Building a Future-ready Banking System1
(Remarks delivered by Shri M. Rajeshwar Rao, Deputy Governor, Reserve Bank of India - June 16, 2022 - at
IMC's 12th Annual Banking & Finance Conference held in Mumbai)
Good morning, everyone!
1. Thank you for inviting me to deliver this inaugural address this morning. This
conference has been appropriately timed and quite aptly themed as we strive to
come out of the debilitating impact of the pandemic. While some parts of the
country are witnessing a rise in infections, the vaccines seem to have reduced its
impact and infections are not as severe as they were previously. Hopefully, going
forward we would be able to go on with our lives even as a new normal has
dawned.
2. Building a resilient financial system is a matter of collective effort and this has
been a critical learning from the pandemic and other crises. All of us are
stakeholders in building a robust and resilient financial system and our collective
and coherent response will make this endeavour less arduous. Against this
backdrop, let me reflect on the strengths and challenges for the financial sector
as we keep up our efforts to recalibrate a sustainable growth path.
3. The outbreak of COVID saw Governments across the globe impose
unprecedented lockdowns because it was considered necessary to contain the
spread of the virus. The consequential economic impact led to widespread
downward revisions in GDP projections with some countries, including ours,
experiencing GDP contraction, last heard of during the fallout of 2008
Global
Financial Crisis (GFC). COVID-19 pandemic also happened to be the first real test
of resilience of the global financial system since implementation of G20 reforms
following the GFC. Now, as the world slowly and steadily steps into the post
pandemic period, the collective focus should be on building stronger and resilient
economies that will deliver inclusive growth in a sustainable manner and be adept
at navigating future shocks. Evolving conditions in the Russia-Ukraine conflict,
increase in the prices of crude oil, food grains and other commodities, along with
rising inflation have just compounded these challenges.
Policy Response to COVID in India
4. Historically, every crisis has forced us to rethink and has almost always
brought out the best in us. In the context of our economy, we can safely say that
the Government and the Reserve Bank were closely monitoring the
developments both globally and in India and have calibrated the fiscal, monetary,
and regulatory responses depending upon the nature and intensity of the impact.
While we all are aware about the monetary policy measures and liquidity support
to the banking system along with targeted operations aimed towards supporting
NBFCs, MSMEs, MFIs, among others, let me focus a bit on the levers of the
prudential regulations which became enablers for extending relief to a large
spectrum of individuals, small business, and industries.
Calibrated Prudential Response
5. The prudential interventions had to be rolled out cautiously and in a phased
manner. During the initial phase of the pandemic, the focus was more on
enabling the borrowers and individuals to weather the immediate financial stress
through the loan moratoriums. Subsequently, even as the liquidity infusion
mitigated the initial impact of the pandemic on the markets, the financial stress
began to manifest as the borrowers started feeling the impact of business losses
on their balance sheets. It was at this juncture, that the Reserve Bank decided to
rollout targeted resolution frameworks.
6. While framing these measures there was a sense of déjà vu, as the experience
of similar dispensations extended during the earlier crisis periods were not very
encouraging. It is now argued, albeit with the benefit of hindsight, that some of
the regulatory dispensations on asset classification during the post-GFC period,
contributed in part to the build-up of NPAs in the subsequent years. But again,
the key lesson which was drawn from the experiences of that period was that the
problem assets need to be 'recognized' and 'provided for' at the earliest through
realistic assessments and also by building in sunset clauses for the regulatory
schemes to the extent possible.
7. Of course, the absence of credible insolvency regime at that point in time
was also one of the key factors responsible for the problems cropping up later.
Just compare that situation with the current one, when there is a formal
Insolvency and Bankruptcy Code in place since 2016. With the legal issues around
the IBC having been largely settled in a relatively short period, it has become a
preferred channel for resolution specially for large value accounts.
8. In this context, the resolution frameworks announced by the RBI in the wake
of Covid19 assimilated the learnings from the past, maintaining a fine balance
between prudence and financial stability on one hand while enabling a flexible
system for helping the COVID stressed borrowers on the other. The resolution
plans implemented under the frameworks included rescheduling of payments,
conversion of any interest accrued, or to be accrued, into another credit facility
and granting of moratorium based on an assessment of income streams of the
borrower for up to two years. The intent was that reliefs for each borrower was
to be tailored by banks to meet the specific problem being faced by the borrower
depending on need rather than have a broad- brush approach in dealing with the
issue. One other distinct feature this time around was a special Committee
constituted with banking experts to arrive at the sector specific benchmark
ranges for the identified financial parameters to be factored into each resolution
plan implemented by the lending institutions.
9. As things moved on, there came the resurgence of the pandemic during the
second wave. The Reserve Bank came up with the Resolution Frameworks 2.0,
this time primarily targeted for individuals, small businesses and MSMEs as the
lockdown measures were more localized in nature and the impact was much
limited.
Challenges
10. In implementing these resolution frameworks, banks encountered several
challenges. While establishing the viability of the borrower itself was a challenge
under the circumstances, managing the expectations was equally tough. The
expectations were multifarious given the widespread economic pain caused by
the pandemic. Some of the representations made at that time were to:
•
Extend the moratorium beyond August 31, 2020;
• Waive off interest/ interest on interest during the moratorium period;
• Permit moratorium for all accounts, instead of being at the discretion of
the lenders;
• Restructure all impacted accounts unconditionally;
•
Include all Standard accounts for resolution under the frameworks besides
NPA accounts and not just the accounts overdue for less than 30 days;
•
Customise the framework to address sector-specific issues such as real
estate, hospitality, other contact intensive sectors, etc;
•
Modify Kamath Committee recommendations relating to financial
parameters as they were perceived to be onerous and impractical to
achieve.
11. From a regulatory perspective, the response was dovetailed to address the
specific challenges unique to the economic fallout of the pandemic. Permitting
such accommodations as sought for, would have entailed significant economic
costs which could not have been absorbed by the banks and other lending
institutions without seriously denting their financials, which in turn would have
had negative implications for the depositors and other stakeholders besides
impacting financial stability.
12. It also needs to be appreciated that the RBI guidelines on moratorium and
Resolution Frameworks were discretionary and not mandatory for the lenders as
well as the borrowers. The lending institutions were permitted to extend the
moratorium to any borrower/ class of borrower in a transparent manner based
on their Board approved policies. Similarly, even the borrowers had the discretion
to decide whether or not to avail the moratorium, after weighing the pros and
cons. Giving a regulatory fiat under the circumstances was not considered
feasible on account of two reasons- first, we needed to differentiate between the
COVID induced stress and structural viability issues; and, second - the lending
institutions were expected to assess the viability of each borrower because they
had the pulse of borrowers' cash flows and both- risks and reward were theirs to
reap.
13. There were also demands to design sector specific schemes. As regards the
sector specific demands, it is one of the stiffest challenges for a regulator since it
gives rise to moral hazard issues. The approach thus was to help lending
institutions design their schemes in a suitable manner to build in such flexibility
in the Resolution Frameworks. The underpinning logic is that resolution plans are
ultimately commercial decisions of the lending institutions, and the regulator
should only specify the boundaries of the game through overarching steady-state
frameworks. The regulatory flexibility cannot and must not be used to solve the
structural issues affecting a particular sector and as such regulatory dispensations
can at best only provide a temporary relief. Overall, every regulatory forbearance
has its trade-off in terms of adverse incentives and unintended consequences.
Outcomes
14. As a result of the co-ordinated efforts of the Reserve Bank and Government,
in 2021-22, the year on year (YOY) growth in SCBs' credit gathered steam. The
success of regulatory interventions, provision of ample banking system liquidity,
coupled with the government's efforts to boost credit demand conditions in the
economy was reflected by credit offtake in various sectors. The momentum in
SCBs' credit offtake has been mostly positive since end-August 2021 and it
increased by 9.6 per cent on a year-on-year basis for 2021-22 as compared with
5.6 per cent the previous year. According to data on the sectoral deployment of
bank credit, credit to agriculture and allied activities grew by 9.9 per cent in
March 2022 vis-à-vis 10.5 per cent in March 2021. Bank credit growth remained
robust for a buoyant agriculture sector even during the COVID-19 pandemic
period with continued support of the government's interest subvention scheme.
Industrial credit growth improved steadily after Q1:2021-22 and accelerated to
7.1 per cent in March 2022. Credit to micro and small industries also posted a
faster growth of 21.5 per cent in March 2022 from 3.9 per cent during the
previous year. Credit growth to large industry, which was mainly in contraction
zone till December 2021, turned positive in January 2022 and stood at 0.9 per
cent in March 20222.
15. The preliminary assessment of health of the banking sector is encouraging.
The restructured portfolio of banks as a percentage of total advances had
expanded significantly post September' 2020 owing to restructuring of accounts
undertaken in view of the Resolution Frameworks announced by RBI. However,
the situation seems to be gradually stabilising.
16. The asset quality of the banks has improved and the GNPA and NNPA levels
of the banks have improved from the pre-pandemic levels. The fresh slippages
have broadly been brought under control. Banks have also enhanced their
provisions for impaired portfolios including provisions towards the restructured
accounts as envisaged under the Resolution Frameworks (Chart-1 & 2).
Chart-1: Asset Quality has been consistently
improving
9.23
8.32
7.45
7.33
6.97
5.97
3.66
2.88
2.43
2.27
2.1
1.7
Sep' 19 Mar' 20 Sep' 20 Mar' 21 Sep' 21 Mar' 22
GNPAs (%) NNPAs (%)
Chart-2: Provision Coverage has improved while
slippages show early signs of moderation
86.8
88 3.73 4
3.8
85.8
3.55
86 84.8
83.8
84 3
2.83 2.81
81.2
82
80 2
77.0
78
Percentage Percentage
76 1
0.74
74
72 0
Sep' 19 Mar' 20 Sep' 20 Mar' 21 Sep' 21 Mar' 22
Provision Coverage Ratio (Write-Off Adj) (%) Slippage Ratio (annualized)
Source: RBI Supervisory Returns; Data for Mar-22 is provisional.
17. The banks have also facilitated timely credit offtake to catalyse the economic
recovery. Needless to mention the ECLGS scheme rolled out by the Government
too effectively dovetailed with the overall efforts in mitigating the risk aversion
amongst the lending institutions.
Chart-3: Capital position has improved along with
18 growth in advances 140
120
17 17.02
100
16.22
16.25
80 Crore
16.16
16
lakh
60
119
Percentage
106 108
96 101 101 Rs.
15.33
40
15
15.1
20
14 0
Sep' 19 Mar' 20 Sep' 20 Mar' 21 Sep' 21 Mar' 22
Gross Loans and Advances Capital Ratio (CRAR)
Source: RBI Supervisory Returns; Data for Mar-22 is provisional.
18. These efforts have also found favour amongst the investors and the markets
too have supported banks in their capital augmentation measures. Today, most
of the banks have a comfortable capital position which should position them well
to support economic recovery (Chart-3). These data points do give us a degree of
comfort at this juncture. However, we may also have to wait a bit longer to see
how the impact completely plays out. While we have attempted to combat the
effects of pandemic on the financial system, the task is only half done, we have
to ensure that the financial system escapes unscathed as we exit from the
pandemic driven regulatory forbearances.
19. The pandemic also saw financial sector enjoying a favourable momentum
with increase in liquidity, flow of credit and government spending on relief
programs. It is increasingly getting debated in global forums as to whether the
pandemic induced measures have led to build up of leverage and debt over-hang
in non-financial sectors. Prudence, therefore, has to be exhibited by banks to
ascertain whether the current levels of asset quality being exhibited is on account
of improvement in fundamentals of business on account of deleveraging and
efficiency gains or on account of support extended by the authorities through the
measures elucidated above. We expect banks and other financial institutions to
pro-actively undertake stress testing of their loan books subjecting them to
various levels of stress including extreme scenarios to estimate the loss
absorption limits available at disposal and take measures to augment the same
wherever necessary.
The way forward
20. As a regulator, we still have miles to go before we sleep and therefore,
continue to contemplate and roll out measures to improve the resilience of
financial sector through planned and calibrated regulatory interventions. The
Scale-Based Regulatory Framework for NBFCs, activity-based regulation for
microfinance sector and guidelines to improve governance in private banks are
few examples of our approach. As we continue to roll out regulatory measures,
let me mention a few of them which are in the pipeline which would help make
the banking sector more resilient to withstand economic shocks in times to come.
21. One of the key lessons which we can draw from our Covid experience is that
the effectiveness of any policy response in crisis situations is critically dependent
on the strength of the financial sector balance sheet. The report put out by the
Basel Committee on early lessons from the Covid-19 pandemic finds that the
increased quality and higher levels of capital and liquidity held by banks have
helped them absorb the impact of the Covid-19 pandemic. It would therefore be
imperative to work towards putting in place appropriate prudential and
accounting frameworks that enhance institutional resilience.
22. To achieve this, we have come out with a Discussion Paper in January this
year seeking comments from the stakeholders for a comprehensive review of the
prudential norms for classification, valuation, and operation of the investment
portfolio. The guidelines for valuation of investments were last revised in the year
2000. Since then, the domestic financial markets had grown in leaps and bounds
in terms of volumes, liquidity, and underlying technology. Illustratively, in the
Government Securities market we have seen the operationalisation of an
anonymous electronic order matching system viz. NDS-OM, DVP-III,
establishment of Clearing Corporation of India Limited (CCIL) as a central
counterparty and introduction of Liquidity Adjustment Facility (LAF) and a whole
suit of trading and hedging products such as market repo, Triparty Repo, Interest
rate futures and options, etc. At the international level too, there have been
several changes in the regulatory norms and accounting practices. While RBI has
been tweaking the guidelines in response to situations as they emerged, there
was a widening gap between our norms and the global standards and practices.
A comprehensive review was therefore overdue and called for.
23. The Discussion Paper (DP) proposes radical changes which are designed to
give greater flexibility to banks in the management of their investment portfolio
while addressing concerns through enhanced disclosure. The idea is to align the
prudential framework with global standards, while retaining elements which are
germane to the domestic context. Some of the proposals in the Discussion Paper
are symmetric recognition of fair value gains and losses, removal of various
restrictions on investment portfolio such as the ceilings on investments in held to
maturity (HTM), allowing non-SLR securities to be included under Held to
Maturity (HTM) book, etc. The proposals in the DP, especially those on
disclosures, would promote transparency and market discipline while giving the
increased degree of freedom to banks. We are in advanced stages of finalising
the revised norms based on feedback received and hope to issue guidelines on
the new framework soon.
24. Another issue that is engaging our attention is the framework for
provisioning on loan exposures. Currently, banks operating in India are required
to make loan loss provisions on incurred loss model, wherein provisions are made
after occurrence of default. However, loan default itself is a lagging indicator of
stress, or more to say an outcome of build-up of stress over a period in the loan
account. Thus, incurred loss approach is inefficient since it may prove pro-cyclical
during economic downturns which can severely impact the health of banks as
well as the financial system.
25. This also meant that recognition and crystallisation of credit risk usually lags
the actual increase in credit risk for the banks. Such delays in recognizing
expected losses under an "incurred loss" approach were found to exacerbate the
downswing during the financial crisis of 2007-09. Faced with a systemic increase
in defaults, the delay in recognizing loan losses resulted in banks having to make
higher provisions which eroded the capital maintained precisely at a time when
banks needed to shore up their capital, thereby affecting their resilience and
exacerbating the systemic risks. Further, the delay in recognizing loan losses and
consequent higher dividend pay-outs reduced internal accruals to the capital.
26. This experience prompted the G-20 and the Basel Committee on Banking
Supervision (BCBS) to recommend to accounting standard setters to modify the
provisioning practices to incorporate a more forward-looking approach rather
than to require the losses to happen before they are recognized. This encouraged
the move towards adoption of provisioning standards that require the use of
expected credit loss (ECL) models rather than incurred loss models. In principle,
the approach requires a credit institution to estimate expected credit losses
based on forward-looking estimations rather than wait for credit losses to be
incurred before making corresponding loss provisions.
27. However, banks in India follow the "incurred loss" approach for loan loss
provisioning, while the bigger non-banking financial companies (NBFCs) are
following the more forward looking "expected credit loss" approach for
estimating credit losses. Therefore, to achieve global convergence in regulations,
we propose to issue a Discussion Paper on introduction of a framework on
Expected Credit Loss (ECL) for banks. The idea is to formulate principle-based
guidelines, supplemented by regulatory backstops wherever necessary. The
Discussion Paper would seek to solicit comments from all the stakeholders,
including the business community, on the proposed approach and the final
contours of the transition will take into account the feedback received.
Concluding Remarks
28. The last two years have been tough on everyone but as individuals and a
nation we have exhibited resilience and fought our way back. As we slowly step
into the post pandemic world, we must strive to be ahead of the curve in
designing and nurturing a financial system that is resilient and sustainable. As a
closing thought I would like to leave you with a quote by Nelson Mandela:
"The Greatest Glory in living lies not in never falling, but in rising every time we
fall"
And indeed, we shall rise strong. Wishing you all the very best! Thank you.
*****