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College of Agricultural Banking, RBI, PUNE Regulation and
Supervision of Urban Cooperative BanksJyoti Kumar PandeyDeputy
General Manager & Member of FacultyCollege of Agricultural
Banking Reserve Bank of India, Pune
College of Agricultural Banking, RBI, PUNE
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College of Agricultural Banking, RBI, PUNE Co-operative Credit
StructureRural credit institutions and urban cooperative banksPACs
and UCBs at the base levelState Co-operative Banks and DCCBs -
higher financing agencies for UCBs also
College of Agricultural Banking, RBI, PUNE
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College of Agricultural Banking, RBI, PUNE Characteristics of
Urban Cooperative Banks Registered under State Cooperative
Societies ActsNo controlling interest since the board of management
is elected by share holders in a democratic mannerOne member one
vote irrespective of number of shares held by a memberDuality of
command RCS / CRCS and RBI
College of Agricultural Banking, RBI, PUNE
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College of Agricultural Banking, RBI, PUNE Characteristics of
UCBs (Contd.)
Borrowing restricted to membersRestricted area of operationShare
linking to borrowingNo listing / no trading of sharesStrong in
helping financially weaker section
College of Agricultural Banking, RBI, PUNE
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College of Agricultural Banking, RBI, PUNE Reasons why UCBs were
brought under RBIs controlDemand for introduction of deposit
insurance to cooperative banksRapid growth of the cooperative
banking sector necessitated better monitoringEffective from March
1,1966, provisions of B.R. Act (1949) were extended to UCBsThis
resulted in dual command, cooperation being a state subject
College of Agricultural Banking, RBI, PUNE
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College of Agricultural Banking, RBI, PUNE Progress of Urban
Co-operative BankPHASE I In formative stage, urban credit societies
organised by communitiesPHASE II - Post 1966PHASE III - Post
Marathe CommitteePHASE IV - Post Madhav Rao / Madhavpura Mercantile
Cooperative Bank Crisis
College of Agricultural Banking, RBI, PUNE
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College of Agricultural Banking, RBI, PUNE Progress of UCBs
(Contd.)
(Rs. in crores)No. of
UCBsDepositsAdvances1966-6711061531671990-911307866078021995-96132724165179081997-9815024069227801
College of Agricultural Banking, RBI, PUNE
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College of Agricultural Banking, RBI, PUNE Progress of UCBs
(Contd.)
(Rs. in crores)No. of
UCBsDepositsAdvances200120848084054389200220909306962060200321041015466488820061853112237703792009172115873397918
College of Agricultural Banking, RBI, PUNE
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College of Agricultural Banking, RBI, PUNE State-wise Position
of UCBsFigures in bracket are for 2007
Regional OfficeNumber of banks in Grade II, III and IVNumber of
banks in Grade IINumber of banks in Grade IIINumber of banks in
Grade IV1Guwahati111 (6)4 (4)6 (1)2Thiruvanathapuram489 (11)31
(28)8 (11)3Bhopal5617 (24)26 (15)13 (9)4Kolkata6- (10)- (1)6
(9)5Nagpur6531 (76)20 (39)14 (39)6Hyderabad10444 (33)34 (7)26
(11)7Bangalore18879 (92)97 (55)12 (42)8Bhubaneshwar115 (4)6 (4)0
(4)9Chandigarh134 (3)5 (-)4 (4)10Ahmedabad18750 (88)85 (42)52
(40)11Lucknow308 (17)14 (4)8 (5)12Jaipur92 (13)5 (1)2
(1)13Mumbai10132 (178)49 (76)20 (80)14Chennai11019 (34)76 (22)15
(6)15New Delhi41 (1)2 (-)1 (2)16Jammu11 ()0 (1)0 ()17Dehradun--
(-)- (1)- (2)18Patna11 (-)0 (-)0 (-)19Raipur -- (5)- (-)-
(4)18Patna11 (-)0 (-)0 (-)Total944303454187
College of Agricultural Banking, RBI, PUNE
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College of Agricultural Banking, RBI, PUNE State-wise Position
of UCBsGrade II 598Grade III 295Grade IV 268Grade I 652
Grade I - 845Grade II - 484Grade III - 219Grade IV 173
Figures in for 2007Figures in for 2009 - 1721
College of Agricultural Banking, RBI, PUNE
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College of Agricultural Banking, RBI, PUNE State-wise Position
of UCBsFigures in bracket are for 2006
CentreGrade IGrade IIGrade IIIGrade IVTotal
2006200720062007200620072006200720062007Ahmedabad136114508867424340296284Bangalore9099769285554642297288Bhopal1612282417151497560Bhubaneswar126434441414Chandigarh109131441616Chennai54693234392276132131Dehradun4127Guwahati664644411817Hyderabad486543331871511124116Jaipur2524101331113939Jammu232144Kolkata3031111031795151Lucknow4744131794857770Mumbai17311712817884767180456451Nagpur5317457643393339174171New
Delhi121211221515Patna351155Raipur55414Thiruvananthapuram1014111428231196060Total7166524605984072952702681,8531,813
College of Agricultural Banking, RBI, PUNE
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Centre-wise Distribution of UCBsCollege of Agricultural Banking,
RBI, PUNE
College of Agricultural Banking, RBI, PUNE
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College of Agricultural Banking, RBI, PUNE Role of
RBIRegulatory, Supervisory, Operational and Developmental
Functions(Carried out through the Urban Banks Department)
RBI derives authority to control and supervise the urban banks
through the Banking Regulation Act, 1949 (As Applicable to
Cooperative societies)
College of Agricultural Banking, RBI, PUNE
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College of Agricultural Banking, RBI, PUNE RBIs Regulatory
FunctionsLicence to commence banking business under Section 22 of
B.R. Act, 1949 (AACS)Licence to open branches & extension
countersPermission to deal in foreign exchangeIssue of directions
to maintain cash reserve and liquid assetsPower to control advances
(Section 21) Purposes for which advances are given, margins to be
maintained
College of Agricultural Banking, RBI, PUNE
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College of Agricultural Banking, RBI, PUNE RBIs Regulatory
FunctionsIssue of prudential and operational guidelinesDirections
on maximum limit on advances, prescribe guidelines on individual /
group exposure normsIssue of requisition to RCS for supersession of
board of management of bank / liquidation of banks
College of Agricultural Banking, RBI, PUNE
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College of Agricultural Banking, RBI, PUNE RBIs Regulatory
FunctionsInterest rates on deposits and advances (Section 21)Issue
of Direction (Section 35A)Imposition of penalty (Section
46)Cancellation / rejection of licence (Section 22(4))Prescription
towards CRR / SLRGrant of scheduled status
College of Agricultural Banking, RBI, PUNE
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College of Agricultural Banking, RBI, PUNE Supervisory
FunctionOn-site supervisionOff-site returnsOff-site
surveillance
College of Agricultural Banking, RBI, PUNE
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College of Agricultural Banking, RBI, PUNE
RBIs Developmental FunctionsRefinance to small scale industries
sector through UCBsIdentification of financially unsound banks and
rehabilitation of such banksTraining of urban bank personnel
support given through RBIs training institutions
College of Agricultural Banking, RBI, PUNE
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College of Agricultural Banking, RBI, PUNE Issues of Regulatory
& Supervisory Concern :Sharp increase in no. of banks and
branchesLarge number of financially unsound banksSteep increase in
deposits consequent on deregulationHigh rate of interest on
deposits, consequently on advancesAdverse selection of borrowersLow
capital baseDual/triple controlBelated introduction of CRAR, ALM
etc.High exposure to real estate and other sensitive sector
College of Agricultural Banking, RBI, PUNE
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College of Agricultural Banking, RBI, PUNE Issues of Regulatory
& Supervisory Concern: Problems Faced By The SectorLack of
professionalismPolitical interferenceUnlicensed UCBsLow level of
computerisationNo Central recruitment Faulty recruitment system /
excess staff / poor skill upgradationLow level of operational
efficiencyHigh operating cost
College of Agricultural Banking, RBI, PUNE
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College of Agricultural Banking, RBI, PUNE Issues of Regulatory
& Supervisory Concern: (Contd.)UCBs membership of Payment
System Should it be unconditional?
Experience of MMCBAccess to call money SLR investments
College of Agricultural Banking, RBI, PUNE *
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College of Agricultural Banking, RBI, PUNE Issues of Regulatory
& Supervisory Concern: (Contd.)Governance in UCBs
Is it enough?How much is enough?Growing ambit of operations of
UCBs
Should UCBs have unlimited access to inter-bank markets?Whether
the reach should be nationwide?Access to capital markets?
College of Agricultural Banking, RBI, PUNE *
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College of Agricultural Banking, RBI, PUNE Issues of Regulatory
& Supervisory Concern: (Contd.)Disclosure Standards
Is it enough?How much is enough?Interest Rates on Advances
High interest rates as compared to the commercial banksAdverse
selection of borrowers
College of Agricultural Banking, RBI, PUNE *
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College of Agricultural Banking, RBI, PUNE Regulatory Issues
concerning RBICapital Adequacy
UCBs unable to maintain capitalHPC viewed CRAR to be made
applicable to UCBsIssue pertaining to Deposit Insurance
Some states do not have eligibility clause to be covered under
DICGC Act, 1961Insured banks often default payment of premium
College of Agricultural Banking, RBI, PUNE *
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College of Agricultural Banking, RBI, PUNE Regulatory Issues
concerning RBISupervision of UCBs
Large number of banks On-site inspection in two years time
frameSystem is under severe strain to maintain the scheduleNeed for
off-site surveillance
Other issues
Financially unsound banksUnlicensed banks in KeralaRecent
transactions by UCBs in Government Securities
College of Agricultural Banking, RBI, PUNE *
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College of Agricultural Banking, RBI, PUNE Road Map To
FutureFocus on:
Consolidation : slow down in issue of new LicenceWeeding out
weak unitsStrengthening of regulatory and supervisory standards
College of Agricultural Banking, RBI, PUNE
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College of Agricultural Banking, RBI, PUNE Policy
ChangesStanding Advisory CommitteeGuidelines issued to commercial
banks by DBOD and DBSRecommendations of committees / working
groupFeed back / representations from NAFCUB / local Cooperative
Banks Association / UnionsRecommendations of JPC etc.
College of Agricultural Banking, RBI, PUNE
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College of Agricultural Banking, RBI, PUNE CommitteesMadhava Das
- 1978Marathe - 1992Chitale Committee -1996Madhava Rao -1999Anant
Geete Committee 2002Joint Parliamentary Committee
College of Agricultural Banking, RBI, PUNE
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College of Agricultural Banking, RBI, PUNE Recent Policy
ChangesImplementation of Madhava Rao committee
recommendationsRecent monetary policy measures after the failure of
Madhavpura Mercantile Cooperative Bank Ltd., AhmedabadAnant Geete
Committee recommendationsRecommendations of JPCSardesai Committee
recommendationsMOUOther measures
College of Agricultural Banking, RBI, PUNE
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College of Agricultural Banking, RBI, PUNE
Off-site surveillance systemDesigned for continuous monitoring
of banks operationInitially made applicable for scheduled urban
banks and to be extended to others in a phased manner
College of Agricultural Banking, RBI, PUNE
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College of Agricultural Banking, RBI, PUNE Off-site monitoring
to be more broad-basedInitially, only the scheduled UCBs and UCBs
with deposit size of over Rs. 100 crore covered Now UCBs with
deposit size of Rs. 50 crore and above are included
College of Agricultural Banking, RBI, PUNE
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College of Agricultural Banking, RBI, PUNE Rehabilitation
Increased frequency of inspection for financially unsound banksSLRC
meets to periodically review progressDiscussions with
CEOs/ChairmenTimeframe for improvement
College of Agricultural Banking, RBI, PUNE
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College of Agricultural Banking, RBI, PUNE Application Of
Prudential NormsIntroduction of CRAR Why CRAR Introduced Belatedly
?Various Constraints
College of Agricultural Banking, RBI, PUNE
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College of Agricultural Banking, RBI, PUNE Introduction of
CRAR
DATEScheduled UCBsNon-scheduled UCBSMARCH 31, 20028 %6 %MARCH
31, 20039 %7 %MARCH 31, 2004AS APPLICABLE TO COMMERCIAL BANKS9
%MARCH 31, 2005As Applicable To Commercial BanksAs Applicable To
Commercial Banks
College of Agricultural Banking, RBI, PUNE
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College of Agricultural Banking, RBI, PUNE Introduction of CRAR
(Contd.)CRAR now important parameter to know the financial
soundness of UCBsExpansion etc. not allowed if CRAR not at
stipulated levelLarge Increase in share capital not possible owing
to Acts provisionsUCBs to transfer 50% of profit if stipulated
level not achieved.
College of Agricultural Banking, RBI, PUNE
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College of Agricultural Banking, RBI, PUNE Vishwanathan Working
GroupFor augmenting capital of UCBsState Governments be requested
to exempt the UCBs from the existing monetary ceiling on individual
shareholdingProvide instruments and avenues for raising stable and
long term funds having equity or quasi equity characteristics
College of Agricultural Banking, RBI, PUNE
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College of Agricultural Banking, RBI, PUNE Vishwanathan Working
Group (Contd.)UCBs may be permitted to issue unsecured,
subordinated (to the claims of depositors), non-convertible,
redeemable debentures / bonds, which can be subscribed to by those
within their area of operations and outside (Tier II)
College of Agricultural Banking, RBI, PUNE
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College of Agricultural Banking, RBI, PUNE Vishwanathan Working
Group (Contd.)UCBs may be allowed to issue special shares UCBs can
also be allowed to issue these shares at a premium, which could be
approved by the respective RCS, in consultation with Reserve
Bank
The special shares will be non-voting, perpetual and
transferable by endorsement and delivery Commercial banks may be
allowed to invest in these shares and Tier II bonds of UCBs
College of Agricultural Banking, RBI, PUNE
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College of Agricultural Banking, RBI, PUNE Vishwanathan Working
Group (Contd.)UCBs may be allowed to issue redeemable cumulative
preference shares on specific terms and conditions with prior
permission of RCS, in consultation with Reserve BankUCBs may be
permitted to raise deposits of over 15 year maturity and such
deposits can be considered as Tier II capital subject to their
meeting certain conditions such as
They shall be subordinate to other deposits Ineligible for DICGC
cover
College of Agricultural Banking, RBI, PUNE
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College of Agricultural Banking, RBI, PUNE Vishwanathan Working
Group (Contd.)UCBs with negative networth may raise Tier II bonds
such as bonds, preference share and long maturity deposits through
conversion of existing deposits
RBI may consider it as part of regulatory capital even though
Tier I capital is negative
College of Agricultural Banking, RBI, PUNE
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College of Agricultural Banking, RBI, PUNE Policy Measures after
Madhavpura Mercantile Cooperative Bank Crisis
No inter UCB depositsRationale
against co-operative principlesTantamount to exposure in the
UCBsPrevention of systemic risks1. Prohibition of Deposits by UCBs
With Other UCBs
College of Agricultural Banking, RBI, PUNE
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College of Agricultural Banking, RBI, PUNE Policy Measures after
Madhavpura Mercantile Cooperative Bank Crisis (Contd.)
Call / notice money borrowing should not exceed 2 per cent of
aggregate deposit as at the end of march of previous financial
year. Complete freedom to lendRationale
To prevent asset liability mismatchEvening out temporary
liquidity mismatches 2. Operations in Call Money Market
College of Agricultural Banking, RBI, PUNE
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College of Agricultural Banking, RBI, PUNE
Operations In Call Money Market
UCBs should report the borrowing every next day to MPD and
UBD
Penalty for violationFortnightly statement to Regional Office on
lending and borrowingMonitoring :
College of Agricultural Banking, RBI, PUNE
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College of Agricultural Banking, RBI, PUNE Changes in SLR
Composition
Category Of UCBsMinimum SLR Holding In Government and other
Approved Securities As Per Cent Of NDTLEarlierNow Applicable
Non-scheduled UCBsUCBs With NDTL Of Rs. 25 Crore And Above10.0
%15.0 %UCBs With NDTL With Less Than Rs.25 Crore NIL10.0 %Scheduled
UCBs15.0 %Entire SLR requirement
College of Agricultural Banking, RBI, PUNE
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College of Agricultural Banking, RBI, PUNE Changes in SLR
Composition (Contd.)
Non-scheduled primary (urban) co-operative bankshaving single
branch-cum-head-office or having multiple branches within a single
districthaving a deposit base of Rs.100 crore or less (?) would be
exempted from maintaining SLR in
prescribed assets upto 15% of their DTL UBD Circular dated
February 16, 2006on keeping the required amount, in interest
bearing deposits, with State Bank of India and its subsidiary banks
and the public sector banks
including Industrial Development Bank of India Ltd.
College of Agricultural Banking, RBI, PUNE
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College of Agricultural Banking, RBI, PUNE Monetary Policy
Measures 2003
Prohibition on loans to directors, their relatives and concerns
in which they are involvedBan to be effective from October 01,
2003Fortnightly return prescribed to monitorRecommendations of
Geete committee i.e. Enhanced limit of unsecured advances,
implemented
Ban On Loans to Directors etc.
College of Agricultural Banking, RBI, PUNE
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College of Agricultural Banking, RBI, PUNE Ban on Loans to
Directors (Contd.) Following categories of director related loans
are out of the purview:
regular employee-related loans to staff directors on the Board
of UCBsnormal loans as applicable to members to the directors on
the Boards of salary earners co-operative banks and normal
employee-related loans to Managing Directors of Multi-State
co-operative banksUBD Circular dated October 06, 2005
College of Agricultural Banking, RBI, PUNE
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College of Agricultural Banking, RBI, PUNE Anant Geete Committee
Recommendations (2002)
Increased as recommended by the CommitteeFor non-scheduled UCBs
with DTL < than Rs.10 crore : Rs.50,000/-For non-scheduled UCBs
with DTL > than Rs.10 crore : Rs.1.00 lakhFor scheduled banks :
Rs.2.00 lakhOnly Gr. I banks can take advantage of this
increase
1. UNSECURED ADVANCES
College of Agricultural Banking, RBI, PUNE
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College of Agricultural Banking, RBI, PUNE Anant Geete Committee
Recommendations (Contd.) Both gold loan and small loans upto Rs.1
lakh were exempted from the 90 days norms, and these loans will
continue to be governed by the 180 days norm for recognition of
loan impairment. UCBs permitted to open extension counters in
residential colonies. The condition to have at least five hundred
beneficiaries accounts for extension counters was withdrawn
Non-scheduled UCBs were allowed to place their surplus funds with
strong scheduled UCBs, subject to certain conditions
College of Agricultural Banking, RBI, PUNE
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College of Agricultural Banking, RBI, PUNE Anant Geete Committee
Recommendations (Contd.)
Scheduled UCBs permitted to accept deposits from other
UCBsRequirement of deposit accepting banks:
Three consecutive A audit ratingsCompliance with RBI
requirementsNo inter scheduled UCB deposits2. PLACEMENT OF DEPOSITS
WITH OTHER UCBsDone away with
College of Agricultural Banking, RBI, PUNE
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College of Agricultural Banking, RBI, PUNE JPC
Recommendations
Concurrent audit made mandatory for all UCBsAudit committee of
board as stated in earlier circulars, should exist in each of the
banksAudit committee to monitor for all audit functions as also
compliance with RBI inspection reports, RBI guidelines etc.
1. Strengthening of Audit:
College of Agricultural Banking, RBI, PUNE
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College of Agricultural Banking, RBI, PUNE JPC Recommendations
(Contd.)
Compliance to be furnished within 6 weeksAll defects pointed out
in inspection report to be removed within 4 monthsCertificate to be
effect submitted to RBI within 4 monthsFalse certificate or delayed
compliance to attract penal actionStrict penalty for non compliance
of RBI directives
2. COMPLIANCE TO RBI REPORT:
College of Agricultural Banking, RBI, PUNE
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College of Agricultural Banking, RBI, PUNE Other JPC
RecommendationsDual control should goInspection report should
comment on the quality of audit reportImprovement of on-site /
off-site supervisionProhibition of loans & Advances to
Directors and their relatives and concerns in which they are
interested
College of Agricultural Banking, RBI, PUNE
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College of Agricultural Banking, RBI, PUNE Sardesai
Committee
ON-SITE INSPECTION- NEW THRUSTClassification of banksExisting
frequencyRevised frequency
Scheduled banks Once in a yearOnce in a yearGrade I Once in
three yearsOnce in two yearsGrade II NA Once in 18 monthsGrade
IIIOnce in a yearOnce in a yearGrade IVOnce in a yearOnce in a
year
College of Agricultural Banking, RBI, PUNE
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College of Agricultural Banking, RBI, PUNE Sardesai Committee
(Contd.)
Each UCB to be inspected at least once in two yearsFocused
supervision of UCBs with deposits more than Rs.100 croreROs to be
fully responsible for follow upPeriodic interaction of ROs with
State Authorities
Inspection New Approach:
College of Agricultural Banking, RBI, PUNE
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College of Agricultural Banking, RBI, PUNE Sardesai Committee
(Contd.)Upgradation of skills of Inspecting OfficersStaff
requirements of UBD being finalisedThree ROs with huge backlog to
initiate revised measures
Inspection New Approach
College of Agricultural Banking, RBI, PUNE
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College of Agricultural Banking, RBI, PUNE Shifting focus -
Inspection
Traditional ApproachCAMELSBalance Sheet ApproachAnalytical
ApproachImpressionisticBased on certain fixed parametersProne to
prejudices of the IOObjective ?IO may miss certain key
areasConclusions based on performance in certain key areas
College of Agricultural Banking, RBI, PUNE
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College of Agricultural Banking, RBI, PUNE Identification Of
Financially Unsound Banks And Future Set UpFocus: On Early
Identification By Objective ParametersNomenclature changed banks
not to be classified as weak / sickThe banks to be classified into
four Grades depending upon their financial statusFour grades
depending upon NPA level, CRAR , Regulatory
complianceProfitability
College of Agricultural Banking, RBI, PUNE
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College of Agricultural Banking, RBI, PUNE Dual Control of UCBs
Managerial aspects viz.
RegistrationConstitution of managementAdministration and
recruitment Amalgamation and liquidationStatutory audit /
appointment of auditors are with State Governments
College of Agricultural Banking, RBI, PUNE
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College of Agricultural Banking, RBI, PUNE Dual Control of UCBs
(Contd.) RBI does not have any powers to: --Appoint or remove the
members of the board of management of urban banks-Initiate
amalgamation of two urban banks-Appoint auditors of urban banks
Matters related to banking operations are governed by directives
and guidelines issued by the RBI
College of Agricultural Banking, RBI, PUNE
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College of Agricultural Banking, RBI, PUNE Dual Control on UCBs
(Contd.)
Shifting to Central SubjectConcurrent ListDemarcation of Areas
of managerial related and banking related functions
Issues:
College of Agricultural Banking, RBI, PUNE
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College of Agricultural Banking, RBI, PUNE Separate Supervisory
AuthorityDuality / multiplicity of control slackens regulatory
controlApex Single body to regulate and superviseComprising
officials from State Government, Central Government, Reserve Bank
of India, Co-operative banks, independent experts etc.
College of Agricultural Banking, RBI, PUNE
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College of Agricultural Banking, RBI, PUNE Separate Supervisory
Authority (Contd.) RBI RESPONSE : After separate supervisory
body
The urban co-operative banks should not accept / demand deposits
(chequable deposits)They should not resort to non collateralised
borrowings and they should not have access to call money market,
andGovernment of India may consider evolving a suitable mechanism
to safeguard the interests of depositors of urban co-operative
banks
College of Agricultural Banking, RBI, PUNE
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College of Agricultural Banking, RBI, PUNE Amendment to B. R.
Act, 1949Management related functions, like, Elections, Conduct of
Directors, etc., to be with RCS.Banking related functions to be
with RBIAudit function, including statutory audit to be with
RBI
College of Agricultural Banking, RBI, PUNE
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College of Agricultural Banking, RBI, PUNE Amendment to B. R.
Act, 1949 (Contd.) Section 56 of B. R. Act, 1949 to be deletedMake
all provisions of the parent Act applicableSection 10B and 10BB
requiring RBI approval for appointment of full time Chairman /
MDSection 10C would enable non-member as ChairmanServing MPs / MLAs
/ MLCs as also stockbrokers banned from being a director of the
bank
College of Agricultural Banking, RBI, PUNE
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College of Agricultural Banking, RBI, PUNE Disclosure
NormsApplicable to UCBs with deposits of Rs.100 crore &
moreCRAR, investments, advances against real estate/shares,
interest of directors, profitability etc. To be declared.
College of Agricultural Banking, RBI, PUNE
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College of Agricultural Banking, RBI, PUNE Specific Issues
Licence Cancelled As Directed By The Supreme CourtThe Court
Holds That The RBI Can Not Give Banking Licence to
Societies Registered Under Multi State ActDirections Issued to
the Bank
Developments Relating to Apex Cooperative Bank of Maharashtra
and Goa
College of Agricultural Banking, RBI, PUNE
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College of Agricultural Banking, RBI, PUNE Unlicensed Banks
Section 2(gg) of DICGC Act, 1961 defines eligible banksSection 16
of the Act deals with the liability of the Corporation in respect
of insured deposits
College of Agricultural Banking, RBI, PUNE
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College of Agricultural Banking, RBI, PUNE Revised Licensing
Policy for New Urban Banks Strong start up capital 4 categories
Emphasis on professionalism Concept of unit banks Relaxation for
special categories to continue Screening committee to process
proposals
Focus: Arrest Mushrooming Growth in UCBs
College of Agricultural Banking, RBI, PUNE
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College of Agricultural Banking, RBI, PUNE Revised Licensing
Policy: Screening CommitteeComprised of four eminent experts of
impeccable credentials from the fields of banking, finance and
co-operation Need and potential, Viability of the proposal /
institutionSince September 2001 up to date, the Committee
considered 216 proposals 'in principle' approval for 9
proposals205 proposals rejected (2 under correspondence)(Licenses
granted in 1999-2000 : 114, 2000-01 : 28)
College of Agricultural Banking, RBI, PUNE
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College of Agricultural Banking, RBI, PUNE Revised Licensing
Policy: Present StanceAnnual Policy Statement 2004 05
To consider issuance of fresh licences only after a
comprehensive policy on UCBs, including an appropriate legal and
regulatory framework for the sector, is put in place and a policy
for improving the financial health of the urban co-operative
banking sector is formulated early
College of Agricultural Banking, RBI, PUNE
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College of Agricultural Banking, RBI, PUNE Revised Licensing
Policy: Present StanceUCBs, other than those in Grade III and IV,
registered in states which have signed MoU and those registered
under Multi-State Cooperative Societies Act, 2002 will be eligible
to convert the extension counters on completion of three years of
their operation into full-fledged branches
Proposal is for shifting/relocation of the converted branch
within the city/town limit Banking services to the existing
customers of the extension counter, including the institutional
customer, are ensuredNo new extension counter will be allowed in
the institution in which the extension counter is housed
presently
College of Agricultural Banking, RBI, PUNE
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College of Agricultural Banking, RBI, PUNE Unlicensed UCBsWHAT
IS AN UNLICENSED BANK ?REQUIEMENT FOR LICENSING: (Present
Policy)
Compliance for entry point normsCompliance with CRARNet NPA less
than 10%, andProfit for preceding 3 yearsFinal decision for
existing unlicensed March 31, 2003Directions of BFS
College of Agricultural Banking, RBI, PUNE
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College of Agricultural Banking, RBI, PUNE Annual Policy
Statement: 2004-05To consider issue of licences to new proposals
only after a comprehensive policy is in place, including
appropriate legal regulatory frameworkTo consider only such schemes
of reconstruction which envisages recapitalisation by
stakeholders
College of Agricultural Banking, RBI, PUNE
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College of Agricultural Banking, RBI, PUNE Mid Term Review of
Annual Policy Statement: 2004-05Vision DocumentStanding Advisory
Committee comprising of DG (RBI), Govt. representatives, Select
State Govt. representatives,Federation, IBA, DICGC, NABARD would
meet on quarterly basis
College of Agricultural Banking, RBI, PUNE
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College of Agricultural Banking, RBI, PUNE Vision DocumentNeed
for State specific approach
State Level Task Force on Coop Urban Banks (TAFCUB) comprising
of RD, RCS, Central Office and in-charges of UBD ROs and a
representative each from NAFCUB and state federationsMOU signed
with the State of Gujarat, Andhra Pradesh, Karnataka and Madhya
PradeshTAFCUB would identify the potentially viable urban
cooperative banks and draw up a time bound action plan for revival
of UCBs by setting specific monitorable milestones
College of Agricultural Banking, RBI, PUNE
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College of Agricultural Banking, RBI, PUNE Vision Document
(Contd.) Terms of Reference
Categorise UCBs in the state under two tiers of regulatory
regimeIdentify banks, which are viable, potentially viable and
unviable To recommend various conditions, including the nature and
extent of funds required to be infused, in each UCB identified as
potentially viablethe sources of fund changes in management where
necessary and the time frame for achieving viabilityIn doing so,
the TAFCUB may assign responsibility to different agencies for
facilitating the turn-aroundTo set up milestones for evaluation of
progress made under the rehabilitation plan
College of Agricultural Banking, RBI, PUNE
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College of Agricultural Banking, RBI, PUNE Vision Document
(Contd.) To recommend the future set up of the existing unlicenced
banks whose applications are pending with Reserve Bank of IndiaTo
recommend the manner and time frame for exit of the un-viable banks
either by
merger / amalgamationconversion into a credit society and
liquidationThe proposals for merger / amalgamation recommended by
the TAFCUB shall conform to the guidelines issued in this regard To
arrive at a threshold limit of deposits that would make a depositor
automatically eligible to become a memberTo recommend on the
management aspects of a bank which is placed under the revival
planAny other issues as may be referred to it by the Reserve Bank
of India
College of Agricultural Banking, RBI, PUNE
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College of Agricultural Banking, RBI, PUNE Vision Document
(Contd.) Proposed Operating Framework
Unit Banks (Deposits Less than Rs. 50 crore)Simplified
regulatory regimeCRAR could be replaced by NOF to NDTL
ratioExposure to sensitive sector restrictedLower prescribed limit
for investment in G-SecRestrictions to insulate them from systemic
shocksRestricted geographical operationsSuch banks to roll back
operations in far off locations
College of Agricultural Banking, RBI, PUNE
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College of Agricultural Banking, RBI, PUNE Vision Document
(Contd.) Proposed Operating Framework
All other Banks Regulatory prescriptions as applicable to
commercial banksExtant relaxations may continue up to the period
specifiedThere should be no concept of unscheduled multi state
bankCRCS may ensure that a bank is scheduled before it is granted
license under MCS ActExisting scheduled banks both under MCS Act
and State Cooperative Societies who do not comply with prudential
and regulatory regime akin to that of commercial banks could be
excluded from second schedule of RBI Act
College of Agricultural Banking, RBI, PUNE
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College of Agricultural Banking, RBI, PUNE Vision Document
(Contd.) Supervision
Increased dependence on off-site surveillance of RBI and on-site
supervision of RCS in respect of small unit banks would provide RBI
with increased flexibility to deploy resources to larger and risky
banksDevelopmental Role
RBI may help particularly small UCBs in helping their skillsCAB
could provide subsidised training RDs of RBI may facilitate with
PDs enabling UCBs to buy sell G-Sec easily
College of Agricultural Banking, RBI, PUNE
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College of Agricultural Banking, RBI, PUNE Two Tier Framework
Smaller UCBs whose operations are limited to a single district and
have deposits of less than Rs.100 crore
Allowed to adopt 180-day delinquency norm for classification of
assets as non-performing Smaller UCBs given exemption from
maintaining SLR in Government securities (up to 15 per cent of
NDTL) to the extent of funds placed in interest bearing deposits
with the public sector banksNot subject to the provisioning norms
of 0.40 per cent of Standard Advances which is applicable to the
larger UCBs Simplified reporting system consisting of five returns
has been introduced for the smaller banks having deposits between
Rs.50 crore and Rs.100 crore and whose branches are limited to a
single district
College of Agricultural Banking, RBI, PUNE
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College of Agricultural Banking, RBI, PUNE Two Tier Framework
Changes Tier I banks :
Unit banks i.e. banks having a single branch / Head Office and
banks with deposits below Rs.100 crore, whose branches are located
in a single districtBanks with deposits below Rs.100 crore having
branches in more than one district, provided the branches are in
contiguous districts and deposits and advances of branches in one
district separately constitute at least 95% of the total deposits
and advances respectively of the bankBanks with deposits below
Rs.100 crore, whose branches were originally in a single district
but subsequently, became multi-district due to reorganization of
the districtTier II Banks: All other banks
The deposit base of Rs. 100 crore will be determined on the
basis of average of the fortnightly Net Demand and Time Liabilities
in the financial year concerned Similarly, advances will be
determined on the basis of fortnightly average in the financial
year concernedMarch 07, 2008
College of Agricultural Banking, RBI, PUNE
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College of Agricultural Banking, RBI, PUNE New Business
OpportunitiesInsurance
All scheduled UCBs having a minimum net worth of Rs.50 crore
were permitted to undertake insurance business as corporate agents.
All other UCBs could undertake insurance business on a referral
basis, without any risk participation, through their network of
branches (January 24, 2005)UCBs registered in States that have
entered into MoUs with the Reserve Bank or registered under the
Multi State Co-operative Societies Act, 2002 to undertake insurance
agency business as corporate agents without risk participation,
subject to compliance with the following eligibility norms: Minimum
networth of Rs 10 croreShould not have been classified as Grade III
or IV bank.In case of UCBs registered in States which have not
signed MoUs with the Reserve Bank existing norms shall continue
College of Agricultural Banking, RBI, PUNE
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College of Agricultural Banking, RBI, PUNE New Business
Opportunities (Contd.) Distribution of Units of Mutual Funds
UCBs registered in States which have signed MoU and those
registered under Multi-State Co-operative Societies Act, 2002 now
permitted to enter into agreement with mutual funds for marketing
their units, subject to certain prescribed normsConduct of Foreign
Exchange Business by UCBs
UCBs registered under the MOU State, or under the Multi-State
Co-operative Societies Act, 2002, permitted for Authorised Dealer
(AD) Category I and II licenceIt was also decided not to give any
fresh authorisation to UCBs to function as Full Fledged Money
Changers (FFMCs)Installation of Automated Teller Machines
(ATMs)
Sound scheduled and non-scheduled UCBs permitted to set up
select off-site/ on-site ATMsBanks permitted to have ATMs can also
issue ATM-cum-debit cardsPrior approval of the Reserve Bank for
network connectivity and/or sharing of the ATMs dispensed
withConversion of Extension Counters into Full-Fledged Branches
Sound UCBs registered in MOU States and those registered under
the Multi-State Cooperative Societies Act, 2002 allowed to convert
existing extension counters into full-fledged branches
College of Agricultural Banking, RBI, PUNE
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College of Agricultural Banking, RBI, PUNE New RelaxationsTier-I
banks
The 180 day loan delinquency norm for NPAs extended by one more
year i.e. up to March 31, 2008The 12-month period for
classification of a substandard asset in doubtful category will be
effective from April 1, 2008Further these banks would be required
to provide 100% on the secured portion of D-III advances classified
as doubtful more than three years on or after April 1, 2010 For the
outstanding stock of D-III advances as on March 31, 2010, banks
will be required to provide as under:50% as on March 31, 201060% as
on March 31, 201175% as on March 31, 2012100% as on March 31,
2013Tier-II banks
100% provisioning for advances classified as D-III (doubtful
more than three years) will apply to those classified as such on or
after April 1, 2007 instead of those so classified on or after
April 1, 2006 Consequently, for the outstanding stock of D-III
assets as on March 31, 2007, banks would be required to provide as
under:50% upto March 31, 200760% as on March 31, 200875% as on
March 31, 2009100% as on March 31, 2010
College of Agricultural Banking, RBI, PUNE
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College of Agricultural Banking, RBI, PUNE New Norms (Contd.)
Statutory minimum CRR requirement of 3 per cent of total demand and
time liabilities no longer exists with effect from the said
notified date (April 25, 2007)Know Your Customer (KYC) Norms /
Anti-Money Laundering (AML)Standards / Combating of Financing of
Terrorism (CFT)
All cross-border wire transfers must be accompanied by accurate
and meaningful originator informationCross-border wire transfers
must contain the name and address of the originator and where an
account exists, the number of that account Information accompanying
all domestic wire transfers of Rs. 50000/- and above must include
complete originator information i.e. name, address and account
number etc., unless full originator information can be made
available to the beneficiary bank by other means. If a bank has
reason to believe that a customer is intentionally structuring wire
transfers to below Rs. 50000/- to several beneficiaries in order to
avoid reporting or monitoring, the bank must insist on complete
customer identification before effecting the transferInterbank
transfers and settlements where both the originator and beneficiary
are banks or financial institutions would be exempted from the
above requirements
College of Agricultural Banking, RBI, PUNE
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College of Agricultural Banking, RBI, PUNE New Norms (Contd.)
Provisioning for Standard Assets (February 19, 2007)
Direct advances to agricultural and SME sectors 0.25 %Personal
loans, Loans and advances qualifying as capital market exposures,
Commercial real estate loans and loans and advances to systemically
important NBFCs-ND. - 2.00 %All other loans and advances not
included in above - 0.40%UCBs to extend individual housing loan up
to the limit of Rs. 25.00 lakh per beneficiary of a dwelling
unit
However, housing finance to borrowers availing loans above Rs
15.00 lakh will not be treated as priority sector lending
College of Agricultural Banking, RBI, PUNE
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College of Agricultural Banking, RBI, PUNE Branch Licensing
RelaxationsBranch licenses only in MOU States
UCBs whose net worth was not less than Rs.10 crore and average
networth per bank, including the proposed ones was not less than
Rs.2 crore in A and B category centres and Rs.1 crore in C and D
category centresThe eligibility of the banks to be decided on the
basis of their audited balance sheet for the financial year ended
March 2007
College of Agricultural Banking, RBI, PUNE
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College of Agricultural Banking, RBI, PUNE Extension of Area of
OperationsLicensed Grade I UCBs may extend their area of operation
to the whole of the district of registration and to its adjoining
districts within their State of registration, without prior
permission from the RBIEligible banks need not approach Reserve
Bank for seeking 'no objection' for extension of area of operation
as stated above. Such banks may directly approach the RCS of the
State concerned for extension of area of operation to the entire
district of registration and its adjoining districts within the
State of registration.Extension of Area of Operation Beyond the
Adjoining Districts and the State of Registration
Extension of Area of Operation beyond the adjoining districts
and the State of registration is not permitted according to the
existing policy
College of Agricultural Banking, RBI, PUNE
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College of Agricultural Banking, RBI, PUNE Branch Licensing
Grade III / IV UCBs and not complying with Section 11(1) of B.
R. Act, 1949 (AACS)to obtain prior approval of the RBI and / or RCS
for :- Sale of bank's own premises-Surrender of existing premises
taken on lease / rental basis-Acquisition of new premises on
ownership or lease / rental basis-Shifting of offices / departments
as a result of sale of premises / surrender of premises /
acquisition of new premises.-To submit their application to the
Regional Office concernedUBD Circular dated July 01, 2008
College of Agricultural Banking, RBI, PUNE
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College of Agricultural Banking, RBI, PUNE Branch Licensing
Relaxations
Branch licenses only in MOU States
UCBs whose net worth was not less than Rs.10 crore and average
networth per bank, including the proposed ones was not less than
Rs.2 crore in A and B category centres and Rs.1 crore in C and D
category centresThe eligibility of the banks to be decided on the
basis of their audited balance sheet for the financial year ended
March 2007 Annual Policy 2007 08 UBD Circular July 04, 2007
College of Agricultural Banking, RBI, PUNE
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College of Agricultural Banking, RBI, PUNE Branch Licensing
Relaxations (contd.)Eligibility Criteria
Well managed and financially sound UCBs MOU signed States and
Those registered under Multi-State Co-operative Societies Act, 2002
may submit their proposals for branch expansion based on their
Annual Business Plans (ABP) for approvals to the respective
Regional Offices of the Urban Banks Department of RBIABP will be
for a period of twelve months beginning 1st April of the following
year. UCBs should satisfy the followingCRAR of 10% on a continuous
basis with minimum owned funds commensurate with entry point
capital norms for the centre where branch is proposedNet NPAs being
less than 10%.No default in the maintenance of CRR/SLR during the
preceding financial yearNet profit in the immediate preceding
financial year andRegulatory comfort - compliance with B. R. Act,
1949 (AACS) and the instructions / directions issued by RBI from
time to timeJune 16, 2008
College of Agricultural Banking, RBI, PUNE
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College of Agricultural Banking, RBI, PUNE Mahila Banks -
MembershipCan enroll male members up to a limit of 25 % of their
total regular membership, subject to compliance by the banks with
their respective bye-laws Mahila UCBs to comply with the entry
point norms for general category banks
College of Agricultural Banking, RBI, PUNE
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CAMELS FrameworkCollege of Agricultural Banking, RBI, PUNE
ParametersWeightsCapital Adequacy18%Asset
Quality18%Management18%Earnings10%Liquidity18%Systems 18%
College of Agricultural Banking, RBI, PUNE
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Camels Framework (contd.) College of Agricultural Banking, RBI,
PUNE
Weighted Average/ marksRatingBelow 45D45 49C-50 54C55 59C+60
64B-65 69B70 74B+75 79A-80 85AAbove 85A+
College of Agricultural Banking, RBI, PUNE
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Health of the SectorStress tests were carried out on 52
scheduled UCBs accounting for 43 per cent of the total assets at
end-March 2007 of all scheduled UCBs
Tests restricted to the credit portfolio of these banksThe
credit portfolios of the UCBs were given shocks in the form of an
increase in the provisioning requirement and an increase of 25 per
cent and 50 per cent in the non-performing assetsTests revealed
that as at end-March 2007, 27 banks (accounting for 38 per cent of
scheduled UCBs assets) would not have been able to comply with the
9 per cent with CRAR norm with an increase in NPA levels by 25 per
cent
College of Agricultural Banking, RBI, PUNE
College of Agricultural Banking, RBI, PUNE
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Health of the Sector (contd.)At the system level, the CRAR
declined from 11.4 per cent to 5.6 per cent at 25 per cent stress
in NPASFurther, with an increase in NPA levels by 50 per cent, the
number of banks that would not have been able to comply with the
stipulated minimum increased to 31At the system level, the CRAR
dipped sharply to 2.8 per cent
College of Agricultural Banking, RBI, PUNE
College of Agricultural Banking, RBI, PUNE
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Umbrella OrganisationProfessionally Managed organsation that
would provide
Offering credit facilities Providing liquidity to meet short
term mismatches Fund management services Investment banking
services Payment and settlement services/gateway IT Services ATM
Network and services Management consultancy Capacity building
servicesCollege of Agricultural Banking, RBI, PUNE
College of Agricultural Banking, RBI, PUNE
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Umbrella Organisation (contd.)Membership to UO voluntaryWill be
an NBFC. Can be converted to a bank laterAuthorised capital Rs. 200
crorePaid up capital Rs. 100 croreMembership at 10 paise per Rs.
100 assetOne time membership of Rs. 1 lakh
College of Agricultural Banking, RBI, PUNE
College of Agricultural Banking, RBI, PUNE
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Umbrella Organisation (contd.)Being a non-deposit taking NBFC,
it would have access to the following sources for its working
capital:
Borrowings from banks/financial institutions Deposits: term
deposits from UCBs Debt instruments: bonds/debentures Refinance:
against financial assets (loans and advances) including securities
Other miscellaneous sourcesCollege of Agricultural Banking, RBI,
PUNE
College of Agricultural Banking, RBI, PUNE
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Umbrella Organisation (contd.)Deposits kept by the UCBs with the
UO qualifying as CRR/SLR Permitting the UO membership of the
Payment & Settlement systems Any other support that may be
required in future, such as setting up of ATM networks, etc.
College of Agricultural Banking, RBI, PUNE
College of Agricultural Banking, RBI, PUNE
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Umbrella Organisation (contd.)Emergency Fund Facility Scheme
under a tripartite Industry Support Agreement (ISA)
UCBs under State Cooperative Act to contribute 0.5 per cent of
their asset to the fund as deposits at a specified rate of interest
Fund would be available to the participating UCBs as a soft loan
(liquidity support) carrying interest, say at 8% [cost of funds
(6%) +2% markup] for a period of not more than six months/one
yearThe quantum of liquidity support at a soft rate (First Tranche)
may be capped at 50% of net worth of the UCB concernedCollege of
Agricultural Banking, RBI, PUNE
College of Agricultural Banking, RBI, PUNE
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Umbrella Organisation (contd.)Under the ISA, a participating UCB
should also commit to provide a line of credit to the Emergency
Fund when called upon to do so (say additional 0.05% of its assets)
at a specified rate of interest (say, the prevailing interest rate
for one year deposit)The amount may be used for providing liquidity
support under Second and Third Tranches to UCBs, at rates higher
than the loan under First Tranche say at 10% [ cost (8%)+ 2%mark
up} and 12%[cost(10%)+2% mark up) respectively. The Second and
Third Tranches may also be to the extent of 75% and 100% of the net
worth of the UCB concerned, respectivelyTAFCUBs may be entrusted
with the responsibility of working as the Steering Committee for
setting up of trust fund
College of Agricultural Banking, RBI, PUNE
College of Agricultural Banking, RBI, PUNE
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Umbrella Organisation (contd.)Revival Fund
UCBs with negative net worth were to be brought to positive net
worth, an enormous sum of about Rs.2, 500 crore may be requiredRBI
may pursue a menu of options, including mergers, with or without
DICGC supportThe total net profit of the sector being about
Rs.1,000 crore, mobilization of this magnitude of resources from
the sector may not be feasibleSuch a fund could only be raised out
of contribution from the net profits of UCBs Further, contribution
from the profits to the Revival Fund would be resisted by UCBsThe
Working Group also felt that the State and Central Government may
not come forward to contribute to the Revival Fund for
UCBsTherefore, creation of separate Revival Fund for UCBs is not
recommendedCollege of Agricultural Banking, RBI, PUNE
College of Agricultural Banking, RBI, PUNE
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Report on IT Support for UCBsThis minimum level of IT
infrastructure should include the following:Computerized front-end
i.e. customer interfaceAutomatic backend accounting (through
software)Computerized MIS reporting; andAutomated regulatory
reporting
College of Agricultural Banking, RBI, PUNE
College of Agricultural Banking, RBI, PUNE
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Report on IT Support for UCBs (contd.)Application Service
Provider (ASP) Model
Agency like IDRBT could short-list/select one/ few vendors and
be the conduit and service quality assuror to the banksPayment
model for the ASP option includes a one time payment and a small
charge every month combined with per transaction feeInitial
Investment in ASP model would be less and by combining the
requirements of a large number of banks the cost could be further
reducedGood for smaller UCBs
College of Agricultural Banking, RBI, PUNE Models Suggested
College of Agricultural Banking, RBI, PUNE
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Report on IT Support for UCBs (contd.)Outright Purchase
Model
Only UCBs which have a business of more than 100 crores, CRAR of
over 9% and have been profit making for the past 3 years could be
provided support for outright purchase Outright purchase of the
Core Banking, including data centre, the cost would be in the range
of 1.5 crore to 2 crore for 5-10 branches per bank
College of Agricultural Banking, RBI, PUNE Models SuggestedOnly
those banks which are well capitalised and with good track record,
who give confidence and comfort that the end use of funds are
assured, and that they haveIT savvy personnel to implement/oversee
and deal with the vendors and for whom investing in an outright
purchase option is financially a preferable option should be given
the option to choose this model
College of Agricultural Banking, RBI, PUNE
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Report on IT Support for UCBs (contd.)Support will be available
to all UCBs but it should not be treated as a grantSupport may be
in the form of a loan and not subsidyInterest free loan for 7 years
for both hardware and software
College of Agricultural Banking, RBI, PUNE Delivery MechanismIf
required, IDRBT may develop an area of expertise within itself to
cater to the ITneeds of small banks, including UCBs. National and
State Federation ofcooperatives may also think of creating such IT
facilities for UCBs in the long runfor the benefit of the
sector
College of Agricultural Banking, RBI, PUNE
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Report on IT Support for UCBs (contd.)Big banks preferring to go
for outright purchase of software and hardware
Interest free with only service charge of percent to 1 percent
to be charged by the SCB routing the loan may be consideredWeak /
sick banks, the moratorium may be for two yearsIn case the UCB
defaults on its repayment obligations even after that, a view may
be taken at that point regarding other options like continuation of
management, non-disruptive exit of the bank etc.College of
Agricultural Banking, RBI, PUNE Delivery Mechanism
College of Agricultural Banking, RBI, PUNE
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Report on IT Support for UCBs (contd.)Banks adopting ASP
Model
Interest-free loan by the Reserve Bank could be through IDRBT,
which could prepare Systems Requirement Specifications, select
vendors, prepare development / testing & implementation plans,
and vetting the SLA (Service Level Agreement) between users i.e.
UCBs and the service providing entityUCBs adopting outright
purchase model
The Group felt that the Reserve Bank may not be able to extend
direct loans However, NABARD has a separate fund for IT usage in
co-operative sector, a portion of which can be routed to UCBs,
through SCCB / DCCBsCollege of Agricultural Banking, RBI, PUNE
Delivery Mechanism
College of Agricultural Banking, RBI, PUNE
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College of Agricultural Banking, RBI, PUNE Thank You
College of Agricultural Banking, RBI, PUNE
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