The Reserve Bank of India’s (RBI) criterion covering “indirect access to public funds” has emerged as a key issue in Tata Sons’ pending application to surrender its registration as a core investment company (CIC). Legal experts, however, differ on whether equity investments by Tata group companies that have access to public funds would bring the holding company within the scope of the rule. Tata Sons applied to surrender its CIC registration after repaying all outstanding debt. If the RBI accepts the application, the holding company could avoid the listing requirement applicable to upper-layer NBFCs. If the application is rejected, Tata Sons may have to pursue a listing.