Wednesday, March 4, 2020

Enhanced Access & Service Excellence (EASE) Reforms for Public Sector Banks


The Government of India announces details of Bank recap and Comprehensive Reform Plan

In order to improve the performance & image of PSBs, Govt has introduced EASE in a time bound manner. Infusion of capital depended exclusively on the extent of implementation of these reforms agenda in banks. It is therefore imperative for banks to implement these reforms agenda unfailingly.
On 24th January 2018 the Government of India unveiled details of the re-capitalisation of Public Sector Banks (PSBs) announced in October, 2017.  The capital infusion plan for 2017-18 included Rs.80,000 crore through Recap Bonds and Rs.8,139 crore as budgetary support.  This plan addressed regulatory capital requirement of all PSBs and provides a significant amount towards growth capital for increasing lending to the economy. 
The six key groups have provided suggestions for responsible and responsive banking, enhanced credit offtake, MSME lending, deepening financial inclusion, and NPA resolution. The Reserve Bank of India has said in its Financial Stability Report (FSR) that the gross NPA ratio of all scheduled Commercial Banks (SCBs) may increase from 9.6% in March 2017 to 10.2% by March 2018.
The Central Government was of the view that it cannot go on infusing capital in state-run banks while lenders continue to function the way they have. The recap was to be accompanied by a strong reforms package across six themes incorporating 30 action points.
The reforms agenda was based on the recommendations made at the PSB Manthan held in November, 2017 involving senior management of PSBs and representatives from Government.
The reform agenda was aimed at EASE - Enhanced Access and Service Excellence, which was focussed on six themes as under:
- Customer responsiveness,
- Responsible banking,
- Credit off take,
- PSBs as Udyami Mitra,
- Deepening financial inclusion &      Digitalisation and
- Developing personnel for brand PSB.
   
The overarching framework for the reforms agenda is “Responsive and Responsible PSBs”.
Capital infusion by the Government was contingent on performance of PSBs on the reform.  Whole Time Directors of PSBs would be assigned theme wise reforms for implementation.  Their performance in this regard would be evaluated by the bank Board.
A survey by an independent agency in respect of EASE would be conducted to measure public perception about improvements in access and service quality.  Results of the survey shall be made public each year.
The recap & reform agenda was sharply focused on strengthening PSBs, increasing lending to MSMEs and making it easier for MSMEs and retail customers to transact as well as significantly increasing access to banking services.  It includes a commitment to banking services within 5 kms of every village, refund within 10 days of any unauthorised debit in electronic transactions, a mobile App  for locating banking outlets and a mobile ATM in every underserved district.

Following is the EASE Reforms Agenda as announced by the Government to be complied with:
The 30 action points have to be necessarily implemented by banks without any exception. All staff members should be aware of these reform agendas. Based on the extent of implementation of these action points, banks would be rated. Proper implementation of these action points would get the Banks good ranking. Hence Banks should endeavour to get good rating. An external agency, BCG had been appointed for the purpose by IBA.

ACTION POINTS FOR BANKING REFORMS
CUSTOMER RESPONSIVENESS
AP- 1. EASE for customer comfort:
1. Banking from home and mobile to progressively make brick-and-mortar branch visits redundant:
Promote digital banking, such as Internet banking, mobile banking, integrated mobile apps and phone banking for EASE of opening accounts and fixed deposits, nomination, sanction of overdraft facility, online loan application, e-payments, return preparation, etc.
2. Simplification of forms:
(a) Maximum two pages for KYC, and two pages for account-opening (inclusive of nomination, Form 60/61, and all other services)
(b) Online forms with auto-filling of information already held by bank, and likely default entries (e.g., current address same as permanent address)
3. Suite of financial services for one-stop access to customers, including banking-plus services such as insurance and investment:
(a) Board-approved plan
(b) Implementation, with partnerships and skilling of personnel
4. Pleasing ambience of customer service area, with proper seating, uncluttered urroundings, cleanliness, proper whitewashing and painting, etc.
5. Courteous & smartly attired staff: Bank-approved code of customer interface
6. Basic customer amenities :
Customer access to clean toilets and safe drinking water.
7. Uniform and attractive signage for customer assistance in languages as per RBI’s instructions
AP- 2. in grievance redressal :
8. System-driven grievance redressal mechanism with—
(a) real-time complaint status tracking by complainant;
(b) time-bound auto-escalation, compliant with time limits laid down by RBI;
(c) feedback from complainant to check the quality of redressal; and
(d) root cause analysis and effective action on common grievances to avoid recurrence
AP- 3.EASE for senior citizens and the differently abled:
9. Doorstep banking
10. Preference in service, or dedicated counters
11. Free cheque-book issuance, without visit
12. Online update of pension life certificate
13. Automatic benefits of senior citizens accounts
14. Visually handicapped may withdraw through authorised person
15. Providing TDS exemption forms proactively
AP- 4. Introduction of EASE Rankings on customer EASE:
16. Annual EASE Ranking survey to measure banks’ customer-responsiveness, assessed on all items, through customer survey and objective measurement
EASE Ranking Index to be to be published annually.

RESPONSIVE BANKING
AP-5. Creation of a Stressed Asset Management Vertical (SAMV):
17.        (a) For focussed recovery efforts through a dedicated, specialised and motivated team for enhanced and timely recovery, under a Board approved policy delineating its scope, roles and responsibilities
(b) Appropriate staffing, with incentive structure linked directly to benchmarked enhancements in recovery levels
(c) Migration of identified Stressed Assets and high-value Special Mention Accounts (SMAs) to SAMV
AP-6. Clean corporate lending through rigorous due diligence and appraisal for sanction:
(a) Ensure that necessary regulatory clearances/approvals are in place, and appropriate backward and forward linkages are tied up before disbursement
(b) Scrutinise group balance-sheet and ring-fencing of cash flows
(c) Consider non-fund and tail risk embedded in project financing
(d) Initiate process for use of technology and analytics for comprehensive due diligence across data sources
(e) Lead banks in consortium to build capacity for techno-economic valuation, and their consortium banks to build requisite capacity to validate/assess such valuation
AP-7. Tie-up with Agencies for Specialised Monitoring (ASMs) for clean and effective post-sanction follow-up, on common engagement basis in case of consortium lending, for :
19.        (a) aspects requiring domain expertise (e.g., inspection and stock audit); and
(b) large credit exposures (say, above Rs. 250 crore) and exposures of a specialised nature.
AP-8. Institute efficient practices for effective coordination in large consortium loans:
20. Observe a minimum threshold for participating in consortium loans (say,10% )
21. Adopt an SOP for the valuation process in consortium loans to synchronise date, periodicity and methodology of valuation, supported by online mechanism for sharing among consortium members
22. Model SOP for coordination among Joint Lenders’ Forum (JLF) members
AP-9. Strict segregation of pre- and post-sanction roles & responsibilities & for enhanced accountability:
23.       (a) Board-approved policy for strict segregation of roles and assignment of responsibilities for appraisal, monitoring and recovery
(b) Identification, training and placement of staff

AP-10. Differentiated Banking Strategy (DBS) thr ough smaller  banks & to leverage their competitive advantage for strong regional and market segment connect, covering Board-approved:
24.       (a) business plan, including asset swap/sale plan to achieve desired risk weighted asset mix, with limited corporate exposure (about 25% of total risk weighted assets) and initial reduction of corporate exposure share by Mar 2019 to below 40% or by at least 15% from Sep 2017 level;
(b) branch network rationalisation plan; and
            (c) plan for realigning organisational resources (including HR, IT and partnerships).
Illustrative categorisation:
• National retail banks, &
• Regional retail banks
AP-11. EASE through transparent and robust One-Time Settlement & (OTS)mechanism, for timely and better realisation through an online OTS platform
25        (a) End-to-end processing, till repayment or recovery in case of nonadherence to OTS; and
            (b) Automated escalation and monitoring.

Furthering Financial Stability
AP-12. Check aggressive and imprudent lending through proactive, dynamic & systemic risk management :
26. Institute and implement Risk Appetite Framework for a structured approach to manage, measure and control risk, with following features:
(a) Cover policies, processes, controls and systems for both material and reputational risks
(b) Include a risk appetite statement, risk limits, and outline of roles and responsibilities of those overseeing implementation and monitoring
27. Institute and implement Risk Based Pricing for pricing loans, keeping in view risk-adjusted return
28. Appointment of Chief Risk Officer with requisite skills, having direct reporting lines to the MD & CEO / Risk Management Committee of the Board
29. Stress-testing to be carried out semi-annually, as per RBI’s Stress Testing Guidelines, for eight quarters, and report of the results to be presented to the Board, with particular attention to:
(a) concentration exposures at the borrower, group and sector levels, and
(b) contingency plans under the stress-test scenarios.
AP-13. Monetise realisable value from sale of non-core assets to strengthen the bank and focus on core business, as per asset-wise, time-bound Board-approved plan for:
30.         (a) Exit from all ‘s trategic equity investment’ in unrelated businesses and sale of all real estate not used for bank operations; and
(b) Divestment of stake for optimal realisation of value in viable complementary businesses.
AP-14. Rationalise overseas operations with in and across PSBs for cost efficiencies and synergies in overseas markets:
31.        (a) Based on competitive strength and viability
(b) Draw up Business-Unit-wise Board-approved plan, for time-boundclosure/ consolidation as per due procedure, to:
(i) Close non-viable branches;
(ii) Consolidate operations in the same geography, taking into account operations of other PSBs; and
(iii) Consolidate equity stake in joint venture having multiple PSB partners.

Ensuring Outcomes – Governance
AP-15. Board-approved strategic vision and business focus plan for five years , consistent with its Risk Appetite Framework and, where applicable,
30 Differentiated Banking Strategy

AP-16.Boards to evaluate performance of Banks’ Whole Time Directors
31. reporting to the bank chief executive on implementation of the Reforms Agenda

CREDIT OFF-TAKE
AP-17. EASE for the borrower:
32. Online application facility for home, education, vehicle and other personal loans, with 100% processing on automated basis, for timebound decision-making and transparent status-tracking
33. Digitalise non-retail credit appraisal process on end-to-end basis
34. Step up cash-flow financing substantially
35. Rationalise decision-making layers: maximum three layers
AP-18. Proactive reach-out to borrowers:
36. Dedicated feet-on-street — as against reliance on branch-based reach-in
37. Broad-base bank’s business-connect:
(i) Institute credit-plus services for handholding borrowers for improved access to finance as a result of enhanced bankability of proposals
(ii) Reach-out to entrepreneurs, in association with chambers of commerce and industry associations
AP-19. Strategy plans for key industry-based market segments:
38. Board-approved plans for key industry-based market segments:
(a) Differentiated products and services
(b) Development of industry-wise technical expertise

PSBs AS UdyamiMitra FOR MSMEs
AP-20. EASE of bill realisation for MSMEs:
39. Registration of all banks on TReDS platform for faster bill discounting
AP-21. EASE of financing for MSMEs:
40. Board-approved policy for enhanced working capital to GSTregistered MSMEs, and its roll-out
41. Enable MSME financing through cluster-based financing and FinTech:
(a) Substantially step up cluster-based lending
(b)Improve due diligence, better risk assessment and faster turnaround through FinTech (financial technology innovation for business transaction)
42. Time-bound and automated processing of MSME loan proposals, including—
(a) 15-day decision timeframe for proposals on www.udyamimitra.com, and
(b) online application facility and automated decision for all micro-enterprise
Loans
AP-22. Single-point MSME Relationship Officers:
43. Designated single-point MSME Relationship Officers for the top-20 MSME
accounts in every MSME-Specialised Branch (total 3,319 branches across
PSBs)
AP-23. Revival Framework for stressed MSMEs:
44. Identification of all SMA-1/2 MSME accounts needing help through the Revival Framework in every MSME-Specialised Branch
45. At least two meetings of the Framework Committee to be held by Mar 2018 to take up all identified cases

Deepening Financial Inclusion & Digitalisation
AP-24. EASE through near-home banking:
46. Banking Outlets within 5 km of every village as approved by State Level Bankers’ Committees
47. Most branch-based services through Bank Mitras for branchless banking
48. Mobile ATM in every under-served district by the district lead bank, with pre-announced programme of availability to customers at various locations
AP-25. Social security through microinsurance:
49. Massive expansion in microinsurance coverage by tagging with MSME, agricultural and other retail loan disbursements to cover borrowing individuals & employees of borrowing entities, under Pradhan Mantri Suraksha Bima Yojana and Pradhan Mantri Jeevan Jyoti Bima Yojana
AP-26. EASE through digital payments:
50. RuPay debit card issuance to all Pradhan Mantri Jan Dhan Yojana accountholders
51. Aadhaar-seed all operative current & savings accounts, as per Prevention of Money-Laundering Rules
52. Enable Aadhaar-seeding through OTP on mobile
53. Massive expansion in Aadhaar-enabled payment Points of Sale through BHIM-Aadhaar devices, as per bank-wise target for deployment of 20 lakh devices
AP-27. Customer protection against cyber-frauds:
54. Ensure credit-back against unauthorised debit in electronic transaction, within 10 working days, of notification by customer, as per mandated norms
55. Real-time alerts for customer protection through data analytics, process automation and intelligent monitoring
56. Free customer-level security updates for apps and Internet-based utilities

Developing Personnel for Brand PSBs
AP-28. Reward select top-performers identified through a Performance Management System (PMS):
57. Performance Management System (PMS) based policy for rewarding select top-performers, approved by the Board, covering:
(a) classification of roles as measurable and non-measurable;
(b) objective grading framework that distinguishes top performers; and
(c) incentive & fast-track promotion for the top performers.
58. Incorporate with PMS, end-to-end digitised Annual Appraisal Reports of all staff, covering both filing and assessment, beginning with the performance appraisal for 2018-19

AP-29. Specialisation through job families—Appropriately identify and
59. optimally allocate personnel to enable:
(a) identification of roles for each job family;
(b) obtaining of options; and
(c) optimal allocation of personnel to job families through an objective process
AP-30. Mandate annual role-based e-learning programme for all officers and a fellowship & training programme for senior executives :
60.       (a) Assign weightage in appraisal for e-learning programme
(b) Develop e-learning role-based lessons with randomised, variable question bank for evaluation, and lay down minimum number of online lessons to be successfully completed annually
(c) Assign weightage for exit evaluation in appraisal for fellowship &
training programme
Report Card promised on Public Sector Bank Reforms Agenda was released by Finance Minister Late Shri Arun Jaitley on 28th February 2019

Key Highlights:
-           Independent EASE Report validates 4R strategy & confirms banking turnaround;
-           EASE Index measures & benchmarks reform progress of each PSB on 140 metrics;
-           Team PSB delivers on Reform Agenda across all six themes: 15% rise in 3 quarters;
-           Big strides in Clean Banking — 26% rise in Responsible Banking EASE Index score

Subsequent to the announcement of EASE Reforms Agenda, BCG was onboarded through IBA to design methodology for objectively measuring performance of each PSB on the Reforms Agenda. A steering committee comprising select WTDs of PSBs, under the aegis of Indian Banks’ Association (IBA), has monitored the design and implementation of EASE Reforms Index.
The independent report was commissioned through Indian Banks’ Association and authored by BCG with Forrester Inc., Kantar IMRB and TransUnion CIBIL as knowledge partners. The report confirmed the effectiveness of Government’s 4R’s strategy in securing banking turnaround, with large 26% Index gain in Responsible Banking underpinning clean banking, and measurable progress in all six Enhance Access & Service Excellence (EASE) reform themes over the three quarters ending December 2018.
The Index measures performance of each PSB on 140 objective metrics across 6 themes and provides all PSBs a comparative evaluation showing where banks stand vis-à-vis benchmarks and peers on the Reforms Agenda. The Index follows a fully transparent scoring methodology, which enables banks to identify precisely their strengths as well as areas for improvement.
The report validates government’s 4R’s strategy and its role in fundamentally rebooting Public Sector Banks. The index and report unveiled today provides insights into how public sector banks are effectively addressing NPA problem. The report shows visible progress made on each of 4 elements of Government’s 4R’s strategy including recognition, recovery, recapitalisation and reforms.
EASE report shows significant improvement in PSB performance on the back of Government’s 4R’s strategy –
  • Stress recognition almost complete: Standard restructured advances as a percentage of gross advances reduced from 7% in Mar-15 to 0.5% in Dec-18
  • GNPA trend reversed: GNPA reduced by Rs 31,168 crore, GNPA ratio have started declining after peaking in Mar-18 and has declined for three successive quarters post Mar-18.
  • Record recovery: IBC has led to record recovery- Rs 98,493 crore recovered by PSBs in first nine months of FY19, YOY growth of 103%.
  • PSB balance-sheet strengthened: PSB balance sheets strengthened through infusion of Rs 3.19 lakh crore including infusion by Government and market raising. This has helped five banks to come out of PCA restrictions and improve PCR from 46% in FY15 to 69% in Dec-18 leading to reduced risk.
  • Stress indicators improving: Fresh slippages reduced by Rs 58,000 crore in first nine months of FY19 compared to same period previous FY, Stock of overdue account reduced by 47%, credit risk weighted assets to gross advances reduced by 11%.
Reforms: Multiple reforms implemented covering wider financial system and PSBs.

CLEAN Banking
EASE index tracks multiple steps are taken by PSBs to institutionalise CLEAN banking and avoid recurrence of NPA problem in future. This includes limiting consortiums to smaller efficient groups, special agencies for monitoring large loans, rationalisation of unviable overseas operations, strong risk appetite framework, focus on strong credit appraisals.


Smart Banking
PSB Reforms EASE Agenda lays strong emphasis on speedy and responsive customer service with an objective to drive SMART Banking. EASE Index shows that PSBs are significantly driving SMART Banking and initial results of the reforms are visible

SMART Banking leading to usage of triangulated data and risk minimisation
Diligence across data sources, process digitilisation and analytics enabling robust underwriting, Fraud risk mitigation, Credit process compliance, and importantly customer ease.


PCA banks show 30% improvement in responsible banking theme of EASE Index
Underlying causes of weakness in PCA banks getting substantially addressed
  • 6 banks without Stressed Asset Verticals fully operationalised SAMV
  • Recovery of Rs 35,405 crore in three qrtrs (72% YoY growth)
  • Corporate exposure reduced from 49% in Mar-18 to 40% in Dec-18 as per focus segment strategy
 EASE Index: Sustainable Reform ingrained in PSBs
The Index provides all PSBs a comparative evaluation showing where banks stand vis-à-vis benchmarks and peers on the Reforms Agenda. The Index follows a fully transparent scoring methodology, which enables banks to identify precisely their strengths as well as areas for improvement. Through periodic updates and by providing bank-specific scorecards and inter-bank comparisons, all PSBs are enabled to keep track of their progress on key reform priorities across time. The goal is to continue driving change by spurring healthy competition among PSBs and also by encouraging them to learn from each other.
The number of initiatives under progress in each PSB concern different departments and are at different levels of progress. EASE Reforms Index provides a robust framework to track the progress of reforms not only across the PSBs but also within the PSBs. The methodology of EASE Reforms Index is shared transparently with PSBs. They can leverage the same and can create customised index for tracking reforms based on bank’s priorities, set up centralised teams to comprehensively drive EASE Reforms Agenda and link performance metrics of concerned employees to achievement on metrics covered in EASE Reforms Index. With this, the EASE Reforms will get ingrained further and will catalyse PSB performance on multiple dimensions.
Performance of PSB on EASE Index
PSBs have shown strong trajectory in their performance over 3 quarters post the launch of EASE Reforms Agenda. Overall score of PSBs increased by 15% between Mar-18 and Dec-18 with average score of PSBs improving from 56.3 to 64.5. Significant progress is seen across themes, with highest growth being in Responsible banking.

Some of the key areas with strong progress across themes are:
§  Responsible Banking: PSBs strengthened large credit appraisal, monitoring, recovery processes and improved their risk management and capital management practices.
  • Developing personnel for brand PSB: PSBs initiated roll out of Job-families, deployed online learning platforms, increased measurability in appraisals, etc.
  • Deepening FI and digitalization: PSBs ensured Bank Mitras remain active, widened their bouquet of services, focused on improving adoption digital transactions, improved Aadhaar / mobile seeding
  • Credit off-take and PSB as UdyamiMitra for MSMEs: PBSs reduced loan processing time in retail, focused on revival of stressed MSMEs, drove adoption of TReDS, and deployed dedicated marketing teams & relationship managers, etc.
  • Customer responsiveness: PSBs focused on improving customer satisfaction, identifying and reducing complaints in top-5 complaint categories, reducing complaint resolution time.
(Source: Press Information Bureau, Government of India, Ministry of Finance dt 28-February-2019)

EASE 2.0 scheme: Comprehensive public sector bank reform on the cards

A host of measures are on the cards for transformation of public sector banks (PSBs). While consolidation topped the agenda, a list of directions was separately worked out for state-owned lenders to focus on risk assessment, enhanced early warning signals in cases of stressed assets and bringing in new fintech players.

PSBs have already been asked to carry out an internal assessment for shortlisting ideal candidates for possible mergers or acquisitions. In this direction Mega Merger of 10 Banks into four has already been announced in August 2019 after which the total no. of Public Sector Banks shall come down to 12.

The new performance parameters that may be introduced this year through the EASE programme include more stringent early warning signals (EWS) to tackle stressed assets, effective coordination in large value loans and bringing in new financial technology players to deepen financial inclusion and digitalisation.
Another suggestion is to reconstitute the management committee of the board which takes decisions on large value loans and have representation from risk management.
Separately, the Banks Board Bureau (BBB) has selected around 80 chief general managers (CGMs) from all PSBs who will be trained in globally acclaimed management institutes such as the Kellogg School of Management in the United States. “This is to create a pipeline for future heads in PSBs and also to address the knowledge gap in key functioning areas of banks.”


SEVERAL ADMINISTRATIVE REFORMS ANNOUNCED are:
>> Bank managements made accountable to boards
>> Bank board committees to appraise performance of GM and above, including that of MD
>> Bank boards given the flexibility to introduce CGM level as per business needs
>> Span of control made manageable in large PSBs, post consolidation.
>> Banks will recruit chief risk officers from market to market-linked compensation to attract best talent
>> Boards will decide system of individual development plans for all senior executive positions
>> To ensure sufficient tenure, boards given flexibility to prescribe residual service of 2 years for GM and above
>> Flexibility given to boards of large public sector banks to enhance sitting fees of non-official directors
>> Boards given the mandate to reduce/rationalise board committees for better functioning
>> Risk management committees given the mandate to fix accountability for compliance of risk appetite framework
>> Longer terms given to directors on management committees of boards to enable them to contribute effectively
>> MCB loan sanction thresholds enhanced by 100% to enable focussed attention to higher value loan proposals
>> Non-official director's role made analogous to that of independent director
>> Bank boards given the mandate for training of directors, both for induction and for specialised purposes
>> Bank boards to evaluate non-official directors (NOD) performance annually on peer-review basis
>> Executive directors' strength in larger banks has been raised to four for better functional focus and thrust to technology
>> Creation of leadership pipeline to be facilitated under bank boards' leadership development programme.


Performance of EASE Reforms (1.0 and 2.0) Journey:-
EASE 2.0 which was built on the foundation laid in EASE 1.0 and furthered the progress on reforms. Reform Action Points in EASE 2.0 aimed at making the reforms journey irreversible, strengthening processes and systems, and driving outcomes. Public Sector Banks have shown significant improvement in the Action Points of the EASE Reforms Agenda since its introduction.
Following the completion of recognition of legacy stress as NPA, PSBs have returned to profitability with sound financial health and institutionalised systems to prevent the recurrence of past weaknesses.
Public Sector Banks have shown important enhancement in the Action Points of the EASE Reforms Agenda since its introduction. The improved financial condition of PSBs reflects in many parameters such as:
  • Gross NPAs reduced from Rs 8.96 lakh crore (14.6%) in March-2018 to Rs 7.17 lakh crore (11.3%) in December-2019;
  • A sharp decline in fraud occurrence from 0.65% of advances during FY10-FY14 to 0.20% in FY18-FY20; due to fraud prevention reforms and proactive checking of legacy NPA
  • Record recovery of Rs 2.04 lakh crore in FY19-9MFY20 driven by newly setup dedicated stressed account management verticals in PSBs that have recovered Rs 1.21 lakh crore in the same period;
  • Number of PSBs under PCA down to four;
  • 12 PSBs reporting profits in 9MFY20;
  • CRAR 340 bps above the regulatory minimum; and
  • The highest provision coverage ratio of 77.5% in nearly eight years.

Performance of PSB on EASE 2.0 Index 
Like in the previous year, progress made by PSBs was tracked quarterly through a published EASE Reforms Index leading up to the annual review. In addition to the inclusion of the EASE Reforms Index in the evaluation of Whole Time Directors of PSBs, it has now been made part of the annual appraisal of PSB leadership up to two levels below the Whole Time Directors.
PSBs have shown a healthy trajectory in their performance over three quarters since the launch of EASE 2.0 Reforms Agenda. The overall score of PSBs increased by 35% between March-2019 and December-2019, with the average EASE index score improving from 49.1 to 66.3 out of 100. Significant progress is seen across six themes of the Reforms Agenda, with the highest improvement seen in the themes of ‘Responsible Banking’ and ‘PSBs as Udyamimitra for MSMEs’.



State Bank of India,
Bank of Baroda and
Oriental Bank of Commerce are the front-runners for the best performing banks.

The final EASE 2.0 index will be published after declaration of bank results for the financial year.

Major Reform achievements over March 2018 to December 2019
  • Significant improvement in customer outreach through dedicated marketing force and external partnerships. The number of dedicated marketing employees has increased from 8,920 to 17,617
  • Turnaround time for loans reduced by 67% from the average of nearly 30 days to nearly 10 days
  • 80% of PSB customers now have access to 35+ services on mobile/ Internet banking, 23 services on call center. The availability of services has nearly doubled over last 18 months.
  • Improvement in the availability of regional languages in call-centers has increased four-fold
  • Complaint redressal turnaround time reduced from the average of 9 days to 6 days
  • 20 branch-equivalent services made available by PSBs through Bank Mitras
  • For prudential lending, PSBs are now systematically keeping watch on adherence to risk-based pricing, and cases with deviation have reduced from 59% to 23%, and have put in place data-driven risk-scoring for appraisal of high-value loans that factors in group-entities.
  • Most PSBs have deployed IT-based EWS systems leveraging third-party data, which have enabled early, time-bound action in stressed accounts. Monitoring has also been strengthened by deploying Agencies for Specialised Monitoring, and proactively monitoring listed entities based on published financials. Slippage into NPA has reduced from 3.90 lakh crore in 12-months ending March-18 to 1.88 lakh crore in 12-months ending December-19.
  • PSBs have adopted digital platforms such as online OTS, e-Bक्रय, e-DRT for expedited recovery. 87% of one-time settlement (OTS) cases are now tracked through dedicated IT systems.
  • PSBs have adopted new ways of credit. 63% of all PSB inland bills are now discounted through online TReDS
  • 40% YoY growth in the quarterly value of loans disbursed through psbloansin59minutes.com (Dec-20)
  • The Government has introduced several governance reforms. The governance reforms include arm’s length selection of top bank management through Banks Board Bureau, introduction of non-executive chairpersons, broader talent pool for such selections, empowered bank Boards,  strengthening of the Board committees system, enhancing the effectiveness of non-official directors, and leadership development and succession planning for the top two levels below the Board. In larger PSBs, Executive Director strength has been increased, and Boards are empowered to introduce CGM level for increased business.
EASE 3.0
Union Minister for Finance & Corporate Affairs Smt. Nirmala Sitharaman unveiled EASE 3.0, the Public Sector Bank (PSB) Reforms Agenda 2020-21 for smart, tech-enabled banking, and the PSB EASE Reforms Annual Report 2019-20 on February 26, 2020 during an event in New Delhi. The function was organised by IBA (Indian Banks Association). Minister of State for Finance and Corporate Affairs Anurag Thakur was the guest of honour for the event. Finance Secretary Rajiv Kumar, Secretary Designate cum Special Secretary (Financial Services) Debashish Panda and Chairman IBA, Rajnish Kumar also graced the unveiling event.
Finance Minister Smt. Sitharaman exhorted Public Sector Banks (PSBs) to have one-to-one interface with their customers through branch-based banking and not rely so much on credit ratings agencies.
She said that banks need to connect with their customers by leveraging technology but not exclusively only through the interface of technology. she asked the bankers to focus more at the grassroot level.
Smt. Sitharaman further exhorted banks to be friendlier to its customers by using local language in bank branch. She said that PSBs have played a great role in enabling financial inclusion in the country.
What is EASE 3.0:
Ease (Enhanced Access and Service Excellence) 3.0 reform agenda aims at providing smart, tech-enabled public sector banking for aspiring India.
New features that customers of public sector banks may experience under EASE 3.0 reforms agenda include facilities like:
1. Palm Banking for “End-to-end digital delivery of financial service”.
2. “Banking on Go” via EASE banking outlets at frequently visited spots like malls, stations, complexes, and campuses.
The idea behind EASE 3.0 agenda:
The Ministry has the idea of establishing paperless and digitally enabled banking at places where people visit the most. The government aims to focus on digitalization in the Public Sector Banks (PSBs) among themes that include responsible banking, PSBs as Udyami Mitra, customer responsiveness, credit take-off, and deep financial inclusions.
EASE 3.0 — Smart, Tech-enabled Banking for Aspiring India

Over the last five years, PSBs have not only cleaned up legacy stress and addressed underlying systemic weaknesses but have emerged stronger as a result of comprehensive and institutionalized EASE reforms. EASE 3.0 sets the agenda and roadmap for FY21 for their transformation into digital and data-driven NextGen Banking of the Future for an aspiring India.
With EASE 1.0 and 2.0 laying a firm foundation of robust banking and institutionalised systems, PSBs are set to transform into digital- and data-driven NextGen banks. EASE 3.0 emphasizes on the use of digital, analytics & AI, FinTech partnerships across customer service, convenient banking, end-to-end digitalised processes for loan sourcing and processing, analytics-driven risk management as well as decision support systems for HR.

Key Reform Action Points in EASE 3.0 include:
  • Dial-a-loan: Digitally-enabled doorstep facilitation for initiation of retail and MSME loans. Customers will have the facility to register loan requests through digitally-enabled channels
  • Customer-need driven credit offers by larger PSBs to existing customers through analytics, e.g., for EMI on expenses like holidays/school-fees/jewellery/consumer durables, home loan takeovers, loan-against-property post home loan closure, working capital enhancement based on sales jump
  • Partnerships with FinTechs and E-commerce companies for customer-need driven credit offers
  • Credit@click: End-to-end digitalised, time-bound retail and MSME lending by larger PSBs, leveraging Account Aggregators, FinTechs and PSBloansin59minutes.com
  • Cash-flow-based MSME credit by larger PSBs, using FinTech, Account Aggregator and other third-party data and transactions-based underwriting models
  • Tech-enabled agriculture lending
  • Palm banking: End-to-end digitalised delivery of a full bouquet of financial services in regional languages and with industry-best service quality
  • EASE Banking Outlets: On-the-spot banking at frequently visited places such as train stations, bus stands, malls, hospitals, etc. through paperless and digitally-enabled banking outlets and kiosks

PSBs have already started taking steps based on the reforms agenda. During the event, several digitally enabled banking solutions, such as tablet-banking, digitally-driven agriculture lending, paperless and digitally-enabled EASE bank outlets, were demonstrated by the PSBs. Progress of PSBs will continue to be tracked on metrics linked to Reform Action Points, and their progress will be published through a quarterly index.
The goal is to continue driving change by spurring healthy competition among PSBs and also by encouraging them to learn from each other.
(Source: Press Information Bureau, Government of India, Ministry of Finance dt. 26-February-2020)

Monday, May 13, 2019

Haircuts: A way to address NPAs in banking system

What is a Haircut (in finance)?

In finance, a haircut refers to the reduction applied to the value of an asset for the purpose of calculating the capital requirement, margin, and collateral level. In other words, it is the difference between the amount of loan given and the market value of the asset to be used as collateral for the loan. The value reduction is expressed in the form of a percentage.
A haircut can also be referred to as the complement of the loan-to-value ratio (when added together, they make 100%). For example, when central banks lend money to commercial banks, the central bank asks for collateral. However, it will apply a haircut – a reduction in the value of the collateral. Let’s say, an asset worth $1 million at market price, given a haircut of 30%, would be sufficient to collateralize a loan of only $700,000. By devaluing the assets provided as collateral, the lender gets a cushion, a measure of risk protection to defend against market value drops.
The level of haircut is decided by the level of risk surrounding the loan. The level of risk includes all factors that may result in a fall in the market value of the collateral. Some variables that influence the amount of haircut include interest rate, creditworthiness, and the collateral’s liquidity.
Other definitions of a Haircut
A haircut can also be referred to as the difference between the buying and selling price of a stock share, bond, futures or options contract, or any other financial instrument. The difference is generally the handling fee for the transaction.
In common financial jargon, a haircut is also used to describe a financial loss on an investment. To “take a haircut” corresponds to accepting or receiving less than what was owed.

What is Collateral Haircut

A haircut refers to the lower-than-market value placed on an asset being used as collateral for a loan. The haircut is expressed as a percentage of the markdown between the two values. When they are used as collateral, securities are generally devalued, since a cushion is required by the lending parties in case the market value falls. When collateral is being pledged, the degree of the haircut is determined by the amount of associated risk to the lender. These risks include any variables that may affect the value of the collateral in the event that the lender has to sell the security due to a loan default by the borrower. Variables that may influence that amount of a haircut include price, volatility, credit quality of the asset's issuer (if applicable), and liquidity risks of the collateral.
 Factors that Determine the Haircut Amount
Generally speaking, price predictability and lower associated risks result in compressed haircuts, as the lender has a high degree of certainty that the full amount of the loan can be covered if the collateral must be liquidated. For example, 
Treasury bills are often used as collateral for overnight borrowing arrangements between government securities dealers, which are referred to as repurchase agreements (repos). In these arrangements, haircuts are negligible due to the high degree of certainty on the value, credit quality, and liquidity of the security.
Securities that are characterized by volatility and price uncertainty have larger haircuts when used as collateral. For example, an investor seeking to borrow funds from a brokerage by posting equity positions to a margin account as collateral can only borrow 50% of the value of the account due to the lack of price predictability, which is a haircut of 50%.
While a 50% haircut is standard for margin accounts, a risk-based haircut can be increased if the deposited securities pose liquidity or volatility risks. For example, the haircut on a portfolio of leveraged exchange-traded funds (ETFs), which are highly volatile, may be as high as 90%. Penny stocks, which pose potential price, volatility and liquidity risks, typically cannot be used as collateral in margin accounts.

Haircut Market Maker Spreads
A haircut is also sometimes referred to as the market maker's spread. Since market makers can transact with razor-thin spreads and low transaction costs they can take small slivers or haircuts of profits (or losses) constantly throughout the day.
With advances in technology and markets becoming more efficient, spreads in many assets have dropped to haircut levels.
Retail traders can transact at the same spreads market makers do, although retail traders costs are still higher which may make trading the spread ineffective. In a stock, both retail traders and market makers can buy and sell for a Rs0.01 spread in an active and liquid stock, but buying and selling 500 shares to make Rs5 (500 * Rs0.01) when each trade typically costs Rs5 to Rs10 (varies by broker) is not a profitable strategy for the retail trader.

Long-Term Capital Management's (LTCM) Failure and Collateral Haircuts Example
LTCM was a hedge fund started in 1993. By 1998 it had amassed massive losses, nearly resulting in a collapse of the financial system. The basis of LTCM's profit model, which worked very well for a while, was to suck up small profits from market inefficiencies. This is commonly called arbitrage. The firm used historical models to highlight opportunities and then deployed capital to profit from them.

Each opportunity typically only produced a small amount of profit, so the firm utilized leverage—or borrowed money—in order to increase the gains. The firm had Rs 5 billion in assets, yet controlled over Rs 1 trillion worth of positions.

Banks and other institutions allowed LTCM to borrow or leverage so much, with little collateral, mainly because they viewed the firm and their positions as non-risky. Ultimately, though, the firm's model failed to predict inefficiencies accurately, and those massively sized positions began to lose far more money than the firm actually had and more money than many of the banks and institutions that lent to them or allow them to purchase assets had.

The failure of LTCM, which required a 
bailout of the financial system, resulted in much higher haircut rules in terms of what can be posted as collateral, and how much the haircut has to be. LTCM had basically no haircuts, yet today an average investor buying regular stocks is subject to a 50% haircut when using those stocks as collateral against the amount borrowed on a margin trading account.

Market Maker Haircut Example
In many markets, the market maker's spread is the same as the retail trader's spread, although the trading costs for the retail trader makes trying to profit from a haircut spread ineffective.
One market where retail traders often cannot trade at the same spreads as the market makers is the forex market. This is because forex brokers often mark-up the spread, which is how they make money. In the EUR/USD forex pair the raw spread available to market makers is 0.00001, yet retail traders may be paying a spread of 0.00005 to 0.00015 (or even higher), a mark-up of five to 15 times the raw spread.
Forex brokers that provide raw spreads to their clients charge a commission on each trade. They make their money off of trading fees instead of marking-up the spread.
Haircut in Economy:
A haircut is the difference between the loan amount and the actual value of the asset used as collateral. It reflects the lender's perception of the risk of fall in the value of assets.
1. What are haircuts in the Indian banking system?
A haircut is the difference between the loan amount and the actual value of the asset used as collateral. It reflects the lender's perception of the risk of fall in the value of assets. But in the context of loan recoveries, it is the difference between the actual dues from a borrower and the amount he settles with the bank.

2. When do lenders opt for haircuts in India?Haircuts are not common in India. However, there have been instances in the past when a lender settles for some equity of a borrower to compensate for a loan loss.
But it is often a last re sort when there is absolutely no hope of a recovery and the loan is written off for a one time settlement. The regulators in the recent past have made many other options for banks like the corporate-debt restructuring or allowing sale of bad loans to asset reconstruction companies among others.

3. Why would lenders opt for such a route?
This is done because the lender gets at least some amount back instead of not getting any mon ey at all. Besides, the lender's provisioning liability comes down to the extent of the write-off, thus it ends up freeing capital in the process. Also, there is a regulatory pressure to clean up banks' balance sheets by March 2017.

4. Why would lenders avoid this option?
Experts say there is no single model to arrive at a haircut for a particular loan. Besides, lenders also fear that investigative agencies may get back at them for their judgement on a particular valuation of a haircut. For instance, there was one-time settlement of over Rs 6,000 crore for a Kingfisher loan of Rs 9,000 crore, which was not accepted by the investigators.

5. How does opting for a haircut impact a balance sheet?
By opting for an haircut in settling a loan, the entire loan is written off by the bank con and to that extent, the assets cerned and to that extent, the assets shrink. But if the loan is settled through a bond subscription of equity sale, the nature of assets changes. If there is a one-time cash settlement, it gets reflected in the profit-and-loss account. 

KEY TAKEAWAYS
  • A haircut is the lower-than-market-value placed on an asset when it is being used as collateral for a loan.
  • The size of the haircut is largely based on the risk of the underlying asset. Riskier assets receive larger haircuts.
  • A haircut also refers to the sliver or haircut-like spreads market makers can create or have access to.


Source: Economic Times, Investopedia article by Cory Michell,  &  https://corporatefinanceinstitute.com/resources/knowledge/finance/haircut/

Friday, April 19, 2019

The Regulatory Sandbox: Principles and Objectives

An Ideal FinTech Sandbox

What is Regulatory Sandbox?
• A regulatory sandbox is a regulatory approach,  typically summarized in writing and published, that allows live, time-bound testing of innovations under a regulator’s oversight. Novel financial products,technologies, and business models can be tested under a set of rules, supervision requirements, and appropriate safeguards.
• A sandbox creates a conducive and contained space where incumbents and challengers experiment with innovations at the edge or even outside of the existing innovations at the edge or even outside of the existing regulatory framework. 
• A regulatory sandbox brings the cost of innovation down, reduces barriers to entry, and allows regulators to collect important insights before deciding if further regulatory action is necessary. 
• A successful test may result in several outcomes, including full-fledged or tailored authorization of the innovation, changes in regulation, or a cease-and desist order.
• The first regulatory sandbox was launched in 2015 in the U.K. and generated great interest from regulators and innovators around the world. At the beginning of 2018, there were more than 20 jurisdictions actively implementing or exploring the concept. 
The Reserve Bank of India (RBI) set up an inter-regulatory Working Group (WG) in July 2016 to look into and report on the granular aspects of FinTech and its implications so as to review the regulatory framework and respond to the dynamics of the rapidly evolving FinTech scenario. FinTech stands for financial technology and describes technologically enabled financial innovations. 
The WG included representatives from RBI, SEBI, IRDA, PFRDA, NPCI, IDRBT, select banks and rating agencies.The report of the WG was released on February 08, 2018 for public comments. 

One of the key recommendations of the WG was to introduce an appropriate framework for a regulatory sandbox (RS) within a well-defined space and duration where the financial sector regulator will provide the requisite regulatory guidance, so as to increase efficiency, manage risks and create new opportunities for consumers.
The Reserve Bank of India released on 18th April 2019, the draft ‘Enabling Framework for Regulatory Sandbox’. Comments on the draft guidelines are invited from stakeholders by May 08, 2019. 
The Regulatory Sandbox: Principles and Objectives
The Regulatory Sandbox
A regulatory sandbox (RS) usually refers to live testing of new products or services in a controlled/test regulatory environment for which regulators may (or may not) permit certain regulatory relaxations for the limited purpose of the testing. The RS allows the regulator, the innovators, the financial service providers (as potential deployers of the technology) and the customers (as final users) to conduct field tests to collect evidence on the benefits and risks of new financial innovations, while carefully monitoring and containing their risks. It can provide a structured avenue for the regulator to engage with the ecosystem and to develop innovation-enabling or innovation-responsive regulations that facilitate delivery of relevant, low-cost financial products. The RS is potentially an important tool which enables more dynamic, evidence-based regulatory environments which learn from, and evolve with, emerging technologies.
Objectives
The RS provides an environment to innovative technology-led entities for limited-scale testing of a new product or service that may or may not involve some relaxation in a regulatory requirement before a wider-scale launch.
The RS is, at its core, a formal regulatory programme for market participants to test new products, services or business models with customers in a live environment, subject to certain safeguards and oversight.
The proposed financial service to be launched under the RS should include new or emerging technology, or use of existing technology in an innovative way and should address a problem, or bring benefits to consumers.
Regulatory Sandbox: Benefits
The setting up of an RS can bring several benefits, some of which are significant and are delineated below:
  1. The RS fosters ‘learning by doing’ on all sides. Regulators obtain first-hand empirical evidence on the benefits and risks of emerging technologies and their implications, enabling them to take a considered view on the regulatory changes or new regulations that may be needed to support useful innovation, while containing the attendant risks. Incumbent financial service providers, including banks, also improve their understanding of how new financial technologies might work, which helps them to appropriately integrate such new technologies with their business plans. Innovators and FinTech companies can improve their understanding of regulations that govern their offerings and shape their products accordingly. Finally, feedback from customers, as end users, educates both the regulator and the innovator as to what costs and benefits might accrue to customers from these innovations.
  2. Users of an RS can test the product’s viability without the need for a larger and more expensive roll-out. If the product appears to have the potential to be successful, the product might then be authorized and brought to the broader market more quickly. If any concerns arise, during the sandbox period, appropriate modifications can be made before the product is launched in the broader market.
  3. FinTechs provide solutions that can further financial inclusion in a significant way. The RS can go a long way in not only improving the pace of innovation and technology absorption but also in financial inclusion and in improving financial reach. Areas that can potentially get a thrust from the RS include microfinance, innovative small savings and micro-insurance products, remittances, mobile banking and other digital payments.
  4. By providing a structured and institutionalized environment for evidence-based regulatory decision-making, the dependence of the regulator on industry/stakeholder consultations only is correspondingly reduced.
  5. The RS could lead to better outcomes for consumers through an increased range of products and services, reduced costs and improved access to financial services.
Regulatory Sandbox: Risks and Limitations
1 Innovators may lose some flexibility and time in going through the RS process (but running the sandbox program in a time-bound manner at each of its stages can mitigate this risk).
2 Case-by-case bespoke authorizations and regulatory relaxations can involve time and discretional judgements (this risk may be addressed by handling applications in a transparent manner and following well-defined principles in decision-making).
3 The RBI or its RS cannot provide any legal waivers.
4 Post-sandbox testing, a successful experimenter may still require regulatory approvals before the product/services/technology can be permitted for wider application.
5 Regulators can potentially face some legal issues, such as those relating to consumer losses in case of failed experimentation or from competitors who are outside the RS, especially those whose applications have been/may be rejected. These, however, may not have much legal ground if the RS framework and processes are transparent and have clear entry and exit criteria. Upfront clarity that liability for customer or business risks shall devolve on the entity entering the RS will be important in this context.
Regulatory Sandbox: Eligibility Criteria for Participating in the Sandbox
The target applicants for entry to the RS are FinTech firms which meet the eligibility conditions prescribed for start-ups by the government.
The focus of the RS will be to encourage innovations where
  1. there is absence of governing regulations;
  2. there is a need to temporarily ease regulations for enabling the proposed innovation;
  3. the proposed innovation shows promise of easing/effecting delivery of financial services in a significant way.
Design Aspects of the Regulatory Sandbox
The RBI shall consider the following key design features for the RS:
Sandbox Cohorts and Product/Services/Technology
The RS may run a few cohorts (end-to-end sandbox process), with a limited number of entities in each cohort testing their products during a stipulated period. The RS shall be based on thematic cohorts focussing on financial inclusion, payments and lending, digital KYC, etc. The cohorts may run for varying time periods but should ordinarily be completed within six months.
An indicative list of innovative products/services/technology which could be considered for testing under RS are as follows.
1 Innovative Products/Services
  • Retail payments
  • Money transfer services
  • Marketplace lending
  • Digital KYC
  • Financial advisory services
  • Wealth management services
  • Digital identification services
  • Smart contracts
  • Financial inclusion products
  • Cyber security products
2 Innovative Technology
  • Mobile technology applications (payments, digital identity, etc.)
  • Data Analytics
  • Application Program Interface (APIs) services
  • Applications under block chain technologies
  • Artificial Intelligence and Machine Learning applications
2 Regulatory Requirements/Relaxations for Sandbox Applicant
The RBI may consider relaxing, if warranted, some of the regulatory requirements for sandbox applicants for the duration of the RS on a case-to-case basis. However, regulatory requirements that shall mandatorily have to be maintained by the applicants are as follows:
  • Customer privacy and data protection
  • Secure storage of and access to payment data of stakeholders
  • Security of transactions
  • KYC/AML/CFT requirements
  • Statutory restrictions
3 Exclusion from Sandbox Testing
The entities may not be suitable for RS if the proposed financial service is similar to those that are already being offered in India unless the applicants can show that either a different technology is being gainfully applied or the same technology is being applied in a more efficient and effective manner.
An indicative negative list of products/services/technology which may not be accepted for testing is as follows:
  • Credit registry
  • Credit information
  • Crypto currency/Crypto assets services
  • Trading/investing/settling in crypto assets
  • Initial Coin Offerings, etc.
  • Chain marketing services
  • Any product/services which have been banned by the regulators/Government of India

Number of FinTech Entities to be Part of a Cohort
The focus of the RS should be narrow in terms of areas of innovation, and limited in terms of intake. The RS shall begin the testing process with 10-12 selected entities through a comprehensive selection process as detailed in the framework under ‘Fit and Proper criteria for selection of participants in RS’.
Fit and Proper Criteria for Selection of Participants in RS
1 The entities should satisfy the following conditions:
  1. The entity should be a company incorporated and registered in India and shall meet the criteria of a start-up as per Govt. of India, DIPP Notification No. G.S.R. 364(E) dated April 11, 20181.
  2. The entity shall have a minimum net worth of Rs.50 lakh as per its latest audited balance sheet.
  3. The promoter(s)/director(s) of the entity are fit and proper as per the criteria enumerated in Annex I. A declaration and undertaking shall be obtained to this effect as per Annex II.
  4. The conduct of the bank accounts of the entity as well its promoters/directors should be satisfactory.
  5. A satisfactory CIBIL or equivalent credit score of the promoter(s)/director(s)/ entity is required.
  6. Applicants should demonstrate that their products/services are technologically ready for deployment in the broader market.
  7. The entity must demonstrate arrangements to ensure compliance with the existing regulations/laws on consumer data protection and privacy.
  8. There should be adequate safeguards built in its IT systems to ensure that it is protected against unauthorized access, alteration, destruction, disclosure or dissemination of records and data.
  9. The entity should have robust IT infrastructure and managerial resources. The IT systems used for end-to-end sandbox processing will be checked by the RBI to ensure end-to-end integrity of information processing by the entities concerned.
2 The proposed FinTech solution should highlight an existing gap in the financial ecosystem and the proposal should demonstrate how it would address the problem, or bring benefits to consumers or the industry or perform the same work more efficiently.
3 The applicants should demonstrate that there is a relevant regulatory barrier that prevents deployment of the product/service at scale, or a genuinely innovative and significantly important product/service/solution is proposed for which relevant regulation is necessary but absent.
4 The test scenarios and expected outcomes of the sandbox experimentation should be clearly defined, and the sandbox entity should report to the RBI on the test progress, based on an agreed schedule.
5 The appropriate boundary conditions (refer to section 6.7) should be clearly defined for the RS to be meaningfully executed while sufficiently protecting consumers’ privacy.
6 An acceptable exit and transition strategy should be clearly defined in the event that the proposed FinTech-driven financial service has to be discontinued, or can proceed to be deployed on a broader scale after exiting the RS.
7 The applicants shall be required to share the results of Proof of Concept (PoC)/testing of use cases including any relevant prior experiences before getting admission into RS for testing, wherever applicable.
8 Significant risks arising from the proposed FinTech solution or financial service should be assessed and mitigated.
Extending or Exiting the Sandbox
At the end of the sandbox period, the regulatory relaxations provided to the entities will expire and the sandbox entity must exit the RS. In the event that the sandbox entity requires an extension of the sandbox period, it should apply to the RBI at least one month before the expiration of the sandbox period and with valid reasons to support the application for extension. The decision of the RBI on the application will be final.
The sandbox testing will be discontinued any time at the discretion of the RBI if the entity does not achieve its intended purpose, based on the latest test scenarios, expected outcomes and schedule mutually agreed by the sandbox entity with the RBI. Further, the RS may also be discontinued if the entity is unable to fully comply with the relevant regulatory requirements and other conditions specified at any stage during the sandbox process. The sandbox entity may also exit from the RS at its own discretion by informing the RBI one week in advance. The sandbox entity should ensure that any existing obligation to its customers of the financial service under experimentation is fully addressed before exiting the RS or discontinuing the RS.
Boundary Conditions
When a sandbox operates in the production environment, it must have a well-defined space and duration for the proposed financial service to be launched, within which the consequences of failure can be contained. The appropriate boundary conditions should be clearly defined for the RS to be meaningfully executed while sufficiently protecting the interests of consumers. The boundary conditions for the RS may include the following:
  • Start and end date of the RS
  • Target customer type
  • Limit on the number of customers involved
  • Transaction ceilings or cash holding limits
  • Cap on customer losses
Ensure Transparency
Outreach with stakeholders and clear and adequate information to the participants in the RS is important. The RBI will communicate the entire RS process including its launch, theme of the cohort, and entry and exit criteria through its official website.
Consumer Protection
The sandbox participant will be required to ensure that any existing obligations to the customers of the financial service under experimentation is fulfilled or addressed before exiting or discontinuing the RS. It may be noted that entering the RS does not limit the entity’s liability towards its customers. The entities entering the RS must be upfront and, in a transparent way, notify test customers of potential risks and the available compensation and obtain their explicit consent in this regard.
The Sandbox Process and its Stages in a Regulatory Sandbox
End-to-End Sandbox Process
A detailed end-to-end sandbox process, including the testing of the products/innovations by FinTech entities, shall be overseen by the FinTech Unit (FTU) at the RBI.
The Sandbox Process: Stages and Timelines
Each cohort of the RS shall have the following five stages and timeline:
1 Preliminary Screening (4 weeks)
The FTU shall ensure that the applicant clearly understands the objective and principles of the sandbox and conforms to it. This phase shall last for 4 weeks from the launch of the sandbox, where the applications shall be received by the FTU and evaluated to shortlist applicants meeting the eligibility criteria.
2 Test Design (3 weeks)
This phase may last for 3 weeks. The FTU shall finalize the test design through an iterative engagement with the applicants and identify outcome metrics for evaluating evidence of benefits and risks.
3 Application Assessment (3 weeks)
This phase may last for 3 weeks. The FTU shall vet the test design and propose regulatory modifications, if any.
4 Testing (12 weeks)
This phase may last for a maximum of 12 weeks. The FTU shall generate empirical evidence to assess the tests by close monitoring.
5 Evaluation (4 weeks)
This phase may last for 4 weeks. The final outcome of the testing of products/services/technology as per the expected parameters including viability/acceptability under the RS shall be confirmed by the RBI. The FTU shall assess the outcome reports on the test and decide on whether the product/service is viable and acceptable under the RS.
Statutory and Legal Issues
  • Upon approval, the applicant becomes the entity responsible for operating in the RS. The RBI will provide the appropriate regulatory support by relaxing specific regulatory requirements (which the sandbox entity will otherwise be subject to), where necessary, for the duration of the RS. The RBI shall bear no liability arising from RS process and any liability arising from the experiment will be borne by the applicant as a sandbox entity.
  • Upon successful experimentation and on exiting the RS, the sandbox entity must fully comply with the relevant regulatory requirements. The applicant should clearly understand the objective and principles of the RS. It must be emphasized that the RS is not intended and cannot be used as a means to circumvent legal and regulatory requirements.
  • At the end of the sandbox period, the entity must exit the RS.


Disclosure
The RBI shall reserve the right to publish any relevant information about the RS applicants on its website, including for the purpose of knowledge transfer and collaboration with other international regulatory agencies.

RBI said that innovation and technologies around credit registry and information, cryptocurrency and assets, trading, ICO and chain marketing services may not be accepted as a part of the sandbox.

The RBI further added that the focus of the sandbox will be at innovations, which have an absence of governing regulations; a need to temporarily ease regulations for enabling the proposed innovation; or is expected to effect the delivery of financial services in a significant way.



Source: rbi.org.in, https://rbi.org.in/Scripts/BS_SpeechesView.aspx?Id=1071United Nations Secretary-General’sSpecial Advocate for Inclusive Finance for Development(UNSGSA), yourstory.com, &
https://www.pwc.in/consulting/financial-services/fintech/fintech-insights/the-sandbox-approach.html