8.1 The reform process in the financial sector has been taken
forward with the primary objective of having a strong and resilient banking
system. Considerable progress has been made in strengthening the regulatory
and supervisory norms with a view to inducing greater accountability and market
discipline amongst the participants. This has enabled the Indian banking system
to acquire strength, efficiency, and vibrancy necessary to meet global competition.
The most significant achievement in the banking sector has been the marked improvement
in financial health of banks in terms of capital adequacy, profitability and
asset quality with an increasing focus on risk management. The Reserve Bank
has made persistent efforts towards adoption of international benchmarks as
appropriate to Indian conditions, improvement in management practices and corporate
governance, and upgradation of technological infrastructure. While certain changes
in the legal infrastructure are yet to be effected, the developments so far
have brought the Indian financial system closer to global standards. From the
mid-1990s, public sector banks had to face competition from the more customer-focused
private sector entrants. This, competitive pressure induced public sector banks
to revitalize their operations. After almost a decade of financial reforms,
the banking sector in India is distinctly better placed in terms of its strength,
efficiency and modernisation.
8.2 The reform process has changed the relationship between
the Reserve Bank and commercial banks from one of micro regulation to that of
macro management. With the focus on deregulation and liberalisation coupled
with enhanced responsibilities for banks, the banking sector is faced with several
challenges. Consistent with the shift to functioning in a competitive economy
and to the adoption of prudential best practices, the major challenges facing
the banking sector are the deployment of funds in quality assets and the management
of revenues and costs. Concurrently, the issues of corporate governance and
appropriate disclosures for enhancing market discipline have received regulatory
attention for ensuring increased transparency and greater accountability.
8.3 Credit growth during the first half of 2004-05, traditionally
a slack season for credit off-take, has been one of the highest in recent years.
Inspite of a rapid acceleration in non-food credit growth caused by lending
to the retail segment, the pick up in non-food credit appears to be broad-based.
Improvement in credit delivery mechanisms has been the focus of recent policy
measures. In the Union Budget 2004-05, the Central Government announced a broad
outline of programmes for doubling the flow of credit to agriculture in three
years with a credit growth of 30 per cent for 2004-05. The flow of credit to
agriculture may lead to greater credit penetration by replacing non-institutional
sources of finance.
8.4 Over the past few years there has been a steady decline
in interest rates largely reflecting sustained reduction in inflation rates
and inflationary expectations. Such reductions in interest rates occurred in
an environment where credit growth remained sluggish. Consequently, there was
a favourable impact on banks’ balance sheets in terms of increased operating
profits from treasury operations given the asset concentration in favour of
Government securities in excess of the requirement of statutory liquidity ratio
(SLR). For example, treasury income of the banking sector increased from Rs.9,541
crore in 2001-02 to Rs.19,532 crore in 2003-04 and constituted 32.0 per cent
and 37.1 per cent of operating profit in the corresponding years. This in turn
enabled banks to make larger loan loss provisions. Consequently, the net NPA
ratio has declined from 5.5 per cent in 2001-02 to 2.9 per cent by 2003-04.
While a declining interest rate scenario has positive spin offs for the banking
sector, given that interest rates had touched historically low levels by 2003-04,
there does not appear to be any further scope for similar trends to be observed
during 2004-05. In future, therefore, an increasing proportion of banks’ income
would emanate from the traditional business of lending. Banks now have a diversified
credit portfolio with increasing shares of lending to housing, consumer credit
and credit to other priority sectors such as small transport operators. The
flow of credit to agriculture also continues to remain robust given the enabling
policy environment which has emphasised credit delivery. In this direction,
vehicles of rural credit delivery through Kisan Credit Cards (KCC) and increasing
linkage of bank credit and self help groups (SHGs), have proved effective. As
regards industrial credit, greater thrust is placed on lending to small and
medium enterprises (SMEs), especially the small scale industries (SSIs). 8.5
In order to enable the banks to determine appropriate pricing
of loans to small and medium enterprises, development of a system of proper
credit records would be very helpful. For this purpose, the Credit Information
Bureau of India Ltd. (CIBIL) would work out appropriate mechanisms in consultation
with the Reserve Bank, SIDBI and IBA. The Reserve Bank has also exhorted banks
to make persistent efforts in obtaining consent from all their borrowers, in
order to establish an efficient credit information system. This would help in
enhancing the quality of credit decisions and improving the asset quality of
banks, apart from facilitating faster credit delivery. As the risk profile of
bank lending is more diversified and banks are expanding their loan books, it
is essential that banks pay adequate attention to quality of lending so that
credit expansion could be on a sustained trajectory building upon higher profitability
while ensuring financial stability. 8.6 Keeping in view these requirements,
as well as the increasing focus on credit delivery mechanisms, the Reserve Bank
initiated various measures in its mid-term Review of annual policy for 2004-05.
These measures include raising of limits for direct finance to the housing sector,
raising of the composite loan limit for small-scale industries, removal of the
restrictive provisions of service area approach, enhancing limits on advances
under the priority sector for dealers in agricultural machinery and distribution
of inputs for allied activities and allowing banks to extend finance to Non-Banking
Financial Companies (NBFCs) against second hand assets financed by them subject
to the approval of the policies by the banks’ Boards.
Infrastructure Financing
8.7 The Reserve Bank has announced several policy measures
in the recent years to facilitate infrastructure financing. These measures included
enlarging the scope of the definition of infrastructure lending, permitting
banks to raise long-term bonds with a minimum maturity of five years to the
extent of their exposure of residual maturity of more than five years to the
infrastructure sector, etc. It is intended that banks should first provide
assistance to such infrastructure projects before raising resources through
bonds. The Reserve Bank has already set up a Working Group to examine the instruments
for credit enhancement which the State Governments can offer to improve creditworthiness
and borrowing capability of State Public Sector Undertakings (PSUs)/Special
Purpose Vehicles (SPVs) to attract institutional financing for infrastructure
projects.
Risk Management
8.8 Growth in the economy has been leading to a natural expansion
of the credit portfolio to fund the increasing demand for industrial growth
and new plans of corporate expansion. The demand for higher levels of infrastructure
financing has also followed this growth. In this context, to ensure a healthy
growth in the credit portfolio, integrated risk management systems to address
all relevant risks need to be evolved alongside selection of appropriate risk
management models.
8.9 With a view to building up of adequate reserves to guard
against any possible reversal of interest rate environment in future due to
unexpected developments, the Reserve Bank advised banks in January 2002, to
build up an Investment Fluctuation Reserve of a minimum of 5.0 per cent of the
investment in held for trading and available for sale categories within a period
of 5 years. Taking cognisance of hardening of inflation and an environment subject
to unanticipated changes because of unforeseen domestic and external developments,
the banking system, in particular, has to recognise interest rate cycles and
strengthen risk management processes to cope with eventualities so that financial
stability could be maintained and interest rate movements could be passed in
a non-disruptive manner.
Basel II Developments
8.10 The process of benchmarking prudential norms applicable
to Indian banks with international best practices has been carried forward.
The Basel Committee on Banking Supervision, after a protracted consultative
process, issued the framework of New Capital Accord (Basel II) in June 2004,
which is expected to be implemented in many jurisdictions by end-2006. An important
pre-requisite for implementation of advanced approaches under Basel II is a
well-established risk management system in banks. Risk management comprises
various risks that a financial institution has to manage viz., credit
risk, operational risk, market risk, including interest rate risk and forex
risk. Basel II aligns the capital measurement framework with sound contemporary
practices in banking, promotes improvements in risk management, and is intended
to enhance financial stability.
8.11 As Indian banks gear up for migration to Basel II, the
progress made by banks in this direction is being monitored by the Reserve Bank
with reviews at quarterly intervals. However, as a logical step before migration
to capital adequacy norms under Basel II, banks have been mandated to maintain
capital charge for market risk. Banks would need to chalk out development strategies
to ensure full compliance with capital requirements arising out of implementation
of Basel II. The Reserve Bank on its part is making efforts to formulate policies
to deal with risks arising on account of operations of large and complex financial
institutions and issues relating to the adoption of Basel II in the form of
supervisory and regulatory challenges. Banks have also been advised to undertake
a self assessment of their existing risk management systems taking into account
the three major risks covered under Basel II and to concurrently initiate appropriate
measures to upgrade them to meet the minimum standards prescribed under Basel
II. In view of complexities involved in migrating to Basel II, a Steering Committee
comprising members from banks, Indian Banks’ Association and the Reserve Bank
has been constituted to prepare guidelines for implementation of Basel II.
Corporate Governance in Banking Sector
8.12 New private banks and foreign banks have been granted
licences in order to allow the financial system to benefit from greater competition
through better technology, specialised skills, better risk management practices,
greater portfolio diversification relating to treasury operations and deepening
of the financial markets. The concentrated shareholding in banks controlling
substantial amount of public funds poses the risk of concentration of ownership
given the moral hazard problem and linkages of owners with businesses. Corporate
governance in banks has therefore, become a major issue. Diversified ownership
becomes a necessary postulate so as to provide balancing stakes. As the ownership
of banks gets broad-based, the importance of institutional and individual shareholders
will increase. In such a scenario, banks will need to put in place a proper
code for corporate governance for benefiting all stakeholders of a corporate
entity.
8.13 Simultaneously, in the interest of diversified ownership
of banks, the Reserve Bank intends to ensure that no single entity or group
of related entities have shareholding or control, directly or indirectly, in
any bank in excess of 10 per cent of the paid up capital of the private sector
banks. Any higher levels of acquisition will be with the prior approval of the
Reserve Bank and in accordance with the guidelines notified on February 3, 2004.
In the draft guidelines circulated in July 2004, the Reserve Bank has proposed
for discussion and feedback a comprehensive framework of policy relating to
ownership and governance in Indian private sector banks. The broad principles
underlying the framework of policy relating to ownership and governance of private
sector banks would have to ensure that the ultimate ownership and control of
private sector banks is well diversified. A revised discussion paper is being
issued after consideration of comments and feedback received. Further, Banks
have to ensure that important shareholders (i.e., shareholding of 5 per
cent and above) are ‘fit and proper’, as laid down in the guidelines dated February
3, 2004 on acknowledgement for allotment and transfer of shares and the directors
and the CEO who manage the affairs of the bank are ‘fit and proper’ and observe
sound corporate governance principles. To ensure that shareholders and directors
on Board are ‘fit and proper’, banks in the private sector should undertake
a process of due diligence to determine the suitability of the person for appointment
/ continuing to hold appointment as a director on the Board, based upon qualification,
expertise, track record, integrity and other ‘fit and proper’ criteria.
Risk-Based Supervision
8.14 With increased deregulation, globalisation and greater
competition from within the country, cross border dealings have exposed banks
to greater risk. Diversification into non-traditional products like insurance,
derivatives, etc., has added to the complexity of banking business. Internet
banking, e-commerce, e-money, etc., have added new dimensions to risks
in the banking sector. Accordingly, there is a need for enlarged focus on risk-based
supervision in order to improve risk sensitivity of the supervisory approach.
However, stabilising risk-based supervision, as an effective supervisory mechanism,
may be a challenging task and long-term drawn out process. A significant development
during 2003-04 was a successful pilot programme run for risk-based supervision,
aimed at allocating supervisory resources in accordance with the risk profile
of banks.
8.15 In order to sensitise banks to explicitly recognise and
take into account the risks arising out of forex exposures of their clients,
banks were advised that henceforth, foreign currency loans of US $ 10 million
and above, or such lower limits as may be deemed appropriate vis-à-vis
the banks’ portfolio of such exposures, can be extended only on the basis
of a well laid down policy of their Boards with regard to hedging of such loans.
The country risk management guidelines have also been reviewed to encompass
country exposures of more than one per cent of a bank’s assets. The information
on the total exposure of the corporate clients is not readily available with
banks. The banks are being encouraged to obtain information from their large
borrowers on their unhedged forex exposures, so that the banks, in turn, can
assess the risk of their own exposure to such corporates on an on-going basis.
8.16 With a view to containing risks arising out of non-SLR
investment portfolio of banks, in particular through the private placement route,
the guidelines, inter alia, addressing the aspects of coverage, regulatory
listing as well as rating requirements, fixing prudential limits, internal assessments,
role of the Boards, disclosures and trading and settlement were issued to banks.
The guidelines on non-SLR investments were issued to banks giving a transition
period up to end-December 2004 for compliance. However, a study of select banks
revealed that banks continue to have significant share of unlisted and unrated
investments in their non-SLR portfolio. Therefore, banks have been urged to
prepare themselves to comply with the prudential requirements within the prescribed
timeframe.
8.17 The prudential norms on income recognition, asset classification
and provisioning thereon were introduced first during 1992-93, as per the recommendations
of the Narasimham Committee. The norms have placed the identification of non-performing
assets (NPAs) and provisioning for them on an objective platform and the endeavour
has since been to make them comparable with the international norms. The enactment
of the Securitisation and Reconstruction of Financial Assets and Enforcement
of Security Interest (SARFAESI) Act, 2002 would help in the recovery of NPAs.
Since the chances/ extent of recovery of an asset reduces over a period of time,
it is essential that banks expedite recovery of NPAs. With effect from March
31, 2005, the Reserve Bank would introduce a graded higher provisioning requirement
according to the age of NPAs, which are included under ‘doubtful for more than
three years’ category.
Technology in Banking
8.18 Technology has been the key driver of the revolutionary
changes in the Indian financial sector with the increasing demand for interconnectivity,
internet banking and Automated Teller Machine (ATM) centres. Net banking, phone
banking, mobile banking, ATMs and bill payments are the new facilities that
banks are using not only to attract customers but also to help them reduce their
total operating costs. The introduction of computerisation in the banking sector
has led to considerable improvements in the functioning of clearing house mechanism,
which facilitates the exchange of instruments, and processing of payment instructions
at a central point among the participating banks. Clearing houses have gradually
extended their range of activities to automate by electronic means the settlement
of payment transactions. The Reserve Bank framed a set of guidelines known as
Uniform Regulations and Rules for the bankers’ clearing houses to provide a
uniform framework for the conduct of clearing throughout the country and have
been adopted individually by the general body of each clearing house in the
country. The momentum achieved needs to be sustained.
8.19 Most public sector banks with their extensive branch networks
are still in the process of making a shift over from the ledger book accounting
practices to computer-balanced spreadsheets and from cashier-dispensed currency
to ATMs. However, the transformation towards computerised functioning in public
sector banks is beginning to set in and the response is becoming evident. The
Reserve Bank has been playing a key role in the development of a modern, state-of-the-art
payment and settlement system in India. Accordingly, the modernisation of the
system has been accorded high priority in the financial sector reforms. The
thrust of these reforms has been towards greater consolidation, development
and integration of the payment and settlement systems in India. In view of the
substantial progress made in payments and settlement system as envisioned in
the ‘Payments System Vision Document 2001-04,’ the Reserve Bank has initiated
measures to draft a document on ‘Payments System Vision Document 2005-08’ under
the guidance of the National Payments Council.
8.20 Technology has become a strategic and integral part of
banking, driving banks to acquire and implement world-class systems that enable
them to provide products and services in large volumes at a competitive cost
with better risk management practices. There is a need to undertake extensive
computerisation across bank branches as banks that adopt the latest in technology
would have an edge over others in terms of productivity. Customers’ awareness
has necessitated banks to deliver tailor-made products through multiple channels,
allowing customers access to the bank round the clock.
8.21 In accordance with the recommendations of the Working
Group on Cheque Truncation and E-cheques, the Reserve Bank decided that an Image
based Cheque Truncation Pilot Project should be initiated for the Bankers’ Clearing
House of the National Capital Region of Delhi and its nearby areas. The pilot
project is expected to be made operational in the early part of 2005. In this
context, some steps need to be taken by the banks relating primarily to the
procurement and/or outsourcing of truncation capabilities and adopting related
changes in systems and procedures. Banks may also form a Policy Group, Implementation
Group and nominate Nodal Officers for the purpose. In order to further promote
other types of electronic modes of funds transfer viz., Electronic Clearing
Service (ECS) and Electronic Fund Transfer (EFT), the Reserve Bank announced
that the service charges on banks for ECS and EFT transactions would be waived
for the period up to March 31, 2006. In order to facilitate large scale usage
of the ECS and EFT schemes for large value money transfers and to meet the requirements
of various segments of the financial sector including the securities markets,
the Reserve Bank, in mid-term Review of annual policy for 2004-05, has dispensed
with the existing per transaction limits for ECS and EFT effective November
1, 2004.
Payment and Settlement System
8.22 A significant development during 2003-04 was the commencement
of Real Time Gross Settlement (RTGS) System as a facility for quick, safe and
secure electronic mode of funds transfer. The technological infrastructure for
the smooth and secure functioning of the payment system was strengthened with
the implementation of RTGS system, the Special Electronic Funds Transfer system
and the Online Tax Accounting System. RTGS System has also enabled ‘Straight
Through Processing’ at the banks’ end for putting through customer transactions.
The Negotiated Dealing System (NDS) enabled an improvement in Liquidity Adjustment
Facility (LAF) auctions by providing in a timely fashion, all the parameters
such as issue, duration, type of auctions, the opening and closing time, etc.
To improve the performance of NDS as a trading platform in Government securities,
a new order matching system (NDS-OM) has been recommended by the Working Group
on Screen Based Trading in Government Securities. NDS-OM would have substantial
advantages like anonymity, better access, quicker trade execution, improved
pre and post trade transparency, reduction in trading costs, more efficient
price discovery, straight through processing and improved market liquidity.
Currently trial runs of the new module are being conducted. The Clearing Corporation
of India Limited (CCIL), which offers a multilateral netting mechanism, has
provided time and cost benefits to banks.
8.23 The Reserve Bank of India has made several efforts in
setting up a safe, secure and efficient communications network for the exclusive
use of the banking sector. INFINET is already being used by a large number of
banks for funds and non-funds based message transfers. INFINET is one of the
few networks in the world which use the latest in technology and security called
‘Public Key Infrastructure’. For such communication systems to be effective,
there is a need for an effective security policy which offers a shared vision
of how the controls in workplace should be implemented with the objective of
protecting data, information and eventually, the economic value of the organisation.
There is a need for creating a culture of security by launching training programmes
in these areas. These efforts need to be supported by surveillance, monitoring,
auditing to detect unusual usage patterns and deficiencies. As the connectivity
expands, there is a greater need for security features that guard against the
spread of e-contagions.
Transparency
8.24 The relationship between the Reserve Bank and market participants
has changed through the expansion and reinforcement of the consultative processes
for formulating prudential regulations. To further this consultative process
and with the specific goal of making the regulatory guidelines more user friendly,
a Users’ Consultative Panel has been constituted comprising representatives
of select banks and market participants. The panel provides feedback on regulatory
instructions at formulation stage to avoid ambiguities and operational glitches.
The Reserve Bank has operationalised a mailbox in October 2004, where the clarifications
issued to individual banks on various prudential aspects would be posted for
benefit of all users. This mailbox can be accessed on the Reserve Bank website.
Further, to strengthen the consultative process and to place such a process
on a continuing basis, a Standing Technical Advisory Committee on Financial
Regulation was constituted in November 2003. The Committee consists of experts
drawn from academia, financial markets, banks, non-bank financial institutions
and credit rating agencies. The purview of the Committee includes examination
of the issues referred to it and advising the Reserve Bank on regulations on
an on-going basis covering banks and non-bank financial institutions and other
market participants.
Issues in Co-operative Banking
8.25 Issues arising out of multiplicity of supervisory authorities
continue to pose challenges in the co-operative banking sector. The Reserve
Bank has repeatedly drawn the attention of the Government to the impact of multiple
supervisory authorities on the performance of the co-operative banks. Cooperative
banks are also subject to other difficulties ranging from members’ apathy, imprudent
investment decisions, low recovery rates, weak financial position and failure
to modernise systems and procedures. Beside these, reconciling democratic character
and financial discipline among these institutions is a challenge. Failure of
a few co-operative banks has adverse implications for rest of the cooperative
banks. A vision document is being evolved for the future role of Urban Co-operative
Banks (UCBs) which must ensure depositors’ interests and avoid contagion while
providing useful service to the local communities. The Reserve Bank would be
encouraging growth of strong and viable entities through consolidation in the
co-operative sector and sensitising the State and Central Governments regarding
the issues that arise in their jurisdiction.
8.26 The Reserve Bank has initiated several measures to mitigate
the systemic implications of various risks prevailing in the co-operative sector.
In its annual policy Statement 2004-05, the Reserve Bank announced that it would
consider issuance of fresh licences only after a comprehensive policy on UCBs,
including an appropriate legal and regulatory framework for the sector, is put
in place. The Reserve Bank advised UCBs to classify an asset as doubtful with
effect from March 31, 2005 if it remained in the sub-standard category for 12
months. Banks were however permitted to phase the consequent additional provisioning
over a four-year period commencing from the year ending March 2005 with a minimum
of 20 per cent each year.
8.27 The Reserve Bank has received requests from banks and
Federations/ Associations of UCBs for giving some more time to restructure the
accounts of UCBs and progressively meet the stricter prudential norms. In response,
the Reserve Bank allowed the phasing of additional provisioning over a five-year
period commencing from the year ending March 2005 instead of four years. Further,
the banks have been permitted to make a minimum of 10 per cent of the required
provision in each of the first two years and the balance in equal instalments
over the subsequent three years. In October 2004, an ordinance to amend Banking
Regulation Act, 1949 has been promulgated to enable the Reserve Bank to issue
licences to Multi State Co-operative Societies to carry on banking business.
The Deposit Insurance Cover for deposits in the UCBs registered under the Multi-State
Co-operative Societies Act has also been extended. The Government has appointed
a Task Force (Chairman: Prof. A. Vaidyanathan) to propose an action plan for
reviving the rural cooperative banking institutions and suggest an appropriate
regulatory framework for these institutions. The Task Force is expected to submit
its Report shortly.
8.28 Regional Rural Banks (RRBs) are another source of credit
in rural areas. Several measures have been initiated to strengthen RRBs in the
form of recapitalisation of weak RRBs, relaxing lending to non-target group
and deregulating deposit and lending rates. The Reserve Bank has also constituted
Empowered Committees in its Regional Offices with members drawn from NABARD,
sponsor banks, conveners of SLBCs and State Governments to ensure that the RRBs
adhere to good governance and comply with prudential regulations. The Committees
would also focus on operational issues and provide clarifications on regulatory
issues. The Reserve Bank in its mid-term Review of annual policy for 2004-05,
has raised concerns about discrimination between RRBs and co-operative banks
in matters of stamp duty, mortgage fee etc. State Governments are also
being requested to accord approval of merger of RRBs within the State, sponsored
by the same bank, as and when approached with such proposals. Sponsor banks
have been advised to provide support to their RRBs in matters relating to efficient
management, training of staff, computerisation and networking of their activities.
Consolidation in the Financial Sector
8.29 The Indian banking sector is gradually heading towards
consolidation of core competencies of different financial intermediaries and
to universal banking, with banks being permitted to diversify into long-term
finance and the DFIs into working capital. The universal banking may lead to
greater economic efficiency in the form of lower cost, higher output and better
products, but there is a need for caution in moving towards such a system by
banks and FIs.
8.30 Consolidation in the financial sector has started encompassing
development financial institutions, public sector banks and non-bank financing
companies. The need is to design the consolidation process so as to achieve
and harness convergence between the reforms undertaken in real sector, external
sector and the financial sector. The Indian Banks’ Association, the bankers’
apex body, has recently set up a committee to look into the intricacies of mergers
and acquisitions in the banking sector.
8.31 NBFCs encompass an extremely heterogeneous group of intermediaries.
They differ in various attributes viz., size, nature of incorporation
and regulation, as well as the basic functionality of financial intermediation.
While regulation of banks has been in place for a long time, the regulation
of NBFCs started when the Reserve Bank of India Act was amended in 1963 to provide
for the regulation of the deposit acceptance activities of these entities. Internationally,
acceptance of public deposits is restricted to banks, and non-banks including
NBFCs raise resources from institutional sources or by accessing capital market.
NBFCs are being encouraged to move in this direction in line with international
practices. The Reserve Bank would be holding discussions with NBFCs in regard
to their plan of action for voluntarily phasing out their acceptance of public
deposits and regulations on banks’ lending to NBFCs will be reviewed by the
Reserve Bank.
8.32 Residuary Non-Banking Companies (RNBCs) fall under the
sub-category of NBFCs with limited supervision of the Reserve Bank. RNBCs are
allowed to tap resources from banks, financial institutions and corporates though
in practice they have focussed primarily on public deposits. Given the discretionary
portfolio of the RNBCs, the scope for unrestricted growth in RNBCs may pose
serious threat to depositors’ safety. As such, revisiting the existing regulatory
structure for the RNBCs is of critical importance in the context of their historical
evolution.
8.33 Since RNBCs have little commonalities in terms of objectives
and workings of Development Financial Institutions (DFIs), attempts would need
to be made to transform them into one of the definable categories of NBFCs.
In order to impart greater liquidity and safety to investments of RNBCs, the
Reserve Bank has prescribed rationalisation of the pattern of directed investment.
This aims to reduce the overall systemic risk and thereby enhance the protection
available to depositors. RNBCs have been advised to reduce their discretionary
investment to 10 per cent of their deposits by April 2005 and completely dispense
with it from April 2006. With a view to smoothening the process of transition
of RNBCs an approach to comply with the Reserve Bank’s directions has been proposed
in the mid-term Review of annual policy for 2004-05. Under this approach, investments
of RNBCs in certificates of deposit of financial institutions which have a minimum
rating of AA+ at the time of investment would be reckoned as eligible securities
as long as they have minimum investment grade rating; current account balances
of RNBCs with commercial banks would be considered as eligible investments;
and the investments of RNBCs in bonds and debentures of companies which meet
stipulated listing and rating requirements at the time of investment would be
considered as ineligible investments if they migrate to below the investment
grade rating. In order to ensure that depositors are served appropriately and
systemic risks are avoided, the Reserve Bank has focused on transparency of
operations, corporate governance standards, adherence to ‘know your customer’
rules and customer services, etc.
Financial Stability
8.34 The critical challenge at this juncture is to improve
the allocative efficiency of resources and at the same time, guard against the
risks of disruptive financial imbalances. The mandate of financial stability,
in the Indian context, thus has to be seen in the broadest sense of the term,
calling for a three-pronged strategy of ensuring uninterrupted financial transactions;
maintaining a level of confidence in the financial system amongst all the participants
and stakeholders; and ensuring orderly conditions in the financial markets to
guard against potential adverse effects on real economic activity. The growing
integration of financial markets, especially the increasing inter-linkages between
domestic financial markets and the foreign exchange market, while desirable
for economic efficiency, tends to heighten the risk of contagion. Accordingly,
early warning indicators, pre-emptive measures and special defence mechanisms
need to be instituted for ensuring financial stability in the face of increasing
uncertainties in the global financial scenario. Recognising the increasing concern
about the impact of the conflicts of interest in the financial sector, a Working
Group on avoidance of conflicts of interest has been constituted to identify
sources and nature of potential conflicts of interest and make recommendations
for avoidance of such conflicts.
Regulatory Role of the Reserve Bank
8.35 Recognising the strengths of risk management systems that
have been put in place by the banks, the Reserve Bank has extended further flexibility
to banks on their loan policies. This is evident from the recent policy measures
announced by the Reserve Bank regarding credit exposure limits and unsecured
exposures. Recently, banks fulfilling certain criteria have been granted the
freedom to pay dividends without the prior approval of Reserve Bank, provided
the dividend pay out ratio does not exceed 33.3 per cent. In the present scenario,
the Reserve Bank has laid stress on greater responsibility of banks to safeguard
depositors’ interest and promotion of systemic stability through monitoring
of banks to ensure that they have adequate capital to cushion risk and that
they follow prudent and transparent accounting practices.
8.36 The Reserve Bank has been focusing on developing a competitive
operating environment in the financial sector in terms of markets, institutions,
products and practices. Increasing market orientation of the financial system
helps in improving allocative efficiency of resources.
At the same time, however, it exposes both public sector and
private sector financial intermediaries to various risks, necessitating prudential
regulation and supervision. The litmus test of regulatory design in a competitive
environment is to strengthen financial stability while at the same time, minimising
the costs of financial regulation. As the process of deregulation deepens, regulatory
initiatives have to be reoriented towards more pro-active supervision of the
financial system. It is in this context that the Reserve Bank’s supervisory
strategy has been to move away from micro-prescription oriented on-site supervision
to risk-based supervision. A key element of a market-oriented risk-based supervisory
strategy is to develop sound corporate governance practices, which would minimise
the need for process-focused supervision. The Reserve Bank, therefore, has been
emphasising corporate governance and better risk assessment within banks and
financial institutions, both public and private.
8.37 Greater transparency and better communication can make
the process of evolution and implementation of policy more effective. Therefore,
the Reserve Bank has adopted a consultative approach through formal institutional
structures such as the Board for Financial Supervision, the newly-formed Standing
Committee on Financial Regulation, the Technical Advisory Committee on Money,
Foreign Exchange and Government Securities Markets and also through specific
working groups and committees as well as formal and informal consultations with
the regulated entities, external experts and professionals.
Conclusion
8.38 The imperative of improving risk management systems of
banks must be seen as much from the angle of financial stability as from the
process of economic development. Improved risk assessment systems are expected
to enable banks to take greater exposures to sectors such as agriculture and
small-scale industries in which collateral valuations often pose difficulties.
This is all the more important as the pattern of credit demand has been changing
in recent years. Demand for bank credit from large corporates has been decelerating
because of financial restructuring, improvements in productivity, optimisation
of inventory cycles, better cash flow management, increased access to external
commercial borrowings and improved internal generation of funds. With better
risk assessment capabilities, banks should be able to shed their risk averse
attitude and extend more finance to hitherto unbanked segments of agriculture,
industry and services. Lending to retail segments, including housing and other
non-priority sector personal loans is increasing, fast. In this context, it
is important that banks Boards undertake an assessment of the risks involved.
Adequate risk management techniques should be put in place to enable banks cope
with risks of debt finance supported boost in consumer spending. Indian banks,
especially public sector banks, have significantly cleaned up their balance
sheets and are in a much better position to capitalise on this opportunity.
However, banks’ lending policies should address the new risks that emerge.
8.39 With revival in industrial credit off-take, the impact
of large credit increase has implications for macroeconomic management. It is
also important to ensure that the credit quality does not deteriorate. In view
of the strong growth in housing and consumer credit witnessed in recent years,
the mid-term Review of annual policy for 2004-05 has proposed to put in place
temporary risk-containment measures on housing and consumer loans. Risk weights
were increased from 50 per cent to 75 per cent in the case of housing loans
and from 100 per cent to 125 per cent in the case of consumer credit including
personal loans and credit cards. However, it is for banks’ Boards to exercise
due diligence and put in place risk containment measures. This will help in
keeping debt-financed growth in consumption orderly while helping asset formation
in the economy.
8.40 In order to enhance transparency in banks’ pricing of
the loan products, in the monetary and credit policy 2003-04 banks were advised
to announce a Benchmark Prime Lending Rate (BPLR) taking into account actual
cost of funds, operating expenses and a minimum margin to cover regulatory requirement
of provisioning/capital charge and profit margin, with the approval of their
Boards to ensure that the PLR truly reflects the actual cost. The BPLR guidelines
were modified suitably in consultation with banks and Indian Banks’ Association
so as to evolve an operationally flexible system. As of now, almost all commercial
banks have adopted the new system of benchmark PLR.
8.41 In order to support broad-based improvement in customer
service in respect of various banking services, banks have been advised to constitute
ad hoc Committees to undertake procedures and performance audit on public
services rendered by them. The Committees would look into simplification of
procedures and practices with a view to safeguarding the interests of common
persons, review the systems in place for providing service to the customers
in respect of meeting their demands for fresh/good notes and coins of all denominations,
exchanging soiled notes, adjudicating mutilated notes, and accepting coins and
notes either for transactions or in exchange, as also the regulations and procedures
prescribed by the Reserve Bank that impinge on customer service of banks. Banks
were advised to submit reports thereon to the Reserve Bank to enable the Standing
Committee (Chairman: Shri S.S.Tarapore) to review the existing policies and
procedures. The Standing Committee has submitted four Reports, on Foreign Exchange
Transactions, Government Transactions Relating to Individuals, Banking Operations
and Currency Management. Some of the recommendations of the Committee have already
been implemented by the Reserve Bank.
8.42 The Reserve Bank is currently examining various policy
options for further strengthening the financial sector. A well-calibrated deregulation
process is currently underway. As the process of strengthening financial sector
unfolds, it would have to take into account factors such as emerging market
structure in banking sector after the likely mergers and acquisitions, restructuring
of development financial institutions and appropriate timing of the entry of
foreign banks so as to be co-terminus with the transition to greater capital
account convertibility while being consistent with continuing obligation under
the WTO commitments. This has underscored the need for adoption of international
standards and global benchmarks in the progress towards globalisation, particularly
in the banking sector, given its systemic importance in the overall economy.