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               IL&FS CRISIS:

               A CLOSE                                                                                                                  Over a year down the line, and there has been no end in   granting the RBI power over NBFC boards (Union budget
                                                                                                                                        sight. The ailing NBFC sector has been on the receiving end   FY20); new norms to improve the liquidity situation, and so
               EXAMINATION                                                                                                              of a slew of government/RBI containment and austerity   on.
                                                                                                                                        measures. Noteworthy among these include tighter RBI
                                                                                                                                        scrutiny; one-time six months' partial credit guarantee on   Come 2020, the extension of a gradually scalable LCR and
                                                                                                                                        purchase of pooled assets from NBFCs; priority sector   NSFR from banks to NBFCs will also be a strong step by the
                                                                                                                                        lending status to key NBFC segments; increase in FALLCR   RBI in this direction.
                                                                                                                                        (facility to avail liquidity for liquidity coverage ratio) by 0.5%
                                                                                                                                                                                          Liquidity powered by an advanced technology suite
                                                                                                                                        for banks and other initiatives to ease credit flow to NBFCs.
               Feb 12 2020                                                                                                                                                                The liquidity risk management framework of a bank or an
                                                                                                                                        Regulations such as the introduction of mandatory levels of   NBFC is a decisive factor in how effectively the liquidity
                                                                                                                                        revision in maturity buckets, liquidity monitoring tools, stock   position of a financial institution is measured and maintained.
               Jaya Vaidhyanathan
                                                                                                                                        approach to LRM (liquidity risk management), and Liquidity   The best outcomes are when stakeholders from different
               CEO, BCT Digital
                                                                                                                                        Coverage Ratio (LCR) to large NBFCs are also likely to see   levels of the NBFC (organisational-level, business-level and
                                                                                                                                        results.                                          user-level) are involved in the process as independent, yet
                                                                                                                                                                                          accountable members. As the final frontier, external
                                                                                                                                        But the question remains — are these measures enough or   regulators, auditors, and credit rating agencies, need to play
                                                                                                                                        did they come through a bit too late?             proactive roles in identifying risk factors, flagging and
                                                                                                                                                                                          following through to closure.
                                                                                                                                        Maintaining liquidity and asset quality through
                                                                                                                                        good governance                                   Across the NBFC sector, asset-liability management (ALM) is
                                                                                                                                        The sheer nature of the business of IL&FS demanded   at the nascent stage, and needs to be structured in a
                                                                                                                                        effective management of assets and liquidity in the short-   manner at par with scheduled commercial banks. The RBI’s
                                                                                                                                        and long-terms. Interestingly, in the case of IL&FS, even   latest guidelines, involving the ALCO, and its rules enforcing
                                                                                                                                        though there were startling discrepancies in the balance   new monitoring mechanisms, have fuelled an urgency
                                                                                                                                        sheet, auditors and rating agencies noted them and moved   among NBFCs to adopt technology for liquidity risk
                                                                                                                                        on – or arguably, did not take notice at all.     management.
                                                                                                                                        In this context, the role of a robust monitoring mechanism   In today’s volatile marketplace, the interest rate risk by itself
                                                                                                                                        becomesmost important for safeguarding the health of the   must be closely linked to funds transfer pricing, intraday
                                                                                                                                        system. In retrospect, in the IL&FS scenario, adhering to a   liquidity and overall capital management. There is a need for
                                                                                                                                        four-tier governance framework – involving both internal   a holistic approach using a robust ALM framework to
                                        The IL&FS debacle of 2018 opened India to the imminent risks                                    and external lines of defence – could have perhaps   protect earnings and capital while reducing complexity and
                                        around asset-liability mismatch and inadequate liquidity                                        accelerated intervention and remediation by authorities.   ensuring compliance.
                                        management. Banks were quick to react to the ripple effect, by                                  More power to RBI through the ratication of new   A standardized system with an independent and targeted
                                        withholding credit from NBFCs, even as mutual funds halted all                                  regulations                                       governance framework (adhering to RBI regulations and
                                        renancing activities. In no time at all, India’s shadow banking                                Perhaps the silver lining - a direct consequence of the NBFC   supported by specialist firms) can make an ocean of
                                        system was knee-deep in trouble. Ratings of several prominent                                   liquidity crisis - was the much-needed shakedown of the   difference in the financial health of an NBFC. Such a
                                        players were downgraded. The possibility of a consumption                                       shadow banking system jointly by RBI and SEBI. Steps   specialist application can help banks and NBFCs meet their
                                        slowdown was suddenly very real.                                                                towards remediation included: grouping HFCs under the   immediate liquidity requirements. Beyond this, it can also
                                                                                                                                        RBI ambit (pulling them away the National Housing Bank);   leapfrog them to the next level of compliance.
                                                                                                                                        stripping several non-compliant NBFCs off their licenses;


               24  rt360 Less risk, more coffee                                                                                                                                                                       rt360 Less risk, more coffee  25
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