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    BANCON 2013

    Two decades of credit

    management in banks:Looking back and moving ahead

    K.C. Chakrabarty

    Deputy Governor

    Reserve Bank of India

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    Introduction

    Business of banking is business of intermediation

    Credit risk is integral to banking business

    When banking was simple

    Lending decisions - made on impressionistic basis

    Credit risk managementstraightforward Information requirementsminimal

    As banking became diverse, complex,sophisticate

    Risks increased, became transmitive and contagious

    But, credit risk managementlagged behind

    And, information systemsremained primitive and didnot capture granular data correctly

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    Objectives Examine how Indian banks have dealt with credit risk

    over the last two decades

    Evolution of regulatory framework Analyse trends in asset quality of Indian banks

    Trends in gross and net NPAs

    Trends in slippages, write offs and recoveries

    Trends in restructuring Dwell on some facets that have a bearing on the asset

    quality of banks

    Risk management and primitive information systems

    GDP growth trends Size / segment analysis of impaired assets

    General governance and management structure

    Credit appraisal and monitoring standards

    Way forward for the regulators, policy makers, banksand bank customers

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    Evolution of NPA

    regulation in India

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    Prudential norms for NPAs 1985

    First-ever system of NPA classification - Health Code system

    Classification of advances into eight categories rangingfrom 1 (Satisfactory) to 8 (Bad and Doubtful Debts)

    1992

    Prudential norms on income recognition, asset classificationand provisioning introduced

    Restructuring guidelines introduced

    Assets, where the terms of the loan agreement regardinginterest and principal is renegotiated or rescheduled aftercommencement of production to be classified as sub-standard

    2001

    90 day norm for NPAs introduced (effective from March 31,2004)

    specified asset classification treatment of restructuredaccounts tightened

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    NPA trendsReflecting regulatory initiatives

    NPAs rose when prudential regulations introduced - reducedthereafter as regulatory initiatives facilitated improved credit risk

    management by banks Pace of introduction / tightening of regulatory reforms slowed after

    2001

    Regulatory norms were not further tightened during the good pre-crisisyears

    Reflected in poor credit standards and increased delinquencies

    Provisioning levels remained low for the Indian banking sector

    Norms with regard to floating provisions changed

    Provisioning coverage ratio was introduced but relaxed thereafter

    Dynamic provisioning coverage yet to be introduced

    Mere tweaking and flip flop approach to Prudential norms

    Restructuring increased as regulatory requirements were relaxed,especially in the post crisis years

    One time special dispensation for asset classification of restructuredaccounts provided to deal with the impact of the global financial crisis

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    Trends in asset quality

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    Trends in gross and net NPAs

    Early 1990s

    NPA ratios rose

    Immediate impact ofprudential norms

    Thereafter, the NPA ratiosdeclined

    Improved risk management

    Increased write offs

    Rising credit growth / robusteconomic growth

    Abundant liquidity conditions

    Increased restructuring

    In recent years, NPA ratioshave been rising, though onan average, the ratios are

    not higher

    Average NPA in % GNPA NNPAs

    1997-2001 12.8 8.4

    2001-2005 8.5 4.2

    2005-2009 3.1 1.2

    2009-2013 2.6 1.2

    Mar 2013 3.4 1.7

    Sep 2013 4.2 2.2

    0

    2

    4

    6

    810

    12

    14

    16

    Ma

    r-96

    Ma

    r-98

    Ma

    r-00

    Ma

    r-02

    Ma

    r-04

    Ma

    r-06

    Ma

    r-08

    Ma

    r-10

    Ma

    r-12

    Sep-13

    Percent

    Gross NPA ratio Net NPA ratio

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    Divergent bank group wise trends

    1996-2003 wide variation

    between NPA ratio of PSBsand other bank groups

    2003-06 - NPA ratios of allbank groups moved in

    tandem

    2007-09NPA ratios begin todecouple

    After 2009, gap betweenPSBs and other bank groupsstarted rising

    0

    2

    4

    6

    8

    10

    12

    14

    16

    All banks PSB OPB NPB FB

    AverageGNPAratioin%

    1997-2001 2001-2005

    2005-2009 2009-2013

    0

    2

    4

    6

    8

    10

    12

    14

    16

    18

    Mar-96

    Mar-98

    Mar-00

    Mar-02

    Mar-04

    Mar-06

    Mar-08

    Mar-10

    Mar-12

    Sep-13

    GNPAratioin%

    PSB OPB NPB FB

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    PSBsgrowing asset quality concerns

    PSBs share a disproportionate and increasingburden of NPAsespecially in recent years

    Share in

    total bank

    credit Mar-03

    Mar-07

    Mar-08

    Mar-09

    Mar-13

    Sep-13

    PSBs 74.0 72.8 72.5 75.2 76.2 75.3

    OPBs 6.2 4.7 4.5 4.3 4.6 5.0NPBs 12.8 16.2 16.4 15.0 14.8 14.7

    FBs 6.9 6.4 6.5 5.6 4.5 5.0

    Share in

    total bankGNPA M

    a

    r-03

    Ma

    r-07

    Ma

    r-08

    Ma

    r-09

    Ma

    r-13

    Sep-13

    PSBs 75.4 76.6 71.1 64.5 84.8 86.1

    OPBs 6.2 5.9 4.6 4.5 2.8 2.8

    NPBs 14.2 12.5 18.7 20.3 8.0 6.8

    FBs 4.2 4.9 5.6 10.7 4.3 4.3

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    Looking beyond the veil of headline numbers

    Gross and net NPAs numbers have limitations!

    In the 1990s, only data about gross and net NPAs wereavailable

    Subsequently, data on flow of NPAs (fresh accretions andrecoveries) collected, followed by data on restructuring,which allowed better understanding of the real problem ofcredit management in the banks

    A more detailed understanding of trends in asset quality ofbanks required collection and analysis of granular dataabout various aspects of NPA management viz. Slippages,Write offs and RecoveriesSegment wise and activity wise

    Such data has been collected only in recent years(since2009), largely due to regulatory impetus

    The current analysis is an attempt to examine trends in assetquality based on this detailed information

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    NPA movement over the last decade Increasing slippages and write offs since the crisis years

    New accretion to NPAs exceeds reduction in NPAs postcrisis

    All amount in

    (Rs crore)

    2001-2013 2001-2007 2007-2013

    NPAs at Beginning of

    the period

    60,434 60,434 50,513

    New Accretion to NPAs

    during the period

    624,772 159,072 465,700

    Reduction in NPAs

    during the period

    492,006 168,993 323,013

    Due to upgradation110,918 24,003 86,915

    Due to write-off 203,616 73,941 129,675

    Due to actual

    recovery

    177,473 71,049 106,424

    NPAs at End of the

    period

    193,200 50,513 193,200

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    Slippages Trends

    Slippagesbetter metric to assess creditmanagement

    Slippages & net slippages

    Showed a declining trend in the early 2000s;started rising since 2006-07

    0

    1

    2

    3

    4

    5

    6

    7

    8

    9

    10

    0

    1

    2

    3

    4

    5

    6

    Mar 03 Mar 04 Mar 05 Mar 06 Mar 07 Mar 08 Mar 09 Mar 10 Mar 11 Mar 12 Mar 13

    percent

    percent

    SlippageRatio Net Slippage Ratio Gross NPA Ratio (RHS)

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    Recovery efforts deteriorating

    Extent to which banks able to reduce NPAs throughrecovery efforts deteriorating

    evidenced by increasing ratio of slippages to recoveryand upgradation

    Average Slippage to

    (Recovery + Upgradation) Ratio

    Slippage to (Recovery +

    Upgradation) Ratio

    Mar-01 191.3

    Mar-02 279.0

    Mar-03 190.5

    Mar-04 167.1

    Mar-05 129.5

    Mar-06 125.4

    Mar-07 173.2Mar-08 205.2

    Mar-09 221.0

    Mar-10 264.1

    Mar-11 217.0

    Mar-12 255.9

    Mar-13 257.0

    PSB OPB NPB FB

    2001-13 191.1 191.3 452.8 438.6

    2001-07 211.3 179.6 376.6 350.6

    2007-13 220.6 202.7 418.7 430.3

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    Recovery & write offsassociated moral hazard Write offs contributing significantly in reduction in NPAs

    Reducing incentives to improve recovery efforts

    Slippages exceeding reduction in NPAs especially post crisis The trends indicate weaknesses in credit as well as recovery management

    Upgradation as

    % of reduction

    in NPAs

    Write off as % of

    reduction in

    NPAs

    Recovery as % of

    reduction in

    NPAs

    Mar-01 12.6 39.3 48.1

    Mar-02 12.0 49.4 38.7

    Mar-03 16.0 50.7 33.4

    Mar-04 12.3 48.3 39.4

    Mar-05 15.2 39.0 45.8

    Mar-06 15.2 40.2 44.6

    Mar-07 14.5 42.5 42.9Mar-08 17.4 40.7 41.8

    Mar-09 23.8 39.6 36.6

    Mar-10 21.3 50.2 28.4

    Mar-11 24.2 42.4 33.4

    Mar-12 31.7 33.4 34.9

    Mar-13 33.1 37.8 29.2

    Reduction as a % ofslippages

    2001-13 78.4

    2001-07 105.3

    2007-13 70.8

    Upgradation as a % of

    slippages

    2001-13 17.6

    2001-07 14.9

    2007-13 18.4

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    i i i

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    Divergent bank group wise trendsnet slippages

    Recovery performance also varied across banks

    as revealed by trends in net slippages

    Net

    Slippage

    Ratio

    All Banks PSB OPB NPB FB

    Mar-07 0.8 0.6 0.5 1.5 1.0

    Mar-08 0.9 0.7 0.5 1.8 1.6

    Mar-09 1.2 0.7 1.0 2.4 4.7

    Mar-10 1.3 1.2 1.1 1.5 3.9

    Mar-11 1.1 1.2 0.7 0.6 0.6

    Mar-12 1.5 1.8 0.6 0.5 1.5

    Mar-13 1.6 1.9 0.8 0.6 1.1

    Average net

    slippage ratio

    PSB OPB NPB FB

    2001-13 1.3 1.3 2.5 1.8

    2001-07 1.3 1.6 3.6 1.4

    2007-13 1.2 0.8 1.3 2.1

    Net slippage ratio is slippage ratio net of recoveries

    i i

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    Divergent bank group wise trendsslippages and fresh restructured accounts

    The bank group wise trends in slippages arefurther re-enforced when the trends inslippages and fresh restructuring areexamined

    All banks PSB OPB NPB FB

    Mar-09 5.1 5.2 5.2 3.9 6.8

    Mar-10 5.4 5.6 4.0 4.0 6.8

    Mar-11 2.9 3.2 2.7 1.5 2.3

    Mar-12 5.4 6.5 2.8 1.9 2.3

    Mar-13 5.9 7.1 3.4 1.8 1.8

    Slippages + fresh restructured ratio

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    Summing up

    Standards of credit and recovery administration isinefficient and poor as is reflected from the fact thatupgradation as a % of slippage is very lowonly lessthan 20 % of accounts have been upgraded

    Recoveries are very less- A major part of reduction is

    through write-off Even during 2001-07, recoveries and upgradation were

    not as good-things have considerably deterioratedthereafter

    Gross NPA in itself not a problem but in conjunctionwith restructured advances they have emerged as amajor issue

    d d

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    Restructured Accounts Trends Growth in restructured accounts

    mixed trend in early 2000s

    sharp uptick in 2008 / 2009 due to the one time regulatory dispensation

    Continued high growth rate thereafter

    -300

    30

    60

    90

    120

    150180

    01

    2

    3

    4

    5

    6

    7

    8

    9

    10

    Mar-03

    Mar-04

    Mar-05

    Mar-06

    Mar-07

    Mar-08

    Mar-09

    Mar-10

    Mar-11

    Mar-12

    Mar-13

    g

    rowthrateinpercent

    ratioinpercent

    Restructured standard advances ratio

    GNPA ratio

    Restructured standard advances growth rate (RHS)

    GNPA growth rate (RHS)

    R t t d A t U d Mi

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    Restructured Accounts Use and Misuse Forbearance a necessity, especially for viable accounts

    facing temporary difficulties

    But, increasing evidence of misuse of facility for ever-greening of problem accounts by banks Restructuring of unviable units

    Deserving & viable units especially for small borrowersget overlooked

    Promoters contribution to equity not ensured

    Restructuring increasingly used as a tool of NPA managementby banks

    All Banks

    (%)

    Mar-

    09

    Mar

    -10

    Mar-

    11

    Mar-

    12

    Mar

    -13

    GNPA

    Ratio2.4 2.5 2.3 2.9 3.4

    (GNPA +

    Rest. Std.

    Adv) to

    Total Adv.

    5.1 6.7 5.8 7.6 9.2

    (GNPA +

    Rest. Std.

    Adv) to Total

    Adv.

    Mar-

    09Mar-10 Mar-11 Mar-12 Mar-13

    PSBs 5.1 7.3 6.6 8.9 11.1

    OPBs 5.7 5.9 4.9 5.3 5.9

    NPBs 5.5 4.8 3.2 3.2 3.1

    FBs 5.0 4.7 2.7 2.8 3.1

    Di t b k i t d i

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    Divergent bank group wise trends inrestructuring and write -off

    Asset quality deteriorates further if restructured accounts and write

    offs are included, especially in the case of PSBs Banks which are more aggressive in identifying NPAs appear to be

    able to manage them better

    0

    20

    40

    60

    80

    100

    PSB OPB NPB FB

    percent

    Share of NPA, restructuring and write offs in total impaired assets - 2013

    Gross NPA Restructured Standard Advances Cumulative Write Off

    Impaired Assets ratio = (GNPA + Restructured Standard Advances +Cumulative write off) to (Total Advances +Cumulative write off)

    Impaired Assets ratio PSB OPB NPB FB

    Mar-09 6.8 6.8 6.6 6.5

    Mar-10 8.8 7.3 7.3 9.5Mar-11 8.1 6.1 5.5 7.2

    Mar-12 10.0 6.3 5.4 6.6

    Mar-13 12.1 6.8 5.3 6.4

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    Summing up..

    Only less then 10% of the total amount written off (including the

    Technical Write-off ) is recovered The amount of restructuring and writeoffs distorts inter-segment

    comparison of credit quality

    Technical writeoff creates moral hazard and creates a dent inoverall recovery efforts

    Banks should be given the freedom to decide whether the casesinvolve restructuring

    - where only the technical covenants of the loan or the date ofcommencement of commercial production might havechanged and the banks are convinced that the pay-offs from

    asset created will be sufficient to repay the loan

    - Cases where the reduction does not bring down the lendingrate below base rate should not be considered as concession

    I

    24

    S t i NPA T d

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    Segment wise NPA Trends Deterioration in asset quality highest for industries segment Though banks devote fewer resources to the administration

    of small credits vis--vis larger credits

    Within industries segment - deterioration driven by mediumand large enterprises (50% share in NPAs)

    0

    5

    10

    15

    20

    Agriculture Industries Services Retail Agriculture Industries Services Retail

    Gross NPA ratio Impaired Assets ratio

    percent

    Mar-09 Mar-13

    in % Mar-09 Mar-10 Mar-11 Mar-12 Mar-13

    Micro+Small 10.7 10.6 9.4 9.7 10.6

    Medium+Large 7.8 9.4 8.0 11.2 14.8

    Impaired Assets ratio

    I f t t fi i ifi tl ff t d

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    Infrastructure financesignificantly affected

    Infrastructure projects strainon banks

    regulatory, administrativeand legal constraints

    Banks took inadequatecognizance of the need forcontingency planning forlarge projects in theirappraisal

    absence or insufficiency ofuser charges

    Impaired Assets ratio

    In % Mar-09 Mar-13

    Mining 4.0 8.2

    Iron and Steel 9.3 16.9

    Textiles 16.7 21.3

    Infrastructure 5.0 18.0

    Real Estate 2.5 2.0

    L ti k t d t h i

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    Large ticket advancesgreater share inrestructured accounts

    Restructuringprovided primarily to large corporates

    medium and large accounts make up over 90 percent of restructured accounts

    larger ticket accounts hold major share in CDR

    in % Mar-09 Mar-10 Mar-11 Mar-12 Mar-13

    Share in total

    bank creditMicro+Small* 10.1 11.4 12.0 10.8 10.7

    Medium+Large 39.9 42.9 45.0 46.8 48.4

    Share in total

    bank NPA

    Micro+Small 16.1 20.4 21.1 17.5 17.2

    Medium+Large 23.8 28.7 27.5 37.7 48.8

    Share in total

    bank

    restructuring

    Micro+Small 12.2 7.7 7.7 4.3 3.4

    Medium+Large 77.4 69.6 71.1 83.0 90.8

    * The data for Medium & Large and Micro & Small pertains to Industries and services sectors.

    A t lit f Di t d L di

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    Asset quality worse for Directed LendingA myth

    General belief is that directed lending has contributed

    to rising NPAsGNPA ratio higher for priority sector than non-priority

    sectorHowever, considering restructured accounts and write

    offs, asset quality worse for the non-priority sector

    Priority sector Non Priority sector

    1

    3

    5

    7

    9

    11

    13

    GNPA Ratio (GNPA +restructured

    standardadvances) ratio

    Impaired assetsratio

    GNPA Ratio (GNPA +restructured

    standardadvances) ratio

    Impaired assetsratio

    Percent

    Mar-11 Mar-12 Mar-13

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    Study Conclusions & Other Issues :

    Why high NPA and such poorstate of Credit Management?

    P i iti I f ti S t

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    Primitive Information Systems

    Improvements in information systems were

    not coincident with increased size of assetportfolio, increasing complexities in creditmanagement

    Banks ability to manage the quality of theirasset portfolio remained weak given

    The lack of granular data on slippages, earlyindications of deterioration in asset quality,

    segment wise, trends, etc.Banks failed in identifying / arresting the early

    pre-crisis trendsfrom 2005-06 - in asset qualitydeterioration

    GDP slowdown leading to increased NPAs!

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    GDP slowdown leading to increased NPAs!

    Recent decline in asset quality coincided with

    deceleration in GDP growth

    2

    3

    4

    5

    6

    7

    8

    9

    10

    11

    12

    13

    14

    15

    -20

    -10

    0

    10

    20

    30

    40

    50

    Mar-96

    Mar-97

    Mar-98

    Mar-99

    Mar-00

    Mar-01

    Mar-02

    Mar-03

    Mar-04

    Mar-05

    Mar-06

    Mar-07

    Mar-08

    Mar-09

    Mar-10

    Mar-11

    Mar-12

    Mar-13

    percent

    percen

    t

    Real GDP growth rate (RHS) Gross Advances growth rate

    Gross NPAs growth rate Gross NPA ratio (RHS)

    Higher NPAs only a result of GDP slowdown?

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    Higher NPAs only a result of GDP slowdown?

    3

    4

    5

    6

    7

    8

    9

    10

    -15

    -5

    5

    15

    25

    35

    45

    55

    Mar-03

    Mar-04

    Mar-05

    Mar-06

    Mar-07

    Mar-08

    Mar-09

    Mar-10

    Mar-11

    Mar-12

    Mar-13

    percent

    percent

    Real GDP growth rate (RHS) Slippage growth rate GNPA growth rate

    Beginnings of deterioration in asset quality started ahead of

    slowdown in economic growth

    Growth rate of GNPAs started rising before the crisis even as

    the pace of slippages turned sharply positive in 2006-07

    Asset quality of PSBs Economic downturn

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    Asset quality of PSBsEconomic downturnor sub-optimal credit management?

    Recent increase in NPAs not reflected across all

    bank groups Though economic downturn faced by all banks

    Early threats to asset quality - swiftly and

    effectively managed by private sector andforeign banks

    PSBs suffer from structural deficiencies related tothe management and governance

    arrangements Reflected in lacunae in credit management

    Pre-dates the crisis, but not dealt with on time,unlike in the case of the FBs and NPBs

    L C dit M t

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    Lax Credit Management Deficiencies in credit

    management crept in during

    the pre-crisis goodyears In general, banks with high credit

    growth in 2004-08 ended up withhigher NPA growth in 2008-13

    The appraisal process failed todifferentiate between promoters

    debt and equity

    Promoters equity contributiondeclined / leverage higher

    Credit monitoring wasneglected

    Recovery efforts slowed

    Legal infrastructure forrecovery remained non-supportive

    Restructuring became rampantOPB

    NPB

    PSB

    FB

    -15

    -10

    -5

    0

    5

    10

    15

    20

    25

    30

    35

    40

    45

    50

    55

    60

    65

    10 15 20 25 30 35

    CAGRNP

    A2008-2013

    CAGR Advances 2003-2008

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    Increasing incidence of

    frauds, especially largevalue frauds in recent years

    Over 64 % of fraud cases areadvances relatedover70% in case of large valuefrauds (over Rs. 50 crore)

    Poor appraisal andabsence of equity has led tolarger no. of advancerelated frauds especiallythrough diversion

    Moral hazard associated

    with identifying businessfailures as frauds

    Lacunae in creditappraisal not identified

    Fixation of Staffaccountability a

    casualty

    Increasing fraudsor are they businessfailures?

    Advance Related Frauds (>Rs. 1cr)

    2010-11 2011-12 2012-13Cumulative(end Mar13)

    BankGroup

    No.Amt

    (in cr.)No.

    Amt

    (in

    cr.)

    No.

    Amt

    (in

    cr.)

    No.Amt

    (in cr.)

    PSBs 201 1820 228 2961 309 6078 1792 14577

    OPB 20 289 14 63 12 49 149 767

    NPB 18 234 12 75 24 67 363 1068

    FB 3 33 19 83 4 16 456 277

    Grand

    Total

    242 2376 273 3183 349 6212 2760 16690

    C dit i l ff d (1)

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    Credit appraisal suffered(1) Poor Credit appraisal at the time of sanctioning as also at the time of

    restruturing

    Significant increase in indebtedness of large business groups

    Sample of 10 large corporate groups - credit more than doubled between 2007 and2013 even while overall debt rose 6 times

    Credit growth concentrated in segments with higher level of impairment

    Lending elevated in several sectors where impairments were higher thanaverage

    0

    2

    4

    6

    8

    10

    12

    14

    0

    1000

    2000

    3000

    4000

    5000

    6000

    7000

    FY07 FY08 FY09 FY10 FY11 FY12 FY13

    percent

    Rsin

    billion

    Borrowings of 10 corporate groups

    Share in system credit (RHS)Source : Credit Suisse Research

    Sectors

    CAGR of

    credit

    2009-

    2012

    Impaired

    Assets ratio

    (March

    2013)

    Iron and Steel 25 17Infrastructure 33 18

    Power 41 18

    Telecom 28 16

    Aggregate

    banking sector 19 11

    Credit appraisal suffered (2)

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    Indian corporates - accessing international marketsto raise capital

    Risk from un-hedged exposures

    Risk from increase in interest rates

    Impact could spill-over to lenders

    Project risks not taken due cognizance ofContingency planning for large projects

    Restructuring extended to large corporates thatfaced problems of over-leverage and inadequateprofitability

    Companies with dwindling repayment capacity torepay debt - raising more and more debt from banks ability of corporates to service debt was falling

    exposure of companies to interest rate risk was rising

    Credit appraisal suffered(2)

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    Summing up..

    High credit growth in select sectors has led to decline incredit quality in subsequent periods

    High incidence of advance related frauds are anoutcome of deficient credit appraisal standards

    Level of Leverage of corporate borrowers, creditgrowth, diversion of funds, sub standard assets andfraud cases are highly correlated. They are first orderderivative of improper credit and recoverymanagement

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    Assessing the resilience of

    the banking system

    Resilience of the banking sector (1)

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    Resilience of the banking sector(1)

    Current NPA levels - not alarming though could poseconcern if current trends persist

    Year

    All Banks PSBsOld Pvt. Sec.

    Banks

    New Pvt. Sec

    BanksForeign Banks

    GNPA

    Ratio

    NNPA

    Ratio

    GNPA

    Ratio

    NNPA

    Ratio

    GNPA

    Ratio

    NNPA

    Ratio

    GNPA

    Ratio

    NNPA

    Ratio

    GNPA

    Ratio

    NNPA

    Ratio

    Mar 94 19.07 13.71 21.11 15.44 6.93 3.88 - - 1.46 -0.65

    Mar-95 15.31 10.46 17.12 11.98 7.35 4.12 2.21 0.93 1.62 -0.91

    Mar-97 14.33 9.50 16.44 11.15 8.29 4.66 2.92 2.51 3.57 1.02

    Mar-99 13.34 8.99 14.63 10.17 13.02 7.82 4.55 3.52 5.00 0.86

    Mar-01 11.14 6.28 11.99 6.97 11.86 6.71 5.40 3.21 6.69 1.72

    Mar-03 8.81 4.42 9.36 4.54 8.86 5.41 7.50 4.67 5.34 1.76

    Mar-05 4.94 1.96 5.38 2.07 5.97 2.72 2.93 1.53 3.01 0.87

    Resilience of the banking sector (2)

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    Stress testing reveals resilience of banking system due tostrong capital position

    June 2013 CRAR Core CRARGNPA

    Ratio

    Losses as % of

    Capital

    Baseline 13.4 9.7 4.0 -

    NPA increases by 50% 11.5 8.0 5.9 15.4

    NPA increases by 100%10.6 7.0 7.9 23.2

    NPA increases by 150%9.6 6.0 9.9 31.0

    30% of restructured advances

    turn into NPAs (Sub-Standard) 12.1 8.6 5.7 10.4

    30% of restructured advances

    written off (Loss) 11.2 7.6 5.7 18.2

    Resilience of the banking sector(2)

    Resilience of the banking sector (3)

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    Provision coverage ratios of Indian banks low byinternational standards declining in recent times

    2.0

    2.2

    2.4

    2.6

    2.83.0

    3.2

    40

    45

    50

    55

    Mar-09 Mar-10 Mar-11 Mar-12 Mar-13

    percent

    percent

    PCR GNPA ratio (RHS)

    Resilience of the banking sector(3)

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    Stressed Assets Provision Coverage Ratio

    Mar 2009 Mar 2010 Mar 2011 Mar 2012 Mar 2013

    PSBs38.47 29.61 34.29 30.00 27.71

    OPBs 33.16 35.40 41.58 33.31 31.11

    NPBs 38.91 42.64 63.25 55.52 53.73

    FBs 51.58 57.73 81.75 83.44 74.04

    All Banks 34.80 30.78 36.25 33.00 30.25

    Stressed Assets Provision Coverage Ratio defined as {(Total Provisions (excl. Provision for std adv) + Tech

    W/Os) to (GNPAs + Rest Std Adv + Tech W/Os)}

    Provision Coverage Ratio presents a dismal picture whenRestructured Standard Advances are also considered

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    Recommendations and way ahead

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    Recommendations and way ahead

    Short run

    Addressing the existing stock of impaired assetsNPAsand restructured

    Time bound revival or recovery

    Long run

    Robust risk management

    Improved information system

    Facilitating granular analysis of trends in asset quality

    Improved credit management

    Credit appraisal and monitoring

    Facilitative regulatory and legal infrastructure

    Short term: Review of NPAs / restructured

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    Short term: Review of NPAs / restructuredadvances

    Assess viability of NPA and restructured accounts oncase-to-case basis

    Pre-stipulated time-frame for review/ restructuring

    Accounts found viable

    Promoters to assume their share of losses - not resort to furtherborrowing for equity

    If need be bring new promoters

    Burden to be equally shared

    Restructuring of small accounts - Reorient restructuring towardssmall customersSMEs, priority sector

    Accounts found to be un-viable

    Put under time bound asset recovery

    banks takeover of units where promotersequity is low

    sale of assets to ARCs

    Improve credit risk management

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    Improve credit risk managementEnhanced Credit Appraisal

    Group Leverage, Source/ structure of equity capital

    Complex project structure (as in SPV) External constraintseffective contingency planning

    Keep a check on credit growth and linkage with equity

    Need for quicker decision making

    Appraisal, sanction, disbursement - timely and fast

    More compassion to smaller borrower and increased stringency forlarger borrowers

    Strengthen Credit Monitoring

    Comprehensive MIS and Early Warning Systems to facilitate regularviability assessment

    Enforce accountability

    Accountability on Individuals and all levels of hierarchy

    Accountability to encompass all aspects of credit management

    Accountability for delayed decision making / non-action

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    Regulatory framework

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    Regulatory framework

    Need to review the existing regulatory arrangements for

    asset classification and provisioningFacilitative and practical regulation

    Restructured accounts to be classified as NPAaligning

    domestic norms with global best practices

    The practice of technical write offs of NPAs to be

    dispensed with

    Increased provisioning requirements in line with

    international norms and to ensure resilience of the

    banking system

    Uniform approach to regulationeither principle or rule based

    For stability in credit risk management practices

    To eliminate ad-hoc implementation processes

    Reforming legal & institutional structures

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    Reforming legal & institutional structures

    Corporate Debt Restructuring (CDR) mechanism

    Remove existing bias towards large-ticket accounts

    Ensure viability and promotersstake upfront Independent oversight of large CDR account

    Debt Recovery Tribunals (DRTs) & other legal provisions

    Need for vigorous follow up in the case of suit filed accounts

    setting up of more DRTs and DRATs

    Asset Reconstruction Companies (ARCs)

    Review and revitalise functioning of ARCs

    Credit Information Companies (CICs)

    Expand use of CICs for credit management

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    Concluding

    Thoughts

    K M (1)

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    Key Messages ..(1)

    Present level of stressed asset as an outcome is not abig problem but present processes, systems and

    structure of creation of stressed assets are a bigproblem.

    Existing level of NPAs are manageable but if correctiveactions to arrest the slide in NPA are not initiated, the

    stability of financial system will be at great risk. Gross NPAs are not alarming but the quantum and

    growth of restructured assets is of great concern

    Economic slowdown and global meltdown are not theprimary reason for creation of stressed assets but thestate of credit and recovery administration in thesystem involving banks, borrowers, policy makers,regulators and legal system have contributedsignificantly to the present state of affairs.

    K M (2)

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    Key Messages .(2)

    Credit quality has a high positive correlation with the prudential

    norms and regulations prescribed by RBI Laxity, soft and flip-flop approach to regulatory and prudential

    norms have contributed significantly to creation of NPAs andstressed assets in the system

    Level of Leverage of corporate borrowers, credit growth,

    diversion of funds, sub standard assets and fraud cases arehighly correlated. They are first order derivative of impropercredit appraisal in determining appropriate structure of debtand equity both in terms of quantity and quality.

    Overall standard and quality of credit management andrecovery management is very poor.

    Less than 20% of NPAs are upgraded

    Reduction of NPAs is less than slippages

    About 50% reduction in NPA is through write-off

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    Key Messages .(3) Banks following the process of recognizing NPAs quickly

    and more aggressively are having better control overNPAs.

    Appraisal standards are lax for bigger loans both at thetime of sanction as also restructuring while appraisal rulesare very stringent for smaller borrowers

    Restructuring and write off processes are highly biasedtowards bigger loans as compared to smaller loans.

    Credit risk for small borrowers is lower than that for biggerborrowers

    Credit risk in priority sector is less than in the non-prioritysector

    High pace of credit growth has resulted in lower creditquality in subsequent periods

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    Measures .(1)

    Credit Appraisal needs to be strengthened with focus on:

    Quantum of equity brought in by the promoters Sources of Equity

    Contingency Planning in respect of infrastructureprojects

    Improve appraisal and approval process for restructuringproposals

    Benefits of restructuring to be also extended to smallerborrowers

    CDR Mechanism grossly misutilised and needs a thoroughoverhaul

    Need for an oversight structure for dealing withrestructuring of large ticket advances

    Independent body to oversee CDR mechanism

    M (2)

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    Measures ..(2)

    Restructuring and Technical Write-off as a prudentialmeasure should be eased out by the regulator

    Existing NPAs need careful examination for determiningrehabilitation or recovery

    Conduct viability study

    Quick rehabilitation with support from boththebank and the borrower

    Those who put spoke needs to be sufficiently dis-incentivized

    Bring new promoter if the existing promoter unableto bring new equity

    Restructuring decision should be left to the bank

    Quick and determined action is the need of the hour !

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    Thank you