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Dr K.C. Chakravarthy, Deputy Governor of Reserve Bank of India speaking at Kochi on 9th February 2013 he stated that if the people in this country are not able to get access to basic banking services even after the regulatory guidelines, we would have to think about enactment of legal provisions for making banking a fundamental right”. He also stated “..across the globe, the provision of a basic banking account for the consumer is considered a right. As I have already mentioned, RBI has issued guidelines advising banks to offer a ‘Basic Savings Bank Deposit Account’ without any minimum balance and provision of basic services without any charges (subject to limitations of operations), thus, conferring a right to every citizen to have a bank account. The mandate is already there and it is for the bank employees to ensure that they open the accounts of everyone who approaches them and not tell them to go to some other bank or branch.”

Unfortunately Dr Chakravarthy’s views donot seem to be part of the RBI policy at least as reflected in the discussion paper on “Disincentivisation of Cheques”.

This discussion paper contains several provisions which hurt the basic aspects of banking service as we know today and mainly affects Bank customers who operate in the physical world. The paper essentially wants to discourage use of physical banking instruments such as cheque or cash and move the customers to the E Banking environment.

The discussion paper is meant to be responded to by the public before February 28, 2013. But it is ironic that the publication that is meant for non Internet Bank users is available for perusal only on the Internet. How does RBI expect a non Internet user to find out the discussion paper and respond?

Even for a casual visitor of Internet, it is not possible to easily locate this discussion paper which is hidden in an URL http://rbidocs.rbi.org.in/rdocs/PublicationReport/Pdfs/DPDC300113_F.pdf

It is therefore necessary for RBI to first publish this discussion paper as a notice to public in the News papers and also put it up as a notice in all Bank branches and make copies available on demand at all Bank branches.

The current move of RBI to post the document on the website will only elicit attention and response from those persons who are internet savvy and therefore have no problems in using Internet Banking service. The message is not meant for them. It has to actually reach non Internet users and any decision taken on the basis of this internet notification will not be a due process of implementing the change.

I request the Supreme Court to take note of this attempt at clever manipulation of public opinion being indulged by some vested interests in RBI.

Naavi

The payment settlement department has authored the E Banking promotion policy reflected in the discussion paper on disincentivisation of cheque usage. I would like to state that this is a promotion of commercial banking business rather than technology enablement and hence not in tune with the regulatory functions of RBI.

Further, RBI is a Banking licensing authority and I need not remind that Banking by definition is integrated with the “Cheque” as a means of withdrawal of deposits. Any policy against this is against the basic constitution of RBI.

The paper is also obnoxiously anti consumer.

I therefore consider the discussion paper as ultra vires the RBI mandate and has to be withdrawn immediately.

I look forward to an acknowledgment of this complaint.

Sent on 12th February 2013 at 7.07 pm. …Naavi

The move from RBI to aggressively promote E Banking even in the light of repeated assertions that the E Banking risks are beyond tolerance levels and to actively discourage use of cheques and cash in Banking is likely to be a nightmare for ordinary citizens of the country.

In its discussion paper on disincentivising the use of cheques, RBI has made several proposals that are aimed at penalizing the current banking practices including use of cheques for payment and receipt and also withdrawals and deposit of cash in the accounts.

If due to this unfair actions of RBI, customers are pushed towards the use of E Banking and they encounter frauds, then RBI will be solely responsible for the losses that the bank consumers are likely to suffer.

I invite the attention of RBI Governor to this development and request him to kindly withdraw the move in toto.

In fact I feel that RBI needs to apologize to the Indian public for the anti consumer statements that have been made in the discussion paper which is uncharacteristic of RBI as we know.

Naavi

The RBI discussion paper on disincentivisation of the use of cheques is very disturbing. The objective of the discussion paper is to get public response on the points raised in the discussion paper or rather get a public endorsement on the suggestions contained there in.

The objective of the proposed changes is to promote the use of E-Banking in preference to the traditional banking channels which use cheques and cash. In the process RBI has suggested several “Anti Consumer Measures”.

A sample of statements made in the discussion paper are as follows.

1.The charges levied by banks beyond this number (minimum number of cheque leaves) may range from moderate to steep

2.In case card holders make payments of card dues using cheques, then high convenience charge may be levied.

3. For any cheques issued beyond the stipulated limit, charges may be levied at the time of payment / debit to the account by the paying bank when the cheque is presented for payment through clearing.

4. In case of individuals who have invested in shares/debentures/bonds etc. and have not opted for receiving dividend/interest directly into their bank accounts, we may consider levying a processing charge when the cheque is deposited into their bank account for collection

5. Cash withdrawals and deposits of cash by individuals may also be charged

6. Discourage cheque collection boxes at public places – have it only at bank branches. This will reduce the convenience of using cheques by individuals

The suggestions indicate a sadistic tendency of RBI and very very depressing.

Naavi