Page 27 - Banking Finance August 2020
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ARTICLE

         Banks (UCBs). Since SAF is in the larger interest of UCBs, it  Revised SAF Guidelines:
         becomes necessary to create awareness of the recent
                                                              SAF is more effective in bringing about the desired
         revised SAF introduced in January 2020. Towards this end,  improvement in the financial health of UCBs as also
         the present article shares the relevant information. To begin
                                                              expeditious resolution of UCBs experiencing financial stress .
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         with, let us examine features of SAF.
                                                              The latest RBI Circular of January 06, 2020 discusses the
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                                                              revised   the SAF .  There are three triggers which include:
         Features of SAF:                                     (i) Asset Quality when Net NPAs exceed 6% of Net Advances.
          RBI conducts inspection of UCBs under the provisions of the  (ii) Profitability when there are losses for two consecutive
         Banking Regulation Act, 1949 to assess the financial position  financial years and there are accumulated losses on its
         of a bank and its adherence to the various provisions of the  balance sheet. And,  (iii) Capital to Risk Weighted Assets
         Act and directions/instructions issued there under. It also  Ratio (CRAR) when it falls below 9%.
         monitors the financial position of UCBs based on periodical
         returns/statements submitted by them. Further, the Reserve  For each trigger, there are certain Common actions which
         Bank initiates supervisory actions based on its assessment  should be taken by the UCB which shall include; a) Advising
         of the financial position of a bank. The SAF envisages, in the  the UCB to submit a Board-approved Action Plan for each
         initial stage of deterioration in the financial position, self  trigger b) Advising the Board of Directors of the UCB to
         corrective action by the management of UCBs themselves  review the progress under the Action Plan on quarterly/
         and, thereafter, supervisory action by the Reserve Bank in  monthly basis, and c) Advising the UCB to submit the post-
         case the financial position of the bank does not improve.  review progress report to Reserve Bank.

         For supervisory action by RBI, there are certain trigger  Besides Common actions, there are certain trigger-wise
         points which indicate the deterioration in the financial  Specific Supervisory actions taken by the RBI. To elaborate,
         position of a bank.  Such deterioration in financial shall refer  for (i) Asset Quality trigger, such specific supervisory actions
         to fall in the asset quality, decline in profits, capital  include: a) UCB would be required to furnish an action plan
         inadequacy etc. As stated earlier, the management of the  for recovery of NPAs and to undertake special drive to reduce
         UCB should  first identify the cause of deterioration and take  the stock of NPAs and contain generation of fresh NPAs. b)
         necessary corrective actions, on  their own, with a view to  The Board of the UCB would review its loan policy, take steps
         improve the financial position of the bank.          to upgrade credit appraisal skills and strengthen follow-up
                                                              of advances including loan recovery; c) Curtailment of
         But, such corrective action should be prompt as any delay  sanction/renewal of credit facilities to sectors/segments
         could be detrimental to the interest of the depositors and  having high proportion of NPAs; d) Reduction in exposure
         other stake holders of the bank. The corrective action should  limits for fresh loans and advances; and, e) Restriction on
         include measures for augmenting capital, close monitoring  fresh loans and advances carrying risk-weights of more than
         of NPAs and their recovery, improving profitability by  100%.
         curtailing expenses, mobilizing low cost deposits etc. The
         UCBs should also prepare a time bound specific action plan  Similarly for (ii) Profitability trigger, additional specific
         for bringing about necessary improvement in its overall  supervisory actions include: a) The UCB is advised not to
         functioning and, the Board of Directors should monitor the  access/renew high cost deposits,  launch special drive to
         progress in implementation of the action plan in its every  reduce the stock of NPAs & contain generation of fresh NPAs,
         meeting.                                             rationalize its branches and close down loss making
                                                              branches; b) Prohibition on declaration/payment of dividend/
         In case necessary steps are not taken to improve their  donation; c) Restriction on incurring capital expenditure
         financials or steps taken do not result in the required  beyond a specified limit, without prior approval of the
         improvement in the financial position of the bank, the  Reserve Bank and, d) Measures for reduction in interest and
         Reserve Bank steps in and initiate supervisory actions as it  operating / administrative expenses.
         deems necessary RBI revises guidelines on SAF from time to
         time to address issues arising in its implementation.  Lastly, for (iii)  CRAR trigger, supervisory actions include: a)

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