issued by the Governor of the State Bank of Vietnam on the handover, storage, and transportation of cash, precious metals, and securities (hereinafter referred to as Circular No. 01/2014/TT-NHNN) as follows:

Article 69 of Circular No. 01/2014/TT-NHNN shall be amended and supplemented as follows:

“Article 69. Report on Vault Security Work

Annually, State Bank of Vietnam branches, credit institutions, and foreign bank branches shall report on vault security work according to the following contents:

1. Content of the report: Report on the situation, results achieved, existing issues, and limitations in vault security work.

2. Receiving authority and reporting deadline:

- Credit institutions and foreign bank branches shall submit their reports to the State Bank of Vietnam branch in their locality and superior credit institution or foreign bank branch (if any) before January 1 of the year immediately following the reporting year.

- State Bank of Vietnam branches, credit institutions, and foreign bank branches shall compile and submit their reports to the State Bank of Vietnam (Issue Department and Vault Division) before January 15 of the year immediately following the reporting year.

3. Method of submission and receipt of reports: Reports shall be prepared in paper form and submitted directly or through postal services.

4. Data cut-off period: From December 15 of the year preceding the reporting period to December 14 of the reporting period.

5. Outline of the report: In accordance with Model No. 01 issued together with this Circular.”

Article 9 of Circular No. 03/2014/TT-NHNN shall be amended and supplemented as follows:

“Article 9. Reporting to the State Management Authority

1. Annually, no later than July 15, cooperative banks shall be responsible for submitting a report on the six-month operation of the Safety Assurance Fund to the State Bank of Vietnam (Supervisory Authority) according to Model No. 01 issued with this Circular.

2. Annually, no later than 45 days after the end of the fiscal year, the cooperative bank shall be responsible for submitting the following reports to the State Bank of Vietnam (Bank Inspection and Supervision Authority):

a) A report on the operational situation and financial status of the Preservation Fund for the previous year using Form No. 02 issued together with this Circular;

b) A report on the results of internal audit supervision by the Audit Committee of the cooperative bank regarding the operational situation and financial results of the Preservation Fund using Form No. 03 issued together with this Circular.

3. Ad hoc reports upon request of the State Bank of Vietnam.

4. The reports under Clause 1, 2, and 3 of this Article shall be prepared in paper form and submitted directly or through postal services to the State Bank of Vietnam (Supervisory Authority).”

6. Amend and supplement the reporting regime on management and use of the State Bank of Vietnam's digital certificate at Circular No. 28/2015/TT-NHNN dated December 18, 2015, issued by the Governor of the State Bank of Vietnam on the management and use of digital signatures, digital certificates, and digital signature certification services of the State Bank of Vietnam (hereinafter referred to as Circular No. 28/2015/TT-NHNN) as follows:

Clause 1 of Article 17 of Circular No. 28/2015/TT-NHNN shall be amended and supplemented as follows:

“1. Periodic report on the management and use of digital certificates:

a) Name of the report: Cross-checking list of State Bank of Vietnam digital certificates.

b) Content of the report: List of digital certificates issued by the Service Provider of the State Bank of Vietnam's digital signature certification and usage status.

c) Implementing entities: Units under the State Bank of Vietnam, credit institutions, foreign bank branches, National Treasury, Deposit Insurance Corporation of Vietnam, and other organizations granted digital certificates by the State Bank of Vietnam.

d) Receiving authority: Information Technology Department - State Bank of Vietnam.

e) Method of submission and receipt of reports:

- Paper document, submitted directly or through postal services;

- Electronic report in Excel format sent via email to the address [email protected] or electronic report sent through the NHNN Online Public Service System.

g) Frequency and deadline for submission of reports: Semi-annually, no later than June 20 and December 20 of the reporting year.

h) Time period for data consolidation for reporting:

- Data cut-off period for the first half-year report is from December 15 of the year preceding the reporting period to June 14 of the reporting period.

- Data cut-off period for the second half-year report is from June 15 to December 14 of the reporting period.

i) Outline of the report: Form No. 09 issued together with this Circular.”

7. Amend and supplement the reporting regime on asset liquidation, asset distribution, and other emerging issues at Circular No. 24/2017/TT-NHNN dated December 29, 2017, issued by the Governor of the State Bank of Vietnam on procedures and formalities for revoking licenses and liquidating assets of credit institutions and foreign bank branches; procedures and formalities for revoking representative offices' licenses of foreign credit institutions and other foreign organizations engaged in banking activities (hereinafter referred to as Circular No. 24/2017/TT-NHNN) as follows:

Clause 4 of Article 17 of Circular No. 24/2017/TT-NHNN shall be amended and supplemented as follows:

“4. Within the first ten working days of each month or at any time deemed necessary, the Liquidation Supervision Team shall prepare a written report and submit it directly or through postal services to the State Bank of Vietnam branch, the Banking Inspection and Supervision Authority, Deposit Insurance Corporation of Vietnam, Governor of the State Bank of Vietnam, and Provincial People's Committee, reporting on the situation of asset liquidation, asset distribution, and other emerging issues according to Model No. 01 issued together with this Circular. If necessary, request relevant authorities to support credit institutions and foreign bank branches in recovering receivables and handling customers who intentionally cause loss of credit institution and foreign bank branch assets.”

8. Amend and supplement the reporting regime on special loan data at Circular No. 01/2018/TT-NHNN dated January 26, 2018, issued by the Governor of the State Bank of Vietnam on special loans to credit institutions under special control (hereinafter referred to as Circular No. 01/2018/TT-NHNN) as follows:

Clause 5 of Article 21 of Circular No. 01/2018/TT-NHNN shall be amended and supplemented as follows:

“5. On a monthly basis, within seven working days of the first month following the reporting month or when necessary, submit a written report directly or through postal services to the Governor of the State Bank of Vietnam on special loan data for credit institutions according to Appendix No. 04 issued together with this Circular. The data cut-off period for the report is from the first day to the last day of the reporting month.”

9. Amend and supplement the reporting regime on the internal control system in Circular No. 13/2018/TT-NHNN dated May 18, 2018, issued by the Governor of the State Bank of Vietnam on the internal control system of commercial banks and foreign bank branches (hereinafter referred to as Circular No. 13/2018/TT-NHNN) as follows:

Clause 1 of Article 7 of Circular No. 13/2018/TT-NHNN shall be amended and supplemented as follows:

"1. Commercial banks and foreign bank branches must prepare a written report and submit it directly or through postal services to the State Bank of Vietnam (Supervisory Authority) on the internal control system in accordance with Clauses 2, 3, and 4 of this Article."

10. Amend and supplement the reporting regime on incidents causing disruptions to payment system operations in Circular No. 20/2018/TT-NHNN dated August 30, 2018, issued by the Governor of the State Bank of Vietnam on supervising payment systems (hereinafter referred to as Circular No. 20/2018/TT-NHNN) as follows:

Point c of Clause 1 of Article 7 of Circular No. 20/2018/TT-NHNN shall be amended and supplemented as follows:

"c) Immediately notify the Supervisory Unit via email at [email protected] upon discovering an incident causing disruption to payment system operations exceeding 30 minutes to grasp and monitor the situation; send a written notification of the incident directly or through postal services or through the State Bank of Vietnam's reporting system as set out in Appendix IV attached hereto within three working days from the date of fully resolving the incident;"

11. Amend and supplement the reporting regime on the importation and use of imported goods by printing and minting establishments in Circular No. 38/2018/TT-NHNN dated December 25, 2018, issued by the Governor of the State Bank of Vietnam on the importation of goods for the activities of printing and minting money of the State Bank of Vietnam (hereinafter referred to as Circular No. 38/2018/TT-NHNN) as follows:

Clause 3 of Article 6 of Circular No. 38/2018/TT-NHNN shall be amended and supplemented as follows:

"3. Quarterly (no later than the 18th day of the first month of the next quarter), printing and minting establishments must report in writing and submit directly or through postal services to the State Bank of Vietnam (Currency Issuance and Treasury Department) on the importation and use of imported goods according to Model No. 01 issued together with this Circular. The data cut-off period for the report is from the 15th day of the previous month before the reporting period to the 14th day of the last month of the reporting quarter."

12. Amend and supplement the reporting regime on the results of implementing the remediation plan in Circular No. 46/2018/TT-NHNN dated December 28, 2018, issued by the Governor of the State Bank of Vietnam on the time limit, procedures, and formalities for transferring shares held by major shareholders and related parties of credit institutions (hereinafter referred to as Circular No. 46/2018/TT-NHNN) as follows:

a) Clause 2 of Article 4 of Circular No. 46/2018/TT-NHNN shall be amended and supplemented as follows:

"2. Before the 10th day of the first month of each quarter, the lead credit institution shall cooperate with other credit institutions and the relevant major shareholder group to report on the implementation results of the Remediation Plan of the previous quarter according to Model No. 01 issued together with this Circular, including:

a) List of shareholders holding shares in excess of the limit;

b) Results of remedying the shareholding ratio exceeding the limit;

c) In case the progress specified in the Remediation Plan has not been achieved, report any difficulties and obstacles (if any) and proposed solutions."

b) Supplement Clause 3a of Article 4 of Circular No. 46/2018/TT-NHNN as follows:

"3a. Reports under Clauses 2 and 3 of this Article must be prepared in written form and submitted directly or through postal services to the State Bank of Vietnam (Supervisory Authority)."

Article 2. Supplement and replace forms in the reporting regimes

Supplement and replace forms in the Circulars attached as appendices to this Circular as follows:

1. Supplement Appendix No. 01 including Forms No. 06/TTTD and Form No. 07/TTTD issued together with this Circular into Circular No. 16/2010/TT-NHNN.

2. Supplement Appendix No. 02 including Form No. 01 issued together with this Circular into Circular No. 01/2014/TT-NHNN.

4. Replace Form No. 09 issued together with Circular No. 28/2015/TT-NHNN with Form No. 09 in Appendix No. 04 issued together with this Circular.

5. Supplement Appendix No. 05 including Form No. 01 issued together with this Circular into Circular No. 24/2017/TT-NHNN.

6. Supplement Appendix No. 06 including Form No. 01 issued together with this Circular into Circular No. 38/2018/TT-NHNN.

7. Supplement Appendix No. 07 including Form No. 01 issued together with this Circular into Circular No. 46/2018/TT-NHNN.

Article 3. Responsibility for organizing implementation

The Heads of the Office, Heads of units under the State Bank of Vietnam, Governors of the State Bank of Vietnam branches in provinces and centrally-administered cities, Chairmen of the Board of Directors (Board of Members), General Directors (Directors) of credit institutions and foreign bank branches, National Treasury Corporation, Credit Information Companies, Printing and Minting Establishments, Deposit Insurance Corporation of Vietnam, and organizations providing payment services are responsible for organizing the implementation of this Circular.

Article 4. Effective Date

1. This Circular takes effect from October 15, 2019.

2. This Circular abolishes the following provisions:

a) Clause 6 of Article 1 of Circular No. 27/2014/TT-NHNN dated September 18, 2014, issued by the Governor of the State Bank of Vietnam on amending and supplementing certain provisions of Circular No. 16/2010/TT-NHNN;

b) Clause 4 of Article 1 of Circular No. 44/2018/TT-NHNN dated December 28, 2018, issued by the Governor of the State Bank of Vietnam on amending and supplementing certain provisions of Circular No. 36/2012/TT-NHNN./.

ANNEX NO. 01

Form No. 06/TTTD

REPORT

OPERATING SITUATION

(Quarter.../Year...) or (Year...)

I. Implementation of Credit Activities

1) List of credit institutions committed to providing information;

2) Detailed list of sources of information outside the committed credit institutions;

3) List of main indicators regarding borrowers, frequency of data collection and update;

4) Classification and number of borrowers by each borrower group;

5) Number of products provided to each user group;

6) Operation status of technological equipment, ensuring information security;

7) Other contents (if any).

II. Proposals and recommendations to the State Bank

Form No. 07/TTTD

COMPUTER INCIDENT REPORT/ INFORMATION CHANGE REPORT

I. Information on computer incidents/or information changes

1. Description of incident/or content of information change

- Description of incident involving damage, malfunction of software, hardware; network system being attacked... causing the system to be unreliable, operating abnormally.

- Content of change: management team; number of credit institutions, foreign bank branches committed to providing credit information; agreement on procedures for collecting, processing, storing and providing credit information between the credit information company and credit organizations that have committed; infrastructure for information technology;

- Other content (if any).

2. Measures taken:

II. Proposals and recommendations to the State Bank

APPENDIX NO. 02

Form No. 01

REPORT ON CASH SAFEKEEPING SECURITY WORK

Respectfully submitted to:...

PART I. RESULTS OF CASH SAFEKEEPING OPERATIONS

I. ACHIEVEMENTS

1. Guidance on cash safekeeping security work

2. Meeting demand for cash in the economy

3. Cash safekeeping management

4. Counterfeit money prevention

II. SOME LIMITATIONS

1. Inspection work, issuance of guiding documents on procedures and operations

2. Counting, storage, and protection of cash, valuable assets, and negotiable instruments

3. Management of cash vaults and entry/exit from cash vaults

4. Protection of premises, cash vaults, and transaction sites

5. Limitations with cash vaults and security equipment systems

6. Causes of limitations

PART II. DIRECTIONS AND TASKS FOR CASH SAFEKEEPING WORK AT BANKS

ANNEX NO. 03

Form No. 01

REPORT

Operation Status of the Reserve Fund in the First Half of the Year

(From January 1, ... to June 30, ...)

Respected: State Bank of Vietnam

1. Management of the Reserve Fund (number of members of the Reserve Fund Management Board).

2. Total fees collected by the Reserve Fund.

3. Operating expenses of the Reserve Fund.

4. Usage for providing loans to support people's credit funds when they face financial difficulties and have difficulty making payments to return to normal operations.

5. Report on the use of Reserve Fund capital:

a) Deposited in cooperative banks or commercial banks in accordance with the Management and Utilization Regulation of the Preservation Fund;

b) Purchase of government bonds, treasury bills, and State Bank of Vietnam bills.

Form No. 02

REPORT

Operation Status and Financial Situation of the Reserve Fund in the Previous Year

(From January 1, ... to December 31, ...)

Respected: State Bank of Vietnam

1. Management of the Reserve Fund (number of members of the Reserve Fund Management Board).

2. Total fees collected by the Reserve Fund:

- Number of people's credit funds that have participated in paying the Reserve Fund fee.

- Number of people's credit funds that have not participated in paying the Reserve Fund fee.

3. Operating expenses of the Reserve Fund.

4. Financial collection and expenditure mechanisms serving the activities of the Reserve Fund.

5. Usage for providing loans to support people's credit funds when they face financial difficulties and have difficulty making payments to return to normal operations.

- Number of people's credit funds requesting loans from the Reserve Fund; Number of people's credit funds approved for loans from the Reserve Fund; Support loan amount; Support loan term; Support loan interest rate;

- Measures to monitor, correct, and strengthen the operations of people's credit funds receiving support loans;

- Implementation of the inspection and supervision mechanism for the use of support loan capital by people's credit funds;

- Handling risks related to support loans that cannot be recovered;

6. Usage of Reserve Fund capital:

- Deposited at cooperative banks and commercial banks in accordance with the regulations on the management and use of the Reserve Fund; Deposit interest rate.

- Purchase of government bonds, treasury bills, and State Bank of Vietnam bills.

Implementation Report of Production Projects of Supporting Industry Products Confirmed with Incentives

REPORT

Internal audit monitoring results of the Supervisory Board of the Cooperative Bank on operational situation
and financial results of the Preservation Fund

(From January 1, ... to December 31, ...)

Respected: State Bank of Vietnam

1. Management of the Reserve Fund (number of members of the Reserve Fund Management Board).

2. Time period for internal audit and supervision by the Supervisory Board of the cooperative bank on the operation status and financial results of the Reserve Fund (Frequency and duration of internal audit)

3. Content and results of internal audit and supervision by the Supervisory Board of the cooperative bank on the operation status and financial results of the Reserve Fund.

ANNEX NO. 04

Form No. 09

REPORT ON CHECKING LIST OF STATE BANK DIGITAL CERTIFICATES

From (dd/mm/yyyy) to (dd/mm/yyyy)

1. List of dedicated digital certificates of the State Bank and usage status

2. Proposals and recommendations (if any)

…………………………

Remarks

1. Only send list of digital certificates THAT HAVE CHANGED compared to the list of digital certificates already issued by SBV.

2. The list of digital certificates should be arranged in ascending order by unit code/branch code.

3. Column "date of birth" should be recorded in 8-digit format (dd/mm/yyyy).

4. Column "type of transaction": only record transaction codes NO LONGER REQUIRED.

Transaction codes in column (4) are defined as follows

5. Column "Usage status" should be recorded with values as follows:

Usage status = 1: Digital certificate is currently in use;

Usage status = 0: Digital certificate NO LONGER required.

ANNEX NO. 05

Form No. 01

MONTHLY REPORT ON ASSET DISPOSAL SUPERVISION …../…

I. Asset disposal situation, asset distribution, and other issues arising

II. Difficulties and obstacles (if any)

III. Recommendations

ANNEX NO. 06

Form No. 01

REPORT ON IMPORTATION
AND USE OF MATERIALS BY MONEY PRINTING FACILITY

(Reporting period: Quarter / )

Part I. Import situation and use of goods

1. Quantity of each type of goods and raw materials imported during the reporting period

2. Quantity of each type of goods and raw materials used during the reporting period

3. Situation regarding the use of confirmation certificates issued by the State Bank for printing establishments to process import procedures for goods and raw materials

Part II. Proposals and recommendations (if any)

ANNEX NO. 07

Form No. 01

REPORT

RESULTS OF IMPLEMENTING THE PLAN TO ADDRESS THE ISSUE OF SHAREHOLDING EXCEEDING LIMITS IN THE QUARTER ... YEAR...

I. List of shareholders holding shares exceeding the limit ratio

II. Results of addressing the issue of shareholding exceeding the limit ratio

III. Difficulties and obstacles (if any)

IV. Recommendations and proposals (if any)