It
may have been the mood evoked by Davos. Or it may be the ''confidence''
that comes at the fag end of a successful tenure. But State Bank of
India Chairman Om Prakash Bhatt took many by surprise when he defended
the ''teaser'' loan scheme for housing that the Reserve Bank of India
has been advising banks to withdraw (See Indian Express, 31 January
2011).
Teaser loans, which gained in notoriety in the run up to sub-prime
crisis in the United States, offer loans for housing that involve
relatively low interest rates during the early phases of the loan.
These rates are then reset and instalments on the loan hiked substantially
to cover the full charges due on the loan during its tenure at the
appropriate interest and amortisation rate.
It should be obvious that teaser rates are offered to attract borrowers,
some of whom may have stayed out of the market if higher rates were
applicable immediately. The difficulty is that some of these borrowers
may be making erroneous projections of future incomes or not even
calculating the burden they would have to carry when rates are reset.
In addition, if the rates charged when they are reset are floating
rates, borrowers may not have factored in the danger of an increase
in the interest costs that may ensue. In the event, borrowers who
may not be in a position to carry the repayment burden may be drawn
into the universe of borrowers.
Bhatt’s defence of the scheme in India is four-fold. First, that when
checking the eligibility of a borrower, what is examined is his or
her ability to repay the loan at the higher interest rate that kicks
in during the later phases of the loan. Second, that (for reasons
that are not clear) for ''anyone who takes a home loan, repayment
is generally difficult in the first two-three years.'' Third that
since teaser rates are being charged on loans of smaller sizes (less
than Rs. 10 lakh), they benefit the aam admi. And, finally, that NPAs
on home loans are the lowest and the bank has the benefit of the client’s
house as collateral to ensure the safety of the credit asset.
The first two of these arguments are without substance. If clients
are those who are seen as being able to cover the higher rate, the
reason why they are being offered a teaser in the first instance is
not clear. And if they are worthy borrowers of this kind, the argument
that they would find it difficult to pay their instalments in the
first year or two and then feel comfortable to do so is also a bit
difficult to swallow. The point is that Mr. Bhatt should know otherwise.
The debate on teaser loans is no invention of the Reserve Bank of
India. It has arisen out of what experience has taught us in other
contexts, including during the recent sub-prime crisis.
From the point of view of banks opting for teaser rate loans, such
rates are essentially a means of expanding their retail lending business.
If that is the motivation, driven by say access to additional cheap
liquidity, banks may be less diligent when assessing the eligibility
of borrowers. This has consequences both positive and negative. Lending
practices that seek to attract borrowers kept out of credit markets
in the past are indeed democratic, inasmuch as they deliver credit
to those who could not access credit before. When this occurs in the
housing market, it does, through market mediated mechanisms, expand
the population that is able to own their own homes. However, one fall-out
of this tendency could be an increase in lending to less creditworthy
or sub-prime borrowers and therefore in the proportion of defaults
and foreclosures. When defaults are not too high foreclosures permit
recovering the capital lent out by the banks. But if defaults and
foreclosures proliferate, housing markets are bound to be depressed
making it difficult for banks to recover their capital. Hence, when
loan pushing is stretched beyond a point and continues for long, default
percentages can rise to levels where they could affect the viability
of individual banks and the banking system. This is what partly happened
during the sub-prime crisis.
It is in this background that we need to assess the apprehensions
expressed by India’s banking regulator, the Reserve Bank of India,
regarding lending for housing purchases in general and lending based
on teaser loans in particular. It has been known for some time now
that, facilitated and encouraged by financial liberalisation, Indian
banks have been following international trends and expanding their
retail lending substantially, so much so that well above a fifth of
commercial bank advances are now to the retail sector. A very high
proportion of those advances have been to housing, which finances
an asset that serves as the best collateral. Hence, early into this
trend the RBI had cautioned banks against excessive exposure to the
housing market. Yet banks not only expanded such lending but opted
to push credit for housing using schemes such as teaser rate loans.
In response, the regulator has through a series of measures sought
to rein in such ending. In its Annual Policy Statement for 2006-07
the Reserve Bank of India increased the general provisioning requirement
for residential housing loans exceeding Rs 20 lakh from 0.40 per cent
to 1.0 per cent. Subsequently, the RBI warned banks against resorting
to teaser interest rates, given the experience with the consequences
of such rates in the US and other contexts. However, the risk weight
on bank exposure to housing loans continued to be kept low and a substantial
segment of home loans falling below Rs. 20 lakhs were kept within
the ambit of the ''priority sector'', which consists of a combination
of sectors like agriculture and small-scale industry to which a specified
minimum percentage of total lending is required to be directed by
the banks (40 per cent for the scheduled commercial banks). This treatment
of housing as a priority sector is partly because the government has
not been able to provide adequate volumes of affordable housing. However,
in the process India may be encouraging a trend that increases the
fragility of the housing finance market and therefore of the financial
and the real economy.
That the RBI fears such a trend emerges from its monetary policy review
for the second quarter of 2010-11, in which it sent out a strong signal
that it wants the commercial banking system to rein in the boom in
housing finance. The RBI’s concern could be traced to the evidence
of a spike in lending for housing. Over the period April 1 to September
25, 2010, for example, housing credit increased by Rs. 16,195 crore
as compared to Rs. 7,891 crore over the corresponding period of the
previous financial year. What is more, during the 5-month April to
August period net credit provided by the housing finance companies
also rose by Rs. 7,519 crore as compared with Rs. 3,581 crore during
six months stretching from April to September 2009. Among the techniques
used by banks to expand this market was, of course, the practice of
offering these loans at lower ''teaser'' interest rates during the
first few years, with the rates being subsequently reset to much higher
levels.
Realising that such practices tend to attract sub-prime borrowers
the RBI opted for four sets of measures. First, it put a ceiling of
80 per cent on the Loan to Value (LTV) ratio, which reduces leverage
by requiring borrowers to commit their own equity to the extent of
at least 20 per cent of the value of the asset at the very beginning.
This reduces the risk burden on the lender. Second, in a reversal
of policies adopted earlier it has decided to raise the average risk
weight associated with larger housing loans. A higher risk weight
requires banks to set aside a larger volume of regulatory capital
for a given loan size. When the risk weight on a particular credit
type is 100 per cent and the capital adequacy requirement is 12 per
cent, capital equivalent to 12 per cent of the loan has to be invested
in specified ''regulatory'' assets. Since regulatory capital is supposed
to be in forms that are safe and relatively liquid, the return on
such assets is lower and reduces average bank revenues. So increasing
risk weights on any kind of lending is expected to discourage that
kind of lending.
Third, the RBI sent out a strong cautionary signal with regard to
the practice of offering teaser rates. In its view: ''This practice
raises concern as some borrowers may find it difficult to service
the loans once the normal interest rate, which is higher than the
rate applicable in the initial years, becomes effective. It has been
observed that many banks at the time of initial loan appraisal do
not take into account the repaying capacity of the borrower at normal
lending rates.'' Finally, having recognised that loans offered with
teaser interest rates have higher risk associated with them, the RBI
decided to increase the provisioning required for these assets categorised
as standard assets from 0.40 per cent to 2 per cent, so as to take
care of that subset of loans that turns non-performing. The message
from the central bank is clear. India may have avoided a crisis of
the sub-prime type, but it remains prone to such crises. Regulation
and control are, therefore, a must.
If Mr. Bhatt is peeved by these measures it could be due to two reasons.
First, he possibly would prefer to lend more to housing when seeking
to meet his priority sector targets, since that would allow meeting
a social responsibility while ensuring a decent return. Second, it
is an area of lending outside the productive sectors that assures
a good return, which he feels that the SBI should exploit. As he put
it: ''Everybody knows, I got a surplus of Rs. 1 lakh crore then. If
I have to park it at the RBI, I get only 3.5 per cent. What I did
was reduce the rate of interest to 8 per cent and removed the cap
on loans, so (borrowers?) could even take Rs 1 crore. What wrong did
we do?'' Perceptions like this amount to saying that the State Bank
of India whch has always been a publicly owned bank and presented
as a trend setter for social banking should be allowed to behave like
any private bank with a thirst for speculative profit. Thankfully,
the RBI does not think so. What is unclear is why Bhatt has decided
to go public on this at this stage in his tenure.