Friday, August 10, 2012

The grand papa of microFinance - oh la la !


The grand papa of microfinance – ohh la la !

I had an occasion of being a part of the Financial inclusion conclave “ the first mile walk to Financial inclusion” organised by sadhan at New Delhi on 7-8 Aug 2012 at New Delhi . The title was very apt and many speakers including the RBI, Deputy Governor commented on the creativeness of the title . The event however, never showcased much of it; with topic like microfinance regulation and SHG federations etc. the beauty of the meet however, was the large participation of the SHG members, who were panellists; we had an exclusive session with them moderated by a CEO of Development Support Team, Pune. Though many complained about the banks not giving credit, most of the clients spoke about the savings balances they maintain and the other benefits that accrued due to their being a part of SHG.

Well, my purpose of writing this piece is to inform about the great dampener session which was the penultimate one on microfinance regulation with Mythili Bhusurmath in the chair, Umarji, Anuraj jain of DFS and the grand dad of microfinance. While everyone spoke the current bill and the good things it can do; but, the grand dad had only one agenda – “blast the AP govt”. He went off at a tangent not covering the bill but castigating the AP govt , telling everyone that they should be tried in a court. It was a virtual diatribe, stating they should be behind bars etc etc, especially when nobody was there from the AP govt to defend or state their point of view. It was at the end that the Chair asked the grand dad to stick to the topic on microfinance regulation and the present bill; for which the grand dad commented i wanted the word microfinance vandalism to be mentioned in the bill; and it be should a part of the microfinance lingo in the future. For a godfather who was once prudent, creative and propped up by NABARD in late 1980’s and then RBI and Government, now seems to make a joke of himself! I wish i posed these Q’s for him

1.      Did the godfather NOT foresee the risks of business, including the risks from external sources, even when perceives it this away.
2.      Did he believe that all the poor in the country live in AP? Was AP the only state where poverty existed; what prompted them to stay away from states that needed these services?
3.      Was he not aware of the microfinance crowding that was happening in AP? Was he not aware of the perils of overcrowding?
4.      What happened to his due diligence abilities of the business side?
5.      If as an industry, why did not learn from the earlier lessons when the first signs were out in 2006?
6.      Was their Code of conduct drafted for mere printing and lip service during conferences? Why was not it put in place to avoid such mishaps?
7.      If the grand pa thought that other mFIs where responsible (which he keeps repeating) not him and his company, why were they not restrained by the association?
8.      If the case is subjudice; cannot the grandpa wait for the final outcome? RBI had only recently filed its affidavit on jurisdictional issue and that too for NBFC which it regulates?
9.      If the RBI regulation was weak  for NBFC ( grand pa has a NBFC); why did not tell this to RBI ?
10.  What happened to client level trust which his mFI had built, and why did the client ditch him?-  i ask this because i had heard him reply to a Q in previous conference meeting at Gujarat Govt in 2008; where a participant asked about mass default by mFI client in Anand, Gujarat. The grand dad’s reply was “ we built trust with clients and they don’t default en-mass    
11.  The AP Act states not more than 2 loans to a client; if it’s more they reserve it, while mFI target the same segment, overcrowd and there are instances of 5-9 loans to one family – does grandpa’s NBFC do a KYC and realize that the client has already got an outstanding 2-4 loans and his loan is the n th, could he not avoid them ?. Did he purposely plunge his fingers into fire and now blaming the fire for it ?

In all his monologue not a word about the client, except stating that “Now the 92 lakh poor families in AP are in debt with money lender at much higher rates” !!  So clients are quoted at their convenience. All request are made for relaxing that, allow this , allow that etc- in short at institution focused and see what they are doing. Well institutions are means to an end and not an end in itself. Institutional survival is not important, which should be determined by markets and its users, it has to be client interest which is paramount.   

Well, the good thing about the earlier part of the conference was it had a lot of SHG members, mFI clients were absent by their presence. Invariably every SHG member, who spoke ( and some did sing)  spoke about savings , but most of the panellists were keen about the credit not adequately following.

After the tirade  by the grandpa - i left the conference in a huch, with a very bad headache...yes literally !    

Now i am inclined to "Stand for something or you'll fall for everything".....
Cheers



Wednesday, March 14, 2012

The little known effect of Bank Rate change!


 
On 13 Feb 2012, what did NOT appear to be a tectonic shift in the financial sector was the sudden spurt in bank rates by the Central Bank, perhaps unknown and unheard in the history. The Reserve Bank of India decided to change the Bank Rate, realigning it with the Marginal Standing Facility (MSF) rate. The upward shift of Bank Rate to 9.5 % was gigantic in real terms; as the same was kept unchanged at 6 % since April 2003. Perhaps such colossal leaps are unheard of in the history of the Central Bank and not many questions were asked by the alert media or finance experts. But, RBI just called it a “technical adjustment”, however, no such technical alteration was ever made in the bank’s history even when growth rates plummeted in the past or when inflation consistently touched double digits a few years back.  Perhaps, we are in an era of rates galore by the Central Bank; a base rate which could provoke clients; MSF rate, repo and reverse repo rates which could incite banker interests by spurring or draining liquidity. Then, has the RBI’s bank rates becomes innocuous now? With monetary policy signaling done through modulations in the reverse repo rate and the repo rates, Bank Rate now merely serve as penal rates for shortfalls in meeting reserve requirements for banks, or serve as reference rate for indexation purposes. Then, why this facade of rates including Bank Rate? Well it permits to obfuscate more than it reveals...  

With high bank rates, it could be the less alert Cooperative Banks that could face trouble as these institutions often unknowingly transgress the required reserve requirements, attracting penalties. While most of the other recent policy shifts by the Central Bank has enabled greater comfort for the beleaguered commercial banks, be it relaxation in prudential norms post the sectoral crisis, or the RBI gift by cut in CRR or the revised and magnified version of priority sector which could now include bank's credit to NBFCs or securitized loans as Priority Sector. But, the real bonanza for the Commercial Banks is the hidden one, that’s by defaulting in priority sector and parking it Rural Infrastructure Development Fund (RIDF) with NABARD, which fetches them the bank rate. Well no retailing headaches, no other transaction costs and no risk and an assured payment of a now attractive Bank rate.  
   
Well, the commercial banks including the foreign banks who are on a level playing field as regards the priority sector targets are concerned seemed to have really saved their skin. But, would the rural sector and development in hinterlands suffer? Would the credit absorption capacities stagnate with no supportive infrastructure being added on, well the obvious answer looks a certain yes !

Since 1995-96, the RIDF investments not only significantly addressed the eroding state in agriculture capital formation in the public sphere, but also brought about a significant change in upgrading the infrastructure in rural areas.  Economists and rural development experts have unequivocally exhorted a direct correlation between the index of infrastructure development and rural development. The RIDF manned by NABARD had made significant strides in fairly building the near absent rural infrastructure, which now serves as the lifeline in the rural hinterlands. While the expert’s assessments have suggested the need for exploring more and sustainable and cost effective resources for this infrastructure building process, the recent Bank rate changes could make it a costlier resource for the state government. In fact such high cost resource could push state governments away from accessing this resource which could deter the efforts at building primary and social infrastructure units in the hinterlands. And in hindsight, one sees that an innocuous rate like the present emasculated Bank Rate could do more harm for the hinterlands rather than help the cause.




Wednesday, March 23, 2011

Recapitalising RRBs : Green capital – an opportunity for DEVELOPMENT FINANCE INSTITUTIONS!!


The Finance Minister in the Budget presentation (2009-10) while commenting on the status of the RRBs mentioned that after the process of amalgamation, the recapitalization of RRBs with negative networth would be a priority area for the Government. This is particularly true as RRBs are expected to be the key players for enabling greater financial inclusion and permitting a range of experimentation in financial inclusion like Business Correspondents, franchisees with technology usage in rural hinterlands. These elucidations are also backed by government action asking RRBs to undertake an aggressive branch expansion programme and open at least one branch in 80 uncovered districts of the country as also the GoI setting up a Committee to look into aspects concerning the capitalization of weak RRBs (particularly) and also suggesting a roadmap to raise the CRAR of RRBs to nine per cent by March 2012.
With the amalgamation process on-stream in the last four years, 196 RRBs have now been merged into 82 RRBs. The monetary policy of RBI (oct, 2009) states that the process of recapitalization has since been completed with 27 RRBs fully recapitalized with an amount of Rs 1,796 crore as on 31 July 2009[1]. The available information as on 31 March 2009 also suggests that 22 RRBs have registered losses with accumulated losses to the tune of Rs 2325 crore as on 31 March 2009[2].
The newspaper reports also inform of GoI intending to infuse Rs.2000 crore towards recapitalisation of RRBs. However, capitalising the RRBs through tier 1 capital has connected issues, viz; concomitant contributions by the sponsor banks and the State Governments; with the later often delaying contributions or showing reluctance for the same. It is in this context that an option of enlarging the Tier II capital of RRBs has been viewed in this brief paper. Rejigging the Tier II capital is also equally (or perhaps the second best) measure of a bank's financial strength  from a regulators stand point. With forms of banking capital largely standardised by the Basel committee, and countries (regulators) accepting this with marginal modifications and suitable legislations, expansion of Tier II capital in RRBs looks a possibility, though limited.
2        Enhancing Tier II capital:
While tier 1 capital is considered as the core and more reliable form of capital, expansion of Tier II capital also brings efficiency gains to the organization by enhancing its leveraging capabilities. In the existing literature, there are several classifications of Tier II capital viz; undisclosed reserves, revaluation reserves, general provisions, hybrid instruments and subordinated term debt. Normally, supplementary capital is considered as Tier II capital up to an amount equal to that of the core capital[3]. Subordinated debt / debenture or subordinated loan is a chief component of the Tier II capital in banks; its a debt which ranks after other debts should a company fall into receivership or be closed. Thus, subordinated debt has a lower priority than other bonds of the issuer in case of liquidation during bankruptcy. Because subordinated debt is repayable after other debts have been paid, they are more risky for the lender of the money3. It is normally unsecured and has lesser priority than that of an additional debt claim on the same asset.
As a measure to enhance Tier II capital in RRBs through subordinated debt, DEVELOPMENT FINANCE INSTITUTION could consider subscribing to the subordinated debts/ or subordinated debenture issued by interested RRB. These subordinated debts or debentures could be customized with a clause restricting their end use of the proceeds to “Green initiatives” which is broadly defined by NABARD. Alternatively, the subscription to the subordinated debt / debenture floated by RRBs could be made after ensuring that the amounts so sought has already been used for funding green initiatives only (please see illustration).


Recapitalising RRBs through issue of Green Capital
 
 




Option 1
Funds clean technology Investments …
Or Environment 
Supportive ventures like forestation, green construction, carbon ventures etc
 















Option 2
RRB uses the funds mobilised for clean technology Investments …
Or Environment 
Supportive ventures …… etc
 













3        The Green initiatives
Environment and climate change has been concern which has been fiercely debated world over. While many of the projects being supported or funded by banks do possess less polluting solutions or mandatory pollution control mechanisms or devices, these should not qualify for coverage under this proactive venture for green capital support. These initiatives should be on its own be environmentally friendly or introduce new venture permitting Zero Emission technologies. These projects will have to be clearly defined viz; 

  1. Clean technology investments[4] 
  2. Green construction projects, Waste recycling etc
  3. Wasteland development projects- Land reclamation, sand-dune stabilisation etc
  4. Forestation projects
  5. Plantation and Horticulture projects
  6. Approved Carbon ventures, energy efficiency projects viz; solar pumps, solar energy

4        Some features of the suggested subordinated debt instrument[5]
 
Ø      How much of subordinated debt:

The amount eligible for inclusion in Tier II capital as subordinated debt will be subject to a maximum ceiling of 50% of the Tier I capital. Further as per extant instructions (for foreign banks) (ref: RBI circular no: DBOD. No. IBS. BC. 65/23.10.015/2001-02 February 14, 2002), the total of Tier II capital should not exceed 100% of Tier I Capital.

Ø      Features of the product:

Subordinated debt eligible to be considered as Tier II capital must:
1)     Have an original maturity of at least five years.
2)     Be subordinated to the claims of depositors
3)     Be unsecured
4)     The subordinated debt is not redeemable before maturity without prior approval of regulator.

Ø      Description of the terms of issuance of subordinated debt

The RRB may not be required to obtain shareholder approval for the issuance or for prepayment of subordinated debt. However, if Reserve Bank of India agrees to issuance of such capital[6], then such borrowings made by RRBs in compliance with the guidelines, would not require prior approval of RBI.

However, RRB may be required to obtain the RBI (regulators) prior approval to issue subordinated debt only if it has a negative networth regardless of whether the subordinated debt is intended to count as capital. Therefore, in such cases the RRB would be required to seek approval to issue or prepay subordinated debt.

Ø      Documentation:

The RRB should obtain a letter from the subscriber (DEVELOPMENT FINANCE INSTITUTION in the instant case) agreeing to give the loan for supplementing the capital base. The loan documentation should confirm that the loan given by subscriber would be subordinated to the claims of all other creditors of the bank. The loan agreement will be governed by, and construed in accordance with the law. Prior approval of the RBI should be obtained in case of any material changes in the original terms of issue

Ø      Redeeming subordinated debt:

Once any scheduled payments of principal begin, all payments shall be made at least annually. The amount of subordinated debt eligible for inclusion as Tier II capital is reduced by 20 percent of the original amount of the instrument (net of any redemptions) at the beginning of each of the last five years of the instrument’s life. Thus, subordinated debt with less than one year to maturity is not normally included in Tier II capital

Ø      Reserve requirements:

The total amount of RRB’s borrowings (under subordinated debt) is to be reckoned as liability for the calculation of net demand and time liabilities for the purpose of reserve requirements and, as such, will attract CRR/SLR requirements
5        Who benefits? 
This initiative could be considered as a win-win proposition for both the participating institutions viz; DEVELOPMENT FINANCE INSTUTITION and RRBs.

The twin objectives of DEVELOPMENT FINANCE INSTITUTION viz; Business and institutional development could be clubbed to address environmental concerns through green-capital or pro-environment investments. Further, with subordinated debts typically carrying a higher rate of risk and for longer durations normally differentially priced. Accordingly, contributors of subordinated debt (like DEVELOPMENT FINANCE INSTITITION in the instant case) could seek a higher compensation for the extra risk and longer duration.



 















Thus, the “green capital” could be priced in such a way that the price is profitable to DEVELOPMENT FINANCE INSTITUTION as also beneficial to the issuing RRB.  The pricing could be such to incentive the receiver Bank to commit its capital to a specified field of activities that would also earn at market related rates. With such enticements, there could be a compulsion for the RRB to diversify their lending activity and also address the concerns of funding environmental friendly projects and meeting the mission of sustainable development. 


[1] RBI: second quarter review of Monetary Policy 2009-10
[2] IDD, NABARD-HO, Mumbai
[3] Ref: http://en.wikipedia.org/wiki/Tier_2_capital   accessed on 13 Dec2009
[4]  Example : livestock is said to account for more than 20% of all carbon emissions.  Mootral is a new feed additive for ruminants, biotechnologically extracted from garlic, that helps animals reduce their methane emissions. 
[5] Could be very similar to the RBI instructions issued to foreign banks - RBI circular no : DBOD. No. IBS. BC. 65/23.10.015/2001-02 February 14, 2002
[6] if a suggestion is made by the Chakravorty Committee after weighing the pros and cons of the suggestion

Works at NABARD for poor HH / was Research Affiliate at CDS, Tvm / was Visiting Faculty on microFinance for MBA students NMIMS, Mumbai.