skills/sarfaesi-advisor/SKILL.md

---
name: sarfaesi-advisor
description: Assesses and plans Indian secured-creditor enforcement under the SARFAESI Act and Security Interest Enforcement Rules. Use for applicability, section 13 demand, possession, section 14 assistance, valuation, auction, sale, borrower challenge or enforcement-defect review.
---

# SARFAESI Advisor

Create a date-specific enforcement roadmap under the current Act, Rules, notifications and controlling authority. Treat each notice and statutory interval as an evidence-backed condition, not a clerical formality.

## Required inputs

- Secured creditor identity, authorisation and transaction assignment history
- Borrower, guarantor, account, facility and complete debt calculation
- NPA classification date, basis and applicable regulatory framework
- Security documents, asset title, location, possession and valuation
- CERSAI and other creation, modification and satisfaction records
- Consortium or multiple-creditor holdings and consent status
- Notices, representations, replies, payments, stays and prior proceedings
- Asset occupation, tenancy, agricultural use, statutory dues and exclusions

## Method

1. **Test applicability.** Verify secured-creditor, financial-asset, borrower and security-interest status, current notifications, debt thresholds and section 31 exclusions. Confirm the asset and claim fall within the Act.
2. **Verify enforceability.** Check execution, stamping, registration, CERSAI compliance including section 26D, limitation, assignment, priority and authorised-officer appointment.
3. **Verify default and NPA.** Reconcile the account, credits and classification under the applicable RBI or other prudential rules. Do not substitute a contractual default for required NPA classification.
4. **Prepare section 13(2).** State the secured debt and assets accurately, calculate the statutory 60-day period from valid service and preserve service evidence for every obligor.
5. **Handle representation.** Track borrower objections and prepare a reasoned, timely response under section 13(3A) without predetermining later measures.
6. **Select section 13(4) measures.** Confirm multiple-creditor consent where required and document the basis for possession, management, assignment or third-party payment directions.
7. **Plan possession and section 14.** Follow movable or immovable asset rules, notices, publication, inventory, panchnama, custody and Magistrate or District Magistrate assistance. Do not use private force or bypass occupants' lawful claims.
8. **Plan valuation and sale.** Obtain required valuation, set reserve price with authority, calculate sale notice periods, choose a permitted method, manage deposits, auction, confirmation, sale certificate and surplus.
9. **Map challenges and overlays.** Track section 17 or appellate remedies, limitation, interim orders, insolvency moratoria, RDB proceedings, priority claims, tenants and tax or government dues.
10. **Close the record.** Apply proceeds transparently, report satisfaction or modification, release documents and preserve the enforcement file.

## Output

Produce an applicability opinion, defect and cure log, debt schedule, notice-and-service pack, statutory timeline, possession and section 14 checklist, valuation and sale pack, challenge-response matrix and proceeds-closure schedule.

## Guardrails

- Do not backdate notices, misstate NPA status, suppress payments or create false service evidence.
- Do not trespass, threaten occupants, seize excluded assets or ignore a stay or insolvency moratorium.
- Do not sell without compliant valuation, reserve, notice, publication and authorised decision-making.
- Escalate agricultural land, tenancy, third-party title, vulnerable occupants and competing statutory claims.
- Require current Indian banking and enforcement counsel review before every external step.