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Showing posts with label RBI Guidelines. Show all posts
Showing posts with label RBI Guidelines. Show all posts

Wednesday, 9 July 2014

Authored article by Rajiv Janjanam, Vice President and Portfolio Head, SME & Retail Lending, Capri Global Capital Ltd.


What financiers do when funding an SME, and what they can do better


The micro, small and medium enterprises (MSMEs) are the backbone of economic development in any country and more so in India as we have a huge population to be served. They are the incubators for talent, innovation and entrepreneurial spirit, which is key to a country's development.

The Indian small & medium enterprises (SMEs) sector is considered as the backbone of the economy, contributing 45 per cent of the industrial output, 40 per cent of the country's total exports, employing 60 million people, creating 1.3 million jobs every year and producing more than 8,000 quality products for the domestic and international markets.

With approximately 30 million SMEs in India, around 12 million people are expected to join the workforce in the next 3 years with the sector growing at a rate of 8 per cent a year. Efficiently organized and innovative, MSMEs often exercise frugal management skills and use local resources to create innovative products and services which cater to any country's growing needs. However, in order to continue scaling up, timely and adequate access to financial services is an imperative, and this has been traditionally one of the biggest hurdles.

Funding Gap in MSMEs
For SMEs, obtaining and securing the right source of finance is a major challenge. Lack of available funding for SMEs has been brought into sharper focus post-credit crunch.

The total gap in MSME funding is estimated to be around $126 billion. Out of this, the debt gap is approximately $84 billion and equity gap is about $42 billion, while the total equity supply is only around $526 million. Many growth businesses are started by entrepreneurs, often with little experience of how to raise finance to fund his/her growth.

The major reasons for creation of this gap are information asymmetry which exists in Indian SMEs, the family-owned nature of Indian businesses, and lack of information regarding tapping the right kind and source of finance.

Funding Structure
Traditionally, private funds from friends and family form the single largest source of finance to MSMEs in India. MSMEs in India also rely heavily on private money lenders and the unorganized financial sector for their requirements, where the terms of financing are unclear and interest rates are high.

Banks have been making steady strides in order to bridge this gap. However, the approach followed by banks to funding is very restrictive as the bank has to create value by controlling and managing risk.

In any loan application for a business, a bank has to necessarily evaluate the risks involved, gauge collateral support and the methods to mitigate those risks. Therefore, it is not always possible for an entrepreneur to satisfy all requirements and conditions which the bank might pose. The above methods of financing are majorly debt financing, and sources of equity funding remain elusive in India.

Government Initiatives in MSME Funding
The government has always been cognizant of the funding gap which plagues Indian SMEs. In the 2012-13 Budget, the government announced an India Opportunity Fund of $878 million to support Indian SMEs. This entire amount will be routed to SIDBI and is divided into specific targeted sectors, which include:

Domestic MSMEs >> Internationalization of SMEs >> Sector Specific Funds -ICE, Traditional Sectors, Defense, Infrastructure >> IPO on SME Exchanges

Such initiatives would go a long way in bridging the financing gap and ensuring that India gets a steady flow of entrepreneurs in various fields.

Some simple guidelines to funding SMEs
It is imperative for the financing company to understand the needs of the MSMEs and the capability of them to repay the loans they take.

>> Very rarely does the intention issue come up with the MSMEs. They are the first generation entrepreneurs from each of their families and do not leave any stone unturned to make their venture a success.

>> MSMEs do not have the wherewithal or the money to develop much needed finance team within their organization and end up hiring on a part time basis a small time chartered accountant to look into their accounts. While this suffices their need, however, when it comes to borrowing from large financial institutions, NBFCs or private equity investors fall short of creating the necessary documentation. For a financing company this can perhaps be overcome by watching the SME at work in their offices or unit, gauging if their operations are genuine and then helping them raise their financial reporting standards.

>> Asking key questions and judging the mentality/attitude of the MSMEs and the passion will tell more than looking for non-existent financial documents. A lifestyle of MSE promoter/partners/teams tells a lot about their future.

>> These micro and small enterprises serve much larger enterprises in their processes through job works / parts manufacturing, process outsourcing, supply chain etc. Strength of the principle plays a vital role. For example, a micro enterprise that manufacturers nuts and bolts for Maruti Suzuki largely draws its past, present and future performance from the performance of Maruti Suzuki as a company. During the boom phase, almost all of the suppliers/small time manufacturers of parts grew at a rapid pace and expanded. Some even ventured to cater to different industries rather than be defined by auto industry.

>> Another key aspect which almost every financier observes these days is their performance on loans/lines taken in the past. Key to this is Credit Information Bureau of India Ltd (CIBIL). A lot of information is derived out of the CIBIL report and plays a key role in assessing future performance on loans given to MSEs.

>> With specific mention to the micro enterprises, there exists one other key issue which is the way they operate. For example, businesses typically run by a family with father as the proprietor and children being inducted into business subsequently. Presence of business / legal existence proof also comes up as a hindrance. In some cases, simple rules like submitting your Know Your Customer (KYC) form requiring at least two proofs are not met as these customers fall short as they usually hold only IT returns. We do need to understand these aspects and help in generating another proof. A simple way could be assisting in installation of a landline at customer's office whose bill would suffice as a second proof.

It goes a long way in understanding these customers and the challenges they face to able to fund them with right products at the right time and help them grow. Be with them on the ground and see what they see, it is that very easy to assist them. After all they are the priority sector, and we carry the responsibility to bring in the financial inclusion.


(The author is Vice President and Portfolio Head, SME & Retail Lending, Capri Global Capital Ltd).

Thursday, 3 April 2014

Views of Mr. Sunil Kapoor, Executive Director, Capri Global Capital Limited on RBI’s Monetary Policy

“In today’s RBI Monetary Policy no major policy changes have happened. Considering that Inflation specifically CPI has eased during last 2 months and the Current Account deficit has also shown significant improvement it was expected that RBI will not make any significant change in the policy rates specifically on the upward direction.


Going forward key monitoring factors will be, formation of new government, impact of el Niño on monsoon performance and the current account deficit. However the positive macro signals along with expected improvement in GDP growth due to clearance of significant infrastructure projects will help a lot. I expect that another few months of improvement in inflation, better GDP growth and stable monsoon will give RBI room to reduce the Policy rates and basis the current trends I don’t expect any further increase in policy rates in the next monetary policy.”

Tuesday, 24 September 2013

Views of Mr P. H. Ravikumar, Managing Director, Capri Global Capital Ltd on the Mid-Quarter Monetary Policy: September 2013 announced by RBI Governor Raghuram Rajan

Markets have reacted adversely to the surprise hike in the repo rate by the Governor of Reserve Bank of India in the Monetary Policy announcement today.

The Market expectations of status quo at the worst or a cut in repo rate in my view were clearly part of the euphoria generated from out of the positive developments on several fronts during the last few weeks post the assumption of charge by Mr. Raghuram Rajan as Governor of RBI.

However, the inflation statistics and the food inflation in particular should be of serious concern to all policy makers. I believe the new Governor is sending a strong signal to markets of his unhesitating ability to take unpopular decisions if such decisions are warranted by ground realities. The Governor has sent a strong message so early in his tenure to the market “don’t take me for granted”.

The deferment in withdrawal of quantitative easing by US has given Indian policy makers a breathing space of three months at the least and six months at the best. It is important that key policy decisions to insulate the economy (to the extent possible on final QE withdrawal by US must be taken quickly even if some of these decisions are not popular).

While the tight interest rate out look continues to be on cards in the short run definitely, Reserve Bank of India will need to address the issues of sufficient liquidity in markets given that the busy season is now round the corner. The management of the currency exchange rate is the other major issue which will have to be addressed. Allowing the Rupee to strengthen beyond current levels may not be actually in the interest of the overall economy in general and exporters in particular.

Tuesday, 30 July 2013

Real Estate Regulatory Bill

Real Estate Regulatory and Development Bill – Step in right direction, but just 1st hurdle cleared

Union Cabinet of India passes the Real Estate Regulatory and Development Bill which intends to project consumers of house space in the country by implementing best practices. The Bill proposes a regulator in each state / union territory which will address the industry issue and a tribunal for fasten the process of the disputes.

The bill would next be tabled in both the house of Parliament and then to standing committee before it becomes an Act. The Bill has just cleared the first hurdle and may take longer to be implemented at ground level.

Reasons for delay in project completion are addressed, but amending the ‘70% customer advance’ clause will lead to low uniformity

The Bill main intention is consumer protection in real estate space wherein project delay is major area of concern. The Bill addresses this concern by two proposed clauses – 1) the developer cannot launch a project before all approvals in place and 2) 70% & lower Customer advances, as stipulated by the state regulator, would be utilised only for development of project which is monetized. The second point here is been diluted from 70% to 70% & lower and also has given power to decide the share in the hands of state regulator. This amendment has diluted the effect of the point and would lead to higher red tapism in the sector.

The current Bill requires a lot of Clarity and doesn’t address many Loopholes in the proposals

The amended RE Bill has many points which needs clarifications or which has loopholes. Firstly, it doesn’t state that the state regulator will have to follow whose law when it comes to the State Bill and Centre’s Bill are at crossroads. The bill doesn’t provide clear demarcation in definition of a project and its phases as well as common amenities for assigning customer advances lock-in.

The bill implemented in the current form affects marginally to developers; lowering the churn of capital is the only concern

The current form of the Bill is diluted from the draft published in 2012. No pre-launches officially & registration of real estate agent would curb investor money in the sector when combined with 1% TDS clause introduced in Union Budget. But there are means to these issues which may lower the impact of the intent of the Bill. Hence, there would be some impact on the churn of capital as usage of customer advances would be restricted. Also, some cost of the company would increase in getting stipulated approvals from the state regulatory.

Interpretation of Key Clauses which may affect Real Estate Companies Clause Intent Current Practice Impact Clarity / Loophole

Clause:

A Real Estate Regulator in each state who will implement and address set regulations in that particular state

Intent:

To streamline best practices in the industry which is reeling under lot of issues pertaining to consumer

Current Practice
There is no single body who regulates the industry and its growing issues

Impact:

A lot of developers would have to streamline their operations to best of industry practices

Clarity/loophole:

Will the state regulator adhere to state level bill or this bill overwrites it

Clause:

The developer cannot launch the projects till all the approvals are in place and the project is registered with the regulator along with project plan

Intent:

To ensure timely completion of projects by making capital available

Current Practice:

A lot of developers would pre-launch the project and utilise the advance from sale towards getting approvals as well as other means

Impact:

The developer cannot do any pre-launch before getting project approvals and registering the same with the government authority. Hence they will have to deploy capital from other source then customer advances

Clarity/loophole:

The Company can always pre-launch and take advances and show it as short term debt. Later convert the same in customer advances at the time of launch. All the pre launches are done on understanding and trust between the parties

Clause:

Compulsory deposit 70% or lower funds received from allotees in a separate bank account. (The same was changed from 70% in 2012 bill to 70% or Lower in 2013 bill)

Intent:

To ensure timely completion of projects by making capital available

Current Practice:

A lot of projects completions are delayed because the developer utilise the customer advances for other means and assign approvals delayed as the reason.

Impact:

The developer cannot utilise the capital generated from one project, unless it is completed, to finance the capital requirement of other projects. This will lead to lower availability of the liquidity.

Clarity/loophole:

There is missing clarity on the definition of the project, as the industry phases out a single project. Can the developer utilise advances of phase 1 towards approvals of phase 2 and not deliver the common amenities, is not clear.

Clause:

Mandatory registration of real estate agents with the regulator

Intent:

To infuse professionalism in the intermediary role To curb money laundering

Current Practice:

With absence of any regulatory authority, there is no registration. Also, with no registration the agents launder the money through their account for a client.

Impact:

This clause along with TDS clause introduces in Union Budget 2013-14 will lead to curbing the transactions routed through multiple parties.

May curb investors from using RE as a medium for money laundering

Clarity/loophole:

The bill states the role of the agent but fails to address the repercussion of the falsification of information by him / her Also, there is no differentiation between a role of agent or a consumer played by the same person.

Charges for putting out misleading advertisements related to the projects carrying photographs of actual site.

Removed in 2013 Bill.  Was part of 2012 Bill

Written Agreement with the buyer needs to be registered before taking more than 10% of advances

Removed in 2013 Bill. Was part of 2012 Bill


Source: Emkay Research, Housing Ministry 

Tuesday, 18 June 2013

MSME schemes - Do you know all of them

How many Government schemes are currently in place to support our micro, small and medium enterprise sector? You may find this a little difficult to answer! Some of the schemes are widely known, but about many others information is not easily available. Here, I have prepared a list of various programmes, schemes and incentives offered by the MSME ministry, and request you to check whether you are aware of them or not.

As far as credit facilitation -- the biggest problem of our MSMEs -- is concerned, there are a number of schemes, including Credit Guarantee Fund Scheme for MSEs (CGMSE) that covers collateral free credit facility, Micro Finance Programme operated by SIDBI, Trade Related Entrepreneurship Assistance and Development (TREAD) Scheme for women, and Performance and Credit Rating Scheme under which MSMEs can get themselves rated by any of seven accredited agencies.

Similarly for skill development, there are a number of programmes, including Industrial Motivation Campaigns, Entrepreneurship Development Programmes (EDPs), Entrepreneurship Skill Development Programmes (ESDPs), Management Development Programmes (MDPs), Rajiv Gandhi Udyami Mitra Yojana (RGUMY), etc. In addition, a number of Tool Rooms & Technical Institutions and Technology Development Centres (Research Institutes) located across the country provide training and assistance to MSMEs.

To support small enterprises in marketing, the MSME ministry offers as many as five schemes, including International Co-operation Scheme, Market Development Assistance Scheme for MSEs (SSI-MDA) - Participation in Exhibition, Vendor Development Programme for Ancillarisation, WTO Export Programme (EP), and Public Procurement Policy for goods produced and services rendered by MSEs by the Central Ministries, Departments and PSUs.

On technology upgradation, there are two notable MSME schemes: Credit Linked Capital Subsidy Scheme and ISO 9001/ISO 1400/HACCP Certification Reimbursement Scheme. Under the first scheme, 15 percent upfront capital subsidy is provided on term loan for induction of improved technologies while the second one is designed to incentivize quality upgradation, improvement, environment management and food safety systems.

For enhancing manufacturing competitiveness, the Ministry offers a number of schemes including Lean Manufacturing Competitiveness Scheme and Design Clinic Scheme, Promotion of ICT Tools in MSME sector, Technology and Quality Up-gradation Support, Marketing Assistance and Technology Up-gradation Support, National Campaign for Building Awareness on IPR, Support for Entrepreneurial and Managerial Development of SMEs through Incubators, Encouraging Adoption of Bar Codes, etc.


So, there is no dearth of schemes -- close to 58 only from the Ministry of MSME, and and if we add to them those offered by NSIC, KVIC, and Coir Board, the list will get much longer-- but despite this, the sector has not achieved much from them. Beyond doubt, this is primarily due to the operational inefficiencies in our current system for small business support, and only a genuine root-and-branch reform in this direction could change the situation, but at the same time we think our lack of awareness is also responsible, at least to some extent.


Source: Money Matters India, www.money-matters.in

Friday, 14 June 2013

Securitisation and India

Securitisation is the financial practice of pooling various types of contractual debt such as residential mortgages, commercial mortgages, auto loans or credit card debt obligations and selling said consolidated debt as bonds, pass-through securities, or collateralized mortgage obligation (CMOs), to various investors. The principal and interest on the debt, underlying the security, is paid back to the various investors regularly. Securities backed by mortgage receivables are called mortgage-backed securities (MBS), while those backed by other types of receivables are asset-backed securities (ABS).

In India, securitisation has been for while now, the route to achieving the mandatory priority sector targets for banks both domestic and multinational. Securitisation as a market itself has evolved from being mere sale of portfolio from one organization to another to becoming complex structures in itself. This market has been in existence since the early 1990s, though has matured significantly only post-2000 with an established narrow band of investor community and regular issuers. In the early 1990s, securitisation was essentially a device of bilateral acquisitions of portfolios of finance companies. There were quasi-securitisations for sometime, where creation of any form of security was rare and the portfolios simply got transferred from the balance sheet of the originator to that of another entity. In recent years, loan sales have become common through the direct assignment route, which is structured using the true sale concept. Europe and United States has one of the most complex and developed securitisation market. India is still a small market where securitisation grew 15% over previous year in value terms. The number of transactions was also 32% higher in FY2012 than in the previous fiscal. The number and volume of retail loan securitisation (both ABS – Asset Backed Securitisation and RMBS – Residential Mortgage Backed Securitisation together), was the highest in FY2012 compared to previous fiscals, while the LSO (Securitisation of individual corporate loans or loan sell-off) issuance was the lowest ever. This in reality is an increase in volume—following a continuous decline for three years and was on account of a 26% rise in securitisation of retail loans.

In India, issuers have typically been private sector banks, foreign banks and non-banking financial companies (NBFCs) with their underlying assets being mostly retail and corporate loans.

The key objectives for Indian banks include:

·       Liquidity: Securitisation is an easy route than raising deposits that are subject to reserve requirements

·       Regulatory issues: Constrains arising out of Provisions, priority sector norms, etc.

·       Capital Relief: Major investors are mostly mutual funds (money market/liquid schemes), close-ended debt schemes and banks. Long term investors like insurance companies and provident funds are currently not active due to regulatory constraints. Foreign institutional investors are also missing due to regulatory ambiguity. As per guidelines, mutual funds are required to declare their NAV’s on a daily basis due to which they prefer the structure/asset classes which involve low pre-payment rates. The lack of domestic non-traditional hedge fund style investors to participate in equity and mezzanine tranches has led to originators holding them.

Some examples of securitisation in the Indian context are:

·       First securitisation deal in India between Citibank and GIC Mutual Fund in 1991 for Rs 160 mn

·       India’s first securitisation of personal loan by Citibank in 1999 for Rs 2,841 mn.

·       India’s largest securitisation deal by ICICI bank of Rs 19,299 mn in 2007. The underlying asset pool was auto loan receivables.

·       India’s first mortgage backed securities issue (MBS) of Rs 597 mn by NHB and HDFC in 2001.

·       Securitisation of aircraft receivables by Jet Airways for Rs 16,000 mn in 2001 through offshore SPV.

·       India’s first floating rate securitisation issuance by Citigroup of Rs 2,810 mn in 2003. The fixed rate auto loan receivables of Citibank and Citicorp Finance India included in the securitisation

·       India’s first securitisation of sovereign lease receivables by Indian Railway Finance Corporation (IRFC) of Rs 1,960 mn in 2005. The receivables consist of lease amounts payable by the ministry of railways to IRFC

·       L&T raised Rs 4,090 mn through the securitisation of future lease rentals to raise capital for its power plant in 1999.

An important change negating lot of banks from lending to NBFCs was what we observed in the ‘Master Circular by the RBI for Lending to Priority Sector’ released in July 2011, where loans by banks to NBFCs no longer qualify as Priority Sector Lending (PSL). With this change in regulation there was only one major way in which banks could meet their shortfall in priority sector lending targets, viz., acquisition of compliant portfolios from NBFCs. For the Originators’ (or NBFCs) motive in entering into these transactions was a pricing, capital relief and tenure-matched funding, apart from having an alternate fund-raising channel. This saw a neat rise in transactions involving bilateral assignment of retail loan pools of mainly including loans to Small and Medium Enterprises (SMEs) or Small Road Transport Operators (SRTOs) and micro credit.

These Bilateral assignments which account for around 75% of ABS and RMBS volume in India—continued to be the preferred route relative to conventional securitisation, given that these transactions were not covered by RBI’s guidelines of Feb 2006 on securitisation, thus making them less restrictive for originators.

That no longer is the case according to our internal estimates given that the RBI Guidelines on Securitisation issued in May 2012 that prohibit stipulation of credit enhancement for assignment transactions, thus exposing the purchasing banks to the entire credit risk on the assigned portfolio.

Priority Sector Lending targets however continue to exist and continue to get stricter and larger (MNCs with greater than 20 branches now are treated similar to domestic banks with 40% of their lending portfolio to be to the Priority Sector. And these could going forward be met at-least partly through the securitisation route, wherein credit enhancement is permitted.

Securitisation too is has its own deterrents which are high capital charge for Originators and impact of mark-to-market for the Investing Banks. Another key constraint presently is the ambiguity on the taxation of PTCs (or Pass Through Certificates), a matter which is presently sub-judice. Pending clarity on the issue, Mutual Funds—as well as several banks—are staying away from making fresh investments in PTC instruments. The microfinance industry saw 13% rise in deals involving sale of portfolio through securitisation and other bilateral transactions last financial year.

Last year, sailing through rough waters, the MFI industry managed to strike deals worth Rs 3700 crore (securitisation and direct assignments). This year, the industry is expected to have sold portfolios worth Rs 4,200 crore to banks and other financial institutions, according to data from MFIN (microfinance institutions network).

Additionally, RBI’s expected adoption of the proposals of the Nair committee on Priority Sector Lending (report submitted in February 2012) would be a key regulatory guideline which could further affect the securitization market in India.

We await further guidelines this year from the regulator – this will in addition to the changes in Priority Sector Norms affect the market in totality.