INDIA'S EXPERIMENT WITH A NEW SETTLEMENT SYSTEM

FOR ITS DOMESTIC FOREIGN EXCHANGE MARKET

Siddhartha Roy*
1. Background receiving Indian Rupee. The counter-party
exposure is therefore a major cause of worry
1.1 US Dollar is the major currency in
for participants in this market.
which most of the India's export and import
transactions are invoiced. It is also the 1.3 Increase in the size of the market over
currency in which most of the inward the years has been causing increase of
remittances are received in India. As a result, counter-party exposures of the market
the domestic inter-bank market in foreign participants. Possible consequences of a
currency in India is mostly confined to default by any market participant has also
buying and selling US Dollar against Indian been increasing correspondingly. Moreover,
Rupee. This market is an Over the Counter with the increase in trade volumes,
market (OTC market) which has settlement cost has also been mounting. To
experienced phenomenal growth in the reduce the risk from any possible failed
volume of transactions during the last one settlement, banks started changing their
and a half decade. Increase in the size of the settlements from deal-wise settlements to
market has also brought in significant settlements on net-basis with their counter-
liquidity. This market has also matured and parties (i.e. through bilateral netting). This
it now offers relatively sophisticated resulted in risk reduction to an extent but the
products like Indian Rupee/USD currency remaining risk continued to remain at high
swaps, currency options etc. level. Cost of transactions also remained
high.
1.2 Domestic market in Indian Rupee
closes before the US Dollar market becomes 1.4 In the mid-nineties, Reserve Bank of
active. Settlement in Indian Rupee funds India (RBI) came out with a proposal to
for any Indian Rupee/US Dollar trade effect the settlement on a multilaterally
therefore happens before settlement of USD netted basis. The proposal was discussed,
funds i.e. the settlement is not on Payment debated in various forums and then taken up
versus Payment (PVP) basis. A trader who for implementation. The process went upto
buys US Dollar against Indian Rupee can running dummy files for days to assess the
therefore loose the entire amount if the requirements. Foreign Exchange Dealer's
counter-party fails to pay US Dollar after Association of India (FEDAI), an

*Shri Siddhartha Roy is Senior Vice President, Risk Management,

The Clearing Corporation of India Limited
association of market entities authorised to has remained more or less unchanged so
deal in foreign exchange in India, a Self far was as under:
Regulatory Authority and some major banks
a) Settlement participants are to report
also participated actively in this exercise.
their trades to CCIL through electronic
This form of settlement however could not
mode using RBI's INFINET network,
finally materialise due to certain legal and
b) Matching of reported trades of the
operational impediments.
participants(counter-parties) are to
2. Inter-bank Trade Settlements through happen in the books of CCIL,
CCIL c) CCIL sets limits in terms of net US
2.1. The Clearing Corporation of India Ltd. Dollar sale positions per settlement date
(CCIL) was set up in 2001. It came into for all settlement participants. [For US
existence to take over the responsibility Dollar Buy positions, payment of US
of settlements in the Government Dollar funds to the Settlement
Securities and Forex markets. CCIL Participants happen after CCIL's
started with a settlement system for the receipt of counter-value Indian Rupee
Government Securities market, a and thus, such positions do not pose
guaranteed settlement, where CCIL any Principal Risk],
becomes a central counter-party. It also d) Trades within limits are accepted for
simultaneously started working for guaranteed settlement by CCIL as a
development of a process for settlement Central Counter-party,
of inter-bank trades in Indian e) Forward trades are taken for guaranteed
Rupee/US Dollar. The legal and settlement only after they enter the Spot
operational impediments faced by RBI Window,
earlier were taken care of. The process f) Settlement for each settlement date
obtained necessary regulatory approvals happens on a netted basis through
from RBI and Federal Reserve Bank of CCIL's accounts - Indian Rupee
New York. Federal Reserve Bank of settlements in the books of RBI and US
New York examined the risk processes Dollar settlements in the books of ABN
involved as the Settlement System was AMRO Bank, New York as CCIL's
considered to be a Systemically settlement bank. US Dollars payable to
Important Payment System in the U.S. the settlement participants are to be
due to its inter-bank nature and released only after receipt of counter-
expected large volume. value Indian Rupee funds. For US
Dollar receivables, however, counter-
2.2 The settlement was started in November
value Indian Rupee funds are to be paid
2002. The process formulated which
 to the settlement participants without the Spot Date]. Maximum time allowed
waiting for receipt of the US Dollar for reporting by the settlement
funds, causing Principal Risk to come participants was upto the mid-day of the
into play in such cases. day prior to the settlement date. A day's
g) In case of settlement default in Indian time was initially kept available as a
Rupee, counter-value US Dollar funds buffer for the participants to get used to
are not to be released. Instead, if Indian the process. It was also felt that the
Rupee funds are not received by the next specific inter-action protocol which was
day, US Dollar amounts held back are to developed with the ABN AMRO Bank
be sold to arrange for the required as settlement bank, would need time to
Indian Rupee amount. On the other mature. The developed process was to
hand, in case of a settlement default in be efficient with abilities on the part of
US Dollar, a principal risk for the CCIL to monitor the movement of each
respective amount is to arise. A transaction through the account so that
provision to claw back funds from the operational slippages did not cause any
defaulting participant's principal payment failure. It was also required to
Indian Rupee account with RBI also be ensured that ABN AMRO Bank's
exists. In case the Indian Rupee funds Mumbai branch which participates in
recovered is inadequate and the margin domestic inter-bank forex market in
of the concerned member is also not India did not have access to the
adequate to take care of the likely loss, a settlement positions of other market
provision exists for allocation of participants. The settlement system
residual loss through a clearly designed worked efficiently from the very
and pre-notified loss allocation beginning and the market participants
mechanism. reposed their confidence in the newly
h) Loss allocation mechanism contains a developed settlement system by shifting
provision for distribution of losses most of their trades to the system for
arising out of any settlement default to settlement. RBI, as a regulator, was
the bilateral counter-parties, pro-rata, closely monitoring the development.
based on their exposures on the They also played the role of a catalyst by
defaulting counter-party. arranging an independent vetting of the
processes in 2003 by an expert from the
2.3 Settlement of Indian Rupee/USD trade European Central Bank, which gave the
started initially with only spot and comfort to the settlement participants
forward trades. [In the Indian about the robustness of the settlement
Rupee/US Dollar market, two working and risk management processes.
days from the trade date is considered as
2.4 Settlement of TOM and CASH trades significant reduction in settlement
i.e. trades with settlement on the next risk. While this has happened in a
working day and on the same working very big way as will be seen from the
day respectively, started in February later paragraphs, some not too
2004. It required significant obvious benefits have also been
restructuring of the processes and of the realized.
risk management system. As CASH
3.2 Increase in Operational
trades were allowed to be reported and
Efficiency:
matched in the CCIL system upto 12.30
P. M. of the day of settlement and the 3.2.1 Inter-bank settlements require huge
settlement participants were required to settlement related activities: matching
settle the trades which were not taken up of counter-party confirmations,
for guaranteed settlement by CCIL effecting payments through the
through direct settlement (and India's nostro accounts, tracking payments
RTGS system was not in operation at and receipts, reconciliation of nostro
that time), maintaining time discipline accounts, effecting back-valuation or
regarding processing at CCIL was payment of interest for delayed
critical for the success of the system. payments, ensuring collection of
On the part of settlement participants interest for delayed receipts etc..
also, this demanded a much more Settlement through CCIL results in
efficient response. It was a big contraction of all these activities into
challenge, but the Indian Financial effecting a single payment in either of
System took it almost effortlessly. the currencies (Indian Rupee or US
Dollar) and tracking a single payment
2.5 Taking in TOM & CASH trades for
and a single receipt per day. Since July
settlement made it possible for the
'04, CCIL has even started sending
market participants to route all their
trades in the Indian Rupee/USD market payment instructions on behalf of the
for settlement through the system. settlement participants against
They availed of this opportunity and the mandates received from them. Cost
trade volumes for settlement started savings in the form of reduction in
moving up steadily. back office activities has therefore
been substantial.
3. Benefits to the Settlement
Participants 3.2.2 Payment or receipt of interest on
delayed settlements had always been a
3.1 Expected benefits to the Settlement contentious issue between the
Participants were to be in the form of c o u n t e r - p a r t i e s a n d re q u i re d
 considerable cost and effort on the the margins collected for the principal
part of both the involved entities to risk element (varying from 3% for
resolve. In the past, these disputes or highly rated entities to 8.5% for the
cases of delays used to finally reach lowest rated entities allowed into the
FEDAI and used to take significant system). Moreover, the ability created
portion of their time and attention as to claw back the counter-value Indian
well. Since settlement of trades Rupee funds from the principal
started through the settlement system account of any defaulting entity with
of CCIL, cases of such claims have RBI has further reinforced the system.
come down to negligible number
3.3.2 Furthermore, from the 3 days in the
evidencing the extent of cost savings
Spot Window (CASH, TOM & SPOT),
and efficiency achieved by the
principal risk is kept confined to only
financial market as a whole.
the CASH date by ensuring that in
3.2.3 Standardization of the processes in case of a default, no payout happens
regard to deal reporting, getting on the subsequent days to the account
information about the status of the of any defaulting entity without
deals etc. has also provided receipt of the counter-value funds.
opportunities for creation of a cost Market risk in the system is taken care
effective on-line system for tracking of of by adding a market risk factor, for
positions based on exception events. collection of margin, in respect of
This offers significant opportunities each settlement date. Thus market
for reduction of operational risk. risk cover is also available for almost
all positions of the participants for all
3.3 Risk Reduction
settlement dates.
3.3.1 On the risk management front, the
3.3.3 The impact of risk reduction achieved
benefits as expected have been
for the settlement participants
e n o rm o u s . Multilateral net
through this process can be gauged
settlement with closely controlled
from the under-noted facts :
processes has virtually eliminated all
principal risk except for the net US i) principal risk for TOM & SPOT dates
Dollar sale position of the are fully eliminated,
participants. This element of risk has
ii) principal risk for CASH date is
also been kept restricted to acceptable
reduced by 85% to 95%, &
amounts in respect of all participating
entities by setting Exposure Limits iii) market risk for almost all positions
and is also additionally covered by are covered fully.
3.3.4 The process, apart from causing huge Buy. The counter-party wise net
reduction of risk to the individual bilateral exposures, irrespective of
settlement participant has also caused whether those were USD Buy
huge reduction of total risk to the positions or USD Sale positions, were
system as a whole. An analysis of data therefore summed up for each
for a one year period between Jan '05 settlement date to arrive at the total
to Dec'05 was undertaken to assess bilateral exposures of the settlement
this impact [Results appended in participants for such settlement date.
Table I]. Two dates per month, one at These values are as per the column (c)
the middle of the month (i.e. 15th of of the Table I.
each month or if it was a holiday, the
3.3.6 For the same settlement dates, total
immediately preceding settlement
e x p o s u re s o f t h e s e t t l e m e n t
date) and another on the last working
participants for settlement through
day of the month (i.e. the day when
CCIL were arrived at by taking the
transactions are highest and hence the
sum of net USD payable amounts for
risk to the system is also at the highest)
the respective settlement dates. These
were considered for this analysis.
values are as per column (e) of Table I.
3.3.5 All trades settling on such settlement
3.3.7 The data clearly reveals that the total
dates were taken into account.
counter-party exposures of all
Bilateral exposures of each of the
settlement participants (i.e. by the
counter-parties were arrived at for
entire system) on account of the
each such settlement date. In absence
settlement risk for these settlement
of a settlement system like the system
dates came down by about 93% on an
run by CCIL, the maximum possible
average (minimum 83.26% to
reduction in counter-party exposures
maximum 96.13%) [column (f) of
could have been to reach such level of
Table I]. Given that the cash margin
bilateral exposures. Moreover, for a
cover available for such positions were
bank, even US Dollar sale position
approximately at around 4% on an
creates exposure as it is not possible
average (margin collected towards
for it to ensure receipt of counter-
Principal Risk is between 3% to 8.5%),
value Indian Rupee funds before
even at a conservative level, the
release of USD payments. Thus, at
residual risk to the system which
bilateral level, both USD sale and
remained uncovered can be taken on
USD buy positions create exposures -
an average at around 5% of the total of
Indian Rupee exposure in case of USD
net bilateral positions.
Sale and USD exposure in case of USD
3.3.8 The risk reduction of about 95% of participants to come down to an
the net bilateral positions as stated average of 72 per day [Column (h) of
above is only if we consider the Table I]. The enormous cost
exposures taken for the settlement re d u c t i o n a n d re d u c t i o n i n
date. In reality, at any point of time, operational risk due to the reduced
the settlement participants take number of settlement is thus evident.
settlement exposures on the counter- It also made the system robust and
parties for 3 settlement dates at a time. significantly more reliable.
If the same is considered and we take it
3.3.10 Incidentally, CCIL has also provided
that the relative positions of the days
members with a Forex Trading System,
other than the day of settlement is at
FX-Clear, which allows straight
significantly lower levels, the risk
through processing of the trades done
reduction can go up to about 96 to
by the members in its Settlement
97% e.g. if a position for the day of
System. No separate deal reporting by
settlement is USD 100 million of
the members is required if they opt for
which USD 5 million (i.e. 5%)
this STP. Members using FX-Clear can
remains as residual risk and if the
derive significant additional benefits
aggregate positions of two other days
by way of cost savings from the deal
in the Spot Window is even at as low as
reporting process. This also ensures
USD 50 million, the total risk
prompt processing of the trades by
reduction is at 96.66% (at USD 145
CCIL in its settlement system leading
million as against the total position of
to early acceptance of such trades for
USD 150 million).
settlement. The exposure of the
3.3.9 Reduction in the number of members on the counter-parties for
settlement related transactions were the period upto CCIL's acceptance of
also analysed. At bilateral net level, the trades can thus come down
the total number of payment significantly through the use of FX-
transactions by the settlement Clear.
participants per settlement date could
3.4 Integration of Relatively Weaker
have reached to as high as 2386
Entities into the System
(minimum 1058) [Column (g) of
Table I]. As against such huge number 3.4.1 Another important benefit of this
of transactions, the settlement settlement system which is often
through CCIL's settlement system overlooked is the ability of this system
caused the number of payment to integrate the relatively weaker
transactions for the settlement entities into the system and cause
 significant reduction in market their dealing. Other users of the
exposures on them. An analysis on financial system can also have access
this aspect was also undertaken for the to higher number of entities.
same period (Jan '05 to Dec '05). The Moreover, smaller entities are
results have been appended in Table II. generally considered to be more
It reveals clearly that, on an average, efficient users of funds and these
the settlement system is able to reduce entities are usually considered as
the risk of the entire system to these Weaker Entities in the market because
entities by about 89% (minimum- of their lower capital and reach. The
63% and maximum- 95%) of the level empowerment of the smaller entities
that could be achieved through to deal with all in the market on near
bilaterally netted settlements. This normal terms through this settlement
estimation again is by taking only the system as against with a few at very
exposures of a single settlement date. adverse terms should therefore allow
If we consider all three settlement the economy to reap significant
dates within the spot window, as benefits.
mentioned in para 8 above and the
4. New possibilities for Counter-
trade volumes at the levels described
party Exposure Management
therein (i.e. aggregate position for the
other two days in the spot window is at 4.1 Another important dimension of
50% of the position on the day of settlement through CCIL's settlement
settlement), the risk reduction would processes is that the exposure of any
be substantially higher at about individual settlement participant on a
92.50%. Moreover, availability of counter-party in the Spot Window can
margin for Principal Risk at 5% to not exceed the Exposure Limit set by
8.5% of the exposure limits for those CCIL for such counter-party for a
entities cause the level of risk to settlement date. Hence, if CCIL sets
reduce further by such amount. an Exposure Limit of USD 10 million
for a settlement participant, say Bank
3.4.2 It is thus evident that the settlement
A for a settlement date, the maximum
system integrates weaker entities into
net USD sale of the settlement
the system and is able to take care of
participant can not exceed USD 10
the risk substantially. The benefits
million for any settlement date.
from such integration of weaker
Moreover, if CCIL has 5% margin
entities into the system can and does
from this participant in respect of
accrue to all concerned. Market
credit risk (credit risk factor), from the
participants have more choices for
 Principal Risk perspective, maximum in the Spot Window without allowing
impact of a default by the participant any principal exposure to be created].
could only be USD 9.5 million and Thus, if there are 3 other settlement
this is for all the trades in the spot participants, Banks B, C & D dealing
window [as explained earlier, CCIL with Bank A having the under-noted
default handling process handles transactions :
exposures for the remaining two days

Settlement Date: CASH date

(Amount in USD million)
Trade
Trades of Bank A Trades of Bank B Trades of Bank C Trades of Bank D
particulars
USD USD USD USD
USD Buy USD Buy USD Buy USD Buy
Sale Sale Sale Sale
1. Trade 1 15 15
2. Trade 2 5 5
3. Trade 3 30 30
Net Positions 10 30 15 5

Settlement Date: TOM date

(Amount in USD million)

Trade
Trades of Bank A Trades of Bank B Trades of Bank C Trades of Bank D
particulars

USD USD USD USD

USD Buy USD Buy USD Buy USD Buy
Sale Sale Sale Sale

1. Trade 4 15 15

2. Trade 5 15 15

3. Trade 6 40 40

Net Positions 10 40 15 15

Settlement Date: SPOT date

(Amount in USD million)

Trade
Trades of Bank A Trades of Bank B Trades of Bank C Trades of Bank D
particulars

USD USD USD USD

USD Buy USD Buy USD Buy USD Buy
Sale Sale Sale Sale

1. Trade 7 35 35

2. Trade 8 15 15

3. Trade 9 60 60

Net Positions 10 60 35 15
All trades of Bank A will pass exposure check counter-party to take care of the
as the net positions of Bank A for all incidental market risk from non-
settlement dates are within USD 10 million. settlement.
If there is a default by Bank A, Bank B can
4.3 This possibility can be explored to
only suffer a loss upto USD 10 million
increase liquidity in the market
(actually USD 9.5 million because of the
significantly and this would also save
existence of the margin) irrespective of its
considerable efforts for the settlement
having bought USD 130 million from Bank
participants in respect of their
A for all the Settlement dates in the Spot
monitoring of the residual counter-
Window. Banks C & D being USD sellers will
party exposures.
have no exposure on Bank A due to
settlement through CCIL. 5. Comparison with CLS Model:

4.2 Thus, if Exposure Limits of all 5.1. It is evident from above that the above-
settlement participants for CCIL mentioned settlement system created
settlement is known, any participant for inter-bank Indian Rupee/US
who is comfortable with a bilateral Dollar trades has evolved as a very
exposure of upto these amounts on the efficient model for risk and cost
other participants need not set any reduction. It is a model which has
limit for trading with such participants attempted to look at mitigation of
for “CCIL Settlement” without anyway 'Herstat Risk' in a very different way
increasing the risk taken by them. This f ro m t h e m o d e a d o p t e d f o r
will however require a discipline of : Continuous Linked Settlement. The
model is simple, easy to implement and
i) clear understanding as to no obligation
extremely efficient. It brings in almost
for settlement of trades outside CCIL
all market participants into the system
Settlement System, even if such trades
irrespective of their credit standings
are not accepted for guaranteed
while simultaneously reducing the
settlement by CCIL, and
systemic risk substantially. It also
ii) immediate reporting of trades so that brings in transparency. A comparison
any non-acceptance of such trade by with the CLS model will perhaps bring
CCIL for guaranteed settlement is out the strength and weakness of the
known well in time for the other system more clearly :-
6. Future Development Potential Trades in Indian Rupee/US Dollar and
settlement of Indian Rupee/ US Dollar
6.1 Settlement System for INR/US Dollar
Currency Swaps, markets where inter-bank
trade settlement system created in India is
exposures are huge and very complicated to
ensuring highly efficient and cost efficient
handle. Settlement of cross currency trades
settlement. The robust system can now also
through CLS Bank has also been started in
be used by India for vertical integration i.e.
India through CCIL using the services of
to allow guaranteed settlement of Forward
ABN AMRO Bank as a CLS Settlement
Member. It is now possible to integrate the 7. Conclusion
above-mentioned Indian Rupee/US Dollar
7.1 If we consider the benefits that have
trade settlement with the CLS settlement
accrued to the Indian Financial System due
leading to creation of a model which many
to the introduction of the inter-bank foreign
countries whose currencies are not
exchange settlement system created at CCIL
international currencies in real sense, may
and the potential of the settlement structure
find extremely advantageous. This may
to play a major role in supporting
perhaps allow them to have the risk from
settlements of trades in the foreign exchange
Inter-bank domestic foreign exchange
forwards and derivatives market with the
markets to be controlled efficiently and
possibilities for efficient risk management,
effectively and simultaneously allow the
there is no doubt that the development can
cross currency trades of domestic banks to be
be considered as one of the most critical
settled through CLS bank.
financial innovation of our time.
 Table I : Gross Exposure of all settlement participants on account of INR/USD trades settled through CCIL Period : Jan'05 to Dec'05

Net Principal Risk No of Payments for

Total Value of Sum of Bilateral CCIL Exposure Netted Exposure No of Payments Reduction in
Settlement Position reduction due to Bilateral settlements
trades for all Exposures of all limits for all when Settled for settlement no of
Dates for all settlement through on netted basis
members members members through CCIL through CCIL Transactions
members CCIL (in both currencies)

Annexure 1
(a) (b) (c) (d) (e) (f) = (c)-(e)/(c) (g) (h) (i)= (g)-h)/(g)
14-Jan-05 6,316 0 3,473 2,295 287 91.74% 1320 71 94.62%
31-Jan-05 32,771 0 10,067 2,318 827 91.79% 2338 72 96.92%
15-Feb-05 9,375 0 5,302 2,340 664 87.48% 1484 72 95.15%
28-Feb-05 31,842 0 10,557 2,370 630 94.03% 2278 72 96.84%
15-Mar-05 6,104 0 3,258 2,427 359 88.98% 1248 71 94.31%
31-Mar-05 49,853 0 12,944 2,524 770 94.05% 2366 72 96.96%
15-Apr-05 5,679 0 3,363 2,554 563 83.26% 1180 72 93.90%
29-Apr-05 34,143 0 11,307 2,596 805 92.88% 2180 72 96.70%
13-May-05 8,555 0 5,066 2,595 394 92.22% 1398 71 94.92%
31-May-05 42,390 0 12,069 2,596 713 94.09% 2386 72 96.98%
15-Jun-05 6,234 0 3,580 2,588 250 93.02% 1336 70 94.76%
29-Jun-05 40,004 0 11,170 2,596 570 94.90% 2320 72 96.90%
15-Jul-05 5,702 0 3,203 2,589 406 87.32% 1058 70 93.38%
29-Jul-05 30,861 0 9,572 2,591 773 91.92% 1986 71 96.42%
12-Aug-05 6,281 0 4,049 2,596 296 92.69% 1130 71 93.72%
31-Aug-05 46,817 0 12,498 2,607 483 96.14% 2380 73 96.93%
15-Sep-05 5,512 0 3,358 2,601 377 88.77% 1244 73 94.13%
29-Sep-05 40,403 0 11,743 2,606 621 94.71% 2370 73 96.92%
14-Oct-05 9,888 0 4,903 2,635 529 89.21% 1388 68 95.10%
31-Oct-05 43,229 0 13,593 2,653 668 95.09% 2264 72 96.82%
14-Nov-05 12,598 0 5,695 2,661 530 90.69% 1704 73 95.72%
30-Nov-05 45,082 0 12,580 2,660 664 94.72% 2334 72 96.92%
15-Dec-05 7,947 0 4,405 2,657 400 90.92% 1384 71 94.87%
30-Dec-05 47,790 0 13,519 2,714 847 93.73% 2410 73 96.97%
Average 23,974 0 7,970 2,557 559 92.99% 1,812 72 96.05%
 Table II : Gross Exposure of all settlement participants on weak entities (i.e. members graded C+ or below) on account of
INR/USD trades settled through CCIL Period : Jan'05 to Dec' 05

Bilateral Exposure of CCIL Exposure Netted Exposure Principal Risk reduction No. of members having
Total USD Total USD Total Value Net
Settlement Dates other participants on Limit for these when Settled due to settlement Bilateral Exposures on
Buys Sales of trades Position *
these entities entities through CCIL through CCIL the weak entities.

(a) (b) (c) (d) (e) (f) (g) (h) (i) = (f)-(h)/(f) (j)
14-Jan-05 36 38 74 (2) 62 102 13 79.03% 38
31-Jan-05 320 330 650 (10) 342 102 25 92.69% 56
15-Feb-05 52 64 116 (12) 95 102 20 78.95% 37
28-Feb-05 269 275 544 (6) 313 102 32 89.78% 57
15-Mar-05 53 61 114 (8) 86 98 20 76.74% 37
31-Mar-05 349 383 732 (34) 391 102 49 87.47% 56
15-Apr-05 34 48 82 (14) 72 102 27 62.50% 33
29-Apr-05 214 229 443 (15) 279 102 37 86.74% 55
13-May-05 58 64 122 (6) 88 102 12 86.36% 34
31-May-05 273 316 589 (43) 330 102 46 86.06% 56
15-Jun-05 60 50 110 10 90 94 6 93.33% 38
29-Jun-05 290 304 594 (14) 357 102 25 93.00% 59
15-Jul-05 39 35 74 4 64 95 10 84.38% 32
29-Jul-05 196 213 409 (17) 245 98 33 86.53% 53
12-Aug-05 68 66 134 2 104 98 10 90.38% 38
31-Aug-05 345 367 712 (22) 409 103 34 91.69% 59
15-Sep-05 38 41 79 (3) 65 98 10 84.62% 35
29-Sep-05 369 402 771 (33) 393 103 42 89.31% 61
14-Oct-05 50 51 101 (1) 74 79 7 90.54% 33
31-Oct-05 237 287 524 (50) 300 95 51 83.00% 55
14-Nov-05 104 121 225 (17) 137 95 20 85.40% 44
30-Nov-05 609 702 1,311 (93) 667 95 68 89.81% 55
15-Dec-05 72 67 139 5 82 92 4 95.12% 37
30-Dec-05 366 385 751 (19) 445 95 34 92.36% 61
Average 188 204 392 (17) 229 98 26 88.65% 47
* Figures in Parenthesis indicate USD Sale Position.

Annexure 2