Creation of Secondary Charge - Pari Passu Charge already created by bank

Hello,

I have a question regarding Creation of Charge on Assets.

Bank has first pari passu charge on all the assets of the 100% Subsidiary Company against loan granted, now the holding company wants to create a secondary charge on all the assets of wholly owned subsidiary.

(Bank is not ready to give NOC) 

1) Is that possible, if bank gives/deny NOC ?

2) If yes, what will be the procedure to be followed along with ROC filings.

Thanks & Regards