H R Khan: Banks in India - challenges and opportunities
Keynote address by Mr H R Khan, Deputy Governor of the Reserve Bank of India, at the
BFSI Conference 2014, organized by SBICap Securities, Mumbai, 12 June 2014.
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The speaker gratefully acknowledges the contributions of Shri. Prakash Baliarsingh, Smt. Nilima Ramteke and
Shri Tulasi Gopinath of the Reserve Bank of India.
1. Smt. Arundhati Bhattacharya, Chairman, State Bank of India, Shri. Deepak Parekh,
Chairman HDFC, Shri. V. G. Kannan, Chairman, SBI Cap Securities Ltd., Shri. Mani
Palivesan, Managing Director, SBI Cap Securities Ltd, distinguished panelists and
participants. It is a pleasure to address the BFSI Conference 2014 which features panel
discussions on topical issues in banking. The first panel discussion, interestingly, is on
Disruptive Themes for Next Decade. The word disruptive is usually used with a negative
connotation and therefore to be chosen as the theme for the panel discussion is a bold
decision. On a careful rethinking, it seems disruptions can be used as synonym for
challenges posed by paradigm shifts in the environment, thereby questioning the way things
are done today. These challenges are opening the opportunities which banks should harness
if they want to remain relevant in the financial service space in India. Therefore, in my
address I intend to focus on some of these challenges & opportunities.
2. As at end-March 2013, there were 155 commercial banks including 151 scheduled
commercial banks (SCBs) of which Regional Rural Banks were 64. The total number of bank
offices at end-March 2014 is estimated to have reached 1,15,014 and the population per
office, 1,10,052. In terms of the regional spread of the bank offices, while North Eastern
region accounted for about 2 per cent (2,785 bank offices), Southern region accounted for
about 28 per cent (30,925 bank offices). Despite such vast expansion of banking network,
banking penetration still remains relatively low. According to the CRISIL's financial inclusion
index, Inclusix, which covers three parameters of branch penetration, deposit penetration
and credit penetration, at all India level, the index is placed (on a scale of 100) at 40.1 in
2011, reflecting under penetration of formal banking facilities in most part of the country.
While the Southern region witnessed highest financial inclusion with index at 62.2,
NorthEastern region registered lowest with 28.5. Under-penetration is evident in terms of number
of ATMs and POS per million population also. In India, it stood at about 94 and
695 respectively as compared to, say, 1200 and 4853 respectively in Russia. The credit to
GDP ratio is at around 53 per cent, which is low compared to the credit-GDP ratio of many
advanced & developing economies. Hence, there is a need for much greater banking and
credit penetration going forward. This is so because despite efforts to develop the corporate
bond market, the Indian financial system remains bank-dominated with commercial banks
accounting for over 60 per cent of the financial sector assets. It is, therefore, essential for the
Indian economy, striving for an accelerating, sustainable and inclusive growth in the medium
to long-term, to have a healthy and growing banking system.
3. Indian banking in future is, thus, expected to grow exponentially supported by technology
intensive processes and customer friendly models with focus on convenience and cost
effectiveness. A report titled Indian Banking 2020: Making Decade's Promise come True
brought out by the Boston Consulting Group in 2010 had identified ten broad trends for the
Indian banking. These and a few other areas which should receive the attention of banks
seeking opportunities for sustainable growth are summarized below:-
i. Retail banking will be immensely benefited from the Indian demographic dividend. It
is important to note that the middle class population is expected to touch 200 million
by 2020 and 475 million by 20271. This would imply mortgages would grow fast and
likely to cross '40 trillion by 2020;
ii. Another segment that will provide huge opportunities will be the financing of
affordable housing for growing "low" & "middle" class;
iii. Rapid accumulation of wealth in rich households will drive wealth management to
10X size;
iv. "The Next Billion" consumer segment will emerge as the largest in terms of numbers
and will accentuate the demand for low cost banking solutions and innovative
operating models, throwing up a big market of small customers;
v. Branches and ATMs will need to grow 2X and 5X respectively to serve the huge
addition to bankable population. Low cost branch network with smaller sized
branches will be adopted;
vi. Mobile banking will come of age with widespread access to internet on mobile
reaping the benefit of the high mobile density in the country;
vii. Banks will adopt CRM and data warehousing in a major way to reduce customer
acquisition costs and improve risk management. Banks will have to understand and
adopt new technologies like, cloud computing and invest significantly in analytics
based on big data;
viii. Margins will see downward pressure both in retail and corporate banking, spurring
banks to generate more fees and improve operating efficiency;
ix. Banks will discover the importance of the SME segment for profitability and growth
and new models to serve SME segment profitably will be found as more than three
fourth of the segment is still waiting to be served;
x. Investment banking will grow 10X, driven by demand from corporates for transaction
support and capital market access; and
xi. Infrastructure debt will surpass 45 trillion - half of which will be on bank's books.
It will touch the ALM limits of banks and will require a significant upgrade of banks'
risk management systems.
xii. The focus of agricultural financing will be on areas like end-to-end supply chain
management, various aggregation models of financing, organic and other niche
areas of agriculture. Rural banking predominantly will have to harness branchless
xiii. Although banks will continue to focus on domestic business, given the rising trend of
globalization, cross-border banking business will need more attention. As per a
recent World Bank report, India retained its topmost position with US$ 70 billion in
remittances in 2013 followed by China (US$ 60 billion), the Philippines
(US$ 25 billion), Mexico (US$ 22 billion), Nigeria (US$ 21 billion), Egypt
(US$ 17 billion), Pakistan (US$ 15 billion) and Bangladesh (US$ 14 billion). Apart
from remittances and deposit & investment related transactions originating from the
growing Indian diaspora, India has been witnessing a significant increase in trade
finance and outward direct investments. In other words, banks will need to gear up
to reap the benefits of increasing business arising out of globalization of India and
resident and non-resident Indians;
xiv. It has now been realized that manufacturing will have to be one of the key drivers of
growth though in the recent past, with moderation in the growth rate, the sector also
witnessed a slowdown. A recent report of the McKinsey Global Institute2 observes
that for making a substantial improvement in the standards of living of the Indian
people and alleviating poverty, about 115 million new non-farm jobs will have to be
created between 2012 and 2022 and of these, about 27 million new jobs need to be
created in manufacturing. The required growth rate in manufacturing sector output
needs to be at least 10 per cent a year, probably higher. The National Manufacturing
Policy envisages share of manufacturing in GDP to 25 per cent by 2022. Achieving
this rate of growth would require significant amount of financing by the banks.
4. Against this evolving milieu of opportunistic trends, I feel it is appropriate to take stock of
the challenges facing banks going forward in terms of strategies and business models that
they will need to adopt more specifically from the regulatory and payment system
perspectives. I intend to highlight some of the major challenges.
Challenges from the regulatory perspective
Re-orientation of the Indian banking structure
5. As the economy expands, a greater quantum of resources will be needed for supporting
the growth process. The Indian banking sector also needs to catch up the likely acceleration
in the credit to GDP ratio as the economy expands. To support the economic growth as
envisaged in the 12th Five Year Plan, the banking business needs to expand significantly to
an estimated 288 trillion by 2020 from about 115 trillion in 20123. Given this, there is a
need for reorienting the banking structure to make it more dynamic and flexible, while
ensuring safety and systemic stability. There is enormous scope for increasing the size and
capacity of the banking structure. Accordingly, the Reserve Bank came out with a set of
guidelines for licensing of new banks in the private sector in February 2013. The process of
licensing culminated with the granting of "in-principle" approval to two applicants who would
set up new banks in the private sector within a period of 18 months.
6. While announcing the decision to grant "in-principle" approval to the two applicants, the
Reserve Bank indicated that going forward, it would use the learning experience from this
licensing exercise to revise the guidelines appropriately and move to grant licences more
regularly on "tap" basis. Further, Reserve Bank would work on a policy of having various
categories of "differentiated" bank licences which will allow a wider pool of entrants into
banking leading to greater banking penetration and more competitive environment. Reserve
Bank has, accordingly, been working on the relevant guidelines for licensing payment banks
and small banks.
7. Eventually, over the years, as visualized in the Discussion Paper, the reoriented the
banking structure may comprise four tiers. The first tier may consist of three or four large
universal Indian banks with domestic and international presence along with branches of
foreign banks in India. The second tier is likely to comprise several mid-sized banking
institutions including niche banks like Payment Banks with economy-wide presence. The
third tier may encompass old private sector banks, Regional Rural Banks, and multi state
Urban Cooperative Banks. The fourth tier may embrace many small privately owned local
banks and cooperative banks.
Competition
8. W. Chan Kim & A. Renee Mauborgne in their "Blue Ocean Strategy" have shown that
companies can succeed not by battling competitors, but rather by creating Blue Oceans of
uncontested market space. These strategic moves create value for the company, its buyers
and its employees, while unlocking new demand and making the competition irrelevant.
Unlike the Red Ocean Strategy, the conventional approach to business of beating
competition, the "Blue Ocean Strategy" tries to align innovation with utility, price and cost
propositions. Similarly, financial sector reforms have brought about significant structural
changes and created several blue oceans. A manifestation of this development is reflected in
the increase in bank competitiveness. The share of public sector banks (PSBs) in total
banking assets, which was 90 per cent on the eve of reforms in 1991 has since declined to
around 72 per cent, a decline of roughly 1 percentage a year. In a move that is further
expected to increase competition in the domestic banking industry, the Reserve Bank
released the framework for setting up of Wholly Owned Subsidiaries (WOS) by foreign banks
to India in November 2013, besides the framework for new universal banks and differentiated
banks, such as, small banks and payment banks, which is in the offing. As I mentioned
above, new banks are set to enter baking sector. Further, banks are facing increasing
competition from non-banks including NBFCs, MFIs and tech companies. Going ahead, there
may be increase in the non-bank related financing activities through innovations like
Peer-toPeer (P2P) lending4, direct consumer lendings and social investing. With increasing
competition, banks, will need to tap into untapped business opportunities. This would also
call for harnessing resources at the bottom of the pyramid. Small customers are as important
to their business growth as big business opportunities. The challenge before banks would be
to make the best use of technology and innovation to bring down intermediation costs while
protecting their bottom lines
Basel III implementation
9. The implementation of Basel III framework will throw various challenges for banks. In
particular, the adoption of Basel III capital requirements by Indian banks would push down
their return on equity (RoE) to an extent. Investors have a wider choice and the stocks of the
manufacturing sector may be preferred to banking sector stocks and, as such, it may
perhaps be difficult to convince the investor community to invest in Indian banks in the
shortterm. It is, however, expected that by looking at the benefits of implementation of Basel III
capital requirements by way of increasing resilience of the banking system, investors will get
adjusted to the new reality. This issue also needs to be seen in a historical perspective to
understand the fact that Indian banks have successfully transited in the past from the regime
of no regulatory requirement for capital to progressively tighter capital requirements and it
would be logical to expect that Indian banks would be able to navigate the current phase as
well. Nevertheless, it needs to be recognized that while moderation of growth in RoE is
inevitable, the key to cushion this impact is to optimise capital and augment efficiency.
10. On June 9, 2014, the Reserve Bank issued guidelines for the implementation of the
Liquidity Converge Ratio (LCR), which is a part of the Basel III framework on Liquidity
Standards. In India, the LCR will be introduced in a phased manner starting with a minimum
requirement of 60 per cent from January 1, 2015 and reaching minimum 100 per cent on
January 1, 2019. Further, Government securities in excess of minimum SLR requirements
and the Government securities within the mandated SLR requirement to the extent allowed
by the Reserve Bank under Marginal Standing Facility (MSF) are permitted to be treated as
Level 1 assets for the computation of LCR. Adoption of liquidity standards under Basel III
may induce changes in funding preferences of the Indian banks reflecting the fact that
availability of and access to quality liquid assets may be a challenge going forward when the
LCR requirement increases incrementally.
Capital mobilisation
11. In the process of phased adoption of Basel III capital norms, Indian banks in general
have a relatively comfortable capital adequacy position to begin with. Rising required amount
of capital going forward would be, however, a challenge, to which I turn now. The Reserve
Bank issued final guidelines on implementation of Basel III capital regulations on May 2,
2012. The guidelines became effective from April 1, 2013 in phases and will be fully
implemented as on March 31, 2019. Though there are various estimates about the additional
capital mobilization by the PSBs arising out of the phased implementation of Basel III capital
requirements, one thing is clear that the required magnitude of capital in the run up to the full
implementation will be substantial. During the last four years, the Government has infused
586 billion in the PSBs. The Government has made a provision of 112 billion in the
interim budget for 2014-15. PSBs hold more than 70 per cent of the banking assets.
Therefore, capital infusion from the Government of this order may not be sufficient. It is also
important to note that there has been over reliance on the Government to infuse equity
despite headroom available for the management of the banks to raise equity from markets.
There have not been concerted efforts made by PSBs to shore up their equity capital base
from the markets, keeping in view the Basel III capital adequacy requirements. Their internal
generation of capital has suffered mainly due to sharp deterioration in the asset quality
possibly due to /adverse selection of assets. The growing pressure on asset quality of PSBs
and the threat of rating downgrades will further add pressure on the equity of banks. Further,
there would be further requirement of capital based on supervisory review and evaluation
process under Basel Pillar II framework.
12. With higher additional capital requirements, as discussed above, recapitalisation of PSBs
could exert significant stress on the government's fiscal position. There are, however, several
potential options available to meet the challenges of mobilization of additional capital. These
would include:
i. Divestment of Government's shares in PSBs. Given the present level of government
shareholding in these banks which ranges from 58 per cent to 89 per cent, there is
substantial ground for raising equity from the market without diluting the public
sector character;
ii. The roles and responsibilities of the Boards of PSBs could be reviewed. The
effectiveness of the Board and senior management has a moderating effect on the
risk profiles, and consequently, overall capital requirements in a bank. The
Government, being the owner of the PSBs, could address the governance aspects
concerning PSBs;
iii. In addition to the public and rights issues, banks have other routes available to raise
equity in the form of qualified institutions' placement (QIP) and ESOP. Boards of
PSBs need to explore all the feasible options to raise equity capital.
iv. Providing tax incentive to investors' on investments in banks' Tier 1 bonds like tax
exemption of interest income(in part or in full) with a view to promoting and
deepening the market for these bonds may be useful at this stage;
v. PSBs may issue non-voting equity shares to the public thereby while the
Government can hold less than 51 per cent of the total equity shares, it can still
maintain at least 51 per cent voting rights of the total voting equity;
vi. Similarly, the option of issuance of differential voting equity could also be
considered. These issuances will allow the Government to maintain their voting
rights at the desired level even though there may be a dilution in the economic
interest, i.e., in terms dividend income to the Government;
vii. The Government's stake in PSBs can be diluted below 51 per cent in conjunction
with certain protective rights given to the Government by amending the respective
statutes governing PSBs;
viii. In this connection, the proposals of the Committee to Review Governance of Boards
of Banks in India (Nayak Committee) to transfer the Government's shares in PSBs
to an investment company viz., Bank Investment Company (BIC), reduce
Government stakes in PSBs to less than 50 percent and provide more autonomy
and professionalism to PSBs which are expected to improve the returns on equity
and attract more capital from the market apart from reducing provision requirements,
etc. are worth serious consideration; and
ix. As regards distressed banks in private sector, Nayak Committee has also
recommended that private equity funds, including sovereign wealth funds be
permitted to take a controlling stake of 40 percent.
Asset quality
13. During the quarter ended December 2013, banks collectively held loan provisions of
about Rupees one lakh crores, an increase of 13 percent over the year, indicating that loan
asset quality of banks in India deteriorated considerably The trend of y-o-y growth in gross
non-performing advances (GNPA) outstripping the y-o-y growth of advances, that started
from the quarter ended September 2011, continues although the gap in the growth rates is
narrowed5. The PSBs continued to register the highest level of stressed advances at 11.3
per cent of the total advances as at end March 2014, followed by the old private bank at 5.8
per cent. Though agriculture sector showed the highest GNPA ratio the industry sector
showed distinctly high level of restructured standard advances, resulting in the stressed
advances of the industry sector reaching 15.6 per cent followed by the services at 7.9 per
cent as at December 2013. There are five sub-sectors, namely, infrastructure {which includes
power generation, telecommunications, roads, ports, airports, railways (other than Indian
Railways) and others infrastructure}, iron and steel, textiles, mining (including coal) and
aviation services had significantly higher level of stress and thus these sub-sectors/segments
were identified as "stressed" sectors in the banks' lending portfolios. The share of these five
stressed sub-sectors to the total advances of the SCBs is around 24 per cent. Infrastructure
has the highest share at 14.7 per cent in the total advances. Among the bank-groups, these
five sub-sectors have the highest share at 27.3 per cent in the case of PSBs.
14. It is widely accepted that the economic slowdown has affected the asset quality of banks
adversely though the impact is not similar across bank groups. Sector-wise and their
sizewise analysis of asset quality shows that the GNPA ratio of PSBs across the sectors and
their size are significantly higher than the other bank-groups. How do we face up to the
challenge of deteriorating asset quality of banks? Though analysts have often pointed out
that the poor asset quality of the banks, to a great extent, could be attributed to the not so
encouraging macro-economic situation, it is expected that the implementation of the new
initiatives by the Central Government would address these issues effectively. Skeptics,
though may still point out at factors, such as, the threat of "El Nino" which could result in poor
monsoon, global developments, such as, quantitative easing, etc. and geopolitical risks,
could threaten the performance of banks in India. It is also true that even when general
economic outlook is healthy, the asset quality of banks could still suffer due to inadequacies
in credit management. There are no short cuts for proper credit appraisals and monitoring.
Recognising early warning signals and taking timely measures to take care of the
weaknesses observed are very important.
15. The Reserve Bank, on January 30, 2014, has issued a "Framework to Revitalise the
Distressed Assets in the Economy", wherein banks would recognise at an early stage the
stress in their assets and take prompt steps towards resolution/ recovery of distressed assets
and detailed guidelines in this regard were issued on February 26, 2014. The Framework has
identified certain structural impediments in the way of smooth resolution/recovery of stressed
assets of banks and suggested steps, such as, revamping the SARFAESI Act, revitalizing
DRTs, etc. and rejuvenating Asset Reconstruction Companies, are also being mooted.
16. The Reserve Bank of India has set up the Central Repository of Information on Large
Credits (CRILC) to collect, store and disseminate data on all borrowers' credit exposures
including Special Mention Accounts (SMA 0, 1 & 2) with aggregate fund-based and non-fund
based exposure of '50 million and above. The CRILC has started disseminating information
on large credit which will reduce credit information asymmetry and improve informed credit
decision making by banks. Banks will be able to know large common exposures and build-up
of leverage in the system. Banks will have access to asset classification of individual large
exposures by different banks. Banks are required to activate the Joint Lenders Forum for
initiating corrective actions when a lender reports a borrower as SMA2 to CRILC. We have
engaged with banks to avoid delay in submission of data and ensure quality and integrity of
data. It is expected that once it stabilizes, the CRILC framework would exert moral
pressure/discipline on large borrowers to repay dues in time lest their names appear in
SMA2 report and bank managements would be better equipped to assess the health of their
high value credit portfolio for initiating timely action.
Governance
17. As mentioned earlier, Nayak Committee has made some major observations regarding
governance aspects of banks in India, especially that of PSBs. According to the Committee,
there is a need to upgrade the quality of board deliberation in PSBs to provide greater
strategic focus. Further, there are seven themes which appear critical to their medium-term
strengths comprising Business Strategy, Financial Reports and their Integrity, Risk,
Compliance, Customer Protection, Financial Inclusion and Human Resources. All other items
for discussion should be brought to the Boards by exception and should typically be
discussed in committees of boards. It is added that, among these seven themes identified for
detailed board scrutiny, predominant emphasis needs to be provided to Business Strategy
and Risk dimensions. Further, the Committee is of the view that as the quality of board
deliberations is sensitive to the skills and independence of board members, it is imperative to
upgrade these skills in boards of PSBs by reconfiguring the entire appointments process.
Otherwise it is unlikely that these boards will be empowered and effective. For this, the
Government has to move towards establishing fully empowered boards in PSBs, solely
entrusted with the governance and oversight of the management of the banks. The proposed
BIC, which is expected to hold the shares of the Government in PSBs, should commence the
process of professionalising and empowering bank boards by reconstituting them and this in
turn would help to improve the corporate governance in a big way. As per the
recommendations of the Committee, eventually in phase III, all ownership functions would be
transferred by BIC to the bank boards. The appointments of independent bank directors and
whole-time directors (including the CEO) would become the responsibility of bank boards.
Equally important from PSBs point of view would be the quality of the top management
particularly from the points of view of experience, expertise & continuity. While
professionalization and effectiveness of boards of PSBs emerged as a major challenge, it is
no less as issue with many private sector banks, say for example, when there is domination
of prominent shareholders/CEOs. Private sector banks also need to focus on the skill-set and
profile of their top management and the board of directors.
Risk management system in banks
18. The design of risk management functions should be based on size, complexity of
business and the quality of MIS. The banks should have the necessary skill set available or
develop it through proper in-house capacity building. Banks, therefore, will need to refine and
re-orient their risk management skills for enterprise-wide risk management. In addition,
banks need to have in place a fair and differentiated risk pricing of products and services
since capital comes at a cost. This involves costing, a quantitative assessment of revenue
streams from each product and service and an efficient transfer-pricing mechanism that
would determine capital allocation. Generally it is observed that some banks put the risk
management architecture in place to meet the regulatory requirements without using the risk
inputs for taking business decisions. The risk is not properly priced for various products. The
most challenging part is the integrity and reliability of data. It must be appreciated that Risk
Based Supervision (RBS) under which all the banks will be covered by the Reserve Bank
over a period of time (28 banks were under RBS last year) is highly data intensive. The risk
profile of a bank, its rating, and most importantly, the computation of supervisory capital
which are the outputs of RBS are determined on the basis of data and other qualitative
information furnished by the banks. It may be remembered that supervisory findings also go
towards formulation of regulatory guidelines and other macroeconomic policies. It is,
therefore, the responsibility of the top managements/Boards of the banks to ensure that this
area is given utmost attention.
HR management
19. This is an area where most of our banks, especially the PSBs, are found lacking. In their
eagerness to expand their core business they tend to forget the relevance of human
expertise which drives their business in a sustainable manner. The complexities of modern
banking and the dependence on IT makes it all the more important why the banks should
have requisite manpower with right amount of knowledge and experience at appropriate
places. Many of the present day ills in Indian banks, e.g., weak appraisal standards, not
being able to pick up the early warning signals in problem accounts which leads to fraudulent
transactions or accounts becoming NPA, recurring customer grievances, etc. can be
ascribed to skill gaps in the manpower of the banks. Near vacuum in the senior management
over the next few years, lack of expertise in critical areas like IT, risk management, credit
appraisal and treasury operations, absence of succession planning for middle and senior
management positions, attracting, retaining and nurturing fresh talent, ad hoc responses to
capacity building and poor performance management system are some of the major HR
challenges staring the PSBs. The proposal of universal and differentiated bank licenses
being available on tap will make it tougher for PSBs to retain whatever skilled manpower is
available with them. In respect of private sector banks, the problem in many cases relates to
the work culture focussing unduly on achieving unrealistic targets by all means. This implies
certain aversion towards employment in such banks and could have serious reputation risk
implications for them.
Challenges from the payment systems perspective
Financial inclusion through the payments route
20. Leveraging technology enabled payment system for electronic transactions provides
challenges and opportunities to the banks by expanding outreach in terms of expanding
customer base, offering multiple product choices, achieving cost efficiency, providing
assurance in terms of standardization, safety and safety. Despite the impressive growth in
the volume and value of electronic transactions the same is concentrated in metros and big
cities, thus widening the digital divide. This imbalance is reflected along various parameters,
be it the deployment of ATMs, or the POS infrastructure, mobile banking services, etc.
Needless to state, the vision of financial inclusion, aided through the payments path, cannot
be achieved unless the rural and semi-urban areas find an equal footing in the policy horizon
for banks.
21. While the ultimate goal is to migrate most of the payments to electronic mode, we cannot
lose sight of the reality that large segment of population is still dependent on cash for
day-today requirements. The lop-sided development of infrastructure mentioned above also
contributes to this challenge. Hence, from a perspective of achieving inclusive payment
system, it is also necessary to facilitate remittance and cash-handling requirements of a large
segment of society, particularly the migrant population, The Reserve Bank has already put in
place the policy framework under the Guidelines for Domestic Money Transfer (DMT) and
now it is up to the banks to take this forward. Towards this end, experiments like "Cardless
cash withdrawal" for the unbanked is gaining ground. We have recently given in-principle
approval for two entities to take this service forward. Of course, for this to gain traction, active
participation of and promotion by banks would be imperative as the delivery channels
envisaged in these models are the ATMs and Business Correspondents (BCs).
Standardisation and capacity build-up
22. While any development in offering electronic services is welcome, stand-alone systems
not only work in silos but also fragment the market to some extent. Hence, as the payments
eco-system matures, inter-operability becomes essential, for which standardization in
processes and procedures is a pre-requisite. This not only facilitates uniformity in transaction
handling but also enables uniform customer experiences. A related point is that of ensuring
that systems are not just adequate to meet present needs but also the growing volumes.
Hence, even as the Reserve Bank is building capacity in the systems operated by it (for
instance, the RTGS or NEFT), it is equally important for banks to review and upgrade their
own infrastructure as well in tune with their policy and expected growth in business.
Partnerships with non-banks
23. Even as we have adopt