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From the very beginning, Raghuram Rajan had a great clarity, pragmatism and
perspective on the issues at hand. He set the stage perfectly and set the ball rolling
for what was going to be a great phase for Indian economy. We will pick some
instances from the book and talk about their implications. We will also talk about what
they demonstrate about his personality and what can be learnt from them.
He was open to changes and decided to actively change the perception of the
RBI from conventional and short sighted to that of adaptable, transparent, long
sighted and self-assured. He understood the need to send the right signals to
the market.
He expressed his clear commitment for financial inclusion, new licenses and
lazy banking. This gave a clear message that he meant business and wasnt
beating around the bush.
He did a quantitative balance of risks and assessed that this was the cheapest
option available to them so he grabbed it by both hands.
He mentioned that this scheme was surely meant to make money for bankers,
drain money from RBI, but it was also going to make the country better so he
decided to go by that calculated risk. Later on his risk did pay off. This particular
instance provides a learning that sometimes taking risks is compulsory but we
can try our best to keep them rational and minimal by proper assessment.
His guiding principles or the 5 pillars for RBIs financial sector policies are:
1. Clarifying strengthening the policies
2. Focussing on new entries, branch expansion, new types of bank, better
regulation of foreign banks.
3. Broadening the markets and increasing their liquidities to decrease risk
4. Expanding to small, medium enterprises, financial inclusion of the poor,
unorganised and the deprived.
5. Dealing with corporate distress and financial institution distress, debt recovery.
As we can clearly see there is an emerging structured way of thinking there. He started
by bringing changes to the existing structures then focusing on new avenues. Post
that he expanded to new inclusions and then focussing on what can be done better to
tackle the issues that arise (distress). This was a wonderful and exhaustive way of
thinking.
Speaking about inflation, he decided to focus on the issue by not getting into
the discourse of the complex reasons but tackling the basic reason i.e.
increased demand first. For this he ensured that the burden is not on the poor
and allowed some concessions and more time to them.
His perspective on financial inclusion was very exhaustive and clear. He didnt
want the financial inclusion to be limited to only opening bank accounts for poor,
rather he stressed about the need to understand the social implications behind
it. So a lot of stress was laid on trust building and recognising special needs of
the rural people.
On dealing with stress he showed a very pragmatic approach. Rather than
complaining about the things that were wrong or unavailable he shifted his
focus on the things which he actually had a control over. Moreover he
mentioned that rather waiting for miracles to happen during distress, it is better
to detect the issues early. This is a perfect example of a person who believes
in doing things rather than just talking about them.
What should be the ideal level of inflation that the RBI should target? Why 2-6% and
why not a moderate level like 7-10%
1. Even if inflation is at moderate level like 7-10% it disproportionately affects
the poor daily wage worker. While industrialist may benefit from high
inflation, the workers wont increase
2. Inflation is more variable at higher level. This raises the chance of
breaching the inflation target range if set at higher level
3. Inflation could feed on itself at higher levels higher the inflation, more
chances of it entering regions where it could spiral upwards
Arguments against RBIs policy in fighting inflation
1. Focus on the wrong index of inflation: But this is misguided. Focus on
WPI is wrong on two fronts. One, common man only experiences retail
inflation. Thus, if the RBI has to manage expectations of inflation it has to
target CPI. Two, WPI contains a lot products that are internationally traded
and whose prices are determined internationally and hence RBIs
monetary policy will play very little part in changing that.
2. RBI has killed private investment by keeping interest rates too high:
This again is misleading argument because a large component of the
interest rate that many industrialists pay for is the credit risk premium that
banks charge them
3. Supply constraints: Monetary policy has no effects on inflation when the
economy is supply constrained. Even though food inflation has contributed
significantly to CPI inflation, inflation in services like education &
healthcare have also played a part. While govt. has the main role to play in
containing food inflation, RBI can control inflation for more discretionary
items in the consumption basket through tighter monetary policy
4. Fiscal dominance: Central bank has little effect over inflation when
government spending dominates. The possibility of fiscal dominance,
however, only means that given the inflation objective set by the
government, both the government and the RBI have a role to play. If the
government overspends, the central bank has to compensate with tighter
policy to achieve the inflation objective. So long as this is commonly
understood, an inflation-focused framework means better coordination
between the government and the central bank as they go towards the
common goal of macro stability.
Financial Inclusion
At the National Seminar on Equity, Access, and Inclusion, on July 18,2016 Governor
Raghuram Rajan delivered a speech on The Changing Paradigm for financial
Inclusion in India which effectively encapsulates his thoughts on the topic and the
underlying principles that governed his decisions during his tenure.
He defines financial inclusion as:
1. The outreach of financial services to those people and businesses who do not
have access to this sector
2. The strengthening of financial services for those who have minimal access
3. Increasing financial literacy so that consumers can make better choices and
increased consumer protection
His justification for Financial inclusion is based both on moral and economic stands.
To give everyone the access to the services that he enjoys seemed morally correct
instinctively and the economist in him argued that more financial services outreach
would create more output, growth and economic prosperity.
But he also was mindful of the impediments to financial inclusion which have been a
hindrance up until now. The primary one that he mentioned was the lack of profitability
in servicing the poor across the world. He has characterised these impediments into
three categories (acronym IIT) :
1. Information
2. Incentives
3. Transaction Costs
IIT
The marginalised may live in remote zones or may have a place with groups or
portions of society that attempt economic activity informally they don't keep up
records or have marked contracts or documentation. They frequently don't possess
property or have consistent built up sources of wage. Therefore, a broker, particularly
if as is typical, he isn't from the neighbourhood locale, will experience issues getting
adequate data to offer budgetary items.
A second concern is incentive. For instance, advances are effortlessly accessible only
if the lender thinks they will be repaid. At the point when the legitimate framework does
not authorize reimbursement rapidly or economically, and when the borrower does not
have any guarantee to promise, the lender may believe that its hard to get
reimbursed.
The third obstruction is transaction costs. Since the extent of exchanges by poor
people, or by micro farmers or SMEs is little, the fixed expenses in executing are
generally high. It requires as much investment helping a customer fill out the forms
and to give the essential documentation in the event that he is applying for a credit for
Rs. 10000 as it takes to enable another to get Rs. 10 lakhs. A financier who is aware
of the main issue would normally concentrate on the huge customer in preference
to the minor one.
How does the local moneylender manage?
One of the essential inspirations for the nation to push for financial inclusion is to free
the marginalised from the grasp of the moneylender. How does the moneylender
actively give out loans where no broker sets out to? Since he doesn't endure similar
obstructions! Being a local citizen, the sahukar is well educated on what everybody's
sources of income are, and the amount they can repay. He is very equipped for utilizing
merciless techniques to implement reimbursement. Additionally, the borrower realizes
that in the event that he defaults on the sahukar, he loses his moneylender of final
resort. So, the borrower has solid impetuses to pay. Lastly, on the grounds that the
sahukar lives close-by and utilizes negligible documentation all things considered,
he wouldn't utilize the courts to enforce reimbursement - advances are effectively and
immediately gotten. In a crisis or if the poor need to acquire consistently, there are no
options more promptly accessible than the moneylender. No big surprise he has such
large number of marginalised citizens in his grasp.
How then should public policy approach this problem? He describes three approaches:
mandates and subventions, transforming institutions, and moving away from credit.
Since there are sure social advantages to financial inclusion that are not caught by the
service provider(what financial experts call "externalities"), such mandates are
sensible from a societal viewpoint. For example, the higher familial and group status
a farm worker gets starting her own poultry homestead and adding to the family salary
may, on net, exceed the costs the bank brings about on making the loan. The bank
can't monetize the status benefits, yet the government can choose those advantages
merit producing and mandate them.
In a similar vein, there may be network benefits from universal access for instance,
direct transfer of benefits is easier when the vast majority of beneficiaries have a bank
account, and the accounts themselves will be used heavily when account to account
transfers are made easier through mobile phones via the soon-to-be-introduced
Unified Payment Interface (UPI). Mandated account opening essentially creates the
universal network with its associated positive network externalities.
There are, however, a number of risks emanating from mandates. The first is that there
is no market test of usefulness, and indeed, these may not be possible how does
one measure the value of the enhanced social status of the poultry farmer? So,
mandates are driven by the beliefs of the political leadership, and may persist a long
time even if they are not effective. Furthermore, some vested interests may benefit
from specific mandates and push for their perpetuation long after they have ceased
being useful. Bankers themselves, seeing little profit in obeying the mandate, will try
and achieve it at least cost by targeting the most accessible and least risky in the
eligible category, and even mislabelling normal activity so that it fits in the eligible list.
Finally, some mandates fall primarily on the public-sector banks. As competition
reduces their profitability, their capacity to carry out mandates and still earn enough to
survive diminishes.
Mandates are not costless. Rather than forcing banks to recover costs by overcharging
ordinary customers, or by demanding recapitalisation by the government, better to
bring the costs into the open by paying for the mandate wherever possible. So, for
instance, accounts or cash machines opened in remote areas could attract a fixed
subsidy, which would be paid to anyone who delivers them. Not only will the cost of
the mandate become transparent and will be borne by the authorities, thus
incentivising them to make sensible decisions about how long to impose the mandate,
the mandate can be delivered by the most efficient service providers, attracted by the
subsidy. This is why the RBI today explicitly subsidises cash recyclers set up in
underserved areas, and why central and state governments are paying banks for
maintaining and servicing specified accounts. Going forward, narrow targeting of
mandates to the truly underserved and explicit payment for fulfilling the mandate so
that they are delivered by the most efficient should be the norm.
Approach 2: Creating the Right Institutions
As mentioned before, the moneylender is especially effective on the grounds that he
knows the area and its kin, and can make a decent appraisal of who is credit worthy.
A large national bank with a local branch suffers from two infirmities. In the first place,
the branch administrator has ordinarily been enrolled through an all-India exam, is
from another state, and regularly isn't personally acquainted with the nearby
individuals. While numerous great branch directors do in fact find out about the group,
some don't. The higher financial status of bank officers additionally makes a barrier
between them and the poorer fragments of the group, and their high pay makes many
branches in remote territories monetarily unviable regardless of the possibility that they
could solicit business intelligently. Finally, given that the marginalized don't have
formal records, bank managers in large banks with bureaucratic unified methodology
think that its difficult to give viable service how can one pass on to head office the
justification for an advance to an astute energetic tribal who needs to set up a little
shop, however who has no formal instruction or reputation?
Local financial institutions, with local control and staffed by knowledgeable local
people, could be more effective at providing financial services to the excluded. HDFC
Bank, for example, has been very successful growing its loan portfolio in Kashmir by
recruiting local youth as loan officers. Certainly, this is also the obvious lesson to be
drawn from the success of micro finance institutions, who combine their local
knowledge with stronger incentives for repayment through peer pressure and frequent
collection of repayments. Indeed, this was also the rationale for local area banks,
regional rural banks, and is a strong feature in the cooperative movement.
Yet, while there have been some grand successes among these institutions, each form
has some deficiencies. Micro finance institutions do not have access to low cost
deposit financing, though securitisation of loans has been a growing avenue of
finance. Local area banks could not expand out of their local area, exposing them to
the geographical concentration risks. Regional rural banks agitated for parity in salary
structures with parent scheduled commercial banks, and having achieved parity, find
that their costs are not optimally suited for the clientele they need to service. There
are some very successful cooperative banks, on par with any universal bank, but far
too many suffer from governance problems. The RBI has been engaged in bringing
stronger governance to urban cooperative banks, but split supervision with state
authorities limits how much it can do.
To provide an alternative institutional avenue for these categories of institutions to fulfil
their mission, the RBI has created a new institution called the small finance bank,
where small refers to the kind of customer the bank deals with, not its size. With 75%
of the loans mandated to be below 25 lakhs, the small finance bank is intended to
provide services to the excluded. Thus far, the licenses have been largely given to
micro-finance institutions and one local area bank, but there is no reason why these
cannot be given to regional rural banks and co-operatives in the future. The hope is
that these institutions will maintain a low-cost structure, augmented by technology, to
provide a menu of financial services to the excluded.
Approach 3: Dont Start with Credit
RBI has been striving for quite a long time to extend credit. RBI has concentrated
considerably less on easing payments and remittances, on expanding remunerative
savings vehicles, or on providing easy-to-obtain insurance against crop failures. In the
developing monetary consideration worldview, the Government and the RBI are
endeavouring to expand inclusion by empowering these different products, enabling
credit to follow them instead of lead. Without a doubt, numerous organisations working
with the poorest of the poor endeavour to motivate them to set aside some cash as
reserve funds, regardless of how little, before giving them loans. Some of the self-help
groups (SHGs) work on this principle. Not only does the savings habit, once taught,
enable the client to deal with the weight of reimbursement better, it might likewise
prompt better credit allocation.
Easy payments and cash out will make formal savings more attractive. Today, a
villager who puts money into a bank has to either trudge the last miles to the bank
branch to take out her money, or wait for an itinerant banking correspondent to come
by. RBI is engaged in strengthening the network of banking correspondents; by
creating a registry of banking correspondents, giving them the ability to take and give
cash on behalf of any bank through the Aadhaar Enabled Payment System (which will
also give them adequate remuneration), and requiring that they are adequately trained
in providing financial services. Cash-in-cash-out points will expand soon as the Postal
Payment Bank and telecom affiliated payment banks make post offices and telephone
kiosks entry points into the financial system. Perhaps most interestingly, transfers from
bank account to bank account will become easier in a few weeks via mobile through
the Unified Payment Interface. A villager needing to pay a shopkeeper only needs to
know the latters alias say Ram@xyzbank.psp. He feeds that into his mobile app,
writes the payment amount, puts in his password, and presses send and the payment
is made, with both getting messages to that effect. Neither needs to visit the bank to
take out or deposit money, no point of sale machine is needed. With the price of
smartphones falling sharply, RBI is on the verge of solving the last mile problem.
Raghuram Rajan, in his book, writes his expectations from the Indian Debt market and
how he plans to make those a reality.
Debt markets and associated derivatives
Why we need them to be deep and liquid,
Why, in addition to central and state governments, we need riskier firms and
projects to be able to access the bond markets for funds,
Why we need to encourage product innovation,
And finally, the dilemmas that regulators like the RBI face
He mentions three key reasons why debt markets have become a lot more attractive
in the recent months:
1. Firstly, we finally have a set of regulations that commits us to low and. stable
inflation. Market participants know that Monetary Policy Committee has to
maintain low and stable inflation, certainly over next 5 years for which tis remit
has been set. This lowers inflation risk premium and thus reduces nominal
fixed interest rates for everyone.
2. Secondly, reluctance of both public and private sector banks to fully pass
through past policy rate cuts into bank lending rates. Short term market rates
have seen full pass through, leading to highly rated firms bypassing banks to
borrow from Commercial Paper markets. But what of lower rated firms?
Unfortunately, the difficulty of debt recovery in India has meant that Credit
spreads are wider than elsewhere. This is where the third notable development
comes in.
3. Recent reforms of SARFAESI Act and Debt Recovery tribunals in the short term
and Bankruptcy code in the medium term should help reduce defaults and lower
credit risk.
Given these developments, what should be the objectives of fixed income market
regulation?
RBI is concerned about three facets of the debt market:
1. Markets can be affected by speculators who can move the price away from
what the fundamentals imply. RBI must act to prevent any concerted effort from
speculators and must ensure that all participants are price-takers.
2. Markets can turn into source of competition for Institutional investors, who as
mentioned previously have moved from Banks to Debt markets thereby forcing
banks to lend to high-risk projects and end up with more NPAs on their balance
sheet as opposed to NBFCs who have more long-term commitments.
3. Worry about unbridled innovation that tries to circumvent the prudential norms
and ends up creating systemic risk like the derivatives and CDSs around
housing mortgage pools that led to the financial crisis of 2008.
The broader point is that a measures and well-signalled liberalisation of fixed income
and derivative markets will allow us to reap benefits of a deeper and more liquid market
while minimising the above mentioned three risks of speculation, competition and
innovation.
Participation:
Greater participation adds greater liquidity and Raghuram Rajan has over the years
tried to enhance participation through his policies as governor.
Increasing access of institution dominated screen-based NDS-OM market to
retail investors so that they can trade G-Secs and use their de-mat accounts
Foreign Portfolio Investors will now have direct access to variety of markets
including NDS-OM, corporate bond trading etc.
Increased bank open position limits
Innovation:
Financial innovation can slice or dice risk so that it is placed on the right shoulders.
CPI based Inflation Indexed Bonds, Tax Protected Gold Monetisation Bonds
First version of Interest Rate futures was not attractive but second version
was highly successful
Setting up of Financial Benchmarks India Pvt. Ltd (FBIL) which is building a
series of market benchmarks.
Managing Distress
Financial distress has been one of the major concerns of the Indian banking
industry. The most recent problems have their roots in the period of 2007-09, when
high economic growth led to increased demand. However, this was followed shortly
by the financial crisis. Lack of recovery instruments only worsened the scene. Banks
have been ineffective with collections and need to be better equipped with more tools
to counter the problem.
Traditionally, lenders in our country have always been seen in a bad light.
However, today, the lenders are not selfish sahukaars and the borrowers are not
illiterate peasants. Despite the fact that the industrial borrowers default and leave
banks helpless creating a hole in the countrys economy and costing taxpayers hard
earned money, the mindset has still not changed much.
One of the reasons this distress has become a major problem to both, banks
and the economy as a whole, is the protection offered by the system to the large
borrowers. While banks face the downside risk in any transaction, the borrowers enjoy
the gains completely during good times and flee during the bad times shifting the entire
burden on the banks. The promoters keep stalling the recovering agents and sell off
their enterprises in the meantime. One key reason for the same is that we currently
have 37 Debt Recovery Tribunals and only 5 Debt Recovery Appellate Tribunals,
which creates a major bottleneck in the system, giving promoters with expensive
lawyers sufficient time to flee.
Two major consequences of the above-mentioned problems are:
Borrowing becomes costly for the entire industry if one of the members defaults.
Stricter laws discourage small business from borrowing and drive down
innovation.
The solution to the problem is to give more control to the lenders during bad
times and taking more from the promoters. A better balance between the two parties
can be ensured by the following initiatives:
Better Capital Structures: Ensuring that the projects are not highly leveraged
and that the promoters too have a considerable stake ensures the sincere
involvement of the promoters as well. Banks also need to ensure that the
promoters do not take their money out once the funding is secured and stay
involved in it. Inefficient project monitoring also leads to major problems down
the line.
Joint Lending Forums: In order to ensure faster action and give more power to
the lenders, RBI came up with JLFs that are banks that come against a common
defaulting promoter. To give them more agility, the RBI has incentivized quicker
decisions and reduced the minimum voting requirements.
A better legal infrastructure: The Government has plans to expand the DRT and
DRAT network. The move needs to be accompanied also by improved laws,
more trained personnel and more effective implementation.
Asset Reconstruction Companies: The Government needs more ARCs and
turnaround agents that can step in in place of promoters and improve the
financial health of the company so that it may repay the debt at some point of
time. In addition, these ARCs need to be more effective not act as mere
liquidators.
Bankruptcy law: A properly structured, well-documented bankruptcy law would
reduce the uncertainty on part of the lenders as well as the shareholders in
times of distress. We will also need accompanying bankruptcy courts for better
results.
There has been a decline in the growth of credit over the years and it has been
largely because of the stress on the public sector banks. To boost the growth, cleanup
of the balance sheets is necessary. It involves recognizing the problem, resolving the
bad loans, and recapitalizing the banks.
Since 2014, the non-food credit growth for the public sector banks has been
falling as compared to credit growth for the private sector banks, which denotes
slowdown in lending. One could say that the firms are not investing, hence no demand
for credit but actually, the lack of capital or the level of interest rates is not the problem.
Banks are reluctant to give out loans to areas of high credit exposure, specifically to
industry and to small enterprises because of mounting distress on their past loans,
that leads to shrinkage. Private sector banks cannot substitute fully for the slowdown
in public sector bank credit.
These problems become severe with inefficient loan recovery system. It does not
follow careful documentation and perfection of collateral, or assets backing promoter
guarantees are not registered and carefully tracked. In such situations, knowing that
banks would find it hard to collect, some promoters double-up by expanding the scale
of the project, even though the initial scale was unable to service debt.
Effects:
Banks are getting into the spirit of the clean-up, and pursuing reluctant promoters to
take the necessary steps to rehabilitate projects. Indebted promoters are being forced
to sell assets to repay lenders.
Fraud:
RBI coordinated with SEBI to increase penalties for willful defaulters and establish
measures for quick and effective investigation
Banks are now showing the promoters alternatives to repayment can be harsh
BANK RISK AVERSION
Bad loans could be a result of bankers sloppy attitude or lack of due diligence or poor
loan monitoring techniques, but not always. Instead of suspecting bankers of
malfeasance, look for a pattern across loans sanctioned.
RBIs Responsibility
RBI believes that the onus of bad loan problem lies on bankers, promoters, and
economic environment. RBI neither can make commercial decisions on behalf of the
bankers or micromanage them. Even investigation of such deals while they are being
made is difficult. RBI tries to help by warning the banks about poor lending practices,
and demanding banks to hold adequate risk buffers.
Because of these measures, the banks have not been lending indiscriminately and
focusing more on reducing the size of distressed loans or NPAs. Contrary to the
popular belief, easing the monetary policies does not help curb the problem of distress.
Government Initiatives:
1. Indradhanush initiative
Breaking up the post of Chairman and Managing Director, strengthening board and
management appointments through the Banks Board Bureau, decentralizing more
decisions to the professional board, finding ways to incentivize management, all these
will help improve loan evaluation, monitoring and repayment improve the governance
of public sector bank