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Vijaya Kittu, M., & Aruna, Polisetty. (November 9, 2018). National Conference on Non-Performing Assets – Disclose or Dispense:
ABSTRACT
Indian banks have a dual challenge of dealing with bad loans on one hand and hurrying to be fully BASEL III compliant on the
other. Both the Reserve Bank of India (RBI) and the Government of India are using various approaches over the past two decades to
help banks. Several different experiences are obtained by domestic and global banks in handling the non-performing loans (NPL)
problem. Yes Bank Limited is India’s 4th largest private sector bank. It has the industry-best NPA ratios and is renowned for its best
practises in the banking industry. Can risk management practices and focus on asset quality help banks maintain loan quality and even
stop loans from not slipping into the vicious Non-Performing Asset (NPA) cycle?
Data from quarterly & annual reports and other reports is collected to understand management philosophy and asset quality
dimensions such as NPA ratio, provisioning coverage ratio, concentration of NPAs, priority sector lending and restructuring of accounts.
As the bank evolved from a mid-size bank into a large-size bank in the last 14 years, it gives an opportunity to pose the question - Will
NPA size increase as bank transformed from a mid-sized bank to a large bank? Will knowledge-driven sectoral approach to assist
customers in their business by lending and offering industry specific financial solutions help the bank? Can technology be used to predict
JEL CLASSIFICATION
G21, G28
KEYWORDS
Non performing asset, non performing loan, asset quality, risk management, knowledge banking, indian banks, banking in india, npa
ratio, provisioning coverage ratio, npa concentration, priority sector lending, gnpa, nnpa
Asset Quality & Risk Management Practices - An Analysis on Yes Bank 2
INTRODUCTION
Banking and finance businesses involve lending and bad-loans are an inevitable part of this. India committed to follow common
set of global banking standards by signing the Basel Accord. The Basel III is the latest evolution in the banking regulation and focuses
on capital, leverage and liquidity to handle banking crisis and ensure financial stability. A sound capital base for a bank requires cleaning
up of balance sheet by managing bad loans and India needs to do this quick so as to meet the March 2019 target of Basel III
implementation across all banks. A loan is an asset to the bank because it bring in income. Bank assets are classified into four types –
Standard asset (performing asset that continue generating income and repayments as and when they fall due), sub-standard asset (asset
not performing for up to 12 months), doubtful asset (assets not performing for more than 12 months) and loss asset (asset which are
irrecoverable either by the bank or the internal/external auditors or by the RBI inspection team). While “12 months” here is more like a
global standard, RBI is actively tweaking the period to lesser timeframes (such as 90-days) to speedup India’s move to international
norms (Sikdar & Munish, 2013). The NPA norms are uniform for all advances including Government-guaranteed accounts. However,
Non-Performing Assets (NPA) is an asset that is no longer performing and ceases to generate income in the form of interest or
principal repayment. Because money gets locked (or lost), NPA affects credit rotation and credit creation and thereby became a dent to
the banking system and negatively impacts the economy. NPA has two variants – GNPA and NNPA. Gross NPA (GNPA) is sum of
advances defaulted for a period of 90 days. These ‘almost bad’ loans are still held in the book of accounts but cease to generate income
to the bank. Over time, it might so happen that the banks may not be able to timely recover the entire amount being lend and hence have
to do necessary provisioning. Net NPA (NNPA) is obtained by deducting provisions from the defaulted loans and an actual loss is
reflected in the books. Sensing NPA as a national priority problem, Government of India and central banker Reserve Bank of India
(RBI) are taking several attempts to help banks tackle the problem.
APPROACHES SO FAR
The level of NPAs has now become a bank assessment metric for measuring credit risk, asset quality and efficiency in allocation
of resources. RBI statistics says that Indian GNPA numbers are alarming compared to the US and other Asian countries but Indian
NNPA are better compared to global numbers because of the strict provision norms prescribed by Narasimham and Verma Committees
(Narasimham, 1991, 1998). Prudential norms and provisioning requirements made banks make provisions and to pro-actively clean-up
their balance sheets. DRTs, Lok Adalats and Securities and Reconstruction of Financial Assets and Enforcement of Securities Interest
Act, 2002 (SARFAESI Act) mechanisms are introduced but with limited success. RBI’s Corporate Debt Restructuring (CDR) Scheme,
2001 allowed a case-by-case restructuring of debt given to firms but this largely failed and very few companies were able to turn-around
and exit successfully. SARFAESI is a bold step towards handling NPAs but loan defaulters went to courts to put a break to its
enforcement. The Strategic Debt Restructuring (SDR) allowed banks to take the majority shareholder seat by making the companies
convert debt into equity. The variant Sustainable Structuring of Stressed Assets (S4A) scheme allows banks to convert unsustainable
debt to equity/quasi equity instruments. Yet another variant, the 5:25 scheme gave a longer time frame for the parties to deal with the
situation and the debt is structured so that more time will be given to the defaulter while the banks can preserve the loan at its net present
Much of the debts that corporates are unable to repay today have originated in the min-2000s when companies came out with
ambitious capex plans. Bank credit have doubled over a span of just three years (FY05 to FY09). The then RBI Governor Raghuram
Rajan has sent a letter to Prime Minister's Office (PMO) highlighting "high-profile fraud list" during 2006-08 that could potentially
become NPAs. He cited that over optimism of bankers, slowdown in global growth, a slow decision-making by Central Government,
malfeasance and frauds as the main reasons for the build-up of the trouble. Even the 2008-global financial crisis could only give a small
pause for this. Between FY10 to FY14, debt pace increased only to pause between FY14 to FY16 and again gain speed from FY16. The
2015 RBI Asset Quality Review (AQR) has unveiled some banking practises such as round tripping of funds, short term OD to repay
and then fresh loan to repay OD, sale of assets within group, inflating rates, same lenders, devolved L/C, late adjustments, changing
loan from non-fund based to fund based, drawing power manipulations etc. RBI turned strict and forced banks to do a regular clean-up
of books and handle the NPA issue so that banks can appear “evergreen”, at least on books. The Government feels that recognizing
The introduction of Insolvency and Bankruptcy Code (IBC) is yet another attempt to give legal strength. The RBI referred 12
big defaulters and several small defaulters to the National Corporate Law Tribunal (NCLT). With IBC in force, RBI, on Feb 12, 2018
introduced an important circular withdrawing almost all debt restructuring schemes in force - CDR, SDR, S4A, Flexible Structuring of
Existing Long Term Project Loans. Even the Joint Lenders Forum is disbanded. RBI directed all banks to initiate a resolution plan as
soon as they witness payment delays starting March 1 and this means that banks need to go for out-of-court settlement for all accounts
over Rs 2,000 crores within 180 days. Failure to do so will mean the account will be referred to National Company Law Tribunals
(NCLTs) for insolvency action, within 15 days after the completion of the deadline. This forced banks to quicken the resolution process
so as avoid large haircuts or loan losses. The move has fastened the recognition, justification, restructuring, resolution, or recovery of
bad loans as the case may be. The June 2018 Financial Stability Report by RBI shows that as many as 701 cases are admitted for
resolution. As many as 70 cases (30 in power sector alone) got ready for IBC. However, some companies, particularly from Power,
Sugar and Shipping sectors, went to the Supreme Court of India (SC) in September 2018. The SC directed banks not to refer cases to
NCLT and transferred all cases challenging the RBI circular to itself and posted them for hearing in November 2018 adding more
uncertainty and delay to the issue. The breather gave banks like SBI which, along with other lenders, is attempting to resolve 7 to 8
stressed power assets. Another development is that the Government decided to merge Bank of Baroda, Dena Bank and Vijaya Bank.
Earlier during the year, SBI and its associated banks are merged so that a “mega bank” gets created. India Ratings said that the merger
of banks could raise NPAs in the short run because slippages will increase as recognition of NPA is “harmonized and accelerated” but
results in better efficiency going forward. The Ministry of Corporate Affairs quickly stepped in and announced it will use the Special
Courts approach to deal with Insolvency Cases which are likely to be set up by November 2018.
While IBC is still getting absorbed into the Indian banking system, it is apparent that the results are coming in slower than what
the Government expected. Added to this, both banks and defaulters feel that this “resolution system” is a lose-lose for them because
both of them have to part off a bit if they go under IBC. The recent Project Shashakt is a follow-up to IBC and suggests setting up an
Asset Management Company (AMC) (“Bad Bank”) to take over all bad debts with funding probably from Alternative Investment Funds
(AIF). The Pariwartan (Power Asset Revival through warehousing and Rehabilitation) scheme is designed to handle power projects
debt. The AMC approach of handling bad debt was used by different countries for different goals as seen in Mexico (1994), the
Philippines (1981-86), Spain (1977-85), the US (1984-91), Finland (1991-94), Sweden (1991-94), Japan (1991), Korea (1997), China
and Indonesia. Countries such as Norway (1987-93), Argentina (1980-82), Chile (1981-86), Thailand (1997 onwards) and Poland (1992-
95) used creditor-led restructuring method, which India wishes to try. Apart from the “bad bank” approach, another strategy India is
Asset Quality & Risk Management Practices - An Analysis on Yes Bank 4
considering is to change its way of handling loans by creating three buckets - SME loans (less than Rs 50 crore), Mid-sized loans
(ranging from Rs 50 crore to Rs 500 crore) and Large loans (over Rs 500 crores).
LITERATURE REVIEW
One of the earliest studies on non-performing loans (NPL) done on 2,470 US insured commercial banks found that those taking
greater risk tend to make higher losses (Keeton & Morris, 1987). Studies on Taiwanese commercial banks have shown something similar
to what experience in India. For example, the study found that banks with higher government ownership have actually recorded lower
NPLs. It says that bank size is negatively related to NPLs and that larger the size of the bank lesser the NPLs (Hu, Li, & Chiu, 2004).
Another study confirmed that and went on to say that private Taiwan banks are more productive but less efficient in NPL management
compared to public sector banks (PSB) (Liang, Yao, Hwang, & Wu, 2008). But when to comes to Indian NPAs, a study on public and
private sector banks between 2005-06 to 2014-15 found that Indian banks are still not comfortable at NPA management and that HDFC
Bank is better over other banks in the area. The paper went on to make some suggestions to avoid future NPAs and to manage existing
NPAs (Neha, 2016). NPA reduction steps of PSBs appears satisfactory between 1997-2002 but failed for private sector banks, even for
Both bank-specific and macro factors are responsible for NPLs (Bercoff, Giovanniz., & Grimardx, 2002). Macroeconomic
conditions (such as global economic situation, GDP growth, domestic demand, government policies, real effective exchange rate
(Khemraj & Pasha, 2009)) and financial factors (cost and terms of credit, contract terms, bank size, credit orientation etc.) influenced
NPLs in India (Ranjan & Dhal, Winter 2003). NPAs act as an indicator of credit risk & efficiency of allocation of resources. A continuous
high interest rate period for 18 months has increased NPA levels sharply and this impacted the economy in general and the banks in
particular (Pooja, 2012). Digging deeper, a study found that the percentage of Gross NPA to Gross advances is increasing for public
banks and ratio of Loss Advances to Gross Advances are higher in foreign banks. The Estimated Gross NPA for 2014 is also more in
public banks as compared to private and foreign banks and that Ratio of Gross NPA to Gross Advances for public sector, private Sector
and foreign Banks does not have significant difference between 2009 to 2013 (Mayur Rao & Ankita Patel, 2015).
RBI gave two NPA controlling strategies – Preventive (to prevent from an asset becoming an NPA) and Curative (maximize
recoveries so that banks funds locked up in NPAs are released for recycling) management strategies (Prasad & Veena, 2011). A study
found that bank managers can monitor and improve their asset quality improve their asset quality continuously over time by monitoring
amounts advanced and corresponding NPAs over a periodic basis (Rajveer, Shwetha, & Pradeep, 2012). Statistical studies have proved
that the early warning signs as suggested by RBI, such as Financial, Operational, Banking, Management and External Risks does work
Funds that got blocked in GNPAs are huge. A sector-wise analysis of NPAs shows that the proportion of NPAs in percentage
terms for the priority sector loan has been increasing compared to non-priority sector and that asset quality improved considerably by
reducing NPAs with respect to public sector. (Hosmani & Jagadish, 2011).
Established in 2004 as a mid-size private bank, Yes Bank is a “full service commercial bank” and has grown up to become the
fourth largest private bank in India. It is the only greenfield bank licence winner in the last two decades from the RBI (institution with
entirely new setup i.e. obtained commercial bank license without any prior exposure to financial business). The bank has best-in-class
NPA numbers and attributes it to its prudent risk management & asset quality functions. Other attributes such as its unique knowledge
Asset Quality & Risk Management Practices - An Analysis on Yes Bank 5
banking initiatives, technology & strategic partnership etc. are studied. Studying these aspects can give us better insights on the
functioning of the bank and can potentially help other banks to pick a que from this thereby keep bad loans under control.
METHODOLOGY
We used Exploratory Research Methodology by collecting secondary data from the bank Quarterly & Annual Reports. (Yes
Bank, 2005-18) and from websites of the bank, RBI and BSEIndia.com. We tried to understand the risk management attributes by
studying how it is practised at the bank. Asset quality numbers are being collected over years and an analysis is done to determine how
RISK MANAGEMENT
Risk is defined as the exposure to danger, harm or a loss. Banks, being lenders of money, are in the business of managing risk
and need to have a robust risk management system so as to get financial stability and bring value to stakeholders. Risk management is
put into core values of Yes Bank and is top-down and bottom-up driven. Risk is kept in mind at three levels – in doing business (credit
risk, market risk, liquidity risk), in conducting business (operational risk) and zero tolerance risk (compliance risk). It is put into various
processes in the form of filters and processes for early warning signals, by way of communication so that proactive actions are taken
and by regular employee training. While all employees are responsible for managing risk, the accountability is put on the Board of
Directors. The board reviews and approves threshold levels of risk periodically and in accordance to the bank objectives. Various teams
foresee Risk Appetite and Risk Limits so that thresholds are not crossed.
Yes Bank believes that ‘risk management is an art’ and hence gives high importance to board and management architecture
stressing that they have to be given powers and made accountable for risk management. Five Board-level sub-committees look after risk
management and are responsible for framing policies, frameworks and systems. These include: Risk Monitoring Committee (RMC),
Audit Committee (AC), Fraud Monitoring Committee (FMC), Board Committee on Wilful Defaulters & Non-Cooperative Borrowers
and Board Credit Committee (BCC). The culture is such that risk identification, appraisal and appropriate time-bound initiatives to
RMC is responsible for preparing policies, frameworks and systems and ensures they are periodically updated. The Chief Risk
Officer (CRO) leads the Credit Risk Unit. Credits are approved by joint delegation and require two or three approvers jointly approving
the proposal. A proprietary model built with the help of a reputed credit rating agency is being followed to carry the appraisal process
which rates customers based on various parameters. Scorecard approach is followed for Retail and SME borrowers. Loan sanction is
done after due diligence adhering to bank credit policy and other regulatory guidelines. Periodic monitoring activity is taken up by a
dedicated team and the ‘Portfolio Analytics Unit’ (PAU) to monitor the loan. PAU provides reports covering various credit quality
indicators, gives early warning signals, identifies portfolio trends and portfolio-level MIS analytics. The market risk systems regularly
ASSET QUALITY
Bank Asset Quality speaks about its loan portfolio quality and the credit administration processes being followed. This includes
quality of loan, securities and other items such as real estate and other off-balance sheet items. According to RBI Master Circular on
Disclosure in Financial Statements (Reserve Bank of India, 2015), banks need to disclosure their asset quality information under 5 broad
heads. This new reporting standard has forced banks to report data more accurately and give a true and fair picture of the state of affairs
of the bank. We analysed data from the above the quarterly and annual reports of the bank from the above heads and tried to interpret
them.
Asset Quality & Risk Management Practices - An Analysis on Yes Bank 6
NPA information is a useful aid in analysing asset quality of a bank, particularly when the information is timely (Meeker &
Gray, 1986). As can be seen from the GNPA and NNPA data, Yes Bank has best in class numbers on both counts.
NPA RATIO
The Net NPA to Advances (Loans given) ratio is a useful metric that speaks about overall quality of a bank’s loan book. The
Net NPA is calculated by subtracting cumulative balance of provisions outstanding at the end of a period from Gross NPAs. In general,
At Yes Bank, the NPA Ratio is contained between 2009 to 2014 but has gradually worsened from 2014 to 2018.
PCR
Provisioning is an RBI prudential regulation norm in which banks have to ‘provision’ (set aside) funds to a prescribed percentage
of their bad assets. The percentage of bad asset that are provided for is called Provisioning Coverage Ratio (PCR). This is a good tool
to determine the extent to which the bank has provided against the troubled part of its loan portfolio. This ratio helps us to determine
relation between current provision balances to the Gross NPA. PCR differs according to the asset quality. When an asset cannot be
recovered, and is lost forever, it will be categorized as a ‘loss assets’ and hence banks have to set aside 100% of such loss assets out of
its profit and if sufficient profits are not there, it eats up the capital impacting capital structure and thereby leading further reparations.
At Yes Bank, PCR has come down from 89% in 2009 to 50% in 2018. The bank says it will strive to maintain PCR > 60% by
March 2019.
CONCENTRATION OF NPAS
One more metric for evaluating bank asset quality is its total exposure to top four NPAs. Contrary to the popular perception,
stress in the banking system is not due to priority sector but restructuring is mostly happening because of large accounts (Mundra,
February 11, 2016). The exposure includes both fund and non-funded exposure. For Yes Bank, the NPA concentration is almost flat till
2014 but has grown exponentially since then and taken a small dip from 2017 to 2018.
DIVERGENCE
RBI felt that banks are under reporting bad loans because banks feel that the loans could be brought into order at a later point of
time during the financial year. In order to bring about transparency and get a true and fair picture about bad loans, RBI issued a circular
on April 18, 2017 insisting that all commercial banks report divergence if the difference between the Bank’s estimate and the RBI
assessment in regard to NPA, Asset Classification, Capital Adequacy Ratio and Provisioning is more than 15%. This data has to be
reported in the subsequent financial report and adequate provisioning be made. This additional reporting is helping banks and RBI to
Several banks including Yes Bank, Axis Bank, ICICI Bank and even SBI have reported eyebrow-raising divergence numbers.
Divergence has become so common place in bank financial reporting that a new financial term – ‘Divergence Ratio’ got evolved (Dugal,
2017).
Asset Quality & Risk Management Practices - An Analysis on Yes Bank 7
When questioned, banks are saying the numbers belong to fiscal 2016 and are likely to have got fixed during fiscal 2017. The
statutory audit takes a sample of accounts that the bank provided while the RBI inspection audit takes a random sample. Meanwhile, the
Institute of Chartered Accountants of India (ICAI)’s Financial Reporting Review Board (FRRB) has written to RBI for more
information. The ICAI Disciplinary Directorate said it is ready to take an action if RBI files a complaint. The annual bank audit process
is done by auditors who are empanelled by RBI through ICAI. The banks appoint the auditors from the list sent by RBI. The audit
process is governed by RBI circulars and ICAI guidance notes. The auditors are responsible for full verification of all NPA advances
Further, if a loan account is a standard asset according to one bank, he would have defaulted with another bank and now RBI
wants even that good account to be treated as an NPA. If FY16, Yes Bank reported Gross NPAs worth Rs 748.9 crore while RBI wanted
to report this at Rs 4,925.6 crore. For FY17, Yes Bank gave Advances of Rs 1,32,262.68 Cr, it reported Gross NPA at Rs 2,018.60 Cr
while the Divergence reported is at Rs 6,355 Cr. The Divergence / Advances is at 4.8% while the Divergence / Gross NPA is at an
alarming 315%! These high divergence gaps have irked investors and so the bank stock experienced a quick downward dip. In regard
to Q2 FY17 data, Rana Kapoor, MD and CEO of Yes Bank said this is “temporary setback on asset quality” and that banks had absorbed
the full impact of the divergence in the second quarter itself. RBI penalized Yes Bank to a tune of Rs. 6 crores for “violations of various
regulations issued by RBI in the assessment of NPAs.” amongst others. Fortunately, for Yes Bank, there were no fresh slippages in
quarter ending March 2018 because as many as 10 of the 19 companies identified in RBI divergence report are being upgraded. Added
to this, the bank is foreseeing very minimal impact on its loans if they are to be taken to NCLT.
Finally, when the bank sought extension of the tenure of Rana Kapoor, RBI rejected it and gave the deadline of February 2019
for the bank to find a suitable successor and industry grapevine is that NPA divergence issue is a strong reason for this (ET NOW, 2018).
Change in top management of the bank adds to uncertainty to its guided strategy.
KNOWLEDGE BANKING
In order to understand customer banking needs better, the bank introduced new and innovative products using its unique
Knowledge Capital & Knowledge Banking concepts. The bank is taking help of domain experts to constantly gathered industry insights
and disseminate it in the form of research reports to its customers. Customers include top corporate houses, emerging corporates and
MSMEs. This focus helped it gain domain knowledge and thereby build sector-specific products to sunrise growth sectors like Food &
Agribusiness, Life-sciences etc. Separate divisions, such as the Food & Agribusiness Strategic Advisory & Research and Government
Strategic Initiatives & Advisory, are formed to work with stakeholders in the respective areas.
SIZE OF BANK
There is mixed empirical evidence in regard to impact of size of bank on NPA. Different studies used different bank size
measurement metrics such as balance sheet size / total assets, capital, bank deposits, market share of the asset or may be on its market
capitalization. Some studies said that larger banks have better risk management strategies and resources and hence will have superior
quality loan portfolio compared to their smaller counterparts (Hu, Li, & Chiu, 2004) (Ranjan & Dhal, Winter 2003) while others said
that large banks are not necessarily effective in screening loans compared to smaller banks (Khemraj & Pasha, 2009).
Yes Bank was established in 2004 and got listed on stock exchanges in May 2005 as a mid-size private bank. In 2014, its balance
sheet size crossed the Rs 1,00,000 crore mark thereby turning it into a large-size bank. As can be seen from the GNPA and NNPA data,
OTHER ATTRIBUTES
Technology advancements helped rapid information exchange allowing banks to implement international best practises.
Extensive use and understanding of technology helped Yes Bank to evolve from a “typical bank that outsources its IT needs” into a
“global banking technology leader”. The bank is a pioneer and a global leader in areas like supply chain financing using Blockchain and
API (Application Program Interface). The bank uses ART of Banking (Alliances & Relationships with underlying Technology).
Together with partners, the bank has introduced innovative features that enhance process efficiencies to mitigate operational risk and
provide sector-specific banking solutions. Its strategic relationships, such as with Agricultural Insurance Company for agriculture
insurance, Max New York Life for life insurance, helped it built platform for mutual benefit.
CONCLUSIONS
The Government of India and the RBI have taken up the task of cleaning up the bank balance sheets on a priority basis. Several
approaches have been used in dealing with loans and the IBC and AMC concepts are major steps towards this. This study felt that
continuous monitoring of risk management, asset quality (GNPA & NNPA status, NPA Ratio, PCR, Concentration of NPAs and
Divergence) and knowledge banking, size of bank and other attributes are actually helping the bank to be with manageable NPA figures.
Volatility in asset quality and larger divergences are a cause of concern and negatively impacted the bank’s stock price.
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