'For Whom the Bell Tolls?' Bank Mergers

Consolidation, Convergence and Competition of Banks in India

Cooperative Banking suffering weak governance, poor legal framework, dual regulation, and excessive politicisation is in search of sustainable solutions and the consolidation move in the three states rightly highlighted by Bloomberg in its article a few days ago is perhaps the right move. Following the recommendations of Vyas Committee (2005) NABARD amalgamated the 196 RRBs established under the Multi-Agency approach to rural lending in the country during a fifteen year period till 1990 into 64 by 2013. This amalgamation has only partial success as the RRBs are still distant from the objectives of their creation in 1975.

1991-2001 saw bank disintermediation in the wake of financial liberalisation, prudential norms and profitability focus. Directed credit program was blamed for the rising NPAs till then. I recall Dr.Y.V.Reddy mentioning in his latest book ‘Advice and Dissent’: “the seeds for bad times are always sown in good times.” 2003 was the year of ‘crazy credit’ that took the route of CDRs in 2010 and 2011. This grew into a immature NPA adult and aged along to reach the unsustainable level of around Rs.8trillion. Courtesy this situation, lazy banking had set in.

NPAs of MSEs Need Alert Banking

NPAs of MSEs Need alert Banking

Grouped under unorganized sector, micro, small enterprises (MSEs) are suppliers to the organized medium and large enterprises. With GST they would migrate from unorganized to organized territory ere long.

Many entrepreneurs have been wondering about their future as their working capital cycles shake up. Credit to them has been on the continuous decline from the banks. In spite of GoI guidelines of June 2015 and master directions of the RBI, several deserving non-willful defaulters’ accounts have not been revived/restructured. Zonal Committees for MSME stressed asset resolution continue to make an apology of their presence. The remedy suggested by the RBI in its master directions with SMA(0,1,2) proved worse than the disease going by the analysis presented below based on the data in RBI Bulletin January 2017.

Obstinate NPAs refuse to leave

Dynamics of NPAs Defy Sensitivities

B. Yerram Raju*

Non-performing Assets (NPA) are a dynamic statistic moving from Rs. 2.50trn in 2013 by nearly four times in four years! Unless the patient cooperates the medicine never works in the sense that it has to be taken on time and in required dose. Here the doctor has been experimenting with the medicine and the patient is unwilling to take it.

Corporate Debt Restructuring measure suggested post 2008 crisis, corrective action plans, Joint Lenders’ forum, 5:25 scheme, strategic debt restructuring (SDR), Sustainable structuring of stressed assets (S4) Scheme have all proved a damp squib and now the regulator-led solution through amendment to the Banking Regulation Act to invoke the provisions of the Insolvency and Bankruptcy Code against the wilful defaulters is made to appear a surgical strike at bad debts.

Any credit decision is bounded by certain forecasts or predictions about future. It is unlikely that every such decision would end up as expected. Hence NPAs are inevitable in lending. But credit assessed for corporate entities requires a finesse. The promoters and directors should be put to the rigor of scrutiny. Environment and economic risks should be part of enterprise risk assessment. When we look at the largesse in lending in the corporate sector, hindsight and individual appraisal of the directors and promoters as also post disbursement monitoring appear to have taken a beating. Banks’ scrutiny lapses could not be drubbed as willful default for a forceful recovery.

The Banks, Government owning most of them, and the RBI have been in the know of the devil in detail. After the Development Banks have been wound up and universal banking came into being where banks started selling credit, mutual funds, insurance etc., and bank-participated rating institutions or their semblance commenced rating the companies, credit risk assessment has become farcical. Lenders are aware that they are lending short term resources for long term investments prone to very high risk of losses. Banks say they were forced to lend to PSUs.

Bank executives eyeing for the top post or those that are in such high post wanting to hold to the chair compromised institutional interests.  The other reason for such credit for infrastructure, real estate, housing, and retail facilitated arm chair lending suiting their limitations in staff recruitment. They earned profits at the cost of efficiency with impunity. 

Bank Boards having the regulators’ and the GOI representatives as Directors liberally subscribed their signatures to the sanctions. Risk management committees, audit committees of Boards, regular audits and inspection reports at annual intervals should have been the instruments of Board oversight mechanism.  Unfortunately all these would appear to have muted. Failures of governance are beyond action.

CDR mechanism helped greening the balance sheets of banks. The postponed debt obligations swooped on the banks after the CDR ended. Banks realized that they had to provide 30 percent of the secured portion and 100 percent of the unsecured for all the doubtful accounts. By the time the CDR ended Banks realized that the tangible securities have all vanished. To save the banks, RBI introduced SDR. Under SDR, banks can convert 51% of debt into equity to be owned by them and also change the management. New investors could hardly be found as the amount involved is over Rs.2trillion.  Management changes could hardly be seen. In the consortium of bankers another peculiarity noticeable was that while one bank declared the asset as standard asset other bank(s) declared it as doubtful calling for action due to the former finding ways to push the ghost of NPA under the carpet.

S4 can be termed a non-starter. Unanimity in restructuring effort proved rarity. On top of this, banks started showing ‘vigilance’ from agencies like the CBI as villains. In most cases where such vigilance stumbled upon, many skeletons in the cupboard of such banks came out and some executive directors and chair persons were also exposed!!

The latest RBI measure to invoke the IBC and also provide for deep haircuts without fear of the ‘vigilance’ bodies has to prove itself as the IBC requires thorough understanding of the art and science of negotiation and arbitration. Until all the stakeholders, advocates and the jury fully acquaint the terms used in the IBC, resolution through this process would be a long and difficult journey given the fact that the banks have not been able to make use of the easiest Sarfaesi Act and its rules in good measure.Recovery effort in most of the cases instead of ‘squeezing oil out of sand’ may be a milking cow for the errant.

It is time for the RBI to step out of the Bank Boards notwithstanding the losses that their planted directors by way of intangibles could be subject to. Regulatory arbitrage shall not take place to preserve the sanctity of central bank. In more than one way, dynamics of NPAs thus far defied sensitivities in resolution. Hopefully, RBI will be able to doctor a solution to the five-star hospital patient.

http://www.moneylife.in/article/obstinate-npas-that-refuse-to-go-away/50914.html?utm_source=PoweRelayEDM&utm_medium=Email&utm_content=Subscriber%2327753&utm_campaign=Daily%20Newsletter%2028%20June%202017

How to redefine and rebuild the banks in India

How to redefine and rebuild Banks?

‘Banks are basically meant to allocate capital to businesses and consumers efficiently.’ Post demonetization, customers feel the pain more than gain in banks. Farmers getting inadequate and untimely credit from banks take to huge private debt only to commit suicides later.

Manufacturing micro and small enterprises, the seed beds of employment and entrepreneurship, are being shown the door by the banks notwithstanding the CGTMSE guarantee up to Rs.2crore. Banks never went beyond the mandated Rs.10lakh guarantee cover for the MSEs.

Large number of customers is slapped with irrational minimum balances in their accounts and levy of penalties at will. RBI is averse to regulate such overtures in the name of micro management of banks being not their role.

With over 38% of the population still illiterate, Jan Dhan and Mudra Yojana as instruments of financial inclusion have only become compulsive agenda for the banking sector. Banks- Public sector or private sector, have their eyes set only on profit. Such profits are dwindling with net interest margins declining following the growing NPAs.

Institutional innovations like the Small Payment Banks, India Post and the likes as also the MFIs have also proved inadequate to meet the needs of the present leave alone the future banking needs of the population.

Cashless banking leading to poor inflow of deposits during the last four months and cashless ATMs demonstrate the erosion of faith in banking in India. Bad banking and good economy cannot co-exist and therefore, it is imperative that innovative institutional solutions should be thought of.

Indian economy targeting double digit growth ere long has competing clientele bases in the current milieu of banking. Domain banking has moved to high tech banking. Men at counters have now become slaves of the machine instead of being masters. Public sector banks have long back forgotten their purpose and their owner proving no better.

Emerging context requires that banking is redefined to meet the specificities of farming, employment, entrepreneurship, infrastructure, and international finance as distinct entities. In fact, Narasimham Committee (1991) suggested consolidation and convergence of the PSBs into six to serve the needs of the service sector, holding government securities, and retail lending; Local Area Banks to cater to the farmers and small entrepreneurs; International Bank to cater to the needs of exports and imports. Development Finance institutions, left untouched, would fund the infrastructure sector. FSLRC also echoed the same in its Report. This is the time to look at the spirit of such recommendations and rebuild the banks to regain the fast eroding trust in banking by the larger customer base of this country.

KISAN BANK:

Breaking the nexus between the farmer and politician can happen only when there is mutual trust between the bank and the farmer. Farm sector, consisting of crop farming (organic, precision, green technologies etc.), dairy farming, shrimp farming, poultry farming, sheep farming and agricultural marketing by itself is inherently capable of cross holding risks, save exceptions like the tsunamis, severe drought for long spells, huge typhoons. It is only in the event of such natural calamities that a Disaster Mitigation Fund should come to the rescue.

The existing commercial banks should shed this portfolio in favour of RRBs and merge all the rural branches with the RRBs. RRBs should be redesigned to take to farm lending in a big way – from farm machinery to crop farming and allied sectors on a project basis. Insurance plays a vital role in mitigating credit risk and therefore, the insurance products should be redesigned and modified on the lines of South Korean model.

All the Rural Cooperative Banks could continue their lending to the farm sector parallel to the RRBs as the lending requirements are huge and farmers require multiple but dedicated lending institutions.

RBI has not been comprehensive in regulating the sector. It is better that NABARD is restructured to play an exclusive refinance and regulatory role over the entire farm and rural lending consistent with its purpose of formation. Its other functions like the RIDF can be relegated to a new institution hived off from the NABARD.

UDYOG MITRA Bank

Nurturing entrepreneurship and promoting employment in manufacturing are moving at snail space in the Start Up, Stand Up and Make-in-India initiatives. Prabhat Kumar Committee (2017) called for setting up a National MSME Authority directly under the PMO to correct the milieu.

All the MSEs should be financed by dedicated MSE Bank Branches. All the existing SME branches should be brought under a new regulatory institution. SIDBI has disappointed the sector. It has to first consolidate all its FUNDS into just five: Incubation Fund; Venture Capital; Equity Fund to meet the margin requirements of MSEs when and where required; Marketing Fund to meet the market promotional requirements; Technology Fund; and Revival and Rehabilitation fund.

SIDBI should reshape into refinance and regulatory institution for the MSME sector with focus on manufacturing and manufacturing alone. It should divest its direct lending portfolio to avoid any conflict of interest. Its present lending to real estate and non-manufacturing MSME lending should be transferred to the commercial banks. RBI which is not currently able to cope with the regulatory burden of this sector can transfer it to SIDBI,

Vaanijya Banks (Commercial Bank):

All the existing commercial banks – both in the public and private sector – would do well confining to the project finance, lending to real estate, services sector, housing, exports and imports etc. All the Banks should constitute at the Board level a sub-committee on Development Banking to work on the transition arrangements to the above functionality.

Maulika Vitta Vitharana Samstha (Infrastructure Bank)

Huge NPAs have come from the practice of lending long with short term resource base coupled with lack of experience in assessing the risks in lending for infrastructure projects. ‘All the perfumes of Arabia’ (RBI’s structural debt restructuring solutions) did not sweeten the bloody hands of banks. It is time to revisit the universal banking model and reestablish Infrastructure Bank to fund the infrastructure projects and logistic parks.

These measures would help achieving the growth like never before.

RBI and GoI could constitute a High Level Committee to work on the modalities for transiting to the new structural transformation of the financial sector.

http://www.moneylife.in/article/how-to-redefine-and-rebuild-banks-for-emerging-demands/50376.html

Politics and Economics of Crop Loan Waivers

Cost of Crop Loan Waivers

SBI Chairman Arundhati Bhattacharya’s impromptu remarks on loan waiver promises of the States to the farmers have attracted the politicians’ ire. Equity and discipline are two sides of the coin of farm lending. If the Banks maintain equity, and care for lending discipline more, borrower discipline would not take a toll.

Loan waivers announced by the State Governments should be met by the state exchequer and not the centre, Venkayya Naidu, the Union Minister said. But when the BJP announced it, decrying the earlier moves of AP and Telangana Governments, it gained political traction and the states demanded a cake in the bargain from the centre with several like Maharashtra, Tamilnadu, Karnataka joining the chorus. Have farm loans become unviable and farmers untrustworthy borrowers? Are there no alternatives to rescue the farmers’ woes?

Unfortunately, lending discipline is lax. Roll over of crop loan with interest as a new loan (this we call book adjustment) and a small incremental credit for crops that take more loan component than that is actually grown on the field has become the order of the day. In South India, it is jewel loans that get accounted for as crop loans. Otherwise one cannot find an explanation for only 20.9% of crop loans getting insurance cover against the mandatory debit of premium for all the crop loans disbursed.

Some grameen banks are debiting processing fee and inspection charges for crop loans and that too without the borrowers knowing it. On top, they charge interest on those debits if not able to recover them.

Arm chair lending even for farm sector has become the order of the day due to inadequate or lack of field staff. Earlier, controlling authorities and even top management used to visit the adopted villages as a semblance of identifying with rural credit activity. One is hard put to find such visits. These are not wild allegations, but facts that came out during the crop loan waiver evaluation done in Telangana by the Development and Research services private limited.

Farmers did not fail the nation in spite of failure of the monsoons, failure of governments not releasing the promised incentives in time, insurance failing them year after year and markets ditching them on the price front. But bankers failed the farmer and the nation with absolute impunity. Any crop loan target set for them by the government is shown to be achieved.

Earlier Loan write offs of 1990 for Rs.10000cr and Rs.70000cr of 2008 were a political stroke and were criticised for lax implementation by the CAG Audits placed before the Parliament.

Telangana Government waiver scheme covers only institutional crop loan including jewel loans outstanding as on 31^st March 2014 up to Rs.1,00,000 per farmer family, spouse and dependent children. It defined eligible short term production loan as loans given for raising crops that are to be repaid within 18months and includes working capital loan for traditional and non-traditional plantation and horticulture. Claims are reimbursed by the Government on the basis of a certificate from the bank that the waived amount has been actually credited into the farmer’s account.

Every lending institution is mandatorily responsible for the correctness and integrity of the list of eligible farmers under the scheme and the particulars of loan waiver in respect of each farmer. All the bankers are expected to provide fresh loans as the existing liability up to Rs.1lakh per farmer family has been picked up by the state government under the scheme.

Evaluation exercise revealed that the farmers to the extent of 70% are happy with the reprieve given to them particularly because they were affected by severe drought for two years in a row although they were unhappy that the waiver instalments were released late leading to delay in release of fresh crop loans by the banks. Fresh crop loans were inordinately delayed in 60 to 70 percent cases during 2014.They wished that the state government would have released in one single go the announced benefit.

55.5% was the share of the crop sector in the total agriculture loans. Government of Telangana agreed for writing off crop loans to an extent of Rs. 16,160crores constituting 76.19% and gave detailed instructions to the banks after consulting the SLBC.

The State having more than 80 percent of small and marginal farmers with loans from multiple institutions and also from private lenders and traders faced problems in addressing the competing demands on the claims for waiver.

Banks’ loan books and farmers’ land record passbooks proved equally non-transparent. Borrowers as well as their parents with identical names figuring in different banks posed impregnable identification issues requiring over six months for resolution at the sub-district level before the first instalment was released.

Average loan amount subject to waiver was a little less than Rs.55000 per farmer family against the announced Rs.1lakh.

Major Public Sector Banks had gross NPAs in Short term crop loans of the order of 2.4% in 2016 as against nearly 8% in 2015.

DRS study came to the conclusion that loan waivers are not a permanent solution to the recurring problems of the farmers either due to man-made or natural calamities.

Solution lies in appropriate insurance mechanisms with individual farmers and income insurance as focus and not the crop insurance that takes threshold limits of crop yields based on area affected historically.

South Korea that supports agriculture sector ranking top among the world’s highest subsidy providers, offers excellent example in this direction.

Korean farmers also get the benefit of a comprehensive agricultural insurance scheme managed by the National Agricultural Cooperative Federation (NACF) with reinsurance support on a quota share basis from a group of domestic reinsurers. The government supports the scheme in four different ways i) provides 50 percent premium subsidies for crops and livestock; ii) acts as a reinsurer of last resort for the liability in excess of 180 percent local market loss ratio;(iii) 100 percent of the NACF’s crop insurance operational expenses and 50 percent of livestock insurance operational expenses are subsidized by federal government budget; and (iv) It participates in product research and development. The insurance coverage in Korea is voluntary.

It will be worthwhile investment on the part of government both in terms of time and resources to provide sustainable income insurance to the farmers on a pan India platform on similar lines, so that the recurring demand for the loan write offs can be warded off.

*The author is an economist and risk management  specialist and part of the DRS Study Team.

 http://telanganatoday.news/cost-of-crop-loan-waiver/250317

Are we on the right track in tackling NPAs?

Are we on the right track for NPA resolution?

B. Yerram Raju*

In the last few years, barring the 2008 Recession and its global impact, no subject other than NPAs of the Indian Banks has occupied so much print space and media attention.

If good number of banks in the public sector has faltered in loan origination succumbing to external pressures, some others have failed to supervise their loan portfolio. But their contribution to NPA portfolio may not be more than 25 percent. NPAs that turn as bad loans are the real culprits. Only 20 percent of the total quantum of loans at the doorsteps of legal system could be resolved to the satisfaction of the banks, notwithstanding the projected empowerment of banks through the SARFAESI Act. The real reason is, therefore, beyond banks – the law and justice.

Bi-monthly Monetary Policy can lower borrowing rates

RBI Governor in his first Monetary Policy during the current financial year has cut the key policy rate by 0.25 percent to 6.50 percent and sends the message louder than ever that banks should pass on the rate cut to their clients to pump prime the economy.

In the backdrop of a supporting fiscal policy and pressures built on the cut in interest rates by the government on its savings schemes all the eyes were on the RBI for a cut in key policy rates. The Governor proved that he is not going to be political but economic.

Growth of domestic savings has hit the lowest rate during the last three years. Inflation - particularly food inflation - still is a cause for anxiety in the backdrop of series of monsoon failures. Weather is weather and the hopeful forecast for the current year by the Met Department has to be taken with a grain of salt.

Banks have been provided a liquidity window should they need to use it, easier than ever. He recognized also the inability of banks to go beyond a point in lowering the interest rates due to their pile of NPAs, which he stressed shall move down southwards day after day if not hour after hour.

Banks should discipline themselves and discipline their borrowers and promote growth is the clear message of the policy.

Consolidation of Banks is no cure to the Ills

James Crabtree of the FT reporting on the predicament of the then PM Singh commented in March 2012 that Indian Banking was at the brink and needed heavy capital infusion to catch up with Basel III requirements and clean up to measure up to the requirements of economic growth to revive to beyond 7%.

The position worsened ever since. Gyan Sangam (Intellectual Confluence), the second after the formation of the present government that discussed the revamp of the banks a couple of days back at Gurgaon, Delhi have not offered any better wisdom than loud whispers of consolidation of banks. Is consolidation of banks the right solution?

Pre-Budget 2016 last strokes

Budget Run Up – The Last Strokes

The long wish list of the budget 2016-17 in the double-digit growth pitched economy has GST implementation as the top agenda and implementation of recommendations of Justice Eswar Committee on tax reforms as the second top item.

Farm sector and rural development find a big surge in the budget run up news columns. Declining credit is a cause for worry in these sectors as the banks hit by NPAs and loan write-off are in no mood to oblige the farmers. Agriculture infrastructure targeting market yard digitisation and revamp calls for a big ticket from the challenging budget 2016.  A separate budget for agriculture would have made lot of sense but the government has no such plans. Still hopes ride high in this sector.

Make-in-India requires a big manufacturing push and this is possible mostly with the MSME  sector that has so far drawn little attention.

MSME  Ministry recently redefined the eligibility criteria whereby the aggregate value of the Plant and machinery under the same ownership located anywhere will be reckoned to classifying as MSME, providing for vertical growth. This will correct the distorted subsidy regime engendered by horizontal growth.

MSMEs Cry for Attention

Start-Ups in MSMEs, particularly in manufacturing can now look for vertical growth instead of horizontal growth with the MSME Ministry revising the definition of plant and machinery to include all such equipment owned by the same owner(s) across the districts and country to be reckoned for classification of MSME under the MSME Development Act 2006. In the long run this redefinition would do lot good to the sector. The sector may witness in the short term more NPAs.

MSMEs in the eye of the storm

MSMEs are in the eye of the storm with NPAs reaching 5.90 percent as of March 2015 even though the net accretion to the portfolio has gone down from 12.3% in 2014 in terms of number of accounts to 10.1% with a corresponding decline in amount outstanding from 23.9% to 13.6%. The industry NPA level was 5.47 although at the systemic level both industry and MSMEs represent 4.7%.  Only 7.9% constitute MSME advances to the total advances. (Financial Stability Report No.11, July 2015)

Risk appetite for the MSMEs is very low among banks and their adherence to the guidelines of both the RBI and GoI to identify sickness at incipient stage and introduce corrective action plans is highly suspect. There is reluctance among banks for either restructuring or revival of even viable advances. Their credit origination has also no less to blame. Monitoring and supervision are hit hard by lack of adequate field staff leaving most accounts for arm chair surveillance.

Debt and Disaster

Disasters may be frequenting the coastal regions. But not like the one that we saw in Chennai till yesterday, in the recent history. It may take months for the city to recover from the shock and may need billions of rupees for recovering the lost infrastructure and assets. This signifies that no disaster will be like its predecessors and they manage us and not us managing them.

The estimate for the insurance sector outflow for the rescue has been put at a measly Rs.500cr.  It may have excluded the assets insured in the financial sector. Several industries, export-oriented auto components industry, leather industry, several MSMEs alone have assets worth around Rs.2lakh crores in and around Chennai, the marooned metro for a century.

Capital Infusion in PSBs – Need and the Deed

Capitalization of Public Sector Banks has been incorporated as one of the seven items in ‘Indra Dhanush’, dubbed as part of Banking Sector Reforms.  Before addressing the issue of such capitalization it is important to understand some of the historical developments in banking globally and the way different countries responded to addressing the issue of refurbishing capital in the banks.

As part of the global financial system, Reserve Bank of India made us to believe that banks in India have to fall in line with capital adequacy norms under Basel regulations. Even prior to the embrace of capital regulations of Basel India had CRR and SLR as regulatory instruments to safeguarding the financial stability of banks. 70 percent of the Banks’ assets in India are in the public sector.

NPAs - the perpetrators go scot free

If the RBI and MoF representatives on the Boards of Banks had prevented approvals of some corporate loans and brought collective wisdom to do due diligence, NPAs would not have reached the current unsustaining levels. Otherwise, how could one explain the debacle like that of King Fisher sanctioned on the basis of Brand as collateral thousands of crores on the instance of the then Chairman of the SBI. And this Chairman goes scot free royal. The successors have to cool their heels. 

It is important that the regulators get out of Boards of PSBs. Government of India, as owner, would do well to provide equity and discipline by sending more qualified representatives on the PSB boards and not the persons who are trying to learn the alphabets of banking. By being in the MoF for donkey years does not make one an expert in banking and finance!!

This is my response to Mrs Usha Thorat's article on the subject in Live Mint dated 15th july 2015.

Banks threatened with huge NPAs

There is a report in First Line that a Collector from Amravati threatened action against bankers for not reaching agricultural loan targets in a quarter under IPC. This is sheer arrogance on the part of the District Collector who does not know his job. There is another report of the UBS on the mounting NPAs in the Live Mint of 7th July 2015. Reading together becomes necessary.

UBS Report has been contested by 'Yes Bank.' while the other banks chose to ignore. The fact remains that the corporate debt today occupies major portfolio of banks. There is excessive interference from the administration in public sector banks.

Take for instance, the story of Maharashtra Government where one of the district collectors audaciously threatened the banks for not achieving the targets in farm lending as per his dictate just a couple of days ago. The news appeared in First Line. The banks in the coordination forums - District level Consultative Committees of which the Collector/DM is the chairman, have never pulled up the district administration for failing to provide reliable land records, for failing to provide the credit related infrastructure for farm schemes to succeed and they mention in their Annual Credit Plans and NABARD in its PLP for the administration to respond adequately. The Administration never adequately responded.

When the 20-point programme was introduced initially, District Collector, Guntur reacted similar to that of Maharashtra District Collector threatening with criminal action for failing to reach the targets under the programme in 1979. The entire banking community walked out of the DCC asking the Collector to go ahead. The then Secretary Planning Govt of AP had to counsel the Collector to behave!!

Thanks to the Live Mint for the chart.

Such interferences do not mean so much as unseating the top executives for not lending to the corporates or for taking any action on the NPAs of delinquent corporates that today reached unsustaining levels. The action on the top executives range from transfer from the portfolio handling to transfer out of place. These are taken without demur as no person would like to be at the risk of his career. The obliging top executives and Chairmen get the plum posts. Such games from the Banking Department should stop. Narasimham Committee -1 recommended in 1991 in its maiden report itself, that the time had come for the banking department of the GoI be wound up and stop regulating banks. This recommendation should be revisited by the GoI in the interest of healthy reforms to the financial sector. .