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Date : 30 Mar 2009
Advisory Panel on Financial Stability Assessment and Stress Testing - Volume III

INDIA’S FINANCIAL SECTOR AN ASSESSMENT

 
Volume III
 
Contents
 

Chapter No.

Subject

Page No.

 

Cover Page

 
 

Composition of the Advisory Panel

 
 

List of Acronyms

9

 

Terms of Reference and Scheme of Report

17

I.

The Macroeconomic Environment

31

 

1.1

Introduction

31

 

1.2

Linkages Between Macroeconomic Performance and Financial Stability

31

 

1.3

The Global Economy

33

 

1.4

India

38

 

1.5

Potential Areas of Macroeconomic Vulnerability

42

 

1.6

Institutional and Financial Market Environment

54

 

1.7

Concluding Remarks

58

II.

Aspects of Stability and Performance of Financial Institutions

61

 

2.1

Introduction

61

 

2.2

Commercial Banks

61

 

2.3

Regional Rural Banks

97

 

2.4

Co-operative Banks

98

 

2.5

The Broader Financial Sector

104

 

2.6

Other Key Concerns

118

 

2.7

Concluding Remarks

139

III.

Aspects of Stability and Performance of Insurance Sector

173

 

3.1

Introduction

173

 

3.2

Current Status

173

 

3.3

Macroeconomic Context

177

 

3.4

Indicators of Financial Strength

178

 

3.5

Major Risk Factors and Exposures

184

 

3.6

Stress Testing

185

 

3.7

Concluding Remarks

187

IV.

Aspects of Stability and Functioning of Financial Markets

191

 

4.1

Introduction

191

 

4.2

Financial Market Integration

192

 

4.3

Money Market

195

 

4.4

Foreign Exchange Market

201

 

4.5

Government Securities Market

209

 

4.6

Equity Market

224

 

4.7

Corporate Bond Market

236

 

4.8

Issues Related to the Credit Market

243

V.

Financial Infrastructure

249

 

5.1

Introduction

249

 

5.2

Regulatory and Supervisory Structure

249

 

5.3

Payment and Settlement Infrastructure

262

 

5.4

Business Continuity Management

272

 

5.5

Legal Infrastructure

287

 

5.6

Liquidity Infrastructure

295

 

5.7

Safety Net Issues - Deposit Insurance

307

 

5.8

Credit Information

317

VI.

Developmental Issues

327

 

6.1

Introduction

327

 

6.2

Customer Service

327

 

6.3

Financial Inclusion

329

 

6.4

Sustainability Issues

334

 

6.5

Access to Finance for Small Scale Industries (SSIs)

335

 

6.6

Concluding Remarks

338

VII.

Assessment and Recommendations

339

 

Peer Reviewers Comments

367

 

Appendix

   
 

Financial Stability Forum Report on Enhancing Market and Institutional Resilience - Summary of Recommendations

397

 

References

405

List of Boxes

 

Box 1.1

The Sub-Prime Crisis

34

Box 1.2

Challenges of Banking Sector in Funding Infrastructure Needs

47

Box 2.1

Vulnerability of Small Old Private Sector Banks

68

Box 2.2

Ownership Structure of Banks

69

Box 2.3

Financial Soundness of Large Banks

72

Box 2.4

Capital Augmenting Measures of Public Sector Banks

79

Box 4.1

Carry Trade

208

Box 4.2

Setting up of Debt Management Office (DMO)

210

Box 4.3

Working Group on Interest Rate Futures - Recommendations

219

Box 4.4

Recommendations of High Level Committee on Corporate Debt

242

Box 5.1

Objectives-Based Regulation

256

Box 5.2

Should Bank Supervision be Separated from the Central Bank?

261

Box 5.3

Use of Telecom for Banking Outreach - Cross-Country Evidence

270

Box 5.4

Major Legal Reforms in Banking

288

Box 5.5

Term Liquidity Facility

300

Box 5.6

The Reserve Bank''s Response to the Global Financial Crisis

305

Box 5.7

Stress Tests of Deposit Insurance

314

Box 6.1

Socially Responsible Investment - Country Practices

335

List of Tables

 

Table 1.1

Output Growth, Inflation and Interest Rates in Select Economies

35

Table 1.2

Key Macroeconomic Ratios (Per Cent to GDP)

38

Table 1.3

Benchmark Policy Rates

40

Table 1.4

Correlations With Agriculture Sector Growth

44

Table 1.5

Fiscal Deficit (Per Cent to GDP)

45

Table 1.6

Doing Business - Global Comparisons (2007-08)

49

Table 1.7

Structure of Indian Financial Institutions

55

Table 1.8

Relative Importance of Various Financial Market Segments

58

Table 1.9

Select Financial Instruments and Credit (Outstanding to GDP ratio)

59

Table 2.1

Commercial Banks - Then and Now

64

Table 2.2

Indicators of Financial Depth - 2008

65

Table 2.3

Bank Group-wise Relative Business Size of Commercial Banks

66

Table 2.4

Asset Concentration Ratios of Banks - Comparative Position

71

Table 2.5

Bank Assets Per Employee

72

Table 2.6

Bank Productivity in India - 2007 & 2008

73

Table 2.7

Soundness Indicators of the Banking Sector

75

Table 2.8

Soundness Indicators of the Banking Sector - March 2008

76

Table 2.9

Summary of Capital Projections for Nationalised Banks

77

Table 2.10

Select Banking Crises and Fiscal Cost

79

Table 2.11

Z-score for Domestic Commercial Banks: 1997-2008

80

Table 2.12

Asset Quality of Commercial Banks

81

Table 2.13

Asset Quality - end March 2008

82

Table 2.14

Banks'' Coverage Ratios

82

Table 2.15

Asset Slippage Across Bank Groups

83

Table 2.16

Earnings and Profitability Indicators of Commercial Banks

85

Table 2.17

Earnings and Profitability Indicators of Commercial Banks-2007-08

85

Table 2.18

Return on Assets (Return on Equity) for Bank Groups

86

Table 2.19

Sources of Income of Banks

87

Table 2.20

Burden of Bank Groups

87

Table 2.21

Cost - Income Ratio and Interest Expense Ratio of Bank Groups

88

Table 2.22

Dynamics of Profit Augmentation for Bank Groups

89

Table 2.23

Liability Profile of the Indian Banking System

90

Table 2.24

Deposit Structure of Indian Banks

91

Table 2.25

Liquidity Ratios and Definitions

92

Table 2.26

Liquidity Ratios - Frequency Distribution and Average Value

94

Table 2.27

Performance Indicators of Regional Rural Banks

97

Table 2.28

Urban Co-operative Banks - Business and Profitability

99

Table 2.29

Number of Scheduled UCBs Defaulting on CRAR Maintenance

102

Table 2.30

Performance of Rural Cooperative Banks (Short-term Structure)

103

Table 2.31

Performance of Rural Cooperative Banks (Long-term Structure)

103

Table 2.32

Profile of NBFC-D/RNBC Segment

105

Table 2.33

Public Deposits According to Interest Rate and Maturity of NBFCs-D

106

Table 2.34

Public Deposits and NPAs Across Different Classes of NBFCs-D

107

Table 2.35

Profile of Systemically Important Non-Deposit Taking NBFCs

108

Table 2.36

Select Indicators of DFIs

109

Table 2.37

Profile of DFIs

110

Table 2.38

Average Ratios on Capital Adequacy - HFCs

111

Table 2.39

Ratios on Asset Quality-HFCs

112

Table 2.40

Ratios on Earnings and Profitability - HFCs

113

Table 2.41

Indicators of Financial Stability in Manufacturing

114

Table 2.42

Planned Capital Expenditure

115

Table 2.43

Indebtedness Over Time at All-India Level

117

Table 2.44

The Inverse Monotonicity Between Indebtedness and Asset Holdings - 2002/03

118

Table 2.45

Distribution of Households Reporting Cash Debt According to Credit Agencies (AIDIS, 1991-92 and AIDIS 2002-03) - Debt to Asset Ratios

119

Table 2.46

Banks' Exposure to Sensitive Sectors

126

Table 2.47

OBS Exposure of Commercial Banks

127

Table 2.48

Executive Compensation in the Banking Sector

131

Table 2.49

Income Diversity of Bank Groups

133

Table 2.50

Cross-Country Limits for Loan Exposure to Single Borrower

133

Table 2.51

Deposits of Rural Financial Institutions - 2007

136

Table 3.1

Number of Registered Insurance and Re-insurance Companies

174

Table 3.2

Premium Growth Rate in Per Cent (Life Insurance)

175

Table 3.3

Segment-wise Growth of Premium in Per Cent (Non-life Sector)

176

Table 3.4

Insurance Industry Related Parameters

177

Table 3.5

Financial Soundness Indicators for Life Insurance Industry

179

Table 3.6

Financial Soundness Indicators for Non-Life Insurance Industry

182

Table 3.7

Regulatory Solvency Ratios of Life Insurance Companies

183

Table 3.8

Regulatory Solvency Ratios of Non-life Insurance and Re-insurance Companies

184

Table 3.9

Stress Testing - Results

187

Table 4.1

Correlation Matrix Across Markets

193

Table 4.2

Activity in Money Market Segments

197

Table 4.3

Volatility in Money Market Rates

199

Table 4.4

Indicators of Indian Foreign Exchange Market Activity

203

Table 4.5

Government Securities Market - A Profile

213

Table 4.6

Funding of Gross Fiscal Deficit Through Market Borrowings

214

Table 4.7

Commercial Banks: Interest Rate Swaps - Outstanding Notional Principal (Benchmark-wise Details)

217

Table 4.8

Classification of Government Securities in Banks' Investment Portfolio

220

Table 4.9

Annual Index Returns

226

Table 4.10

Trends in Market Capitalisation

227

Table 4.11

Equity Spot Market Liquidity

228

Table 4.12

Total Turnover in Cash and Derivatives Segments of Equity Markets

229

Table 4.13

Resource Mobilisation by the Corporate Sector

239

Table 4.14

Secondary Market Transactions in Corporate Bonds (2007-08)

239

Table 4.15

Spreads Between Corporate Bonds and Government Securities

240

Table 4.16

Credit Risk Transfer Through Loan Sales and Securitisation

245

Table 5.1

Classification of Institutions as 'Conglomerates' According to Financial Market Presence

257

Table 5.2

Payment System Indicators

267

Table 5.3

Retail Electronic Funds Transfer System

268

Table 5.4

Computerisation in Public Sector Banks

269

Table 5.5

Total CCIL Settlement Volumes

276

Table 5.6

Progress in Setting up of Data Centres

279

Table 5.7

Daily Average Liquidity Absorptions

296

Table 5.8

India's Capital Flows: Composition

301

Table 5.9

Extent of RBI Intervention in Foreign Exchange Market

304

Table 5.10

India's Foreign Exchange Reserves

306

Table 5.11

External Sustainability Indicators

307

Table 5.12

Features of Deposit Insurance Scheme

309

Table 5.13

Position of Various Funds of DICGC

310

Table 5.14

Trend in Claim Settlement and Premium Received

311

Table 5.15

Risk-adjusted Premiums - Cross-County Experience

312

Table 5.16

Designated Reserve Ratio of the DIF

313

Table 5.17

Credit Information Bureaus: Country Experience

318

Table 6.1

Regional Differences in Financial Services

331

Table 6.2

Share of Top 100 Centres in Aggregate Deposits and Credit

331

Table 6.3

Trends in Rural Banking

331

Table 6.4

Performance of SSI Sector

336

Table 6.5

Definition of Micro, Small and Medium Enterprises

336

Table 6.6

‘Credit Gap’ for SSI

338

List of Charts

 

Chart 1.1

Macroeconomic Shocks and Financial Stability

32

Chart 1.2

Business Confidence Index

39

Chart 1.3

Movement in Key Policy Rates and Reserve Requirements

40

Chart 1.4

NEER and REER of Indian Rupee

41

Chart 1.5

Demographic Transition

50

Chart 1.6

Percentage of Working Age Population (Forecast)

50

Chart 1.7

International Commodities

51

Chart 2.1

Bank Assets and Net Interest Margin - 2005

62

Chart 2.2

CRAR and NPA Ratio of Commercial Banks - 2006

63

Chart 2.3

Trend in CRAR and Capital Ratio

76

Chart 2.4

Asset Quality of Commercial Banks

81

Chart 2.5

Impaired Loan to Outstanding Loan (Category-wise) in Retail Portfolio

83

Chart 2.6

RoA and RoE - Cross Country Comparisons

84

Chart 2.7

Interest Expense Ratios & NIM of Commercial Banks

88

Chart 2.8

Structure of Co-operative Banking Sector

98

Chart 2.9

Select Prudential and Financial Indicators of Co-operative Banks

101

Chart 2.10

Asset Quality Indicators of HFCs

112

Chart 2.11

Growth in Advances and Investments of Banks

122

Chart 2.12

Credit-Deposit and Investment-Deposit Ratios

122

Chart 2.13

Sub-BPLR Loans

123

Chart 2.14

Credit Flow to Priority Sector and Major Industries

125

Chart 2.15

Share of Retail Loans in Total Loans

125

Chart 3.1

Life Insurance Penetration & Per Capita (2006)

175

Chart 4.1

Movements in Government Securities and Money Market Rates

194

Chart 4.2

Movements in Exchange Rate and Stock Market

194

Chart 4.3

Foreign Exchange Forwards and Money Market Rates

195

Chart 4.4

Bid-Ask Spread in the Inter-bank Overnight Money Market
(April 1, 2004 - November 25, 2008)

198

Chart 4.5

Daily Turnover in the INR/USD Market

203

Chart 4.6

NDF Movement

204

Chart 4.7

Bid-Ask Spread (INR/USD) in Spot Foreign Exchange Market

204

Chart 4.8

Movement of Forward Premia and INR/USD Exchange Rate

205

Chart 4.9

Transmission from Call Money Market to Forward Market

205

Chart 4.10

Holding Pattern of Central and State Government Securities (Outstanding as at end-March)

211

Chart 4.11

Yield and Maturity of Central Government Dated Securities

215

Chart 4.12

Yield Curve Movement - SGL Transactions

215

Chart 4.13

2-10 year Spread in Government Securities Market

216

Chart 4.14

Movements in Yield Spread

216

Chart 4.15

Yield and Annual Turnover (Dated Central Government Securities)

220

Chart 4.16

Trading Volumes in ‘When Issued’ Market

224

Chart 4.17

(a) Per Cent Variation in 2007-08 Domestic Market Capitalisation In Equity Market

227

Chart 4.17

(b) Per Cent Variation in 2008-09 (up to 11.11.08) Domestic Market Capitalisation In Equity Market

227

Chart 4.18

Comparative Movement of World Indices (Normalised to End-December 2005=100)

228

Chart 4.19

NSE - Break-up of Gross Turnover in Cash Segment (Per Cent)

229

Chart 4.20

NSE - Break-up of Gross Turnover in Derivatives Segment (Per Cent)

230

Chart 4.21

Resource Mobilisation from the Primary Capital Market

230

Chart 4.22

Equity Valuations in India

231

Chart 4.23

Net FII Inflows and P/E Ratio

232

Chart 4.24

Volatility of World Indices (Co-efficient of Variation)

233

Chart 4.25

Volatility Index of S&P CNX Nifty

233

Chart 4.26

Implied Volatility of the Call Options - NSE

234

Chart 4.27

Implied Volatility of the Put Options - NSE

234

Chart 4.28

Open Interest in Nifty Index Futures (No. of Contracts)

235

Chart 4.29

Open Interest in Nifty Index Futures (Value)

235

Chart 4.30

Share in Total Credit - Position as at end March 2008

244

Chart 5.1

Money Market Rates

297

Chart 5.2

LAF Corridor and the Call Rate

297

Chart 5.3

INR/USD Market

302

Chart 5.4

Stock Markets are Directly Fuelled by FII Inflows

303

Chart 5.5

INR/USD Movement During Same Period

303

Chart 6.1

Share of Credit to SSI vs. Share of SSI in GDP

337

List of Annexes

 

Annex 2.1

Projected Capital Requirements of Nationalised Banks

140

Annex 2.2

Credit Risk Stress Test - Scenarios and Results

142

Annex 2.3

Asset-Liability Mismatches

145

Annex 2.4

Liquidity Scenario Analysis

148

Annex 2.5

Interest Rate Risk - Scenarios and Results

152

Annex 2.6

House Price Index and Housing Starts

159

Annex 2.7

Human Resource Issues in Public Sector Banks

160

Annex 2.8

Bank Consolidation

164

Annex 2.9

Credit Portfolio Management

167

Annex 2.10

Loan Loss Provisioning

169

Annex 2.11

Off-balance Sheet Activities of Banks

171

Annex 3.1

RoE Tree Framework for Life Insurance Companies

190

Annex 5.1

Regulatory Structure of Indian Financial System - Institutions and Markets

320

Annex 5.2

Major Models of Financial Regulation and Supervision

321

Annex 5.3

Large and Complex Banking Groups

323

Annex 5.4

Laws Relating to Financial Stability

325

 

INDIA’S FINANCIAL SECTOR AN ASSESSMENT

 
Volume III

Advisory Panel on Financial Stability Assessment and Stress Testing

 

Committee on Financial Sector Assessment March 2009

 
1
 

This Report was completed in June 2008. However, looking at the global financial developments of late, an attempt has been made to update some relevant portions of the report, particularly Chapter I (Macroeconomic Environment) and Chapter IV (Aspects of Stability and Functioning of Financial Markets).

 

© Committee on Financial Sector Assessment, 2009

All rights reserved. No part of this publication may be reproduced, stored in a retrieval system, or transmitted in any form or by any means, electronic, mechanical, photocopying, recording and/or otherwise, without the prior written permission of the publisher.

 

Sale Price: Rs. 2,000

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Published by Dr. Mohua Roy, Director, Monetary Policy Department, Reserve Bank of India, Central Office, Mumbai - 400 001 and printed at Jayant Printery, 352/54, Girgaum Road, Murlidhar Temple Compound, Near Thakurdwar Post Office, Mumbai - 400 002.
 

Composition of the Advisory Panel on
Financial Stability Assessment and Stress Testing

Shri M.B.N.Rao

Chairman and Managing Director Canara Bank

Chairman

Dr. Rajiv B. Lall

Managing Director and Chief Executive Officer Infrastructure Development Finance Company Ltd.

Member

Dr. T.T.Ram Mohan

Professor Indian Institute of Management Ahmedabad

Member

Shri Ravi Mohan

Managing Director and Region Head Standard & Poor's, South Asia

Member

Shri Ashok Soota

Chairman and Managing Director Mind Tree Consulting Ltd.

Member

Shri Pavan Sukhdev

Head of Global Markets Deutsche Bank AG.

Member

Special Invitees

   

Shri G.C. Chaturvedi

Joint Secretary (Banking & Insurance) Department of Financial Services Ministry of Finance Government of India

 

Dr. K. P. Krishnan

Joint Secretary (Capital Markets) Department of Economic Affairs Ministry of Finance Government of India

 

Shri Amitabh Verma

Joint Secretary (Banking Operations) Department of Financial Services Ministry of Finance Government of India

 

Shri V.K.Sharma

Executive Director Reserve Bank of India

 

Dr. R. Kannan

Member (Actuary) Insurance Regulatory and Development Authority

 

Dr. Sanjeevan Kapshe

Officer on Special Duty Securities and Exchange Board of India

 
 

List of Acronyms

 

ABS

Asset Backed Securities

ACRC

Agricultural Credit Review Committee

AD

Authorised Dealer

ADR

American Depository Receipt

AFC

Asset Finance Company

AFS

Available for Sale

AGL

Aggregate Gap Limit

AIDIS

All India Debt and Investment Survey

ALD

Aggregate Liability to Depositors

ALM

Asset Liability Management

AMBI

Association of Merchant Bankers of India

AMFI

Association of Mutual Funds of India

ANMI

Association of National Exchange Members of India

ANP

Average of Net Premiums

ATM

Automated Teller Machine

AU

Asset Utilisation

AUM

Assets under Management

BCBS

Basel Committee on Banking Supervision

BCI

Business Confidence Index

BCM

Business Continuity Management

BCP

Business Continuity Plan

BCP

Basel Core Principles

BCSBI

Banking Codes and Standards Board of India

BE

Budget Estimates

BFRS

Board for Financial Regulation and Supervision

BFS

Board for Financial Supervision

BHC

Bank Holding Company

BIS

Bank for International Settlements

BO

Banking Ombudsman

BPLR

Benchmark Prime Lending Rate

BPO

Business Process Outsourcing

BPSS

Board for regulation and supervision of Payment and Settlement Systems

BR Act

Banking Regulation Act

BSE

Bombay Stock Exchange

CA

Current Account

CAB

Change Approval Board

CAC

Capital Account Convertibility

CAGR

Compound Average Growth Rate

CAMELS

Capital adequacy, Asset quality, Management, Earnings, Liquidity and Systems

CASA

Current And Savings Account

CBLO

Collateralised Borrowing and Lending Obligation

CBS

Core Banking Solution/s

CCC

Credit Card Companies

CCF

Contingent Credit Facility

CCIL

Clearing Corporation of India Ltd.

CCP

Central Counter Party

CD

Credit deposit/Certificates of Deposit

CDBMS

Centralised Data Base Management Systems

CDO

Collateralised Debt Obligation

CDS

Credit Default Swap

CDSL

Central Depository Services (India) Ltd.

CEO

Chief Executive Officer

CFCAC

Committee on Fuller Capital Account Convertibility

CFMS

Centralised Funds Management System

CFS

Consolidated Financial Statements

CFSA

Committee on Financial Sector Assessment

CGF

Credit Guarantee Fund

CHF

Swiss Franc

CIB

Credit Information Bureau

CIBIL

Credit Information Bureau (India) Ltd.

CIP

Central Integrated Platform

CIR

Cost Income Ratio

CLO

Collateralised Loan Obligation

CLS

Continuous Linked Settlement

CMBS

Commercial Mortgage-Backed Security

CMD

Chairman and Managing Director

CoR

Certificate of Registration

CP

Commercial Paper

CPC

Cheque Processing Centre

CPI

Consumer Price Index

CPM

Credit Portfolio Management

CPPAPS

Committee on Procedures and Performance Audit of Public Services

CPR

Consolidated Prudential Reports

CPSS

Committee on Payment and Settlement Systems

CRAR

Capital to Risk-weighted Assets Ratio

CRISIL

Credit Rating Information Services of India Ltd.

CRR

Cash Reserve Ratio

CRT

Credit Risk Transfer

CSR

Corporate Social Responsibility

CUG

Closed User Group

CVC

Central Vigilance Commission

DCCB

District Central Cooperative Bank

DFI

Development Financial Institution

DI

Deposit Insurance

DICGC

Deposit Insurance and Credit Guarantee Corporation

DIF

Deposit Insurance Fund

DMA

Direct Marketing Associates/ Agencies

DMO

Debt Management Office

DNS

Deferred Net Settlement

DoE

Duration of Equity

DOS

Denial of Service

DR

Disaster Recovery

DRAT

Debt Recovery Appellate Tribunal

DRR

Designated Reserve Ratio

DRT

Debt Recovery Tribunal

DSA

Direct Selling Association/ Agency

DVP

Delivery versus Payment

EaR

Earnings at Risk

ECB

European Central Bank/External Commercial Borrowing

ECR

Export Credit Refinance

ECS

Electronic Clearing Service

EFT

Electronic Funds Transfer

EL

Equipment Leasing

EME

Emerging Market Economy

ESM

Enterprise Security Management

ESOP

Employees Stock Option Plan

EV

Economic Value

FAO

Food and Agriculture Organisation

FC

Financial Conglomerate/Foreign Currency

FCA

Foreign Currency Asset

FCAC

Fuller Capital Account Convertibility

FCCB

Foreign Currency Convertible Bond

FCNR

Foreign Currency Non Resident

FDI

Foreign Direct Investment

FDIC

Federal Deposit Insurance Corporation

FEDAI

Foreign Exchange Dealers' Association of India

FEMA

Foreign Exchange Management Act

FERA

Foreign Exchange Regulations Act

FFMC

Full Fledged Money Changer

FII

Foreign Institutional Investor

FIMMDA

Fixed Income, Money Market and Derivatives Association of India

FIU-IND

Financial Intelligence Unit-India

FMC

Financial Markets Committee

FPI

Foreign Portfolio Investment

FPSBI

Financial Planning Standards Board of India

FRBM Act

Fiscal Responsibility and Budget Management Act

FSI

Financial Stability Institute

FY

Financial Year

GBC

Gross Bank Credit

GCC

General Credit Card

GCF

Gross Capital Formation

GDP

Gross Domestic Product

GDR

Global Depository Receipt

GE

General Electric

GER

Gross Enrolment Ratio

GoI

Government of India

GP

Gross Premium

G-Secs

Government Securities

HFC

Housing Finance Company

HFT

Held for Trading

HIDS

Host Intrusion Detection System

HLCCFM

High Level Coordination Committee on Financial Markets

HP

Hire Purchase

HR

Human Resource

HTM

Held to Maturity

HUDCO

Housing and Urban Development Corporation

IAIS

International Association of Insurance Supervisors

IAS

International Accounting Standards

IBNR

Incurred But Not Reported

IC

Investment Companies

ICAAP

Internal Capital Adequacy Assessment Process

ICAI

Institute of Chartered Accountants of India

ICOR

Incremental Capital Output Ratio

IDFC

Infrastructure Development Finance Company

IDL

Intra-Day Liquidity

IDS

Intrusion Detection System

IEM

Industrial Entrepreneurs Memoranda

IFCI

Industrial Finance Corporation of India

IFRS

International Financial Reporting Standards

IIBI

Industrial Investment Bank of India

IIFC

India Infrastructure Finance Company

IMF

International Monetary Fund

IMSS

Integrated Market Surveillance System

INFINET

Indian Financial Network

INR

Indian Rupee

IOSCO

International Organisation of Securities Commissions

IPDI

Innovative Perpetual Debt Instrument

IPO

Initial Public Offer

IPS

Intrusion Prevention System

IRAC

Income Recognition and Asset Classification

IRDA

Insurance Regulatory and Development Authority

IRF

Interest Rate Futures

IRFC

Indian Railway Finance Corporation

IRS

Interest Rate Swaps

ISDA

International Swaps and Derivatives Association

IT

Information Technology

IT Act

Information Technology Act

ITC

India Tobacco Company

ITES

Information Technology Enabled Services

JPY

Japanese Yen

KCC

Kisan Credit Card

KYC

Know Your Customer

LAB

Local Area Bank

LAF

Liquidity Adjustment Facility

LC

Loan Companies

LCB

Large and Complex Bank

LCBG

Large and Complex Banking Group

LCDS

Loan Credit Default Swaps

LIB OR

London Interbank Offered Rate

LIC

Life Insurance Corporation of India

LLP

Loan Loss Provision

LLR

Lender of Last Resort

LoC

Line of Credit

LPG

Liquefied Petroleum Gas

LTV

Loan to Value

MBC

Mutual Benefit Company

MBFC

Mutual Benefit Finance Company

MCA

Model Confidentiality Agreement

MFI

Micro Finance Institution

MIBOR

Mumbai Inter-Bank Offer Rate

MICR

Magnetic Ink Character Recognition

MIFOR

Mumbai Inter-Bank Forward Offer Rate

MIS

Management Information System

MNBC

Miscellaneous Non Banking Company

MoU

Memorandum of Understanding

MR

Mathematical Reserves

MRTP Act

Monopolies and Restrictive Trade Practices Act

MSCI

Morgan Stanley Capital International

MSE

Micro and Small Enterprises

MSMED Act

Micro, Small and Medium Enterprises Development Act

MSS

Market Stabilisation Scheme

MTM

Marked to Market

NA

Not Available

NABARD

National Bank for Agriculture and Rural Development

NBFC

Non-Banking Finance Company

NBFC-ND-SI

Non Deposit Taking Systemically Important Non-Banking Finance Company

NBO

National Building Organisation

NCAER

National Council of Applied Economic Research

NCLT

National Company Law Tribunal

NDA

Non-Disclosure Agreement

NDF

Non-Deliverable Forwards

NDP

Net Domestic Product

NDS

Negotiated Dealing System

NDTL

Net Demand and Time Liabilities

NEAT

National Exchange for Automated Trading

NEFT

National Electronic Funds Transfer

NFS

National Financial Switch

NGO

Non Governmental Organisation

NHB

National Housing Bank

NII

Net Interest Income

NIM

Net Interest Margin

NL

Non-Linked

NLNBP

Non-Linked New Business Premium

NLNPNBP

Non-Linked Non-Par New Business Premium

NoF

Net Owned Fund

NP

Net Premium

NPA

Non-Performing Assets

NPL

Non-Performing Loans

NRE

Non Resident External

NRFIP

National Rural Financial Inclusion Plan

NSCCL

National Securities Clearing Corporation Ltd.

NSDL

National Securities Depository Ltd.

NSE

National Stock Exchange

OBS

Off-Balance Sheet

ODC

Office Data Connection

OECD

Organisation for Economic Co-operation and Development

OIS

Overnight Indexed Swap

OMO

Open Market Operation

OPB

Old Private-sector Bank

OTC

Over The Counter

P/E ratio

Price Earnings Ratio

PACS

Primary Agricultural Credit Societies

PCA

Prompt Corrective Action

PCARDB

Primary Cooperative Agriculture and Rural Development Bank

PD

Primary Dealer

PDAI

Primary Dealers Association of India

PDO

Public Debt Office

PFC

Power Finance Corporation

PFI

Public Financial Institution

PFRDA

Pension Fund Regulatory and Development Authority

PLR

Prime Lending Rate

PM

Profit Margin

PMLA

Prevention of Money Laundering Act

PN

Participatory Note

PoS

Point of Sale

PPP

Public Private Partnership

PSB

Public Sector Bank

PV

Present Value

PV01

Present Value Impact of 1 Basis Point Movement in Interest Rate

QIB

Qualified Institutional Buyers

RaRoC

Risk-adjusted Return on Capital

RBI

Reserve Bank of India

RBS

Risk Based Supervision

RC

Reconstruction Company

RCS

Registrar of Cooperative Societies

RE

Revised Estimate

REC

Rural Electrification Corporation

RMBS

Residential Mortgage Backed Securities

RMDS

Reuters Market Data System

RNBC

Residuary Non-Banking Companies

RoA

Return on Assets

RoE

Return on Equity

RRB

Regional Rural Bank

Rs.

Indian Rupees

RTGS

Real Time Gross Settlement

RWA

Risk Weighted Asset

SA

System Administrator

SARFAESI

Act Securitisation And Reconstruction of Financial Assets and Enforcement of Security Interest Act

SBI

State Bank of India

SC

Securitisation Company

SCARDB

State Cooperative Agriculture and Rural Development Bank

SCB

Scheduled Commercial Bank

SCRA

Securities Contracts (Regulation) Act

SD

Standard Deviation

SDDS

Special Data Dissemination Standards

SEBI

Securities and Exchange Board of India

SFC

State Financial Corporation

SGL

Subsidiary General Ledger

SHG

Self Help Group

SIDBI

Small Industries Development Bank of India

SIDC

State Industrial Development Corporation

SIPS

Systemically Important Payment Systems

SIV

Structured Investment Vehicles

SLOC

Source Lines of Code

SLR

Statutory Liquidity Ratio

SME

Small and Medium Enterprise

SPV

Special Purpose Vehicle

SR

Solvency Ratio

SRI

Socially Responsible Investment

SRO

Self Regulatory Organisation

SSI

Small-Scale Industry

SSS

Securities Settlement System

StCB

State Cooperative Bank

STP

Straight Through Processing

SUCB

Scheduled Urban Co-operative Bank

TAFCUB

Task Force for Urban Cooperative Banks

TAG

Technical Advisory Group

TDS

Tax Deduction at Source

TFCI

Tourism Finance Corporation of India

TMR

Total Mathematical Reserves

TRAI

Telecom Regulatory Authority of India

UCB

Urban Cooperative Bank

UK

United Kingdom

US

United States

USD

US Dollar

VaR

Value at Risk

VC

Vice Chairman

VRS

Voluntary Retirement Scheme

WDM

Wholesale Debt Market

WI

When Issued

WMA

Ways and Means Advance

WOS

Wholly Owned Subsidiaries

WPI

Wholesale Price Index

 

Terms of Reference and Scheme of Report

 

The Government of India, in consultation with the Reserve Bank of India constituted the Committee on Financial Sector Assessment (CFSA) in September 2006, with a mandate to undertake a comprehensive assessment of the Indian Financial Sector, focusing upon stability and development. The CFSA was chaired by Dr. Rakesh Mohan, Deputy Governor, Reserve Bank of India. The Co-Chairmen at different points in time were Shri Ashok Jha, Dr. D. Subbarao and Shri Ashok Chawla, Secretary, Economic Affairs, Government of India. The Committee also had other officials from the Government of India as its members.

To assist the Committee in the process of assessment, the CFSA constituted four Advisory Panels respectively for the assessment of Financial Stability Assessment and Stress Testing, Financial Regulation and Supervision, Institutions and Market Structure and Transparency Standards. These Panels were assisted by Technical Groups comprising mainly of officials from relevant organisations to provide technical inputs and data support, as appropriate, to the respective Advisory Panels.

Taking into account the legal, regulatory and supervisory architecture in India, it was felt that there was a need for involving and closely associating the major regulatory institutions, viz., Reserve Bank of India (RBI), Securities and Exchange Board of India (SEBI) and Insurance Regulatory and Development Authority (IRDA), in addition to representatives from the Government. Based on the discussion with the regulatory agencies, IRDA instituted its own groups for financial stability assessment and stress testing and financial regulation and supervision, whereas the Reserve Bank and SEBI nominated suitable officials for the Technical Groups. These institutions were also represented in Advisory Panels, constituted by the CFSA, as Special Invitees. In order to leverage the available expertise to the maximum permissible extent, it was also deemed fit to involve, besides the above regulatory authorities, other agencies as relevant to the work.

Advisory Panel on Financial Stability Assessment and Stress Testing

A key analytical component of financial sector assessment was a comprehensive assessment of financial stability and stress testing of the Indian financial sector. The Advisory Panel on Financial Stability Assessment and Stress Testing was constituted to conduct macro-prudential surveillance (including system level stress testing) to assess the soundness and stability of financial system and suggest measures for strengthening the financial structure and system and its development in a medium-term perspective. The Advisory Panel chaired by Shri M.B.N. Rao comprised of non-official experts as members and officials representing Government and other agencies as special invitees – Annex A.

The terms of reference of the Advisory Panel were:
  • to conduct an analysis of macro-prudential surveillance and financial stability (including business continuity and disaster recovery) and to assess the impact of potential macroeconomic and institutional factors (both domestic and external) on the soundness (risks and vulnerabilities) and stability of financial systems;
  • to analyse relevant data and information and apply techniques and methodologies as relevant to banking, insurance, securities markets and non-banking financial sectors;
  • to subject the assessment of stability to stress testing duly taking into account potential impact of macroeconomic and institutional factors and risks on the stability (including business continuity and disaster recovery) indicators, including natural and man-made disasters/catastrophe; and
  • based on the assessment, suggest measures for strengthening the financial structure and system and its development in a medium-term perspective.
The Advisory Panel also had the option of co-opting as Special Invitees any other experts as they deemed fit.

Technical Group on Financial Stability Assessment and Stress Testing

A Technical Group comprising of officials drawn from the Government and other agencies who are directly associated with respective areas of work, assisted the Advisory Panel in preparing preliminary assessments and background material which served as inputs to the Advisory Panel's work (Please see Annex B for the composition of the Technical Group and terms of reference). Apart from the officials indicated in the Annex B the Panel also benefited from the inputs of the officials indicated in Annex C. IRDA formed its own Technical Group for assessment of aspects of Stability and Performance of the Insurance Sector - Annex D.

Approach and Methodology

Along with the Reserve Bank and SEBI officials, the Technical Group involved officials from CCIL, CRISIL, ICRA, DICGC, ICICI Bank, SBI, NABARD, NHB and IBA in their deliberations. To facilitate analysis of various areas which were covered in the report, the group formed three sub-groups. The first one was for deciding upon the methodology to be adopted for conduct of various system level stress tests and projections. Another sub-group went into identification of issues germane to financial stability. The third sub-group deliberated on the methodology to be adopted for assessment of level of Business Continuity Management in the Indian financial system. Focused discussions were held with some members of other Advisory Panels on HR issues and financial inclusion. The Group also held discussions with various resource persons within the Reserve Bank in areas of their expertise. The preliminary report of the Technical Group also drew on initial write ups provided by various departments within RBI. Similarly, IRDA in its separate exercise drew resources from Life Insurance Council, Prudential Corporation, Asia, ICICI Prudential Life Insurance Company Ltd, IIM, Bangalore and Genpact. Based on the deliberations of the Technical Groups, the Secretariat to the Committee identified the preliminary set of issues and results which was taken up for discussion by the Advisory Panel.

The Advisory Panel also drew upon various reports published, both in India and elsewhere. A major input for the Report was the Handbook on Financial Sector Assessment, published by the Fund and the World Bank in September 2005. Drawing on the framework for assessment as elucidated in the Handbook, the draft Report has been tailored to suit country-specific realities, taking on board the state of development of the financial system and the maturity of financial institutions and markets. The report also benefited from the issues and recommendations flagged by other Advisory Panels on assessments of standards and codes. Extensive use has been made of off-site supervisory data in building up of various financial soundness indicators and stress testing. The Advisory Panel held a total of nine meetings.

Peer Review

At the request of the CFSA, two international experts (Annex E) peer reviewed the draft reports on respective assessments and recommendations. The Advisory Panel considered in depth the comments made by the peer reviewers and modified the report after appropriately incorporating their comments / suggestions. The Panel also had the option to differ with the peer reviewers comments. In the interest of transparency, the comments of the peer reviewers and the stance taken by the Panel thereon are appended to this report.

Scheme of the Report

The report is divided into seven chapters. Chapter I dwells on the macroeconomic environment in the backdrop of current global economic scenario. To the extent that the overall economic situation impinges upon the functioning of institutions, markets and infrastructure, the analysis in this Chapter focuses on potential areas of vulnerabilities which have a bearing on overall stability for sustained growth. It provides an overview of the institutional and financial market environment, bringing out the importance of various financial institutions in the overall financial system as also the relative importance of various financial market segments.

Chapter II assesses the soundness and performance of financial institutions and discusses the emerging issues confronting the financial institutions at the present juncture. It employs various ratios/trend analyses to gauge the performance of financial institutions and benchmarks them with available international best practices, as appropriate. In addition, drawing upon recent events in global financial markets, the analysis also devises a set of liquidity ratios and evaluates the trends. Institutional coverage includes banking sector (commercial banks/Regional Rural Banks/co­operative banks), broader financial sector (NBFCs, DFIs and HFCs) as also the relevant non-financial sectors (corporate and household). Central to the analyses of Chapter II has been the use of stress tests to ascertain the resilience of the concerned institutions. Taking into account the maturity of the financial system and the present financial health of the relevant institutions, stress tests were appropriately designed to focus on the major risk factors.

Chapter III examines the stability and performance of the insurance sector. Subsequent to its opening up to private participation, there has been a rapid growth in this sector. As a consequence, it was deemed desirable to undertake an initial assessment of the strength and resilience of this sector including a stress test.

Chapter IV examines the stability and functioning of financial markets, including the money market, government securities market, foreign exchange market, equity market and corporate bond market. In addition, it also addresses the stability and developmental issues as germane to the credit market.

Financial infrastructure issues are examined in Chapter V, covering the payment and settlement infrastructure, business continuity and disaster management, the regulatory and supervisory structure, the legal infrastructure, liquidity infrastructure and issues relating to the safety net such as deposit insurance.

Chapter VI focuses on some of the salient developmental issues in the Indian context having a bearing on the equity and efficiency aspects, such as financial inclusion.

The final Chapter VII provides a summary of observations and recommendations.
 

Annex A

 

RESERVE BANK OF INDIA
CENTRAL OFFICE,
SHAHID BHAGAT SINGH ROAD,
MUMBAI – 400 001, INDIA

 

MEMORANDUM

 

Constitution of Advisory Panel on Financial Stability Assessment and Stress Testing

A Committee on Financial Sector Assessment (CFSA) has been constituted by the Government of India (GOI) in consultation with the Reserve Bank with the objective of undertaking a self-assessment of financial sector stability and development. One of the analytical components of Financial Sector Assessment would encompass a comprehensive assessment of financial stability and stress testing of the Indian financial sector.

2. In this connection the CFSA has decided to constitute an Advisory Panel on Financial Stability Assessment and Stress Testing comprising the following:

 

Sr. No.

Name

Designation/Institution

 

1.

Shri M.B.N.Rao

Chairman and Managing Director, Canara Bank

Chairman

2.

Dr. Rajiv B. Lall

Managing Director and Chief Executive Officer, Infrastructure Development Finance Company Ltd.

Member

3.

Dr. T.T.Ram Mohan

Professor, Indian Institute of Management, Ahmedabad

Member

4.

Shri Ravi Mohan

Managing Director and Region Head, Standard & Poor's, South Asia

Member

5.

Shri Ashok Soota

Chairman and Managing Director, Mind Tree Consulting Ltd.

Member

6.

Shri Pavan Sukhdev

Head of Global Markets, Deutsche Bank AG

Member

 
3. In addition, the Advisory Panel can utilise the expertise of the following ex-officio Special Invitees:
 

Sr. No.

Name

Designation/Organisation

1.

Shri G. C. Chaturvedi

Joint Secretary (Banking & Insurance), Government of India

2.

Dr. K.P.Krishnan

Joint Secretary (Capital Markets), Government of India

3.

Shri Amitabh Verma

Joint Secretary (Banking Operations), Government of India

4.

Shri V.KSharma

Executive Director, Reserve Bank of India

5.

Dr. R. Kannan

Member (Actuary), Insurance Regulatory and Development Authority

6.

Dr. Sanjeevan Kapshe

Officer on Special Duty, Securities and Exchange Board of India

 

4. The Advisory Panel will have the following terms of reference:

  1. to conduct an analysis of macro-prudential surveillance and financial stability (including business continuity and disaster recovery) and to assess the impact of potential macroeconomic and institutional factors (both domestic and external) on the soundness (risks and vulnerabilities) and stability of financial systems;

  2. to analyse relevant data and information and apply techniques and methodologies as relevant to Banking, Insurance, Securities Markets and Non-banking financial sectors;

  3. to subject the assessment of stability to stress testing duly taking into account potential impact of macroeconomic and institutional factors and risks on the stability (including business continuity and disaster recovery) indicators, including natural and man-made disasters/catastrophe; and
  4. based on the assessment, suggest measures for strengthening the financial structure and system and its development in a medium-term perspective.
 
  1. The Advisory Panel would have the option of co-opting as Special Invitees any other experts as they deem fit.

  2. The secretarial assistance to the Advisory Panel will be provided by the Reserve Bank of India. The Technical Groups on Financial Stability Assessment and Stress Testing constituted by the Reserve Bank and the Insurance Regulatory and Development Authority (IRDA) at the instance of the Committee have already progressed with the technical work with regard to above terms of reference. The technical notes and background material prepared by these groups would inter-alia form the basis for discussion by the Panel and in drafting of the Report.

  3. The Advisory Panel will prepare a detailed Report covering the above aspects and the Government of India/ Reserve Bank of India will have the discretion of making the Report public, after a peer review, as they may deem fit.
  4. The Advisory Panel is expected to submit its Report in about three months from the date of its first meeting.
 

(Rakesh Mohan)

 
Deputy Governor and

Chairman of the Committee on Financial Sector Assessment

Mumbai
August 10, 2007
 

Annex B

 

RESERVE BANK OF INDIA
CENTRAL OFFICE,
SHAHID BHAGAT SINGH ROAD,
MUMBAI – 400 001, INDIA

 

DEPUTY GOVERNOR

MEMORANDUM
 

Constitution of Technical Group on Financial Stability Assessment and Stress Testing

 

The Committee on Financial Sector Assessment (CFSA) will undertake a self-assessment of financial sector stability and development. CFSA has decided to constitute a Technical Group on Financial Stability Assessment and Stress Testing comprising the following:

 

Sr. No.

Name

Designation/Organisation

 

1.

Shri C.S. Murthy

Chief General Manager, RBI

Member

2.

Shri P.Krishnamurthy

Chief General Manager, RBI

Member

3.

Shri Prashant Saran

Chief General Manager, RBI

Member

4.

Shri N.S. Vishwanathan

Chief General Manager, RBI

Member

5.

Shri Chandan Sinha

Chief General Manager, RBI

Member

6.

Shri S.Sen

Chief General Manager, RBI

Member

7.

S. Ramann

Chief General Manager, SEBI

Member

8.

Dr A.S Ramasastri

Adviser, RBI

Member

9.

Dr Charan Singh

Director, RBI

Member

10.

Shri K. Kanagasabapathy

Secretary, CFSA

Convener

 
2. The Group will have the following terms of reference:

(i) to contribute to the work related to analysis of macroprudential surveillance and financial stability to monitor the impact of potential macroeconomic and institutional factors (both domestic and external) on the soundness (risks and vulnerabilities) and stability of financial systems based on the direction/guideline provided by the Advisory Panel; and

(ii) to compile relevant data and information and apply techniques and methodologies as relevant to Banking, Insurance, Securities Markets and Non-banking financial sectors; and

(iii) to subject the assessment of stability (including Business Continuity and Disaster recovery) to stress testing duly taking into account potential impact of macroeconomic and institutional factors and risks on the stability (including Business Continuity and Disaster recovery) indicators, including natural and man-made disasters/ catastrophe; and

(iv) based on the assessment, to suggest measures for strengthening the financial structure and system and its development in a medium-term perspective; and

(v) to provide such inputs for discussion to the Advisory Group on Financial Stability Assessment and Stress testing as needed and participate in their deliberations.

 
3. The Group would function under the overall guidance of Shri V.K. Sharma, Executive Director, Reserve Bank of India. Shri Anand Sinha, Executive Director, Reserve Bank of India will be a permanent invitee.

4. The Group will also be directed by decisions taken in the Advisory Panel for Financial Stability Assessment and Stress Testing.

5. A list of Special Invitees who could act as resource persons to the Group and whose expertise can be called upon by the Group while preparing inputs for the Advisory Panels is provided in Annex C. The Group may co-opt as special invitees, one or more of the identified officials, or any other officials from RBI, Government or other agencies as they deem appropriate.

6 . The Group is expected to complete its task in the minimum possible time which, in any case, would not go beyond four months from the date of its constitution.
 
(Rakesh Mohan)
Chairman
Mumbai
March 1, 2007
 

Annex C

 

List of Officials who Assisted the Advisory Panel

 
The Panel has also benefited considerably from the inputs provided by following officials from different agencies.
 

Sr. No.

Name

Areas

1.

Shri Mohandas Pai, Member of the Board and Director-Human Resources, Infosys

HR issues in the Financial Sector

2

Shri Anand Sinha, Executive Director, RBI

Liquidity issues in commercial banks, Stress Testing methodology

3.

Shri S.K. Mitra, Executive Director, NABARD

Stability issues in the rural financial sector

4.

Shri Nachiket Mor, President, ICICI Foundation for Inclusive Growth

Financial Inclusion

5.

Shri H N Sinor, Ex Chief Executive, IBA

Major issues facing commercial banks

6.

Shri Akhilesh Tuteja, ED, KPMG

Business Continuity Management and Payment & Settlement Systems

 
Further, the Panel also acknowledges the contributions made by the following officials in preparation of the draft reports.
 

Sr. No.

Name

Designation

1.

Shri G. Padmanabhan

Chief General Manager, RBI

2.

Shri A. P. Hota

Chief General Manager, RBI

3.

Shri A. K. Khound

Chief General Manager, RBI

4.

Shri K.D. Zacharias

Legal Adviser, RBI

5.

Dr Janak Raj

Adviser, RBI

6.

Dr A. M. Pedgaonkar

Chief General Manager, RBI

7.

Shri M.P. Kothari

Chief General Manager, DICGC

8.

Shri R. Ravlchandran

Chief General Manager, SEBI

9.

Shri B. B. Mohanty

Chief General Manager, NABARD

10.

Shri R. Nagarajan

Chief General Manager, SBI

11.

Ms. Ritu Anand

Principal Adviser & Chief Economist, IDFC

12.

Shri R. Bhalla

General Manager, NHB

13.

Shri P.R. Ravlmohan

General Manager, RBI

14.

Shri E. T. Rajendran

General Manager, RBI

15.

Shri Somnath Chatterjee

Director, RBI

16.

Shri S. Ganesh Kumar

General Manager, RBI

17.

Shri A. S. Meena

General Manager, RBI

18.

Dr Ashok Hegde

Vice President, Mind Tree Consulting Ltd

19.

Smt. Asha P. Kannan

Director, RBI

20.

Shri R. K. Jain

Director, RBI

21.

Shri Anujit Mltra

General Manager, RBI

22.

Shri Rajan Goyal

Director, RBI

23.

Smt. R. Kausallya

Director, DICGC

24.

Shri Neeraj Gambhlr

Former General Manager, ICICI Bank

25.

Shri B. P. Tikekar

Senior Vice President, HDFC

26.

Shri S. Ray

Senior Vice President, CCIL

27.

Shri Ashok Naraln

Deputy General Manager, RBI

28.

Shri T. Rabi Shankar

Deputy General Manager, RBI

29.

Shri K. Babuji

Deputy General Manager, RBI

30.

Shri K.R. Krishna Kumar

Deputy General Manager, RBI

31.

Shri Aloke Chatteriee

Deputy General Manager, RBI

32.

Shri Haregour Nayak

Deputy General Manager, RBI

33.

Shri Shayama Chakraborty

Deputy Director, IRDA

34.

Shri R. Chaudhuri

Deputy General Manager, ICICI Bank

35.

Shri V. Konda

Deputy General Manager, ICICI Bank

36.

Shri Rakesh Bansal

Deputy General Manager, ICICI Bank

37.

Shri Sanjay Purao

Deputy General Manager, SEBI

38.

Shri B. Rajendran

Deputy General Manager, SEBI

39.

Shri N. Muthuraman

Former Director, CRISIL

50.

Shri Somasekhar Vemuri

Senior Manager, CRISIL

41.

Shri G. Sankaranarayanan

Former Senior Vice President, IBA

42.

Shri Puneet Pancholy

Assistant General Manager, RBI

43.

Shri D. Sathish Kumar

Assistant General Manager, RBI

44.

Shri Divyaman Srivastava

Assistant General Manager, RBI

45.

Shri Y. Jayakumar

Assistant General Manager, RBI

46.

Shri K. Vijay Kumar

Assistant General Manager, RBI

47.

Shri Navin Nambiar

Assistant General Manager, RBI

48.

Shri N. Suganandh

Assistant General Manager, RBI

49.

Shri Ashok Kumar

Assistant General Manager, RBI

50.

Shri Ashish Verma

Assistant General Manager, RBI

51.

Shri Brij Raj

Assistant General Manager, RBI

52.

Shri D.P. Singh

Assistant Adviser, RBI

53.

Shri Indranil Bhattacharya

Assistant Adviser, RBI

54.

Dr. Pradip Bhuyan

Assistant Adviser, RBI

55.

Shri Unnikrishnan N. K.

Assistant Adviser, RBI

56.

Smt. Anupam Prakash

Assistant Adviser, RBI

57.

Shri Jai Chander

Assistant Adviser, RBI

58.

Shri S. Madhusudhanan

Assistant General Manager, SEBI

59.

Shri Vineet Gupta

Former General Manager, ICRA

60.

Shri Ranjul Goswami

Director, Deutsche Bank

61.

Shri Abhilash A.

Legal Officer, RBI

62.

Shri M. Unnikrishnan

Legal Officer, RBI

63.

Shri Piyush Gupta

Manager, RBI

64.

Shri Aloke Kumar Ghosh

Research Officer, RBI

65.

Ms. Sangita Misra

Research Officer, RBI

66.

Ms. P. B. Rakhi

Research Officer, RBI

67.

Shri Dipankar Mitra

Research Officer, RBI

68.

Shri S. K. Chattopadhyay

Research Officer, RBI

69.

Shri Samir Behera

Research Officer, RBI

 

Annex D

 
Technical Group for Aspects of Stability and Performance of Insurance
Sector – List of Members
 

Sr. No.

Name

Designation

1.

Shri S.V. Mony

Secretary General, Life Insurance Council

2.

Shri S. P. Subhedar

Senior Advisor, Prudential Corporation, Asia

3.

Shri N. S. Kannan

Executive Director, ICICI Prudential Life Insurance Company Ltd

4.

Prof R. Vaidyanathan

Professor (Finance), IIM Bangalore

5.

Dr. K. Sriram

Consulting Actuary, Genpact

 

Annex E

 

List of Peer Reviewers who Reviewed the Report

 

Sr. No.

Names of the Peer Reviewers

1.

Mr. V. Sundararajan,

 

Director, and Head of Financial Practice, Centennial Group Holdings, Washington DC and former Deputy Director, Department of Monetary and Capital Markets, International Monetary Fund (IMF).

2.

Mr. Andrew Sheng, Adjunct Professor, University of Malaya and Tsinghua, Beijing and former Chairman of Securities and Futures Commission, Hong Kong.

 
NOTE
 

This report was completed in June 2008. However, looking at the global financial developments of late, an attempt has been made to update some relevant portions of the report, particularly Chapter I (The Macroeconomic Environment) and Chapter IV (Aspects of Stability and Functioning of Financial Markets).

 

Chapter I

 

The Macroeconomic Environment

 

1.1 Introduction

After a period of robust global growth and favourable economic conditions, global financial markets have entered a turbulent phase because of the subprime crisis which started in mid-2007. Non-performing housing loans, declining global equity prices and the rising cost of default protection on corporate bonds forced some major banks to face significant losses. Alongside, the tightening of banking credit standards in major industrial economies has reinforced worries of an impending credit crunch.

The impact has been compounded by the volatility in international food and oil prices. These effects are expected to impact global economic growth in the current year as well as next.

The adjustment process in the advanced economies is underway and its gradual unfolding has implications for global capital flows, exchange rates and the adjustment of domestic economies. With the growing integration of the Indian economy with global markets, the weight of global factors, along with domestic considerations, has also become important in the formulation of macroeconomic policies and outcomes. There are several positives pointing to sustainable higher growth rate. But, some of the recent global and domestic developments show heightened domestic risks to the short-term outlook of the Indian economy.

Against this background, Chapter I analyses the linkages between macroeconomic performance and financial stability and goes on to summarise the global economic developments. It then provides an overview of the Indian economic scenario including the institutional and financial market environment and identifies certain potential macroeconomic vulnerabilities in the Indian economy at the present juncture.

1.2 Linkages Between Macroeconomic Performance and Financial Stability

Macroeconomic developments and shocks can have an impact on the financial sector. The role of macro-prudential or financial stability analysis has therefore gained importance among central banks, regulatory authorities and international agencies. Various macroeconomic developments such as an increase in inflation due to a spurt in crude oil/commodity prices, a sudden inflow/ outflow of capital, a sharp increase in the fiscal deficit, sudden and sharp increases in interest rate/asset prices can adversely affect financial institutions’ balance sheets and the financial markets. This has implications for financial stability. Macro stress testing has, therefore, assumed significance in recent years.

The linkages between macroeconomic performance and financial stability are schematically presented in Chart 1.1. These shocks can emanate from the real or the financial sector. Such shocks affect the banks’ balance sheets through the conventional channels of credit and market risk. They also affect balance sheets through the financial markets and asset prices. Both effects may amplify the first round balance sheet impact, in particular the liquidity and network effects. Taken together, all of these channels then translate into a final impact on balance sheets, as reflected in aggregate loss distribution. This loss distribution, in turn, can then be mapped back into the impact on the economy.

A stable and resilient financial system is therefore vital for achieving sustained growth with low inflation as it can withstand fluctuations resulting from dynamic changes in economic conditions, as well as sudden and substantial increases in uncertainty.

The resilience of the financial system can be tested by subjecting the system to stress scenarios. Since the early 1990’s, stress-tests at the level of individual institutions have been widely applied by internationally active banks. In addition to applying such stress tests to the portfolios of individual institutions at the micro level, stress-testing is assuming an increasingly important role in the macro-prudential analysis

 
1
 

as well. The main objective of an aggregate stress test is to help public authorities identify those structural vulnerabilities and overall risk exposures that could lead to systemic problems.

For macro stress testing, a distinction is made between the “bottom-up” and “top-down” approaches. Under the former, the response to various shocks in a given scenario is estimated at the portfolio level using highly disaggregated data from individual financial institutions at a point in time. The results of the bottom-up approach can then be aggregated or compared to analyse the sensitivity of the entire sector or group of institutions. This approach has the advantage of making better use of individual portfolio data. However, if individual institutions provide their own estimates, the approach may introduce some inconsistencies about how each institution applies the scenario and produces its numerical estimates.

The top-down approach entails the calculation of the consequences based on a centralised model, normally using aggregated data, for the entire sector as a whole. The advantages of the top-down approach are that these stress tests are relatively easy to implement without burdening the individual institutions. The drawback is that the aggregated data only captures the effects for the sector as a whole, and not the different risk profiles and vulnerabilities of the individual institutions.

An important issue relating to stress testing is the determination of yardsticks to be used when setting the ranges of shock variables. In India, stress testing scenarios often tend to be hypothetical due to the lack of past data on benchmarks. To get a more realistic view, however, there is a need to construct scenarios which are combinations of shock variables. The correlations among such variables would need to be considered when constructing such scenarios.

As in many other countries, macro stress-testing in India is constrained by data availability and absence of a comprehensive macroeconomic model. But, in view of its importance for monetary and financial stability, there is, a need to put in place a macroeconomic stress-testing framework for assessment and surveillance on a regular basis.

The rapid pace of financial innovation of the last few years has brought about a proliferation of new and increasingly sophisticated financial products. It has also, in turn, led to significant institutional changes requiring and creating new and expanded roles in the system. Against this backdrop of increased complexity, financial stability depends on the ability to understand financial markets and to be able to identify, in a timely fashion, the potential consequences of new developments. This requires a great deal of reliance on expertise and judgment, market intelligence and a broad range of financial indicators. Many of these indicators are also measures of financial strength.

1.3 The Global Economy

After four years of continuous strong expansion, global activity has slowed down significantly during 2008. Many advanced economies are experiencing recessionary conditions while growth in emerging market economies is also weakening. The financial crisis that first erupted with the collapse of the US subprime mortgage (Box 1.1) has deepened further and entered a new turbulent phase in September 2008, which has severely affected confidence in global financial institutions and markets. According to the projections released by the International Monetary Fund (IMF) in January 2009 (Table 1.1), global economic activity is estimated to soften from 5.2 per cent in 2007 to 3.4 per cent in 2008 and to 0.5 per cent in 2009 with the downturn led by advanced economies. In advanced economies, output is

 

Box1.1: The Sub-Prime Crisis

 

The delinquency rate in the US sub-prime mortgage market began to rise in 2005, but market response to developments began only in mid 2007, when credit spreads suddenly began to widen. The trigger was the revelation of losses by a number of firms and the cascade of rating downgrades for sub-prime mortgage products and some other structured products. By August 2007, growing concerns about counterparty risk and liquidity risk, aided by difficulties in valuing structured products, led to a number of other advanced markets being adversely affected. In particular, there was an effective collapse in the market for Collateralised Debt Obligations (CDOs), which are structured products based, in part, on sub-prime mortgages and a withdrawal from asset-backed commercial paper market, and a sudden drying up of the inter-bank term money market. A high degree of inter-linkages across various markets resulted in swift transmission of the crisis from one segment to other segments.

Two explanations have been advanced for the underlying causes. The first highlights the influences particular to this period. Central to this hypothesis is that the ‘originate and distribute’ model altered incentives, so that it became less likely to produce ‘due diligence’ in making loans. Those at the beginning of the sub-prime chain received fees to originate mortgages and were secure in the knowledge that someone else would buy them. Banks at the centre of the securitisation process focused on the profits associated with these instruments, rather than possible threats to their financial soundness and capacity to sustain liquidity. As a result, the quality of mortgage credit declined in the sub-prime area, and much of this credit seems to have ended up being held in highly leveraged positions. Insofar as structured products are concerned, many were highly rated by the concerned rating agencies. In retrospect, it became clear that the ratings were highly sensitive to even minor changes in assumptions about the underlying fundamentals, as well as correlations among defaults and recovery rates. Many investors also did not take on board the fact that ratings were concerned with only credit risk, and high ratings provided no indication of possible major movements in market prices.

The second explanation focuses on the fact that these problems are a manifestation of the unwinding of credit excesses. A continuous worsening of credit standards over the years, in a period of benign interest rates and robust economic growth, eventually culminated in a moment of recognition and recoil.

In terms of possible policy responses, proponents of the first set of arguments contend that the logic of this position leads to the need for central bank liquidity infusions to get markets back on keel. Looking forward, a better understanding of complex financial products and how credit risk transfer techniques reshape downside risks and the greater role of transparency as a cornerstone of modern financial markets assumes importance. Those who focus on credit excesses would emphasise, in addition to the measures enunciated above, the desirability of easing monetary policy, in response to a significant threat to growth.

The current financial turmoil has several important lessons. First, the appropriate role of the monetary authorities and second, the appropriate structure of regulation and supervision. As regards the first, the evidence indicates that the focus of central banks has gradually been narrowing, relative to the more complex responsibilities they have traditionally shouldered. Secondly, there is an increasing trend towards separation of financial regulation and supervision from monetary policy. A view has emerged that problems of information asymmetry might become aggravated in case prudential regulation and supervision are separated from monetary policy, contributing to less than adequate surveillance.

The role of the central bank apart, the sub-prime crisis has thrown up fresh issues and challenges for regulation; the management of risks posed by securitisation; the role of credit rating agencies; the need for greater transparency in financial markets especially where highly leveraged institutions are concerned; better pricing of risk; the design of incentives in banking; better management and supervision of liquidity risk; and, perhaps, the need for the central bank to bring investment banks as well as non-bank financial entities and other market intermediaries that have the potential to affect the stability of financial system under the ambit of its policy framework and operations.

In the Indian case, the authorities have not favoured the adoption of inflation targeting, owing to several reasons. Secondly, the approach to regulation has been institution and market based, being located within the central bank and other regulators combined with a system of coordinated information sharing and monitoring among them. With joint responsibilities for monetary policy and supervision, this has enabled the authorities to use techniques that are precisely calibrated to emerging issues or problems.

forecast to contract on a full-year basis in 2009, the first such fall in the post-war period. Slowdown has been witnessed in both advanced as well as emerging market economies (EMEs) like Argentina, China, India and Thailand during 2008. All major advanced economies like the

 

Table 1.1: Output Growth, Inflation and Interest Rates in Select Economies

(per cent)

Region/ Country

Real GDP*

Consumer price Inflation

Short-term interest rate

2007

2008

2009

2010

2007

2008

Current

1

2

3

4

5

6

7

8

World

5.2

3.4

0.5

3.0

-

-

 

Advanced economies

2.7

1.0

(-2.0)

1.1

2.1

3.5

 

Of which

             

United States

2.0

1.1

(-1.6)

1.6

4.1

3.8

0.36

Euro Area

2.6

1.0

(-2.0)

0.2

3.2

3.1

2.05

Japan

2.4

(-0.3)

(-2.6)

0.6

0.7

1.4

0.61

Emerging economies

8.3

6.3

3.3

5.0

6.4

9.2

 

Developing Asia

10.6

7.8

5.5

6.9

5.4

7.8

 

China

13.0

9.0

6.7

8.0

6.5

5.9

1.34

India**

9.3

7.3

5.1

6.5

5.5

8.2

4.78

South Korea

5.0

4.1

(-2.8)

-

3.9

4.9

2.93

Singapore

7.7

1.9

(-2.9)

-

4.4

6.6

0.56

Thailand

4.8

3.4

(-1.0)

-

4.3

5.5

2.22

Argentina

8.7

5.5

(-1.8)

-

8.5

8.6

15.13

Brazil

5.7

5.8

1.8

3.5

4.5

5.7

12.66

Mexico

3.2

1.8

(-0.3)

2.1

3.8

5.1

7.16

Central and

             

Eastern Europe

5.4

3.2

(-0.4)

2.5

-

-

 

Russia

8.1

6.2

(-0.7)

1.3

12.6

14.1

13.00

Turkey

4.6

2.3

0.4

-

8.2

10.5

14.02

Updated from World Economic Outlook – January 28, 2009 and ‘The Economist’ – February 7, 2009
* : Average annual change, in per cent;
** : for India, wholesale prices;
Note: Interest rate per cent per annum.
Source: IMF World Economic Outlook and the Economist.

 

Euro area, Japan, the UK and the US are projected to register decelerated growth rates (at times negative growth rates) in 2008 as compared to those during 2007.

The IMF has projected the US economy to grow by 1.1 per cent in 2008 (2.0 per cent in 2007) and contract by 1.6 per cent in 2009. The US economy has been severely impacted by the direct effects of the financial crisis that originated in its subprime mortgage market, though aggressive policy easing by the Federal Reserve, a timely fiscal stimulus package, and a strong export performance on the back of a weakening US dollar have helped to cushion the impact of the financial crisis till the second quarter of 2008. The US economy may contract during the final quarter of 2008 and the first half of 2009, as export momentum moderates and tight financial conditions lead to more problems. The IMF expects the US economy to stabilise by the end of 2009 and then recover gradually. The key factors that will determine short-term outlook include effectiveness of recent Government initiatives to stabilise financial market conditions, the behaviour of US households in the face of rising stress and the depth of housing cycle. The projections envisage a significant slowdown in growth in the Euro area to 1.0 per cent in 2008 from 2.6 per cent in 2007 mainly on account of tightening credit conditions, falling confidence, housing downturns in several economies and the US slowdown. The economy is expected to contract by 2.0 per cent in 2009. The momentum of recession in Japan is projected to accelerate to -2.6 per cent in 2009 (-0.3 per cent in 2008) on account of slowing exports, expected further weakening of domestic demand and slowing down of private investment.

The emerging and developing economies have not decoupled from this downturn. Growth projection for developing Asia by the IMF is placed at 7.8 per cent for 2008 as against 10.6 per cent in 2007 as domestic demand, particularly investment and net exports have moderated. Countries with strong trade links with the US and Europe are slowing down markedly. Also, countries relying on bank-related or portfolio flows to finance large current account deficits have been adversely affected by strong risk aversion, deleveraging and the consequent shrinkage in external financing. Nevertheless, growth in emerging Asia during 2008 was led by China and India. GDP in China eased to 9.0 per cent for 2008 (projected to grow at 6.7 per cent in 2009) from 13.0 per cent during 2007 partly due to slowing of exports. The IMF projects India's growth rate to moderate from 9.0 per cent in 2007 to 7.3 per cent in 2008. Upon weakening of investment though private consumption and exports, India’s GDP is expected to decelerate further to 5.1 per cent during 2009.

Going forward, financial conditions are likely to remain fragile, constraining global growth prospects. Financial markets are expected to remain under stress throughout 2008 and 2009 though some recovery is expected in 2010. Though the forceful and co­ ordinated policy responses in many countries have contained the risks of a systemic financial meltdown, further strong and complementary policy efforts may be needed to rekindle activity. At the same time fiscal stimulus packages should rely primarily on temporary measures and be formulated within medium-term fiscal frameworks that ensure that the envisaged build-up in fiscal deficits can be reversed as economies recover. There are many reasons to remain concerned about the potential impact on activity of the financial crisis. There are substantial downside risks to the global growth outlook, which relate to two concerns, viz., financial stress could remain very high and credit constraints from deleveraging could be deeper and more protracted than envisaged. This would increase risk of substantial capital flow reversals and disorderly exchange rate depreciation for many emerging market economies. Another downside risk relates to growing risk for deflationary conditions in advanced economies. Additionally, the US housing market deterioration could be deeper and more prolonged than forecast, and the European housing markets could weaken more broadly. Factors that would help in reviving the global economy in late 2009 include expected stabilisation in commodity prices, a turnaround in the US housing sector after finally reaching the bottom and support from continued robust demand in many EMEs despite some cooling of their momentum. Policy makers face the major challenge of stabilising global financial markets, while nursing their economies through a period of slower growth and keeping inflation under control.

Rising inflation, which was a concern for a major part of 2008, has however, eased since September 2008 and is now a declining concern on account of marked decline in food and fuel prices as well as augmentation of downward risks to growth from the intensification of the global financial crisis.

As per the IMF projections, inflation in the advanced economies will decline from 3.5 per cent in 2008 to 0.3 per cent in 2009, before edging up to 0.8 per cent in 2010. For the emerging market and developing economies, the IMF projects the CPI inflation to subside from 9.2 per cent in 2008 to 5.8 per cent 2009, and to 5.0 per cent in 2010.

Global financial markets witnessed generally uncertain conditions since 2008. The turbulence that had erupted in the US sub-prime mortgage market in mid 2007 and gradually deepened towards early 2008, resulted in the inter-bank money markets failing to recover as liquidity demand remained elevated. Spreads between LIBOR rates and overnight index swap rates increased in all three major markets, viz., the US, the UK and the euro area. Central banks continued to work together and also individually to improve liquidity conditions in financial markets. Financial markets deteriorated substantially during the third quarter of 2008 (July-September). Bankruptcy/sell-out/ restructuring became more widespread spreading from mortgage lending institutions to systemically important financial institutions and further to commercial banks. The failure of banks and financial institutions also broadened geographically from the US to many European countries. As a result, funding pressures in the inter-bank money market persisted, equity markets weakened further and counterparty credit risk increased. Central banks continued to take action to enhance the effectiveness of their liquidity facilities. EMEs, which had been relatively resilient in the initial phase of the financial turbulence, witnessed an environment of tightened external funding condition, rising risk and till recently, high inflation led by elevated food and energy prices.

During the last quarter of 2008, short-term interest rates in advanced economies eased considerably, moving broadly in tandem with the policy rates and liquidity conditions. In the US, short-term interest rates continued to decline between October 2008 and December 2008 as a result of reduction in its policy rates and liquidity injections. In the UK, short-term interest rates which increased till September 2008, declined from October 2008 as a consequence of the cuts in the policy rate. Short-term interest rates which increased in the Euro area during the quarter ended September 2008, declined in October 2008 on account of reductions in its refinance rate. In the EMEs, short-term interest rates generally softened in countries such as China, India, Singapore, South Korea, Brazil and Thailand but firmed up in economies like Argentina and Philippines from October 2008.

1.4 India

The impressive performance of the Indian economy in recent years bears testimony to the benefits of the economic reforms undertaken since the early 1990s (Table 1.2). Real GDP growth had averaged 5.2 per cent during 1997-98 to 2002-03. Since 2003-04, there has been a strengthening of the growth momentum. Real GDP growth averaged 8.8 per cent during the five year period ended 2007-08,making it one of the world’s fastest growing economies. This is because of a number of factors, including the restructuring measures taken by Indian industry, the overall reduction in domestic interest rates, improved corporate profitability, a benign investment climate, strong global demand and a commitment to a rule based fiscal policy. In the very recent period, growth in Indian economy has seen some moderation on the back of the global financial meltdown. The recent Business Confidence Index (NCAER, October 2008), has fallen to a five-year low of 119.9 reflecting a dent in optimism because of current financial market volatility (Chart 1.2)1. The index stood at 154 in January 2008 but has consistently deteriorated since then.

Unlike in East Asia, domestic demand has been the main driver of economic activity in India. The consumption to GDP ratio at nearly two-thirds is one of the highest in Asia. The

 

Table 1.2 : Key Macroeconomic Ratios (Per Cent to GDP)

(at Factor cost)

2000-01

2006-07

2007-08

1

2

3

4

Gross Domestic Product (Per cent growth)

4.4

9.6

9.0

Consumption Expenditure

76.3

66.1

65.5

Investment

24.3

35.5

39.0

Savings

23.7

34.3

37.7

Exports

13.2

22.1

21.3

Imports

14.2

25.1

24.4

Balance of Trade

-1.0

-3.0

-3.1

Current Account Deficit

-0.4

-0.9

-1.4

Net inflows by FIIs in the Indian stock market

0.52

0.81

1.54

Source : RBI, CSO

 

1 The computation of BCI is based on two indicators each for overall economic environment and business performance. These include: (a) overall assessment of the economy over the next six months; (b) prevailing investment climate; (c) financial position of firms over the next six months; and (d) present rate of capacity utilisation. In essence, the index captures the prospective assessment of the business conditions and the economic environment by the business sector.

 
2
 

corporate sector has responded to increased global competition by improving productivity between 2003-04 to 2006-07. This, in turn, has improved corporate profitability and led to a pick-up in investment rates, from 22.8 per cent of GDP in 2001-02 to 35.9 per cent in 2006-07. The Wholesale Price Index (WPI) inflation was contained, averaging 5.1 per cent over 2000-01 to 2007-08, partly reflecting a very limited pass through of higher oil prices, administrative steps to dampen food price pressures and stable inflation expectations in view of pre-emptive policy measures. Higher food prices, however, have contributed to Consumer Price Index (CPI) inflation, which has hovered around 6 per cent. Mid-2008 also saw a significant increase in WPI resulting in a high rate of inflation touching almost 13 per cent in August 2008 which however has maintained a downward trend since September 2008. The administered price of petroleum products, which were revised upwards in June 2008, was the major driver of the high inflation rate. Prices of freely priced petroleum products had also increased and added to the inflationary pressure. There has however, been a very significant reduction in oil prices in recent months. The administered price of petroleum products have been reduced in January 2009.

In response to global hardening of interest rates and increased inflationary pressure till August 2008, the Reserve Bank had gradually raised policy rates. The reverse repo (borrowing) rate had risen to 6 per cent (since July 2006), while the repo (lending) rate had risen to 9 per cent. The Cash Reserve Ratio (CRR) for the banking system also was raised from 5.25 per cent in December 2006 to 9 per cent effective from August 30, 2008. In response to higher credit growth, the Reserve Bank tightened prudential norms, including increasing provisioning requirements and raising risk-weights in select sectors. Indicators on financial soundness, including stress tests of credit and interest rate risks, suggest that banks’ balance sheets and income remain healthy and robust.

However, consequent to the reversal of capital flows which have led to a liquidity shortage in the economy the Reserve Bank has reduced key ratios from October 2008, to facilitate flow of funds in the market. By January 2009 the CRR was reduced to 5.0 per cent, repo rate to 5.5 per cent and reverse repo rate to 4.0 per cent. The banks were also allowed to reduce SLR to 24 per cent (Table 1.3 & Chart 1.3).

Merchandise exports has been growing and becoming increasingly broad-based in terms of destinations and composition, reflecting India’s growing integration into the global economy. A striking feature of export growth has been the rapid growth in services exports, amounting to USD 87.7 billion in 2007-08. Merchandise exports and imports for quarter ended June 2008 stood at USD 43.7 billion and USD 75.2 billion respectively. Export to GDP ratio has more than doubled to 13.5 per cent in 2007-08 compared to less than 6 per cent in 1990-91. The growth in imports has also been rapid, with the import/GDP ratio being 21.2 per cent in 2007-08. Despite the widening trade deficit, the current account deficit has remained modest, due largely to high levels of private transfers, aggregating USD 42.6 billion in 2007-08 averaging 3.2 per cent of GDP during the last four years. India is the leading remittance receiving country in the world with relative stability of such inflows.

 

Table 1.3: Benchmark Policy Rates

(per cent per annum)

 

2000-01*

2003-04*

2006-07*

2007-08*

January 17, 2009

1

2

3

4

5

6

Repo rate$

6.50

6.00

7.75

7.75

5.50

Reverse repo rate$

8.50

4.75

6.00

6.00

4.00

CRR

8.00

5.00

7.50

7.50

5.00

SLR

25.00

25.00

25.00

25.00

24.00

* Position as on March 31.
$ w.e.f October 29, 2004 the nomenclature of repo and reverse repo has been changed as per international usage in terms of which, repo rate represents the rate at which the central bank injects liquidity into the system and the reverse repo rate represents the rate at which it absorbs liquidity.
CRR – Cash Reserve Ratio
SLR – Statutory Liquidity Ratio
Source: RBI

 
3
 

Strong capital inflows have been instrumental in financing the current account deficit. Capital flows (net) jumped from an average of around USD 9.4 billion (2 per cent of GDP) during 2000-03 to around USD 51.8 billion (5.3 per cent of GDP) during 2004-08. Capital flows (net) amounted to USD108.0 billion during 2007-08. In a reversal of a previously observed trend, foreign direct investment (FDI) has outpaced foreign portfolio investment (FPI), in 2008-09. FDI and FPI for the quarter ended June 2008 stood at USD 10 billion and USD (-)4 billion respectively. The positive investment climate, progressive liberalisation of the FDI policy regime, along with rising pace of mergers and acquisitions across diverse sectors, has boosted FDI flows. The reversal in trend in respect of portfolio capital inflows in 2008-09. however, has, impacted the capital market and the foreign exchange markets in India significantly.

Foreign exchange reserves rose to USD 309.7 billion at end March 2008. The increase in reserves has mainly been on account of an increase in foreign currency assets from USD 191.9 billion during end March 2007 to USD 299.2 billion as at end March 2008. However, in the past few months, the foreign exchange reserves, have shown a declining trend, mainly reflecting valuation changes and stood at USD 248.6 billion as on January 30, 2009.

The rupee, exhibiting two-way movements against the US dollar during 2007-08 remained in the broad range of Rs.39.26 -43.15 per US dollar (RBI Reference Rate). During 2007-08, the real effective exchange rate of the Indian rupee on 6-currency trade-weight based measure reflected an appreciation of 8.1 per cent on an annual average basis (Chart 1.4). The Reserve Bank intervened in the foreign exchange market to contain exchange rate volatility. Net market purchases by the Reserve Bank amounted to USD 78.2 billion during 2007-08 as against USD 26.8 billion in 2006-07. During 2008-09, the Indian rupee generally depreciated. During this period (till end-January 2009), the rupee moved in the range of Rs.39.89 - 50.52 per US dollar.

While financial markets in India have gained depth, liquidity and resilience on account of various measures initiated there has been increased volatility in the markets in 2008-09 – a fall out of the turbulence in the global financial markets which led to a reversal of capital flows.

 
4
 

The fiscal position of the Government since 2004-05 has been shaped by the rule based fiscal correction process. The Central Government has implemented the Fiscal Responsibility and Budget Management (FRBM) Act. Similar legislations have been enacted in 26 States. The improvement in the fiscal position was reflected in the decline in the key deficit indicators of the Central and State Governments in the budget estimates (BE) till 2007-08. During the fiscal year 2007-08 (April 2007-March 2008), the key deficit indicators of the Central Government, viz. the revenue deficit and gross fiscal deficit, were lower than those in the previous year. The continued increase in revenue receipts at a higher rate in relation to increase in expenditure had led to improvement in all the deficit indicators during 2007-08 compared to the previous year and 2007-08 (BE).

During the latter half of 2008-09, Government announced various fiscal stimulus measures for the Indian economy, in the backdrop of the global financial crisis. The FRBM targets for 2008-09 and for 2009-10 have been relaxed to provide a demand boost to the economy. This has resulted in revenue deficit for 2008-09 increasing from 1.0 per cent of GDP (BE) to 4.4 per cent of GDP (RE). Similarly, fiscal deficit increased from 2.5 per cent of GDP (BE) to 6.0 per cent of GDP (RE). The Government has announced that it will return to FRBM targets once the economy is restored to its recent trend growth path.

1.5 Potential Areas of Macroeconomic Vulnerability

Macroeconomic conditions in India, in general, improved significantly in the recent years with the economy witnessing a robust growth and inflation, but for some spikes in April-September 2008, remaining at a moderate level. The banking system has become quite resilient. The depth and width of the financial markets also improved. The payment and settlement system became robust and a major source of systemic risk was eliminated with the implementation of RTGS. There are, however, some downside risks to macroeconomic prospects.

1.5.1 Sustaining Growth

Sustaining the present rate of high growth, is a big challenge. Many institutions/ organisations have projected different rates of sustainable growth depending on the method and assumptions adopted. The 11th Plan approach paper had projected that India should achieve 9 per cent growth during the Plan period. The IMF has projected India’s growth would be 7.3 per cent for 2008 and 5.1 per cent for 2009.

The Indian economy has never grown at double-digit rates except in 1988-89 which was due to the base effect. Many views have been expressed on the sustainability of India’s current growth. There have been several instances in recent history when economies have grown at more than 9 per cent for many years. Japan grew at an annual average of 10.4 per cent between 1960 and 1970. China has grown at above 8 per cent in 14 out of the 19 years since 1987, and at double-digit rates in recent years. In view of positive features of the Indian economy, the Panel believes that though the growth rate will experience some moderation in the immediate future, a trend of eight per cent plus growth rate is sustainable over the medium-term. This is because;

(a) Growth is led by both investment and consumption demand: The changing composition of demand in recent times indicates support to the production capacity to sustain a higher growth rate. During 2007-08 investment and consumption expenditure contributed 39.0 per cent and 65.5 per cent of GDP respectively.

(b) Upbeat investment climate: The investment climate in the recent years has been very good. After a decline in 2002, investment activity picked up sharply in terms of Industrial Entrepreneurs Memoranda (IEM) submitted to the Secretariat for Industrial Assistance (SIA), Department of Industrial Policy and Promotion. Besides rising capacity utilisation, there has also been a substantial increase in investment proposals. While there has been a decline in the Business Confidence Index in the recent times, the investment climate from the medium and long term perspectives remain intact.

(c) Continued upturn in capital goods production: In the last couple of years, the capital goods sector has been expanding at double-digit rates. This also suggests the continuance of the already upbeat and buoyant investment climate. However, during the current year, so far, the capital goods sector has witnessed moderation which is expected to reverse with the reversal of the current phase in the global economy.

(d) Record rise in sales and profits in corporate sector: Since the last quarter of 2003, the Indian corporate sector has recorded a double-digit growth in sales in tune with the buoyant demand conditions prevailing in the economy. There has also been an improvement in corporate profitability. Gross profit to sales of corporates improved from 10.6 per cent during 1997/98 to 2002/03 to 12.7 per cent during 2003/04 to 2006/07. The ratio of profit- after- tax to sales during the same period also increased from 3.6 per cent to 8 per cent. This has translated into a decline in leverage for the corporate sector: the debt equity ratio declined from 67 per cent to 51.4 per cent during the aforementioned period. High internal accruals and lower levels of leverage have put the corporate sector in a good position to sustain growth through investment. However, there has been a moderation in profit in the recent years.

India’s high growth had been aided by the buoyant performance of both the manufacturing and the services sectors. However, there is moderation in growth during the current year on account of deceleration in manufacturing and electricity sectors. The services sector continues to record high growth during the first half of 2008-09 albeit some moderation. But, the performance of the agricultural sector is a concern.

While there is a clear need and justification for fiscal expansion to counter the current global and domestic economic downturn, India needs to return to its path of fiscal correction once the current crisis is over. Public debt needs to be brought down and fiscal discipline needs to be maintained to sustain the growth. Investment in social and infrastructure sectors need to be scaled up. The capital market has to be further developed and portfolio flows need to be prudently managed. Above all, institutional reforms have to be strengthened.

At the current juncture the deepening of financial crisis has impacted the macroeconomic outlook in advanced economies with second round effects across the rest of the world. Consequently monetary policy action against inflation in advanced and emerging economies alike appears to be getting increasingly circumscribed by the more overarching concerns relating to economy and financial system.

1.5.2 Reversing Slowdown in Agriculture

The performance of the agricultural sector is critical for sustaining economic growth. Although the share of agriculture has declined from over half of GDP in 1950s to less than a fifth of GDP by 2006-07, there has not been a concomitant decline in the share of population dependent on agriculture. Over half of the workforce is still dependent on it. As a result, fluctuations in rainfall are magnified through their impact on rural incomes and consumption, and the correlation between agricultural growth and overall GDP growth, has, in fact, strengthened over the reforms period (Table 1.4).

The slowdown in agriculture has been characterised by stagnation in the production of wheat, sugar and pulses. The actual production of foodgrains, on an average, was only 93 per cent of the targets during 2001-07. In the case of pulses and oilseeds, these ratios were much lower. Coupled with this has been another feature: the declining capital formation in agriculture. Gross capital formation (GCF) in agriculture as a proportion to total capital formation has shown a continuous decline, and the share of agriculture in total GCF has declined from 8.6 per cent in 1999-2000 to 5.8 per cent in 2006-07.

Agriculture in India is largely rain - fed. Around 40 per cent of the net - sown area is under irrigation, which leaves the major agricultural season (June-September) dependent on both the timely arrival and widespread dispersion of the South-West monsoon. The high correlation between agricultural growth and rainfall in India (about 0.7 over the period 2000-2007) illustrates the dependence of agricultural growth on rainfall. In the absence of proper irrigation, large parts of the country cannot take advantage of the second agricultural season (October-December).

 
 

Table 1.4: Correlations with Agriculture Sector Growth

Item / Period

1951-52 to 2006-07

1970-71 to 2006-07

1991-92 to 2006-07

1

2

3

4

GDP at factor cost

0.552 (0.00)

0.448 (0.00)

0.636 (0.00)

Industrial sector growth

0.293 (0.02)

0.310 (0.06)

0.102 (0.70)

Growth in THTC

0.307 (0.02)

0.314 (0.05)

0.179 (0.50)

Growth in financing etc.

0.012 (0.92)

0.040 (0.81)

- 0.274 (0.30)

Growth in public administration etc.

- 0.225 (0.09)

- 0.298 (0.07)

0.190 (0.48)

Note : Figures within brackets represent level of significance
THTC: trade, hotels, transport and communications
Source : The Economic Survey 2007-08

 

In the present context, low growth in the agriculture sector could be a challenge for sustaining economic growth. The agriculture sector has to grow faster than its long-term average growth rate of 2.5 per cent. If it remains in distress, growth can neither be inclusive nor sustainable. The most critical problems are low yields and the inability of the farmers to exploit the advantages of the market. Clearly, the need of the hour is to modernise and diversify the agriculture sector by improving both the forward and backward linkages. These will include better credit delivery, investment in irrigation and rural infrastructure, improved cropping pattern and farming techniques, emphasis on diversification of agricultural activities such as horticulture and livestock and development of food processing industry and cold storage chains across the entire distribution system. The absence of reforms, especially creation of a single market, is also a major issue.

1.5.3 Fiscal Consolidation

Among the other critical challenges is the way forward on fiscal consolidation. High fiscal deficits can crowd out private investment. Depending on how they are financed, fiscal deficits can have an adverse impact through inflation, the interest rate and the exchange rate. Further, revenue and expenditure measures are needed to meet the revenue deficit target under FRBM, which require broadening the tax base, tightening control on state borrowings and improvement in efficiency in expenditure management. In 2008-09, the revenue deficit is budgeted to increase by Rs. 1,88,704 crores2 as compared to 2007-08(RE) (Table 1.5). However, given the current pressures on the economy in terms of oil prices volatility, rising input costs, increase in current account deficit, coupled with the declared farm loan waivers, the Panel concluded that it would not be possible to contain the fiscal deficit at the budgetary levels for the year 2008-09. While the interim budget for 2009-10 has shown a stoppage, the Government has stated that it will return to FRBM target after the economy restores to its recent trend growth path.

1.5.4 Meeting the Infrastructure Deficit

Among the concerns the businesses in India face are infrastructure, where there are significant gaps. The Eleventh Plan has estimated that for accelerating the GDP growth at 9 per cent per annum during the Plan period, there is a need for accelerating the current level of investment in infrastructure at 5 per cent of GDP during 2006-07 to 9 per cent during the Plan period. Meeting this huge financing requirement appear to be challenging, given the governance structure, policy uncertainty and lack of stricter entry and exit norms prevalent in the country.

(a) Public-Private Partnerships

An investment of roughly USD 500 billion has been projected for physical infrastructure (comprising roads, power, telecom, railways, airports and ports). Of this, roughly USD 150 billion is to be funded by the private sector. The Government therefore has sought to foster a policy and procedural environment to actively

 

Table 1.5 : Fiscal Deficit (Per Cent to GDP)

 

2000-01

2003-04

2007-08

2008-09 (RE)

2009-10 (BE)

1

2

3

4

5

6

Revenue Deficit

4.1

3.6

1.1

(1.0) 4.4

4.0

Gross Fiscal Deficit

5.7

4.5

2.7

(2.5) 6.0

5.5

Source: Government of India/RBI.
Note: Figures in parenthesis pertain to BE for the year.

 

2 1 crore = 100 lakhs = 10 million = 0.01 billion

 

encourage public-private partnerships (PPP). It has established the India Infrastructure Finance Company Limited (IIFCL) to provide long tenor debt to infrastructure projects and for launching of a scheme for financial support to PPPs in infrastructure. Steps have also been initiated to use foreign exchange reserves for building infrastructure. IIFCL has set up an offshore Special Purpose Vehicle (SPV) entity called IIFC (UK) Ltd. in London to utilise part of foreign exchange reserves for infrastructure development. Reserve Bank has given “in principle” approval to invest upto USD 5 billion in the securities of the SPV and these would be guaranteed by the Government. Additional efforts such as strong and independent sector regulators will reduce regulatory uncertainties for investors. Developing the domestic bond market will facilitate infrastructure finance. The Government has reported giving in-principle approval to 54 Central sector infrastructure projects at a cost of Rs.67,700 crore and approving 23 projects amounting to Rs.27,900 crore for viability gap funding in 2008-09.

The projections for infrastructure finance need to be viewed with a measure of scepticism. Past record suggests that there is tendency to overstate these requirements – in the1990’s, the requirement of FDI in infrastructure was estimated at USD 150 billion, without which any acceleration in growth was thought difficult. Only a small fraction of this figure materialised but that did not keep the Indian economy from sprinting ahead in recent years.

It is well-recognised that financing of infrastructure projects is a specialised activity and would continue to be of critical importance in the period ahead. All over the world, infrastructure services have generally been provided by the public sector for a large part of the twentieth century as most of these services have a significant component of public goods in them. It is only of late that private financing of infrastructure has made some headway.

This trend is not without its echo in India where financing infrastructure was till recently a Government activity. However, there has been a paradigm shift in infrastructure funding from the Government to the private sector due mainly to budgetary constraints in making available funds to meet the burgeoning financing requirements. In addition, the emphasis on allocation of budgetary resources to social sectors has also engendered this shift. As a result, the emphasis has shifted towards PPPs and increasingly, it is perceived that commercial entities such as banks could play an important role in this respect. Although the argument is not without its merits, there are significant challenges for the banking sector in funding the growing infrastructure need (Box 1.2). The Government has recently announced that IIFCL will refinance 60 per cent of commercial bank loans for PPP projects in critical sector for which it has been authorised to raise Rs.10,000 crore by March 2009 as well as an additional Rs.30,000 crore if required

(b) Funding

The Planning Commission has estimated the total investments in the infrastructure sector to be to the tune of Rs. 20,56,150 crore during the plan period. While the public sector, including the public corporate sector, would continue to play a dominant role in investment for infrastructure, investment by the private sector, which includes PPP projects, is envisaged at 30 per cent of the total investment, i.e. around Rs. 6,20,000 crore. Of the total requirement the debt financing needs for infrastructure investment during the Eleventh Five-Year Plan is estimated to be Rs. 9,88,035 crore at constant prices. In other words, more than Rs. 2,00,000 crore a year on average would be required at current prices. However, the availability of debt financing for infrastructure during the Eleventh Plan is estimated at Rs. 8,25,539 crore which implies that there is a funding gap of Rs. 1,62,496 crore for the debt component. The required investment in infrastructure would, therefore, be possible only if there is a substantial expansion in internal generation and extra-budgetary resources of the public sector, in addition to a significant rise in private investment.

 

Box 1.2 : Challenges of Banking Sector in Funding Infrastructure Needs

 

Infrastructure projects are characterised by large capital costs and long gestation periods. The assets of these projects are not readily transferable and the services provided are typically non-tradable in nature. In addition, these projects are also susceptible to various market and other non-measured risks. In addition, the nature of financing of these projects necessitates exhaustive due diligence process on the part of funding agencies to ascertain that the project cash flows are adequate to cover the debt service obligations. Therefore, proper risk assessment and adequate risk mitigation mechanisms comprise a sine qua non of the process. The complexity of the transaction and large funding requirements necessitates an innovative approach towards financial structuring and the use of an array of financial instruments.

In India, such financing was earlier undertaken by specialised term-lending institutions. Commercial banks rarely undertook equity positions in projects. Infrastructure financing requires the commitment of long-term funds, both as equity and long-term debt. In the past, since the infrastructure sector was predominantly catered to by public investment, the need for developing appropriate financing mechanisms was not acute. As a result, the financial sector was biased towards short and medium-term debt.

A key question is whether the Indian financial system is equipped to intermediate the huge financial resources that are required for investment in infrastructure. Commercial bank lending to infrastructure has expanded very rapidly over the last few years and has become by far the largest source. It now faces serious constraints as banks’ balance sheets have a growing concentration of risks which they have not been able to transfer. There are issues of ALM mismatch as the maturity of banks’ assets has become longer term while their liabilities have become shorter. Banks will also reach exposure limits to large developers. Moreover, the tenor of the loans is not very long (about half of the concession period of a typical infrastructure project) with a short re-set period. All this points to the need for more diversified sources of long-term finance for infrastructure, including tapping contractual savings. The key lies in the rapid but orderly growth of the corporate bond market.

Being seized of these concerns, the policymakers have made appropriate relaxations for bank lending to infrastructure projects in regard to their exposure and other related norms. The effect of these measures has been an improvement in the credit flow to infrastructure (comprising power, telecom, roads and ports) from less than 3 per cent in 2001 to nearly 8 per cent in 2007.

Over the longer-term, the development of a secondary debt market assumes importance. Of the two major segments, the government debt and the corporate bond market, while the former has exhibited substantial progress, developments in the latter have been less than satisfactory (Chapter IV). The actions required for this purpose are in several areas including, legal, technological, regulatory, risk management etc. Other possible sources of finance could be long-term fund providers such as pension, provident and insurance funds, that have the advantage of providing a better maturity match for infrastructure financing. In addition, steps could be undertaken to actively promote cash-flow based securitisation, subject to prudential safeguards. By facilitating unbundling, better allocation and management of project risks, this could enlarge the market by attracting new players. This needs to be supplemented with a well-defined regulatory framework. Such a framework must provide for transparency, clarity of obligations between participants in the infrastructure projects and reduce the layering of approvals to bring about a greater degree of certainty in obtaining them within a definite time frame.

This is even more of a challenge given the constraints to growth in each of the sources of debt finance. Commercial bank lending to infrastructure has expanded very rapidly over the last few years and has become by far the largest source. Banks’ balance sheets thus have a growing concentration of risk which they have not been able to transfer. There are asset-liability mismatches because the maturity of banks’ assets has become longer term while their liabilities have become shorter. NBFCs’ lending will also be constrained because their cost of funding is higher. External commercial borrowing, till recently had been reined in due to concerns regarding the monetary expansion effects of capital inflows. The infrastructure sector is particularly hard hit as it has a high domestic expenditure component. And finally, insurance companies are limited by their investment guidelines. Also, the public sector insurance companies tend to be risk- averse, which is manifested in their high investments in government securities and less than mandated in infrastructure and that too mostly in public infrastructure companies.

This points to the urgency for getting additional sources of debt financing for infrastructure investment and private participation/financing. This would require a shift from the bank dominated financing system to a capital-market oriented system for financing infrastructure and housing projects. This calls for pension reforms and allowing pension and insurance companies to invest more in long-term corporate debt. The Panel underscores the need for a deep and liquid corporate bond market for infrastructure finance and for reducing the concentration of risks that are building in the banking system.

1.5.5 Governance Issues

As Table 1.6 demonstrates, governance issues and regulations are among the leading deterrents for doing business in India, leading to a ranking of 120 (out of 178 countries) in the World Bank’s Ease of Doing Business 2008 publication. Starting a business in India is significantly time-consuming. Compared to their counterparts in the OECD countries, India’s entrepreneurs need to follow twice as many procedures, face about thrice the time delay, and close to fifteen times the cost as a proportion of per capita income. In the area of credit availability, India lags behind not because of creditor rights (which are virtually on par with OECD standards), but because of lack of credit information available from public registries and from private bureaus. Pendency is also an issue in this context. The contract enforcement procedure is deficient as the number of procedures that must be followed and the resulting time delays are about more than three times that of OECD countries and the costs of contract enforcement are over twice as high. Closing a business takes 10 years with a recovery rate of around 11 per cent, one of the worst among countries.

1.5.6 Demographic Dividend

It has been argued that as more and more people join the workforce in India, this will entail greater savings, as it did in other countries in East Asia that developed rapidly. By 2025, the proportion of working age population (15-59 years), which was roughly 657 million in 2005 increases to 907 million (Chart 1.5). While this will help in sustaining productivity-led growth, there is a need for rapid job creation in the manufacturing sector, particularly in the hinterland states and coastal areas.

 

Table 1.6 : Doing Business - Global Comparisons (2007-08)

Item

India

China

Thailand

Korea

Philippines

Australia

US

Best

1

2

3

4

5

6

7

8

9

Starting a business (no. of days)

30

40

33

17

52

2

6

1 (New Zealand)

Dealing with licenses (no. of days)

224

336

156

34

203

221

40

34 (Korea)

Employing workers (difficulty of firing index)

70

50

0

30

30

10

0

0 (US)*

Registering property (no. of days)

45

29

2

11

33

5

12

2 (Sweden, SaudiArabia, New Zealand, Thailand)

Getting credit (strength of legal rights index)

8

6

4

7

3

9

8

10 (Hong Kong China, Kenya, Malaysia,Singapore)

Protecting investors (strength of investor protection index)

6

5

7.7

5.3

4

5.7

8.3

10 (New Zealand, Kenya)

Enforcing contracts (days)

1420

406

479

230

842

395

300

150 (Singapore)

Closing a business (years)

10

1.7

2.7

1.5

5.7

1

1.5

0.4 (Ireland)

* Hong Kong, China, Singapore, Maldives, Marshall Islands also have the same status Difficulty of firing index: 0 (zero difficulty) to 100 (highest difficulty) Strength of legal rights index: 0 (no strength) to 10 (maximum strength) Strength of investor protection index: 0 (no strength) to 10 (maximum strength)
Source: World Bank Doing Business Database (2009)

 

The employment elasticity of growth, however, has not been significant. According to the Economic Survey 2007-08, employment elasticity of output has declined from 0.41 over the period 1983 to 1993-94 to 0.15 over 1993-94 to 1999-2000. However, during 1999-2000 to 2004-05, it has increased to 0.48 (Rangarajan et al, Money and Finance, ICRA Bulletin September 2007), with wide divergences across states. The growth rate of employment in the organised sector has declined over the period 1994-2005 to (–0.31) per cent from 1.2 per cent in the previous ten year period. An overwhelming majority of the labour force continues to work in agriculture. The challenge is to create jobs on a scale needed to successfully absorb excess agricultural labour.

India will have the benefit of having a relatively young population for a considerable period of time in comparison to other emerging and even developed countries (Chart 1.6). But it has to create jobs to take advantage of this. Education and skills are a serious concern. The evidence provides limited room for comfort. Although the gross enrolment ratio (GER), which shows the total enrolment in secondary stage (class IX to XII) as percentage of total population

 
6
 

in the relevant age group, has improved from 19.3 in 1990-91 to 39.9 in 2004-05, in the secondary (class IX to X i.e., 14-16 years) stage, the all-India figure is 51.7; and as many as 9 (out of 18 states covered) are below this average. At the post-secondary stage the GER for (class XI to XII i.e., 16-18 years) is 27.8 at the all-India level and 8 states are below this number. On the supply side, merely 18 per cent of primary schools have four or more teachers. Industry too has a role in better utilising human resources by investing more in training. IT firms have set an example that other sectors might profitably emulate.

 
7
 

1.5.7 Oil Prices

As India is primarily an oil importing country, oil prices are a critical element in the sustainability of the growth and, in some ways the maintenance of financial stability. The increase in crude oil prices in the international markets adversely affects the oil importing countries in terms of output loss, inflationary spirals and adverse balance of payments. The increasing cost of production resulting in adverse terms of trade erodes international competitiveness. It also tends to deteriorate the fiscal balance if the Government absorbs the rise in international oil prices and if the pass-through to domestic consumers is staggered and incomplete. The end result in most of the episodes of oil shock has been a significant loss of output in the short run and general level of welfare in the long run. A recent analysis estimates that a supply-induced doubling of prices would raise inflation rate in emerging Asia by as much as 1.4 percentage points above the baseline (BIS, 2007).

Central banks have to manage the dilemma of the growth-inflation trade-off more acutely during episodes of oil price increase. However, recent history suggests that there has been greater success for central banks in stemming inflationary pressures arising out of oil shocks. This is in contrast to the 1970s and the early 1980s which witnessed severe wage-price spirals and a consequent impact on growth on account of monetary tightening.

Crude Oil Price – Recent Trends

The renewed hardening of international crude prices from an average level of USD 57 per barrel at end 2005 to an average level of USD 73 per barrel by July 2006 resulted in an increase of 6-9 per cent in domestic administered prices of petrol and diesel. Subsequently, in response to easing in international oil prices, domestic petrol and diesel prices were cut twice during November 2006 and February 2007. Thereafter, international crude oil prices rose sharply to reach a historical high of USD 145.3 per barrel by early July 2008, reflecting a tight supply-demand balance, geo-political tensions, supply disruptions in Nigeria, a weakening of the US dollar against major currencies and increased interest from investors and financial market participants-(Chart 1.7). Subsequently, crude oil prices eased, reflecting decline in demand in OECD countries and improved near-term supply prospects in non-OPEC countries. The WTI crude price was hovering at around USD 62 per barrel level at end October 2008. This has declined further in recent times and is around USD 40 per barrel currently.

 
8
 

In India, inflation based on year-on-year variations in the wholesale price index (WPI) increased to 7.7 per cent in 2007-08. A year ago it was 5.9 per cent. There was an increase in the prices of all the three major groups, namely primary articles, fuel and manufactured products. Inflation increased further to 12.9 per cent by August 2, 2008 reflecting pass-through of international crude oil prices to domestic prices (domestic prices of petrol and diesel were raised twice during February and June 2008) as well as elevated levels of prices of iron and steel, basic heavy inorganic chemicals, machinery and machinery tools, oilseeds, sugar, raw cotton and textiles on account of strong demand as well as international commodity price pressures. Subsequently, inflation eased to 10.7 per cent by October 25, 2008 reflecting decline in prices of freely priced petroleum products (in the range of 15-22 per cent) in line with decline in international crude oil prices (by 45 per cent since July 2008) as well as easing in other commodity prices such as oilseeds/edible oils/ oil cakes, raw cotton and cotton textiles following global trends. The inflation, continuing its downward trend, stood at 4.4 per cent as on January 31, 2009 along with the decline in petroleum prices.

1.5.8 Food Prices

Another major concern both domestically and globally has been the sharp rise in food prices. While the global food price index rose on an average by 10.5 per cent in calendar year 2006 and by 15.2 per cent in 2007, it has increased substantially by around 42 per cent in the first half of 2008 compared to the corresponding period of the previous year. According to the Food and Agriculture Organisation (FAO), 37 countries in the world are facing food crisis, 31 of which are in Africa and Asia. This increase in food prices has been on account of various factors such as higher global demand, lower stocks and production and diversion of food grains for bio-fuel production and speculation. The anaemic global growth has resulted in a marked decline in food prices since October 2008, resulting in the easing of inflationary pressures.

However, the increase in food prices in India had during the first half of 2008-09 been only a fraction of that observed in many other countries. In particular, the global prices of wheat and rice almost doubled between January and April 2008, while in India the increase has been far less than a tenth of that. This reflects the long-standing public policy emphasis on food security. Even so, the rise in food prices is a cause for worry. The average annual increase in the Wholesale Price Index (WPI) of food articles was around 7 per cent during 2006 and 2007. It was led by wheat (13 per cent) during 2006, rice (6 per cent) and edible oil (13.1 per cent) and pulses (3.21 per cent)in 2007. However, food price inflation has witnessed increase in 2008. The Wholesale Price Index of food articles up to October 18, 2008 had increased by around 6.5 per cent compared to the 4.6 per cent in the previous year.

As regards prospects for the near future, public policies in regard to food, especially diversion to bio-fuel, cross border trading, subsidies, and replenishment or use of buffer stocks would impact the evolution of prices globally. However, the redeeming feature is that supply response in regard to food grains is possible in a year or two. As per FAO estimates, wheat output is set to achieve a new record in 2008, though against the backdrop of deeply depleted stocks. Global production of rice in 2008 is expected to be only marginally better than the previous year and hence, some depletion of stocks held may be expected. The global output of edible oil is anticipated to fall by about 3 per cent in the current year and, according to FAO, oil seeds and edible oil prices are expected to remain firm.

As regards India, the abatement of global prices, indications of better domestic supplies and addition to buffer stocks, along with the series of measures already taken by the Government on the supply side are expected to yield results in the months to come. Over the medium-term, however, the National Food Security Mission launched about two years ago should yield positive results.

1.5.9 Managing the Impact of Capital Inflows

Foreign investment flows into India, comprising foreign direct investment (FDI) and foreign portfolio investment (FPI), have risen sharply during the 1990s reflecting the policies to attract non-debt creating flows. Foreign investment flows (net) have increased from negligible levels during 1980s to reach USD 45 billion by 2007-08. As a proportion of FDI flows to developing countries, the FDI flows to India have shown a consistent rise from 2.2 per cent in 2000 to 4.3 per cent in 2007. The share of net FPI flows to India as a proportion of total flows to developing countries remained in the range of 9-25 per cent during 2004 and 2007. Both direct and portfolio investment flows maintained the pace during 2007-08. Foreign direct investment flows into India were 52.1 per cent higher during 2007-08 on the back of positive investment climate, improved growth prospects and initiatives aimed at liberalising the FDI policy and simplifying the procedures.

Portfolio equity flows during 2007-08, were led mainly by steady inflows from foreign institutional investors (FIIs) and ADRs/GDRs. The number of FIIs registered with the SEBI increased from 997 by end March 2007 to 1319 by end March 2008 and 1541 by end June, 2008. Inflows on account of Foreign Institutional Investors (FIIs) increased to USD 20.3 billion during 2007-08 from USD 3.2 billion during 2006-07. Capital inflows through the issuances of American depository receipts (ADRs) / global depository receipts (GDRs) were also substantially higher (USD 8.8 billion) as booming stock markets during the period offered corporates the opportunity to issue equities abroad.

Gross inward FDI inflows increased to USD 34.9 billion in 2007-08 from USD 23.0 billion in the previous year. The classification of flows under FDI includes sizeable investments from private equity funds and venture capital funds. On the one hand, figures for FDI do not provide adequate information on technology transfer, and linkages with the parent firms are relatively absent. Private equity and venture capital may bring in capital and, to a lesser extent, improved management. But private equity and venture capital also have lower time horizons than classical firm FDI and hence constitute less stable flows.

In 2008-09 however there has been a reversal of capital flows. In the current financial year, net FII outflows have been to the tune of USD 11.9 billion (up to January 9, 2009). There has also been a concomitant depreciation in USD/Rupee exchange rate and a decline in stock market indices. The Reserve Bank’s intervention to ensure stable conditions in foreign exchange market had resulted in some liquidity shortage which had to be tackled through expansionary monetary and accommodating fiscal initiatives. Management of foreign exchange movements could change course due to any abrupt changes in sentiments or global liquidity conditions. Strategic management of the capital account warrants preparedness for all situations.

The benefits of capital account liberalisation are well known. In India there is a broad consensus that it is desirable but should be gradual, well sequenced and undertaken in conjunction with several other measures at the micro and macro level. While the Panel supports a general policy stance that encourages more capital account flows, liberalisation could be used strategically to help the evolution of the financial markets in alignment with concomitant improvements in macro-economic management. Among the more important of these are fiscal consolidations, further strengthening the banking system, diversifying financial intermediation through both banks and non-banks, and developing as well as regulating financial markets in a sound manner.

1.6 Institutional and Financial Market Environment

The financial system in India comprising financial institutions, markets, instruments and services is characterised by two major segments – a growing organised sector and a traditional informal sector. Financial intermediation in the organised sector is conducted by a large number of financial institutions (banking and non-banking) like commercial banks, cooperative banks, regional rural banks and development banks. Non-banking financial institutions include finance and leasing companies and other institutions like the insurance companies, mutual funds, provident funds, post office banks etc.

The financial sector was heavily regulated till the early 1990s. But since then it has become market-oriented and opened up to private players. The reforms have aimed at enhancing productivity and efficiency of the financial sector, improving the transparency of operations, and ensuring that it is resilient and capable of withstanding stress due to domestic or external shocks. Interest rates have been gradually and mostly liberalised. Financial savings have grown steadily in line with liberalisation of the financial sector, reflecting high domestic savings (34.8 per cent of GDP in 2006-07 as per Economic Survey 2007-08).

The predominance of Government ownership of banks, combined with continued directed credit allocations and administered interest rates in certain segments, while auguring well for financial stability and fulfilment of social targets, could constrain the manoeuvrability of operations. The requirements in the form of SLR and CRR also pre-empt a significant part of resources, besides constraining the free pricing of assets. Competition in the banking sector has nevertheless improved due to the emergence of private players and greater private shareholding in public sector banks. The insurance sector has also been opened up to private competition. The regulatory and supervisory apparatus has been restructured, strengthened and augmented with the formation of new regulatory authorities. The size of the capital market has significantly expanded in recent years in terms of market capitalisation and the number and assets under management of mutual funds. Financial markets, in general have thus acquired greater depth and vibrancy.

1.6.1 Financial Institutions

Table 1.7 presents the broad structure of the Indian financial system in terms of number and assets base of financial institutions. As some

Table 1.7: Structure of Indian Financial Institutions

(As at end-March 2008)

Institution

No of institutions

Total assets (Rs crore)

Per cent

1

2

3

4

Financial Sector (I to III)

3,815

74,75,310

100.0

The Banking Sector (I + II)

3,062

50,00,821

66.9

I.

Commercial banks

173

44,50,681

59.5

 

Scheduled commercial banks

169

44,50,027

59.5

 

Public sector banks

28

30,22,237

40.4

 

State Bank group

8

10,11,169

13.5

 

Nationalised banks

19

18,80,374

25.2

 

Other public sector banks

1

1,30,694

1.7

 

Private sector banks

23

9,40,150

12.6

 

Old private banks

15

1,94,555

2.6

 

New private banks

8

7,45,595

10.0

 

Foreign banks

28

3,64,099

4.9

 

Regional Rural Banks

91

1,23,541

1.7

 

Non-scheduled commercial banks (Local area banks)

4

654

0.01

II.

Cooperative banks

2,889

5,50,140

7.4

 

(a) Urban co-operative banks

1,770

1,79,421

2.4

 

Scheduled

53

79,318

1.1

 

Non-scheduled

1,717

1,00,103

1.3

 

(b) Rural co-operative banks

1,119

3,70,719

5.0

 

Short-term structure

402

3,24,609

4.3

 

State co-operative banks (StCBs)*

31

85,756

1.1

 

District central co-operative banks (DCCBs)*

371

1,58,894

2.1

 

Primary Agriculture Credit Societies (PACS) @

..

79,959

1.1

 

Long-term structure

717

46,110

0.6

 

SCARDBs

20

24,336

0.3

 

PCARDBs

697

21,774

0.3

III.

The Broader Financial Sector

753

24,74,489

33.1

III.1

Development Finance Institutions**

4

1,77,765

2.4

III.2

State Financial Corporations#

18

12,841

0.2

III.3

Insurance institutions

37

10,39,704

13.9

 

Life insurance

18

9,07,280

12.1

 

Public

1

7,98,685

10.7

 

Private

17

1,08,595

1.5

 

Non-life insurance

19

1,32,424

1.8

 

GIC (re-insurer)

1

36,013

0.5

 

Public

4

79,208

1.1

 

Private

12

12,237

0.2

 

Others &%

2

4,966

0.07

III.4

Other Institutions***

1

25,744

0.3

III.5

Non-banking Financial Companies##

565

6,79,927

9.1

 

NBFC (Deposit-taking)

335

70,292

0.9

 

NBFCs (non deposit-taking)

176

4,08,705

5.5

 

RNBC

2

24,452

0.3

 

Primary Dealers

9

10,882

0.1

 

Housing Finance companies

43

1,65,596

2.2

III.6

Mutual Funds

101

5,38,508

7.2

 

Bank-sponsored

2

81,229

1.1

 

Institution-sponsored

2

14,337

0.2

 

Private

97

4,42,942

5.9

 

Indian

27

1,66,104

2.2

 

Foreign

7

31,168

0.4

 

Joint ventures (pre-dominantly Indian)

33

1,65,790

2.2

 

Joint ventures (pre-dominantly foreign)

30

79,880

1.1

* : Data for rural co-operative banks pertain to end March 2007.
@ : 97,224 Primary Agricultural Credit Societies (PACS) with loans outstanding of Rs.58,600 crore at end March 2007
** : Comprising NABARD, NHB, SIDBI and EXIM Bank.
*** : Pertains to DICGC (Deposit insurance fund)
# : Total assets pertain to end March 2007.
## : Pertains to reporting NBFCs
Source: RBI, SEBI, IRDA and Association of Mutual Funds of India (AMFI) documents

financial assets (equities, bonds) are held by private individuals and non-financial corporates, they have not been made a part of Table 1.7. Post office deposits have also not been included. Therefore the total assets of financial institutions may not fully reflect the total size of the financial system as a whole.

Banks are the most important of the financial intermediaries, accounting for nearly 67 per cent of total assets and commercial banks dominate the sector, comprising around three-fifths of the financial system assets. New private and foreign banks, whose activities were limited until the onset of reforms, represent a rising share of the sector, promoting new financial products with strong technological backup. The share of some other segments, particularly the development finance institutions, has gradually declined as a result of restructuring and rationalisation. Some major institutions have since amalgamated themselves into commercial banks.

A large network of regional rural banks (RRBs) and co-operative banks (rural and urban) serves small borrowers, primarily in rural and semi-urban areas as also smaller towns. RRBs were established under an Act of Parliament to improve credit delivery in rural areas with the Central Government, State Governments and sponsor public sector banks all taking holdings in them. Subsequent to the restructuring process in RRBs, their numbers have dwindled and stood at 90 at end March 2008 down from 196 at end March 1991. Co-operative banks cater to the credit needs of specific communities or groups of people in a region and comprise both rural and urban entities.

Development finance institutions at the national level are mostly government owned and have been the traditional providers of long-term project loans. Accounting for approximately 2.4 per cent of total assets, these institutions raise funds in the capital markets and through retail sales of savings instruments. Over the past few years, these institutions have been gradually rationalised, two of them having been amalgamated into banks. Some others have become NBFCs.

Of the state level institutions, the State Financial Corporations registered under the State Financial Corporations Act, 1951 purvey credit to industries/sectors in different states and account for about 0.2 per cent of total assets3.

Insurance sector has been open to private participation since 2000, though public sector insurance institutions dominate, both in the life as well as non-life segment. The insurance institutions account for roughly 14 per cent of sectoral assets, with the share of private insurance companies, currently 1.7 per cent of financial sector assets, gradually increasing. The share of other institutions of about 0.3 per cent is from the Deposit Insurance and Credit Guarantee Corporation (DICGC), a wholly owned subsidiary of the Reserve Bank providing insurance for depositors of commercial and co­operative banks.

 
3 Other institutions established to meet specific financing needs include Power Finance Corporation (PFC) and Rural Electrification Corporation (REC) (financial assistance to the power sector) and Indian Railway Finance Corporation (IRFC), which is the capital market financing arm of Indian Railways. These institutions have been notified as Public Financial Institutions (PFIs) under the Companies Act, 1956 and enjoy less stringent compliance and regulatory norms. In addition, at the state-level, there exists the North Eastern Development Finance Corporation (NEDFi) extending credit to industry/agricultural concerns in the North Eastern region, and Technical Consultancy Organisations, providing technical inputs for feasibility studies on viability of projects. Besides, the State Industrial Development Corporations (SIDCs), registered under the Companies Act, 1956 also provide credit to industries at the state level.
 

NBFCs provide a wide range of services and account for roughly 9.1 per cent of financial sector assets. Deposit taking NBFCs witnessed a rapid growth in the mid 1990s, but consequent to the introduction of new norms for their registration and functioning, their growth has slowed down. The NBFC (non deposit taking) segment has emerged as the dominant component of the NBFC segment in recent times. While NBFCs offer some bank like services, many of them do not have the benefit of low cost deposit funds. Since regulatory and prudential norms differ between the banking and NBFC sectors and the flexibility and range of activities that NBFCs could undertake, the NBFC structure could have some advantages over banks, resulting in them being used, inter alia, by banks as a delivery vehicle for arbitrage opportunities.

Primary Dealers (PDs) are active players in the government securities market. There are nine PDs accounting for roughly 0.1 per cent of assets.

With the development of the securities market, the activities of the mutual funds are on the rise. As at end March 2008, there were 101 mutual funds accounting for 7.2 per cent of the assets of the financial institutions.

1.6.2 Financial Markets

India’s financial markets were relatively underdeveloped and dormant till the mid 1980s because of tight regulation and administrative restrictions. Financial sector reforms, introduced as part of overall economic reforms in the early 1990s, have brought about a sea change in the functioning of these markets. Reforms have encompassed all segments – money, credit, government securities, foreign exchange, equity and to a lesser extent, the corporate debt market. The emphasis has been on deregulation and liberalisation, strengthening transparency and price discovery, easing of restrictions on flow of transactions, lowering transactions costs and enhancing liquidity.

While deregulation, globalisation and liberalisation have engendered several benefits, they also pose several risks to financial stability. Financial markets are often governed by herd behaviour and excessive competition. In recognition of the possible destabilising factors, India has been following a gradualist approach in liberalising its financial markets with appropriate prudential safeguards being put in place that take into account the impact of reforms across institutions and markets. Excessive fluctuations and volatility in financial markets can mask the underlying value and give rise to confusing signals, hindering efficient price discovery. Accordingly, policy efforts have also aimed at ensuring orderly conditions in financial markets. Enhancing competitive efficiency, while at the same time avoiding instability in the system, has been a continuous challenge in implementing liberalisation measures.

In this context, it is useful to understand the increase in the secondary market activities of various segments of the financial markets in India (Table 1.8). With the transformation of the call money market into a pure inter-bank market, the turnover has declined significantly and money market activity has migrated to other overnight collateralised market segments such as market repo and collateralised borrowing and lending obligations (CBLO). The turnover in the term money market segment, however, continues to remain low.

Measures undertaken to develop the government securities market since the early 1990s have contributed to a significant growth in the market. The continuous improvement in market infrastructure has also resulted in

 

Table 1.8: Relative Importance of Various Financial Market Segments

No.

Market

Volume of transactions (Rs. crore)

2000-01

2007-08

1

2

3

4

A

Money

1,02,37,680

3,32,30,400

B

Government securities

6,98,146

56,27,396

C

Foreign exchange

63,35,816

4,95,27,392

D

Equities

23,39,542

51,29,894

E

Corporate bonds

14,486

96,119

1. For A, it is the aggregate of average daily turnover in call money market, market repo (outside LAF), CBLO and term money market has been multiplied by the yearly number of working days (taken to be 240 days).

2. For B, it represents the secondary market transactions in the respective markets.

3. For C, it is the total annual turnover in foreign exchange market, expressed in INR crore by multiplying the relevant numbers by average INR-USD exchange rates.

4. For D it represents the aggregate turnover at BSE and NSE (spot segment).

5. For E data is aggregation of transactions in trading and reporting platforms.

Source: RBI/SEBI

 

enhanced depth, liquidity and efficiency in the foreign exchange market, resulting in increased turnover. But the corporate bond market remains a laggard. The functioning of the stock exchanges has witnessed significant developments after the initiation of reforms in the 1990s. Several regulatory measures have aided this development.

As indicated in Table 1.9, market capitalisation (BSE) at end-March 2008 was Rs. 51,38,015 crore, equal to 109.0 per cent of GDP, which showed significant increase from Rs 5,71,553 crore equal to 27.2 per cent of GDP for end March 2001. Similarly the outstanding government securities at Rs. 13,32,435 crore remained significant as at March 31, 2008 accounting for 28.3 per cent of GDP. The share of the CPs and CDs as a per cent of GDP continues to be negligible.

The credit market, with commercial banks as the predominant segment, has been the major source of meeting the financing requirements of the economy. Such credit is mainly in the form of bank loans. The development of marketable credit instruments is at a nascent stage. Total loans outstanding by credit institutions increased at a compound rate of nearly 16 per cent during the 1990s and by more than 17 per cent per annum in the current decade. As a percentage of GDP, loans outstanding increased from roughly 24 per cent in March 2001 to 50 per cent in March 2008.

1.7 Concluding Remarks

In spite of the current blips, the evidence indicates that the economy has moved firmly to a higher growth trajectory. The change in trend growth also means that the economy needs to prepare itself to meet ongoing challenges. The key to maintaining high growth with reasonable price stability lies in rapid capacity additions through investments, productivity improvements, removal of infrastructure bottlenecks and ameliorating the skill shortages. While monetary policy will continue to play a critical role in maintaining price stability, the sustainability of high growth with moderate inflation will depend critically on bolstering investment and improving the effectiveness of government intervention in critical areas such as agriculture, education and health in the quest for more inclusive growth.

 

Table 1.9: Select Financial Instruments and Credit (Outstanding to GDP Ratio)

(Amount in Rs crore; Ratios in per cent)

Instruments

Outstanding

As ratio of GDP

Mar-01

Mar-08

Mar-01

Mar-08

1

2

3

4

5

Government Securities

4,53,668

13,32,435

21.6

28.3

CPs

5,846

32,592

0.3

0.7

CDs

771

1,47,792

0.1

3.1

Equity (mkt cap)*

5,71,553

51,38,015

27.2

109.0

Credit Outstanding**

5,11,434

23,61,914

24.3

50.1

* Only pertains to BSE.
** Food credit + Non-food credit
Source: RBI

 

As a result of manifold policy initiatives, financial institutions have transited from an erstwhile administered regime to a system dominated by market determined interest and exchange rates and migration from direct and quantitative to price-based instruments of monetary policy. These developments, by improving the depth and liquidity of financial markets, have contributed to better price discovery, enabling greater efficiency of resource use. However, further expansion and sophistication of the financial sector have posed new challenges to regulation and supervision, particularly of the banking system. The existing regulatory and supervisory structures also need to be addressed from the standpoint of gaps, overlaps and conflicts of interest. The regulatory and governance regimes also need some rationalisation.

 

Chapter II

Aspects of Stability and Performance of Financial Institutions

 

2.1 Introduction

Banks are central to the Indian financial hierarchy. They are also an integral part of the payment system. This chapter examines the stability and performance of financial institutions. Accordingly, the discussion examines the performance issues germane to commercial banks (Section 2.2), regional rural banks (Section 2.3) and co-operative banks (Section 2.4), both urban and rural. The broader financial sector is then discussed (Section 2.5), encompassing inter alia, non-banking finance companies (NBFCs), development finance institutions (DFIs), housing finance companies (HFCs) as also the non-financial (corporate and household) sectors. The penultimate section (Section 2.6) discusses some key concerns in the concerned sectors, viz., commercial banks, the co-operative banking segment and non-banking financial companies. The final section (Section 2.7) gathers the concluding remarks.4

2.2 Commercial Banks

2.2.1 Cross-country Perspective

A comparative position of the commercial banking sector on the eve of reforms and that as at end March 2008 is presented in the Table 2.1. Some relevant financial ratios and indicators as also comparable cross-country information are summarised in the table.

Several features stand out. First, there has been a significant increase in the number of listed banks and the assets of listed banks comprise 85 per cent of total commercial banking assets. No bank was listed at the inception of reforms. Second, both deposits and credit have improved markedly, leading to significant financial deepening. The bank asset to GDP ratio has increased significantly (Table 2.1). These numbers would have been even higher if the co-operative and regional rural banks had been taken into account. But these ratios are nevertheless lower than international benchmarks as the bank asset to GDP ratio was in excess of 100 per cent in 15 countries (Chart 2.1). Third, there has been a marked improvement in profitability, comparable to international levels (Table 2.1). Fourth, the costs of financial intermediation have dwindled over the years. Though globally, at the median, these costs are 2.67 per cent, but for India, they were just above the median level (Chart 2.1) in 2005.5

 

4 The stability and performance aspects of the insurance sector are covered separately in Chapter III. The data used for analysis is mostly sourced from regulatory returns and may be marginally different from that available in various issues of the Report on Trend and Progress of Banking in India.
5 The costs of financial intermediation are defined as the accounting value of banks’ net interest revenue as a share of its interest bearing (total earning) assets

 
1
 

Fifth, even in terms of prudential parameters, India is at the middle of the scale (Chart 2.2).

Efforts are being made towards the adoption of international benchmarks as appropriate to Indian conditions, improving management practices and corporate governance and upgrading technological infrastructure. While certain changes in the legal infrastructure are yet to be effected, the developments so far have been gradually bringing the Indian financial system closer to global standards. But although the banking
 
2
 

system has made significant headway, there is still some distance to go before it can truly come up to international standards. The analysis therefore examines the strengths and vulnerabilities of the banking system at the present juncture, focusing, in particular on the areas where progress has been less than adequate so as to draw lessons for further development.

The bank asset to GDP ratio for commercial and co-operative banks in 2008 stood at 103.4 per cent, with deposits and loans, as percentages of GDP, being 78.5 per cent and 58.6 per cent, respectively (Table 2.2). These ratios are generally within the range of those observed for OECD countries and ranks at the higher end of the scale when compared with countries in East Asia and Pacific region. The major exception is the loan-to-GDP ratio, which suggests less than adequate penetration of credit in India. With loan growth running at over 20 per cent which is higher than the nominal GDP growth, this ratio too should rise sharply in the coming years.

 

Table 2.1: Commercial Banks – Then and Now

No.

Indicators

March 1991

March 2000

March 2006

March 2008

1

2

3

4

5

6

I.

Size (Numbers)

       
 

Number of commercial banks(a)

272

297

222

174

 

Number of bank offices in India

60,570

65,412

69,471

76,518

 

Of which:

       
 

Rural and semi-urban branches

46,115

47,141

46,135

48,985

 

Population per bank office (‘000s)

14

15

16

15

 

Deposits (Rs. crore)

2,01,200

8,51,593

21,09,049

33,20,054

 

Per capita deposits (Rs.)

2,368

8,498

19,276

23,468

 

Credit (Rs. crore)

1,219

4,54,069

15,07,077

24,77,039

 

Per capita credit (Rs.)

1,434

4,531

13,774

17,355

 

Total bank asset (Rs. crore)^

3,20,345

11,05,464

27,85,863

43,26,486

 

Assets of listed banks (Rs. crore)

..

5,87,800

23,74,044

36,59,866

 

Assets of listed banks/

       
 

Total bank asset ( per cent)^

..

51

85

85

 

Bank concentration (assets of 3 largest banks/

       
 

commercial bank assets)^

0.4

0.3

0.3

0.3

 

Bank asset/GDP ( per cent)(b)^

56.2

56.6

77.8

92.0

II.

Performance (in per cent)^

       
 

Profitability (Net profit/Asset)

0.23

0.66

0.88

1.0

 

Cost of Intermediation (Net interest margin)

3.31 (c)

2.73

2.81

2.3

 

Administrative and staff costs

       
 

(Operating expense/Asset)

2.60 (c)

2.49

2.13

1.8

 

Soundness (Capital adequacy ratio – CRAR)

10.4*

11.1

12.3

13.0

 

Fragility (Non-performing loan ratio – NPA)

23.2 **

14.0**

3.7**

2.3**

   

(for 1992-93)

(12.7 – for Sch. Comm. banks)

(3.3 - for Sch. comm. banks)

(2.4 – for Sch. comm. Banks)

 

Provisions/NPAs

..

..

58.9

56.1

III.

International Comparisons (d)

       

2006

RoA {min, max}

79 countries

 

{0.2, 4.3}

 

2006

CRAR {min, max}

75 countries

 

{7.1, 34.9}

 

2006

NPA {min, max}

79 countries

 

{0.2, 24.7}

 

2006

Provisions/NPA {min, max}

60 countries

 

{23.1, 229.1}

 

2005

Net interest margin {min, max}

83 countries

 

{0.61, 14.23}

 

2005

Bank concentration {min, max}

95 countries

 

{0.30, 1.00}

 

2005

Bank deposits/ GDP {min, max}

96 countries

 

{0.6, 334}

 

2005

Bank credit/ GDP {min, max}

96 countries

 

{7.2, 202}

 

(a) including RRBs
(b) GDP at current market prices
(c) for 1991-92
* for 1996-97
** for public sector banks only
(d) includes Latin America, Emerging and Western Europe, Asia and Middle East and Central Asia
^ Excluding RRBs
Figures reported in the table might not match with those reported elsewhere in the text owing to differences in data sources
Source: RBI, IMF (Global Financial Stability Report) and World Bank (Financial Structure Database)


Table 2.2: Indicators of Financial Depth – 2008

Country/Region

Bank asset /GDP (March 2008)

Deposits/GDP (March 2008)

Loans/GDP (March 2008)

Bank assets/(bank + central bank assets) (March 2008)

1

2

3

4

5

India

103.4 [95.8]

78.5 [73.4]

58.6 [54.1]

84.0 [84.9]

OECD [range]*

[48.2, 202.9]

[44.6, 334.1]

[46.1, 202.4]

[86.8, 99.9]

East Asia & Pacific [range]*

[8.2, 109.7]

[0.5, 93.5]

[7.9, 102.9]

[24.6 , 99.7]

Note : Bank asset for India is the aggregate of commercial and co-operative banks (Urban co-perative banks, State co-operative banks and District Central co-operative banks) for March 2008. Figures within parentheses pertain to March 2007. Central bank assets = Reserve Money
* for December 2005
Source: RBI and World Bank (Financial Structure Database)

 
 

The approach of the Reserve Bank towards prudential norms has been of gradual convergence with international best practices, tailored to country-specific considerations. In order to assess the level of adherence to international best practices in respect of regulation and supervision of commercial banks, an assessment of their adherence to the Basel Core Principles (BCP) was undertaken as a part of this exercise.

BCPs lay down a framework of institutional arrangements (i.e. policies, processes, powers and infrastructure) that provide a foundation to help in promoting and assessing financial stability. Financial stability depends upon risk management practices, macroeconomic conditions, market regulation and supervision, the quality of financial institution management and its supervision, etc. While BCP compliance may not be a sufficient condition for financial stability, a reasonable observance of the principles can be taken as a necessary pre-condition.

Despite improvements in supervision and risk management, the level of compliance to the BCPs appears to have declined. This apparent anomaly may be viewed in the light of revision of BCPs themselves, a change in assessment methodology and a different assessor. It suggests that commercial banks are currently compliant/largely compliant in respect of 18 of the 25 Principles6 which is lower than the last assessment in 2001 when India was found compliant/largely compliant with 23 out of the 25 principles7. Partial/non-compliance is mainly in the areas of risk management and home-host country co-ordination in information sharing. Erstwhile observed areas of weaknesses, e.g. in country risk, have since been addressed. Consolidated accounting for banks has also been introduced along with a pilot system of risk-based supervision for intensified monitoring of vulnerabilities.

A scheme of Prompt Corrective Action has been in effect since December 2002 to undertake ‘structured’ and ‘discretionary’ action against banks exhibiting weaknesses in respect of financial and prudential parameters. At the macro level, a half-yearly review based on macro-prudential and financial soundness indicators is being undertaken to assess the health of individual institutions and financial system soundness. The findings arising thereof are disseminated through various Reports.

 

6 For details please see the report of the Advisory Panel on Financial Regulation and Supervision

7 The lower level of compliance is due to the revision of Basel Core Principles in 2006. The earlier assessment was based on Basel Core Principles 1999 while the current assessment is based on Basel Core Principles 2006.
 

Table 2.3: Bank Group-wise Relative Business Size of Commercial Banks

(share in per cent)

Bank Group

Assets

Deposits

Advances

Employees

 

Mar-01

Mar-07

Mar-08

Mar-01

Mar-07

Mar-08

Mar-01

Mar-07

Mar-08

Mar-01

Mar-07

Mar-08

1

2

3

4

5

6

7

8

9

10

11

12

13

Public Sector Banks

79.5

70.4

69.8

81.4

73.9

73.9

78.9

72.7

72.6

91.1

81.9

78.4

Old Private Banks

6.5

4.6

4.5

7.0

5.1

5.2

7.2

4.7

4.8

NA

5.5

5.4

New Private Banks

6.1

16.9

17.2

6.0

15.3

15.3

5.7

16.2

16.4

NA

9.3

12.9

Foreign Banks

7.9

8.0

8.4

5.6

5.6

5.8

8.2

6.4

6.5

1.6

3.2

3.3

NA – Data not available
Source : RBI

 

2.2.2 Ownership

The banking sector is dominated by public sector banks (PSBs) which accounted for about 70 per cent of commercial banking assets and over 78 per cent of employees at end March 2008 (Table 2.3). In 2000-01, they accounted for nearly 80 per cent of banking assets and roughly four-fifths of deposits and advances. In other words, there has been a decline of roughly one percentage point per annum for loans and even higher for deposits for PSBs, matched largely by an increase in the same for the new private banks8.

In the wake of envisaged Basel II norms, there is an ongoing debate whether this process should be accelerated through a divestment of Central Government shareholding in PSBs. In case PSBs are corporatised while keeping their “public sector character” intact, the implications will be as follows:

• So long as the shareholding of the Government is not reduced to less than 51 per cent of the total capital of any bank, the bank will remain a government company within the meaning of Section 617 of the Companies Act. In case, however, the Government shareholding becomes less than 51 per cent, the banks will not remain a government company, but if the dominant shareholding, even if below 51 per cent, remains with the Government, then for all practical purposes, Government will continue to be in a position of control. However, such a step would have implications in respect of placing banks’ balance sheets before the Parliament and jurisdiction of central vigilance commission (CVC) over the banks.

• The directors of the company will be elected by shareholders, but as long as the Government continues to be a shareholder, Government / Reserve Bank could exercise its powers for appointing the directors, as per the requirements of the Banking Regulation (BR) Act.
 

8 The business profile of public sector banks in India are somewhat different from other banking groups driven by regulatory and other considerations; hence comparisons of bank-group wise figures here and elsewhere in this report need to take this aspect on board.

 
• Since Section 30 (1A) of the BR Act will apply to the corporatised banks, the appointment of the auditors will continue as is being done at present.

• Such banks will be able to raise capital as per the provisions of the Companies Act/ BR Act without prior permission from the Government and the Government could choose to divest its shareholding.

The predominant Government ownership of commercial banks helps in ensuring systemic stability as state-owned banks enjoy an implicit sovereign guarantee. The possible adverse consequences, insofar as Government ownership causes regulatory forbearance that lead to larger fiscal costs over the medium-term have been often debated. The fiscal cost to the exchequer in respect of recapitalisation of PSBs has been minimal. The recapitalisation by the Government on a cumulative basis up to 2002-03, taking into account the capital returned by banks has amounted to approximately Rs.22,000 crore or around one per cent of GDP (2002-03).

The Reserve Bank has shown a preference for merging weak banks with healthy PSBs to exploit synergies. Active Government support has been forthcoming in facilitating such mergers and has been important in protecting systemic stability and the interest of small depositors. The Panel therefore feels that, PSBs have an important role to play in fostering stability in the financial system.

PSBs have also shown improvements in efficiency. The goal of promoting efficiency will be better served if steps are taken to improve the incentive structure so as to foster greater innovation, customer orientation and diversification of their income stream. The development of risk management skills in respect of PSBs is a sine qua non. Given the current incentive structure of PSBs there is a possibility of losing staff to the higher paying private financial institutions.9

It is the Panel’s view that there is a need to augment the capital base of PSBs over the next five to seven years so that they do not face a capital impediment for credit extension. With the listing of PSBs, government ownership in them has been diluted over time and, in case of several banks, it is marginally above the stipulated threshold of 51 per cent. There is a perception that PSBs’ access to the markets for further equity has become a challenging proposition because of the Government’s decision thus far not to dilute its ownership to lower than 51 per cent. According to a capital-projection analysis attempted by the Panel, (Section 2.2.4.(c)), this would apply to 19 (of the 20 nationalised10) banks by 2012-13 in the worst-case scenario.

The objective of financial intermediation has changed over the years. More efficiency and productivity in operations with emphasis on disclosure and accountability is now required. This can be achieved through diversification of ownership, leading to greater public participation, and through competition. As a major step towards enhancing competition, foreign direct investment in private sector banks is allowed up to 74 per cent, subject to conformity with the prescribed guidelines.

Private sector banks comprise of two distinct categories; the professionally managed new private sector banks which are the fastest growing segment among commercial banks and the old private sector banks, comprising 5.0 per cent of the total business as on March 31, 2008, which are typically smaller banks catering mainly to a specific geographic location and are a vulnerable part of the commercial banks with less than satisfactory financial performance and poor governance. An analysis of the key financial indicators of the smaller old private sector banks is given in Box 2.1. However, given that these banks comprise a small portion of banking assets, it is not a systemic concern. Recognising the growing importance of private sector banks, the Reserve Bank, in addition to encouraging the diversification of ownership, has stressed on the need for fit and proper guidelines for the board, management and important shareholders.
 

9 Ref Section 2.6.1(i) ibid.
10 Including IDBI Bank Ltd.

 

Box 2.1: Vulnerability of Small Old Private Sector Banks

 
3
 

The small old private sector banks (OPBs), with aggregate asset size of less than Rs.6,000 crore as on March 31, 2008, continue to be the weak link in the commercial banking sector. Although there has been some improvement in the key financial ratios of these banks, partly due to amalgamation/ merger of some of the banks, in most cases they remained considerably adverse compared to the system as a whole. The level of capitalisation (CRAR) of small OPBs at 14.6 per cent was, however, higher than the system average of 13.0 per cent. The gross and net NPL ratios for small OPBs stood at 3.4 per cent and 1.1 per cent, respectively, while the corresponding figures for the entire system were 2.4 per cent and 1.1 per cent, respectively. Also, while the profitability (ROA) at the system level was 1.0 per cent, that for the small OPBs was only 0.9 per cent. The cost income (efficiency) ratio of these banks, at 59.7 per cent, was considerably higher as compared to the system figure of 48.6 per cent, which reflected their relative inefficiency.

Currently, foreign banks have a three track presence in the Indian financial sector: in terms of asset share, equity stake in Indian banks and FII investment in Indian banks. Foreign banks play a small but increasingly important and innovative role. At the end of March 2008, as many as 28 foreign banks were operating in India through branches. These banks account for more than 8 per cent of total commercial banking sector assets. As for foreign ownership of Indian banks, total foreign ownership in a private sector bank cannot exceed 74 per cent of the paid-up capital. In state-owned banks, however, the Foreign Direct Investment (FDI) limit is 20 per cent. In non-distressed banks, foreign banks cannot hold more than 5 per cent equity, in general.

Consistent with the policy of increasing financial globalisation, existing guidelines on FDI in the banking sector were revised in March 2004. In 2005, a roadmap for foreign banks in India was announced. In the first phase (2005-2009), foreign banks were allowed to establish a wholly-owned subsidiary or to convert their existing operations into a subsidiary. In addition, the limit of FDI in private sector banks was raised from 49 per cent to 74 per cent.

The roadmap also included guidelines on ownership and governance in private sector banks. In the first phase till 2009, foreign banks would only be allowed in a phased manner to acquire up to 74 per cent ownership in distressed private sector banks identified by the Reserve Bank for restructuring. In other private sector banks, no bank can have a stake in excess of 5 per cent.

 

Box 2.2: Ownership Structure of Banks

 

Public Sector Banks

Public sector banks are statute-based banks. They are regulated by their respective statutes of Parliament in addition to some important provisions of Banking Regulation Act, 1949 as enunciated in Section 51 thereof. Primarily, public sector banks constitutes the following -

(i) State Bank of India regulated by State Bank of India Act, 1955.

(ii) Subsidiary Banks of State Bank of India regulated by State Bank of India (Subsidiary banks) Act, 1959.

(iii) Nationalised Banks regulated by Banking Companies (Acquisition and Transfer of Undertakings) Act, 1970 & 1980.

As per the provisions of their respective statutes, the Central Government is mandated to hold a minimum percentage of shareholding which is 51% in case of nationalised banks and 55% in case of the State Bank of India. In case of the subsidiary banks, the shareholding of the State Bank of India can not go below the minimum of 51% of the total shareholding in those banks. Foreign investment in any form cannot exceed 20% of the total paid-up capital of the PSBs. The PSBs are permitted to divest their holdings subject to minimum holding by Central Government as stated above.

The Board consists of whole-time directors {Chairman / EDs / MDs (in case of SBI & its subsidiary banks)}, Government nominee directors, Reserve Bank’s nominee director, workmen and non-workmen directors and elected directors. Number of elected director depends upon the percentage of public shareholding in the banks. In case of nationalised banks and subsidiary banks, it can be maximum of three if the percentage of shareholding is more than 32% whereas in case of State Bank of India, it can be four if the public shareholding is more than 25%. The director to be nominated by the Reserve Bank will be a person possessing necessary experience and expertise in regulation or supervision of commercial banks instead of an officer of the Reserve Bank of India11.

Private Sector Banks

The broad principles underlying the framework of policy relating to ownership and governance of private sector banks are:

(i) ultimate ownership and control of private sector banks is well diversified.

(ii) Important shareholders (i.e., shareholding of 5 per cent and above) are ‘fit and proper’, as laid down in the guidelines on acknowledgement for allotment and transfer of shares.

(iii) The director nominated by the Reserve Bank and the CEO who manage the affairs of the bank are ‘fit and proper’ as indicated in the Reserve Bank guidelines and observe sound corporate governance principles.

The objective is to ensure that no single entity or group of related entities has shareholding or control, directly or indirectly, in any bank in excess of 10 per cent of the paid up capital of the private sector bank. Any higher level of acquisition will be with the prior approval of Reserve Bank. Where ownership is that of a corporate entity, the objective will be to ensure that no single individual/entity has ownership and control in excess of 10 per cent of that entity. Banks (including foreign banks having branch presence in India)/FIs should not acquire any fresh stake in a bank’s equity shares, if by such acquisition, the investing bank’s/FI’s holding exceeds 5 per cent of the investee bank’s equity capital. The present policy requires the Reserve Bank’s acknowledgement for acquisition/transfer of shares of 5 per cent and more of a private sector bank. In case of restructuring of problem/weak banks or in the interest of consolidation in the banking sector, the Reserve Bank may permit a higher level of shareholding, including by a bank.

The aggregate foreign investment in private banks from all sources (FDI, FII, NRI) cannot exceed 74 per cent. At all times, at least 26 per cent of the paid-up capital of the private sector banks will have to be held by resident Indians. Currently there is a limit of 10 per cent for individual FII investment with the aggregate limit for all FIIs restricted to 24 per cent which can be raised to 49 per cent with the approval of board/general body. Similarly, there is a limit of 5 per cent for individual NRI portfolio investment with the aggregate limit for all NRIs restricted to 10 per cent which can be raised to 24 per cent with the approval of Board/General Body.

The capital requirement of existing private sector banks should be on par with the entry capital requirement for new private sector banks which is initially Rs.200 crore, with a commitment to increase to Rs.300 crore within three years.
 
11 Amendment to SBI Act, 1955 incorporating the changes has not yet been passed.
 
Foreign Banks

Foreign banks are required to bring an assigned capital of USD 25 million up front at the time of opening the first branch in India. In case of foreign banks the aggregate foreign investment from all sources was allowed up to a maximum of 74 per cent of the paid-up capital of the bank while the resident Indian holding of the capital was to be at least 26 per cent. It was also provided that foreign banks may operate in India through only one of the three channels, namely (i) branch/es (ii) a wholly owned subsidiary or (iii) a subsidiary with an aggregate foreign investment up to a maximum of 74 per cent in a private bank.

The Reserve Bank had in February 2005 in consultation with the Government of India released the road map for presence of foreign banks in India. The roadmap was divided into two phases. During the first phase, between March 2005 and March 2009, foreign banks would be permitted to establish presence by way of setting up a wholly owned banking subsidiary (WOS) or conversion of the existing branches into a WOS. The aforesaid guidelines cover, inter alia, the eligibility criteria of the applicant foreign banks such as ownership pattern, financial soundness, supervisory rating and the international ranking. The WOS will have a minimum capital requirement of Rs.300 crore and is required to maintain a capital adequacy ratio of 10 per cent or as may be prescribed from time to time on a continuous basis, from the commencement of its operations. The WOS will be treated on par with the existing branches of foreign banks for branch expansion with flexibility to go beyond the existing WTO commitments of 12 branches in a year and preference for branch expansion in under-banked areas. During this phase, permission for acquisition of share holding in Indian private sector banks by eligible foreign banks will be limited to banks identified by the Reserve Bank for restructuring. The Reserve Bank may, if it is satisfied that such investment by the foreign bank concerned will be in the long-term interest of all the stakeholders in the investee bank, permit such acquisition. Where such acquisition is by a foreign bank having presence in India, a maximum period of six months will be given for conforming to the ‘one form of presence’ concept.

The second phase will commence in April 2009 after a review of the experience gained and after due consultation with all the stakeholders in the banking sector. The review would examine issues concerning extension of national treatment to WOS, dilution of stake and permitting mergers / acquisitions of any private sector banks in India by a foreign bank in the second phase.

The parent foreign bank will continue to hold 100 per cent equity in the Indian subsidiary for a minimum prescribed period of operation. The composition of the Board of directors should, inter alia, meet the following requirements:

* Not less than 50 per cent of the directors should be Indian nationals resident in India.

* Not less than 50 per cent of the Directors should be non-executive directors.

Source : Reserve Bank of India

 

The second phase commences in April 2009 after a review of the experience gained and after due consultation with the stakeholders in the banking sector. This review examines issues concerning the extension of national treatment to wholly-owned subsidiaries, dilutions of stakes and permitting mergers/acquisitions of private sector banks in India. An amendment to the BR Act, 1949 has also been proposed to allow for the voting rights of banks to reflect their ownership level, eliminating the current 10 per cent cap.

The Panel is of the view that this has the potential of changing the ownership structure of the Indian financial sector and also raises challenges for improving risk management skills and attendant capacity-building issues for PSBs. The regulation of the operations of large global banks needs to recognise the fact that their Indian operations form only a small proportion of global operations and key decisions relating to risks are taken abroad while the impact is felt locally. The Panel notes that the general preference for economic reforms in India has been ‘gradualism’. In keeping with this approach, the regulators are moving towards the future being financial risk-oriented and guided by disclosure norms and capital requirements. The ramifications of global banks’ operations need to be carefully examined and their implications fully assessed. From this standpoint, the Panel endorses the Reserve Bank view on the roadmap for foreign banks and reiterates that developing appropriate risk management skills for domestic banks remains a sine qua non at the present juncture.

2.2.3 Competition, Concentration and Efficiency


The growing pressures of competition have led to a gradual decline in the share of public sector banks in total commercial bank assets. The evidence of competitive pressure is supported from the low Herfindahl concentration index (Table 2.4)12. While the low Herfindahl index indicates low concentration and that the situation theoretically is conducive for mergers, the gains from such consolidation need to be clearly understood.

An analysis of the top five banks reveals that though their financial ratios were marginally poorer when compared to the system average in March 2008, (Box 2.3: Financial soundness of large banks) they were healthy in absolute terms.

An examination of bank productivity ratios reveal that compared to developed markets, banks in India are overstaffed and their productivity levels lower (Table 2.5). Available data suggests that bank assets per employee were USD18.5 million for the UK and USD 15 million for the Euro economies in 2004. Bank assets per employee of commercial banks were Rs.4.5 crore (approximately USD 1.13 million) in 200813.

 

Table 2.4: Asset Concentration Ratios of Banks – Comparative Position

Country

CR3

CR5

Herfindahl Index

1

2

3

4

India

0.31

0.39

536

UK

0.26

0.35

493

US

0.12

0.19

157

Germany

0.19

0.27

283

France

0.36

0.51

682

Spain

0.51

0.59

1188

EU 25

 

0.40

570

Note: 1. Cross country data for 2004
2. Data for India pertain to end-March 2008
Source: RBI, EU Banking Structure (ECB, October 2005), IMF Working Paper (07/26)

 

12 Herfindahl index (HHI) is defined as the sum of squares of market shares and ranges between 0 and 10,000. In practice, markets in which HHI is below 1000 are considered as “loosely concentrated”, between 1001 and 1800 as “moderately concentrated” and above 1800 as “highly concentrated”.

13 Assuming USD1=INR 40

 

Box 2.3 : Financial Soundness of Large Banks

 
4
 

The soundness of large banks is critical to soundness of the financial system. CRAR of the 5 largest banks (by asset size) was 13.7 per cent in March 2008. This was higher than the average CRAR of the banking system of 13.0 per cent. Net NPA of the five largest banks was 1.5 per cent in March 2008 compared to 1.1 per cent for the system. RoA of the 5 largest banks at 1.0 per cent was similar to the system average. The cost-income (efficiency) ratio of the five largest banks was 49.8 per cent as compared to 48.9 per cent of the system as a whole. To summarise, the key financial ratios of these five largest banks were marginally poorer when compared to the system as a whole.

 

In the Indian context, there are large differences in productivity across ownership groups. Partly because of their large retail and consumer accounts base, PSBs have roughly three-times as many employees relative to their assets and roughly two-times in respect of loans and deposits (and even higher for net interest income) as foreign banks (Table 2.6). Private domestic banks are less productive and more overstaffed than foreign banks, but more productive (in terms of loans) and less overstaffed than public sector banks. This divergence across ownership groups indicates the significant potential gains available through productivity improvements by increasing competition.

 

Table 2.5: Bank Assets Per Employee

Country

Bank assets per employee

1

2

India

USD 1.13 million

United Kingdom

USD 18.5 million

Euro economies

USD 15 .0 million

Source : RBI and IMF


One of the main reasons for the low employee productivity in PSBs could be the lower mechanisation of work processes with the attendant cost implications. Also, higher employee productivity of banks could be due to significant outsourcing activities. In order to take a more holistic view, cost income (efficiency) ratios14 for each banking group were calculated. It was seen that the ratios displayed greater convergence across bank groups.

2.2.4 Assessment of Financial Soundness Indicators

A significant strengthening of prudential supervision along with the gamut of measures undertaken over the years has significantly improved the health of the sector. Since the beginning of reforms in the early 1990s, financial performance, especially of PSBs, has gradually improved. This section analyses the financial soundness indicators of the commercial banks in India to assess the strengths and vulnerabilities in the sector and also benchmarks it against similar indicators across countries.

 

14 Cost income Ratio = Non-interest expenses/ (Total income –Interest expenses)

 

Table 2.6: Bank Productivity in India – 2007 & 2008

(Rs. in crore)

Bank Group

Asset Per Employee

Net Interest Income Per Employee

Gross Advances Per Employee

Deposits Per Employee

Cost Income Ratio (per cent)

 

Mar-07

Mar-08

Mar-07

Mar-08

Mar-07

Mar-08

Mar-07

Mar-08

Mar-07

Mar-08

1

2

3

4

5

6

7

8

9

10

11

Commercial Banks

3.9

4.5

0.1

0.1

2.1

2.6

2.9

3.5

51.2

48.9

Public Sector

3.2

4.0

0.1

0.1

1.9

2.4

2.6

3.3

51.5

48.9

Old Private

3.3

4.0

0.1

0.1

1.9

2.3

2.8

3.4

49.3

47.4

New Private

6.6

5.8

0.2

0.1

3.6

3.1

4.9

4.3

55.1

54.0

Foreign

9.8

12.1

0.4

0.5

4.5

5.4

5.3

6.4

45.1

42.9

Source: RBI

 
2.2.4. (a) Stress Testing

Ideally, stress scenarios are required to be linked to a macroeconomic framework. The qualitative response models employ econometric techniques to estimate the relationship between the macroeconomic variables and the prudential variables to be used for financial stress-testing. Studies using a multinomial regression approach suggest that the financial sector problems are associated with the following macroeconomic variables:

• Real interest rates

• Output growth

• Domestic credit growth

• Real exchange rate

• Inflation rate

However to establish the exact extent of the impact of changes in these variables on the variables to be stressed, further empirical analysis has to be undertaken. It is in this context that the Reserve Bank formed an internal group on financial stability/ vulnerability indicators. When the group initiated the model building work, it found that time series data was not available for several variables.

Therefore, to start with, the group identified a manageable set of core indicators required for econometric model building. A central database is also being built. This core set of indicators is being used by the group for the monitoring and preparation of reports on financial soundness indicators on a regular basis. It is expected that the necessary time series would be in place in about two years, when it would be possible to develop models for having early warning signals and a set of variables that can be used for stress testing.

In the absence of adequate data to link macroeconomic scenarios with financial soundness indicators and also the lack of any ‘stress events’ in the Indian financial system for the last 15 years15, the current assessment has used single factor sensitivity analysis to assess the resilience of the financial system to exceptional but plausible events. In formulating the quantum of shocks, the Panel has applied “judicial” criteria on “selected” indicators based on its experience of the Indian financial system.
 

15 The position continued till August 2008. The global financial meltdown has impacted the Indian economy in September 2008 and there has been a reversal of capital inflows. This had led to some stress situations in the financial markets, particularly in the equity and foreign exchange markets.

 

Based on the supervisory data, individual banks’ positions have been stressed by applying shocks in respect of a single key variable which is then related to an important financial soundness indicator (FSI) - typically the regulatory capital adequacy ratio. The same analysis is carried out for the system as a whole by aggregating individual bank balance sheets.

Various data limitations like unavailability of adequate time series data for several variables, lack of econometric models, unavailability of data relating to leakages in the form of inter­bank contagion (including NBFCs) and systemic level netting out etc., have constrained a multiple-factor, scenario-based analysis. The Panel suggests that the off-site monitoring and surveillance mechanism of the Reserve Bank thus needs to be augmented to include collection of data necessary to monitor financial stability.

A comprehensive stress testing exercise, based on well articulated scenarios that correspond to a combination of macroeconomic and sectoral shocks should be feasible once data becomes available. For example, the specified stress scenarios can be applied to individual portfolios of institutions in order to estimate their impact on the balance sheets and income statements, and these institution by institution results can then be analysed using various statistical methods. An alternative approach would be to apply the scenarios on the aggregated balance sheet for a group or sub group of institutions. This would require estimation of econometric relationships between key financial soundness indicators and key macro economic and sectoral variables using historical regressions of aggregate data or panel regressions.

Once adequate data is available, systematic analysis of the relationship between FSIs for non-financial corporations (and household sector) and corresponding FSIs for banking sector and between FSIs and macro variables, so that the FSIs can be projected based on projected developments in non-financial sectors, could be attempted. Such forward looking analysis of FSIs is needed, because current levels of FSIs are lagging or at best contemporaneous indicators of financial health. Also, stress test results themselves can be viewed as financial soundness indicators. Thus, results of some standard stress tests (e.g. specific increase in benchmark interest rate, or a change in exchange rate, or shift in volatility etc.) may be monitored periodically to capture any balance sheet deterioration over time, while carrying out scenario analysis and scenario based stress testing in order to capture current developments.

In the above context, the Panel recommends that the existing informal vulnerability group be crystallised into an inter­disciplinary Financial Stability Unit (comprising members drawn from research, statistics, supervisory and market operations background) which could periodically monitor systemic vulnerabilities. The responsibilities of the unit could broadly be to:

• Conduct macro prudential surveillance of the financial system.

• Prepare a periodic financial stability report.

• Develop a data base in co-ordination with the supervisory wing for collection of key data in respect of variables which could impact financial stability.

• Develop a time series of a core set of financial soundness indicators.

• Conduct systemic stress tests based on plausible scenarios to assess resilience.

• Development of models for assessing financial stability.

2.2.4 (b) Capital Adequacy

The Capital-to-Risk-Weighted Assets Ratio (CRAR) of scheduled commercial banks (SCBs) had witnessed a sharp increase and stood at 13.0 per cent at end March 2008 against the regulatory requirement of 9 per cent with the tier-I capital ratio at 9.1 per cent (Table 2.7, 2.8). Though the level appears to be comfortable at present, there is a requirement of additional capital to sustain credit growth, and the impending full implementation of Basel II norms which would require an additional capital charge for operational risk16. Recognising the need for additional capital, the Reserve Bank has attempted to enhance banks’ capital raising options by permitting them to raise capital through instruments such as innovative perpetual debt instruments (IPDI), debt capital instruments, perpetual non-cumulative preference shares and redeemable cumulative preference shares. The IPDIs have already gained in popularity and several banks have augmented their tier-I capital through this route.

Chart 2.3 details the movement of systemic capital adequacy over 2001-2008.

The ratio of net NPAs to capital, which is reflective of the vulnerability in banks’ balance sheets, declined from 52 per cent at end March 2001 to 7.6 per cent by end March 2008.

 

Table 2.7: Soundness Indicators of the Banking Sector

(Ratios in per cent)

 

Capital adequacy ratio

Tier I Capital Ratio

Non-performing assets net of provisions/ Capital

Capital/Asset

Year

March 05

March 06

March 07

March 05

March 06

March 07

March 05

March 06

March 07

March 05

March 06

March 07

1

2

3

4

5

6

7

8

9

10

11

12

13

Public sector

12.9

12.2

12.4

8.0

9.1

8.0

16.9

12.5

11.3

5.9

6.1

6.0

Old private

12.5

11.7

12.1

8.9

9.4

9.7

23.9

14.6

8.7

5.9

6.2

6.4

New private

11.8

12.6

12.0

8.1

8.8

7.6

10.3

5.3

8.1

7.6

8.4

7.1

Foreign

14.0

13.0

12.4

11.1

11.2

10.7

3.5

3.3

2.8

12.0

11.8

11.8

Commercial banks

12.8

12.3

12.3

8.4

9.3

8.3

14.6

10.2

9.4

6.6

6.9

6.7

Emerging Markets

                       

Brazil

17.9

18.9

18.5

..

..

..

-7.5

..

..

9.8

9.9

9.4

Mexico

14.5

16.3

16.1

13.4

15.2

..

-10.5

-10.6

..

11.5

13.2

..

Korea

13.0

12.8

13.0

..

..

..

6.5

4.9

..

9.3

9.2

9.5

South Africa

12.7

12.3

12.7

8.9

9.0

8.9

..

..

..

7.9

7.8

..

Developed

                       

US

12.9

13.0

13.0

10.6

10.5

10.2

-2.8

..

..

10.3

10.5

10.6

UK

12.8

12.9

..

..

..

..

..

..

..

9.1

8.9

..

Japan

12.2

13.1

..

..

..

..

..

..

..

4.9

5.3

..

Canada

12.9

12.5

12.4

10.2

7.6

9.8

..

..

..

4.4

5.7

5.6

Australia

10.4

10.4

10.4

7.6

10.5

7.5

2.3

..

..

5.2

4.9

4.9

Source: RBI, IMF (GFSR) and Financial Soundness Indicators (FSI) database

 

16 Basel II norms have been made applicable to foreign banks operating in India and Indian banks with foreign presence from March 31, 2008. Basel II norms would be made applicable to remaining 36 banks accounting for around one thirds of the banking system assets only from March 2009.

 

Table 2.8 : Soundness Indicators of the Banking Sector - March 2008

(per cent)

Bank Group

Capital adequacy ratio

Tier I Capital Ratio

Non-performing loans net of provisions/ Capital

Capital/Asset

1

2

3

4

5

Public Sector

12.5

7.9

9.6

6.5

Old Private Sector

14.1

11.8

4.8

7.9

New Private Sector

14.4

10.8

6.5

11.1

Foreign

13.1

11.3

2.5

13.5

Commercial Banks

13.0

9.1

7.6

7.9

Source : RBI

 

The un-weighted capital ratio that is, the ratio of capital and reserves to total assets i.e. the extent to which assets are funded by their own funds, has increased for banks between 2002 and 2008. Illustratively, from 2002 onwards, the ratio of capital-plus-reserves to total assets has recorded a rise from 5.5 per cent to over 7.9 per cent. In other words the growth of capital has been consistently outpacing asset growth in the recent past. This implies that the leverage which is the inverse of capital to asset ratio in the banking sector has reduced over time.


2.2.4 (c) Capital Requirement

Notwithstanding their improved performance, Indian banks continue to face challenges. Thus while minimum regulatory capital requirements covering credit and market risk continue to be relevant and an integral part of the three pillar approach under Basel II, the emphasis on an internal capital adequacy assessment process and the provision for capital allocation for operational risk mean that the banking system will now face enhanced capital needs, especially those intending to integrate

 
5
 

with international markets. In order to enable a smooth transition towards Basel II, which came into effect in India from March 2008, banks have been provided with additional options for raising capital.

In the past, PSBs had relied on the Government for capital augmentation. However, with a gradual reduction of government holdings, most of them have approached the capital market for raising resources within the stipulations of majority government shareholding. But a stage has now been reached where further capital augmentation in some of these banks will not be possible unless the government shareholding reduces below the stipulated minimum, or the Government is able to meet matching contributions as needed. Given the growth momentum of the economy, banks will have to intermediate a larger quantum of funds. The lending portfolio of banks is therefore expected to witness a manifold increase in the near future. Concomitantly, with capital requirements expected to become more risk-sensitive, especially with the envisaged introduction of Basel II, capital requirement per unit of risk asset too could undergo an increase.

An attempt was therefore made to ascertain the capital requirements of nationalised banks (including IDBI Ltd.) up to 2012-13. In the case of nationalised banks, assuming a capital adequacy ratio of 12 per cent (the excess three per cent over regulatory minimum is expected to take care of the Pillar II capital requirements) and a growth in RWAs of 30 per cent (a worst case scenario keeping in view fluctuations/downturn in future business cycles and its impact on credit off-take as well as introduction/use of credit transfer instruments) up to 2012-13, it is estimated that the Government is required to contribute Rs.49,552 crore to 19 of the 20 banks to maintain their share at a minimum of 51 per cent of the share capital of nationalised bank. This analysis supposes that all possible avenues of raising additional capital in the form of IPDI, preference shares, tier II bonds and plough back of income are considered before the estimated equity infusion to be made by the Government is arrived at. (Annex 2.1: Projected capital requirements of nationalised banks).

Table 2.9 provides the details of number of banks and the amount of capital contribution required from the Government, on the assumptions of 20 per cent, 25 per cent and 30 per cent growth in RWA.

It is observed that even with an assumed lower growth rate of RWA at 25 per cent over six years beginning April 2007, the Government’s contribution to nationalised banks capital requirement would still be a significant Rs.16,321 crore. As many as 15 banks’, i.e. 75 per cent of the nationalised banks would be requiring capital. If the projection is carried further, the Government contribution to these banks would increase at an increasing rate. However, the requirement for capital would reduce to Rs 2,134 crore at an assumed annual increase of 20 per cent in RWA from Rs 49,552 crore at 30 per cent RWA.

The Panel therefore is of the view that, given the current policy scenario, selective relaxation should be granted to banks where the

Table 2.9: Summary of Capital Projections for Nationalised Banks

Growth assumption in RWA No. of banks requiring capital

20 per cent

25 per cent

30 per cent

1

2

3

4

In 2011-12

4 (903)

11 (6,886)

18 (26,583)

In 2012-13

7 (2,134)

15 (16,321)

19 (49,552)

Note: Figures in brackets indicate the required Government’s contribution in Rs. crore

 

government ownership is at the borderline of 51 per cent and the extent of dilution should be decided on a case-by-case basis. This could be effected by making amendments to enabling legal provisions, so as to facilitate the process of selective relaxation to be granted to banks in this regard.

Several other possibilities in parallel could also be explored:

• Perpetual non-cumulative preference shares without voting rights: These shares will not have fixed maturity and thus be perpetual in nature. Issuance of these shares will not have any impact on the Government’s stake in the bank. This however will require the development of an active secondary market.17

• Perpetual preference shares in foreign currency: At present, though banks can technically issue perpetual preference shares which can comprise up to 40 per cent of the tier I capital, there is limited appetite for such instruments in the domestic market. In this regard, the regulatory norms for participation by insurance companies subscribing to these instruments need to be clarified. The current regulations do not also allow issue of this instrument in foreign currency. Allowing this instrument in foreign currency in the meanwhile can significantly boost the capital raising ability of banks, especially PSBs, without any dilution in government holding.

• Issue of golden shares: Another possible way to address the issue could be through the issuance of golden shares. With the issue of such a share, the Government can relinquish majority ownership in PSBs, but still retain majority control over them.

• Stock split: Increasing the number of shares through a stock split could enable the raising of equity capital.

• Dividend stocks: The Government could issue bonds to banks in lieu of the dividend amount. The banks would then be in a position to retain this and shore up their capital.

• Rights issue: The Government should also examine the possibility of permitting banks to take the rights issue route for shoring up the capital base.

2.2.4 (d) Capital Augmenting Measures

Recapitalisation of PSBs/RRBs was started in 1993-94 to enable nationalised banks to meet the prescribed CRAR and the gap created by the application of prudential accounting norms. Over the years, the total capital contributed by the Government amounted to approximately Rs.22,000 crore on a cumulative basis which is only about one per cent of GDP (2002-03).

Internationally, the impact on the exchequer of recapitalisation has often been quite large. According to an estimate from 40 episodes of banking crises across countries, Governments spent on an average 12.8 per cent of national GDP to clean up their financial systems (Honohan and Klingebiel, 2000 and 2001). The percentage was even higher (14.3 per cent) in developing countries. Hoelscher and Quintyn (2003) provide an estimate of comparable fiscal costs across countries of various banking crises during 1980 - 2003. These costs have varied sharply, ranging from small amounts (close to zero) in France and New Zealand to 50 per cent or more in Indonesia and Argentina. The fiscal cost of banking crises in select countries is given in Table 2.10.

 

17 Although issuance of these shares has been permitted by RBI, at present, they cannot be issued by private sector banks till the relevant amendments to the Banking Regulation Act are passed by Parliament.

 

Table 2.10 Select Banking Crises and Fiscal Cost

Country

Year of Crisis

Fiscal cost
(% of GDP)

1

2

3

Argentina (I)

1980

55.1

Argentina (II)

1995

0.5

Australia

1989

1.9

Brazil

1994

13.2

Bulgaria

1996

13.0

Chile

1981

41.2

France

1994

0.7

Indonesia (I)

1992

3.8

Indonesia (II)

1997

50.0

Malaysia (I)

1985

4.7

Malaysia (II)

1997

16.4

New Zealand

1997

1.0

Thailand (I)

1983

2.0

Thailand (II)

1997

32.8

Philippines (I)

1983

13.2

Philippines (II)

1998

0.5

USA

1981

3.2

Source: Honohan, P. and Klingebiel, D. (2003).

 

In the above context, the cost incurred by India for recapitalising the PSBs is low and there does not appear to be any regulatory forbearance which has resulted in any significant increase in fiscal costs. The last few years of strong performance has also enabled PSBs to return substantial amount of capital to the Government and the outstanding amount of recapitalisation has declined significantly.

Legislative amendments have also been made to allow PSBs to raise capital from the market not exceeding 49 per cent of their equity. This has strengthened the capital base of PSBs. (Box 2.4: Capital augmenting measures).

2.2.4 (e) Solvency of the Banking System

A commonly employed indicator of banking soundness is the Z-score. A higher Z-score implies a lower probability of insolvency risk. Under this model, risk is measured as the number of standard deviations an institution's earnings must drop below its expected value before equity capital is depleted. The Z-score can be summarised as Z ≡ (k+µ)/ó where k is the equity capital as percentage of assets, µ is the average after-tax return percent on assets and ó is the standard deviation of the after-tax return on assets19. Based on this identity, an attempt has been made to assess the trend in solvency of the domestically incorporated Indian commercial banks. The foreign commercial banks operating in India have been left out of the analysis as these entities operate only as branches and as such their capital requirements are met by their foreign parents incorporated abroad and are subject to separate regulatory guidelines. The Z-score for domestic banks for the period 1997 to 2008 are provided in Table 2.11. The scores show an improvement in solvency over time.
 

Box 2.4: Capital Augmenting Measures of Public Sector Banks

 

Over the period beginning 1984-85, the Government injected capital for strengthening the equity base of nationalised banks. There appears to be three distinct phases of recapitalisation: phase I (regular and general) covering the period 1984-85 to 1992-93 when all nationalised banks were recapitalised without any pre-set norm, phase II (pre-designed under a recovery programme) covering the period 1993-1995, when financial sector reforms were given a big push and recapitalisation of all nationalised banks had to be accorded priority and phase III (case-by-case basis) covering the period post 1995 wherein Government, as the owner of banks, had to improve their capital position to the stipulated levels. This also included several years when no capital injection was provided to the nationalised banks. Several such banks, which were recapitalised in phase II, have since returned substantial amount of capital back to the Government. The total recapitalisation till end-March 2006 aggregated to around Rs.22,000 crore, amounting to approximately one per cent of GDP (2002-03). The Union Budget 2006-07 proposed the winding up of the Special Securities through their conversion from non-tradable into tradable, SLR Government of India dated securities.

Around the same time, measures were undertaken to broaden the banks’ capital base. The Banking Companies (Acquisition and Transfer of Undertakings) Act, 1970 and 1980 and the State Bank of India Act, 1955 were amended to allow banks to raise capital not exceeding 49 per cent18 of their equity. Equity sales in the market aggregating around Rs.19,600 crore have been made by the PSBs, with several banks approaching the market more than once. Over the period 1993-2007, as many as 22 PSBs have accessed the capital market; their extent of divestment presently ranges from 23.2 - 48.9 per cent.

Source : Government of India/Reserve Bank of India
 

18 In the case of SBI, Government shareholding cannot come down below 55 per cent at present.


2.2.4 (f) Asset Quality

The ratio of gross NPA to total loans, which was 11.4 per cent for scheduled commercial banks at end March 2001 saw a marked decline to 2.5 per cent at end March 2008 (Chart 2.4). The improvement in asset quality is observed across bank groups (Tables 2.12, 2.13). This sizeable decline can be attributed to three major factors.

First, there has been significant increase in write-offs by taking advantage of the increased treasury income (till 2004) in a falling interest rate environment. Second, improved credit risk management practices adopted by banks have resulted in lower asset slippage. Also, taking advantage of legal reforms, the recovery performance of the banking sector has also improved markedly, particularly during the last few years. The Securitisation and Reconstruction of Financial Assets and Enforcement of Security Interest (SARFAESI) Act 2002 for enforcement of security interest without intervention of the courts has also given negotiating power to banks. Some significant recoveries have since been effected under the SARFAESI Act, 2002 (Rs.4,429 crore in 2007-08) and other accompanying measures (Rs.3,196 crore in 2007-08).20 As at end June 2008, the book value of assets acquired by securitisation companies and reconstruction companies amounted to Rs.41,414 crore.
 

Table 2.11: Z-score for Domestic Commercial Banks: 1997-2008

Period

Z-score

Equity/Asset (k)

RoA

Standard deviation of RoA ( per cent) (ó)

1

2

3

4

5

1997 - 2006

10.2

5.7

0.83

0.64

1998 - 2007

11.5

5.8

0.85

0.58

1999 - 2008

13.2

6.3

0.86

0.54

Source: Computed from RBI data

 

19 Let µ ≡ expected earnings (RoA to asset), ó ≡ standard deviation and k ≡ capital to asset. Then Z-score≡(k+µ)/ó is the number of standard deviation below the mean earnings that just wipes out capital. Under standard economic theory, a firm trades off between higher expected earnings and lower variation in earnings along its µ -ó efficient frontier, as well as choosing its capital k. Although this framework has its limits, it is useful to think of the contributions to risk in terms of factors that affect expected earnings (returns), the variation in earnings, capital and the institution’s trade-off along the efficient risk-return frontier.

 
6
 
Net NPAs also witnessed significant declines, driven by reduction in gross NPAs and appropriate provisioning. The net effect of these improvements has been reflected in a rise in banks’ coverage ratios (ratio of capital and reserves net of net NPAs scaled by assets) (Table 2.14).21 Coverage ratios of commercial banks, which was less than 2.4 per cent at end March 2001 increased three-fold to 7.3 per cent at end March 2008; the increase being witnessed across banks group.
 

Table 2.12: Asset Quality of Commercial Banks

(per cent)

Bank Group Year

Gross NPA/Loans

Provisioning/NPA

 

March 05

March 06

March 07

March 05

March 06

March 07

1

2

3

4

5

6

7

Public Sector

5.5

3.6

2.7

60.4

61.9

56.8

Old Private

6.0

4.4

3.1

52.4

62.6

66.0

New Private

3.6

1.7

1.9

47.9

54.8

49.1

Foreign

2.8

1.9

1.8

54.1

44.9

51.1

Commercial Banks

5.2

3.3

2.5

58.6

60.7

56.1

Emerging Markets

           

Brazil

4.2

4.1

4.0

151.8

152.8

153.0

Mexico

1.8

2.1

2.2

232.1

207.4

194.7

Korea

1.2

0.8

0.8

131.4

175.2

177.7

South Africa

1.5

1.2

1.1

64.3

..

..

Developed

           

US

0.7

0.8

0.8

155.0

137.2

129.9

UK

1.0

0.9

..

56.1

..

..

Japan

2.9

2.5

..

31.4

30.3

..

Canada

0.5

0.4

..

49.3

55.3

..

Australia

0.2

0.2

0.2

203.0

204.5

..

Source: RBI and IMF (GFSR)

 

20 These included recoveries under Debt Recovery Tribunal (Rs.3,020 crore) and recoveries under Lok Adalats (Rs.176 crore).

 

Table 2.13 : Asset Quality - end March 2008

Bank Group

Gross NPA / Loans

Provisions / Gross NPAs

1

2

3

Public Sector

2.3

51.9

Old Private Sector

2.3

68.8

New Private Sector

2.9

51.4

Foreign

0.9

51.2

Commercial Banks

2.4

52.5

Source: RBI

 

The evidence on asset slippage of banks over the past few years provides apparently limited cause for concern (Table 2.15)22. Illustratively, asset slippage in 2008 was consistently lower across all bank groups, except for foreign banks where it increased marginally in 2007-08. In the event of an economic downturn however, these could rapidly manifest in an increased burden of NPAs in the banks’ balance sheets.

In spite of several legal reforms, the rights of Indian banks in the event of a loan default remain ambiguous. While the laws are reasonably adequate, the procedures are time-consuming and amenable to repeated stay orders which result in the erosion of rights of creditors. Also, the improvement in asset quality could, at least partially, be attributed to the benign economic scenario prevalent in the last five years (till 2007-08) and could be impacted in the event of an economic downturn. Higher interest rates could also impact asset quality adversely.

 

Table 2.14. Banks’ Coverage Ratios

Figures in per cent

At end-March

Commercial Banks

Public Sector Banks

Old Private Banks

New Private Banks

Foreign Banks

1

2

3

4

5

6

2001

2.4

1.7

2.1

4.5

8.0

2007

6.1

5.3

5.9

6.4

11.4

2008

7.3

5.9

7.5

10.2

13.1

Source: Computed from RBI data

 

21 The coverage ratio allows for simultaneous monitoring of two important elements, viz., (i) level of non-performing assets and (ii) equity capital, adverse movements in which have been found to precede most cases of banking crises. Focusing on this ratio for identifying weakness of a bank is quite advantageous as it allows differentiation between banks which may have the same level of NPAs but different levels of equity capital and loan reserves. It thus gives due credit to the banks that have higher capital funds and have followed a more prudent policy of provisioning for their NPAs.
22 Asset slippage is defined as: NPAs at end of year - NPAs at beginning of year + recoveries due to upgradation, compromise/write-offs + actual recoveries

 

Table 2.15: Asset Slippage Across Bank Groups

End-March

Public Sector Banks

Old Private Banks

New Private Banks

Foreign Banks

Commercial Banks

1

2

3

4

5

6

2004

3.1

2.9

3.4

2.5

3.1

2005

2.3

2.1

3.3

1.8

2.3

2006

1.9

1.7

1.7

1.5

1.8

2007

1.7

1.7

2.0

1.5

1.8

2008

1.6

1.3

2.0

2.1

1.7

Note : Figures in per cent and expressed as ratios to gross advances at the beginning of the year. Source: RBI

 

(I) Asset Quality of Retail Assets

There has been a marginal uptrend in the impaired loans in banks’ retail portfolio (Chart 2.5). This has been especially marked for consumer durables and credit card receivables, where impaired credit as percentage of outstanding amount has been higher than the overall ratio for this segment. Also, a significant portion of other personal loans, credit card receivables, consumer durables, are uncollateralised. But the real vulnerability lies in housing loans where there may be an increase in NPAs owing to inadequate risk assessment, sudden increase in Loan-to-Value (LTV) ratio due to fall in housing prices and increased delinquency. Though the default rate on housing loans in India is among the lowest in the world, the balance of evidence points to the need to exercise better credit discipline by banks in retail loan administration.

(II) Stress Tests of Credit Risk

To ascertain the resilience of banks, stress tests of credit portfolio by increasing both NPA levels (for entire portfolio as well as specific sector) and provisioning requirement were undertaken. The resulting estimates were related to bank capital. The analysis was carried out both at the aggregate level as well as at the individual bank level based on supervisory data as at end March 2007 and end March 2008 under three scenarios.

Along with increased provisioning norms for standard, sub-standard and doubtful/loss assets, the first scenario assumes a 25 per cent increase in NPAs (an alternative scenario assumes a 50 per cent increase in NPAs). The shock imparted in the second scenario amounts to the maximum asset slippage experienced by banks since 2001. The third scenario assumes a 50 per cent increase in delinquent loans in the retail segment.

 
7
 


The findings indicated that the likely impact of credit default on banks' capital position was relatively muted. Under the worst-case scenario (scenario-II), the overall capital adequacy of the commercial banking sector declined to 11.6 per cent in March 2008. As many as 15 banks accounting for roughly 14.7 per cent of commercial banking sector assets at end March 2008 would not be able to meet minimum regulatory capital requirements. The corresponding figures for end March 2007 were 14 banks and 10.2 per cent, respectively (Annex 2.2: Credit Risk Stress Test - Scenarios and Results).

Combining these results with earlier observations, the Panel believes that although credit risk concerns are low at present, there is a need for closure and continuous monitoring in order to avoid any unforeseen possibilities of significant asset quality deterioration over the medium term. This gains particular importance as the current slowdown in economic growth could result in the NPA ratios going up by the end of the financial year 2008-09.

2.2.4. (g) Earnings and Profitability Indicators

The returns on equity (RoE) levels of Indian banks are comparable to those prevailing internationally (Chart 2.6)23. Operating expenses have been mostly contained. The interest margins are broadly comparable to those prevailing internationally. But provisioning expenses are on the higher side as compared to developed economies. The pre-tax profits of Indian banks are also comparable to international ones (Table 2.16).

 
8
 

23 Figures for India pertain to 2007-08. For all other countries figures pertain to 2007. Figures for South Korea pertain to 2006. Table 2.17 depicts the earnings and profitability indicators for 2007–08.

 

Table 2.16: Earnings and Profitability Indicators of Commercial Banks

(Ratios in per cent)

Bank Group

Operating Expenses

Provisioning expenses

Net interest Income

Pre-tax profit

2004-05

2005-06

2006-07

2004-05

2005-06

2006-07

2004-05

2005-06

2006-07

2004-05

2005-06

2006-07

1

2

3

4

5

6

7

8

9

10

11

12

13

Commercial Banks

2.1

2.1

1.9

1.3

1.1

1.0

2.8

2.8

2.7

1.2

1.2

1.3

Public sector

2.1

2.1

1.8

1.3

1.1

0.9

2.9

2.9

2.7

1.1

1.1

1.2

Private sector

2.0

2.1

2.1

1.0

0.8

1.0

2.3

2.4

2.5

1.1

1.2

1.1

Old private

2.0

2.1

1.9

1.4

0.9

1.2

2.7

2.8

2.8

0.4

0.9

1.1

New private

2.1

2.1

2.1

0.8

0.8

1.0

2.2

2.3

2.3

1.5

1.3

1.1

Foreign

2.9

2.9

2.8

1.7

1.8

1.8

3.3

3.6

3.7

2.2

2.6

2.8

Country

                       

Australia

2.2

1.6

1.6

0.2

0.1

0.1

2.1

1.7

2.0

1.5

1.4

1.6

Germany

1.4

1.2

1.2

0.2

0.1

0.1

0.7

0.6

0.7

0.1

0.4

0.5

France

1.5

1.9

1.4

0.1

0.1

0.1

0.9

0.8

0.8

0.7

0.7

0.9

Netherlands

1.5

1.3

1.5

0.1

0.1

0.1

1.3

1.1

1.1

0.5

0.6

0.6

Japan

1.7

1.3

1.4

0.6

0.1

0.1

1.0

0.9

1.0

0.3

0.7

0.9

UK

1.7

1.6

1.7

0.2

0.2

0.3

1.2

1.1

1.1

1.0

0.9

1.0

US

3.5

3.3

3.1

0.2

0.2

0.2

2.8

2.7

2.5

1.8

1.9

1.8

Note : As per cent to total asset for India and as per cent to total average assets for other countries. Cross-country figures are for 2004, 2005 and 2006, respectively. Number of reporting varies markedly in cross-country numbers.
Source: RBI and BIS.

 

The return on asset (RoA) has improved over the last few years, to reach one per cent of total assets in 2007-08. Among bank groups, RoE is highest for public sector and foreign banks and comparatively lower for Indian private sector banks (Table 2.18). The RoE compares favourably with the 2000-01 numbers, although there has been a significant decline from its 2003-04 peak of 19.3 per cent, which was a result of high treasury profits arising out of a benign interest rate regime. Owing to rapid credit expansion and some upward pressure on interest rates since 2004, there has been an increase in net interest income (NII) which has helped retain RoE and RoA at a relatively high level (till 2006-07). The increase in NII is further buttressed by replacement of low-yielding excess SLR with retail loans fetching relatively higher rates of return (Table 2.19), though there has been some fall in NII in 2007-08. While the bottom-line of SCBs witnessed a perceptible improvement, the net interest margin (NIM) of banks showing a declining trend though it has generally remained on the higher side.

 

Table 2.17 : Earnings and Profitability Indicators of Commercial Banks – 2007-08

(Ratios in per cent)

Bank Group

Operating Expenses

Provisioning Expenses

Net Interest Income

Pre-tax Profit

1

2

3

4

5

Commercial Banks

1.8

1.0

2.4

1.4

Public Sector

1.6

0.8

2.2

1.2

New Private Sector

2.5

1.2

2.4

1.3

Old Private Sector

1.7

0.8

2.4

1.5

Foreign

2.8

2.0

3.8

3.2

Note : Per cent to total assets.
Source : RBI

 

Table 2.18 : Return on Assets (Return on Equity) for Bank Groups

(Figures in per cent)

Year

Public sector

Private sector

Old private

New private

Foreign

Commercial banks

1

2

3

4

5

6

7

2000-2001

0.42 (8.8)

0.70 (12.8)

0.59 (11.3)

0.81 (14.3)

0.93 (11.1)

0.49 (9.7)

2003-2004

1.12 (20.9)

0.95 (16.3)

1.20 (19.6)

0.83 (14.6)

1.65 (15.4)

1.13 (19.3)

2004-2005

0.87 (14.6)

0.83 (11.9)

0.33 (5.5)

1.05 (14.0)

1.29 (10.8)

0.89 (13.6)

2005-2006

0.82 (13.3)

0.87 (10.9)

0.58 (9.6)

0.97 (11.4)

1.54 (12.9)

0.88 (12.7)

2006-2007

0.85 (13.6)

0.87 (11.6)

0.70 (10.9)

0.91 (11.8)

1.65 (14.0)

0.90 (13.2)

2007-2008

0.89(13.7)

0.99(9.6)

1.02(12.9)

0.98(8.9)

1.81(13.5)

0.99(12.5)

Note : Figures in parentheses indicate Return on Equity (RoE)
Source: RBI

 
Although interest income has generally remained the mainstay for banks, the diversification of banks’ portfolio has resulted in rising share of non-interest income, especially for new private sector and foreign banks. While share of fee income for public and old private sector banks has trended at around six per cent and five per cent respectively; of total income new private and especially foreign banks generate nearly 15 per cent of their income from fee-based sources (Table 2.19). Treasury income, which constituted an important income component of banks in an era of benign interest rates, has since tapered off. Generating innovative ways of increasing fee income by diversifying income sources remains an ongoing challenge for public and old private sector banks. Driven to a large extent by the decline in treasury income, the burden of banks has increased significantly across bank groups from 2003-04 levels. (Table 2.20).24

The containment of operating expenses along with the improvements in total income, has led to a moderation in the cost-income ratio (CIR) which stood at less than 50 per cent at end March 2008 (Table 2.21; Chart 2.7). Across bank groups, the ratio hovered around 43-54 per cent in 2007-08, being the highest for new private banks, owing to their relatively higher operating expenses. NIMs witnessed a decline, reflecting higher efficiency and competitive pressures. But the interest expense ratio has increased in recent years due to the stickiness of deposit rates.
 

24 The burden reflects the extent to which non-interest expenses are recovered through non interest income and is computed as non interest income less non interest expense scaled by total assets. A higher ratio indicates lower appropriation of non interest income to meet non interest expenses and therefore lower burden.

 

Table 2.19: Sources of Income of Banks

(Percentage of total income)

Year (April-March)

Public sector

Old private

New private

Foreign

Commercial Banks

1

2

3

4

5

6

A: Net interest income

2000-2001

28.1

22.6

21.4

30.6

27.6

2003-2004

31.7

26.3

22.0

36.1

30.5

2004-2005

35.9

34.1

29.0

39.3

35.2

2005-2006

36.1

35.0

28.2

40.6

35.2

2006-2007

34.7

34.5

27.6

41.7

34.1

2007-2008

26.7

28.1

23.7

39.5

27.4

B: Fee income

2000-2001

6.3

5.3

6.8

10.6

6.7

2003-2004

5.6

4.5

8.6

12.8

6.4

2004-2005

6.1

5.3

13.9

16.8

7.8

2005-2006

6.3

5.3

15.5

15.3

8.3

2006-2007

6.6

5.4

13.8

15.4

8.6

2007-2008

6.1

4.9

12.8

15.3

8.2

C: Treasury income (Profit/loss on securities trading)

2000-2001

2.4

2.3

3.0

2.9

2.4

2003-2004

11.3

12.7

9.4

4.1

10.6

2004-2005

5.9

1.7

2.2

-4.4

4.5

2005-2006

2.9

1.5

2.8

-3.3

2.3

2006-2007

1.0

1.5

0.1

-3.7

0.5

2007-2008

2.9

2.0

3.3

0.4

2.7

Source: RBI

 

The interest expense ratio (defined as interest expense as percentage to total income) declined from 54.3 per cent for commercial banks in 2002-03 to 47.6 per cent in 2005-06 and has thereafter seen an increase to 55.9 per cent in 2007-08. On the other hand, non interest expense ratio saw an increase from 22.1 per cent in 2002-03 to 27.0 per cent in 2005-06 and thereafter decreased to 21.6 per cent in 2007-08, primarily due to a decline in ratio of wages to total income (from 13.8 per cent in 2002-03 to 11.1 per cent in 2007-08). Increase in provident fund and pension liabilities coupled with increased expenditure due to technology upgradation could put some pressure on operating expenses in the future.

An analysis of the dynamics underlying the profit augmentation process of banks

 

Table 2.20 : Burden of Bank Groups

(per cent)

Bank Group

2002-03

2003-04

2004-05

2005-06

2006-07

2007-08

1

2

3

4

5

6

7

Commerical banks

-0.36

-0.17

-0.66

-0.78

-0.81

-0.41

Public sector banks

-0.60

-0.28

-0.73

-0.94

-0.94

-0.51

Old private banks

0.25

0.12

-1.00

-1.16

-0.90

-0.57

New private banks

0.65

0.11

-0.31

-0.15

-0.50

-0.21

Foreign banks

-0.15

0.20

-0.33

-0.19

-0.28

0.05

Source: RBI

 

Table 2.21: Cost - Income Ratio and Interest Expense Ratio of Bank Groups

(per cent)

Parameter / Bank Group

2002-03

2003-04

2004-05

2005-06

2006-07

2007-08

1

2

3

4

5

6

7

A: Cost income ratio

           

Scheduled commercial banks

48.3

45.6

49.4

51.8

51.2

48.9

Public sector

49.3

45.1

48.5

52.3

51.5

48.9

Old private

43.4

42.8

53.8

58.3

49.3

47.4

New private

46.0

50.2

52.6

50.2

55.1

54.0

Foreign

46.6

46.2

49.4

47.8

45.1

42.9

B: Interest expense ratio

           

Scheduled commercial banks

54.3

47.7

46.7

47.6

51.4

55.9

Public sector

54.4

47.8

47.5

49.3

53.9

60.2

Old private

55.8

51.8

53.9

53.2

53.9

59.2

New private

60.1

53.4

47.5

46.8

52.0

53.3

Foreign

42.2

32.9

30.9

29.5

30.5

30.4

Source: RBI

 
 
indicates that25 while the profit margins have increased, asset utilisation (AU) has witnessed a decline between 2000 and 2008 (Table 2.22). This implies that banks could maintain RoA at around 0.9 - 1 per cent in the recent past, primarily because of better profit
 
9
 
25 This follows from the relationship:
 
10
 
The first term on the RHS is profit margin (PM) and the second term is asset utilisation (AU).
 

Table 2.22 Dynamics of Profit Augmentation for Bank Groups

(per cent)

 

Public sector

Old private

New private

Foreign

Commerical banks

 

PM

AU

PM

AU

PM

AU

PM

AU

PM

AU

1

2

3

4

5

6

7

8

9

10

11

2000-2001

3.9

10.2

5.6

10.8

8.6

9.5

8.1

11.9

4.7

10.4

2003-2004

11.9

9.6

12.5

9.6

9.4

8.8

17.2

9.5

12.0

9.5

2004-2005

10.4

8.3

4.0

7.9

14.0

7.6

15.4

8.4

10.9

8.2

2005-2006

10.2

8.0

7.7

7.8

12.3

7.8

17.8

8.6

10.9

8.0

2006-2007

10.6

7.8

8.5

8.2

9.8

8.6

18.4

8.9

11.1

8.0

2007-2008

10.8

8.2

11.8

8.6

9.9

9.9

18.9

9.6

11.5

8.6

Source: RBI

 

margins. The profit margins depend, inter alia on level of provisions and contingencies, which depends on the efficacy of risk management practices. In recent years, PM has improved on account of lower loan loss provisioning requirements and lower depreciation on investments due to transfer of significant portion of banks’ investment portfolio to the held to maturity (HTM) category. Banks’ ability to influence interest costs is limited. Asset quality could become a cause for concern going forward, and the benign loan loss provisioning scenario may not continue. This will strain profit margins. Given the declining yields on deployment of funds as reflected by dwindling asset utilisation, banks have to adopt better and more sophisticated risk management techniques for balance sheet management to maintain their existing RoA levels.

2.2.4 (h) Liquidity Risk Management

The rapidly increasing loan book of the banks is clearly reflected in a decline in the ratio of liquid assets to total assets. At a time when the economy is in a higher growth trajectory, it is imperative that banks simultaneously stress on low-cost deposit mobilisation and eschew excessive recourse to borrowed funds to avoid potential asset-liability maturity mismatches.

Liquidity demands can emanate from the asset as well as the liability sides of balance sheet. On the asset side, liquidity risk may arise due to the unbridled growth of illiquid on-balance sheet items or due to the crystallisation of off-balance sheet items in the asset book. On the liability side, banks can face challenges in refinancing debts, particularly those with overwhelming dependence on wholesale deposits and short-term borrowings to fund asset growth. Given the magnitude of the turmoil currently experienced in the global financial markets, the Panel feels that liquidity risk management needs to be accorded priority. The Panel carried out an analysis of liquidity from three angles: the traditional asset liability mismatch, an analysis of select liquidity ratios and scenario analyses of liquidity.

(I) Asset Liability Management

With an increase in banks’ exposure to real estate, infrastructure and other long-term loans, banks’ asset liability maturity mismatches need to be monitored closely. An analysis of asset-liability profile of banks reveals the following:

• Since March 2001, there has been a steady rise in the proportion of deposits maturing up to one year. These increased from 33.2 per cent in March 2001 to 43.6 per cent in March 2008.

• Loans maturing between three to five years increased from 7.6 per cent of total loans in March 2001 to 11.7 per cent in March 2007. The ratio moderated to 10.3 per cent as at end March 2008. Loans maturing over 5 years grew even higher from 9.3 per cent to 18.9 per cent between 2001 and 2007 before moderating to 16.5 per cent in 2008.

• Funding of incremental asset growth by sources in addition to incremental deposits had been the trend in 2005 and 2006. But in 2007 and 2008, deposit growth has outpaced the growth in credit. (Annex 2.3: Asset liability mismatches)

(II) Liquidity Ratios

The sub-prime turmoil has brought the liquidity issue to the fore as a cornerstone of financial stability. What began with initial disruptions in credit market quickly manifested itself in the form of a drying up of market liquidity, both within and across borders. The emergence of innovative financial instruments to distribute credit risks prompted institutions to take risks disproportionate to their capability to assume such risks. In view of such concerns, attempts are underway to arrive at a better understanding of liquidity ratios.

Banks in India appear to have ample liquidity in view of the predominance of deposits as the main source of funding (Table 2.23).

The evidence indicates that low cost deposits, mainly current and savings deposits, comprised more than one third of total deposits, reflecting the inherent strength of banks in terms of cost. The fiscal incentives announced in the Union Budget 2006-07 have led to an increase in the share of time deposits (Table 2.24).

Banks have funded the high credit growth over the last few years by drawing down on their investments, resulting in a lowering from over 40 per cent of net demand and time liabilities (NDTL) in the early 2000s to around 30 per cent in end-2008.

Banks can meet their liquidity needs by two methods: stored liquidity and/or purchased liquidity. The former utilises on-balance sheet liquid assets and a well-crafted deposit structure to provide all funding needs; the latter uses non-core liabilities and borrowings to meet funding needs26. While each has its advantages and disadvantages because additional stored liquidity is garnered at an additional cost, a balanced approach to a liquidity strategy is often the most cost effective. It also entails low-risk.
 

Table 2.23: Liability Profile of the Indian Banking System

Particulars

Mar-03

Mar-04

Mar-05

Mar-06

Mar-07

Mar-08

1

2

3

4

5

6

7

Capital & Reserves

5.7

5.9

6.6

6.9

6.7

7.9

Customer Deposits

76.8

77.3

75.4

75.4

76.1

75.7

Bank Deposits

3.7

3.2

3.0

2.5

2.7

2.2

Borrowings

4.8

4.0

6.2

6.1

5.2

4.6

Other Liabilities

9.0

9.6

8.8

9.1

9.3

9.6

Note : As per cent to total liabilities including capital and reserves
Source: RBI

 

26 Ref: A Regulator’s View Of Liquidity, David Hanson, NCBA Conference, Greensboro, NC 2003

 

Table 2.24: Deposit Structure of Indian Banks

Particulars

Mar-03

Mar-04

Mar-05

Mar-06

Mar-07

Mar-08

1

2

3

4

5

6

7

Time Deposits

49.3

51.0

51.5

50.6

52.4

53.0

Savings Deposits

21.9

23.1

23.7

24.6

23.1

22.0

Current Deposits

10.5

11.2

11.1

12.0

11.4

12.1

NRI Deposits

13.8

10.8

9.4

7.6

6.8

5.3

CDs

0.0

0.1

0.5

1.9

3.0

4.7

Bank Deposits

4.5

3.9

3.8

3.3

3.3

2.9

Note : As per cent to total deposits
Source: RBI

 

Keeping these considerations in view, a set of liquidity ratios has been developed to focus squarely on this facet. Despite its limitations, these numbers provide important pointers towards the banks’ overall funding strategy. The ratios along with the definitions, are given in Table 2.25.

An analysis of the data for the last four years reveals that there is a gradual and growing dependence on purchased liquidity coupled with an increase in illiquid component of banks’ balance sheets (Table 2.26).
The analysis shows the following:

• There is now greater reliance on large liabilities to support asset growth. The ratio of volatile liabilities net of temporary assets to earning assets net of temporary assets increased from 34.7 per cent in March 2005 to 43.9 per cent in March 2008. The dependence on large volatile deposits is buttressed by the increasing dependence on wholesale deposits (deposits in excess of Rs.15 lakhs) which increased from less than 40 per cent in March 2004 to 57.6 per cent in March 2007.


• The share of stable funding source is shrinking and there is a greater reliance on short-term deposits and borrowings. The ratio of core deposits including net worth to total assets works out to 49.3 per cent in March 2008, down from 53.8 per cent in March 2005.

• The ratio of loans including fixed assets, mandatory CRR and SLR prescriptions to total assets has increased from 75.0 per cent in March 2005 to 85.9 per cent in March 2008 reflecting higher illiquidity in banks’ balance sheets.

• The ratio of loans including fixed assets, mandatory CRR and SLR prescriptions to core deposits (including net worth) has remained over 1, reflecting purchased liquidity management generally followed by the banks. The ratio increased from 1.4 in March 2005 to 1.7 in March 2008.

• There is an increase in short-term assets with corresponding rise in short-term liabilities. The ratio of temporary assets to total assets has increased from about 29 per cent in March 2005 to 52 per cent in March 2008.

• Despite the rise in temporary assets, the cover of liquid assets in relation to volatile liabilities has remained at less than 1, reflecting a potential liquidity problem.

• The ratio of volatile liabilities to total assets has increased from 53.5 per cent in March 2005 to 73.1 per cent in March 2008, reflecting higher reliance on large volatile liabilities to fund asset growth.

• The ratio of market value of non-SLR securities and surplus SLR securities to their book values generally hovered around 1.
 

Table 2.25: Liquidity Ratios and Definitions

No

Ratio

Components

Significance

1

2

3

4

1

(Volatile  liabilities  – Temporary      Assets)/ (Earning     Assets     – Temporary Assets)

Volatile Liabilities:
(Deposits   +   borrowings+bills payable upto 1 year)
Letters of credit – full outstanding Component-wise  CCF  of  other
contingent credit and commitments Swap funds (buy/ sell) upto one year
As per extant norms, 15 per cent of current deposits (CA) and 10 per cent of savings deposits (SA) are to be treated as volatile and shown in 1-14 days time bucket; remainder in 1-3 years bucket. Hence CASA deposits reported by banks as payable within one year are included under volatile liabilities.
Borrowings include from RBI, call, other institutions and refinance

Measures the extent to which hot money supports bank’s basic earning assets. Since the numerator represents short-term, interest sensitive funds, a high and positive number implies some risk of illiquidity.

Temporary Assets:
Cash
Excess CRR balances with RBI
Balances with banks Bills purchased/discounted upto 1 year
Investments upto one year Swap funds (sell/ buy) upto one year

Earning Assets:
Total assets – (Fixed assets + Balances in current accounts with other banks + Other assets excl. leasing + Intangible assets)

2

Core deposits / Total Assets

Core Deposits:
All deposits (including CASA) above
1 year+net worth
Total Assets: Balance sheet footing

Measures the extent to which assets are funded through stable deposit base

3

(Loans + mandatory SLR + mandatory CRR + Fixed Assets )/ Total Assets

Gross Advances Required SLR Required CRR Fixed assets

Loans including mandatory cash reserves and statutory liquidity investments are least liquid and hence a high ratio signifies the degree of ‘illiquidity’ embedded in the balance sheet

4 (Loans + mandatory SLR + mandatory CRR + Fixed Assets) / Core Deposits Advances Required SLR Required CRR Fixed assets Measures the extent to which illiquid assets are financed out of core deposits.
Greater than 1 (purchased liquidity)
Less than 1 (stored liquidity)
5 Temporary Assets / Total Assets   Measures the extent of available liquid assets. A higher ratio could impinge on the asset utilisation of banking system in terms of opportunity cost of holding liquidity
6 Temporary Assets / Volatile Liabilities   Measures the cover of liquid investments relative to volatile liabilities.
A ratio of less than 1 indicates the possibility of a liquidity problem.
7 Volatile liabilities/Total Assets Item 5 divided by item 6 Measures the extent to which volatile liabilities fund the balance sheet
8 (Market Value of Non-SLR Securities + Excess SLR Securities)/(Book Value of Non-SLR Securities + Excess SLR Securities)   Measures the market value of non-SLR securities and excess SLR securities relative to their book value. A ratio exceeding 1 reflects that a bank stands to gain if it sells off its saleable portfolio
Source : RBI/Joseph F. Sinkey - Commercial Bank Financial Management
 
 
 

(III) Liquidity Scenario Analysis

Liquidity risk is essentially a consequential risk triggered by a combination of several other risks like a loss of depositors’ confidence, changes in counterparty credit risk, changes in economic conditions, fluctuations of interest rates, etc. Assessing liquidity involves estimating net cash-flow which, if adverse, has the potential of turning into a liquidity risk. A system level liquidity scenario analysis involves the aggregation of individual exposures, which may lead to netting-out effect. Besides, aggregation can also conceal substantial exposures at the individual level.

The severity, correlation, and impact of these multiple factors on banks’ liquidity are often difficult to capture in a stress test scenario. In view of this, it is desirable that risk factors that create potential liquidity risk be analysed in a segmented way.

Keeping this in view, three scenarios depicting various factors with a bearing on bank liquidity have been hypothesised. The first captures unexpected deposit withdrawals and its bearing on bank liquidity. The second segregates unexpected withdrawal between uninsured and insured deposits. The third envisages a crystallisation of contingent credits/ commitments as a result of changes in the credit-risk profile and delinquency in the repayment of loans due to an economic downturn. The analysis has been done in respect of the five largest banks in terms of asset size at end March 2008.

The findings indicate that, under the first scenario, total deposit withdrawal on day one accounts for 5.7 per cent of total deposits of these banks. One bank exhausts its stock of liquid assets and ends up with a negative balance at the end of the first day.
 

Table 2.26: Liquidity Ratios – Frequency Distribution and Average Value

Variable/Range (per cent)

Mar-05

Mar-06

Mar-07

Mar-08

 

No. of banks

Share in asset

No. of banks

Share in asset

No. of banks

Share in asset

No. of banks

Share in asset

(Volatile liabilities – temp. asset)/ (Earning asset – temp. asset) - (per cent)

1

2

3

4

5

6

7

8

9

Negative

8

0.3

8

1

8

0.9

5

0.4

0 - 25

23

21.4

16

9.7

10

7.6

9

1.9

25 - 50

33

60.6

37

67.5

34

64.2

34

70.7

Above 50

24

17.8

24

21.8

29

27.3

38

27.0

Mean Value

34.7

38.4

41.4

43.9

Core deposits)/Total assets – (per cent)

Below 50

44

26

38

32.1

37

35.9

42

43.5

Above 50

44

74

47

67.9

44

64.1

34

56.5

Mean Value

53.8

53.9

52.2

49.3

Loans+ Mandatory CRR + Mandatory SLR + Fixed assets)/ Total Assets – (per cent)

Below 40

7

0.2

6

0.3

7

0.6

6

0.5

40 - 50

4

0.6

4

0.6

4

0.1

3

0.2

50 - 70

15

32.9

8

5.2

9

5.9

8

2.9

Above 70

62

66.3

67

93.9

61

93.4

59

96.4

Mean Value

75.0

79.9

83.4

85.9

Loans + Mandatory CRR + Mandatory SLR + Fixed assets) / Core Deposits

Less than 1

10

5.5

9

0.2

9

0.3

7

0.4

More than 1

78

94.5

76

99.8

72

99.7

69

99.6

Mean Value

1.4

1.5

1.6

1.7

Temporary Assets/ Total assets - (per cent)

Less than 15

19

51.1

18

31.6

14

26.2

9

13.5

15 - 20

11

12.1

4

3.9

7

9.7

11

17.3

Above 20

58

36.8

63

64.5

60

64.1

56

69.2

Mean Value

28.8

30.3

43.4

52.0

Temporary Assets/ Volatile Liabilities

Less than 1

78

99.3

76

98.9

71

99.1

68

99.0

One or more

10

0.7

9

1.1

10

0.9

8

1.0

Mean Value

0.54

0.53

0.65

0.71

Volatile liabilities/Total asset - (per cent)

Upto 10

0

0

0

0

0

0

0

0

10 - 25

3

3.2

3

1.6

2

0.4

0

0

25 - 50

39

66.2

33

48.5

29

47.8

22

26.5

Above 50

46

30.6

49

49.5

50

51.3

54

73.5

Mean Value

53.5

57.1

66.8

73.1

(Market Value of Non-SLR Securities + Excess SLR securities)/
(Book Value of Non-SLR Securities + Excess SLR Securities)

Less than 1

45

31.6

62

66.7

69

76.3

47

57.9

One or more

43

68.4

22

33.3

12

23.7

29

42.1

Mean Value

1

1.1

0.98

1.0

Source: Computed from RBI data

 

Under the second scenario, 4.1 per cent of total deposits are withdrawn on the first day and all the five banks are able to meet their stressed repayment obligations on the first day. One bank exhibit liquidity strains from the end of day two onwards.

In the third scenario, all five banks are able to meet the devolvement of their contingent liabilities upto three months horizon (Annex 2.4: Liquidity scenario analysis).

(IV) Recommendations

While the new financial environment has offered avenues for a better management of various risks, including credit, interest rate and foreign exchange risks, one exception to this general pattern has been liquidity risk. Banking, by definition, involves the acceptance of deposits that can be generally redeemed on demand. As a result, segregating the risks associated with liquidity for banks remains an important challenge. Measures to strengthen liquidity management, therefore, require priority attention. The Panel notes that there is a gradual and growing dependence on purchased liquidity coupled with an increase in the illiquid component of banks’ balance sheets. Excessive reliance on short-term borrowed funds and wholesale deposits, rather than on retail deposits as a model for funding asset growth may engender serious asset liability mismatches, which can be called into question in times of stress.

Liquidity management and capital management are intimately intertwined as liquidity crises impact banks’ balance sheets and in turn, impact their capital position. Liquidity risk can arise out of credit, market or operational risk and vice versa. Potential liquidity risk should, therefore, take into account its contagion with other risks and also be factored into the capital adequacy requirement of banks. Although there is no stipulated requirement of capital charge for liquidity risk prescribed by the BCBS, the internal capital adequacy assessment process (ICAAP), as enumerated in Pillar II of the Basel II capital accord, also includes liquidity risk. These internal assessments of capital requirements should be supported by appropriate stress and scenario testing arising out of liquidity shocks. In addition, these can be supplemented by system-wide modelling of liquidity using different levels of margins and risk spreads to ensure that the macro-prudential supervisor has an understanding of where liquidity pressures may build up in the system as a whole, rather than in specific institutions.

The recent sub-prime crisis shows that a significant component of liquidity risk has been the crystallisation of complex derivatives product on the balance sheets of institutions. In this context, the Panel feels that the on-site examination process can be supplemented by a forensic “follow the evolution of the product” approach. In such a scenario, instead of examining institution by institution, the examination process follows the evolution of a derivative product through its origination to final holder to check whether the final institutions, infrastructure and trading, clearing and settlement, risk management processes along the trading chain, are adequate in terms of sufficient due diligence and a risk control/audit trail. The purpose of such a “forensic” examination is to train examiners to understand complex products and “follow the money”, to alert market participants (including originators) that the regulators are alert and checking the controls at every level of the transaction, so that all are at risk of being tested, and reveal to the examiners how embedded leverage is increased and risks can be transformed (or missed) at each stage of evolution of a derivative product. Dependence on purchased liquidity enhances the liquidity risk of banks and should be suitably factored into the internal assessment of capital. It may also be worth considering a specific regulatory capital charge if banks’ dependence on purchased liquidity exceeds a threshold.

The Panel recommends the constitution of a Working Group to examine this aspect in its totality.

2.2.4 (i) Interest Rate Risk

Interest rate risk stress tests were undertaken using both earnings at risk (EaR) or short-term perspective, as also the economic value perspective (Annex 2.5: Interest Rate Risk – Scenarios and Results). In the EaR perspective, the focus of analysis is the impact of changes in interest rates on accrual or reported earnings. Changes in interest rates impact a bank's earnings due to changes in interest income and the level of other interest-sensitive income and operating expenses. In the EaR approach, the impact of changes in earnings due to changes in interest rates is related to net interest income (NII). Applying the EaR approach, it was observed in March 2008 that the NII increases for 45 banks comprising 64 per cent of the banking assets for an increase in interest rates. This is because, typically, the banks' balance sheets are asset sensitive and an increase in interest rate raises the interest income relative to interest expenses.

An increase in interest rates leads to a contraction in the economic value of both rate sensitive assets and liabilities as also off balance sheet items. The impact on banks' capital would be more, higher the duration of assets, as compared to the duration of liabilities. From the economic value perspective, the analyses have been carried out from two different angles. The duration of equity (DoE) or duration of net worth approach calculates the erosion in accounting capital due to unit increase in interest rate. Subject to certain limitations, DoE captures the interest rate risk and help move towards the assessment of risk based capital. Higher the duration of equity, more is the interest rate risk and greater the requirement of capital. For the purpose of the analyses, DoE is calculated for two scenarios. Scenario I assumes that all rate sensitive savings deposits mature in a 1 - 28 days time bucket. Scenario II assumes that the entire rate sensitive savings deposits mature in 3 - 6 months. Scenario I implies a lower duration of liabilities and consequently, is the more stringent scenario of the two.

From the DoE perspective, it is observed that banks have been actively managing their interest rate risk by reducing the duration of their portfolios. The duration of equity reduced from 14.0 years in March 2006 to 8.0 years in March 2008 (Scenario I) - a pointer to better interest rate risk management. The corresponding figures in Scenario II were 13.1 years and 7.2 years. As many as 65 banks under Scenario I and 68 banks under Scenario II have DoE less than or equal to 20 years as at end March 2008, suggesting that an interest rate shock of 500 bps or more would be required to wipe out their capital and reserve. Yield volatility was estimated at 244 basis points (bps) for a one-year holding period. A 244 bps increase in yield, ceteris paribus, would result in an erosion of 19.5 per cent of capital and reserves under Scenario I.

The erosion in capital funds (regulatory capital) is estimated by calculating the duration of the assets and liabilities including off balance sheet items and estimating the net duration gap. The erosion so arrived at is deducted from the existing regulatory capital and the adjusted CRAR is arrived at. In this case it is observed that as at end March 2008, CRAR would reduce from 13 per cent to 10.9 per cent under Scenario I (11.1 per cent under Scenario II) for a 244 bps shock, CRAR of 29 banks (28 under Scenario II) accounting for 36 per cent (35 per cent in Scenario II) of the assets would go below the stipulated minimum.

Given the existing accounting norms, the impact of interest rate increase on the economic value of investment is expected to be significantly muted as a substantial portion of the banks' portfolio is immune to mark-to-market losses. An interest rate shock of 244 bps on the banks' trading book on the position as at end March 2008 would reduce the system level CRAR to 12.0 per cent, whereas it would have been reduced to 10.9 per cent if the entire balance sheet was marked to market. Similarly, a 244 bps rise in interest rates, if applied only to the banking book , would result in the CRAR being reduced from 13.0 per cent to 11.9 per cent in March 2008.

2.3 Regional Rural Banks

The regional rural banks (RRBs) present minimal risk because of their small size, but the risk of contagion always remains27. The asset quality of RRBs raises some cause for concern, with 5.9 per cent of their assets being classified as non-performing at end March 2008 along with a stagnant recovery performance. The ratio of recovery to demand has hovered around 80 per cent over the last few years. Profitability remains low, with 8 (out of 91) being loss-making banks at end March 2008 (Table 2.27). The Government has initiated recapitalisation of 27 RRBs to the tune of Rs.1,741 crore upto March 2010 to shore up their capital base.

The Annual Policy Statement by the Reserve Bank in 2004 had indicated that sponsor banks, in consultation with State Governments (the capital of base is held by the Central Government, State Governments and sponsor banks in the ratio of 50:15:35 in that order) would initiate steps for the amalgamation of RRBs sponsored by them. The process of amalgamation began in September 2005 as a result, the number of RRBs has declined to 86, including 41 stand-alone RRBs of which one RRB is newly incorporated, by December 2008. The SARFAESI Act has been extended to loans advanced by RRBs. The eligible RRBs are permitted to accept foreign currency (NRE/ FCNR) deposits. In the meantime, several measures have been undertaken, to enlarge their scope of operations and improve profitability. Sponsor banks have been advised to provide
 

Table 2.27 : Performance Indicators of Regional Rural Banks

Position as at end-March

(Amount in Rs. crore, ratios in per cent)

Year

2005

2006

2007

2008

1

2

3

4

5

Number

196

133**

96**

91**

Branch network

14,481

14,488

14,545

14,790

Deposits

62,143

71,329

83,144

99,095

Loans and advances (net)

31,803

38,520

47,326

57,601

Total assets

77,867

89,645

1,05,768

1,23,541

Profit-making RRBs (No.)

167

111

81

82

Net Profit (+)/Loss (-)

748

617

625

1,374

Net Profit/total assets

1.0

0.6

0.6

1.1

NPA/total assets

8.5

7.3

6.6

5.9

** after amalgamation;
Source: RBI and NABARD

 
27 Reference 2.6.3 ibid
 

lines of credit at reasonable rates to augment their resource base. They have also been allowed to access inter-RRBs term money/borrowings and also to the repo/CBLO markets. They have been permitted to set up off-site ATMs, issue debit/credit cards and handle pension/ government business. RRBs have also been allowed to take up corporate agency business, without risk participation, for distribution of all insurance products, including health insurance and animal insurance.

Currently, RRBs are not required to be Basel I compliant, and there is no stipulation for risk-based capital adequacy norms for these entities. Though not all principles as delineated in BCPs are applicable to RRBs, given their importance in rural credit delivery and financial inclusion, an assessment of the Basel Core Principles relating to RRBs was taken up by the Advisory Panel on Financial Regulation and Supervision. It indicated that out of the applicable 20 (out of 25) principles, they are compliant/largely compliant in respect of 12 principles. They are non compliant/materially non compliant in respect of eight which are mainly in respect of various inadequacies in the risk management process.

The Panel feels that given the varying status of RRBs as regards their financial health, computerisation, quality of governance, etc., these banks could be appropriately categorised and a roadmap could be prescribed for operationalisation of Basel I norms.

2.4 Co-operative Banks

The co-operative banking structure comprises urban and rural co-operative banks (Chart 2.8). While urban co-operative banks (UCBs) have a single tier structure, rural co­operative credit institutions comprise two distinct structures: the short-term and the long-term. The short-term structure, comprises of Primary Agricultural Credit Societies (PACs) at the village level, District Central Co-operative Banks (DCCBs) at the intermediate level and State Co-operative Banks (StCBs) at the apex
 
11
 

level. These institutions provide crop and other working capital loans to farmers and rural artisans.

The long-term structure comprises state co-operative agriculture and rural development banks at the state-level and primary co-operative agriculture and rural development banks at the district level. These entities typically provide medium and long-term loans for agricultural investments, rural industries and in the recent period, rural housing as well. This section discusses the performance and stability issues for the urban and rural co-operative banks.

2.4.1 Urban Co-operative Banks

Urban co-operative banks exhibit a high degree of regional concentration, with five states (Andhra Pradesh, Gujarat, Karnataka, Tamil Nadu and Maharashtra) accounting for nearly 79 per cent of total number of UCBs. 50 out of the 53 scheduled banks as on March 2008 are in Andhra Pradesh, Gujarat, Karnataka, and Maharashtra. 874 out of 1770 UCBs were unit (single branch) banks as at the end of March 2008 and nearly 75 per cent have a small deposit base (less than Rs 50 crore). The scheduled UCBs constitute a significant portion of the sector, accounting for about 41.8 per cent of deposits and 40.0 percent of advances. Profitability levels are low and the quantum of non-performing advances quite high (Table 2.28).

A series of policy initiatives have been undertaken such as:

• subjecting these banks to CRAR discipline (9 per cent for all banks),

• introducing a system of graded supervisory action based on financial/ prudential parameters,

• 90-day norms for loan impairment (excluding gold loans and small loans and the smaller UCBs) enhanced provisioning (0.40 per cent from 0.25 per cent earlier) on standard advances [other than in case of direct advances to agriculture and SME and except for Tier I banks (i.e. UCBs with less than Rs.100 crore of deposits),

• enhanced risk weight on commercial real estate advances, exposure norms on par with commercial banks and enhanced disclosures in their balance sheets (effective March 31, 2003) for UCBs with more than Rs.100 crore of deposits. The enhanced risk weights have since been reduced in December 2008 as a counter­cyclical measure.

 

Table 2.28: Urban Co-operative Banks - Business and Profitability

(Amount in Rs. crore)

 

Urban co-operative banks

Of which
Scheduled urban co-operative banks

Year (end-March)

2005

2006

2007

2008

2005

2006

2007

2008

1

2

3

4

5

6

7

8

9

Number

1,872

1,853

1,813

1,770

55

55

53

53

Deposits

1,05,021

1,14,060

1,21,391

1,38,496

40,950

45,297

51,173

57,916

Loans & advances

66,874

71,641

79,733

88,981

25,061

27,960

32,809

35,619

Total assets

132,145

1,50,954

1,61,452

1,79,421

56,217

64,702

72,085

79,318

CRAR

       

12.7

12.7

11.4

11.9

Gross NPA ratio

23.2

18.9

18.3

16.4

24.8

21.1

17.7

14.2

(per cent)

               

RoA (per cent)

NA

NA

0.7

0.6

0.3

0.7

0.7

0.7

Cost income ratio

-

-

-

-

66.5

55.9

58.9

56.2

(per cent)

               

Provisional data based on OSS returns submitted by banks;
Source: RBI.

 

To optimise supervisory resources28 and focus on the weaker banks, the UCBs are classified into four grades, i.e. I to IV, with higher grades reflecting increasing supervisory concerns. Between 2005-08, there has been a decline in the proportion of banks in grades III and IV (i.e. weak / sick banks).

A Vision Document has been prepared for the sector, which proposes a state-specific strategy. As envisaged in the document, Memorandum of Understanding (MoU) have been entered into between the Reserve Bank and most of the State Governments, whereby a Task Force for UCBs has been constituted in these states to suggest revival plans for potentially viable banks and a non-disruptive exit for unviable ones.

MOU has also been entered into with the Central Government in respect of multi state UCBs. The MOU arrangement currently encompasses around 98.7 per cent of the banks and 99.3 per cent of the business. As a part of the process of consolidation of this sector, transparent and objective guidelines on mergers of UCBs were issued in February 2005. Consequently 65 mergers have been effected till end-January 2009.

Given the special features of UCBs in terms of their size, and the nature of their operations, some of the BCPs are not strictly applicable to UCBs. However, being banks, they are a part of the payments and settlement system and could have a significant contagion impact on financial stability. In view of this an assessment of the adherence to BCPs in regulating/supervising UCBs was attempted by the Advisory Panel on Financial Regulation and Supervision. This revealed that four principles were compliant, eleven were largely compliant, four were materially non-compliant and two principles were not compliant. Some of the principles, such as those relating to the transfer of significant ownership, country risk, consolidated supervision and home host relationship are not applicable to UCBs. The assessment reveals that significant gaps in the adherence to principles relating to management of market risk, operational risk, liquidity risk, as also internal control exist.

2.4.1. (a) Financial Soundness Indicators

A trend analysis of select financial soundness indicators for the scheduled UCBs is depicted in the following chart 2.9.

As compared to March 2007, there has been marginal improvement in the average CRAR at end March 2008. The leverage ratio (banks assets to capital) is hovering around 16 -17. NPA ratios are showing a declining trend. But they are much higher compared to commercial banks. The gross NPA ratio, at around 14 per cent, throws up some concerns. The profitability of UCBs is low as evident from the low RoA and high cost-income ratio of the sector.

2.4.1. (b) Stress Test of Credit Risk

A stress test on 52 scheduled UCBs, accounting for 43 per cent of the total assets of the sector, was carried out by increasing the provisioning requirement and subjecting the credit portfolio to shocks of 25 per cent and 50 per cent increase in NPAs (Annex 2.2). The test revealed that for a 25 per cent shock, at end

 
28 Reference III.6.2
 
12
 

March 2007, 27 banks (accounting for 38 per cent of scheduled UCBs assets and 16.5 per cent of urban co-operative banking assets) would not be able to comply with the 9 per cent CRAR norm (Table 2.29). Similarly, for a 50 per cent shock, 31 banks would be affected. At the system level, the CRAR would decline from 11.4 per cent to 5.56 per cent at 25 per cent stress and 2.8 per cent at 50 per cent consequent to the stress test, pointing to the fragility of this segment.

2.4.2 Rural Co-operative Banks

India has a broad range of rural financial service providers, which includes formal sector

 

Table 2.29: Number of Scheduled UCBs Defaulting on CRAR Maintenance

CRAR (per cent)

 

Before stress

After stress

25 per cent

50 per cent

25 per cent

50 per cent

1

2

3

4

5

Negative

9

9

14

19

[0, 3)

1

1

5

2

[3, 4.5)

-

-

-

1

[4.5, 7.5)

1

1

6

6

[7.5, 9)

-

-

2

3

Total

11

11

27

31

Source : RBI

 

financial institutions at one end of the spectrum, informal providers at the other end, and between these two extremes, a large number of semi-formal providers. The formal providers include banks (rural and semi-urban branches of commercial banks, regional rural banks and rural co-operative banks) as also PACS. The semi-formal sector comprises of Self-Help Groups (primarily, the SHG-Bank linkage) and Micro Finance Institutions (MFIs). The informal providers comprise of a large number of players – professional moneylenders, traders, etc.

The rural co-operative institutions29 are beset with problems. The co-operative institutions have a low resource base, inadequate business diversification and recoveries, high levels of accumulated losses, weak management information systems (MIS) and poor internal controls. About a quarter of DCCBs(26 per cent) and 13 per cent of StCBs were unprofitable at end-2007. Of the long-term credit providers, about 40 per cent of SCARDBs and 50 per cent of PCARDBs were unprofitable during the same period. The total accumulated losses of the long and short-term co-operative credit structure (excluding PACS) amounted to Rs.9,917 crore at end-March 2007. The financial performance of rural co-operative banks (short-term structure) is given in Table 2.30.

Like the short-term institutions, the long-term rural co-operative institutions are also plagued by low profitability and high non-performing loans (Table 2.31). Given their low resource base, they (SCARDBs) are almost totally dependent on NABARD refinance. Compounding the problem is the low recovery performance and its declining trend.

StCBs and DCCBs are an important part of the financial system in India providing need based quality-banking services, essentially to the middle and lower middle classes and marginalised sections of the society. Basel norms have not yet been made applicable to the StCBs and DCCBs. The assessment of the BCPs by the Advisory Panel on Financial Regulation and Supervision has therefore been conducted keeping in view the ground realities in the rural financial sector. The assessment indicates that, three principles are compliant, ten are largely
 
29 These institutions are typically classified into the short-term and long-term structure. The former comprises of State co-operative banks (StCBs), District Central Co-operative Banks (DCCBs) and Primary Agricultural Credit Societies (PACS); the long-term structure includes State Co-operative Agriculture and Rural Development Banks (SCARDBs) and Primary Co-operative Agriculture and Rural Development Banks (PCARDBs).
 

Table 2.30: Performance of Rural Co-operative Banks (Short-term Structure)

Position as at end-March

(Amount in Rs. crore, ratios in per cent)

Item

StCBs

DCCBs

PACS

 

2005

2006

2007

2005

2006

2007

2005

2006

2007

1

2

3

4

5

6

7

8

9

10

Number*

31

31

31

367

366

371

109

106

97

Deposits

44,316

45,405

48,560

82,098

87,532

94,529

18,976

19,561

23,484

Loans outstanding

37,346

39,684

47,354

73,091

79,202

89,038

48,787

51,779

58,620

Net Profit

291

378

275

974

203

30

(-)1,261

(-)857

(-)1,653

Total asset

71,806

76,481

85,756

1,33,331

1,43,090

1,58,894

75,407&

73,387&

79,959

Net profit/total asset

0.41

0.49

0.32

0.73

0.14

0.02

(-)1.67

(-)0.12

(-)2.07

(per cent)

                 

Non-performing loan@

6,073

6,360

6,704

14,520

15,712

16,495

16,052

15,476

11,558

Non-performing loans/#

                 

Total loans (per cent)

16.3

16.0

14.2

19.9

19.8

18.5

33.6

30.4

26.9

NA : Not available;
* : For PACS, number in thousands;
@ : For PACS, figures relate to Overdues;
# : For PACS, figures relate to Overdues/Loans outstanding;
& : For PACS, figures relate to working capital;
Source: RBI and NABARD

 

compliant, six are materially non-compliant and two are non-compliant. Some of the principles like those relating to transfer of significant ownership, country risk, consolidated supervision and home-host relationship are not applicable. The major gaps in adherence are observed in respect of capital adequacy and risk management.

Given the need for strengthening the rural co-operative credit institutions, a Task Force was constituted by the Government in August 2004 to recommend an implementable action plan for their revival. In its Report on the short-term co-operative credit institutions, the Task Force recommended the provision of liberal financial assistance to the ailing co-operatives,

 

Table 2.31: Performance of Rural Co-operative Banks (Long-term Structure)

Position as at end-March

(Amount in Rs. crore, ratios in per cent)

Item

SCARDBs

PCARDBs

 

2005

2006

2007

2005

2006

2007

1

2

3

4

5

6

7

Number

20

20

20

727

696

697

Share capital

791

801

794

920

922

918

Reserves

2,165

2,354

2,137

2,196

2,665

2,678

Deposits

608

636

605

364

382

341

Borrowings

17,182

17,075

16,662

12,750

13,066

12,751

Loan outstanding

17,403

17,713

18,644

12,622

12,740

12,114

Total asset

24,271

24,604

24,336

20,413

21,365

21,774

Net profit

(-)163

262

89

359

(-)109

(-)147

Net profit/total asset

(-)0.7

1.1

0.4

1.8

(-)0.5

(-)0.7

Non-performing assets (NPAs)

5,437

5,779

5,643

4,056

4,586

4,316

NPAs/ total loans

31.2

32.7

30.3

32.1

35.6

35.4

Source: RBI and NABARD

 

subject to certain legal and institutional reforms in the sector. Based on consultations with State Governments and other feedback received, an estimated outlay of Rs.13,600 crore was provided for the purpose. Financial assistance under the package, including a cleansing of the balance sheets, capital infusion to ensure a CRAR of 7 per cent, technical support for building up a common accounting and internal control system, computerisation and capacity-building were made contingent upon certain legal and institutional reforms relating to the co-operative credit structure. Implementation and Monitoring Committees at the national, state and district levels have been constituted to oversee the restructuring exercise. The Government has constituted a National Implementing and Monitoring Committee while NABARD has constituted state-level Task Forces. NABARD is the implementing agency for the purpose. Until November 2008, 25 State Governments had executed MoUs with the Government and NABARD for implementing the revival package.

On its part, the Government has been making concerted efforts over the last few years to strengthen the co-operative sector. Beginning 2004, budget allocations have been made for grants through NABARD to incentivise State Governments and co-operative institutions to adopt reform measures for strengthening the co-operative credit structure. Until 2006, Rs.602 crore had been allotted to NABARD. The Union Budget 2006-07 has earmarked Rs.1,500 crore for this purpose.

The Task Force was also asked by the Government to make suggestions for the revival of the long-term co-operative credit institutions.

The Report was submitted to the Government in August 2006. The Government has since circulated the Report to all states and Union Territories. Based on the deliberations with the State Governments, the package is being finalised by the Central Government.

2.5 The Broader Financial Sector

The broader financial sector comprises development financial institutions, non-banking financial companies, the non-financial sector, including corporates and households and the housing finance companies.

2.5.1 Non-banking Finance Companies

Non-banking finance companies (NBFCs) have become an integral part of the financial system in India, playing a crucial role in broadening access to financial services, enhancing competition and bringing in greater diversification of the financial sector which also enables risk diversification in the system. Their growth has been supported by the following factors:

• They constitute an important avenue for private initiative and innovation in the Indian financial system.

• The diversification of the economy, the growth in infrastructure development related activities, and the rise in middle class consumerism.

• They have shown great flexibility in meeting the increasingly complex financial needs of India’s growing economy.

Deposit-taking NBFCs (NBFCs-D) witnessed rapid growth in the mid-1990s, but, growth has since slowed down because of the introduction of strict entry and prudential norms, the prescription of ceiling rate of interest on deposits that can be offered by these entities and the process of obtaining a Certificate of Registration (CoR) by these NBFCs. In spite of a slowdown in NBFCs-D, there has since been a resurgence of this sector, primarily because of high growth recorded in the NBFC-ND (non-deposit-taking) segment, which has emerged as the most dominant component of the NBFC segment in recent times.

Out of 364 deposit-taking NBFCs, 335 (including 2 Residuary Non-Banking Companies or RNBCs) filed annual returns for the year ended March 2008, with total asset of Rs. 94,744 crore and public deposits of Rs.24,395 crore (Table 2.32). RNBCs is a separate sub-set of deposit-taking NBFCs, allowed to accept deposits with no ceiling on quantum of deposits as a multiple of net owned fund (NoF), unlike other deposit-taking NBFCs. Hence, RNBCs cannot be compared with other NBFCs.

The RNBC segment accounts for over 90 per cent of public deposits with high gearing ratios, defined as public deposits as a multiple of NoF(Table 2.32). However, this cannot be considered a matter for concern as RNBCs have no freedom for investments and are not permitted discretionary investment against the aggregate liability to depositors. RNBCs are required to invest 100 per cent of their Aggregate Liability towards Depositors (ALD) in directed investments:

• investments in unencumbered approved securities like securities issued by the Central and State Government,

• fixed deposits / certificates of deposits of SCBs and CDs of specified financial institutions, provided the CDs are rated not less than AA+ or its equivalent by an approved credit rating agency,

• bonds and debentures of any company incorporated under Companies Act, 1956 which have a minimum credit rating of not less than AA+ or equivalent by an approved credit rating agency and listed on a recognised stock exchange and

• debt oriented mutual funds subject to the condition that not more than two per cent of the ALD shall be invested in any one mutual fund and the aggregate of such investment shall not exceed 10 per cent of the ALD.

Although the interest rate paid by NBFCs-D on their public deposits has been high in comparison to that payable by banks (the ceiling interest rate is capped at 12.5 per cent with effect from April 24, 2007), 73 per cent of public deposits bear interest rates not exceeding 10 per cent; the maturity profile has been evenly distributed, with roughly 30 per cent being at the shorter end of the maturity spectrum (1 year) (Table 2.33). On account of the spread (difference between ceiling interest rate on NBFC deposits and the maximum rate on bank deposits of 1-5 years maturity by PSBs), a concern regarding the risk-premium on NBFC deposits vis-à-vis banks, given their low NoF requirement, may arise.

 

Table 2.32: Profile of NBFC-D/RNBC Segment

Position as at end-March

(Amount in Rs. crore)

Institution

NBFCs

RNBCs

 

2005*

2006

2007

2008

2005

2006

2007

2008

1

2

3

4

5

6

7

8

9

Reporting numbers

703

435

362

335

3

3

3

2

NoF

5,036

6,494

6,921

10,547

1,065

1,183

1,366

1,714

Public deposits

3,926

2,448

2,077

2,037

16,600

20,175

22,622

22,358

Public deposit/NoF

0.8

0.4

0.3

0.2

15.6

17.1

16.6

13.0

Total Asset

36,003

37,828

48,553

70,292

19,056

21,891

23,172

24.452

* : Data for 2004-05 include MBCs, MBFCs and MNBCs besides NBFC-D, hence not comparable to the data for the years 2005-06 and 2006-07.
Note : NoF: Net owned funds
Source: RBI

 
 

In reality, though the NoF requirement in case of NBFCs is low compared to banks, NBFCs, especially deposit-taking ones, have to maintain higher CRAR ranging from 12-15 per cent, which is substantially higher than banks. It may also be mentioned that minimum Net Owned Funds (NoF) of Rupees two crore (with effect from April 21, 1999) is only an entry point norm and the accretion to reserve fund under Section 45-IC of the Reserve Bank Act has helped NBFCs to increase their NoF over time. Even non-deposit-taking NBFCs with an asset size of Rs.100 crore and above have to maintain a CRAR of 10 per cent, a notch above 9 per cent requirement in case of banks.

The asset quality of NBFCs-D reveals that their gross NPA to gross loans ratio has declined over the period. The overall ratio was 1.5 per cent at end March 2008 (Table 2.34).

Capital adequacy ratios of the NBFCs-D are high at 22.4 per cent as at end March 2008. At end March 2008, 44 NBFCs had CRAR ratios less than the stipulated minimum of 12 per cent, up from 20 the year earlier. Of the 167 asset finance companies (the segment with the majority of public deposits), 147 had a CRAR in excess of the stipulated levels; 115 (or 69 per cent) had CRAR ratios of 30 per cent and above.

The NBFC sector is less closely regulated and supervised than the banks and not all Basel Core Principles (BCPs) can be made applicable to it. Further, the BCPs are not applicable to a significant proportion of these entities as they are very small in size and do not strictly conduct banking operations. Though NBFCs are not part of the payments and settlement system like banks, they provide some financial services that are similar to that of banks. Therefore, an assessment of the adherence to BCPs in respect of regulation and supervision of NBFCs under the broad categories was attempted by the

 

Table 2.33:Public Deposits According to Interest Rate and Maturity of NBFCs-D

Year

Interest rates (in per cent)

Maturity (in years)

Total deposits (Rs. crore)

Upto 10

10-12

Above 12

Less than 1

1-2

Exceeding 2

1

2

3

4

5

6

7

8

2004-05*

68.7

21.7

9.6

30.8

24.0

45.2

3,926

2005-06

83.6

13.0

3.4

35.9

26.5

37.6

2,447

2006-07

88.5

9.7

1.7

34.9

23.0

42.1

2,077

2007-08

73.1

25.4

1.5

29.9

23.6

46.5

2,038

* : Data for 2004-05 include MBCs, MBFCs and MNBCs besides NBFC-D, hence not comparable to the data for the years 2005-06 and 2006-07.
Source: RBI.

 

Table 2.34: Public Deposits and NPAs Across Different Classes of NBFCs-D

 

AFC@

EL

HP

LC

IC

Others

Total

1

2

3

4

5

6

7

8

Public deposits (per cent)

             

2004-05

..

8.7

61.7

5.2

2.4

22.0

100.0

2005-06

..

6.7

83.2

6.8

3.3

..

100.0

2006-07

9.0

2.1

81.0

5.6

2.2

0.1

100.0

2007-08

56.7

0.4

26.2

15.8

0.9

..

100.0

Gross NPA/

           

Overall

Gross advances (per cent)

           

ratio %

2004-05

..

12.3

3.8

6.0

18.0

..

5.7

2005-06

..

2.4

2.5

36.5

0.4

..

3.6

2006-07

2.2

4.2

2.5

1.6

2.8

..

2.2

2007-08

1.8

24.3

29.2

0.2

..

..

1.5

@ : Companies financing real/physical assets for productive/ economic activities are re-classified as Asset Finance Companies (AFCs). This revised classification became effective since December 2006.
EL : equipment leasing;
HP : hire purchase;
LC : loan companies;
IC : investment companies
* : Data for 2004-05 includes MBCs, MBFCs and MNBCs besides NBFC-D, hence not comparable to the data for the years 2005-06 and 2006-07.
Source: RBI

 

Advisory Panel on Financial Regulation and Supervision. Out of the 24 Core Principles applicable to NBFCs, they were observed to be compliant/ largely compliant in respect of 14 Principles and materially non-compliant /non-compliant in respect of 10, which relate primarily to risk management, ownership and control and home host relationship.

Given the growing similarity in the business of banks and deposit-taking NBFCs, especially on the asset side and in view of the differential regulatory and cost-incentive structure across these two sets of institutions, it became imperative to establish certain checks and balances to ensure that bank depositors are not directly exposed to the risks of a different cost-incentive structure. Furthermore, some regulatory gaps in the area of bank vis-à-vis NBFC operations may contribute to creating the possibility of regulatory arbitrage, giving rise to an uneven playing field and some concerns of systemic risk. In view of these concerns, the regulatory framework for systemically important (non-deposit taking) NBFCs (NBFCs-ND-SI) was modified. The basic framework for classifying such NBFCs was based on their asset size.30 These NBFCs have also to comply with various prudential regulations, viz., capital adequacy ratio, exposures and credit/ investment concentration norms.

The NBFCs-ND-SI is the fastest growing segment in the NBFC sector. It grew at a rate of 28.6 per cent between 2007 and 2008. A profile of balance sheet and income positions reveals that in aggregate, NBFCs-ND-SI have a significant exposure to the capital market which accounted for more than 25 per cent of their asset base at end March 2008. More specifically, capital market exposures as at end March 2008 have been 67.8 per cent, 33.3 per cent and less than 1 per cent of total assets for investment NBFCs-ND-SI, all NBFCs-ND-SI and deposit-taking NBFCs with asset size of Rs.100 crore and above, respectively. Dependence on bank borrowings

 

30 NBFCs with asset size of Rs.100 crore and above as per their latest audited balance sheet were considered has NBFCs-ND-SI.

 

as sources of funds of NBFCs-ND-SI has been declining over the period in comparison to that of debentures. Though, Capital Market Exposure as a percentage of total liabilities appears to be high, it is restricted to Investment Companies. The bank borrowings of the Investment NBFCs-ND-SI was at Rs.10,845 crore. CME constituted 248 per cent of the bank borrowings, indicating that dependence of CME on bank borrowings of such companies cannot be considered as significant.

From the sources of funds at end March 2008, unsecured borrowings constitute a significant portion (36.8 per cent) of sources of funds (total liabilities) and 55.4 per cent of the total borrowings of NBFCs-ND-SI (Table 2.35). Of this, bank borrowings (secured as well as unsecured) constituted 26.5 per cent of their total borrowings as on the same date. Unsecured bank borrowings constituted 17 per cent of total borrowings during the same period. Unsecured debentures constituted 16.4 per cent of total borrowings of NBFCs-ND-SI as at end March 2008. Secured debentures also constituted 16.4 per cent of the total borrowings of the NBFCs-ND-SI as at end-March 2008.

Unlike banks, NBFCs do not have access to low cost deposits. NBFCs are therefore much more dependent on borrowing especially, the non-deposit taking NBFCs. Of the borrowings, significant portion is unsecured, which other than cost implications, could also have a huge systemic impact if the NBFCs go bankrupt. In this context therefore, in order to reduce

 

Table 2.35: Profile of Systemically Important Non-Deposit Taking NBFCs

(Amount in Rs. crore)

Year/ Item

March 2006

March 2007

March 2008

1

2

3

4

Source of funds

     

Secured borrowings

71,509

93,765

1,21,082

of which: Debentures

39,179

32,564

44,439

Bank borrowings

16,116

19,503

25,774

Unsecured borrowings

1,03,086

1,18,221

1,50,206

of which: Loans from banks

28,276

33,191

46,243

Inter-corporate deposits

19,459

20,018

22,019

Debentures

20,788

30,549

44,432

Use of funds

     

Total loans

1,68,728

2,12,667

2,78,632

of which: Secured loans

63,120

1,14,898

1,60,017

Unsecured loans

82,996

69,609

88,783

Capital market exposure

59,583

81,435

1,11,630

Total Asset/Liabilities

2,50,765

3,17,898

4,08,705

Net profit

4,301 (1.7)

7,460 (2.3)

8,705 (2.1)

Gross NPAs/Total credit exposure ( per cent)

7.0

4.9

3.1

Note : Figures in brackets are percent to total asset
Source: RBI

 

systemic liability arising out of exposures to unsecured borrowings from NBFCs, there is an immediate requirement to develop the corporate bond market which could be a source of funds to NBFCs. The Panel therefore feels that while capping of bank lending to NBFCs has a prudential objective, there is an urgent need to develop an active corporate bond market so that these entities have alternative financing sources to enable their growth without disrupting systemic stability.

2.5.2 Development Finance Institutions (DFIs)

DFIs which were designed to provide long-term finance to industry, have gradually shrunk, with some of the large all-India finance institutions (term-lending and refinance institutions) having amalgamated with their banking counterparts over the last few years. Some of the FIs have been reclassified as systemically important non deposit-taking NBFCs.31 Their outstanding loans increased from Rs.85,151 crore as at end March 2005 to Rs.1,44,692 crore by end March 2008. With the economic upturn over the past few years, there has been an improvement in the asset quality as seen from the decline in NPA ratios as well as their absolute levels (Table 2.36). These numbers need to be viewed in the light of the fact that income recognition and asset classification for DFIs have, only recently, been made on par with those for banks.32

 

Table 2.36: Select Indicators of DFIs

Year

2005-06

2006-07

2007-08

1

2

3

4

I. Increase/ decrease (-)

     

Loans and advances

24.8

20.5

16.9

Gross NPAs

(-)12.2

(-)26.1

(-)27.4

Net NPAs

(-)29.0

(-)56.2

(-)5.6

II. Key ratios

     

Gross NPA ratio

1.3

0.8

0.5

Net NPA ratio

0.9

0.1

0.1

III. Weighted average cost

     

TFCI

10.1

9.9

..

SIDBI

5.9

6.9

8.2

EXIM Bank

6.9

7.8

8.2

NABARD

5.8

8.7

9.5

NHB

6.4

7.4

7.7

IV. Weighted average maturity

     

TFCI

5.2

4.3

..

SIDBI

3.9

6.5

1.0

EXIM Bank

4.6

3.7

3.0

NABARD

3.5

5.0

4.0

NHB

2.2

2.4

2.8

Note : Under (I), the reported numbers are percentage change over the previous year.
Data for 2005-06, 2006-07 and 2007-08 (I and II) includes only four DFIs (SIDBI, NABARD, NHB & EXIM
Bank) currently being regulated by RBI.
Source: RBI

 

31 IIBI is in process of voluntary winding up. IFCI and IDFC are presently regulated as systemically important non deposit-taking NBFC. TFCI is being regulated as a NBFC.

32 For DFIs, with effect from end-March 2006, an asset would be classified as non-performing if the interest and/or instalment of principal remain overdue for more than 90 days. DFIs would have the option to phase out the additional provisioning required for moving over to the 90-day income recognition norm over a period of three years beginning from the year ending March 31, 2006, subject to at least one fourth of the additional provisioning being made in each
year.

 

In keeping with the increase in interest rates during 2004-07, there has been an increase in the cost of borrowings of DFIs. But it is lower than the levels seen in early 2000. Though DFIs are required to fund themselves with initial maturities of over one year, their long-term nature of loan portfolio can entail a term mismatch. Illustratively, the weighted average maturity of the rupee resources of DFIs has declined significantly over the past few years from an average of over six years to less than four years. The change in the operating environment coupled with increased competition and availability of alternative modes of finance to the corporates and organisational restructuring being faced by these institutions, inter alia, have led to the declining share of business of the financial institutions.

The aggregate CRAR of DFIs stood at 25.6 per cent at end March 2008 (Table 2.37). All reporting institutions adhered to the stipulated minimum CRAR requirements. Gross NPA ratio declined significantly from 1.3 per cent to 0.5 per cent between March 2006 and March 2008. Reflecting the combined effect of better recovery management and improved provisioning, net NPAs witnessed a sharp decline and stood at 0.1 per cent at end March 2008.

2.5.3 Housing Finance Companies (HFCs)

The real estate sector has been experiencing a credit boom in recent years. Housing loans outstanding as at end March 2006 which were to the tune of Rs.2,72,600 crore, increased to Rs.3,10,755 crore as at end March 2007 and further to Rs.3,50,957 crore as at end March 2008. Outstanding housing loans however, constituted only 7.4 per cent of GDP (2007-08).

The entry of banks in the housing finance business resulted in a rapid expansion of the market. While the HFCs also witnessed an increase in their business (aggregate housing finance disbursed was Rs.46,164 crore during 2007-08), banks garnered the larger share of this market due to their lower cost of funds and

 

Table 2.37: Profile of DFIs

(Amount in Rs. Crore)

Item

2005-06

2006-07

2007-08

1

2

3

4

Income

7,562

9,073

11,541

Expenditure

5,489

6,895

8,707

Tax provision

588

632

936

Operating profit

2,073

2,178

2,834

Net profit

1,484

1,546

1,898

Total assets

1,27,686

1,48,787

1,77,765

Net profit/Total asset ( per cent)

1.16

1.04

1.07

CRAR ( per cent)

30.7

25.9

25.6

CRAR (below 12 per cent)

nil

nil

nil

Note : Data for 2005-06 and 2006-07 includes only four DFIs (SIDBI, NABARD, NHB & EXIM Bank) currently being regulated by RBI.
Source: RBI

 
 

wider distribution network. Notwithstanding this, an analysis of HFCs assumes importance, because changes in the volumes of lending and property prices could have a bearing on credit quality and collateral. For the purpose of analysis, 12 (out of the 43 registered with National Housing Bank) HFCs were chosen.33

Although the BCPs are not strictly applicable to HFCs, an attempt was made by the Advisory Panel on Financial Regulation and Supervision to assess the relevance of these Principles to HFCs, as appropriate. The assessment indicated that they are compliant/ largely compliant in respect of 12 of the 25 Principles. Assessed areas of material non-compliance relate to permissible activities, risk management process, exposure to related parties and home-host relationships.

2.5.3. (a) Capital Adequacy

The prescribed minimum Net Owned Fund (tier-I capital) for HFCs to commence or carry on the business of a housing finance institution is Rs. two crore. All the selected HFCs complied with these minimum numbers.

The prescribed minimum CRAR for HFCs is 12 per cent. On an average, HFCs have been able to maintain a CRAR well above the prescribed levels, with an overwhelming portion comprising core capital (Table 2.38). The ratio of tier-I capital to risk-weighted assets increased between 2004 and 2008. This is inspite of the increased risk weights in individual housing loans from 50 per cent to 75 per cent with effect from October 2005. The improvement in the ratio of tier-I capital to risk-weighted assets continued during 2007-08. This is a manifestation of the lowering of risk-weight applicable to individual housing loans up to Rs.20 lakh, from 75 per cent to 50 per cent with effect from July 2007. This is also reflected in the increase in the ratios of tier I capital to total assets during 2007-08.

The ratio of tier II capital to risk weighted assets showed a sudden jump for the year ended March 2006 due to issue of Foreign Currency Convertible Bonds (FCCBs) by a leading HFC. Subsequently, almost 78 per cent of these FCCBs got converted into equity, resulting in a drop in tier II ratio and an increase in the tier I ratio in 2006-07.

A significant aspect of HFCs is their leveraged positions. As per regulatory prescriptions, a ceiling of 16 times of NoF for borrowings is mandated for them.34 Over the period March 2004 to March 2006, the ratio has shown steady increase from 8.25 to 9.38. The increase in tier II Capital (a debt component) between 2004 and 2006 appears to have contributed to the increase in this ratio. However, the same has declined to 6.58 for the period ending March 2008.

 

Table 2.38 Average Ratios on Capital Adequacy - HFCs

(Ratios in per cent)

Parameter

2004

2005

2006

2007

2008

1

2

3

4

5

6

Total capital funds (tier-I and tier-II)/

         

Risk weighted assets

15.0

16.2

17.8

16.8

18.1

Tier-I capital/ Risk weighted assets

14.0

14.7

12.4

15.3

15.8

Tier-I capital/ Total assets

10.3

9.9

9.2

10.0

10.4

Tier-II capital/Risk weighted assets

0.9

1.6

5.4

1.5

2.3

Note : figures as at end-March.
Source: NHB

 

33 Based on their asset size at end-June 2006. These HFCs account for roughly 97 per cent of the outstanding housing
loans, 99 per cent of the public deposits and 98 per cent of the total borrowings of the sector. The analysis is based on
statutory returns submitted by the HFCs.

34 This ratio indicates borrowings leveraged by the institution vis-à-vis their tier-I capital.

 

Table 2.39: Ratios on Asset Quality-HFCs

(Ratios in per cent)

Category

2004

2005

2006

2007

2008

1

2

3

4

5

6

Gross NPAs/ Gross loans

3.6

6.2

4.5

1.7

2.2

Net NPAs/ Net loans

2.0

4.4

3.1

1.2

1.6

Net NPAs/ Tier-I capital

16.5

37.5

28.9

7.7

7.8

Note : figures as at end-March
Source: NHB

 

2.5.3. (b) Asset Quality

The asset quality of housing loans is an area of concern, especially in a regime of rapid credit growth, given the evidence of asset impairment in periods of economic downturn. The data for HFCs, however, indicate that these ratios are still moderate (Table 2.39). The spurt during 2004-05 was more on account of the introduction of 90-day norm for asset classification norms with effect from end March, 2005 (Chart 2.10).

2.5.3. (c) Earnings and Profitability

The marginal declining trend of the Return on Assets (RoA) particularly during 2005-06 in the wake of increased competition and volume building has shown an upturn during 2007 and 2008. The sector exhibits high potential as seen from the increasing levels of the interest margin to gross income ratio. The growing demand for housing has prompted HFCs to assume more debt and thereby increase their balance sheet size. Though the HFCs are comfortably placed in terms of liquidity as indicated by their current ratio, the declining trend since 2006 indicates a growing concern (Table 2.40).

While the CAGR of housing loans has been around 33 per cent between 2003 and

 
13
 

Table 2.40 : Ratios on Earnings and Profitability - HFCs

(Ratios in per cent)

Indicators

2003-04

2004-05

2005-06

2006-07

2007-08

1

2

3

4

5

6

Return on assets

1.9

1.9

1.8

1.99

2.23

Return on Tier-I capital

18.3

19.2

19.3

19.83

17.71

Interest margin to gross income

25.1

28.0

26.2

28.92

34.16

Non-interest expense to gross income

11.1

12.1

10.1

8.11

7.37

Current ratio

1.77

1.73

1.83

1.41

1.15

Note : figures as at end-March
Source: NHB

 

2006, the growth in household income in the corresponding period has been 20 per cent35. This, coupled with the increase in interest rates, has led to an increase in the household debt burdens and elongation of repayment periods, raising concerns of loan delinquency.

2.5.3. (d) Housing Price Index

Most countries employ house prices as part of their assessment of the asset-price channel of monetary policy. In the Indian context, owing to non-availability of systematic data on house prices, gauging the impact of activity in this segment is a challenging task. To overcome this deficiency, a Technical Advisory Group (TAG) had been constituted by the National Housing Bank (NHB) for the construction of a national Housing Price Index. Based on its recommendation, NHB has developed a housing price index for five cities viz., Mumbai, Bhopal, Bangalore, Delhi and Kolkata. Over time, it is expected to cover 63 cities with population more than one million. However to make an assessment of the risks associated with the housing growth a national loan to value (LTV) ratio is required. Due to the non-availability of a nation-wide housing price index, an accurate estimate of the LTV ratio is difficult. The Panel therefore recommends that the work related to the construction of a national housing price index be taken up on priority basis. It should be supplemented by a house start-up index to provide insights on the elasticity of property supply to property prices as well as the cost of housing credit. The Panel recommends that the report of the TAG set up by the Reserve Bank for the purpose of constructing the housing start up index requires to be submitted early.Annex 2.6: House Price Index and Housing Starts).

2.5.4 Non-Financial Sectors

The quality of assets and performance of financial institutions depend directly on borrowers’ capacity to repay. The non-financial sector, therefore, is the counterpart of the financial sector in a myriad of transactions, and could become a source of risk. This makes it necessary for central banks to monitor and analyse the financial strength of corporate borrowers. A second reason for monitoring the non-financial sector is that the dividing line between the financial and non-financial sector has become increasingly blurred. The evolution of the credit risk transfer market, for example, has facilitated shifts in credit risk between the financial and non-financial sectors. The two major components of the non-financial sector are the corporate and the household sectors.

2.5.4. (a) Corporate Sector

The manufacturing sector had witnessed a significant improvement in financial performance during the period between 2003-04 and 2006-07. Return on equity for public limited companies increased significantly to

 

35 Source - CRISIL

 
19.8 per cent in 2006 -07 from 13.7 per cent in 2003-04. Also for private limited companies, it has increased to 16.3 per cent in 2005-06 from 14.8 per cent in 2003-04. The profit margin (gross profits to sales) for public limited companies in the year 2006-07 was the highest in the recent past. This robust economic activity, and the decline in debt servicing, are the two important factors driving the high profitability levels (Table 2.41).

For public limited companies, the debt-equity ratio has declined, a fall-out of a lesser reliance on borrowed funds; for private companies, there has been a marginal rise, although the ratios were much lower than public companies. With the reduced dependence on borrowed funds, interest outgo declined, lowering its share in total expenditure for both public and private companies. Companies have been maintaining a current ratio (current assets to current liabilities) in excess of one, indicating their ability to meet their current obligations.

Primarily on account of the sustained moderation in inflation till the end of 2007, nominal interest rate was not high. This resulted in substantial fall in debt servicing costs. Given that borrowing costs for larger corporates have fallen in recent years, profits for these companies have surged. Combined with rising economic activity, the average growth of profits was 45.8 per cent during 2003-04 to 2006-07, raising returns on equity to well above the overall cost of capital. Mainly driven by the up-trend in the investment cycle since 2003-04, firms retained a higher proportion of profits, which as the share of profits increased from 62.6 per cent in 2003-04 to 79.5 per cent in 2006-07. Improved internal funds so generated led to the increase in overall equity capital.

 

Table 2.41 : Indicators of Financial Stability in Manufacturing

(Ratios in per cent)

Item / Year

2003-04

2004-05

2005-06

2006-07

Public

Private

Public

Private

Public

Private

Public

Private

1

2

3

4

5

6

7

8

9

Debt equity ratio

62.2

14.5

52.8

22.1

47.7

20.8

48.4

NA

Return on equity

13.7

14.9

17.6

14.3

17.7

16.3

19.8

NA

Interest coverage ratio (times)

               

(Gross Profit/Interest payments)

3.2

6.7

4.5

7.0

5.3

7.4

6.2

NA

Interest payments/Total

               

expenditure

3.6

1.3

2.8

1.1

2.3

1.2

2.3

NA

Gross profit/Sales

10.9

8.4

11.8

7.8

11.8

8.4

13.2

NA

Sales / gross fixed asset

116.3

267.4

130.4

295.2

131.4

304.4

141.7

NA

Profits retained / Profits after tax

62.6

76.7

71.4

79.4

74.4

85.5

79.5

NA

Current asset/current liabilities

               

(number of times)

1.0

1.40

1.0

1.40

1.1

1.40

1.2

NA

ICOR (number of times)

0.75

0.57

0.62

0.56

1.2

0.57

1.03

NA

Memo: Number of firms

1,693

785

1,693

785

2,263

785

2,263

NA

Source: RBI

 

Over time, the corporate tax rate in India has also witnessed a downward trend, from 45 per cent in 1992-93 to 30 per cent by 2005-06. Since then the rate has held fairly steady. The peak rate of customs duty on non-farm goods has also been brought down from 150 per cent in 1991-92 to 10 per cent in 2007-08. The declining tax rates took away to some extent the advantages generally associated with debt and at the same time increased the reliance of firms on equity finance. Restructuring of debt helped firms to retire expensive debt. Encouraged by the buoyant asset markets and valuations which tended upwards on account of large profits and lower debt levels on their balance sheet, firms raised funds with huge premia. Though debt and equity levels have been rising over the years, it is equity which has been rising much faster relative to the rise in debt, as reflected in declining debt-equity ratio.

However, there has been some moderation in sales and profits growth from 2007-08 and it has started impacting profitability. This could result in a lower generation of internal funds. Lately, there has also been a sharp correction in the valuations of listed firms. To that extent, there could be a reversal in the declining debt equity ratio. The sales performance of select non-government non-financial public limited companies in the private corporate sector during the first two quarters of 2008-09 showed improvement, however, profits performance was subdued as compared to 2008-09. This could further accentuate the increase in debt-equity ratio.

The private corporate sector has performed well during the period 2003-04 to 2006-07. An analysis by CRISIL among its rated companies indicate that the risk appetite of Indian corporates in the manufacturing and infrastructure sectors has increased as is evident in the growing number and size of acquisitions. This recent phenomenon has reversed the trend of steadily declining debt-equity ratio that was observed among Indian corporates between 2002 and 2007.

The total investments by Indian corporates in capacity expansion across sectors are expected to increase significantly. As per CRISIL, the total estimated investments for seven major industries (aluminium, automobiles, cement, oil and gas, petrochemical, steel and textiles) during the period between FY07 and FY11 is around Rs.6,29,500 crore, which is more than thrice the investments in these industries during the period between FY02 and FY06.

The aggressive growth plans of Indian corporates’ are also illustrated by a study of about 70 CRISIL-rated companies36 with a total turnover of Rs.2,60,000 crores. The study reveals that the total planned capital expenditure between FY08 and FY10 is expected to be nearly 1.4 times the aggregate net worth of the companies as on March 31, 2007. This is in comparison to a figure of 0.6 times for the period FY05 to FY07 (Table 2.42).

As per the study, a large part of these capacity expansions and acquisitions will be debt-funded which could add to credit quality pressure among Indian corporates. Increase in input costs, higher interest rates and wage inflation could add to the profitability pressures resulting in weakening in credit quality among Indian corporates. However, the default rates are not likely to increase significantly, as the balance sheet of the corporates have strengthened significantly due to healthy operating performance and minimal capital expenditure of most of these companies during the preceding five years.

 

Table 2.42 : Planned Capital Expenditure

(Rs. crore)

As on

Networth

Capital Expenditure during the next 3 years

Projected Capital Expenditure / Networth

1

2

3

4

March 31, 2004

86,150

51,740 (FY05-07)

0.60

March 31, 2007

1,45,860

2,04,970 (FY08-10)

1.41

Source: CRISIL Estimates

 

36 CRISIL ratings cover more than two thirds of manufacturing companies forming part of BSE Sensex. This study covers more than 50 per cent of these rated manufacturing companies.

The incremental capital output ratio (ICOR), defined as the ratio between incremental capital employed to incremental value of production, increased significantly to 1.03 in 2006-07 from 0.75 in 2003-04 for public limited companies. But it remained unchanged at 0.57 for private limited companies during the same period. The steep increase in ICOR for the former may be attributed partly to deployment of capital for creation of additional capacity.

2.5.4. (b) Unhedged Foreign Currency (FC) Exposure of Corporates

Indian corporates with foreign currency exposures (export, import, borrowings, equity issues, etc) are exposed to currency risk, unless natural hedges (revenue or other flows in foreign currency) are available. In the context of the appreciation of the rupee, it is observed that there is no incentive for the entities including exporters (exporters expect that rupee would depreciate) to hedge their exposures. Thus, the unhedged exposures had been increasing, leading to a systemic risk. This, in spite of, the policymakers increasingly expressing concern over the unhedged foreign currency exposures of corporates in view of its implications for financial stability in the event of unforeseen adverse conditions.

In view of such concerns, an attempt was made to arrive at some ballpark numbers on the unhedged foreign currency exposure of corporates. Based on an analysis on 32 companies out of the BSE top 100 in the manufacturing and infrastructure sectors, CRISIL found that, as on March 31, 2007:

• Total unhedged FC exposure of these companies of the order of Rs.51,000 crore

• Total net worth of these companies of the order of Rs.2,03,600 crore

• Total net profits of these companies of the order of Rs.46,600 crore

Therefore, for these 32 companies on aggregate, the unhedged FC exposure constituted about 25 per cent of their net worth and nearly 110 per cent of their net profits. In case the foreign currency were to appreciate / depreciate by, say 10 per cent, the resultant impact could be about 11 per cent on the net profits of these companies.

This analysis might not reflect the underlying position, as it seems likely that the natural hedges that are available to the corporates might not have been taken into account. As a result, the real risk being run by the corporates could be higher or lower, depending on the extent of the natural hedge available.37

 

37 In this set of 32 companies, four companies have the unhedged foreign currency exposure exceeding their net worth and six companies have their unhedged foreign currency exposures forming significantly more than 2 times the net profits reported in the previous year. This could be a pointer to the fact that for smaller companies, these numbers could be much higher and given their paucity of skills in managing foreign currency risks, the ability to manage the foreign currency movements might be limited in relation to the large companies.

 

While hedging or not hedging of currency exposure is a commercial decision, the impact of market risk triggered credit risk on the financials of banks is significant. It is therefore important that banks, for prudential reasons, be aware of and monitor the unhedged exposures of their clients and the impact on their asset quality. In view of this risk, banks have been encouraged to obtain information from their large borrowers on their unhedged foreign exchange exposures, so that they can assess the risk of their own exposure to such corporates on an on-going basis.

Similarly, while corporate profits have been healthy and leverage ratios are down, the monitoring of corporate leverage, particularly for SMEs and their foreign exchange mismatch has become necessary. Such reporting could be done as part of listed company disclosures and also such data could be captured for credit information to be shared amongst banks.

The Panel feels that a practical way forward could be a two-pronged strategy comprising a periodic survey by the Reserve Bank based on the returns collated by authorised dealers, supplemented with mandated disclosures in companies’ balance sheets, through ICAI.

2.5.4. (c) Household Sector

The absence of recent data in respect of household indebtedness is a serious concern. This shortcoming is all the more pronounced in view of the recent increase in the retail loan portfolio of the banks and the increasing housing demand. The Panel underscores the requirement to have recent system level data of household indebtedness as a major action point going forward.

The health of the household sector provides useful leads as to the overall health of the financial sector. At the all-India rural level, the available data suggests that in respect of two indicators of indebtedness, there has been a decline over time in indebtedness (Table 2.43).38 While the incidence of indebtedness appears to be lower, the debt-asset ratio is generally higher for urban than for rural areas.

The burden of debt is higher for the asset-poor households than for the asset-rich ones, as reflected in a monotonically declining debt-asset ratio with the size class of asset ownership (Table 2.44), which presents data for India, rural and urban households combined, in 2002-03).

Available evidence as per the results of the All-India Debt and Investment Survey 2002-03 indicates that 26.5 per cent of the rural households reported indebtedness to various agencies (either institutional or non-institutional). The comparable figure for urban households was 17.8 per cent (Table 2.45). Professional money-lenders emerged as the main non-institutional source of finance in both rural and urban areas. The average amount of debt per rural household which was Rs.1,906 in 1991-92 increased to Rs.7,539 in 2002-03, a four-fold increase. The corresponding figures for urban household for the two periods were Rs.3,618 and Rs.11,771, respectively.

 

Table 2.43: Indebtedness Over Time at All-India Level

(All figures in percentage terms)

Year

Rural

Urban

Proportion of household indebted

Debt asset ratio

Proportion of household indebted

Debt asset ratio

1

2

3

4

5

1961-62

62.8

NA

NA

NA

1971-72

42.9

4.4

NA

NA

1981-82

19.9

1.8

17.4

2.5

1991-92

23.4

1.8

19.3

2.5

2002-03

26.5

2.8

17.8

2.8

Note : NA: Not Available
Source: RBI (1965); NSSO (1985, 37th round); NSSO (1998; 48 th Round); NSSO (2005; 59 th Round)

 

38 Indebtedness is captured through the incidence measure (or, the proportion of households reporting indebtedness) and the debt-asset ratio.

 

Table 2.44 : The Inverse Monotonicity Between Indebtedness and Asset Holdings – 2002/03

Size class of household asset holdings (Rupees)

Average value of cash loans (Rupees)

Average value of asset holdings (Rupees)

Debt asset ratio
(per cent)

1

2

3

4

0-15,000

1,443

6,317

22.8

15,000-30,000

2,510

22,353

11.2

30,000-60,000

3,251

44,595

7.3

60,000-1,00,000

4,323

78,539

5.5

1,00,000-1,50,000

5,279

1,23,453

4.3

1,50,000-2,00,000

5,729

1,73,397

3.3

2,00,000-3,00,000

7,458

2,44,483

3.1

3,00,000-4,50,000

10,201

3,67,066

2.8

4,50,000-8,00,000

16,772

5,92,415

2.8

> 8,00,000

36,712

17,52,321

2.1

Aggregate

8,694

3,06,967

2.8

Source: Subramanium and Jayaraj (WIDER Working Paper 116, 2006)

 
A study by CRISIL (April 2007) shows that for five years till March 2006, the affordability index39 for home buyers in metros and larger cities was around 4.4, indicating that the average home-buyer spent around 4 times the net annual income for purchasing a new residential home. The subsequent increase in property prices and increase in interest rates on new home loan originations, notwithstanding the increase in the salary of the home buyer, suggests that the affordability index has increased. Stress tests of twin shocks of an increase in property prices (by 50 per cent over March 2006) and increase in interest rates on a 20-year loan to 10.5 per cent (from 8.75 per cent), taking into account the cushion of a 20 per cent increase in the annual salary of the home buyer, indicate a rise in the affordability index to 5.5. Given the high level of retail borrowings, primarily by urban households over the past several years, the Panel feels that any downturn in economic activity might quickly impair their repayment schedule and engender increased indebtedness.

2.6 Other Key concerns

This section examines, based on the above analysis, some key concerns confronting the banking and broader financial sector.

2.6.1 Commercial Banks

PSBs dominate the system accounting for 70 per cent of the assets of commercial banks.

 

39 Affordability index is defined as the ratio of property price to average net annual income; higher value indicates lower affordability.

 

Table 2.45 : Distribution of Households Reporting Cash Debt According to Credit Agencies (AIDIS, 1991-92 and AIDIS 2002-03) - Debt to Asset Ratios

(per cent)

Credit agency

Rural

Urban

 

1991-92

2002-03

1991-92

2002-03

1

2

3

4

5

I. Institutional

15.6

13.4

11.8

9.3

1.1 Government, etc

1.7

0.8

2.3

1.0

1.2 Co-operative society/ bank

6.7

6.9

4.9

3.6

1.3 Commercial banks, etc.

7.5

5.7

3.7

3.2

1.4 Insurance

0.1

0.1

0.3

0.3

1.5 Provident fund

0.2

0.1

1.7

0.7

1.6 Other institutional agencies

0.4

0.5

1.2

1.1

II. Non-institutional

9.8

15.5

9.4

9.4

II.1 Landlord

1.1

0.4

0.2

0.1

II.2 Agriculturalist moneylender

2.3

3.3

0.4

0.2

II.3 Professional moneylender

3.1

6.9

3.4

4.9

II.4 Trader

0.7

0.9

0.8

0.5

II.5 Relatives/ friends

2.3

3.7

3.9

3.6

II.6 Others, including doctors, etc

1.2

1.0

1.6

3.7

III. Unspecified

1.8

0.0

1.1

0.0

IV. Total

23.4

26.5

19.3

17.8

V. Average amount of debt per household (Rs.)

1,906

7,539

3,618

11,771

Source: National Sample Survey Organisation

 

The importance of this bank group was even greater in 2001, when they accounted for nearly 80 per cent of the commercial banks’ assets. The decline in the market share of PSBs since the latter half of the 1990s was primarily due to the growth of private sector banks and the growing presence of foreign banks.

PSBs still maintain their dominance notwithstanding growing competition because of their extensive branch network that permits deposit mobilisation at low cost, increased holding of government debt (although declining in recent times, because of rapid credit expansion), labour cost saving from voluntary retirement programmes (wage cost of public banks declined from 1.85 per cent of assets in 1999-2000 to 1.59 per cent in 2003-04 and have remained low since then);40 and the gradual improvement in customer service and technology.

2.6.1.(a) Capacity Building

Greater openness and competition, along with the increasing presence of new players, have led to new supervisory challenges. First, there is the challenge of improving the quality of aggregate supervisory information on financial institutions and the transparency and integrity of such information. Second is the challenge of better risk monitoring. This is because, banks in general, and the new private Indian banks and foreign banks in particular, have tended to rely more on market-based funding and have been venturing forth with new and complex products like derivatives. This in turn requires the Reserve Bank to develop and strengthen expertise in monitoring and assessing standard risk management capacities and operational risks, emerging as the standard for bank supervision, particularly under Basel II. The Reserve Bank has therefore been

 

40 Even the share of wages in total expense has declined from 19.1 per cent in 1999-2000 to 14.3 per cent in 2007-08.

 

endeavouring to introduce risk-based supervision (RBS) for commercial banks. This would lead to better allocation of supervisory resources in accordance with the risk profile of the respective institutions and is a refinement/ enhancement over the CAMELS approach of on-site and off-site monitoring.

The effectiveness of RBS hinges on the Reserve Bank’s preparedness in critical areas, like instituting an efficient and elaborate off-site surveillance mechanism, effectively exploiting the synergies with on-site inspections, thereby enhancing the quality and reliability of data, assessment of soundness of systems and technology, appropriateness of risk control mechanisms, etc. This would, in turn, require supporting human resources in terms of capacity building, both for commercial banks (Annex 2.7: Human Resource Issues in banks) as also within the Reserve Bank. Currently, pilot RBS programmes are running parallel with the CAMELS-based supervision. The Panel feels that the adoption of techniques and methodology of RBS at an early date needs to be actively considered.

In the case of derivative products, it is felt that the on-site examination process should be supplemented by a forensic “follow the evolution of the product” approach. Such “forensic” examination would require training examiners to understand complex products and the risks at each stage of evolution of a derivative product41.

2.6.1.(b) Bank Consolidation

The pressure on capital structure is expected to trigger a phase of consolidation in the banking industry. The point was raised in both the Narasimham Committee Reports. Both had pointed to the need for a four-tier banking sector structure. This would comprise three to four banks with global presence at the top end of the tier, followed by national banks with country-wide presence and, local and rural banks with niche markets at the lowest two tiers. So far, restructuring has not led to an extensive consolidation process. The number of commercial banks decreased by 20 between 1998-2007, partly as a result of about 17 mergers over 1993-2007, with four such mergers occurring in 2006-07. Two private sector banks were merged in 2007-08. The year also saw the amalgamation of one foreign bank. The consolidation process at present has primarily been confined to domestic mergers, often as a response to localised bank failures.

Though the legal framework for insolvency in banking companies is in substantial compliance with the emerging international standards professed by the World Bank, timely invocation of creditor rights remains an issue.42 As a result, the bankruptcy process frequently fails to provide a timely exit route. To circumvent the problem, merger of weak banks with stronger ones are resorted to protect depositors’ interests.

In the past, mergers were initiated by regulators to protect the interests of depositors of weak banks. In recent years, market-led mergers between private banks have also taken place. It is expected that this process will gain momentum in the coming years. Market-led mergers between PSBs or PSBs and private banks

 

41 Reference: Section 2.2.4 (h) (IV) ibid.

42 Although the Indian legal system provides excellent protection for lenders, the de facto protection of investors’ rights
lags far behind the de jure protection (Chakrabarti, S., W.Megginson and P.K.Yadav, 2007).

 

could be the next logical development as market players consolidate their positions to remain in competition (Annex 2.8 : Bank consolidation).

Consolidation can also take place through strategic alliances / partnerships. Besides helping banks to achieve economies of scale and augment the capital base, it could help market players in other ways also to strengthen their competitiveness. Alternatively, strategic alliances and collaborative approaches could be attempted to reduce transaction costs through outsourcing, leveraging synergies in operations and avoiding problems related to work culture. Rapid expansion in foreign markets without a sufficient knowledge of the local economic conditions could increase the vulnerability of individual banks.

Pressure on bottom lines can prompt banks to seek consolidation in their range of services offered. For instance, some banks may like to shed their non-core business portfolios to others. This could see the emergence of niche players in different functional areas and business segments such as housing, cards, mutual funds, insurance, sharing of their infrastructure including ATM network. Accordingly, the rationalisation of a very large network of branches, which at present has rendered the system cost ineffective and deficient in services would also need to assume priority. While brick-and-mortar branches continue to be relevant in a poorly connected country like India, the real growth driver for cost cutting would be virtual branches, viz., ATMs, internet banking, mobile banking, kiosks etc. This will stimulate strategic alliances/ partnerships amongst banks and this phenomenon has already set in as evidenced in the adoption of core-banking solutions in a fully networked environment.

The Panel feels that, notwithstanding the advantages, the scope for consolidation in PSBs needs to be explored with caution, although it might be more appropriate just now for the troubled, smaller banks. In any case, the gains from consolidation and the synergies needed should be clearly quantified by the management and it is important for bank boards to track whether these gains are, in fact, being realised. It would prove useful provided suitable progress could be made on human resources, and more importantly, industrial relations issues. The Panel, therefore, believes that consolidation would prove useful only if certain enabling conditions, such as progress in terms of industrial relations and human resource issues, are adequately addressed.

The Panel is also of the view that the time is opportune for old private banks to explore the possibilities of consolidation, more so given that several of them are already listed. The regulators can also play a pro-active role in facilitating consolidation within this segment.

2.6.1. (c) Credit Growth

There was a sharp increase in bank credit from the financial year 2004-05 onwards. The rate of growth in bank credit which touched a low of 15.8 per cent (net of conversion) in 2002-03 accelerated sharply to 31.7 per cent in 2004-05 and 30.8 per cent in 2005-06. Though there has been a decline to 28.5 per cent in 2006-07 and a further deceleration to 23.1 per cent during 2007-08, credit growth still remains high (Chart 2.11). This upturn can be attributed to the following factors:

• Robust macroeconomic performance with GDP growth rates hovering between 7.5 per cent and 9.6 per cent between 2004-05 and 2007-08.

• Rising income levels reflecting a benign economic climate leading to growth in credit demand in the retail sector.

• The removal of restrictions on retail credit and project finance by banks.

• The hardening of sovereign yields from the second half of 2003-04 has exposed the banks to market risks. As a result, banks have been reshuffling their assets

 
13
 

portfolio by shifting from investments to advances. While the share of gross advances in total assets of commercial banks grew from 49.4 per cent to 56.5 per cent, that of investments declined from 38.0 per cent to 28.2 per cent during the period March' 05 to March' 08.

Growth in credit out-performed the growth in deposits between 2004-05 and 2005-06 resulting in the increase in credit deposit ratio from 55.9 per cent at end March 2004 to 72.5 per cent at end March 2008 (Chart 2.12). The increase was accompanied by a corresponding drop in the investment-deposit

 
14
 

ratio, which declined from 51.7 per cent to 36.2 per cent during the same period. This indicates a shift of preference from SLR investments to advances. The incremental credit deposit ratio which increased from 56.5 per cent in 2003-04 to 111.6 per cent in 2005-06 declined to 72.0 per cent in 2007-08.

This growth in credit has been widely welcomed. But cross-country data provides graphic evidence of the pitfalls. Firstly, with growing housing loans and real estate exposure and exposure to infrastructure sectors, the maturity profiles of assets of banks are becoming increasingly long-term. Coupled with excessive dependence on borrowings, which are mostly short-term, serious ALM mismatches are a possibility. Increased recourse to borrowed funds could also engender liquidity problems (See Section 2.2.4(h)(IV)).

Post March 2007, deposit growth has significantly outpaced credit growth. This has implications for banks’ ability to effectively deploy funds to assets. Also the increasing dependence on bulk deposits has resulted in an escalation in the cost of raising deposits at the margin which could have profitability implications.

The current credit boom, particularly in the retail loans and commercial real estate sectors, has been accompanied by an increase in asset prices. Increased competition has resulted in a high proportion of sub-BPLR43 loans in total loans which could have jeopardised the appropriate risk pricing of assets.

Sub-BPLR loans by SCBs, which comprised 27.7 per cent of total loans in March 2002 have shown an increasing trend and stood at 76.0 per cent as at end March 2008 (Chart 2.13) and further at 78.6 per cent as at end June 2008. This growth is highly noticeable in consumer credit, followed by term loans. The share of consumer credit in sub-BPLR loans which was 0.4 per cent in March 2002, increased sharply over a period of time to 15.2 per cent of total sub-BPLR loans in March 2008. The share of term loans in total sub-BPLR loans increased from 9.9 per cent in March 2002 to 46.9 per cent in June 2008. The high proportion of sub-BPLR loans has come about because of an increase in liquidity, stiff competition, buoyant corporate performance which lowered credit risk and growth in retail credit (housing). An increasing ratio gives rise to a concern in relation to risk-pricing of assets, which appears to be less than adequate, and could affect banks adversely in the event of an economic downturn.
 
15
 

43 Sub-BPLR loans are loans advanced below the Benchmark Prime Lending Rate and should not be confused with subprime loans.

 
It is widely recognised that during an upswing, credit evaluation skills are often compromised. Often, the seeds of non-performing loans are sown during periods of economic upturns due to an underestimation of potential risks. The increased share of credit portfolio has also resulted in a decline in the liquidity embedded in the banks’ balance sheets. The shift of portfolios away from SLR securities inhibits banks’ ability to avail of collateralised facilities as many banks are now operating with marginal SLR securities.

Recognising the inherent risks in rapid credit growth, especially in the retail and housing loans segments, the Reserve Bank has cautioned banks on the need for proper risk assessments and a honing of their risk assessment skills. Risk-weights for retail, real estate and capital market exposures had been enhanced as counter-cyclical measures. Provisions for standard advances on exposures to these sectors had also been increased. These helped to cushion the negative fallout of a cyclical downturn. Very recently, the Reserve Bank has reversed this measure to boost domestic credit aimed at countering the decline in external funding sources of the corporates due to the global financial meltdown.

Banks have also been advised to devise and improve their risk management systems suitably tailored to their business philosophies. Besides, banks have built up comfortable capital buffers that can enable them to withstand exigencies in the real estate sector (see the stress tests on credit risk section 2.4.4(f)(II). These need to be tempered by the fact that the Reserve Bank has stipulated limits on the exposure to capital markets. As regards other sensitive sectors, it has directed the bank boards to fix internal limits. Also, the level of consumer credit penetration is low compared to emerging economies and the loan to value ratios in housing is also not perceived to be high (though there is some pressure on LTV ratio in 2008-09).

The development of the credit derivatives market could, to a great extent, be a risk mitigator. At the same time, there is need to tread cautiously in this respect as excessive dependence on the principle of ‘originate and distribute’ could result in a compromise on loan evaluation and increase systemic risks (Annex 2.9: Credit Portfolio Management). The management of credit portfolio with particular reference to credit risk transfer (CRT) is analysed in Chapter V.

2.6.1.(d) Sectoral Distribution of Credit

Credit growth has been broad-based making banks less vulnerable to credit concentration risk. Although the share of the priority sector in credit allocations has been stable, the flow of credit to agriculture and SSI has declined somewhat (Chart 2.14). This is in line with the widening definition of priority sector which has opened options for banks to fund alternate avenues. Credit flow to medium and large industries has also witnessed a moderate decline due to structural changes in the economy towards the services sector. Also, there has been a tendency on the part of an increasing number of corporates to meet their funding requirements by accessing domestic and overseas capital markets, as also through robust internal accruals. External Commercial
 
16
 

Borrowings (ECBs) by corporates have also increased significantly till 2007-08. The ongoing global financial turmoil has, however, reduced the flow of ECBs very significantly in 2008-09.

The declining trend of priority sector loans in the credit book of banks due to prudential write - offs and compromise settlements of a large number of small accounts in 2001- 2002 was reversed from 2002-03 on the strength of growth in the housing loan portfolio of banks.

Retail loans, which witnessed a growth of around 41 per cent in both 2004-05 and 2005-06, have been one of the prime drivers of the credit growth in recent years even after a moderation of the growth rate to 30 per cent in 2006-07 and further to 17 per cent in 2007-08 (Chart 2.15). Of the components of retail credit, the growth in housing loans which had been 50 per cent in 2004-05 came down to 25 per cent in 2006-07 and further to 12.7 per cent in 2007-08. Retail loans as a percentage of gross advances, however, increased from 18.3 per cent in March 2004 to 24.5 per cent in March 2008.

The buoyancy in the housing market has also increased banks’ exposure to real estate at

 
17
 

19.3 per cent of total loans in 2007-08. However, banks need to be on guard against movements in property prices because cross-country evidence indicates that housing price peaks tend to follow equity price peaks with a lag in the wake of buoyant economic activity. The feedback from property prices to credit growth is strongest in countries with a greater prevalence of variable rate mortgages, indicating the possibility of mutually reinforcing imbalances in the real estate market and the financial sector. These could have implications for financial stability.

Banks’ exposure to the capital market remains low and direct equity exposure is small (Table 2.46). While PSBs have negligible exposures, it is only slightly higher for new private sector banks. So the vulnerability on this count appears to be limited. Stress tests of banks’ direct exposure to the capital market as at end-March 2007, assuming a drop in the representative index by 26 to 35 per cent44, reveals limited impact on banks’ capital position. In the case of the former, capital adequacy declines to 12.05 per cent (system average of 12.32 per cent).In the case of the latter, the decline is slightly larger at 11.95 per cent. The correlation between direct and indirect (financial guarantees) exposures to the capital market, although significant for the banking sector as a whole, is only prominent in the case of old private sector and foreign banks, suggesting limited systemic concerns. Looking to the sharp decline in representative index since the beginning of 2008, a stress test

 

Table 2.46 : Banks’ Exposure to Sensitive Sectors

(Rs. crore)

Sector/Year

2005-06

2006-07

2007-08

CM

RE

Comm.

CM

RE

Comm.

CM

RE

Comm.

1

2

3

4

5

6

7

8

9

10

Commercial Banks

22,303

2,62,053

1,414

35,106

3,72,874

862

62,998

4,46,758

1,238

 

(1.5)

(17.3)

(0.09)

(1.8)

(18.9)

(0.04)

(2.5)

(18.0)

(0.1)

Public sector

13,470

1,58,033

1,228

20,621

2,19,785

351

32,719

2,75,134

734

 

(1.2)

(14.3)

(0.1)

(1.4)

(15.3)

(0.02)

(1.8)

(15.3)

(0.04)

Old private

1,049

12,086

155

1,708

15,566

501

2,267

18,427

403

 

(1.3)

(14.5)

(0.19)

(1.8)

(16.8)

(0.5)

(2.0)

(16.5)

(0.4)

New private

5,282

66,980

..

8,968

1,04,093

..

22,729

16,002

..

 

(2.3)

(29.1)

 

(2.8)

(32.3)

..

(5.6)

(28.6)

..

Foreign

2,502

24,954

32

3,809

33,430

10

5,283

37,195

101

 

(2.6)

(25.6)

(0.03)

(3.0)

(26.5)

(0.01)

(3.3)

(23.1)

(0.01)

CM : capital market;
RE : real estate market
Comm : Commodities market
Note : Figures in brackets are per cent to total loans and advances of concerned bank group
Source : RBI.

 

44 These represent the largest change in a representative index over a five-year horizon (March 2001 to March 2006)

 

assuming diminution in value by 80 per cent (a much more adverse stress than that attempted for March 2007) was undertaken as at end-March 2008. The stress test revealed that the impact on capital adequacy was to the tune of one per cent and CRAR decreased from 13.0 before the stress to 12.0 thereafter. The impact on equity price risk on banks’ capital therefore does not appear to be significant.

Banks’ foreign exchange exposure is limited by position limits, which in most cases limit a bank’s open position to 25 per cent of regulatory capital.

2.6.1. (e) Off-balance Sheet Exposures

Banks have expanded heavily into off-balance sheet (OBS) activities over the last few years. As a result, the notional principal amount of OBS exposures has increased from Rs.8,41,882 crore at end March 2002 to Rs.1,49,69,243 crore at end March 2008. The ratio of OBS exposure to total assets increased from 57 per cent at end March 2002 to 363 per cent at end March 2008. The spurt in OBS exposures has been fuelled mainly by derivatives, whose share averaged around 80 per cent. The derivatives portfolio has undergone a transformation, with single currency interest rate swaps comprising roughly 57 per cent (Table 2.47) of the total derivatives portfolio at end-2008 from less than 15 per cent at end-2002.

From the financial stability perspective, the tendency of participants to use derivatives to assume greater leverage coupled with a lack of prudential accounting guidelines is a major concern. Along with knowledge concentration and reporting issues, the use of appropriate risk mitigation techniques (such as collaterals and netting) to reduce systemic risks and evolving appropriate accounting guidelines is a must now. (Annex 2.11: Off-balance Sheet Activities of Banks). Bank regulators also need to have a much better understanding of off-balance sheet liabilities. There should be disclosure on the probability of such liabilities being likely to crystallise as on-balance sheet items. A centralised netting, collateral custody and clearing system for derivative transactions could mitigate some of these risks.
 

Table 2.47: OBS Exposure of Commercial Banks

(Amount in Rs. crore)

Particulars

2004-05

2005-06

 

SCBs

PSBs

OPBs

NPBs

FBs

SCBs

PSBs

OPBs

NPBs

FBs

1

2

3

4

5

6

7

8

9

10

11

Currency Options

                   

Purchased

52,570

3,100

429

13,208

35,834

199,847

20,206

1,101

48,657

129,884

%

2.31

0.18

0.32

4.35

23.17

7.42

1.04

0.74

12.14

64.04

Forward Forex

                   

Contracts

1,248,717

380,066

22,826

164,016

681,809

1,528,644

413,766

25,924

219,174

869,779

%

54.81

22.54

17.13

53.98

440.93

56.72

21.31

17.33

54.7

428.85

IRS

1,281,727

61,639

21,220

269,279

929,590

2,152,986

154,009

21,277

409,960

1,567,739

%

56.26

3.66

15.93

88.62

601.17

79.89

7.93

14.22

102.32

772.98

LCs and

                   

Guarantees

230,672

159,672

9,988

34,454

26,559

285,981

195,294

12,200

42,395

36,093

%

10.13

9.47

7.5

11.34

17.18

10.61

10.06

8.15

10.58

17.8

Particulars

2006-07

2007-08

 

SCBs

PSBs

OPBs

NPBs

FBs

SCBs

PSBs

OPBs

NPBs

FBs

Currency Options

                   

Purchased

460,104

38,391

9,092

75,491

337,130

769,717

117,195

12,370

99,515

540,637

%

13.89

1.65

5.67

13.93

120.77

18.66

4.06

6.35

14.67

148.05

Forward Forex

                   

Contracts

2,465,312

485,421

26,598

333,420

1,619,873

4,735,959

888,917

56,931

616,351

3,173,761

%

74.45

20.84

16.58

61.51

580.29

114.84

30.81

29.23

90.85

869.13

IRS (Single

                   

Currency IRS)

4,159,721

277,972

19,421

653,550

3,208,778

8,515,949

224,262

18,237

1,217,452

7,055,998

%

125.62

11.93

12.1

120.57

1149.48

206.50

7.77

9.36

179.45

1932.27

LCs and Guarantees

392,053

262,731

12,978

63,887

52,456

546,267

359,793

18,554

101,063

66,857

%

11.84

11.28

8.09

11.79

18.79

13.25

12.47

9.53

14.90

18.31

SCBs : Scheduled Commercial Banks
PSBs : Public Sector Banks
OPBs : Old Private Sector Banks
NPBs : New Private Sector banks
FBs : Foreign Banks
% : percentages of total liabilities including capital of the concerned bank group.
Forex : Foreign Exchange.
Source : RBI

 
In view of these concerns, the holding of minimum defined regulatory capital for all OBS exposures, the collection of periodic supervisory data and incorporating transparency and disclosure requirements in banks’ balance sheets are some of the major regulatory initiatives undertaken by the Reserve Bank. More recently, comprehensive guidelines have been issued to banks encompassing broad generic principles for undertaking derivative transactions, management of risk and sound corporate governance requirements.

2.6.1. (f) Risk Management

As the system graduates towards a more market-oriented one with emphasis on customer value enhancement, the demands for improved risk management will increase manifold. Even under the impending implementation of Basel II, capital allocation will be based on the risk inherent in the asset. It will also strengthen the regulatory review process and, with the passage of time, the review process will become increasingly sophisticated. Besides regulatory requirements, capital allocation would also be determined by the market forces. External users of financial information will demand better inputs to make investment decisions. There will be an increase in the growth of consulting services such as data providers, risk advisory bureaus and risk reviewers. These reviews will be intended to provide comfort to the bank managements and regulators as to the soundness of internal risk management systems. These have assumed added significance in the context of the recent sub-prime turmoil.

To handle all this, risk management functions will need to be centralised and seamlessly integrated into the business process. Risk-return will be assessed for new business opportunities and incorporated into the designs of the new products. All risks – credit, market and operational - should be combined, reported and managed on an integrated basis. The demand for Risk Adjusted Return on Capital (RaRoC) based performance measures will increase. RaRoC will be used to drive pricing, performance measurement, portfolio management and capital management.

Banks will also have to deal with issues relating to reputational risks as they will need to maintain a high degree of public confidence for raising capital and other resources. Risks to reputation could arise on account of operational lapses, opaqueness in operations, shortcomings in services and the intent to defraud. Systems and internal controls would then be crucial for ensuring that this risk is managed well.

Risk management is also intricately linked to the banks’ credit evaluation skills. With the establishment of the best risk management systems and implementation of prudential norms of accounting and asset classification, the quality of assets in commercial banks ought to improve. At the same time, there should be adequate cover through provisioning for impaired loans. In this context, dynamic provisioning as a pattern of general provisioning has gained currency. The fundamental principle underpinning such provisioning is that provisions are set against loans outstanding in each accounting time period in line with an estimate of long-run expected loss. Pending such a measure, several countries including India have stipulated a minimum requirement for standard loans - a de facto general provision - as the rudiment of a forward-looking system (Annex 2.10: Loan loss provisioning).

2.6.1. (g) Corporate Governance

The issue of the governance framework in banks also assumes relevance at the present juncture. Admittedly, a significant amount of progress has been made. Most banks explicitly state their governance policy in their Annual Reports as part of ‘Notes on Accounts’ in their balance sheets and also provide information on number of board meetings, the functions and workings of the sub-committees of the board, price performance of bank shares (if listed) along with auditors’ certification on the procedures and implementation for ensuring compliance. For listed banks, the governance standards are even more stringent, with such banks having to disclose quarterly information on financial parameters to SEBI as a part of listing requirements.

The Second Narasimham Committee (1998) had observed that it is for bank boards to take decisions on corporate strategy and all aspects of business management. However, to the extent that the Government happens to be the sole (or major) shareholder of banks, the boards have necessarily to be responsible to the Government. In the Indian case, with pre­dominant government ownership, it has been an instrument of management, leading to a blurring of distinction between ownership responsibility and managerial duties.

Composition, independence and professionalism of the boards of the PSBs also remain a concern. Also treading into an uncharted territory of somewhat complex financial instruments requires investment in capacity building and drawing of appropriate talent.

The Panel is of the view that any suggestion that Government must exit its monitoring function and leave governance entirely to a duly constituted board is unrealistic in the present environment and that such a move might, perhaps, be undesirable as well. It is unrealistic because Government, as owner, is ultimately responsible for PSBs and, therefore, Government cannot possibly be expected to abdicate its monitoring function. The BR Act prescribes that members of bank boards should possess specialised knowledge or practical experience pertinent to banking activities. Fit and proper criteria for elected directors have also been prescribed by the Banking Companies (Acquisition & Transfer of Undertakings) Act, 1980 (as amended in 2006). The Reserve Bank of India, in November 2007, has extended the fit and proper criteria for directors earlier issued to private sector banks, to the elected directors on boards of nationalised banks and associate banks of State bank of India. The Banking Companies (Acquisition & Transfer of Undertakings) Act, 1980 as well as the State Bank of India (Subsidiary Banks) Act, 1959 have laid emphasis on having varied experience on the bank boards. The Panel however, feels that full professionalism in the Boards may not have been fully achieved.

The Panel believes therefore that the fit and proper guidelines stipulated for bank boards need to be followed in both letter and spirit. Improving flexibility of decision making of bank management, unhindered by government interference also remains a key challenge in this regard.

2.6.1. (h) Prompt Corrective Action and Exit Policy

Increased competition in the banking sector has generated an even greater need to create an effective prompt corrective action mechanism and exit policies. The risk is that, sans such a mechanism, weak banks, whether public or private, could have incentives for high risk/high return lending in an attempt to re­establish their capital, leaving the Government to bear an even larger burden when the risks materialise. A Prompt Correction Action (PCA) framework was put in place for banks exhibiting weaknesses in certain prudential and financial parameters in 2002; however, whether any action on this front has been undertaken against any bank and under what circumstance is not transparent. While well-defined trigger points have been provided for prudential/financial parameters breaching defined thresholds, a suitable time-frame for the delineated action points would need to be categorically documented for effective implementation, which the Panel feels is a crucial ingredient to improve the efficacy of the PCA framework.

2.6.1. (i) Executive Compensation in Banking

One of the important issues arising from the current sub-prime crisis is the role of managerial remuneration in the financial sector in creating systemic risk. Excessive risk-taking in the presence of high leverage as is the case of banks has assumed prominence, a phenomenon highlighted in the wake of the recent sub-prime episode. Managers have incentives to take huge risks because of limited liability constraint, they stand to benefit from high payoffs; if the bets did not work out, shareholders and bondholders bear the loss. Internationally, there is increasing concern about the excessive rewards for bankers. Leading investment bankers are proposing new guidelines on pay and bonuses in the financial sector.45 Table 2.48 lists the remuneration of top executives in banks across ownership groups in India. It omits stock options whose value cannot be determined from balance sheet information. Keeping in view the possible data limitations, several observations emanating from the data are of note:

First, in 2006-07, the salary of the chief executive of the largest (in terms of assets) new private sector bank exceeded that of the largest state-owned bank by a factor of 44.9:1; in other words, the chief executive in new private sector bank earned total remuneration that was 45 times the state-owned banking counterpart.

Second, the ratio of remuneration of the largest new private sector bank to that of the remuneration of the highest paid old private bank is roughly in the ratio of 9:1

Third, the average remuneration of CEOs in new private sector banks was Rs.1.4 crore, as compared with Rs.0.06 crore in state-owned banks and Rs.0.26 crore in old private sector banks.46

In view of such concerns, the Reserve Bank had, in August 2003, instructed new private sector banks that, while devising the total

 

45 Ideas floated include bonuses being deferred until the full impact of bankers’ strategy is clear, to prevent them benefitting from short-term high-risk bets that later do not bear fruit (Financial Times, March 5, 2008).

46 The average value is based on the sample available in Table 2.48. Owing to missing data on the relevant figures for old
private bank, reported figures for one old private bank pertain only to 2006-07.

 

Table 2.48: Executive Compensation in the Banking Sector

(Amount in Rupees)

Bank category/Name

Year

Designation

Salary

Sitting fees

B & C

Perquisites

Total remuneration (4+5+6+7)

1

2

3

4

5

6

7

8

New private banks

             

Bank A

2005-06

MD & CEO

1,83,84,181

0

52,15,200

0

2,35,99,381

 

2006-07

MD & CEO

1,28,34,000

0

55,80,000

64,03,635

2,48,17,635

Bank B

2005-06

MD

83,41,508

0

36,05,000

0

1,19,46,508

 

2006-07

MD

1,03,83,247

0

51,46,020

0

1,55,29,267

Bank C

2005-06

Exec. VC & MD

1,04,25,000

0

0

0

1,04,25,000

 

2006-07

Exec. VC & MD

92,07,200

0

0

0

92,07,200

Bank D

2005-06

CH & MD

71,28,000

1,20,000

0

0

72,48,000

 

2006-07

CH & MD

94,80,000

0

0

0

94,80,000

Public sector banks

             

Bank A

2005-06

CH

5,72,833

0

0

0

5,72,833

 

2006-07

CH

5,52,259

0

0

0

5,52,259

Bank B

2005-06

CH & MD

5,76,876

0

0

0

5,76,876

 

2006-07

CH & MD

5,92,431

..

..

..

5,92,431

Bank C

2005-06

CH & MD

5,83,784

0

0

0

5,83,784

 

2006-07

CH & MD

6,06,721

0

0

0

6,06,721

Old private banks

             

Bank A

2005-06

CH & CEO

19,01,342

0

0

0

19,01,342

 

2006-07

CH & CEO

22,44,356

0

0

0

22,44,356

Bank B

2005-06

CH & CEO

..

..

..

..

..

 

2006-07

CH & CEO

28,79,000

0

0

0

28,79,000

.. Not reported
Note : CH: Chairman; MD: Managing Director; CEO: Chief Executive Officer; VC: Vice Chairman; B&C: Bonus & Commissions
Source : Prowess database (Release 3.0) and annual reports of banks

 

remuneration package (including all perquisites and bonus) of the CEO and whole-time directors, boards should ensure that the package is ‘reasonable’ in the light of industry norms.

In March 2007, the Government issued the parameters for payment of performance-linked incentives, beginning from the financial year 2005-06, to the whole-time directors of PSBs, subject to achievement of broad quantitative parameters fixed for performance evaluation matrix based on the statement of intent on goals and qualitative parameters and benchmarks based on various compliance reports during the previous financial year. The basis of evaluation of the quantitative and qualitative parameters would be bank’s audited financial data as on March 31 of the relevant year.

The quantitative parameters are based on growth in i) core deposits (ii) advances (iii) agricultural advances (iv) SME advances (v) advances to weaker sections, along with (vi) reduction in gross NPAs (vii) return on average assets (viii) net profit and, (ix) cost income ratio.

The qualitative parameters are leadership and brand building, human resource management and information technology and other initiatives (for CMDs) and customer centricity, adherence to KYC/AML guidelines, prevention/detection of frauds and quality of compliance of inspection and audit reports (for Executive Directors).

The evaluation of performance would be done by a sub-committee of the board of directors called the ‘Remuneration Committee’. On completion of the evaluation by the Committee, the eligible incentive amount would be paid to the whole-time director(s) and a copy of the evaluation report would be put to the board for information and a copy of the same should also be sent to the Ministry of Finance (Department of Financial Services) for information.

The Panel is of the view that there is a need to closely examine this issue of managerial compensation in the Indian banking sector. The remuneration/incentive structure of the PSBs should be commensurate with the responsibility that the job entails and more aligned to market trends. As long as pay is constrained relative to private sector compensation, PSBs may lose valuable staff with entrepreneurial skills to the higher paying private financial institutions.

At the same time, there is also a need to ensure that the incentives for top management and key executives are linked to their performance over a longer-term economic cycle and both cash and non-cash (e.g., ESOPs) payments need to be monitored. This is important in the context of the recent sub-prime turmoil, given that some top executives are believed to have resorted to excessive risk-taking encouraged by rewards for their shorter-term performance. In case of banks where incentives for risk-taking are high, it may be appropriate to mandate a higher level of regulatory capital.

2.6.1. (j) Assessment

In-spite of the overall systemic stability, certain vulnerabilities remain in the commercial banking system. First, there is a need to further improve the capital cushion in terms of tier-I capital, in order to build up a capital cushion against market, operational and other non-measured risks. Second, notwithstanding improvements in credit quality, the absolute quantum of delinquent loans at Rs.55,844 crore at end March 2008 remains high though the ‘standard asset’ category across all banks works out to 97.6 per cent of total loans at end March 2008. Third, most emerging markets with high quantum of sticky assets also have high ‘coverage’ (i.e., provisions/NPA). Despite the improvements in ‘coverage’ by Indian banks over the last few years emanating largely from the ploughing back of trading income in a low interest environment, these remain low compared to international standards.

These vulnerabilities need to be tempered by three positives: first, loan classification norms in India are presently on par with international best practices, so that the decline in NPAs has occurred despite the switchover to more stringent norms. Second, the difference between gross and net NPAs has gradually narrowed, reflecting the improved loan loss provisions by the banking sector. It also seems that the decline in gross NPAs could have been driven by increased write-offs and recoveries. Third, profitability of the banking sector has improved in recent years, with return on asset trending at around 1 per cent, a figure comparable to international levels.

However, the sustenance of high profitability levels, much of which was the result of high trading incomes in a soft interest regime, in a changed environment when interest rates have firmed up remains an open question. The significant improvements in non-interest income notwithstanding, its share in total income for PSBs is around 20 per cent, compared with about 25 per cent for foreign banks. This is consistent with the income diversity numbers across bank groups, which shows that public and old private sector banks tend to be the least income-diversified47 (Table 2.49).
 

Table 2.49: Income Diversity of Bank Groups

End-March

All Banks

Public Sector Banks

Old Private Banks

New Private Banks

Foreign Banks

1

2

3

4

5

6

2004-05

0.680

0.633

0.516

0.895

0.857

2005-06

0.654

0.575

0.502

0.938

0.844

2006-07

0.590

0.487

0.499

0.845

0.794

2007-08

0.753

0.660

0.620

0.982

0.859

Source: RBI

 

Another notable feature has been that banks’ exposure limits in India have gradually been brought on par with international standards. Effective March 31, 2002 the exposure ceiling is computed in relation to total capital as defined under capital adequacy standards (tier-I plus tier-II) and includes credit exposure (funded and non-funded credit limits) and investment exposure (underwriting and similar commitments). The exposure limits for single borrowers presently stands at 15 per cent and that for group borrowers at 40 per cent; the latter being extendible by an additional 10 per cent in case of financing infrastructure projects (Table 2.50).

In assessing the risks to stability, it must be mentioned that the Indian banking system is almost unique among banking systems in not having had any major crisis consequent to deregulation. It is plausible that public ownership of banks and pre-emptive recapitalisation of these at the start of deregulation have contributed to this impressive record. In order to maintain the record in the face of growing complexities, the levels of regulation and supervision will need to be raised to a higher level in order to ensure that the system remains free from crisis.

 

Table 2.50: Cross-Country Limits for Loan Exposure to Single Borrower

Country

Single borrower
(per cent of capital)

1

2

Chile

5

China, Colombia, Mexico

10

Argentina, India, Israel, Korea, United States (a)

15

Brazil, Hong Kong, Hungary, Japan, Malaysia,

 

Philippines, Poland, Russia, Singapore

25

Australia

30

Note : 10-25 per cent for state-chartered banks
Source: Hawkins and Turner (IMF, 1999) and Morris (IMF, 2001)

 

47 The diversity of the income streams for a bank, provides comfort as to whether a bank is able to maintain its profitability if one of its revenue streams were to become insignificant and is calculated as:

1- |(net interest income – other operating income)/total operating income|, where, net interest income is interest income less interest expense and other operating income includes fee income, commission income and trading income. Income diversity ranges between zero and one, higher values indicative of greater diversification.

 

2.6.2 Urban Co-operative Banks

Urban Co-operative Banks (UCBs) occupy an important place in the financial system providing need based banking services, essentially to the middle and lower middle classes and marginalised sections of the society. UCBs are regulated and supervised by State Registrars of Co-operative Societies, Central Registrar of Co-operative Societies in case of multi-state co-operative banks and by the Reserve Bank. The Registrars of Co-operative Societies of the States exercise powers under the respective Co-operative Societies Act of the States in regard to incorporation, registration, management, amalgamation, reconstruction or liquidation. In case of the urban co-operative banks having multi-state presence, the Central Registrar of Co-operative Societies (CRCS) exercises such powers. The banking related functions, such as issue of license to start new banks / branches, matters relating to interest rates, loan policies, investments, prudential exposure norms etc., are regulated and supervised by the Reserve Bank under the provisions of the BR Act, 1949 (AACS)48. Various committees in the past, which went into working of the UCBs, have found that the multiplicity of command centres and the absence of clear-cut demarcation between the functions of State Governments and the Reserve Bank have been a vexatious problem of urban co-operative banking sector.

In order to address the problem of dual control, the Vision Document for UCBs, released in March 2005, proposed signing of Memorandum of Understanding (MoU) between the Reserve Bank and respective State Governments for establishing a consultative approach to supervision and regulation of the banks by establishing of a Task Force for Urban Co-operative Banks (TAFCUBs) comprising representatives of State Government, Federation of UCBs and the Reserve Bank. As indicated earlier49, till date MoUs have been signed with 24 states and the Central Government in respect of multi state UCBs, thereby bringing about 98.7 per cent of banks and 99.3 per cent of deposits of the sector under the MoU arrangement. The TAFCUBs constituted in MoU states identify the potentially viable and unviable UCBs in the respective states and suggest measures for revival of the former and non - disruptive exit of the latter either through merger/ amalgamation with stronger banks, conversion into societies or by liquidation as a last resort. As per the terms of the MoU the Reserve Bank commits to facilitate human resources development and information technology initiatives in UCBs. The State Government undertakes to introduce reforms relating to audit of UCBs.

Many of the problems faced by UCBs have also been due to governance issues and related lending activities. Since board members of UCBs are elected by borrowers, this has the potential of influencing the boards to take decisions that may not always be in the interest of the depositors who constitute the most important stakeholders of a bank. While the role of directors has been sought to be delineated by the Reserve Bank, the power of taking action against the directors or the board is vested with

 

48 AACS: As Applicable to Co-operative Societies

49 Ref Section 2.4.1 ibid

 

the State/Central Government. In case of gross violation of the Reserve Bank guidelines/ directives where complicity of a director or of the board is noticed, the Reserve Bank has to approach the Registrar of Co-operative societies of the concerned state for removal of director / supersession of board. While the MoU arrangement forms a basis for greater co­ordination, the Panel thinks that it would be desirable to bring aspects related to management of the UCBs within the ambit of BR Act and limiting the influence of the Registrar of Co-operative Societies in this respect. This could create an environment for enhancing professionalism in the UCB management.

The prudential norms stipulated for the UCBs are mostly Basel-I compliant. However, the Reserve Bank recognises the varied nature of UCBs and has devised a two-tier regulatory framework wherein some relaxation and deferment of prudential norms have been allowed in respect of select categories of UCBs considering their difficulties in adhering to the norms. An attempt is made to phase out weaker UCBs through a process of merger/amalgamation and restructuring of weak UCBs. However, the process of merger/amalgamation is time consuming as in much as the involvement of both the Reserve Bank (for issuance of no-objection certificate) and Registrar of Co­operative Societies (for issuance of the order of amalgamation) is required. The Panel feels that procedural simplification by enhancement of the power of the regulator may speed up the process.

UCBs are saddled with high levels of gross NPAs. Other than the inherent difficulties of credit appraisal, cumbersome procedure of writing-off of NPAs, etc., it is also related to the propensity of UCBs to pursue borrower-oriented policies as generally, the debtors are shareholders of the banks and have a say in their governance. This leads to a distortion as UCBs solicit deposits from non-members as well, while their policies are not always in congruence with the interests of depositors. As such, the Panel feels that increasing the involvement of depositors in the management of UCBs by encouraging membership for depositors would go a long way in strengthening governance of UCBs.

2.6.3 Rural Financial Institutions

The inadequate performance of the sector can be traced to several reasons.

First, with volatile cash flows, there is often uncertainty about loan repayment. They are also exposed to systemic risk – such as crop failures or a decline in commodity prices – and therefore, face difficulties in servicing loans.

Second, such problems are exacerbated by the lack of reliable information on past credit histories of borrowers. Additionally, with limited collateral backing and paucity of proper titles to their assets, the uncertainty regarding repayment is further compounded.

Third, the small loan sizes, high frequency of transactions, borrower heterogeneity, rising transactions costs, further acts as a deterrent to rural lending.

Fourth, the legal and regulatory environment is less creditor-friendly, making contract design, its renegotiation and enforcement weak, thereby making it difficult for financiers to provide borrowers with the right incentives for repayment.

Fifth, the cost of funds for rural co­operatives is very high, which squeezes their financial margins. Illustratively, the costs of funds50 for rural co-operatives at end-2005 ranged from 5.2 to 9.6 per cent, whereas the same for commercial banks during the same period was 4.8 per cent and even lower for RRBs (Table 2.51).

 

50 Cost of funds= Interest expended/(Deposits+ Borrowings), expressed in percentage terms Return on Funds = Interest income/(loans + investments), expressed in percentage terms

 

Table 2.51 : Deposits of Rural Financial Institutions - 2007

Category

Deposits + Borrowings

Cost of Funds

Loans+ investments

Return on Funds

1

2

3

4

5

StCBs

82.6

5.2

83.4

7.0

DCCBs

78.3

5.4

81.8

8.1

SCARDBs

71.0

7.4

84.5

8.8

PCARDBs

60.1

9.6

59.4

14.9

RRBs

85.8

4.2

87.9

7.9

Commercial banks

85.0

4.8

84.7

7.9

Note : Deposits + Borrowings and Loans + Investments are as percentages to total assets of the concerned institution
Source: Computed from RBI data

 

To top it all, the overarching presence of the Government complicates the risk-return signals and creates inefficiencies in the delivery of rural financial services: RRBs are majority government owned, in case of rural co­operatives, the State Governments, through the Registrar of Rural Co-operatives, have considerable powers and can supersede elected boards. As at end March 2007, 46.4 per cent of the elected boards of rural co-operatives were under supersession. This is compounded by weaknesses in the regulatory architecture. While the Reserve Bank is the overall regulator of the rural finance sector, supervision of RRBs and rural co-operatives is delegated to NABARD. State Governments, through the Registrar of Co­operatives, also play a role in the regulatory process. The net effect of this process is cross-directives, inadequate levels of control by the central bank in respect of banking and consequent weakening of the overall quality of regulation of co-operative banks.

The combined effect of government intervention, weak asset quality, and high cost of funds has led to a weakening of the balance sheets of these institutions. By virtue of the MoUs entered into by the State Governments with NABARD under the package recommended by the Task Force on Revival of Co-operative Credit Institutions which was headed by Dr.A.Vaidyanathan, the issues of dual control and good governance as also government interference are being addressed. Carrying out necessary legislative amendments by the State Governments is one of the pre-requisites for getting financial assistance under the package.

The responsibility for regulation and supervision of the State Co-operative Bank (SCBs) and District Central Co-operative Banks (DCCBs) and the Regional Rural Banks (RRBs) is divided between the Reserve Bank of India (RBI) and National Bank for Agricultural and Rural Development (NABARD). While the Reserve Bank has the regulatory responsibilities, NABARD is entrusted with supervisory responsibilities. So is the case of RRBs. Furthermore, co-operation being a state subject, the aspects relating to registration, audit liquidation, election and constitution of the board of directors, its dismissal, registration of bye-laws and other management aspects regarding co-operative institutions are in the realm of the State Governments. Therefore, the State Government is also involved in the regulation and supervision of co-operative societies. The division of regulatory responsibilities is that the banking regulation is in the ambit of the Reserve Bank and the regulation relating to the provisions of the State Act is with the State Government. In practice, however, there are considerable overlaps in regulatory roles which lead to conflicts.

The Vaidyanathan Committee has suggested some changes in the laws to resolve these issues. Based on the recommendations of the Committee, the Government has approved a revival package which includes providing financial assistance, subject to introduction of legal and institutional reforms and improvement of quality of management. Until November 2008, 25 states had agreed to participate in the package.

In the case of RRBs, there are four institutions involved. The Reserve Bank is the regulator, NABARD is the supervisor, the sponsor bank is providing financial and technical assistance and the Government is in the picture as per the provisions of the RRB Act. The issues such as establishment, constitution of the board, amalgamation, closure, etc., are in the realm of the Government. Given the poor financial health of the RRBs it has been decided to restructure the sector through amalgamation and recapitalisation.

While most prudential norms related to asset quality (IRAC norms) are applicable to the rural financial institutions, capital adequacy (CRAR) norms have not been made applicable to them as yet. The co-operatives could graduate and further accomplish adoption of certain Basel principles through on-going reform process particularly in light of Vaidyanathan Committee recommendations where 7 per cent capital adequacy norm is envisaged. Similarly, the amalgamation of RRBs could hasten the process of application of Basel principles as there has been a significant boost in IT initiatives by banks.

The segregation of regulatory and supervisory roles insofar as StCB/DCCB and RRB are concerned, has raised some important issues. The Agricultural Credit Review Committee (ACRC) has commented that the powers of enforcement of inspection findings by NABARD are limited. These limitations are that NABARD has no powers to grant or withdraw licenses; and any restriction on withdrawal of refinance by NABARD is likely to weaken the institutions rather than improving them. Furthermore, the control is divided among the Reserve Bank /NABARD/State Governments. Thus, NABARD has to depend on its own persuasiveness for ensuring its inspection recommendations which contain development aspects also. In extreme cases, it has to seek action through interventions by the Reserve Bank or State Government which delays action and reduces the efficacy of supervisory process. The action that the regulator can take, in view of the duality of control, is also constrained. While the regulator can issue directions to the bank relating to the banking business, it cannot take action against the management. For bringing about improvement in the system, these institutions will have to be brought completely under the BR Act, including Section 10 (management), 30 (audit), Part III (winding up) etc., and limiting the powers presently exercised by the Registrars of Co­operative Societies.

2.6.4 Non-Banking Finance Companies

Given that NBFCs fill an important void in India’s financial space, factors impeding their growth and viability need to be immediately addressed. An important inhibiting factor for NBFCs relates to their funding sources. Barring deposit-taking, which only some NBFCs engage in, banks are a major source of funding for NBFCs, either directly or indirectly. Besides providing loans, banks also are major investors in bonds issued by NBFCs. This results in extremely high dependence of NBFCs on banks, which raises systemic risk in the financial system.

In response to the perceived increase in risk, prudential norms have been significantly tightened for bank lending to NBFCs in terms of bank exposure limits, higher provisioning requirement and higher risk weights regardless of the credit rating of the borrowing NBFC. These measures have reduced NBFCs’ access to bank funds and also increased their cost of funds. However, the root cause of the problem lies in the absence of alternative avenues for NBFCs to mobilise funds. The appropriate response should focus on diversifying the funding sources for NBFCs. The Panel therefore considers it urgent to develop an active corporate bond market. This would help NBFCs to continue to grow, albeit with less dependence on banks and such growth would have fewer repercussions on systemic risk. On the other hand, NBFCs would need to improve their corporate governance to attract funds from the market.

Over the past few years, the market share of NBFCs in most retail finance segments, especially car and commercial vehicle financing, has been declining. As price-setters in a rate-sensitive market, banks have an edge over NBFCs, resulting from their access to low-cost funds. In a rising interest rate environment, NBFCs have not been able to fully pass on the increases in cost of borrowings to end users, except in markets where banks have done it, resulting in severe profitability pressures for this sector. In response, NBFCs have diversified their portfolios and ventured into newer and riskier assets classes, such as small-ticket personal loans. Although banks dominate the personal finance market, their presence in the small-ticket segment (loans less than Rs.50,000 or roughly USD 1,250)51 is limited, given the high credit costs and operating expense that characterise this segment. This has resulted in a mismatch between the demand for loans and supply of credit from organised financiers, enabling loan companies to garner significantly higher rates of return. Others (investment companies) have adopted a capital market based business model, with a presence in the loan – against - shares and public issue financing businesses on account of higher yields in these segments.

The Panel is of the view that there is a need to devise an appropriate framework for regulating this diverse set of companies with different business models.

For the purpose of regulation NBFCs are segregated in three distinct categories. These are deposit taking NBFCs (NBFC-D), non-deposit taking NBFCs (NBFC-ND) and Residuary Non-Banking Companies (RNBC). NBFCs in India are not permitted to accept demand deposits and are not part of the payment and settlement system. While the NBFC-D segment and the RNBCs have been monitored closely, NBFC-NDs were till recently subject to minimal regulation.

The Reserve Bank’s powers to regulate NBFCs are drawn from Section 45N of the RBI Act. Though, since 1997 the Reserve Bank has been formulating policies in tune with the
 
51 At USD1= Rs.40
 

changing environment in order to strengthen the regulatory and supervisory framework with the objective of making the sector healthy and vibrant, there are some significant gaps in the power of the regulator to regulate and supervise NBFCs. The Reserve Bank has no say in the removal of management nor does it have any power in the appointment of auditors. The issuance of appropriate guidelines in this regard to empower the Reserve Bank regarding appointment, rejection and rescinding of auditors could be explored, in consultation with ICAI. The major acquisitions of the NBFCs cannot be reviewed by the supervisor.

The Panel believes that the Reserve Bank may explore the option of obtaining information on names and holdings of significant shareholders of NBFCs who exert controlling influence.

The current benign economic scenario has evinced considerable interest of the foreign non-banking companies in the Indian financial sector. No direct arrangements have so far been worked out with other regulators outside the country for sharing regulatory information. There is a need to explore the possibility of formalisation of relationship with foreign regulators that encompasses a transparent method of information sharing. Also, unlike in case of banks, the Reserve Bank has no control over the branch expansion by NBFCs.

The regulatory framework for banks and NBFCs needs to be appropriately defined. Illustratively, in the case of banks there are limited restrictions on their liability side as they can raise low-cost deposits. On the asset side, there are restrictions on their lending and investments. Therefore, if a level playing field is sought to be ensured between banks and NBFCs by restricting NBFCs on their asset side akin to those for banks, the Panel feels that a similar freedom needs to be provided to them on their liability side as well.

Bank exposure to risks emanating from lending to non-banks and through them to the capital market needs to be reviewed. To address this potential problem, restrictions on the range of activities that NBFCs can undertake might not be the appropriate remedy.

The Panel believes that it is important to create a regulatory structure that prevents regulatory arbitrage.

2.7 Concluding Remarks

The financial sector is in the throes of very significant changes. Rapid growth is opening up unprecedented opportunities. But at the same time, it also contains the potential for future disturbances. Notwithstanding observed successes, much remains to be done for the sector if it has to support the rapid economic growth, maintain system stability and improve shareholder value. Enabling policy that imparts greater flexibility in decision-making of state-owned banks and supports their globalisation efforts is essential. A constant re­balancing of growth and stability, without jeopardising equity concerns, remains an on­going challenge.

 
 
Annex 2.1: Projected Capital Requirements of Nationalised Banks
 

The exercise attempts to assess the capital requirements of 20 nationalised banks, including IDBI Ltd., over the period beginning April 1, 2007 through March 31, 2013. This covers not only the Basel II requirements, but also their future business growth. The assumptions underlying the analysis are as under:

1) The banks are expected to maintain a capital adequacy ratio of 12 per cent (for both Pillar I and Pillar II) and a tier I capital ratio of at least 8 per cent,

2) Risk Weighted Assets (RWA) of the banks are estimated to grow at 20, 25 and 30 per cent per annum (this takes into account the effect of trade cycles on credit off-take).

3) Likely benefit of reduction in RWA for credit risk, if any, under Basel II is ignored.

4) RWAs for market risk are assumed at 10 per cent of the RWA for credit risk.

5) RWAs for operational risk are assumed at 12 per cent of the RWA for credit risk.

6) The banks retain each year profits to the extent of 15 per cent of their tier I capital (excluding Innovative Perpetual Debt Instruments [IPDI]).

7) The banks raise tier II capital up to the permissible level, during the above period.

8) The banks raise the IPDI up to eligible level i.e., up to 15 per cent of tier I capital as at the end of the previous year during the above period.

9) The banks raise the preference shares up to eligible level i.e., up to 25 per cent of tier I capital as at the end of the previous year during the above period.

10) The banks’ share issue price has been taken at the average of low and high prices between June 28, 2006 and June 27, 2007.

 

Table: Year-wise Projected Government Infusion of Capital

(Amount in Rs. crore)

(i) Scenario: RWAs grow by 20 per cent

Bank name*

2007-08

2008-09

2009-10

2010-11

2011-12

2012-13

Total

1

2

3

4

5

6

7

8

Bank No 1

0

0

0

0

0

0

0

Bank No 2

0

0

0

0

0

0

0

Bank No 3

0

0

0

0

0

0

0

Bank No 4

0

0

0

0

0

0

0

Bank No 5

0

0

0

0

0

79

79

Bank No 6

0

0

0

0

0

0

0

Bank No 7

0

0

0

0

0

254

254

Bank No 8

0

0

0

0

0

0

0

Bank No 9

19

65

8

61

79

102

334

Bank No 10

0

0

0

0

0

0

0

Bank No 11

0

0

0

0

0

0

0

Bank No 12

0

0

0

0

0

0

0

Bank No 13

0

0

0

0

0

0

0

Bank No 14

0

0

0

0

0

0

0

Bank No 15

0

0

0

0

16

276

292

Bank No 16

188

0

5

201

254

320

968

Bank No 17

0

0

0

0

0

93

93

Bank No 18

0

0

0

0

0

0

0

Bank No 19

0

0

0

0

7

107

114

Bank No 20

0

0

0

0

0

0

0

Total

207

65

12

262

356

1231

2134

Banks needing funds (no.)

2

1

2

2

4

7

 
 
 
 

(ii) Scenario: RWAs grow by 25 per cent

Bank name*

2007-08

2008-09

2009-10

2010-11

2011-12

2012-13

Total

1

2

3

4

5

6

7

8

Bank No 1

0

0

0

0

340

483

823

Bank No 2

0

0

0

0

0

0

0

Bank No 3

0

0

0

0

95

873

968

Bank No 4

0

0

0

0

0

862

862

Bank No 5

0

0

0

138

266

353

757

Bank No 6

0

0

0

0

64

1362

1426

Bank No 7

0

0

24

399

537

715

1674

Bank No 8

0

0

0

0

0

0

0

Bank No 9

56

114

66

143

192

254

824

Bank No 10

0

0

0

0

0

0

0

Bank No 11

0

0

0

0

437

649

1086

Bank No 12

0

0

0

0

0

233

233

Bank No 13

0

0

0

0

0

0

0

Bank No 14

0

0

0

0

0

367

367

Bank No 15

0

0

49

396

532

708

1686

Bank No 16

288

0

256

403

530

692

2169

Bank No 17

0

0

69

419

579

787

1854

Bank No 18

0

0

0

0

0

0

0

Bank No 19

0

8

69

176

242

327

822

Bank No 20

0

0

0

0

0

770

770

Total

343

122

531

2076

3814

9435

16321

Banks needing funds (no.)

2

2

6

7

11

15

 

(iii) Scenario: RWAs grow by 30 per cent

Bank name*

2007-08

2008-09

2009-10

2010-11

2011-12

2012-13

Total

1

2

3

4

5

6

7

8

Bank No 1

0

0

129

492

702

983

2306

Bank No 2

0

0

0

0

402

615

1017

Bank No 3

0

0

0

728

1318

1867

3913

Bank No 4

0

0

0

51

1612

2212

3875

Bank No 5

0

0

156

339

467

637

1598

Bank No 6

0

0

0

629

1888

2612

5130

Bank No 7

0

105

373

691

956

1309

3434

Bank No 8

0

0

0

0

0

364

364

Bank No 9

92

166

133

244

336

459

1431

Bank No 10

0

0

0

0

0

0

0

Bank No 11

0

0

75

645

906

1255

2881

Bank No 12

0

0

0

213

714

1026

1952

Bank No 13

0

0

0

0

14

250

264

Bank No 14

0

0

0

120

1653

2348

4121

Bank No 15

0

1

488

683

944

1291

3407

Bank No 16

387

65

475

651

885

1194

3657

Bank No 17

0

235

397

782

1099

1524

4037

Bank No 18

0

0

0

0

154

562

716

Bank No 19

0

137

166

322

451

623

1700

Bank No 20

0

0

0

620

1291

1839

3750

Total

480

708

2394

7211

15791

22969

49552

Banks needing funds (no.)

2

6

9

15

18

19

 

Note : 1. In all the three scenarios above, Bank 1 ,2, 3…etc refer to the same bank.
2. Total after rounding off

 

Computed from RBI data

 

Annex 2.2: Credit Risk Stress Test - Scenarios and Results

 

(a) Commercial Banks

To ascertain the resilience of banks, stress tests of credit portfolio by increasing both NPA levels (for entire portfolio as well as specific sector) and provisioning requirement were undertaken and the resultant estimates were related to bank capital. The analysis was carried out both at the aggregate level as well as at the individual bank level based on supervisory data as at end March 2008 under three scenarios. Along with increased provisioning norms for standard, sub-standard and doubtful assets, the first scenario assumes a 25 per cent increase and 50 per cent increase in NPAs. The shock imparted in the second scenario amounts to the maximum asset slippage experienced by banks since 2001. The third scenario assumes a 50 per cent increase in retail NPAs. The findings indicated that the impact of credit risk on banks' capital position was relatively muted. Under the worst-case scanario (scenario II), the overall capital adequacy of the banking sector declined to 11.6 per cent (10.9 per cent as at end-March 2007). CRAR of 15 banks accounting for roughly 14.7 per cent of commercial banking sector assets would be reduced below the regulatory minimum as against 14 banks accounting for about 10.2 per cent as at end March 2007 (Table 1: Stress Tests of Credit Risk - Scenarios and Results). The details of the assumptions under various scenarios are as under:

Scenario I:

Under this scenario, NPAs were subjected to increase of 25 per cent and then 50 per cent. The increase in NPAs was distributed across sub-standard, doubtful and loss category in the existing proportion. An additional provisioning requirement was applied to the altered composition of the credit portfolio. The provisioning requirements were taken to be 1 per cent, 25 per cent and 100 per cent on standard, sub-standard and doubtful/loss assets, respectively.

Scenario II:

Standard NPA ratios often do not reveal fresh slippages in loan assets as they are computed net of recoveries, write-offs and NPAs' upgradation to standard category through restructuring or otherwise. Credit quality generally tends to deteriorate during economic downturn as debtors begin to experience cash flow problems which in turn affect smooth servicing of debts leading to a possible deterioration in asset quality. In order to simulate the effect of an economic slowdown on the banks advances portfolio, the maximum asset slippage experienced by banks since 2001 was applied to the stock of gross loans to arrive at gross NPAs. The NPAs so generated were distributed among sub-standard, doubtful and loss assets in the existing proportion. The additional provisioning requirements stipulated in scenario I were then applied to the portfolio of standard and non-performing loans.

Scenario III:

This scenario assumes differential NPAs in the retail segments. Specifically, this category of loan was subjected to a shock in the form of an increase in impairment by 50 per cent. The increase in NPAs thereof was distributed among sub-standard, doubtful and loss categories in the existing proportion. The additional provisioning requirements stipulated in scenario I were then applied to the portfolio of standard and non-performing loans.

 

Stress Tests of Credit Risk – Scenarios and Results

Bank Group

Existing

Scenario I

Scenario II

Scenario III

CRAR

Banks

NPA increase by
25%

NPA increase by
50%

CRAR

Banks

CRAR

Outlier Banks

CRAR

Banks

CRAR

Banks

1

2

3

4

5

6

7

8

9

10

11

All Banks

13.0

0

12.3

5

12.1

5

11.6

15

12.6

2

 

(12.3)

(1)

(11.4)

(6)

(11.1)

(8)

(10.9)

(14)

(11.7)

(3)

Nationalised

12.1

0

11.4

2

11.1

2

10.4

6

11.6

1

 

(12.4)

(0)

(11.4)

(1)

(11.0)

(1)

(10.9)

(3)

(11.8)

(0)

SBI Group

13.2

0

12.1

0

10.8

0

11.7

2

12.4

0

 

(12.3)

(0)

(11.1)

(0)

(10.7)

(0)

(10.7)

(2)

(11.4)

(0)

NPB

14.4

0

14.1

0

13.9

0

13.8

2

14.3

0

 

(12.0)

(0)

(11.6)

(0)

(11.5)

(1)

(11.0)

(3)

(11.8)

(0)

OPB

14.1

0

13.2

2

12.9

2

12.1

4

13.5

1

 

(12.1)

(1)

(10.8)

(4)

(10.3)

(5)

(10.2)

(5)

(11.3)

(3)

FB

13.1

0

12.9

1

12.8

1

12.2

1

13.0

0

 

(12.4)

(0)

(12.1)

(1)

(12.0)

(1)

(11.6)

(1)

(12.2)

(0)

Share #

 

0.0

 

5.3

 

5.3

 

14.7

 

2.1

   

(0.04)

 

(3.2)

 

(3.8)

 

(10.2)

 

(0.3)

Note : 1. Position as at end March 2008.
2. Figures in parenthesis indicate the position as at end March 2007.
3. The impact on CRAR has been arrived at without reckoning the PBT of banks.
4. Under Scenario-II, asset slippage of one outlier bank is replaced with the system average.
@: Number of affected banks.
#: Assets of affected banks as percent to commercial banking system assets.

 

Results: Under Scenario I, if NPAs were increased by 25 per cent, the CRAR at the system level reduced to 12.3 per cent in March 2008 (as against 11.4 per cent as at end March 2007) and if NPAs were increased by 50 per cent, the CRAR reduced to 12.1 per cent (as against 11.1 per cent as at end March 2007). When NPAs were subjected to 50 percent increase in place of 25 percent increase, the number of affected banks whose CRAR went below the stipulated minimum remained the same at 5 (as against the increase to 8 from 6 as at end March 2007).

Under Scenario II (the most stringent scenario), system-level CRAR would decline to 11.6 per cent (as against 10.9 per cent as at end March 2007) and as many as 15 banks (as against 14 banks as at end March 2007) accounting for about 14.7 per cent (10.2 per cent at end March 2007) of commercial banking assets would not be able to meet the stipulated minimum. Scenario III is the least stringent and proportion of the assets of the affected banks to the total commercial banking assets was 2.1 per cent at end March 2008.

(b) Urban Co-operative Banks

A stress test on 52 scheduled UCBs accounting for 43 per cent of the total assets of the sector was carried out for March 2007 by increasing the provisioning requirement and subjecting the credit portfolio to a shock of 25 and 50 per cent and also increase in non performing assets.

The following scenario was considered: -

1 per cent provisions for standard assets;

25 per cent provisioning for sub-standard assets

100 per cent for provisioning doubtful and loss assets

25/50 per cent increase in Non-Performing Assets

Thereafter, capital (tier I & II) was recomputed by subtracting the new provisions from the original capital (tier I & II) and adding the actual provisions already made. The CRAR was recompiled with reference to recomputed capital and original Risk Weighted Assets (RWAs).
 

CRAR (per cent)

Before stress

After stress

25%

50%

25%

50%

1

2

3

4

5

Negative

9

9

14

19

[0, 3)

1

1

5

2

[3, 4.5)

-

-

-

1

[4.5, 7.5)

1

1

6

6

[7.5, 9)

-

-

2

3

Total

11

11

27

31

 

The stress test revealed that for a 25 per cent shock, as at end March 2007, 27 banks (accounting for 38 per cent of scheduled UCBs’ assets and 16.5 per cent of urban co-operative banking assets) would not be able to comply with the 9 per cent CRAR norm. Similarly, for a 50 per cent shock, 31 banks would not be able to comply with the 9 per cent CRAR. At the system level, the CRAR declined from 11.4 per cent to 5.6 per cent for a 25 per cent stress and further to 2.8 per cent consequent upon a 50 per cent stress, pointing to the fragility inherent in this segment.

Computed from RBI data.
 

Annex 2.3: Asset-Liability Mismatches

 

The essence of liability management is raising and managing of appropriate resources at a competitive cost. The sources available to a bank to raise resources to fund asset growth are capital and reserves (owned funds), customer deposits, institutional deposits, borrowings, and float funds. Being highly leveraged institutions, deposits and borrowings account for the major share of banks’ total liabilities. While longer-term customer deposits constitute the core deposits of a bank, bank deposits and borrowings as also short-term customer deposits form the purchased liquidity base of the bank. Avenues of deployment of funds are primarily loans and investments. Loans are preferred as they generate higher spread but these are generally long-term, illiquid and carry credit risk.

The core activity of any bank is to attain profitability through fund management i.e. acquisition and deployment of financial resources. Integral to fund management is liquidity management which relates primarily to the forecasting and structuring of cash flows, both inflows and outflows, with a view to enabling the bank to meet maturing liabilities and customer demands for cash within its basic pricing policy framework. Liquidity risk, thus originates from the potential inability of a bank to generate cash to cope with demands entailing a decline in liabilities or increase in assets. Thus, the cause and effect of liquidity risk are primarily linked to the nature of the assets and liabilities of a bank.

 

Maturity Profile of Deposits, Advances and Investments of Commercial Banks

Deposits (percent to total)

Period

Mar-01

Mar-02

Mar-03

Mar-04

Mar-05

Mar-06

Mar-07

Mar-08

1

2

3

4

5

6

7

8

9

1- 14 days

7.8

7.6

7.1

7.3

7.9

8.1

7.8

8.8

15 – 28 days

2.4

2.5

2.0

2.1

2.3

2.6

2.8

2.5

29 days - 3 months

6.0

5.9

5.2

6.0

6.7

7.8

8.6

8.6

3 - 6 months

6.6

6.0

7.3

6.2

6.7

6.9

7.6

8.8

6 - 12 months

10.4

9.6

10.1

9.3

12.2

12.6

13.3

14.9

1- 3 years

46.0

47.6

43.7

35.6

32.4

29.5

29.5

28.7

3 - 5 years

11.7

9.2

7.9

10.0

9.9

10.1

10.8

9.0

Over 5 years

9.1

11.8

16.7

23.5

21.9

22.5

19.7

18.8

 
    • Since March 01 there has been a steady rise in the proportion of deposits maturing up to one year.

    • Deposits maturing upto one year increased from 33.2 per cent in March 01 to 43.6 per cent in March 08.

    • Similarly, deposits maturing beyond 5 years have increased from 9.1 per cent in March 01 to 18.8 per cent in March 08.
 

Advances (percent to total)

Period

Mar-01

Mar-02

Mar-03

Mar-04

Mar-05

Mar-06

Mar-07

Mar-08

1

2

3

4

5

6

7

8

9

1- 14 days

13.5

13.3

11.1

11.7

11.8

10.1

8.5

8.6

15 – 28 days

7.5

5.9

5.5

4.3

2.9

2.4

2.6

2.4

29 days - 3 months

11.6

10.2

9.9

9.1

7.5

7.0

6.5

7.5

3 - 6 months

6.7

6.6

6.1

6.7

6.2

6.1

5.9

6.3

6 - 12 months

9.5

11.0

8.6

9.6

9.0

8.9

8.7

10.2

1- 3 years

34.3

36.0

35.5

34.0

35.1

36.3

37.1

38.1

3-5 years

7.6

7.8

8.6

10.3

10.0

11.0

11.7

10.3

Over 5 years

9.3

9.2

14.6

14.4

17.4

18.3

18.9

16.5

 
    • Loan portfolio is steadily becoming long-term oriented.

    • Loans maturing between three to five years increased from 7.6 per cent of total loans in March 01 to 10.3 per cent in March 08 while those maturing over 5 years grew even higher from 9.3 per cent to 16.5 per cent during the same period.

    • Thus proportion of advances maturing over 3 years increased from 17 per cent in March 01 to 27 per cent in March 08.
 

Investments (percent to total)

Period

Mar-01

Mar-02

Mar-03

Mar-04

Mar-05

Mar-06

Mar-07

Mar-08

1

2

3

4

5

6

7

8

9

1- 14 days

13.5

13.3

11.1

11.7

11.8

10.1

8.5

12.4

15 – 28 days

7.5

5.9

5.5

4.3

2.9

2.4

2.6

2.7

29 days - 3 months

11.6

10.2

9.9

9.1

7.5

7.0

6.5

7.2

3 - 6 months

6.7

6.6

6.1

6.7

6.2

6.1

5.9

5.5

6 - 12 months

9.5

11.0

8.6

9.6

9.0

8.9

8.7

8.2

1- 3 years

34.3

36.0

35.5

34.0

35.1

36.3

37.1

20.3

3-5 years

7.6

7.8

8.6

10.3

10.0

11.0

11.7

11.0

Over 5 years

9.3

9.2

14.6

14.4

17.4

18.3

18.9

32.2

 
• Total investments maturing up to one year declined from 48.8 per cent in March 01 to 36.0 per cent in March 08.

• The share of investments maturing over 5 years in total investments increased considerably from 9.3 per cent in March 2001 to 18.9 per cent in March 2007 and further to 32.2 per cent in March 2008.

Thus it is observed that while there has been a steady decline in maturity of deposits, maturity of loan and investment portfolio has increased reflecting higher asset liability mismatches. This is important as banking system loan portfolio & investment portfolio witnessed a steep increase in the last couple of years. The table below shows the important growth parameters of commercial banks since March 2001.
 

(All figures in per cent)

Growth Indicators

Mar-01

Mar-02

Mar-03

Mar-04

Mar-05

Mar-06

Mar-07

Mar-08

1

2

3

4

5

6

7

8

9

Total Assets

17.2

19.0

11.7

16.0

19.3

18.3

22.9

24.9

Total Deposits

18.0

14.1

13.2

16.0

16.3

17.5

24.1

23.1

Gross Advances

17.6

23.6

14.4

16.2

31.0

31.0

28.5

25.0

Total Investments

18.9

20.1

18.4

16.1

8.8

0.1

8.7

23.4

Ratios

               

Credit Deposit (CD)

50.9

55.2

55.8

55.9

63.0

70.2

72.7

72.5

Incremental CD

49.9

85.3

60.5

56.5

106.4

111.6

82.9

72.0

Incremental Credit +

               

Investment Deposit

98.8

152.1

129.6

108.4

134.3

111.9

97.8

108.2

 
• Funding of incremental asset growth by sources in addition to incremental deposits has been the general trend.

• Incremental CD ratio in March 05 & 06 stood above 100 per cent and reflected incremental deposits lagging far behind the growth in loans.

The process entails certain risks, the crux of which can be summarised as under:

Liquidity and Interest Rate Risk: Extensive reliance on purchased liquidity may expose a bank to liquidity problems. Purchased liquidity is much more sensitive than core deposits to both changes in bank risk and interest rates changes. If the financial market perceives a decline in a bank’s safety and soundness, its purchased liquidity would have to be rolled over at higher rates and may even cease to be available as institutions may shy away from placing liquid assets in an institution that shows deteriorating financials.

Systemic Risk: Funding long-term assets through short-term funds usually takes the route of purchased liquidity. A concern emanating from such inter-bank exposures is that of systemic risk. Bank failures are potentially contagious and losses in one bank may cascade into problems for other banks or to the economy at large.

Computed from RBI data.

 
 
Annex 2.4: Liquidity Scenario Analysis
 

The basic objective of liquidity stress testing is to ascertain how long a bank may withstand a liquidity drain without resorting to liquidity from outside. This is a relatively narrow approach to liquidity stress testing, but it is one that allows for an introductory exposition without going into complex details. Recently, a leading bank in the UK faced a deposit run and reportedly lost 6 per cent of its total deposits in a single day.

The analysis is done on top-five banks according to asset size as at end-March 2008. Taken together, these banks accounted for roughly two-fifths of commercial bank assets.

Scenario I depicts unexpected deposit withdrawals on account of sudden loss of depositors’ confidence and assesses the adequacy of liquid assets available to the bank to fund them. The rate of withdrawal is different for different types of deposits. The deposit run is assumed to continue for five days.

Scenario II attempts to capture unexpected withdrawal of uninsured and insured deposits separately. Empirical research suggests that bank runs are often information-based, i.e. they are the result of noisy and adverse information about banks. Uninsured depositors comprise institutional depositors and other bulk depositors and generally are privy to market information. Experience has shown that these deposits are the first to adopt the ‘flight to quality’ as soon as they sense a bank in trouble. On the other hand, insured deposits adopt a wait and watch policy partly on account of deposit insurance comfort and lack of information about market developments.

Scenario III describes different probabilities of crystallisation of contingent credits / commitments as result of changes in bank’s borrowers’ credit risk and delinquency in repayment of loans due to economic downturn. The time horizon has been considered to be six months. During economic downturn, expected cash inflows for maturing loans are expected to be impacted due to increased delinquency. Hence, a haircut has been applied for the expected repayment of loans upto six months. The liquid assets available with the bank are compared with the stressed funding requirement.

Methodologies: Scenario I

• Objective is to capture the ability of the bank to meet unexpected withdrawal of deposits for five days through sale of its available liquid assets without any outside support.

• Deposits are segregated into three types, current deposits, savings deposits and term deposits.

• Liquid assets consist of cash funds, excess CRR balance with the Reserve Bank, balances with other banks payable within one year and investments payable within one year.

• Unexpected withdrawal of deposits is assumed to take place in the following proportion:

• Current deposits – two times the proportion of reported outflows of current deposits in 1-14 days time bucket.

• Savings deposits – two times the proportion of reported outflows of savings deposits in 1-14 days time bucket.

• Term deposits – three times the proportion of reported outflows of term deposits in 1-14 days time bucket.

• The bank is assumed to meet stressed withdrawal of deposits through sale of liquid assets.

• The sale of investments is done with a hair cut of 10 per cent of their market value.

• The stress test is done on a static mode.


Methodologies: Scenario II


• Objective is to capture differential withdrawal of uninsured and insured deposits and the adequacy of liquid assets to sustain repayment of withdrawals without any outside support for five days.

• 30 per cent of total uninsured deposits of the bank are assumed to be withdrawn in a span of five days in the following proportion:

• 10 per cent on the first day.

• 8 per cent on the second day.

• 5 per cent on the third day.

• 4 per cent fourth day.

• 3 per cent on the fifth day.

• 1 per cent of total insured deposits are assumed to be withdrawn on each of the five days.

• Liquid assets consist of cash funds, excess CRR balance with the Reserve Bank, balances with other banks payable within one year and investments payable within one year.

• Investments are sold with a hair cut of 10 per cent of their market value.


Methodologies: Scenario III


• Objective is to capture the impact of devolvement of off-balance sheet exposures viz. letters of credit, guarantees, other commitments on account of adverse changes in credit worthiness of the bank’s borrowers spread over six month period.

• The stress scenario is carried out on one month, three months and six months time horizon.

• Contingent credits and commitments consist of LCs, guarantees (both financial and performance), and all other contingent commitments.

• 10 per cent, 20 per cent and 30 per cent of total contingent credits and commitments are assumed to devolve.

• As borrowers face financial difficulties, expected inflow of loans and advances are also adversely impacted and defaults are assumed which add to adverse cash flow mismatches.

• Expected inflows of loans and advances within six month time horizon are assumed to materialise with a hair cut of 5 per cent, 10 per cent and 15 per cent respectively.

• Liquid assets consist of cash funds, excess CRR balance with the Reserve Bank, balances with other banks payable within one year and investments payable within one year.

• Investments are sold with a hair cut of 5 per cent, 10 per cent and 15 per cent of their market value respectively for one month, three months and six months time horizon.

 
 

Scenario I
Results

 

Scenario I

(Withdrawal of deposits due to loss of depositors’ confidence)

Cumulative Withdrawal as per cent of total deposits

Day 1

Day 2

Day 3

Day 4

Day 5

1

2

3

4

5

6

Bank 1

6.3

9.4

12.5

14.1

15.7

Bank 2

5.5

8.3

11.0

12.4

13.8

Bank 3

4.2

6.2

8.3

9.3

</