Currently,
banks seem to be the prime targets of the government's reforming zeal.
Having encouraged foreign acquisition, consolidation and universalization
in the banking system, the Finance Ministry's current thrust seems to
be to find a host of new areas of activity for these institutions. According
to unconfirmed reports, the Reserve Bank of India (RBI) has approved a
proposal from the government to amend the Banking Regulation Act to permit
banks to trade in commodities and commodity derivatives. This offer to
banks, of one more new avenue of speculative investment by removal of
a prohibition on commodity trading that has been in existence for long,
merely furthers the fundamental changes that have been under way in India's
banking sector.
These changes impinge upon the nature of the institutions, operations
and instruments that constitute the sector. Institutional changes include:
a rapid increase in the number of new private sector banks; a process
of consolidation of banks that thus far has principally affected the private
banking sector but is now being consciously promoted in the public sector
as well; privatization of equity in public sector banks; mergers of banks
and other financial institutions, particularly development banking institutions;
and the creation of universal banks that are in the nature of financial
supermarkets, offering customers a range of products from across the financial
sector such as debt products, investment opportunities in equity, debt
and commodity markets and insurance products of different kinds.
Implicit in these institutional changes are changes in the operations
of the increasingly ''universalized'' banks. The most crucial change has
been an increasing reluctance of banks to play their traditional role
as agents who carry risks in return for a margin defined broadly by the
spread between deposit and lending rates. Traditionally, banks accepted
small deposits that highly liquid investments protected against capital
and income risk. They in turn made large investments in highly illiquid
assets characterized by a significant degree of capital and income risk.
This made banks crucial intermediaries for facilitating the conversion
of savings into investment.
Given this crucial role of intermediation conventionally reserved for
the banking system, the regulatory framework which had the central bank
at is apex, sought to protect the banking system from possible fragility
and failure. That protective framework across the globe involved regulating
interest rates, providing for deposit insurance and limiting the areas
of activity and the investments undertaken by the banking system. The
understanding was that banks should not divert household savings place
in their care to risky investments promising high returns. In developing
countries, the interventionist framework also had developmental objectives
and involved measures to direct credit to what were ''priority'' sectors
in the government's view.
In recent years, liberalization and ''denationalization'' have changed
all that and forced a change in banking practices in two ways. First,
private players are unsatisfied with returns that are available within
a regulated framework, so that the government and the central bank have
had to dilute or dismantle regulatory measures as is happening in the
case of priority lending as well as restrictions on banking activities
in India. Second, even public sector banks find that as private domestic
and foreign banks, particularly the latter, lure away the most lucrative
banking clients because of the special services and terms they are able
to offer, they have to seek new sources of finance, new activities and
new avenues for investments, so that they can shore up their interest
incomes as well as revenues from various fee-based activities.
In sum, the processes of liberalization noted above fundamentally alter
the terrain of operation of the banks. Their immediate impact is a visible
shift in the focus of bank activities away from facilitating commodity
production and investment to lubricating trade and promoting personal
consumption. Interest rates in these areas are much higher than that which
could be charged to investments in commodity production. According to
a study (Consumer Outlook 2004), conducted by market research firm KSA
Technopak, Indian consumers are increasingly financing purchases of their
dream products with credit that is now on offer, even without collateral.
"Personal credit offtake has increased from about Rs 50,000 crore
in 2000 to Rs 1,60,000 crore in 2003, giving an unprecedented boom to
high-ticket item purchases such as housing and automobiles," the
study reportedly found.
But there are changes also in the areas of operation of the banks, with
banking entities not only creating or linking up with insurance companies,
say, but also entering into other ''sensitive'' markets like the stock
and real estate markets. It should be expected that this growing exposure
to non-collateralized personal debt and entry into sensitive sectors would
increase bank vulnerability to default or failure. The effects on bank
fragility became clear after the stock scam of the late 1990s. The RBI's
Monetary and Credit Policy Statement for the year 2001-2002 had noted
that: ''The recent experience in equity markets, and its aftermath, have
thrown up new challenges for the regulatory system as well as for the
conduct of monetary policy. It has become evident that certain banks in
the cooperative sector did not adhere to their prudential norms nor to
the well-defined regulatory guidelines for asset-liability management
nor even to the requirement of meeting their inter-bank payment obligations.
Even though such behaviour was confined to a few relatively small banks
by national standards, in two or three locations, it caused losses to
some correspondent banks in addition to severe problems for depositors.''
Interestingly, this increase in financial fragility has been accompanied
by the emergence of new instruments in the banking sector. Derivatives
of different kinds are now traded in the Indian financial system, including
crucially, credit derivatives. Most derivatives, financial instruments
whose value is based on or derived from the value of something else, are
linked to interest rates or currencies. Credit derivatives are based on
the value of loans, bonds or other lending instruments.
A working group of the Reserve Bank of India had recommended in 2003 that
scheduled commercial banks may initially be permitted to use credit derivatives
only for managing their credit risks. But banks were not permitted to
take long or short credit derivative positions with a trading intent.
Credit derivatives were seen as helping banks manage the risk arising
from adverse movements in the quality of their loans, advances, and investments
by transferring that risk to a protection seller. Using credit derivatives
banks can: (1) transfer credit risk and, hence, free up capital, which
can be used in other opportunities; (2) diversify credit risk; (3) maintain
client relationships, and (4) construct and manage a credit risk portfolio
as per their risk preference.
Banks in India have quickly responded to this opportunity. For example,
soon after the introduction of interest rate futures in India, Citigroup
concluded three securitization deals worth Rs 570 crore ($126.6 million),
where yields on government securities or the call money rate, were used
as the benchmark for pricing floating rate payments for investors. The
underlying receivables arise from a large number of fixed rate loan contracts
made for financing commercial vehicles and construction equipment. The
risk here is being shared with mutual funds, who are reportedly the major
investors.
Even the conservative State Bank of India (SBI) has taken a plunge into
the credit derivatives market to cope with the risk arising from its growing
loan portfolio. The bank had recorded a growth of almost Rs 36,000 crore
or 25 per cent in its loan portfolio on a year-on-year basis till September
2004, staring from a total loan assets position of Rs 1,35,000 crore in
the corresponding period of the previous year. Of this credit growth recorded
by the bank, more than 40 per cent had been contributed by retail assets.
Credit derivatives offered an opportunity to hedge against the risks being
accumulated in this manner.
It should be clear that credit derivatives are an industry response to
the increasing fragility which comes with the changed nature of banking
practices. Derivatives of this kind permit the socialization of the risks
associated with the liberlaization-induced transformation of banking.
These trends are in keeping with changes in the international banking
industry as well. As The Economist, London, put it: ''The world's leading
banks decided some years ago that lending is a mugs' game. They began
to get rid of their loans, repackaging them and selling them off as securities,
or getting others to re-insure their risk.''
From the point of view of the banks this effort has been extremely fruitful.
Thus, when there was a major melt down in corporate America, as a result
of financial fraud and accounting malpractice, leading to the closure
of giants like Enron and WorldCom, leading banks that had lent large sums
to them appeared unaffected. According to one estimate, loans totalling
$34 billion were wiped out through these bankruptcies. But far less amounts
showed up as losses in the bank's accounts and, in the second quarter
of 2003, Citigroup reported a 12 per cent increase in profits and J.P.
Morgan Chase a 78 per cent increase.
It should be clear that these losses have to show up somewhere in the
accounts of the financial system, but as the Bank of International Settlements
(BIS) argued, it is not easy to trace them. ''The markets lack transparency
about the ultimate distribution of credit risks,'' it declared. One reason
could be that these losses were being borne by insurance companies, which
would be treating them like any other casualty loss so that they are not
identifiable. The BIS sees this conundrum as being the result of the substantial
growth of the practice of credit-risk transfer—the shifting of risk from
banks on to the buyers of securities and loans, and on to the sellers
of credit insurance.
In sum, the traditional image of the great banks with armoured vaults
has little to do with the banks of today. The latter appear to make loans
and then pass them on as quickly as possible, pocketing the margin. That
allows them to take bigger risks in trading securities, derivatives, and
foreign exchange. But these risks do not go away. At the end of 2002,
though non-bank entities accounted for just 10 percent of the syndicated
loan market in the US, they held 22.6 per cent of the bad or doubtful
loans. The same is now happening in India, increasing the fragility of
a host of non-bank financial institutions, such as pension funds, mutual
funds and life-insurance companies. Unfortunately, rather than recognise
this danger, the Finance Ministry is keen on ensuring changes of the kind
described above through a State-directed process of financial engineering.
The full implications of the resulting changes would be revealed only
in the days to come. But the experience elsewhere provides cause for concern.
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