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JNANA VARDHINI SIBSTC MONTHLY NEWSLETTER -COVERING CONTEMPORARY BANKING RELATED TOPICS 9th Issue APRIL- 2011 SOUTHERN INDIA BANKS’ STAFF TRAINING COLLEGE No.531, Faiz Avenue, 11th Main, 32nd Cross IV Block, Jayanagar, BANGALORE-560 011 1 RBI MONETARY POLICY FOR 2011-12 ANNOUNCED ON 03.05.2011- HIGHLIGHTS 1. Global commodity prices may surge further over the course of the year indicating higher inflation. 2. The weighted average overnight call money rate will be the operating target of monetary policy of the RBI. 3. Henceforth, only the repo rate will be a varying policy rate to signal the monetary policy stance more accurately. 4. The Reverse repo rate will be pegged at a fixed 100 bps below the repo rate. 5. RBI will be instituting a new Marginal Standing Facility (MSF). Banks can borrow overnight from the MSF up to 1% of their respective net demand and time liabilities or NDTL. The rate of interest on amounts accessed from this facility will be 100 bps above the repo rate. 6. The repo rate has been increased by 50 bps. Accordingly, it goes up from 6.75% to 7.25%. 7. The reverse repo rate will stand adjusted at 6.25%. 8. The Marginal Standing Facility (MSF) rate will be 8.25% 9. The Bank Rate remains at 6.0%. 10. CRR remains unchanged at 6% of NDTL 11. SLR remains unchanged at 24% of NDTL. 12. Savings Deposit(SB) Interest Rate: Pending a final decision on deregulation on SB rate, the savings bank deposit interest rate is increased from the present 3.5% to 4.0% with immediate effect. 13. Indian Economy was estimated to have grown at 8.6% for 2010-11. The GDP Growth for 2011-12 is placed at around 8% 14. The projection for WPI inflation for March 2012 is 6% with an upward bias. 15. The Liquidity position is in the comfort zone of RBI. 2 16. Under Financial Inclusion to provide banking access to all villages with population of over 2000 by March 2012. There are 72,800 villages identified as falling into this category. RBI is asking banks to ensure that at least 25% of the new branches being opened during this year are located in tier 5 and tier 6 centers. 17. The Provisioning requirements on certain categories of NPAs and restructured advances will be enhanced. 18. The investment by banks in liquid schemes of debt oriented mutual funds will be subject to a prudential cap of 10% of their net worth as on March 31 of the previous year. CURRENCY WARS What is a ‘currency war’? It is a competition between nations to lower the value of their sovereign currency in order to give a boost to exports and the sagging domestic economy. Why there is a “currency war”? The world is witnessing an ongoing economic war, as every country wants to be economically developed, compete with other progressive countries in terms of trade and economic growth. Similarly there is an ongoing currency war in which nations compete with one another to lower the value of their domestic currency in order to help the home industries gain greater profits from exports. The currency war recently restarted following a conflict of interest between the United States and China. The U.S. has been struggling against a massive fiscal deficit and foreign debt in recent years, especially since the global financial crisis. With so much at stake, the era of U.S dollar hegemony seems to be ending. China has been raking in profits from its biggest export market, the U.S, by keeping its sovereign currency YUAN, also known as the renminbi, undervalued. China has also been purchasing U.S. treasury bonds to add to its foreign reserves, worth more than $2 trillion. In September, the U.S. House of Representatives passed the Currency Reform for Fair Trade Act. Under the bill, the U.S. is allowed to slap tariffs on goods from China and other countries whose currencies are perceived to be undervalued. Basically, it is U.S who is directly or indirectly pushing China to allow the YUAN to appreciate. 3 But China does not want the value of its currency to increase because a stronger Yuan will hurt Chinese exporters who will see a decline in exports to the U.S. once the value of home currency rises. As the recent currency war continues to spread around the globe, some countries are now saying that there is a need for a new Plaza Accord to stabilize the world economy and the global financial market and also the unbridled war for currencies and exchange rates. US vs CHINA - Whether the ongoing currency war- A cause for concern? Tensions have been rising over China’s Yuan policy ever since the US President depicted China as “currency manipulator,” during his earlier days in office. Western countries along with some emerging economies are of the view that China is deliberately manipulating Yuan’s value not allowing it to appreciate. They opine, China is following various means to keep Yuan value deliberately low, like buying dollars and other forex currencies, pegging it to the dollar etc. IMF also shares this view and called several times on China to allow Yuan to appreciate to correct global economic and trade imbalances. Lower Yuan value is making Chinese products more competitive in the global trade, due to which China is able to amass trade surplus in hundreds of billions of dollars, according to the developed economies. China disagrees with the west’s contention and says that it is not responsible for the problems faced by the Western countries. China says the developed countries have many problems created by them that require immediate attention. It is not fair for the west to attack Chinese Yuan Policy without reforming their financial regulatory laws, due to which the western states are not in a position to control the “too-big-to-fail” (or “too-important-to-fail” according to the IMF) financial conglomerates, China says. RBI - LIQUIDITY ADJUSTMENT FACILITY Background: In India, the forex reserves increased from US $ 54 billion as at the end of March 2002 to US $ 305 billion by April 2011. These forex flows have implications for the conduct of domestic monetary policy and exchange rate management. The liquidity impact of the inflows was managed by RBI mainly through the day-today Liquidity Adjustment Facility (LAF) and OMO. In addition, the measures taken to deal with these inflows included building up of government balances with the Reserve Bank particularly through Treasury Bills, forex swaps, prepayment of external debt, liberalization of current and capital outflows and measures to restrict debt inflows. These flows cannot be easily predicted due to 4 which the monetary authorities have to make choices for day-to-day exchange rate and monetary management. Intervention by Monetary Authority: When the monetary authority intervenes in the foreign exchange market through purchases of foreign exchange it injects liquidity into the system through the corresponding sales of domestic currency. Conversely, when it sells foreign exchange, the domestic liquidity is absorbed from the system. Such operations in the foreign exchange market cause unanticipated expansion or contraction of base money and money supply, which may not necessarily be consistent with the prevailing monetary policy stance. What is Sterilization? There are two approaches to offset the impact of forex inflows i.e. market based or non-market based. The market based approach involves financial transactions between the central bank and the market, which leads to withdrawal or injection of liquidity. The non-market based approach involves the use of quantitative barriers, rules or restrictions in market activity, which attempt to keep the potential injection of liquidity outside the domestic financial system. The market based approach aimed at neutralising part or whole of the monetary impact of foreign inflows is termed as sterilization. Conceptually the sterilisation process involves: Decision of the monetary authority to intervene by substituting foreign currency with domestic currency in case of excess capital inflows. Decision to intervene further in the bond or money market to substitute domestic currency so released out of the intervention in forex market with bonds or other eligible paper. While Open Market Operations (OMO) involving sale of securities constitute the commonly used instrument of sterilisation, there are several other instruments available to offset the impact of capital inflows on domestic money supply. Existing instruments for sterilization The appropriate mix of instruments would depend on the prevailing circumstances, the associated costs and benefits, and the opportunity cost of not using sterilisation as a policy option. While RBI can strengthen and refine the existing instrument (such as LAF, OMO, CRR etc), it can also explore new instruments appropriate in the Indian context. 5 Liquidity Adjustment Facility (LAF) LAF involves absorption or injection of liquidity by way of sale or purchase of securities followed by their repurchase or resale under the repo/reverse repo operations. Such operations have the added advantage that sale of securities does not require the financial system to take the market risk involved in such purchase of securities. Further, the access to this facility is at the discretion of market participants enabling them to undertake their own liquidity management. Thus, this facility has all the advantages of reserve maintenance without being an across-the-board mandatory requirement. In effect, the LAF has also effectively acted as an instrument of sterilisation. Operations under LAF require the availability of adequate stock of government securities with the Reserve Bank. These operations involve costs, which impact the balance sheet of the Reserve Bank. When the LAF is used as an instrument of sterilisation, it loses its character as a day-to-day liquidity adjustment tool operating at the margin. Open Market Operations (OMO) OMO involves the sale or purchase of securities with the objective of absorbing excess liquidity in the system through outright sale of securities or injecting liquidity by purchase of securities. It is the main instrument of sterilisation used by the RBI. RBI can make use of this instrument as and when necessary, but in view of the finite stock of government securities with RBI, such operations for sterilisation can obviously not continue indefinitely. OMO sales entail the permanent absorption of the liquidity. Balances of the Government of India with RBI The surplus balances of the Government with the RBI effectively act as an instrument of sterilisation. As the RBI Act does not permit payments of interest on Government balances, these balances are invested in government securities held in the portfolio of RBI, thus enabling Govt. to obtain a return on such balances. As a consequence, the stock of government securities to that extent becomes unavailable for monetary management operations like LAF and OMO. Forex Swaps Some central banks use foreign exchange swaps for sterilisation as it helps postponement of creation of liquidity generated by capital inflows and the consequent accretion to reserves. The cost of such swaps gets reflected in the premium paid by the central bank and the earnings on the foreign exchange reserves foregone. The extent to which such swaps can be undertaken depends on the depth of the forex market. Such operations could result in pressure on the market to meet deliveries. Further the cost of swaps can increase with the appreciation of the Rupee. 6 Cash Reserve Requirements (CRR) The use of CRR as a direct method of monetary policy intervention has the ability of sterilising liquidity by raising the proportion of NDTLs of banks to be kept impounded with the RBI. It is an inflexible instrument of monetary policy that drains liquidity across the board without distinguishing between banks having idle cash balances from those that are deficient. In case, CRR is not remunerated, it has the distortionary impact of a “tax” on the banking system. New Instruments Issuance of Reserve Bank Securities In the context of a declining stock of government securities with RBI to conduct sterilisation operations, issuances of securities by RBI could be enabled to facilitate OMO. A number of central banks in emerging market economies have resorted to issuance of central bank paper to facilitate sterilisation. Issuance of central bank securities can fragment the debt market due to availability of two competing sovereign issues, one of the Government of India and the other of RBI. Normally central banks issue securities at the short end of the maturity spectrum, on the premise that the capital inflows are transient and may reverse over a short period; in the event of reversal, liquidity could be matched by the maturing central bank paper. Market Stabilization Bills / Bonds by Government In view of the finite stock of government securities available with RBI for sterilisation, Govt. could issue a special variety of bills/bonds for sterilisation purposes. To operationalise such a new instrument of sterilisation and ensure fiscal transparency, the Government could consider setting up a Market Stabilisation Fund (MSF) to be created in the Public Account. This Fund could issue new instruments called Market Stabilisation Bills/Bonds (MSBs) for mopping up enduring surplus liquidity from the system over and above the amount that could be absorbed under the day to day repo operations of LAF. To impart liquidity to these bills/bonds, they may be raised through auctions and permitted to be actively traded in the secondary market. The amounts raised would be credited to the Market Stabilisation Fund. 7 INFRASTRUCTURE FINANCING BY BANKS Article Published in IBA’s Monthly Journal “The Indian Banker” for the Month of April 2011. (Authors of the Article: Sri. K L S N Rao, Principal, Southern India Banks’ Staff Training College & Sri. S. Murali, Director of a Training & Consulting organization) Definition: Infrastructure is generally defined as the physical framework of facilities through which goods and services are provided to the public. Infrastructure covers wide spectrum of services and transportation. The development of infrastructure is the sine qua non to the development of an economy. It is well understood that the responsibility of infrastructure development in the country is of the Government. Infrastructure development involves huge resources (finance and time). Due to restrictions self imposed by the country in minimizing the deficit financing under Fiscal Responsibility and Budget Management (FRBM), and also prioritizations of various other developmental functions, government alone will not be in a position to take up huge projects involving very high costs due to paucity of funds. Given these glitches, Public Private Partnership (PPP) is found to be a viable model for funding and development of huge infrastructure projects. This article deals with the role of banks in Infrastructure Financing and the key issues involved. Definition of ‘Infrastructure” Reserve Bank of India has defined “Infrastructure” to cover projects in the following areas: Developing, operating and maintaining or developing, operating and maintaining any infrastructure facility that is a project in any of the following sectors, or any infrastructure facility of a similar nature: A road, including toll road, a bridge or a rail system A highway project including other activities being an integral part of the highway project A port, airport, inland waterway or inland port A water supply project, irrigation project, water treatment system, sanitation and sewerage system or solid waste management system 8 Telecommunication services whether basic or cellular, including radio paging, domestic satellite service (i.e., a satellite owned and operated by an Indian company for providing telecommunication service), Telecom Towers, network of trunking, broadband network and internet services An industrial park or special economic zone Generation or generation and distribution of power including power projects based on all the renewable energy sources such as wind, biomass, small hydro, solar, etc. Transmission or distribution of power by laying a network of new transmission or distribution lines. Projects involving agro-processing and supply of inputs to agriculture Projects for preservation and storage of processed agro-products, perishable goods such as fruits, vegetables and flowers including testing facilities for quality Educational institutions and hospitals. Laying down and / or maintenance of pipelines for gas, crude oil, petroleum, minerals including city gas distribution networks. Any other infrastructure facility of similar nature. Why Infrastructure is Important: Its linkages to the economy are multiple and complex, because it affects production and consumption directly. The availability of adequate infrastructure facilities is a necessity for overall economic development of a country. Infrastructure facilities are often referred to as wheels of growth or engines of growth. Infrastructure is the key for growth of all the sectors of the economy with multiplier effect leading to overall growth in GDP & economic stability On account of India’s improved importance for infrastructure development, GDP is consistently growing since nineties. Achieved a GDP growth of 7.4% for 2009-10 despite continued global recession and aims to achieve 8.5% for 2010-11. India aims to achieve double digit GDP growth and attain the status of financial superpower by 2020. How much of investments required for infrastructure development? Developing nations need to make massive investments of 5% of GDP per year and this will continue to increase substantially over a period of time because of demand created by economic growth, rising population, rapid urbanization, and so on. 9 The 11th Five year plan (2007-12) envisages allocation of 9% of GDP i.e an amount of Rs 20, 56,151 crore for infrastructure development. Of the massive investment, 30% is expected to be financed by private sector. In 12th Five year plan, the investment estimated is US $ 1 Trillion What Constitutes ‘Infrastructure Lending’? As per RBI guidelines, any credit facility in whatever form extended by lenders (i.e. banks, FIs or NBFCs) to an infrastructure facility falls within the definition of “infrastructure lending”. In other words, a credit facility provided to a borrower company engaged in developing or operating and maintaining, or developing, operating and maintaining any infrastructure facility that is a project in any of the above sectors. What is Public Private Partnership? PPP or P3 is a government service or private business venture which is funded and operated through a partnership of government and one or more private sector companies. PPP involves a contract between a public-sector authority and a private party, in which the private party provides a public service or project and assumes substantial financial, technical and operational risk in the project. In some types of PPP, the cost of using the service is borne exclusively by the users of the service and not by the taxpayer. A PPP Project means a project based on a contract or concession agreement, between a Government or a statutory entity on the one side and a Private Sector Company on the other-side, for investing in construction and maintenance of infrastructure asset and / or delivering an infrastructure service. Why PPP? Lack of adequate funds with Government for development of infrastructure Infusion of Professionalism Risk sharing by Private Partners High Quality Service provided to the Government by the Private, for a long period Faster development of the infrastructure thereby higher growth of the economy as a whole 10 Key success factors for PPP As per the National Council for Public Private Partnerships the following six factors are vital for the success of the Project: 1. Political Leadership 2. Public Sector involvement 3. A well thought out plan 4. A dedicated income stream 5. Communication with all stake holders 6. Selection of the right partner PPP Process – Project Delivery Lifecycle 1. Opportunity Identification 2. Opportunity Assessment 3. Tender Preparation 4. Partner Selection 5. Contracting 6. Project Realisation 7. Performance Monitoring 8. Project Conclusion Various Models of PPP Build-Operate-Transfer (BOT) Under this model, the private partner builds a facility to the specifications agreed to by the public agency, operates the facility for a specified time period ( concession period) under a contract and then transfers the facility to the government at the end of the specified period of time. During the operation period, the private partner is authorized to collect a user charge which forms the basis for bank loan recovery. This is predominantly used in Road projects. 11 Build-Own-Operate (BOO) Here, the private partner builds and operates the facility without transferring the ownership to the government. There will be no obligation on the part of the government to purchase the facility or to get the title transferred to its name. This is applicable for Power and Telecom projects. Build-Own-Operate- Transfer (BOOT) Similar to BOO except that at the end of the contracted period, the facility will be transferred to Government. This model used in roads and ports. Buy-Build-Operate (BBO) A BBO is a form of asset sale that includes a rehabilitation or expansion of an existing facility. The government sells the asset to the private sector entity, which then makes the improvements necessary to operate the facility in a profitable manner. Build – Operate – Lease – Transfer (BOLT) The Infrastructure Asset is leased to the Govt. upto a specific period for a fixed rent and after completion of the fixed period; the private sector entity transfers the ownership to the Govt. Applicable under “Own your Wagon” scheme of Indian Railways Build – Own – Operate – Share – Transfer (BOOST) This is applicable in development of Ports. Contract Services Operations and Maintenance Here the government enters into a contract with a private partner to provide and/or maintain a specific service. Under this model, the government retains ownership and overall management of the public facility or system. Design-Build (DB) Here, the private partner provides design and constructs the project. This model helps in the reduction of time, save money and transfer risk to the private partner. The government owns the assets and has the responsibility for the operation and maintenance. Design-Build-Maintain (DBM) A DBM is similar to a DB except the maintenance of the facility for some period of time becomes the responsibility of the private sector partner. The benefits are similar to the 12 DB with maintenance risk also being transferred to the private sector partner. The government owns and operates the assets. Lease/Develop/Operate (LDO) or Build/Develop/Operate (BDO) Under these arrangements, the private party leases or buys an existing facility from a public agency; invests its own capital to renovate, modernize, and/or expand the facility; and then operates it under a contract with the public agency. This model is used in development of air ports. Sale/Leaseback This is a financial arrangement in which the owner of a facility sells it to another entity, and subsequently leases it back from the new owner. An innovative application of the sale/leaseback technique is the sale of a public facility to a private party for the purposes of limiting governmental liability under certain statues. Under this arrangement, the government that sold the facility leases it back and continues to operate it. Turnkey Under this model, the government contracts with a private partner to design and build a complete facility in accordance with specified performance standards. The private partner commits to build the facility for a fixed price and absorbs the construction risk of meeting that price commitment. In a turnkey transaction, financing and ownership of the facility can rest with either the public or private partner. Why Banks have started financing Infrastructure Projects? All India Term Lending Institutions like IDBI, ICICI converting themselves into Commercial banks, thus exclusivity is lost and other commercial banks entered the field. Source of funds with Infrastructure NBFCs such as PFC, NPC, IRFC, IL&FS, etc, alone were inadequate to meet huge funds demand for this vital sector. Govt with a view to achieve greater economic progress with good speed. floated multiple infrastructure projects simultaneously, calling for huge funds requirement. Commencing from mid 90s, on account of economic liberalization and financial disintermediation, liquidity in the banking system for most part of the last 15 years is highly comfortable, driving the banks to scout for lending options for long time. 13 With infrastructure assuming economic prominence, big industrial houses had set up huge infrastructure development companies and banks found it convenient to fund such large industrial houses. Compared to manufacturing sector, the demand for bank credit from infrastructure projects was huge and banks encashed upon this opportunity. Income Tax benefits to the banks under Sec 10(23G) of IT Act (withdrawn vide Finance Bill 2005), i.e. Interest earned by the banks on lending to infrastructure was exempted from payment of Income Tax. Commencing from late 90s, banks have set up robust ALM process, through which the Liquidity and Interest rate risk is effectively addressed. This has provided the necessary comfort to the banks to lend aggressively to this sector not minding the long tenure of the loan. With the sector blooming, Loan Syndication emerged as the best mode for infrastructure funding. This has driven the banks to set up Merchant Banking Division (like SBI Caps, etc,) to organize Loan Syndication and earn huge commission for the same and thus boost the fee based income substantially. Banks exposure to infrastructure lending has grown four fold since March 2005 from 6% to 9.25% of bank credit in March 2009. RBI Guidelines: Criteria for financing an Infrastructure Project. Banks/FIs are free to finance technically feasible, financially viable and bankable projects undertaken by both public sector and private sector undertakings subject to the following conditions: (i) The amount sanctioned should be within the overall ceiling of the prudential exposure norms prescribed by RBI for infrastructure financing (20% of the Bank’s Capital funds to individuals and 50% in the case of finance to a group). (ii) Banks/ FIs should have the requisite expertise for appraising technical feasibility, financial viability and bankability of projects, with particular reference to the risk analysis and sensitivity analysis. (iii) In respect of projects undertaken by public sector units, term loans may be sanctioned only for corporate entities (i.e. public sector undertakings registered under Companies Act or a Corporation established under the relevant statute). Further, such term loans should not be in lieu of or to substitute budgetary resources envisaged for the project. It should be ensured by banks that these loans/investments are not used for financing the budget of 14 the State Governments. Banks should undertake due diligence on the viability and bankability of such projects to ensure that revenue stream from the project is sufficient to take care of the debt servicing obligations and that the repayment/servicing of debt is not out of budgetary resources. What type of facilities provided by banks for Infrastructure Projects? Normally, banks provide long term loans with the tenor ranging from 7 to 12 or 15 years. Banks also provide non fund based facilities like Guarantees for participation in the bidding as also for performance of the contract and LCs for purchase / import of machinery. Where projects are completed and the same is in commercial operations, Working capital facility both fund based and non fund based is provided. Banks may also lend money for acquisition of the promoter's shares in an existing company, which is engaged in implementing or operating an infrastructure project in India subject to certain conditions. Key Issues in Bank Financing: 01 Long Tenor of the Loan & ALM Mismatches: Considering the prevailing interest rate volatility in Deposit rates, most of the bank deposits (around 90%) are short term in nature with a maturity profile of 2 to 3 years. Therefore, lending long creates a huge maturity mismatch and presents a big challenge to ALCO of banks for effective and acceptable presentation to the stake holders, in management of Interest rate risk and Liquidity risk. 02 Reliability of Future Cash Flows of the Project for Repayment. The typical of a project loan, more precisely an infrastructure lending is that, it is a Cash flow based lending and NOT Balance Sheet based lending. This essentially leads to dependency only on the cash flows of the specific project for repayment of a project loan. To some extent, future cash flows arising from infrastructure projects like Power (on account of availability of PPA) can be relied upon, but the same thing cannot be said of Road projects, particularly if it is not under Annuity basis. On account of this uncertainty in spite of sensitivity analysis, acceptance of long term cash flow projections interalia Debt Service Coverage Ratio (DSCR) may not be realistic. 03. Security for Infrastructure Loans: Normally, Project Assets are held as Security for loans. This is practicable and acceptable in the case of loans resulting in creation of physical assets like Power sector or so. 15 In the case of Roads, Bridges and Dams, etc. the Project Assets are not to be treated as Security for bank loans. Also the rights, licenses, authorizations, etc., charged to the banks as collateral should not be reckoned as tangible security as per RBI guidelines. Hence, such advances shall be reckoned as unsecured. Banks may treat annuities under Build-Operate-Transfer (BOT) model in respect of road / highway projects and toll collection rights, where there are provisions to compensate the project sponsor if a certain level of traffic is not achieved, as tangible securities subject to the condition that banks' right to receive annuities and toll collection rights is legally enforceable and irrevocable. The above RBI guidelines clearly spell that long term loans for Road projects are unsecured unless it is backed by other collateral security, which is a rarity considering the huge quantum of loan and also the fact that these are developed by Special Purpose Vehicles (SPVs). 04. Delay in Commercial Operation Date (COD) and Consequential Extension of Door to Door Tenor of Loan In Infrastructure projects, the more imminent risk is delay in implementation of the Project. This is more pronounced in Road projects for acquiring required land and Right of way. Because of these obvious reasons, the COD gets postponed. Though RBI guidelines provide cushion time for treating the account as Standard Asset during this period (upto a maximum of 4 years from the original date of COD), but the connected repayment will have to be obviously extended resulting in extended Door to Door tenor of such loans. Such reschedulement of the loan is to be termed as Restructured advances to be published in the banks’ balance sheet. Delay in project implementation may take the cash flows for a toss and quantum of Interest During Construction (IDC) also increases, thus affecting the DSCR or the repayment itself. 05. Risk Weight for Lending to SPVs Infrastructure projects are implemented through SPVs. As SPVs are new companies and the Sponsor distances himself from these SPVs, on a standalone basis, SPVs do not command the highest rating. In such cases the risk weight for the bank lending is 100% or more. 06. Prudential Exposure Ceiling for Group Borrowers; As Sponsors have contributed to the equity of SPV, they are treated as Group companies of the Sponsors attracting the RBI Prudential exposure ceiling of 50% of the Bank’s Capital funds. In many cases, bank’s ability to lend is restricted on account of this. 16 07. Industry wise- Sector wise Exposure of banks to Infrastructure Projects: As a prudent credit risk management and to avoid concentration risk, banks prescribe exposure ceiling to various industries, sectors, activities, etc. In the case of infrastructure projects, considering the huge funds requirements, that too for longer durations, generally, only big banks take exposure in infrastructure lending. As most banks would have fixed exposure ceiling to this sector, the actual exposure is either exceeded or near about the ceiling, leaving little head room for future lending. 08. Interest Rate Reset Normally, infrastructure loans carry fixed interest with reset option at the end of each year or so as agreed upon. Generally, where interest rate reset option is provided, no prepayment penalty is imposed if the loan is repaid at the time of reset of interest. Here, depending upon the prevailing interest rate scenario, banks reset the interest and conveys the same to the borrower. If such reset rate is acceptable, the borrower would continue or else he would prepay the loan by raising loans (mostly short term) elsewhere. Thus the borrower always tries to take advantage of interest rate reset and it is not always win - win for both. 09. Loan Draw downs- Non Availment Delay in implementation of the project causes irregular draw downs than originally envisaged resulting in derailment of ALM process and proper policy initiation thereon. Also, in many occasions where banks are sitting on abundant liquidity, they offer short term loans to the corporates at competitive rates of interest for managing their temporary cash flow mismatches. Corporates use such short term loans instead of prescribed draw down of term loan to acquire the required asset and thus plan to reduce their interest burden. Thus many a times it may so happen that the loan sanctions to infrastructures are huge but the availment is comparatively low. Support to be provided to banks by Government/RBI: In view of the major role played by banks, the Government and RBI may examine providing following support to the banks: Reintroduction of Section 10(23G) of IT Act As a special case, treat the assignment of toll receivables, rights, licenses, authorizations, etc as security for loans. Treat SPVs on the same platform as that of the sponsor for the purpose of Risk Rating as also the applicable risk weight. As project assets, project related contracts and project cash flows are separated to a large degree from the sponsors and that the sponsors provide limited or no 17 recourse to cash flows from other assets, for the purpose of Group exposure, the lending to Group entity need not be clubbed with the exposure to SPVs. To permit the banks to issue tax free infrastructure bonds and treat the same as part of Tier II capital for Capital Adequacy purpose Infrastructure loans to a water supply project, irrigation project, water treatment system, sanitation and sewerage system or solid waste management system, renewable energy sources such as wind, biomass, small hydro, solar, etc. projects for preservation and storage of processed agro-products, perishable goods such as fruits, vegetables and flowers including testing facilities for quality and Projects involving agro-processing and supply of inputs to agriculture, irrespective of loan quantum may be treated as part of priority sector lending. RBI/ IDFC/ IIFCL may provide refinance to banks upto a certain percentage of bank’s infrastructure lending to tide over liquidity constraints and treat that portion of refinance as short term source (inflow) of funds for bank’s ALM purpose. Conclusion: Funds requirement for Infrastructure projects are huge and banks alone for various reasons stated above may not be able to fund the massive requirement. In fact, Dr. Rakesh Mohan Committee report in 1996 itself has recommended for development of Bond market to fund the huge requirement. PF, LIC and such other funds will have to be effectively deployed to meet the fund requirement for infrastructure development. Banks on their part will have to continue to play a major supportive role in growth of this vital sector, supported by Government/ RBI as stated above. References: 1. RBI Guidelines 2. Deepak Parekh Committee Report on Infrastructure Financing 3. ICRA Report on Public Private Partnership 4. United States General Accounting Office Glossary on PPP 5. PPP Process – World Bank Institute 6. National Council for Public Private Partnerships 7. http://info.worldbank.org/etools/pppi-portal/docs/events/PPPProcess.pdf 8. http://www.pppinindia.com/ 9. http://www.pppindiadatabase.com/ 10. Wikipedia 18