The biggest complaint of loan consumers in India who have taken loans on a floating rate has been that lenders are quick to raise rates for them when interest rates rise in the market but are very reluctant to reduce their interest rates when market interest rates drop. Till June 30, 2010 the floating rate products were priced with reference to their Benchmark Prime Lending Rate (BPLR). Clearly the BPLR system was not functioning in a transparent manner. After setting up a committee to examine the issue and a draft note inviting public suggestions the guidelines relating to the new “Base Rate” system have been made effective for all loans issued or renewed on or after July 1, 2010. So will this new Base Rate system be effective?

This article examines the difference between BPLR and Base Rate regime and the potential impact of the Base Rate system.

The rate is “to be computed taking into consideration (i) cost of funds; (ii) operational expenses; and (ii) a minimum margin to cover regulatory requirements of provisioning and capital charge, and profit margin”. No this RBI pronouncement is not about the Base Rate but about the Benchmark PLR. If you see the non-binding “illustrative methodology” for the Computation of the Base Rate in the guidelines, it also more or less lays out the same set of parameters but just in greater detail.

So if the calculation method is similar how will Base Rate system make a significant difference?

For starters there are two big differences. Whilst each bank can choose its own benchmark for the cost of funds they will have to document the detailed formula for the calculation of the “Base Rate” and the method of calculation and follow it consistently (except during a brief six month transition period). This formula will need to be disclosed to RBI, which can also scrutinize that it is being followed consistently. This is unlike the BPLR regime where the BPLR was supposed to take into account the same set of parameters but no documentation was required and it was not open to RBI scrutiny. This is a significant difference between the two regimes since this forces the banks to follow a consistent method of calculating the Base Rate unlike the BPLR.

The second big difference is that, unlike the BPLR, banks are not allowed to lend below the Base Rate (again there are a few exceptions but they are not very relevant for this purpose). Now we all know that blue chip corporates are always able to get good rates from the banks. They are likely to be borrowing at interest rates very close to the banks’ current Base Rates. When market interest rates fall they will naturally expect to get better rates and naturally the banks will be forced to drop their Base Rates if they still want to maintain their share of this market. So apart from the point mentioned in the first paragraph, this factor will also exert downward pressure on the Base Rate when market interest rates fall.

If the transparency is so built in then why the doubt on whether the Base Rate system will be effective or not? Clearly the Base rate system is designed to be more transparent than BPLR. But unfortunately there is no requirement that the detailed formula of each bank’s Base Rate be made public (it is only to be available for review and scrutiny by RBI). Clearly RBI will need to set up a machinery to monitor and review these calculations to ensure that they are consistent, which given their focus on ensuring transparency is likely to function as an effective check on the proper implementation of the Base Rate system. It would be very interesting to find out whether the general public under RTI can access a specific bank’s calculation of Base Rate that is available with RBI.

As is likely the effective functioning of the Base Rate regime will significantly change the retail lending industry in India. Firstly as changes in the effective interest rate for the customer will depend on the “average” cost of funds rather than the “marginal” cost of funds any increases in market rates will take time before they are fully passed on to the borrower (see box for difference between “average” and “marginal” cost of funds). Whilst this is beneficial when interest rates increase it is also not so bad when interest rates decrease as, unlike the current situation, the consumer is likely to get some decrease immediately compared to none or very little in the current scenario.

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Difference between average and marginal cost of funds

Assume a bank currently has funds of Rs. 100 crores at an average cost of 10% (total cost of funds is Rs. 10 crores or Rs. 2.50 crores per quarter). Now the cost of funds in the market goes up by 1% pa. On an arithmetic basis the banks cost of funds should go up by Rs. 1 crore per annum or Rs. 25 lacs per quarter. However since a lot of the bank’s funds are in time deposits which are at a fixed cost - where the cost will rise only when the deposit comes up for renewal - immediately its cost may go up by only say 12.50 lacs for this quarter or only 0.50% p.a. Of course over a period of time as all the fixed deposits mature and are renewed at new higher rates the cost of funds will go up to Rs. 11 crore per annum or 2.75 crores per quarter). Thus the average cost -10% in this example changing to 10.50% or a change of 0.50% only - will always change slower than the marginal cost - +1% in this example)

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If you have an existing loan should you shift to the new Base rate regime?

Firstly there is no automatic shift to the new regime. You will have to ask your bank to shift you to the new Base rate regime for which they are not supposed to charge you any fees. If you are on an existing fixed rate loans (or in the teaser period where rates are still fixed) where the rate is lower than the current floating rate of 8.50% - 9% than wait till you are on a floating rate basis for shifting to the new regime. If you are paying interest rate in double digits then shift to the new regime immediately. If your existing lender is not giving you good terms for the shift or is not acting fast enough to shift you to the new regime then you should seriously consider shifting to a new lender altogether)

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The National Housing Bank (NHB) which regulates the housing finance companies – HDFC, LIC Housing Finance, etc.- will also be forced to come out with a similar system for HFCs which will be good for the home loan consumers. Similarly the scheme will have to be extended to NBFCs also by RBI though that is likely to have a smaller impact on the loan consumers.

In any case the impact of this fundamental change will be felt only over a period of time – at least 6-12 months as interest rates change (likely to increase) during that period. Here’s hoping that this change has a fundamental impact on all loan consumers.

Just participated on a hour long TV show on a popular hindi business channel devoted entirely to CIBIL. The panel of experts included a retired PSU bank chief and a well known politician cum consumer activist from Mumbai. The anchor and the political panelist panned CIBIL for accepting any data that the banks/NBFCs provided to them (CIBIL) and branding consumers as  ”defaulters” on the basis of such wrong data. Suggestions were made on how CIBIL should seek confirmation from the customer before accepting any such data from the lenders. The retired PSU head also correctly suggested that CIBIL is only a reporting institution and that lenders can ignore the CIBIL report if they are satisfied with the consumers explanation of any default reported by CIBIL.   What he perhaps missed is that in retail lending the consumer does not get a chance to explain his side of the story.

I was almost ignored when i tried to get in a word that CIBIL keeps records of all your payments to lenders - whether on time or not -  as reported by lenders . I also pointed out that this ensures that for 90% of the consumers their good repayment track record (now provided by an independent reporting agency like CIBIL) ensures that they get fresh loans at a good rate and speed. This is how Credit bureaus work anywhere else in the world. Off course the banks there are under a legal obligation (Fair Credit Reporting Act in the US)  to report correct and accurate information. Obviously in a country where courts can award millions in punitive damages the banks do carry out their obligations seriously. The only role that a credit bureau plays is in making the credit reports available to the consumers themselves and allowing them to raise a dispute on any item. The disputed entries are referred to the concerned lender and the entry is deleted if the lender does not respond within a fixed time frame. Similiar provisions exist in Indian laws governing Credit Information companies such as CIBIL though such laws have just come in effect and will take time before they are implented on the ground.

Even on www.apnapaisa.com we receive about  10-20 queries daily purely on CIBIL related matters. The blogosphere is also full of how this new animal called “CIBIL” is affecting their financial lives without giving them a chance to provide their side of the story.

Thus CIBIL is fast acquiring a perception of a BIG brother hand in glove with the banks that is out to make the helpless consumer pay up monies that are not due from him.

Clearly therefore there is very little understanding of the role that a credit information company like CIBIL plays in the market. So what has led to this wrong perception in the market.

First off course is the operational inefficiency of the banks (see my blog on  can we trust our lenders http://blog.apnapaisa.com/2008/06/26/can-we-trust-our-lenders/) . Bank’s machinery to deal with consumer grievances is only now acquiring some shape and form under the threat of the banking ombudsman. This leads to many disputes in loan/credit cards and in quite a few cases the consumer is clearly right. Thus when the data provided by the banks itself is suspect any reporter of such data also comes in the circle of suspicion automatically. This has more to do with the banks then CIBIL itelf.

However the perception gets magnified when CIBIL does not take active steps to dispel the wrong perception. CIBIL identifies only the lenders as it’s clients (after all they pay the bills) and perhaps see the obligation  to supply the consumers own credit report to him as a  drain on its profitability. The fact that this report would have to be supplied has been known for the last 30 months and yet they did not put into place any mechanism to deal with it as soon as the license was issued. Even now (almost 2 months + after the license has been issued) CIBIL is yet to officially give a date by which this facility will finally be available to consumers. Niether is there any word on the interim measures to provide credit reports to at least those consumers who are immediately  affected by any alleged wrong reporting by the banks.

CIBIL (and the other 3 credit information companies that have also been provided a license) will need to factor in the consumers as a significant stakeholder in the whole credit reporting process if they have to change the perception about themselves as “only collection aides” for the bankers.

Clearly a robust credit reporting structure benefits the consumers immensely but a consumer education drive is needed so that it does not acquire a bad name.

Any views or comments are welcome.

It’s that time of the year again when wishes are horses (well almost). Imagination (and hope) runs high . Well here is my wishlist for Mr. Mukherjee.

http://www.apnaloan.com/prebudget-wishlist.html

A non-banking financial company (NBFC) is a company registered under the Companies Act, 1956 and is engaged in the business of loans and advances, acquisition of shares/stock/bonds/debentures/securities issued by government or local authority or other securities of like marketable nature, leasing, hire-purchase, insurance business, chit business, but does not include any institution whose principal business is that of agriculture activity, industrial activity, sale/purchase/construction of immovable property.

A non-banking institution which is a company and which has its principal business of receiving deposits under any scheme or arrangement or any other manner, or lending in any manner is also a non-banking financial company (residuary non-banking company).

Major difference between Banks & NBFCs

NBFCs are doing functions akin to that of banks; however there are a few differences:

• A NBFC cannot accept demand deposits (demand deposits are funds deposited at a depository institution that are payable on demand immediately or within a very short period like your current or savings accounts).
• It is not a part of the payment and settlement system and as such cannot issue cheque to its customers.
• Deposit insurance facility of DICGC is not available for NBFC depositors unlike in case of banks.

There are different types of NBFCs registered with the RBI:

• Equipment leasing company
• Hire-purchase Company
• Loan Company
• Investment Company

The important regulations relating to acceptance of deposits by NBFCs are as follows:

• The NBFCs are allowed to accept/renew public deposits for a minimum period of 12 months and maximum period of 60 months. They cannot accept deposits repayable on demand.
• NBFCs cannot offer interest rates higher than the ceiling rate prescribed by RBI from time to time. The present ceiling is 11 per cent per annum. The interest may be paid or compounded at rests not shorter than monthly rests.
• NBFCs cannot offer gifts/incentives or any other additional benefit to the depositors.
• NBFCs (except certain AFCs) should have minimum investment grade credit rating.
• The deposits with NBFCs are not insured.
• The repayment of deposits by NBFCs is not guaranteed by RBI.
• There are certain mandatory disclosures about the company in the Application Form issued by the company soliciting deposits.

Non-banking financial companies (NBFCs) have seen considerable business model shift over last decade because of regulatory environment and market dynamics.

In the early 2000s, the NBFC sector in our country was facing following problems:

• High cost of funds
• Slow industrial growth
• Stiff competition with NBFCs as well as with banking sector
• Small balance sheet size resulting in high cost of fund and low asset profile
• Non performing assets

A majority of NBFCs were not able to face the pressure created on and were wiped out. However, since FY2001-2002, there has been significant improvement in the business model of existing NBFCs with improvement in overall business environment. NBFCs have been able to expand their resource profile by diversifying the funding avenues. Further a strict control on asset quality and overheads, coupled with use of innovative borrowing tools such as securitization has resulted in improved profitability of NBFCs.

NBFC sector reports robust growth – 2008

The RBI increased the increased the capital adequacy requirement of non-deposit taking non-banking finance companies from 10 per cent to 12 per cent by 31 March 2009 and to 15 per cent by 31 March 2010.

For the quarter ended 30 June 2008, the NBFC sector reported a robust top line growth of 45.4 per cent and well converted it into a robust bottom line growth of 43.2 per cent. Net profit margin expanded by 110 basis points to 12.8 per cent.

August 2008, the sector yielded a minimal 0.4 per cent returns during July 2008, but witnessed a surge in volumes from 14.4 million shares in June to 20.1 million shares in July.

NBFC capital adequacy hiked

On 12 December 2006, the RBI had stated that all non–deposit taking NBFCs with an asset size of Rs.100 crores and more as per the last audited balance sheet would be considered as systemically important (NBFC-ND-SI).Thereafter, with effect from 1 April 2007, specific regulatory framework involving prescription of capital adequacy and exposure norms was put in place. NBFCs-ND-SI were advised to maintain a minimum Capital to Risk-Assets Ratio (CRAR) of 10 per cent with effect from 1 April 2007. The RBI increased the minimum capital to risk assets ratio (CRAR) for NBFCs-ND-SI from 10 per cent to 12 per cent to be achieved by 31 March 2009 and further 15 per cent to be achieved by 31 March 2010.

Sara Jain is Portfolio Manager at Ajmera Group of Companies.

Need to fulfill your short term cash needs? Personal loan is the solution. Personal loans are unsecured all purpose loans which can be taken by individuals to meet their short term cash needs. The quantum of personal loan is dependent on your income and repayment capacity. Personal loans usually have a high fixed interest rate with a fixed repayment period, you should always think of taking a personal loan as the last resort after you have utilized all other sources of cash.

Personal loans are available from Rs. 10,000 to Rs. 10 lakhs for any purpose depending on your requirement, you can utilize the money in any way you want to; there is no restriction on the end usage of the loan. Personal loans are given without any security, guarantor or collateral, resulting in a very simple, fast and quick approval process. The loan lifespan ranges from 1 year to 7 years.

The quantum and the interest rate of the personal loans depend on different factors:

1. Whether you are salaried or self employed
2. Your monthly income
3. Your employment stability
4. Total EMI payments towards your existing loans
5. Repayment track record of previous loans, if any
6. Your age
7. Your stability with the place of residence

The personal loan quantum and the rate of interest are totally dependent on your profile and the documents you provide for verification. After signing the loan documents, a demand draft or a cheque is drawn in your favour by the lender and you need to deposit post-dated cheques for the lifespan of the loan agreed by you.

Apart from the interest charged some other charges might be applicable. These charges can be charged at the time of disbursement of loan, during the lifespan of the loan, or when you terminate the loan. These charges include (a) processing charge (b) pre-payment fee (c) late payment charge (d) cheque bounce penalty (e) documentation charges (f) duplicate statement fees

Who can take a personal loan? Personal loans are provided only to resident individuals in India. Banks do check on your age minimum being 25 years and maximum being 65 years, your salary or income (if self employed), stability of profession and place of residence.

Before you proceed for a personal loan do ask few questions to yourself:

1. Is personal loan the right option? As stated above, personal loans are very expensive and you should only opt for this when there is no choice left with you and you are in need for short-term cash.
2. Is my loan lifespan appropriate? Do analyze your daily expenses, otherwise to repay early you might have to cut down your even your necessary expenses. The early repayment might not be the better option in that case.
3. Am I taking advantage of all the discounts I’m eligible for? Women get discount in many public sector banks, NBFC/Banks provide discounts to existing customers, do check on this and avail the discounts available and you are eligible to.
4. Have I chosen the right repayment schedule? There are options available for repayment of the loan, it can be larger payments at the beginning (upfront) or larger payments later in the lifespan of the loan.

You must choose a personal loan repayment period and schedule that matches your needs. Choose a shorter repayment period if you are expecting an inflow of cash in short run, this will help to meet your immediate cash needs and you will be able to repay the loan with less amount of interest.

Most banks and NBFC provide group life insurance as loan protector insurance. Purchasing this insurance ensures that the insurance company pays the lender in case you meet with an unfortunate incident. This protects your dependents from your liabilities.

A comparison of short term credit options:

Using the above table you can choose an option of a short term loan, with a view of repaying it as early as possible.