Banking Licensing in India - Past and Future: Sian Esearch Onsortium

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Asian Journal

of Research in
Asian Research Consortium Banking
and
Asian Journal of Research in Banking and Finance
Vol. 4, No. 10, October 2014, pp. 270-283. Finance
ISSN 2249-7323 www.aijsh.org

Banking Licensing in India – Past and Future

Dr. Chitta Shyamsunder*; Mr. Anant Wakade**

*Associate Professor,
Balaji Institute of Telecom & Management,
Pune, India.
**Assistant Professor,
Balaji Institute of Telecom & Management,
Pune, India. (DOI NUMBER-10.5958/2249-7323.2014.01426.6)

Abstract
As the reach of banking is an issue in India, from financial inclusion perspective, considering
access to bank credit and services through expansion of banks in unbanked and under-banked
regions is of utmost importance. The specific risks on account of the business model may have to
be addressed by calibrating the prudential regulations together with developing the resolution
regime and process reorientation for shortening the time period for settlement of deposit insurance
claim. In the deregulated interest rate regime, the small banks will have freedom to decide their
lending rates based on the cost of funds. Similarly, the improvement in communication facilities
would enable them to reap the efficiency gains driven by technology similar to the medium and
large banks. The approval of licences for IDFC Ltd and Bandhan Financial Services marks the start
of a cautious experiment for a sector dominated by lethargic state lenders, many of which are
reluctant to expand into rural areas or towns where banking penetration is low.

Keywords: Financial Inclusion, Bank Credit, Banking Licensing, Banking Penetration, Bandhan,
IDFC.
________________________________________________________________________________

1. Introduction
The financial sector, with banking sector at its core, owes its existence to the real sector and assists
its progress. However, the recent global financial crisis has demonstrated that the financial sector
had expanded out of alignment with the real sector which led to the precipitation of the crisis. With
the lessons learnt from the crisis, many countries have been reviewing their banking structures post
crisis.

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The existing banking structure in India, evolved over several decades, is elaborate and has helped to
serve the credit and banking services needs of the economy with multiple layers catering the
specific and varied requirements of different customers and borrowers. Hence, we can say that
Indian banks have played a major role in the mobilisation of savings and promotion of economic
development.

It is important to review the banking structure in the Indian context also with a view to enabling the
banking sector to cater to the needs of a growing and globalizing economy as well as furthering
financial inclusion. While this is the primary motivation of this exercise as Indian banks came out
relatively unscathed from the crisis, it is equally important to factor in the lessons learnt from the
crisis, particularly on structural issues.

Since the Indian economy is dynamic, the banking system needs to be flexible and competitive. The
balancing act of flexibility with effective oversight is an unexceptionable principle to take potential
steps and requisite changes. Competition is increasingly influencing the future landscape of the
financial sector, and it can be effective in producing desired outcomes if accompanied by a level
playing field for all participants.

Though the broad functions and objectives of the banking structure are similar across countries
globally, we can observe different models in terms of banking structures, ownership patterns, and
size of the banks. Different studies show that small, regional and local banks perform differently
from large banks, with greater access to local information, greater commitment to local prosperity,
differences in costs and risk management, and competition policy, which explains the specific
influence of these banks on local economic development. Local banks could improve financing
opportunities to small and medium size enterprises and encourage entrepreneurship in developing
countries, where economic development is hampered by insufficient and inadequate access to
financial services in rural areas. A country’s banking system should be dynamic and competitive
depending upon the structure and needs of an economy.

In India the financial system is dominated by banking model, which has changed significantly over
the past years. Various policy initiatives and reform measures have improved the resilience of the
Indian banking system, which has enabled it to withstand adverse economic and financial
conditions from time to time. But, the present structure may need to be reoriented to increase the
capacity to serve the economy better on the growth perspective.

Since independence, the Indian banking sector has come a long way with the nationalisation of 14
major banks in 1969 and 6 banks in 1980, with substantial increase in banking business, captured
by the ratio of banking business (credit plus deposits) to GDP. The reach of banking has widened
significantly to include relatively under-banked regions, particularly in rural areas. Commercial
bank credit as per cent of GDP picked up steadily from 5.8 per cent in 1951 to 56.5 per cent by
2012. The population per bank branch came down from 64,000 in 1969 to 12,300 in 2012
(RBI, 2013).

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Vol. 4, No.10, pp. 270-283.

Chart – 1: Banking Business/GDP Ratio

The structural breaks were estimated using the Bai-Perron Test

Source: Handbook of Statistics on Indian Economy.

The fostering of different types of institutions catering to the divergent banking needs of various
sectors of the economy is the key distinctive feature of Indian banking sector, with credit
cooperatives catering to the credit, processing and marketing needs of small and marginal farmers
organised on cooperative lines. They also expanded in urban and semi-urban areas in the form of
urban cooperative banks, thereby meeting the banking and credit requirements of people with
smaller means. Regional Rural Banks were created with the positive features of credit cooperatives
and commercial banks to specifically address credit needs of specific backward sections in rural
areas. Establishment of Local Area Banks on a smaller scale was an experiment to bridge the gap in
credit availability and strengthen the institutional credit framework in the rural and semi-urban
areas.

In spite of these developments, Indian banking sector is yet to meet the desired banking penetration
and inclusion as witnessed in most advanced and some of the emerging economies. As per the data
given in Basic Statistical Returns, it is estimated that rural India had only 7 branches per 1,00,000
adults in 2011 in contrast to most of the developed and even BRICS economies having over 40
branches. North-eastern, eastern and central regions are more excluded in terms of banking
penetration regionally.

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2. Access to Banking
According to RBI data, India has 27 state-run banks and 22 private sector banks, but its ratio of
branches to adults is only about one-fourth of Brazil's, leaving about half of households in India’s
population outside the banking system.

With the Indian economy focusing on increasing the manufacturing and infrastructure sectors, the
credit requirement is higher and more resources will be needed for supporting the growth process.
To achieve an annual economic growth of 8 per cent envisaged by the 12th Five Year Plan, banking
business needs to expand significantly to an estimated Rs. 288 trillion by 2020 from about Rs. 115
trillion in 2012.

Chart – 2: Projection of Banking Business

Note: GDP is projected assuming the rate of growth of 8 per cent per annum till 2020. The ratio of banking business to GDP
is worked out assuming that the trend witnessed in the latest break period of 1999-2012 would continue during the projected
period.

As on March 31, 2013, there were 64 RRBs (consolidated from 196 RRBs originally set up), 1,606
urban co-operative banks (UCBs), 31 State co-operative banks (StCBs), 371 district central co-
operative banks (DCCBs), 20 State Cooperative Agriculture and Rural Development Banks
(SCARDBs) and 697 Primary Cooperative Agriculture and Rural Development Banks
(PCARDBs), which indicates that small local banks with geographical limitations play an important
role in the supply of credit to small enterprises and agriculture.

In spite of significant progress, a deeper analysis is required into the inadequate coverage of the
banking and financial sectors. With 157 [26 Public Sector Banks, 7 New Private Sector Banks, 13
Old Private Sector Banks, 43 Foreign Banks, 4 Local Area Banks (LABs), 64 RRBs] domestic
banks operating in the country, only 40 per cent of the adults have formal bank accounts. Therefore,

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Vol. 4, No.10, pp. 270-283.

innovative approaches (including channels, products, interface, etc.) are required to provide formal
banking access to low income households and the unbanked sectors of the society.

Appendix – 1: Existing Banking Structure in India*

As the reach of banking is an issue in India, from financial inclusion perspective, considering
access to bank credit and services through expansion of banks in unbanked and under-banked
regions is of utmost importance. The specific risks on account of the business model may have to
be addressed by calibrating the prudential regulations together with developing the resolution
regime and process reorientation for shortening the time period for settlement of deposit insurance
claim. In the deregulated interest rate regime, the small banks will have freedom to decide their
lending rates based on the cost of funds. Similarly, the improvement in communication facilities

274
Shyamsunder & Wakade (2014). Asian Journal of Research in Banking and Finance,
Vol. 4, No.10, pp. 270-283.

would enable them to reap the efficiency gains driven by technology similar to the medium and
large banks.

3. Competition and Licensing of Banks in India


Section 22 of the Banking Regulation Act, 1949 provides that a company intending to carry on
banking business must obtain a license from RBI except such of the banks (public sector banks and
RRBs), which are established under specific enactments. Every bank in India, i.e., domestic and
foreign, apart from banking business, can carry out all the activities permitted under Section 6 of
the Banking Regulation Act. The RBI issues licence only after ‘tests of entry’ are fulfilled. One of
the major objectives of reforms was to bring in greater efficiency by permitting entry of private
sector banks, liberalised policy on entry of new foreign banks and increased operational flexibility
to banks.

4. Licensing Policy for Domestic Private Sector Banks


Following the recommendations of Narasimham Committee I in 1991, guidelines on new banks
were released in 1993 with a minimum capital requirement of Rs.100 crore for the new banks.
Under these guidelines, 10 new private sector banks were licensed. After the recommendations of
the Second Report of the Narasimham Committee on Banking Sector Reforms, a new set of
guidelines were issued in 2001 with capital requirement of banks at Rs.300 crore. Under the 2001
guidelines, 2 new private sector banks were licensed. Further, in February 2013, fresh guidelines
for licensing of new banks were issued. The guidelines permit business/industrial houses to
promote banks, conversion of NBFCs into banks and setting up of new banks in the private sector
by entities in the public sector, through a Non-Operative Financial Holding Company (NOHFC)
structure. The minimum capital requirement for setting up a bank is Rs.500 crore. With regard to
branch licensing policy, general permission has been granted to the domestic scheduled commercial
banks for opening branches in Tier 2 to Tier 6 centres without RBI’s prior approval subject to
reporting. Further banks have to open at least 25 per cent of the total number of branches opened
during a year in unbanked rural (Tier 5 and Tier 6) centres. At present, foreign banks operate in
India as branches of the parent banks. Currently, permission for opening of branches by foreign
banks in India is guided by India’s commitment to WTO to allow12 new branches in a year.

5. Ownership of Indian Banks - Issues


During independence, banks were owned by the private sector and as such there was large
concentration of resources in the hands of a few business families. The objectives of social control
was introduced to achieve a wider spread of bank credit, prevent its misuse, direct a larger volume
of credit flow to priority sectors and to make it an effective instrument of economic development.
Following this, nationalisation of banks was resorted to in 1969 (14 banks) and subsequently in
1980 (6 banks).

Reflecting large-scale expansion of branch network by the PSBs over the years, population per
branch fell significantly from 1,36,000 in 1951 to 12,500 in 2012, indicating a big leap towards
inclusive banking.

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However, there is a debate about the private sector banks being more profitable and efficient than
the public sector banks, which makes it essential to look at the comparative performance of the
PSBs and the private sector banks.

6. Comparative Analysis: Public Vs. Private Banks


Given the fact that PSBs have more number of branches and more number of employees than the
private sector peers, profit per-branch and profit per-employee are invariably lower for PSBs.
Hence, a better way to gauge the performance of PSBs is to examine their share in total assets and
profits of all scheduled commercial banks (SCBs) since the on-set of banking sector reforms.

The share of PSBs in total assets of all scheduled commercial banks (SCBs) fell from over 85 per
cent in 1995-96 to about 73 per cent in 2011-12. However, the share of PSBs in the overall profits
of the banking sector rose from over a negative profit of 39 per cent to about 61 per cent during the
same period. The two main indicators of profitability, viz., return on assets (RoA) and return on
equity (RoE), indicates that the private sector banks showed relatively better performance as
compared with the public sector banks, which is reflected in higher RoA of private sector banks for
almost all the years during 2000-2012. In addition, RoE of private sector banks shows an increasing
trend from 2007 onwards, as compared with that of public sector banks, which were stable during
the same period. RoA of PSBs was placed at 0.9 per cent in 2011-12, against 1.5 per cent for the
private sector banks. The corresponding figures for RoE were 15.3 and 15.2 per cent respectively.
The Net Interest Margin (NIM) of public sector banks was higher than private sector banks before
2008, but it showed a reversal trend thereafter, which implies an increased profitability of private
sector banks.

The Report on Currency and Finance (RCF) 2006-08 made an assessment of efficiency and
productivity of banking sector in India using different dimensions, in terms of ownership (public
vs. private). The efficiency and productivity of the banking system was measured in terms of
certain parameters, which included ratio of operating cost to total assets, cost to income ratio,
labour cost per unit of earning assets, non-labour cost per unit of earning assets, Net Interest
Margin (NIM) to total assets ratio, business per employee and business per branch. The report
suggested that PSBs posted divergent performance standards when measured by different
yardsticks, and the performance of the PSBs was better than that of the other two bank groups
(private sector banks and foreign banks) in terms of measures such as operating cost to total assets
and non-labour cost per unit of earning assets, but it was poorest when measured in terms of
business per employee and business per branch. On the other hand, performance of the PSBs was
placed between that of the other two groups in terms of labour cost per unit of earning assets, cost
to income ratio and net interest margin to total assets ratio.

With a huge size and variety of PSBs, it is possible to find banks that could equal the good private
sector banks as well as the not so good ones. In addition, PSBs had to reckon with many of the non-
performing assets that they have been saddled with. Recent trends in NPAs clearly indicate that the
stress on asset quality in the PSBs is significantly higher than that in the private sector and foreign
banks. This is due to the larger presence of PSBs in infrastructure and other big projects which have
suffered due to delays in various clearances, and some PSBs operating in relatively backward areas

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with limited discretion to pull out from such areas and also due to credit appraisal and risk
management issues.

Over the years, the performance of public sector banks has converged with that of new private
sector and foreign banks and more importantly, in contrast to popular perception, there is also no
significant relationship between ownership and efficiency, and the most efficient banks straddle all
three segments, i.e., public sector banks, private sector banks and foreign banks (Subbarao, 2011b).

Many studies in the Indian context have not found any significant difference between the
performance indicators of Public Sector Banks (PSBs) vis-à-vis private sector banks in the post-
reform period. This shows that public sector banks are competing relatively effectively with private
sector and foreign banks with operational flexibility. The ‘market discipline’ imposed by the listing
of public sector banks may be one of the reasons for this improved performance. Public sector bank
managements are now more tuned to the market consequences of their activities. Another factor is
that PSBs enjoy a huge first mover advantage in terms of scale of operations over private sector
banks and hence these advantages offset any inefficiency that could be ascribed to the Government
ownership.

7. Need for New Bank Licenses: Financial Inclusion


The prime motive of reopening the window for licenses by the RBI was to achieve “financial
inclusion” and the targets come from three broad policy stances:

 Coverage—monitored by number of no-frills accounts and other such products

 Outreach—branches in different categories of habitation, and

 Deployment—priority sector, agriculture and weaker sections

The need for the inclusion focus comes from the fact that India has the world’s largest unbanked
population and only 1 in 2 Indians have a savings account and 1 in 7 Indians have access to bank
credit. CRISIL’s financial inclusion index called “Inclusix” (which measures financial inclusion on
three parameters: branch penetration, deposit penetration and credit penetration) recorded an all
India score of 42.8 on a scale of 100 (2012) which, although reflecting a healthy upward trend,
points towards an under penetration of formal banking, and there were wide disparities in access to
financial services as well. While India’s six largest cities were found to have 10% of all bank
branches, the bottom 50 districts merely have 2%, which is confirmed by an IMF study from 2011,
and that India is way short of its next door neighbors in this regard.

8. RBI Decides to Grant “In-Principle” approval for Banking Licences


On April 2, 2014 the Reserve Bank of India (RBI) has decided to grant “in-principle” approval to
two applicants, IDFC Limited and Bandhan Financial Services Private Limited, to set up banks
under the purview of ‘Guidelines on Licensing of New Banks in the Private Sector’, issued on
February 22, 2013. These two applicants were also recommended as suitable for grant of “in-
principle” approval by the High Level Advisory Committee (HLAC) set up by the RBI. IDFC, a

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Mumbai-based non-bank financial company, specialises in infrastructure lending, while Bandhan


Financial is a microfinance organisation based in Kolkata. In the previous round of licensing, two
entities — Kotak and YES Bank — had been allowed to enter the banking sector in 2003-04.

This approval granted will be valid for a period of 18 months during which the applicants have to
comply with the requirements under the Guidelines and fulfil the other conditions as may be
stipulated by the RBI. On being satisfied that the applicants have complied with the requisite
conditions laid down by the RBI, they would be considered for grant of a licence for
commencement of banking business under Section 22(1) of the Banking Regulation Act, 1949 and
until a regular licence is issued, the applicants would be barred from doing banking business.

The process to issue bank licences was started in February 2010, after a Budget announcement by
the then finance minister (now President) Pranab Mukherjee, with the objective of promoting
financial inclusion. Three years later, the RBI released the final licensing guidelines in February
2013. The deadline for filing applications was July 1, 2013. A total of 27 entities applied for
licences. These included conglomerates like the Birlas, the Anil Ambani group, Larsen & Toubro
and the Bajaj group, as well as non-banking financial companies like LIC Housing Finance and
Edelweiss. Another micro lender, Janalakhsmi, had also applied. While the Tata group withdrew its
application citing stringent norms that stipulated a non-operative financial holding company
structure, Videocon Group-promoted Value Industries also dropped out.

After withdrawal by two applicants, 25 applications have been considered. A HLAC was set up on
October 30, 2013 chaired by former RBI Governor, Dr. Bimal Jalan and comprising three members
(viz. Shri C.B. Bhave, former Chairman, SEBI; Smt. Usha Thorat, former Deputy Governor, RBI;
and Shri Nachiket Mor, Director, RBI Central Board) to screen the applications, and to recommend
licences only to those applicants who comply with the Guidelines. In the first stage, the applications
were scrutinised by RBI to ensure eligibility of the applicants and thereafter, the applications were
referred to the HLAC, which submitted its recommendations to RBI on February 25, 2014 for
consideration.

The RBI assessed the quantitative and qualitative aspects of the applicants as per the criteria laid
down in the Guidelines, which includes analysis of the financial statements of the key entities in the
group, 10 year track record of running their businesses, proposed business model for the bank as
well as the applicants’ demonstrated capabilities for running a bank, plan for expanding inclusion,
and culture of compliance and integrity demonstrated by the applicant in its past activities. Based
on all this, the RBI took a view of the “fit and proper” status of the applicant.

The approval of licences for IDFC Ltd and Bandhan Financial Services marks the start of a
cautious experiment for a sector dominated by lethargic state lenders, many of which are reluctant
to expand into rural areas or towns where banking penetration is low.

9. Timeline on Bank Licensing in India: Past Experience


1) 1947-1969: Following a spate of mergers and amalgamations, the number of commercial
banks in the country decreased from 640 in 1947 to 85 in 1969.

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2) July, 1969: 14 major commercial banks were nationalised with the basic objective of
ensuring credit flow to priority sectors of the economy.

3) April, 1980: Six more commercial banks were nationalised.

4) January, 1993: Reserve Bank of India (RBI) released guidelines for licensing of new
banks in the private sector. 10 new banks were formed on the basis of these guidelines.
These were Global Trust Bank, ICICI Bank, HDFC Bank, Axis Bank, Bank of Punjab,
IndusInd Bank, Centurion Bank, IDBI Bank, Times Bank and Development Credit Bank.

5) January, 2001: RBI revised the guidelines for new bank licences. Two new banks – Kotak
Mahindra Bank and YES Bank – were formed.

6) February 26, 2010: Former finance minister and now president Pranab Mukherjee
announces in his budget speech (for 2010-11) that companies and business houses will be
allowed to set up new banks.

7) August 11, 2010: RBI releases discussion paper on entry of new banks in the private
sector.

8) December 23, 2010: RBI releases gist of comments from the feedback on the discussion
paper.

9) August 29, 2011: RBI releases draft guidelines for licensing of new banks in the private
sector.

10) July 10, 2012: RBI releases gist of comments from the feedback on the draft guidelines.

11) February 22, 2013: RBI releases guidelines for licensing of new banks.

12) July 1, 2013: Last date for submitting applications for new banking licence. RBI discloses
names of 26 applicants for new banking licence – two of them drop out while one new
player gets added to the list later.

13) September 4, 2013: RBI governor Raghuram Rajan announces setting up of a committee
headed by Bimal Jalan to screen the applications.

14) November 1, 2013: Bimal Jalan committee holds its first meeting.

15) February 25, 2014: Bimal Jalan committee submits its report to RBI.

16) March 12, 2014: RBI seeks Election Commission's permission to issue in-principle
approvals for banking licence.

17) April 1, 2014: Election Commission allows RBI to issue new bank licences.

18) April 2, 2014: RBI grants in-principle approval to IDFC and Bandhan Financial Services
to set up banks. The in-principle approval will be valid for 18 months.

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10. Expansion of Banking Infrastructure


As per Census 2011, 58.7% households are availing banking services in the country. There are
102,343 branches of Scheduled Commercial Banks (SCBs) in the country, out of which 37,953
(37%) bank branches are in the rural areas and 27,219 (26%) in semi-urban areas, constituting 63
per cent of the total numbers of branches in semi-urban and rural areas of the country. However, a
significant proportion of the households, especially in rural areas, are still outside the formal fold of
the banking system.

Table – 1: Position of Households availing Banking Services

Table – 2: No. of Branches of Scheduled Commercial Banks as on


31st March, 2013

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Table – 3: No. of Functioning Branches of Scheduled Commercial Banks


during Last Five Years

Table – 4: No. of Branches of Scheduled Commercial Banks Opened during


Five Years

Table – 5: No. of Villages and Average Population Per Branch (APPB)

Table – 6: No. of Bank Branches of SCBS over the Years

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Table -7: Number of ATMS in the Country as on 31st March, 2013

Table - 8: Select Indicators of Financial Inclusion –


Cross Country Comparison

All data pertain to 2011 Source: Trends and Progress of Banking in India

Conclusion
The predominance of government owned banks in India has contributed to financial stability in the
country, and experiences have shown that even the deterioration in bank financials does not lead to
erosion of consumer confidence in such banks, which does not extend to private sector banks
(Mohan, 2006). Apart from that, during the recent global financial crisis, public-ownership has
positive implications for financial stability as deposits migrated from the private sector banks to
public sector banks. Also, retail deposits in Indian PSBs increased in contrast to the banks in
advanced economies where there was a liquidity crisis due to deposit run, as a result of which there
was a need for blanket extension of deposit insurance across Europe.

Hence, we may conclude that, in order to achieve the objectives of adequacy of credit and financial
inclusion, it may be necessary to expand the number of banks and the size of the banking sector.
However, such expansion is unlikely to come about from public banks given the fiscal costs
involved in providing continuous capital support to these institutions. Hence, there is a need to
boost the presence of private banks, while consolidating the existing public banking system.

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