As regards PCR, it was decided to freeze the PCR with reference to the gross NPA position in banks as on September 30, 2010, since in the absence of a calibrated methodology it would be difficult to allow banks to use the countercyclical provisions built up  4  BIS central bankers’ speeches  under PCR freely and there were certain design issues too,.
The buffer (surplus of provisions over specific provisions) will be allowed to be used by banks for making specific provisions for NPAs during periods of system wide downturn, with the prior approval of RBI. 20. The financial crisis also led to heavy criticism of accounting rules that permitted certain structured/ special purpose entities and exposure to remain off-balance sheet.