R Gandhi: Financial consumer (depositor) protection - reflections on
some lingering questions
Text of the M R Pai Memorial Lecture by Mr R Gandhi, Deputy Governor of the Reserve
Bank of India, at the Indian Merchant's Chamber (IMC), Mumbai, 8 September 2015.
* * *
Assistance provided by Ms Reena Banerjee is gratefully acknowledged.
1. At the outset, let me express my pleasure at being here today with you on the
occasion of the M R Pai Memorial Lecture; it is my proud honour to have presented the
Eleventh M R Pai Memorial award to Madam Smt K J Udeshi, former Deputy Governor,
Reserve Bank and former Chairperson, Banking Codes and Standards Board of India
(BCSBI). It is normal for teachers to be presenting awards and prizes to their students and
wards; but it is a strange thing for a student to present an award to his teacher. The M R Pai
Foundation has just caused that. As young boys and girls, I am sure, many of you, like me,
would have day dreamed to present awards and prizes to our teachers. Today, thanks to the
M R Pai Foundation, my such daydream has become a reality. Smt Udeshi has been a
mentor to me and many more in the Reserve Bank. With her charming disposition and
dedication, her staunch adherence to principles and high values and varied knowledge and
expertise, she had been a well-respected coach and mentor; and also a strict disciplinarian.
Having been a sports person, she knew the value of playing by rules and importance of fair
play. That definitely helped her in being a strict disciplinarian when she was in the Reserve
Bank and also during her tenure as the first Chair-person of the BCSBI. I am very grateful to
you, Madam, for giving me this privilege to honour you with the M R Pai Memorial Award.
2. As is well known, Shri M R Pai was a multi-faceted personality, but his greatest
contribution lay in starting the consumer movement in India. He was active in all areas, and
confronted monopolistic giants like the telephone services, the Indian Airlines, and more
particularly the banks, earning the title of Champion of the Consumer. Consumer protection
and consumer activism has come a long way since those times. The best example of this is
in what the Financial Sector Legislative Reforms Commission (FSLRC) has said in their
Report in 2013.
"Consumer protection: A prime motivation of all financial regulation is to protect
consumers. The relationship between financial firms and their customers is one
where, many times, the outcomes may harm customers. These problems are not
sporadic or accidental; but are often rooted in basic problems of information and
incentives and will not be alleviated through financial literacy campaigns. The
central purpose of financial regulation is to intervene in the relationship between
financial firms and their customers, and address market failures. This requires a
comprehensive consumer protection framework that covers both the problem of
prevention (interventions that induce financial firms towards fair play) and cure
(addressing consumer grievances)".
3. I am sure this is music for the great soul of Shri Pai. I will be discussing the essential
elements of, and the need for consumer protection, as well as initiatives taken both globally
and in India with specific reference to the financial sector.
Consumer protection - role of the Reserve Bank
4. Protection of the interests of the depositors has been one of the mandates of the
Reserve Bank. The Banking Regulations Act 1949 is replete with the phrases like "in the
interests of depositors" wherever it entrusts powers to the Reserve Bank; be it granting of a
banking license or cancellation thereof, giving directions on advances or on any banking
matter, applying for suspension, winding up, or amalgamation of banks, approving
appointment of CEOs or additional directors, removal of CEOs, all these are to be exercised
keeping, among other things, the depositors interests in view. But the services provided by
the banking sector today are much more than only deposit services. This rapid increase in
the nature of financial services has highlighted the need for robust regulation as well as
consumer education to protect and empower consumers. The need to extend provision of
banking services to underserved sections of the population whose financial literacy is low,
combined with the growing complexity of financial products and the use of technology can
increase the risk of mis-selling. Financial consumer protection should be reinforced and
integrated with other financial inclusion and financial education policies. If such protection is
absent, the benefits to economic growth of expanded financial inclusion may be severely
undermined. Financial consumer protection also contributes to strengthening financial
stability. Taking these factors into account, Reserve Bank has recently articulated its Core
Purpose, Values and Vision as its commitment to the Nation to include regulating markets
and institutions under its ambit to ensure financial system stability and consumer protection.
5. Apart from the Reserve Bank, the Government of India has also been concerned
with financial consumer protection. The Financial Sector Legislative Reforms Commission
(FSLRC), about which I had referred to earlier, was constituted by the Ministry of Finance in
March 2011, and was asked to comprehensively review and redraw the legislations
governing India's financial system. In its report submitted to the Ministry of Finance in March
2013, containing a draft Indian Financial Code to replace the bulk of the existing financial
laws, consumer protection was also highlighted.
6. The work of the Commission in the field of consumer protection marks a watershed
compared with traditional approaches in Indian financial law. It marks a break with the
tradition of caveat emptor, the "buyers beware" concept, and moves towards a position
where a significant burden of consumer protection is placed upon financial firms. The draft
Code first establishes certain basic rights for all financial consumers. In addition, the Code
defines what is a unsophisticated consumer, and an additional set of protections are defined
for these consumers. The proposed basic protections are:
a) Financial service providers must act with professional diligence;
b) Protection against unfair contract terms;
c) Protection against unfair conduct;
d) Protection of personal information;
e) Requirement of fair disclosure;
f) Redress of complaints by financial service providers.
7. In addition, unsophisticated consumers will have three additional protections:
a) The right to receive suitable advice;
b) Protection from conflicts of interest of advisors;
c) Access to the redress agency for redress of grievances.
8. The regulator will be given an enumerated set of powers through which it must
implement these protections. Alongside these objectives and powers, the regulator will also
be given a set of principles that guide the use of the powers.
9. The Reserve Bank has welcomed this suggested approach to consumer protection.
The draft IFC is currently under examination.
Consumer protection - what does it imply and how will it help?
10. Financial consumer protection sets clear rules of conduct for financial firms
regarding their retail customers. It aims to ensure that consumers: (1) receive information to
allow them to make informed decisions, (2) are not subject to unfair or deceptive practices,
and (3) have access to recourse mechanisms to resolve disputes. Complementary financial
literacy initiatives are aimed at giving consumers the knowledge and skills to understand the
risks and rewards of using financial products and services - and their legal rights and
obligations in using them. Clear rules of conduct for financial institutions, combined with
programs of financial education for consumers, will increase consumer trust in financial
markets and will support the development of these markets1.
International initiatives regarding consumer protection - initiatives by International
organisations
11. Globally, several initiatives have been taken for consumer protection by both the
international standard setting bodies and the regulators. Regarding initiatives taken by
standard setting bodies, the G20 requested the OECD / FSB and others to articulate
principles on Financial Consumer Protection. These broadly state that financial consumer
protection should be an integral part of the legal, regulatory and supervisory framework and
there should be equitable and fair treatment of consumers with special attention dedicated to
the needs of vulnerable groups. It should include access to adequate complaints handling
and redress mechanisms that are accessible, affordable, independent, fair, accountable,
timely and efficient. The G20 / OECD Task Force on Financial Consumer Protection is
currently focused on supporting the implementation of the High-level Principles. The OECD
is workingon how to enhance financial consumer protection, which includes determining what
is required to help consumers gain the confidence, knowledge, information, security and
choices they need to enable them to fully participate in financial markets. In 2011, the
Financial Stability Board published its report on Consumer Finance Protection with particular
focus on credit.
12. Consumers International (CI) is a world federation of consumer groups. Recently, CI
conducted a global survey of 80 member jurisdictions to assess the state of consumer
protection across the world. Key findings include:
• Since 2012, Members felt the top three advances they had witnessed in consumer
protection were from: new legislation, consumer representation and regulation and
enforcement. Increasing consumers' awareness of their rights was also an important
factor.
• Members felt that the three main factors that contribute to consumer detriment are:
economic and development challenges, lack of regulation and enforcement; and
poor quality products and services.
Financial Consumer Protection
13. Various national initiatives:
a) In USA, the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010
(Dodd-Frank Act) established the Consumer Financial Protection Bureau (CFPB) to
protect consumers by carrying out federal consumer financial laws. The CFPB is
authorized to exercise its authority to ensure that: (1) Consumers are provided with
timely and understandable information to make responsible decisions about
transactions involving consumer financial products and services; (2) Consumers are
protected from unfair, deceptive, or abusive acts and practices and from
discrimination; (3) Outdated, unnecessary, or unduly burdensome regulations
concerning consumer financial products and services are regularly identified and
addressed in order to reduce unwarranted regulatory burdens; (4) Federal consumer
financial law is enforced consistently, without regard to (service providers') status as
depository institutions, in order to promote fair competition; and (5) Markets for
consumer financial products and services operate transparently and efficiently to
facilitate access and innovation.
b) In UK, the Financial Services Act of 2012 set up the Financial Conduct Authority
(FCA) which is responsible for regulating the consumer credit industry from 1 April
2014, taking over the role from theOffice of Fair Trading. The FCA supervises banks
to ensure they treat customers fairly, and encourages innovation and healthy
competition. The authority has significant powers, including the power to regulate
conduct related to the marketing of financial products. It is able to specify minimum
standards and to place requirements on products. In addition, the FCA is able to ban
financial products for up to a year while considering an indefinite ban; it will have the
power to instruct firms to immediately retract or modify promotions which it finds to
be misleading, and to publish such decisions.
c) In the European Union, the European Banking Authority (EBA) promotes a
transparent, simple and fair internal market for consumers in financial products and
services. The EBA seeks to foster consumer protection in financial services across
the EU by identifying and addressing detriments consumers may experience, or are
at risk of experiencing, in their dealings with financial firms. The role and tasks of the
EBA related to consumer protection and financial activities include: collecting,
analysing and reporting on consumer trends in the EU; reviewing and coordinating
financial literacy and education initiatives; developing training standards for the
industry; contributing to the development of common disclosure rules; monitoring
existing and new financial activities; issuing warnings if a financial activity poses a
serious threat to the EBA's objectives as set out in the its funding Regulation; and
temporarily prohibiting or restraining certain financial activities, provided certain
conditions are met. The market is governed by the various directives issued by the
EU such as the Directives on Consumer Credit.
d) In Hong Kong, the industry-established Code of Banking Practice (CoBP) promotes
good banking practices by setting out the minimum standards which financial
institutions should follow in their dealings with customers. The Code is a
nonstatutory one issued by the financial industry associations for voluntary compliance
by financial institutions. The Hong Kong Monetary Authority (HKMA) expects
financial institutions in Hong Kong to comply with the CoBP and will monitor
compliance as part of its regular supervision. There are also examples of
international voluntary codes.
Consumer protection in India - initiatives by the Reserve Bank
14. Consumer protection has been an ongoing effort of Reserve Bank. For greater
effectiveness and a more focused approach, several committees were appointed on aspects
of customer service in banks from time to time, including the Talwar Committee (1975), the
Goiporia Committee (1990), the Tarapore Committee (2004), the Sadasivan Working Group
(2006), and the Damodaran Committee on Customer Service (2010). The importance of
consumer protection was also highlighted in the Committee on Financial Sector Reform
chaired by Dr Raghuram G. Rajan. The RBI had set up the Banking Ombudsman Scheme to
act as a visible and credible dispute resolution agency for common persons utilizing banking
services and to ensure redress of grievances of users of banking services in an inexpensive,
expeditious and fair manner that provides impetus to improve customer services in the
banking sector on a continuous basis.
Some recent initiatives by the Reserve Bank
15. Let me now detail some recent initiatives by the Reserve Bank regarding consumer
protection:
a) Most important perhaps was the release of a Charter of Customer Rights, which
enshrined broad, overarching principles for protection of bank customers and
enunciates the "five" basic rights of bank customers. These are: (i) Right to Fair
Treatment; (ii) Right to Transparency; Fair and Honest Dealing; (iii) Right to
Suitability; (iv) Right to Privacy; and (v) Right to Grievance Redress and
Compensation. The Reserve Bank also advised the Indian Banks' Association (IBA)
and the Banking Codes and Standards Board of India (BCSBI) to formulate a "Model
Customer Rights Policy" encapsulating the principles enshrined in the Charter.
Initially, all the scheduled commercial banks, regional rural banks and urban
co-operative banks are expected to prepare their own Board approved policy
incorporating the five basic rights of the Charter which, among other things, would
contain a monitoring and oversight mechanism for ensuring adherence.
b) The Reserve Bank of India undertook several measures on KYC, including releasing
a note along with a poster and a booklet comprising a few common questions
relating to Know Your Customer (KYC) norms for opening bank accounts. The
objective of this is to bring awareness among the general public about the KYC
simplification measures taken by the Reserve Bank in the recent times with a view
to helping the common man in opening bank accounts.
c) The measures taken for simplification of KYC include prescribing a single document
for proof of identity and proof of address, removing the requirement for separate
proof of address for current address, making KYC a bank process rather than a
branch process, relaxing the officially valid documents (OVDs) for low risk
customers, increasing the time intervals for periodic updation of KYC for existing low
/ medium and high risk customers from 5/2/1 years to 10/8/2 years, respectively.
d) Further, banks need not seek fresh proofs of identity and address at the time of
periodic updation, from those customers who are categorised as "low risk", in case
of no change in status with respect to their identities and addresses. A
selfcertification by the customer to that effect should suffice in such cases. Banks may
not insist on physical presence of such low risk customer at the time of periodic
updation. Further, if an existing KYC compliant customer of a bank desires to open
another account in the same bank, there should be no need for submission of fresh
proof of identity and / or proof of address for the purpose. Further, Business
Correspondents and Business Facilitators were allowed to act as Customer Service
Point (CSP) for e-KYC purpose.
e) To mitigate the difficulties faced by transgender persons in opening accounts, banks
were directed to include "third gender" in all forms / applications, etc. as a valid
classification.
f) Initiatives were taken to further enhance transparency in pricing of credit, based on
the recommendations of Working Group on Pricing of Credit. Banks were advised to
display on their website inter alia, the interest rate range of contracted loans for the
past quarter for different categories of advances granted to individual borrowers
along with mean interest rates for such loans; the total fees and charges applicable
on various types of loans to individual borrower which should also be disclosed at
the time of processing of loan for transparency and comparability and to facilitate
informed decision making by customers; Annual Percentage Rate (APR) or such
similar other arrangement of representing the total cost of credit on a loan to an
individual borrower so as to allow customers to compare the costs associated with
borrowing across products and / or lenders. Apart from displaying such information,
banks were also advised to provide a clear, concise, one page key fact statement /
fact sheet, to all individual borrowers at every stage of the loan processing as well
as in case of any change in any terms and conditions, which would also be included
as a summary box to be displayed in the credit agreement.
g) While undertaking insurance distribution business, either under the corporate
agency or broking model under the relevant IRDA Regulations, banks were directed
to put in place a system of assessment of the suitability of products for customers,
and classify products into universally suitable products and complex products which
necessarily require customer need assessment prior to sale. It should be ensured
that there is a standardized system of assessing the needs of the customer and that
initiation / transactional and approval processes are segregated. Banks should treat
their customers fairly, honestly and transparently, with regard to suitability and
appropriateness of the insurance product sold. There should be no violation either of
Section 10(1) (ii) of the BR Act, 1949 or the guidelines issued by IRDA in payment of
commissions / brokerage / incentives. This may be factored in while formulating a
suitable performance assessment and incentive structure for staff. Further, it must
be ensured that no incentive (cash or non-cash) should be paid to the staff engaged
in insurance broking / corporate agency services by the insurance company. The
bank should not follow any restrictive practices of forcing a customer to either opt for
products of a specific insurance company or link sale of such products to any
banking product. It should be prominently stated in all publicity material distributed
by the bank that the purchase by a bank's customer of any insurance products is
purely voluntary, and is not linked to availment of any other facility from the bank.
Further, the details of fees / brokerage received in respect of insurance broking /
agency business undertaken by them should be disclosed in the "Notes to
Accounts" to their Balance Sheet. A robust internal grievance redressal mechanism
should be put in place along with a Board approved customer compensation policy
for resolving issues related to services offered. It must also ensure that the
insurance companies whose products are being sold have robust customer
grievance redressal arrangements in place. Further, the bank must facilitate the
redressal of grievances of the customer.
h) To encourage the usage of credit and debit cards, Reserve Bank has issued various
instructions on security of card transactions and risk mitigation measures, including
directions on online alerts as well as on additional factor of authentication which
have significantly increased customer confidence in using cards. Some initiatives
taken recently are as under:
• To avoid inconvenience, the requirement of Additional Factor of Authentication
for small value card present transactions was relaxed for customers making
small value payments on contactless cards up to a maximum value of
₹ 2,000/- per transaction subject to certain conditions.
• Banks were also advised in the interest of customer awareness and protection
to clearly explain to customers about the technology, its use, and risks while
issuing such contact less cards; indicate the maximum liability devolving on
the customer, if any, at the time of issuance of such cards along with the
responsibility of the customer to report the loss of such cards to the bank; and
to put in place robust mechanism for seamless reporting of lost / stolen cards,
which can be accessed through multiple channels.
• To further put in place risk mitigation measures for customers using various
types of cards, banks are advised that with effect from Feb 1, 2016 all new
cards issued - debit and credit, domestic and international - by banks shall be
EMV chip and pin based cards.
i) To alleviate the hardships faced by pensioners who are deprived of regular pension
payments in case of misplacement of life certificates, all agency banks handling
government pension payments were advised to issue a duly signed
acknowledgement to pensioners on receipt of the life certificate submitted in
physical form. Banks were also advised to promote the use of digital life certificates
among pensioners, which would eliminate the need for physical presence at
branches and issue of acknowledgement.
j) To ensure transparency in the promotional material and to build an enduring
relationship with the customers, correlate a product brand name to the name of the
entity / company authorised under the PSS Act, all authorised entities issuing
payment products were advised that all the information available to the public
regarding the product as advertisements, on website, application form, etc. should
prominently carry the name of the entity / company authorised by RBI under the
PSS Act.
k) Banks were advised to ensure that penal charges on non-maintenance of minimum
balances in savings bank accounts are directly proportionate to the extent of
shortfall observed, reasonable and not out of line with the average cost of providing
the services that the balance in the savings account does not turn into negative
balance solely on account of levy of charges for non-maintenance of minimum
balance the bank should notify the customer clearly by SMS / email / letter etc. that
in the event of the minimum balance not being restored in the account within a
month from the date of notice, penal charges will be applicable. In case the
minimum balance is not restored within a reasonable period, which shall not be less
than one month from the date of notice of shortfall, penal charges may be recovered
under intimation to the account holder.
l) To further boost the quality of customer service and to ensure that there is undivided
attention to resolution of customer complaints in banks, all public sector banks and
select private sector and foreign banks were advised to appoint an internal
ombudsman thereby providing a forum available to bank customers for grievance
redressal before they approach the Banking Ombudsman.
m) Apart from issuing instructions to banks, the Reserve Bank also issues cautionaries
to members of the general public. We cautioned members of the public against an
app (application) doing rounds on WhatsApp purportedly to facilitate checking of
balance in customers' bank accounts.
n) The Reserve Bank of India also cautioned the public against Multi-level Marketing
(MLM) activities explaining the functioning of these entities, and advising that falling
prey to such offers can result in direct financial losses, apart from the fact that these
are cognizable offences under the Prize Chit and Money Circulation (Banning) Act
1978.
Some lingering questions
16. I understand that in many a depositor's mind, several questions linger and they
eagerly await the regulator's response. As I understand, it is not the answer they seek but
the rationale and explanation for our actions and the so called "inactions". It is our duty to
explain. Let me discuss some of these contemporary issues and questions.
Deposit insurance
17. First issue that I want to discuss relates to deposit insurance. More specifically, the
issue relating to increasing the limit on deposit insurance cover. Deposit Insurance protects
depositors against the loss of their deposits in case a deposit institution is not able to meet its
obligation to the insured depositors. In India, the commercial banks, Regional Rural Banks
(RRBs), Local Area Banks (LABs) and co-operative banks are covered by deposit insurance.
There has been a persistent demand from stakeholders and public representatives in the
recent past for a hike in deposit insurance cover from the current level of ₹1 lakh. The
Deposit Insurance Systems around the world have evolved over time by reforms adopted by
various jurisdictions based on experience, international developments, guidance from supra
national bodies like IMF, International Association of Deposit Insurers (IADI and other
environmental changes from time to time. One of the basic principles of deposit insurance is
that the deposit insurance system should cover at least 80% of the deposit accounts and
20-30% of the total assessable deposits. In India, we have surpassed this norm in a
substantial way; as on March 31, 2015, our DICGC's deposit insurance covers as high as
92.3% of the deposit accounts and 31% of the total assessable deposits.
18. Therefore, before deciding on this demand, we have to factor in two major issues
viz., the moral hazard issue and the risk based premium issue. Deposit insurance inherently
creates a moral hazard i.e. the parties to the deposit insurance viz. a bank and its insured
depositors get an incentive to take more risk because the costs of risk, in whole or in part,
are borne by others, generally a deposit insurance agency, in our case the Deposit Insurance
and Credit Guarantee Corporation (DICGC). Most deposit insurance systems initially adopt
an ex-ante flat-rate premium system because they are relatively simple to design, implement
and administer. However, these systems were open to criticism in that they do not reflect the
level of risk that banks pose to the deposit insurance system. Flat-rate premium systems
have also been viewed as being unfair as "low-risk" banks are required to pay the same
premium as "higher-risk" banks. With no inbuilt incentive for "higher risk" banks to improve
their risk profile, a flat rate system would accentuate the moral hazard problem. Therefore
the primary objective of most differential premium systems has been to provide incentives for
banks to avoid excessive risk taking, minimise moral hazard and introduce more fairness into
the premium assessment process. Introducing fairness into the system bolsters industry
support for deposit insurance. A hike in cover without calibrating the premium rates to the
risk profile of the insured banks only exacerbates the moral hazard. Recognising this, a
Committee on Differential Premium System for Banks in India (Chairman: Shri Jasbir Singh)
has been constituted by DICGC and has submitted its Report yesterday. We hope that
introduction of Risk Based Premium system will make ground for considering raising the
insurance cover from the present ceiling of ₹ 1 lakh.
Structure of differentiated banks and consumer protection
19. You have noticed that we have recently granted "in principle" licenses to 11 entities
to form Payments Banks in the country; and several of you nurture a vague feeling about
how these differentiated banks will subserve consumers interests. I want to explain to you
how we have carefully structured the regulatory arrangements of these banks from the
perspective of consumer protection.
20. As you will recall, consequent to the discussion paper called "Banking Structure in
India - The Way Forward", brought out by the Reserve Bank in August 2013, and the
recommendations of the Committee headed by Shri Nachiket Mor, on Comprehensive
Financial Services for Small Businesses and Low-Income Households to look into the issues
relating to financial inclusion, in November 2014 we announced our intention to grant
licenses to two types of differentiated banks viz., the Payments Banks and the Small Finance
Banks.
21. The objective of setting up of Payments Banks will be to further financial inclusion;
the strategies will be by providing (i) small savings accounts and (ii) payments / remittance
services to migrant labour workforce, low income households, small businesses, other
unorganised sector entities and other users. The scope of the activities permitted for the
Payment Banks included a. Acceptance of demand deposits. Payments Bank will initially be
restricted to holding a maximum balance of ₹ 1 lakh per individual customer, b. Issuance of
ATM / debit cards c. Payments and remittance services through various channels and some
ancillary activities.
22. The deposits collected by them can be only in current or savings account; they
cannot accept fixed deposits. The payments banks are prohibited from lending activity. They
can deploy the deposits largely in government securities only; a small portion, up to 25% of
their deposits, can be held in deposits with other banks.
23. The consumer protection aspects of the design are as follows: The public deposits
in the Payments Banks will be covered by the deposit insurance of the DICGC. As the
deposit ceiling is ₹ 1 lakh and the deposit insurance ceiling is also ₹ 1 lakh, it means that the
depositors of the Payments Banks will be fully insured. Actually, there were arguments why
Payments Banks should be covered under deposit insurance, when their assets will be fully
in high quality liquid assets of government securities and high credit bank accounts. Still, we
concluded that such an assurance as deposit insurance is needed for the depositors of
payments banks, as the concept is new and depositors will need additional confidence.
24. As the payments bank may operate in remote areas mostly through BCs, ATMs and
other networks, the payments bank will be required to have at least 25 per cent of physical
access points including BCs in rural centres. Further, we require that a controlling office for a
cluster of access points should also be established for control over various outlets and
customer grievance redressal. We have insisted that the bank should have a high powered
Customer Grievances Cell to handle customer complaints. The payments banks will also
come under the purview of RBI's Banking Ombudsman Scheme, 2006.
25. Now, let me explain the arduous process we adopted for granting "in principle"
licence. I want to emphasize here that granting banking licenses is not a tick box exercise; it
needs to be based on the high regulatory comfort about the "fit and proper" position of those
who will manage the bank. Further, banks are high leverage organisations; and whose
moneys they leverage? They actually leverage public deposits. Should we not require
highest degree of assurance about the entities with whom public moneys can be entrusted?
Will this not actually mean, as we said in our Guidelines, licenses shall be issued on