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Rakesh Mohan Deputy Governor Reserve Bank of India and Chairman, CFSA:

Rakesh Mohan Deputy Governor Reserve Bank of India and Chairman, CFSA Financial Sector Assessment

What is an FSAP?:

What is an FSAP? The Financial Sector Assessment Program is an IMF-World Bank initiative A comprehensive health check of the financial system A review of strengths, vulnerabilities and weaknesses Measures compliance with international financial standards and codes Initiated after the1997 Asian financial crisis

Presentation Outline:

Presentation Outline Part I: The FSAP and Self-Assessment A. Background and Timing B. Macroeconomic Outlook and Vulnerabilities C. Stability Assessment & Stress Testing Part II: Lessons and Issues from the Assessment D-F. Financial Institutions, Markets and Infrastructure G. Transparency and Developmental Issues Part III: Transparent Reporting H. Peer Reviewers’ Comments I. CFSA and Advisory Panels – Some Differences Part IV: Conclusions and Concerns J. Summary of Assessment K. Main Concerns

Slide 4:

Part I The FSAP and Self-Assessment

Slide 5:

A. Background and Timing

Background and Timing (1) The Story So Far:

Background and Timing (1) The Story So Far IMF-WB FSAP in 2001, self-assessment of international standards and codes in 2002, reviewed again in 2005 Set up CFSA in 2006 India among the first country to undertake comprehensive and holistic self-assessment of financial sector Post-crisis, emphasis by the G-20

Background and Timing (2) Overview of Self-Assessment :

Background and Timing (2) Overview of Self-Assessment Approach and Methodology Pillar I  Macro-prudential surveillance and financial stability analysis Pillar II  Legal and institutional frameworks review Pillar III  International financial standards and codes: assessment and status of implementation

Background and Timing (3) The Process:

Background and Timing (3) The Process Benefits Composition of CFSA: ownership and commitment Regulatory cooperation: GoI, RBI, SEBI, IRDA, other agencies Involvement of experts: advisory panels Peer reviews: Impartiality Learning and capacity-building: involvement of professionals Execution Complex issues – approach with humility Broad directions instead of specifics in the current context Focus on Transparent Reporting : Differing opinions of CFSA and Panels covered in the report

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B. Macroeconomic Outlook and Vulnerabilities

Macroeconomic Outlook and Vulnerabilities (1) The Growth Story:

Macroeconomic Outlook and Vulnerabilities (1) The Growth Story Growth in recent period contributed by several factors High domestic demand Productivity Credit growth High levels of savings and investment Current global financial crisis: shift from benign outlook to one of uncertainty 8 %+ growth sustainable in the medium-term due to high demand; deceleration in the short-term

Macroeconomic Outlook and Vulnerabilities (2) Pressing Challenges:

Macroeconomic Outlook and Vulnerabilities (2) Pressing Challenges Need for revival of growth in agriculture Address restoration of the fiscal reform path Continuation of financial sector consolidation and development Address the infrastructure deficit Complement bank financing with bond market development Insurance and pension reforms FCAC desirable, but with concomitant macroeconomic and market developments

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C. Stability Assessment and Stress Testing

Stability Assessment and Stress Testing (1) Main Findings :

Stability Assessment and Stress Testing (1) Main Findings Financial Institutions Commercial Banks: financially robust NBFCs and HFCs: healthy financial indicators Some financing concerns UCBs and RRBs: improvements in financials governance concerns Rural Co-operative Sector significant weaknesses

Stability Assessment and Stress Testing (2) Financial Soundness Indicators:

Stability Assessment and Stress Testing (2) Financial Soundness Indicators Commercial Banks - Broad improvement in the post-reform period Financial Soundness Indicators 2000 2008 CRAR 11.1 13.0 Gross NPAs to Gross Advances 13.1 2.4 Net NPAs to Net Advances 7.1 1.1 Return on Total Assets 0.7 1.0 Return on Equity 12.7 12.5 Efficiency (Cost Income) Ratio 61.2 48.9

Stability Assessment and Stress Testing (3) Financial Soundness Indicators:

Stability Assessment and Stress Testing (3) Financial Soundness Indicators Other Institutions - Broad improvement in the post-reform period – Rural Co-operative Sector – some concerns NBFCs - D HFCs Scheduled UCBs RRBs StCBs/ DCCBs 2004 2008 2004 2008 2005 2008 2005 2008 2005 2007 CRAR 26.8 22.4 15.0 18.1 12.7 11.9 ---- ---- ---- ---- Gross NPAs Ratio 8.2 1.5 3.6 2.2 24.8 14.2 8.5* 5.9* 16.3 19.9 14.2 18.5 RoA* 2.5 2.9 1.9 2.2 0.3 0.7 1.0 1.1 0.4 0.7 0.3 0.02 * Ratio to Total Assets

Stability Assessment and Stress Testing (4) Stress Testing:

Stability Assessment and Stress Testing (4) Stress Testing What is Stress Testing Techniques to assess vulnerability of the financial system in the face of shocks ; identifies how portfolios respond to changes in key economic variables: e.g., interest rates, credit quality Coverage of stress tests Credit risk Market/interest rate risk Liquidity risk Open positions in foreign exchange much below regulatory limits – Exchange rate tests not undertaken

Stability Assessment and Stress Testing (5) Credit Risk:

Stability Assessment and Stress Testing (5) Credit Risk Without Stress Scenario - increase in NPA by: 100 per cent 150 per cent CRAR (%) CRAR (%) CRAR (%) Mar-08 13.0 11.6 11.0 Sept–08 12.5 11.1 10.6 Note: CRAR = credit to risk assets ratio Concerns about credit risk remain muted at present Need for close monitoring of such risks in the current scenario

Stability Assessment and Stress Testing (6) Interest rate risk:

Stability Assessment and Stress Testing (6) Interest rate risk Higher the DoE (duration of equity), greater the sensitivity of banks capital to interest rate shocks Calculates the erosion in accounting capital due to unit increase in interest rate Period Mar-06 Mar-07 Mar-08 Sep-08 DoE (yrs) 14.1 12.0 8.0 8.1 The annualised yield volatility is estimated at 244 bps Given a DoE of 8.1 years, a 244 bps shock implies an erosion of 20 per cent of capital and reserves. => Better management of interest rate risk by commercial banks over time

Stability Assessment and Stress Testing (7) An Overview of Liquidity Ratios:

Stability Assessment and Stress Testing (7) An Overview of Liquidity Ratios Ratio Mar-05 Mar-08 Sep-08 (Volatile Liabilities –Temporary Assets) / (Earning Assets –Temporary Assets) (per cent) (High and positive number implies some risk of funding liquidity. ) 34.7 43.9 49.3 (Core Deposits) / Total Assets (per cent) - (Extent to which assets are funded through stable deposit base) 53.8 49.3 47.7 (Loans + Mandatory CRR + Mandatory SLR + Fixed Assets) / Total Assets (per cent) – (Embedded illiquidity in the balance sheet) 75.0 86.3 86.5 (Loans + Mandatory CRR + Mandatory SLR + Fixed Assets) / Core Deposits – (Dependence on purchased liquidity) 1.4 1.8 1.8

Stability Assessment and Stress Testing (8) Liquidity Risk Management:

Stability Assessment and Stress Testing (8) Liquidity Risk Management Gradual, growing dependence on purchased liquidity Increase in illiquid parts of banks’ balance sheets Greater reliance on volatile liabilities for asset growth

Stability Assessment and Stress Testing (9) The Way Forward:

Stability Assessment and Stress Testing (9) The Way Forward In Sum: Commercial Banking System – Broadly Sound Can withstand significant shocks from large potential changes Possible Next Steps: Need to strengthen liquidity management Stress Testing by individual banks Periodic scenario testing by RBI Setting up of a Financial Stability Unit

Slide 22:

Part II Lessons and Issues From the Assessment

Slide 23:

D. Financial Institutions

Financial Institutions (1) Regulation and Supervision:

Financial Institutions (1) Regulation and Supervision Inherent linkages across institutions Inter-bank Bank and non-banks Basel Core Principles not applicable to: Co-operative Sector; Regional Rural Banks; NBFCs; HFCs But, Assessment done for health check Results : Generally satisfactory

Financial Institutions (2) Basel Core Principles: A Compliance Summary:

Financial Institutions (2) Basel Core Principles: A Compliance Summary Assessment CB UCB StCB/ DCCB RRB NBFC HFC Compliant 7 4 3 4 1 2 Largely Compliant 11 11 10 8 13 10 Materially Non-compliant 6 4 6 6 2 5 Non-compliant 1 2 2 2 8 8 Not applicable - 4 4 5 1 -

Financial Institutions (3) Basel Core Principles: A Compliance Summary:

Financial Institutions (3) Basel Core Principles: A Compliance Summary Major Gaps: All Institutions: Risk management (for commercial banks the level of compliance is comparatively lower in respect of banking groups); home-host country regulation Commercial Banks : Exposure to related parties; non-compliance in respect to interest rate risk in banking book for which guidelines have since been issued Rural & Co-operative Banks : Dual Control; internal control; corporate governance NBFCs: Major acquisitions, transfer of significant ownership, internal control HFCs : Permissible activities; internal control

Financial Institutions (4) Commercial Banks Oversight:

Financial Institutions (4) Commercial Banks Oversight Government ownership poses dilemmas Possibility of conflicts of interest minimised through even-handed regulation Capital augmentation of PSBs is a challenge, but could be managed through a variety of ways Amalgamation where commercial synergies exist Newer instruments Through selective dilution of government equity

Financial Institutions (5) Banking For The 21st Century:

Financial Institutions (5) Banking For The 21 st Century Capacity Building: Training Succession Planning Lateral Recruitment Improved remuneration – but discourage excessive risk taking Corporate Governance: Improve governance in PSBs Roadmap for foreign banks – A well-considered approach within the WTO norms

Financial Institutions (6) New Competition Act: Some Issues :

Financial Institutions (6) New Competition Act: Some Issues Power of Competition Commission to regulate combination Any combination required to be notified to Commission Maximum period of wait 210 days RBI may be able to give sanction only after getting order of Commission or wait for 210 days Delays the process Possibility of regulatory conflict as order of any statutory authority not binding on Commission Could lead to regulatory overlap and conflict Central Government could give necessary exemption under Section 54 of the Competition (Amendment) Act 2007

Financial Institutions (7) Risk Management and Governance:

Financial Institutions (7) Risk Management and Governance Conservative risk management matters Counter-cyclical prudential measures by RBI Off-balance sheet items: Better accounting, disclosure Capital charge if reliance on purchased liquidity beyond a threshold Consolidation Encourage market-based consolidation Co-operative and rural banks need better governance Dual control: improve corporate governance Regulation and supervision of rural financial sector: role for RBI and NABARD

Financial Institutions (8) Non-Bank Financial Services :

Financial Institutions (8) Non-Bank Financial Services NBFCs are key players in financial markets Corporate bond market development would ease funding constraints Development of regulatory structure for financial conglomerates Prudential regulations of NBFCs strengthened – some way to go Housing finance: growing and important segment National Housing Price Index, Housing Starts Index a priority Regulation of HFCs should be entrusted to RBI – Government’s stance – status quo

Financial Institutions (9) An Assessment of Insurance:

Financial Institutions (9) An Assessment of Insurance Assessment Number of Principles Observed 5 Largely Observed 13 Partly Observed 10 Not Observed - The level of compliance of the Insurance Sector to IAIS Core Principles

Financial Institutions (10) An Assessment of Insurance:

Financial Institutions (10) An Assessment of Insurance Significant growth in size, penetration and diversified products Comfortable solvency and capital adequacy But gaps/issues remain Increase supervisory powers of IRDA Group-wide supervision – effective policy to be put in place Risk Management Further requirement of skilled professionals – actuaries, treasury managers

Slide 34:

E. Financial Markets

Financial Markets (1) Regulation and Supervision:

Financial Markets (1) Regulation and Supervision Systemic stability Importance of markets other than equity market IOSCO Principles extended to: G-Sec markets; Forex Markets; Money Markets Results : Generally satisfactory

Financial Markets (2) Foreign Exchange Market:

Financial Markets (2) Foreign Exchange Market Fastest growing market globally Total annual turnover increased from USD 1.3 trillion during 1997-98 to USD 12.3 trillion during 2007-08 Derivatives: High growth in forward market Forex futures introduced in 2008 Need for monitoring and regulation Customer appropriateness and product suitability

Financial Markets (3) Sovereign Debt Market:

Financial Markets (3) Sovereign Debt Market Significant growth in volume and liquidity Further diversification of investor base needed Foreign investor participation: proceed with care Increase in tradable assets desirable Large proportion parked in HTM category

Financial Markets (4) Equity Market:

Financial Markets (4) Equity Market Significant improvement in market and settlement infrastructure Functions in robust regulatory environment Very high compliance with IOSCO Principles Risk management by market participants Strengthening of inter-exchange surveillance Need to improve IPO processes Setting up of Central Integrated Platform

Financial Markets (5) Money Market:

Financial Markets (5) Money Mar ket Liquid market Increased share of repo and CBLO Need for active interest rate futures market Being re-introduced Development of term money market Development of short-end yield curve necessary Under examination in TAC Group Development of the repo market

Financial Markets (6) Other Market Segments:

Financial Markets (6) Other Market Segments Need to develop corporate bond market Develop credit risk transfer mechanism But with appropriate checks and balances Capacity building in financial institutions with regard to securitisation and credit derivatives

Financial Markets (7) Compliance With IOSCO:

Financial Markets (7) Compliance With IOSCO Markets/ Assessment Equities Foreign exchange Govt. securities Money market Fully Implemented 20 16 19 19 Broadly Implemented 8 - 2 4 Partly Implemented 2 5 5 5 Not applicable - 9 4 2

Financial Markets (8) Compliance With IOSCO:

Financial Markets (8) Compliance With IOSCO Despite high compliance, some gaps remain Equities Market: Responsibilities and operational independence of regulator; inspection and surveillance powers; capital and prudential requirements for market intermediaries Foreign Exchange Market: Operational independence and accountability of regulator; co-operation and detection of manipulation and unfair trading practices G-Sec markets: Operational independence and accountability of regulator; home-host co-operation; disclosure of financial results Money markets: Operational independence; regulatory co-operation with foreign regulator

Slide 43:

F. Financial Infrastructure

Financial Infrastructure (1) Regulatory Infrastructure:

Financial Infrastructure (1) Regulatory Infrastructure Multiple roles of regulators Consistent with financial development Needs effective coordination Principles vs. Rules-based: complementary Develop supervision of financial conglomerates Legislation, a new Act? Develop Self -Regulatory Organisations? Regulatory independence Panels have raised some issues But CFSA considered adequate

Financial Infrastructure (2) Markets and Liquidity:

Financial Infrastructure (2) Markets and Liquidity Large capital movements Volatility in overnight rates Strengthen government cash management Asset liability management of banks Issues related to market integrity—participatory notes Term liquidity facility not required at this stage

Financial Infrastructure (3) Accounting and Auditing:

Financial Infrastructure (3) Accounting and Auditing More autonomy for Accounting Standards Board Need to develop sector-specific guidance Issues in auditing about convergence with ISAs Need to give functional independence to AASB

Financial Infrastructure (4) Payment and Settlement:

Financial Infrastructure (4) Payment and Settlement Payment & Settlement Act of 2007 fills a major gap Sub-optimal utilisation of electronic payment infrastructure Delays in collection of outstation cheques Financial resources with CCIL need strengthening

Financial Infrastructure (5) Business Continuity Management:

Financial Infrastructure (5) Business Continuity Management Ease of operations during crises Areas for strengthening Human Resources management Business continuity processes of vendors Outsourcing risk Succession planning

Financial Infrastructure (6) Assessment of Bankruptcy Law Principles:

Financial Infrastructure (6) Assessment of Bankruptcy Law Principles Assessment Number Observed 38 Broadly Observed 24 Partly Observed 12 Total 74 Major Gaps: Implementation of bankruptcy laws – poor- average 10 years to complete liquidation proceedings – ‘Doing Business Report’- World Bank Amendment to the Companies Act still pending – Setting up of NCLT Issues relating to Competition Amendment Act, 2007 Lack of a Central Registry for recording security interests

Financial Infrastructure (7) Depositor Protection:

Financial Infrastructure (7) Depositor Protection Independence of Deposit Insurance and Credit Guarantee Corporation (DICGC) (recommended by Advisory Panel) Increase flat-rate premium Involvement of DICGC in resolution process- delink settlement of DICGC claims from liquidation process

Slide 51:

G. Transparency and Development Issues

Transparency and Development Issues (1) Assessment of Transparency in Monetary and Financial Policies:

Transparency and Development Issues (1) Assessment of Transparency in Monetary and Financial Policies Assessment Transparency in Monetary Policy Transparency in Financial Policies RBI SEBI IRDA Observed 40 32 33 29 Broadly Observed 1 - - - Partly Observed 3 4 - - Not Observed - - - 1 Not Applicable 2 - 3 6 Major Gaps/Issues: Need for review of legislations- overhaul of legislations not required Operational independence of RBI Strengthening TACMP – requires ongoing review Separation of debt management from monetary management – Chairman’s dissent Price index for measuring inflation – WPI/CPI deb ate

Transparency and Development Issues (2) Assessment of Fiscal Transparency:

Transparency and Development Issues (2) Assessment of Fiscal Transparency Assessment Centre States Observed 36 22 Broadly Observed 4 6 Partly Observed 5 15 Not Observed - 2 Significant improvement following FRBM Act and Fiscal Responsibility Legislations Major Gaps/Issues: Functional overlap by Central Government on issues relating to State Government like health and agriculture Mode of calculating FD does not capture off-budget items separately –augmented FD required Need for accrual-based accounting – guarded approach

Transparency and Development Issues (3) Assessment of Data Dissemination Standards:

Transparency and Development Issues (3) Assessment of Data Dissemination Standards Assessment National Accounts WPI CPI-IW Government Finance Statistics Monetary Statistics Balance of Payments Observed 6 15 18 9 22 19 Largely Observed 13 6 3 10 - 3 Largely Not Observed 3 1 1 3 - - Not Observed - - - - - - Major Gaps : Need for proper legal and institutional support for CSO IIP data - need to adjust basket of commodities and weights assigned Multiple agencies in collection of labour data WPI – outdated weights

Transparency and Development Issues (4) Making Financial Inclusion Work:

Transparency and Development Issues (4) Making Financial Inclusion Work Rangarajan Committee on financial inclusion Exploit synergies between local and national level financial institutions Finance consumption and household expenditure Scale-up IT initiatives Biometric smart cards in rural areas Development of mobile banking Incentivise BCs Urban poor Dilute KYC norms

Slide 56:

Part III Transparent Reporting

Slide 57:

H. Peer Reviewers’ Comments

Peer Reviewers’ Comments (1) :

Peer Reviewers’ Comments (1) Financial Stability Assessment and Stress Testing V. Sundararajan Plausible shocks and vulnerabilities arising out of domestic macroeconomic and external sectors should be systemically linked to stress scenarios Growing use of purchased funds need analysis of second round contagion effects Andrew Sheng Creation of secondary mortgage market Setting up of Government sponsored secondary mortgage vehicles On-site examination process should be supplemented by a forensic “follow the evolution of the product” approach.

Peer Reviewers’ Comments (2) :

Peer Reviewers’ Comments (2) Assessment of BCP Eric Rosengren Urgent need to improve co-ordination between regulatory agencies LoLR should have the ability to assess solvency and liquidity risks facing institutions Report should elaborate on aspects relating to Central Government’s role in operation of PSBs – whether it interferes with the regulatory role of RBI Corporate Governance and Transparency in Monetary Policy Sir Andrew Large Higher corporate governance standards for the unlisted sector Mechanism to enable central bank to be adequately informed to handle liquidity related events Improvements in transparency would enhance central bank independence

Peer Reviewers’ Comments (3) :

Peer Reviewers’ Comments (3) Bankruptcy Laws Thomas Baxter Indian insolvency regime remains an enigma Special Insolvency regime for banks complement access to credit facilities of central bank and deposit insurance Fiscal Transparency Vito Tanzi Better classification of expenditure central to fiscal policy Relevant fiscal target should be GFD and not revenue deficit Relatively few countries have made a transition to accrual based accounting

Peer Reviewers’ Comments (4) :

Peer Reviewers’ Comments (4) Accounting and Auditing Ian Mackintosh Exercise caution while developing country specific and sector specific accounting standards Important to give functional independence to AASB N.P. Sarda Determining the role of the Quality Review Board to review and improve the quality of audit service is required

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I. CFSA and Advisory Panels – Some Differences

CFSA and Advisory Panels – Some Differences:

CFSA and Advisory Panels – Some Differences Regulatory Independence Panel view : Issues regarding independence of SEBI and IRDA CFSA view: Regulatory independence adequate Review of Legislation Panel view : Review of RBI Act needed CFSA view : Requires to be viewed in a more comprehensive manner Role of HLCCFM Panel view : Further formalisation and institutionalisation CFSA view: Not consistent with regulators’ autonomy Prompt Corrective Action Panel view : Appropriate time-frame required CFSA view: Any rigidity in timeline unduly restrictive

Slide 64:

Part IV Conclusions and Concerns

Conclusions and Concerns (1) Summary of Assessment:

Conclusions and Concerns (1) Summary of Assessment Financial Sector – Has expanded; acquired greater depth and vibrancy Macro economy – Short-term - Uncertainty; Medium-term - high growth sustainable Banks – Healthy and Robust Financial Markets – Resilient and fairly liquid Financial Infrastructure – Robust Transparency – Significant improvements

Conclusions and Concerns (2) Main Concerns :

Conclusions and Concerns (2) Main Concerns Macro economy – Fiscal Deficit Agricultural Growth Susceptibility to international commodity price movements Institutions – Emerging liquidity concerns Corporate governance in co-operative sector Health of rural co-operatives Funding constraints for NBFCs Lack of timely data to gauge household indebtedness Stress Testing Lack of database, techniques and capacity to conduct appropriate systemic stress tests taking into account sectoral interlinkages as also contagion risk

Conclusions and Concerns (3) Main Concerns :

Conclusions and Concerns (3) Main Concerns Financial Markets – Risk of contagion Development of an appropriate risk free yield curve Corporate bond markets Issues relating to derivatives – knowledge concentration and capacity building Transparency – Some issues in fiscal transparency; Need to strengthen data collection agencies

Conclusions and Concerns (4) Main Concerns :

Conclusions and Concerns (4) Main Concerns Delay in bankruptcy proceedings and credit dispute resolution Time taken for winding up proceedings is highest in the world Improvement in effective enforcement of creditor rights required Faster resolution of stressed assets of financial intermediaries Regulation of financial conglomerates and holding companies Role of SROs Regulatory co-operation – particularly cross border Management of capital account Deficiency in retail payment systems

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