What RERA filings tell a lender that the borrower's MIS cannot

Every construction finance file contains two versions of the same project. One is the borrower's MIS: monthly, formatted to the sanction letter, prepared by the party asking for the next tranche. The other sits on a public register: quarterly, standardized, certified by three independent professionals and sworn to a regulator with penalty exposure. Most credit teams read the first religiously and the second never. This article is the case for reversing that, field by field.

Two documents, two masters#

The logic is worth stating precisely, because it is the foundation for everything else in this series.

A borrower's MIS is a private representation. It is prepared by the borrower, for the lender, in a format the borrower controls, with no independent certification and no penalty for optimism short of outright fraud. Sales figures routinely include expressions of interest; progress percentages are management estimates; receivables age quietly.

A RERA filing is a public, sworn disclosure. Under section 11 of the RERA Act, the promoter must update the register quarterly. Under section 60, providing false or misleading information carries a penalty of up to 5 percent of the estimated project cost. The quarterly progress reports are due within 20 days of quarter end in Maharashtra (MahaRERA Orders 18/2021 and 33/2022), and the money-side disclosures carry the signatures of an independent architect, engineer and chartered accountant, professionals with their own registrations at stake.

The consequence for a credit desk: where the MIS and the filing diverge, the filing is the harder number, because lying in it is expensive and the liar is not the only signatory. That asymmetry is the entire monitoring edge.

The field-by-field comparison#

The last row deserves emphasis. Your borrower's MIS covers your project. The register covers your borrower. A promoter servicing your loan punctually while their three other projects file extensions and freeze sales is a deteriorating credit whose deterioration is visible only in the filings, and it is visible quarterly, for free. Our developer-series opener, what MahaRERA filings tell a developer, maps that portfolio-wide reading from the supply side; the credit reading is the same discipline with a different question.

A worked example: the reconciliation that pays for itself#

Take a live construction finance position, illustrative numbers throughout. Sanction Rs 60 crore against a project with estimated cost Rs 100 crore. Your disbursement stands at Rs 42 crore, 70 percent drawn. The borrower's MIS reports 55 percent physical progress and Rs 58 crore collected from buyers.

Now the filings. Form 1 and Form 2 certify work done at 45 percent of estimated cost. Form 3 shows Rs 55 crore realised from allottees, of which the permissible withdrawal at 45 percent completion is 45 percent of cost, Rs 45 crore, and actual certified withdrawals stand at Rs 44 crore.

The reconciliation: your Rs 42 crore plus Rs 44 crore of buyer-money withdrawals is Rs 86 crore deployed against 45 percent certified progress, which should have consumed about Rs 45 crore. Even allowing for land cost recorded upfront and approval spend, the gap is large enough to demand an answer in writing before the next tranche. The MIS, read alone, showed a healthy project one tranche away from 70 percent drawn. The filings, read against it, showed money moving roughly twice as fast as the building. Ten minutes of arithmetic, quarterly, on public documents.

The delay clock gives the same arithmetic teeth on the way out: if the project misses its registered date, allottees earn interest at SBI's highest MCLR plus 2 percent, currently 10.90 percent per annum, a statutory claim that ranks ahead of the promoter's equity in every practical sense and shrinks the cushion under your security. The buyer-side mechanics are in the delayed possession guide; the desk-side lesson is that every quarter of slippage manufactures new creditors.

What the public record already proved#

The costliest recent lessons in Indian real estate credit were, at bottom, reconciliation failures. In the Amrapali matter, the Supreme Court's July 2019 judgment, following court-ordered forensic audits, recorded large-scale diversion of homebuyer money away from the projects it was collected for, cancelled the group's RERA registrations and handed completion to NBCC; more than 42,000 buyers were affected (Supreme Court of India, Bikram Chatterji v. Union of India, judgment of 23 July 2019). The disclosure regime that would have made that diversion legible quarter by quarter, certified forms, ring-fenced accounts, public filing, is precisely the one lenders now get for free. The scale of the cleanup industry says what ignoring the data costs: the government's SWAMIH fund alone reported 63,200 stalled homes completed out of 1,01,443 in its portfolio as of January 2026 (SWAMIH programme data), and Budget 2026-27 committed a further Rs 15,000 crore to a second fund.

Meanwhile the exposure being monitored keeps growing: commercial real estate credit grew 16.2 percent year on year per RBI's sectoral deployment data for January 2026, among the faster wholesale segments. More book, same MIS-first toolkit, is not a stable combination.

Turning the reading into covenants#

The reconciliation only binds if the documents arrive, so the facility should hard-wire them. Four information covenants cost the borrower nothing if they are compliant and expose them precisely if they are not. First, delivery of each filed QPR and each Form 1, 2 and 3 within seven days of filing, with the filed copy controlling over any management version; the QPR reading guide shows what a healthy series looks like. Second, notice of any extension application under section 6 or 7 before it is filed, not after it is granted. Third, notice of any change in the certifying architect, engineer or CA, with reasons. Fourth, a representation that no other group entity's registration has lapsed or drawn enforcement action, repeated at each drawdown, which imports the group-level view into a single-project facility. None of these covenants asks the borrower to produce anything the regulator does not already require; they simply make the regulator's cadence the lender's cadence. A borrower who resists them is telling you which document stream they intend to manage, and the regulator's own enforcement record tells you how that usually ends.

Kavya Menon's desk (illustrative, as our stories always are) added a one-page filings reconciliation to its quarterly review format last year: filed progress versus disbursement, Form 3 collections versus MIS collections, portfolio-wide extension count for each promoter group. On a 14-account book it flagged two names. One explained the divergence satisfactorily in a week, with documents. The other asked why the bank was reading "buyer-side paperwork". That answer went into the file too.

Assembling this manually is the honest objection: filings live project by project on the portal, quarters get overwritten, and group entities fragment across names. That is the tooling gap ReraGenie closes: archived quarterly filings as time series, promoters resolved into group records, and the Rs 2,999 project analysis assembling exactly the reconciliation fields above for any registered project. For a book-level view, the area consolidated reports do it across a micro-market. If your desk monitors Maharashtra exposure, start with the register's own numbers and see what a quarter of filings says about your book.

The one-line summary#

The borrower reports what they want you to see; the register records what they must swear. Read both, reconcile quarterly, and treat every divergence as the agenda for the next borrower call.