Should Indian Post be granted Banking license?..Do they need one?

The decision of Indian Postal Department to seek a Banking license from RBI through the Licensing Scheme meant for private sector has been an object of discussion since the announcement was made.  The application is a source of embarrassment to  RBI which now has the challenge of deciding whether to grant a license to Indian Post or not as a traditional Bank.

There have been many positive reviews by experts indicating why Indian Post deserves a Banking license. However, I am personally not convinced that it is a good idea for Indian Post to become a “Commercial Bank”. In fact Indian Post has a greater future by simply modernizing its traditional services rather than becoming a Bank. By converting itself into a Bank, India will lose a great  digital post service that can be developed by only the department of post and not by any other entity in future.

Let me present some of my preliminary views in this regard so that E&Y instead of advising the Postal department to convert itself into a Bank can work on how to modernize the postal system into a “Digital Postal System”.

To start with, we can recognize that the Postal department is today a department of the Government of India which meets its costs from out of the Consolidated Fund of India. It is stated that  in the fiscal year 2012, it suffered a loss of Rs 6346 crores. Had it not been debited to the consolidated fund of India, perhaps the Postal department would be considered as a “Sick” company and wound up.

Post offices accept Savings Bank accounts, Recurring deposits, Time deposits and also sells long term investment instruments. The deposits in the system  are stated to be in the region of Rs 6 trillion (600,000 crores) . It is therefore the largest Bank in the country as regards deposit mobilization. It has over 150000 offices with nearly 89% of them in rural areas making it the largest institution in financial services across the country.

If the department needs to obtain Banking license then the “Banking Arm” has to be carved out as a “Public Sector Company” and run as a “Profit Center”. It cannot enjoy the benefit of “Money on tap” from the Government and has to earn money out of lending operations. It needs to also maintain SLR and CRR on the deposits.

From the depositor’s angle, the rates of interest paid by the Post office today may go down in the Banking arm. Secondly, the deposits which now have an “Unlimited Deposit Insurance” will come under the limited guarantee scheme of the DICGC. Hence the deposit products of the Indian Postal Bank would be inferior to the current products of the Indian post office.

If this inferior product is offered with the current service levels of the Postal department vis a vis an ICICI Bank or a Kotak Mahindra Bank, it is not possible for the Indian Postal Bank to retain its current customer base of around 23.8 crore customers (Savings Bank).

What will therefore happen is that the postal department will have to continue its operations in the present form while its own sister organization will cannibalize into its present activities. As a result the department will continue to carry the unprofitable part of its operations which has resulted in the loss of Rs 6436 crores in 2012 and will also be burdened with commercial competition from its Banking arm to wean away profitable niche of the current business portfolio.

At the same time, the need to undertake “Lending” as a new activity will create a complete upheaval in the system. At present the manpower in post office is not geared towards any lending activity and hence it has to borrow the entire lending portfolio from outside.

The proposal therefore is neither good for the Postal department nor is rosy for the Banking subsidiary. It would be beneficial for both the Postal department and the Banking industry as well as for the people if Indian Post continues to be “Deposit only Institution” backed for repayment by the Government of India.

The Banking subsidiary of the postal department will essentially be a Government owned Bank much like the REPCO Bank presently owned by the Ministry of Home Affairs (as a Society). This trend of each ministry having a Bank of its own is unhealthy from the point of view of a central regulator like RBI.

Once an Indian Postal Bank comes into existence, its staff mostly drawn from outside will be in a higher remuneration package compared to the existing employees. The existing employees in rural areas will end up doing all the dirty business as agents of their Bank counterparts who will be entrenched in the district head quarters in air conditioned chambers. Sooner or later this will give raise to a huge HR conflict and makes the entire business unviable.

We now have the example of Air India and Public Sector Hotel businesses suffering from the competition fuelled by sell out from within by corrupt politicians. The fate of Indian Postal Bank cannot be different.  We can therefore anticipate that the risk of failure of the Indian Postal Bank is relatively higher than in the case of any other private sector owned Bank.

It must be remembered that “Risk of Failure” is inherent in every financial business and hence it cannot be eliminated in Banking. We can only take precautions so that risks are identified at an early time and mitigated before it becomes unmanageable. From the RBI’s point of view, risk management strategy within the banking system is better administered if the risk can be contained within a “Failed Entity”. If the failure of one Bank can bring down other stable businesses, it would mean bad risk management. In this respect, failure of “Indian Post Bank” has the potential of developing into a major scam that can spread the risk to the consolidated fund of India.

In my opinion it is not logical for RBI to create this new risk.

Further, going by the legal structure in India, it is possible that the prospect of “Indian Post” turning into a “Commercial Venture” either directly or indirectly may be in conflict with the constitutional framework. Hence the Banking license to Indian Post could be challenged.

I would like Dr Subramanya Swamy to provide his views on this aspect.

While therefore giving my firm view that Indian Postal Department should withdraw its application (rather than RBI rejecting the same), I would like to express that the Indian Postal Department can contribute to the “Financial Inclusion” objective without setting up a Bank.

For example, as is already happening, Postal department can continue to be the “Disbursal Agent” for any Government subsidy. By simply linking the E Money order scheme to the disbursement chain, the objectives can be achieved without any additional investment from the side of the postal department.

Postal department can also modernize its IT infrastructure so that the efficiency of operation can be improved. Even today, the Speed Post is actually more efficient than private courier service though many in the public donot realize it. May be we need to introduce 24X7 speed post counters and more customer friendly operators to manage the counters. The back end can be stream lined and just as Premium couriers charge upto Rs 400 for guaranteed next day delivery, Postal authorities may also introduce “Guaranteed Speedpost Delivery” as a premium service.

The postal letter system can also be revolutionized with E-Letters being delivered electronically from one end to another end so that while Telegrams might have gone extinct, all letters would be delivered at the speed faster than the telegrams. The system would require a vending machine where the letter posted would be scanned and delivered to the destination post office where a print out would be delivered to the addressee. This will eliminate the movement of the cards in physical form. This system is similar to the Truncated Cheques or E Cheques conceptualized under the NI Act.

Postal authorities can also develop the “Postal ID” into a biometric based personal ID which can automatically be a “Postal Aadhar”. Then there could be bio-metric-cum face recognition based Assisted Money Vending systems in its rural Post offices which  can be used as universal money disbursal systems for various government disbursements and also support other Banks which donot have such a network.

 Additionally, Postal authority can and should develop a national e-mail exchange backbone with a secured server farm equivalent to the infrastructure of gmail so that all emails from within the country can be handled through this “Indian postal email”. Creating a commercially viable gmail alternative would be a great service that Indian Postal authorities could do to the people of India instead of rushing to become a Bank for which they are ill equipped.

It is regrettable that E &Y has failed to provide the correct guidance to the department for maximizing its service potential by upgrading and extending its present services rather than setting out to be a Banking institution which eventually may turn out to be a bad decision.

Many of the arguments presented above will with some modification apply in principle to the application of LIC Housing Finance also. Hence I donot consider it desirable that neither Indian Post nor LIC Home Finance should be considered for license.

Continuing from our previous discussion  we are now left with 6 applicants only who need to be short listed for the license.

Naavi

Related Articles:

Why India Post should get a banking licence

India Post plans to enter banking businsess

Dept Of Posts To Move Cabinet Note To Apply For Bank License

Post Bank of India?

India Post needs to become a corporate for banking foray

India Post Bank?

Indian Postal Service a Research Report

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Which of the 26 applicants deserve Bank license?

As the debate on the choice of probable licensees hots up, here is an interesting debate in moneycontrol.com between three experts

See Copy of the Detailed debate here

The three experts who have expressed their views are R Jagannathan, the Editor Firstpost, Haseeb Drabu former chairman J&K Bank and former editor Business Standard and a columnist with Livemint, and B D Narang former chairman of Oriental Bank of Commerce and now director of many companies. The experts have concluded that they would prefer to categorize the applicants into different categories namely NBFCs-pure play, NBFCs backed by Corporates, NBFCs backed by Government,  Brokerage and Real Estate Firms, Corporates in the private sector, Public sector companies and Government owned entities.

All experts are unanimous on rejecting the applications of the brokerage firms and real estate companies. Most also eliminate corporates on the basis of conflict of interest. Pure play NBFCs are being preferred with Shriram and SREI Infrastructure Finance as preferred candidates in this category. In the corporate backed NBFCs, Bajaj FInServe and L&T Finance are preferred. In the Government sector, Postal Department is the preferred applicant with LIC Housing Finance the next preference. One of the experts have preferred both Tatas and Birlas for the license though other two have not shown the inclination.

We thus have six candidates who seem to have passed this short listing exercise and if we add the Tatas and Birlas, it adds upto 8 inthe short list.

I am happy to note that the experts have given weightage to the “Financial Inclusion Capability” as one of the criteria for selection. I cannot but agree with this criteria as the main parity breaker as I have indicated in my earlier post.

Based on the views of the experts the following 18 applicants are considered as not suitable for the award of the license.

1.India Infoline Ltd., Mumbai
2.Religare Enterprises Limited, New Delhi.
3.J M Financial Limited, Mumbai
4.Muthoot Finance Limited, Kochi
5.UAE Exchange & Financial Services Ltd., Kochi
6.INMACS Management Services Limited, Gurgaon.
7.Smart Global Ventures Pvt. Ltd., Noida.
8.Indiabulls Housing Finance Limited, New Delhi
9.Suryamani Financing Company Limited, Kolkata.
10.Janalakshmi Financial Services Pvt. Ltd., Bangalore
11.Magma Fincorp Limited, Kolkata
12.Bandhan Financial Services Pvt. Ltd., Kolkata
13.Edelweiss Financial Services Limited, Mumbai
14.Tourism Finance Corporation of India Limited, New Delhi
15.IFCI Limited, New Delhi
16.IDFC Limited, Mumbai
17.Value Industries Limited, Aurangabad
18.Reliance Capital Limited, Mumbai

This leaves the following 8  candidates in the fray as preferred candidates  namely

1. TATA Sons Limited, Mumbai.
2. Aditya Birla Nuvo Ltd., Mumbai.

3.Bajaj Finserv Ltd., Pune
4. L & T Finance Holdings Limited, Mumbai

5.Shriram Capital Limited, Chennai.
6.SREI Infrastructure Finance Limited, Kolkata

7. Department of Posts, New Delhi.
8. LIC Housing Finance Ltd., Mumbai

I will expand on my comments in my next post.

Naavi

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Beware of any fraudulent email

I am informed that there was an unsuccessful attempt to change password in my yahoo email account. (vijayashankar@yahoo.com). While I have taken some precautions since the report, If this is a malicious attempt and is repeated again with success, I anticipate emails to be sent to my contacts such as ” I am stranded in London, lost my passport and purse, please send me some money immediately..etc”.

Kindly ignore such mails if any.

This post is made as a means of public notice and will also be posted in cyber-notice.com.

Naavi

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Banking License Aspirants Should Disclose Business Plans to Public

In India, Reserve Bank of India (RBI) is gearing itself to grant fresh Banking licenses. 26 applications are now under the consideration of RBI. The applicants include a diverse set of groups which includes

a) A department of the Government of India
b) 3 Public sector Companies
c) 4 large private sector groups
d) 11 Private sector NBFCs including a Housing loan company and 2 Infrastructure finance companies
e) 3 Share broking companies
f) A Gold loan company
g) A Currency Exchange company
h) A Mobile handset Company
i) A Management consultancy company

Many of the companies donot even need a second look for rejection.

The list indicates that there might not have been any strict pre application criteria and hence anybody with an intention of getting some free publicity has entered the fray even though they may get rejected in the next 4 months. They will be trading on the false reputation they have gained as “Applicant for Bank License” during the next 4-6 months and extract some benefit out of the same. If nothing else their share prices are likely to remain higher than normal and provide enough financial gain to provide justification for the application.

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Will RBI disclose “Sanction Mechanism” to enforce sanctity of Banking license conditions?

The opening up of a licensing window for Private Banks in India which has attracted 26 applications has also raised a debate on whether the new licenses are beneficial to the economy. RBI intends to impose “Financial Inclusion” and “Priority Sector Obligations” in addition to “Minimum Capital”, “Majority Public Holding” and “Avoidance of Conflict of Business” as norms to ensure that the new licenses will actually benefit the society.

The undersigned  has been fighting for a “Safe E Banking” environment in India and has been pointing out that RBI has not succeeded in imposing its own regulatory prescriptions for safe banking with the current Bankers. Many of the Bankers simply ignore RBI guidelines and RBI is forced to remain silent. Non notification of Damodaran Committee recommendation on customer service and the recent postponement of security mitigation guidelines for cards and e banking scheduled for June 30, 2013 are glaring examples of how RBI’s good intentions are remaining only on paper.

Naavi has pointed out several instances where some Banks have failed to follow RBI guidelines and flouted licensing norms causing loss to the public. At least in two instances, Naavi has demanded that licenses of two branches of two Banks should be suspended as a matter of punishment. Naavi has also demanded that the penalty for KYC failures should be increased and the funds generated should be used for providing “E Banking Fraud Guarantee Scheme”. RBI has not been able to take any action on these demands.

Additionally several sting operations have recently exposed the malpractices in prominent Banks indulging in money laundering.

Most Banks including public sector Banks have gone on record with illegal and anti consumer terms in the Internet Banking guidelines and RBI has not even taken notice of the same.

Many of these violations are sufficient to cancel the license of the entire Bank if not the erring branch. But considering that Naavi’s demand for cancellation of licenses of one branch of PNB and one branch of ICICI Bank for flouting RBI guidelines has not evoked proper response from RBI, it is unlikely that RBI will ever consider “Non Compliance of Regulations” as sufficient cause for cancellation of license. RBI may consider strict action only when there is a “Managerial Fraud” and “Imminent failure possiblity” in the Bank.

RBI has therefore shown its inability to take any strict penal action against erring Banks who continue to flout regulatory norms and are ready to pay the financial penalty if caught. Absence of any other stricter penalty has diluted the perceived power of RBI.

Had RBI initiated criminal action against some of the Chairpersons of the erring Banks who are proved to be involved in money laundering and other illegal activities, the regulatory compliance situation would have been better. Even if the licenses of the erring branches had been cancelled, it would have had a significant impact in preventing future violations of similar kind. But RBI did not have the guts to impose such strict penalty on the erring Banks.

As things stand today, RBI is therefore becoming less and less effective in regulating the industry. Some of the individual Banks and the IBA are gaining too much indulgence to dictate the regulatory aspects of the industry.

The “Strict Norms” for licensing which are now being discussed need to be seen in this perspective.

For example, even now, RBI has not been able to achieve its Financial Inclusion and Priority Sector lending objectives and there is an admitted large scale rigging of figures by Banks to report non existing compliance. Failure of RBI in “Selective Credit Control” and “Over Liberalization without adequate monitoring and control” is part of the reason why inflation is going unchecked in the country. “Commercial objectives superseding social welfare” has slowly converted “Banks” into “Money shops” with no social obligations.

In this background, the so called “Strict Norms for Licensing” appear amusing. These norms could finally  end up only as an eye wash to let influential corporates get the coveted Bank licenses.

I am sure that some corporates may more than satisfy the minimum captial criteria prescribed by RBI for the New banks to profess that they have “Deep Pockets” to ensure success of the venture. The “holding structure” also would be met with suitable restructuring. They may also provide all assurances on “Financial Inclusion” and “Priority Sector Lending”.

But it is more or less certain that many of the new Banks will finally end up with only “Elite Banking”. They have no capability nor will have the willingness to take up “Financial Inclusion” obligations or “Priority Sector lending”. They will also openly flout “Safe E Banking Principles”. Even though the players will provide assurances and guarantees for obtaining the licenses, they will conveniently ignore in times to come.

From the past one can infer that RBI  does not have the capability to cancel the license even if the Banks turn out to be “In House ATMs” for large corporate houses.

This raises the question that if RBI is not capable of taking strict deterrent action against flouting of Banking norms as has been exhibited in the past, then what is the sanctity of the “Strict Licensing Norms”?

In this background, it appears that just as the applicants need to prove their credentials, it is time for RBI to prove its own credentials as a regulatory agency capable of enforcing its own regulations. For this purpose, RBI should disclose a “Sanctions Mechanism” by which it intends to enforce license obligations in the years to come and the possibility of suspension or cancellation of licenses in cases of repeated failures to meet regulatory guidelines. Such a mechanism should clearly identify “Non Compliance Incident identification and reporting structure”, “Gradation of non compliance incidents”,”Mandatory penalties for different grades of non compliance”, “Inclusion of criminal penalty against erring officials” and also “Cancellation of License”.

May be it can be considered as  an opportunity for RBI to develop an effective regulatory mechanism for the new Banks with which it can also set right the regulatory short falls that have crept into the system at present.

I therefore urge RBI to take some of the steps that have been indicated in this and earlier articles such as

a) Undertaking a Socio-Economic Cost benefit analysis of the business plans submitted by the applicants and placing the reports in public domain along with the proposed business plans

b) Making Cyber Crime insurance mandatory

c) Imposing strict sanctions for non compliance including mandatory loss of license and disclosing the sanction policy as a public document.

Naavi

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Not all Eligible applicants to get Bank License

Governor of RBI has clarified that out of the 26 applications received by RBI for new Banking license, not all otherwise eligible applicants will be granted the license.  RBI has also clarified that it would take about 3-4 months for scrutiny of the applicants before handing the short listed applications to an external consultant. It is preferable that the licenses are not taken up for issue before the next Parliamentary elections as otherwise there would be political pressure to grant licenses to preferred groups.

In a hard hitting article in Economic Times in the form of an open letter to the RBI Governor, Mr Jaithirth Rao a veteran Banker himself and a leading Software professional at present has cautioned the RBI about the possibility of large business houses misusing the Banking license and later forcing the Government to bail out not only the Banks promoted by them but also the group companies that might have acquired large stake in the Bank.

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