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NEW SYSTEM
OF LOAN
PRICING BY
BANKS IN
INDIA
Rama Krishna Vadlamudi, BOMBAY June 13, 2010
ABBREVIATIONS USED:
BPLR : Benchmark Prime Lending Rate
BRS : Base Rate System
CASA : Current Account and Savings Bank Accounts (low-cost deposits)
CD : Certificate of Deposit; CP : Commercial paper;
CRR : Cash Reserve Ratio; DRI : Differential Rate of Interest
G-Sec : Government Security
LAF : Liquidity Adjustment Facility of the RBI
MIBOR : Mumbai Inter-bank Offered Rate
PLR : Prime Lending Rate
RBI : Reserve Bank of India; and, SLR : Statutory Liquidity Ratio
Rama Krishna Vadlamudi, BOMBAY June 13, 2010
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EXECUTIVE SUMMARY
Come July 2010, the Indian banking sector is going to witness some
fast moving and high-impact developments. India’s banking regulator,
Reserve Bank of India, is ushering in a new Base Rate System (BRS)
replacing the existing, outdated and non-transparent Benchmark Prime
Lending Rate (BPLR) system. At present, sub-BPLR lending is rampant
in the system. Once the new BRS comes into effect, one expects that
such a non-transparent and discriminatory system will come to an end.
So far, no bank has announced its Base Rate. They may announce the
Base Rates in the next few weeks before the deadline of July 1, 2010.
The author expects the Base Rate range to be between six and nine per
cent due to wide differences in cost of funds, NPAs and other costs.
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At the end, the following annexures are provided for additional reading:
Base Rate is the minimum lending rate below which a bank can not lend to
borrowers except in a few cases. Base Rate is being implemented in India with
effect from July 1, 2010. From that date, the existing Benchmark Prime Lending
Rate (BPLR) will cease to exist and the new Base Rate System will come into
effect. Base Rate will differ from bank to bank depending on individual bank’s
cost of deposits/funds and other criteria.
There is a public perception that banks have been offering lower lending rates to
big corporate customers, while charging higher rates from small borrowers in the
retail, small business and agriculture segments. This amounts to cross-
subsidization. RBI has received several complaints to this effect from various
industry bodies and associations. RBI has taken this view into consideration. For
several years especially since the early 2000s, RBI had tried to bring in a
transparent system of lending rates in the banking system. After trying very hard,
RBI has genuinely felt that banks’ BPLRs are not transparent and there is a
large-scale sub-BPLR lending.
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Downward stickiness in rates: RBI has observed that whenever RBI raises policy
rates and reserve ratios, banks are quick to increase their loan rates. But, when
RBI reduces policy rates and reserve ratios, banks respond very slowly effecting
decreased lending rates with a considerable time lag. Such a phenomenon is
called downward stickiness in rates. RBI is of the view that it is adversely
impacting the monetary transmission mechanism in the banking system.
Due to competition, banks have been offering loans to first class borrowers with
high credit rating at rates much below the BPLR in a non-transparent manner.
RBI opines that banks’ lending at sub-BPLR rates is not in tune with the central
bank’s objective of bringing transparency to the loan rates. BPLR has fallen short
of RBI’s expectations to work as a reference rate or benchmark rate.
Keeping the above in mind, RBI had set up, in April 2009, a committee under the
chairmanship of Deepak Mohanty to look into the existing BPLR system and
suggest a suitable alternative system for pricing bank loans. The Deepak
Mohanty Committee’s recommendations were made public in October 2009,
which suggested shifting from the current BPLR to a new system called Base
Rate System. After getting feedback from banks and other stakeholders, RBI had
issued its Final Guidelines on April 9, 2010.
The concept of BPLR is outdated and is out of sync with the present market
conditions and it should be replaced with a new Base Rate System
Base Rate would be based on one-year card rate on deposits, loss incurred
by banks for SLR/CRR, overhead cost and average return on net worth
Banks should not lend below the Base Rate, except in a few cases
(For full set of recommendations, see Annexure I at the end of this article.)
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RBI had made public the report of Deepak Mohanty Committee in October 2009.
After getting feedback from banks, RBI had issued the final guidelines on Base
Rate System on April 9, 2010.
All scheduled commercial banks should switch over from the existing BPLR
system to the new Base Rate System
Banks may choose any benchmark to arrive at the Base Rate for a specific
tenor (tenure of the loan)
Banks are free to use any other methodology, provided it is made available for
RBI’s scrutiny
All loans and advances should be linked to Base Rate. But, there are a few
exceptions meaning the following loans can be disbursed without linking them
to Base Rate:
i. DRI advances
ii. Loans to banks’ own employees
iii. Loans to banks’ depositors against their own deposits
Effectively, it means banks can lend below Base Rate in the above cases.
Actual lending rate will be based on Base Rate plus customer specific charges
Until the new system stabilizes, banks are given flexibility to change the
benchmark and methodology any time between July and December 2010
Base Rate can be used as a reference rate for floating rate loans
The current stipulation of BPLR as the ceiling rate for loans up to Rs. 2 lakh,
under priority sector and others, stands withdrawn wef July 1, 2010
RBI will separately announce lending rates for export credit (The details are
given elsewhere)
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The Base Rate system will be applicable to new loans as well as loans that
have come up for renewal
Banks shall exhibit the information on Base Rate on their websites and at all
their branches
For loans below maturity of one year, banks No such stipulation by RBI
are free to charge rates without any link to
Base Rate
Interest rates on export credit should not RBI has stated that export credit should be
exceed Base Rate at or above Base Rate
Base Rate should be calculated based on Base Rate should be calculated based on
one year deposit rate adjusted for CASA cost of deposits/funds and other criteria.
deposits and other criteria
As can be seen from the above table, RBI has accepted the Committee’s
recommendations only partially. For calculating the Base Rate, RBI has given
greater flexibility to banks with regard to selecting a benchmark and calculation
methodology.
Under the existing Benchmark Prime Lending Rate (BPLR), banks can give loans
below BPLR, called sub-BPLR lending. In fact, as at the end of March 2009, 67
per cent of total loans in the entire banking system were contracted at below
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BPLR. This is not possible under the new Base Rate System. Banks are not
allowed to lend at below Base Rate. It is the minimum lending rate banks have to
charge to their customers. However, there are a few exceptions to this rule (the
details are given elsewhere).
Banks are given freedom to decide their own Base Rates based on cost of
deposits, adjustment for CRR/SLR maintenance, unallocatable overhead costs
and average return on net worth.
According to RBI, Base Rate shall include all those elements of the lending rates
that are common across all categories of borrowers. Banks may choose any
benchmark to arrive at the Base Rate for a specific tenor to be disclosed
transparently. An RBI illustration, for computing the Base Rate is given below:
BASE RATE
=
Cost of deposits/funds
+
Negative carry on CRR/SLR
+
Unallocatable overhead cost
+
Average return on net worth
Strictly speaking, the above is only for illustrative purposes. RBI has given
freedom to banks to use their own methods for the calculation of Base Rate.
(The above terms are explained with formulas in Annexure II at the end.)
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RBI says that banks can calculate the actual lending rate by adding customer
specific charges to the Base Rate.
Frankly speaking, Base Rate is not equal to lending rate that will be charged
ultimately to the customer. While arriving at the actual lending rate, banks will
add certain appropriate charges specific to the customer, like overhead costs,
credit risk premium and tenor premium. As per the Deepak Mohanty Committee’s
report, actual lending rate can be arrived at as follows:
+
Credit risk premium
+
Tenor premium
* Actual lending rate that will be charged by banks to the borrowers
Credit risk premium: All loans carry credit risk meaning that the borrower may fail
to repay the loan. The extent of credit risk differs from one borrower to another
borrower depending on the borrower’s overall credit standing and other factors.
So, the credit risk premium may be lower for a customer with good track record
and may be higher for customers with not-so-good record.
Tenor premium: In general, the longer the maturity of the loan, the higher the risk
for a lender. As such, banks usually charge higher rates for long-term loans
compared to short-term loans, other things being equal.
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Example: As all loans will be linked to Base Rate, whenever a bank changes its
Base Rate, the loan rates of customers will change accordingly. Suppose Bank
Efficient has kept its Base Rate at 8 per cent. And the Bank Efficient has fixed
car loans at Base Rate plus 4 per cent (ie, 400 basis points), the car loan rate will
be 12 per cent (8 + 4). After a few months, Bank Efficient has revised the Base
Rate to 9 per cent, the car loan rate will be revised to 13 per cent (Base Rate
plus car loan premium = 9 + 4). Moreover, the Bank has got freedom to revise
the car loan premium. Depending on the market conditions and other
considerations, the Bank may decide to increase the loan premium to 5 per cent
from 4 per cent. Then, the car loan rate will be revised to 14 per cent (9 + 5).
Whenever RBI raises or lowers policy rates, banks are expected to revise their
interest rates in tune with the RBI. The intentions of RBI will be carried through
the commercial banks to the entire economy. Banks pass on the RBI’s policy
measures either by increasing the lending and deposit rates or by lowering them
in tune with the RBI’s policy measures. This is called Monetary Policy
transmission. But, this monetary transmission is not happening in actual practice
due to a variety of reasons. Banks usually respond with a considerable time lag
to the changes in RBI’s policy rates. Whenever RBI raises policy rates, it is
observed that banks raise their lending rates immediately. However, when RBI
lowers policy rates, banks act slowly and lower their loan rates with a substantial
time lag. Such downward stickiness in rates is creating problems for RBI in its
objectives of achieving price stability and growth.
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10. What type of customers can get loans at below Base Rate?
As stated above, there are a few exceptions to Base Rate rule which forbids
banks from lending below Base Rate. In the following cases, RBI has permitted
banks to fix rates without linking them to Base Rate:
RBI has decided to replace the BPLR with Base Rate to make credit
pricing more transparent
The biggest impact is that the new Base Rates from commercial banks will be
much lower than the existing Benchmark Prime Lending Rates (BPLR). Due to
heavy competition in the industry, some aggressive banks, whose cost of
deposits/funds is lower compared to industry levels, may peg their Base Rates
very low.
The new Base Rate System (BRS) is expected to impact the banks in different
ways depending on their cost of deposits, overhead cost, their customer profile,
geographical concentration and others. Likewise, the BRS will impact the debtors
in various ways.
One biggest benefit with the BRS as cited by policymakers and experts is that it
will help the Reserve Bank of India to transmit the changes in policy rates (Repo
and Reverse Repo under LAF) in a better manner. Under the BPLR, monetary
policy transmission is weak due to lack of transparency in BPLR. This has been
brought out elaborately by Deepak Mohanty Committee’s Report. Now, with the
BRS, RBI expects that banks will respond immediately to RBI’s policy rates.
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It remains to be seen how the Base Rate will impact the credit offtake. As of now,
credit growth is sluggish due to a variety of reasons. As banks will not be able to
lend below Base Rate, corporates will turn toward Commercial Paper route and
banks may not be able to lend their surplus funds in the short term. One piquant
situation may be that borrowers with ‘AAA’ rating will approach the markets
through the Commercial Paper (CP) route. Banks will invest in these CPs and
such lending through CP route will not be part of their ‘Advances,’ but part of
‘Investments.’
Alternatively, banks may be tempted to park their surplus with the Reverse Repo
window of the RBI’s LAF or invest in G-Secs or liquid schemes of mutual funds.
The Base Rate is made applicable by RBI to all scheduled commercial banks
(ASCBs) in India, except Regional Rural Banks (RRBs).
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Union Bank of India has hinted that it may set the Base Rate between 8.25 and
8.75 per cent. According to rumours, it seems HDFC Bank is likely to fix its Base
Rate at around six per cent. It may be noted that its Net Interest Margin has
traditionally been much higher at around 4.0 per cent. In fact, for the year 2009-
10, the net interest margin is 4.3 per cent for the bank. This is due to very low
cost of deposits, which is at 4.7 per cent for 2009-10.
Overall, the Base Rate range may be between six and nine per cent for most of
the commercial banks initially.
(The timeline for the evolution of PLR/BPLR system is given in Annexure III.)
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The Working Group has observed that whenever RBI raises policy rates and
reserve ratios, banks are quick to increase their loan rates. But, when RBI
reduces policy rates and reserve ratios, banks respond very slowly effecting
decreased lending rates with a considerable time lag. This is called downward
stickiness in rates. RBI has opined that this downward stickiness is adversely
impacting the monetary transmission mechanism in the banking system.
One of the major reasons for downward stickiness is the large share of deposits
(major portion consists of term deposits with fixed tenure) contracted at high
rates in the past. In response to RBI’s reduction of policy rates, banks are not in
a position to reduce their lending rates as their cost of funds will remain high for
quite some time during the early part of a declining interest rate environment.
The marginal cost of funds is more relevant for banks for pricing current
loans/advances rather than the average cost which is computed on the basis of
the cost of all outstanding purchased and borrowed liabilities reflected in the
balance sheet.
The new Base Rate System has received more brickbats than bouquets from
several industry watchers:
U.R.Bhat, Dalton Capital Advisors: “The prohibition from lending below the
base rate virtually bids goodbye to the principles of free market…Banks
may need to lend short-term to low-risk borrowers at rates below the Base
Rate depending on the market conditions…” (Economic Times, March 8,
2010).
Saurabh Mukherjea, Noble Group: “Seventy per cent of the Indian banking
system is in the hands of public sector banks. These banks’ profits will
come under pressure as the interest rate cycle moves north…Hence, by
diminishing the intensity of competition in the banking sector, RBI is taking
care of the interests of public sector titans like the State Bank of India and
Punjab National Bank…” (Outlook Profit, 2nd April 2010)
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The Base Rate System is only starting from July 1, 2010. The RBI has given a
cooling period of six months till December 31, 2010, which gives banks flexibility
to experiment with various calculation methods and Base Rates, before settling
for a particular method or a specific Base Rate. As such, the system will evolve
over a period of time.
We can definitely expect some more changes to the Base Rate System once RBI
gets a feel of the new system. Banks have been smart players and they have
been making good profits notwithstanding the global financial meltdown of 2008
and the wild movements in interest rates.
It is expected that banks will be able to protect their margins despite the Base
Rate System, unless more banking licenses are given by RBI/Government.
India’s Telecom Sector has witnessed intense competition in the last two to three
years and this has benefited the customers immensely due to steep reduction in
telephone tariffs. The competition in Telecom Sector has widened the market
base and this has brought higher revenues for the Government in the form of
service tax, corporate tax and income tax.
Can we expect that the same thing will happen in the banking sector?
It may not happen in banking sector until more banking licenses have been
issued to both the private sector and public sector players. In this backdrop, it
remains to be seen whether the twin objectives of RBI of bringing in better
transparency and improved monetary policy transmission will be achieved.
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ANNEXURE I
(i) to review the concept of BPLR and the manner of its computation;
(ii) to examine the extent of sub-BPLR lending and the reasons thereof;
(iii) to suggest an appropriate loan pricing system for banks based on
international best practices.
1. The concept of BPLR is outdated and is out of sync with the present
market conditions
2. BPLR system is not very effective in achieving the objectives of RBI in
terms of monetary policy transmission
3. BPLR system lacks transparency
4. Due to distortions in the BPLR, banks were lending at rates much below
the BPLR thus defeating principles of commercial judgment
5. A new system called BASE RATE should be introduced replacing the
existing BPLR
6. Base Rate would be based on the following:
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10. Base Rate System would be applicable for loans with maturity of one year
and above (including working capital loans)
11. Banks may give loans for periods of less than one year at fixed or floating
rates without reference to Base Rate subject to certain conditions. In this
regard, the Committee has recommended certain ceilings for such sub-
Base Rate lending.
12. Base rate shall be the basis for floating rate loans also. Banks may use
Base Rate or any external market-based benchmark rates (like, G-Sec,
Repo rate, MIBOR, CP, CD etc).
13. At present, the Government administers loans of up to Rs 2 lakh to small
borrowers, under priority sector and others. This administered regime shall
be discontinued and these loans can be brought under the Base Rate
system.
14. Interest rate on rupee export credit should not exceed Base Rate
15. Educational loans should be given a special exemption and they should
continue to be administered. Interest rate on educational loans should not
exceed Base Rate plus 200 basis points.
16. Banks should pass on the information about Base Rates to the public
through their websites
ANNEXURE II
Base Rate = a + b + c + d
Uc
c = Unallocatable overhead cost = ------ x 100
Dply
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NP NW
Where,
NP = Net profit
Negative carry on SLR and CRR: At present, SLR is 25 per cent and CRR is 6
per cent. CRR balance does not provide any return to banks; while the return on
SLR balance is lower than the cost of deposits. As such, SLR and CRR carry
negative returns for banks.
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ANNEXURE III
Early 1990s
Till the early 1990s, deposit and lending rates were mostly administered by RBI. In the early
1990s, RBI started deregulating deposit rates and lending rates.
October 1994
Lending rates for loans with credit limits of over Rs. 2 lakh deregulated. Banks were required
to declare their Prime lending rates (PLRs).
February 1997
Banks allowed to prescribe separate PLRs and spreads over PLRs, both for loan and cash
credit components.
October 1997
For term loans of 3 years and above, separate Prime Term Lending Rates (PTLRs) were
required to be announced by banks.
April 1998
April 99
October 1999
Banks were given flexibility to charge interest rates without reference to the PLR in respect of
certain categories of loans/credit.
April 2000
Banks allowed to charge fixed/floating rate on their lending for credit limit of over Rs.2 lakh.
April 2001
The PLR ceased to be the floor rate for loans above Rs. 2 lakh.
Commercial banks allowed to lend at sub-PLR rate for loans above Rs.2 lakh.
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April 2002
A system of collection of additional information from banks on the (a) maximum and minimum
interest rates on advances charged by the banks; and (b) range of interest rates with large
value of business and disseminating through the Reserve Bank’s website was introduced.
April 2003
In place of PLR, RBI announced introduction of a new system called Benchmark Prime
Lending Rate (BPLR). The Reserve Bank advised banks to announce a BPLR with the
approval of their boards. The BPLR was seen as a reference rate and was to be computed
taking into consideration (i) cost of funds; (ii) operational expenses; and (iii) a minimum margin
to cover regulatory requirements of provisioning and capital charge, and profit margin. The
system of tenor-linked PLR discontinued.
ANNEXURE IV
SOURCES:
RBI website
Deepak Mohanty Committee’s Report of the Working Group on study of BPLR
Economic Times, Business Line, Outlook Profit, etc.
DISCLAIMER: The views are personal. The views need not be construed as those of the
organisation which the author represents.
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