Indian Securities Depository System: What Has Gone Wrong?

Author(s): L. C. Gupta and Naveen Jain

Source: Economic and Political Weekly , May 17-23, 2003, Vol. 38, No. 20 (May 17-23,
2003), pp. 1969-1971+1973-1974
Published by: Economic and Political Weekly

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 Indian Securities Depository System
What Has Gone Wrong?
Unknowingly and unintentionally, the share depository system is adversely affecting
millions of small investors and also hurting the equity market's growth by causing such
investors to gradually withdraw from the market. This paper attempts to explain
how this has come about and what corrective action is needed.

L C GUPTA, NAVEEN JAIN

and to continue holding paper certificates but this leaves them o

the horns of a dilemma (see below). Also, about 40 per cent
Emerging Problem Areas
listed companies, mainly the smaller ones, have not joined
W hile the depository system eliminates many irritating depository system but, as the traditional trading system has bee
problems and costs (like back-and-forth transmission
almost dismanatled in haste, the shareholders of such compan
of millions of physical share certificates, bad deli-
are also suffering. This has created serious difficulties for mid-si
veries, shares lost or stolen in transit, delay in share and
transfer
small companies in tapping the public market for capital.
registration, etc), it has created some new problems which thesehave
aspects are not being given proper consideration by poli
hurt most of the small investors. As we shall show, the small
makers and regulators concerned with the capital market.
long-term investors are finding the system so costly that they
Empirical data about ordinary investors' attitude towards depo
are tending to quit the equity market in large numbers. toryThe system and its spread among such investors has beco
depository system has belied the expectations raised by it.available
Around through a recent Household Investors Survey organi
the time when the Depositories Act was enacted in 1996 by the Society for Capital Market Research and Developme
to enable
(SCMRD),
the creation of a depository system, the official expectation from jointly with Vivek Financial Focus.4 Our main co
the new system of dematerialisation of securities was expressed
clusions are derived on the basis of this new data, as present
by SEBI in the following words: later in this paper. The sample households covered by the sur
It is expected that as the network of depository participantsrepresent
expands, a wide cross-section of the middle class investors. Det
about the composition of the sample, in terms of income-classw
and the proportion of securities dematerialised in the depository
agewise,
increases, the benefits of reduced risk and lower transaction costs occupation wise and statewise distribution of samp
household,
will extend to the vast majority of market participants and lead is shown in the Appendix Tables Al to A4.
to improved investor protection and service.1 (emphasis added.)
The truth is that the 'vast majority of market participants' have II
been cheated by the depository system. Depository System's Overall Structure in India
The securities depository system was introduced in India towards
Compulsory Demat Needs Reconsiderationthe end of 1996 with the creation of the National Securities

A point to be noted is that share depository serviceDepository

has un- (NSDL) under the sponsorship of IDBI, UTI and N
fortunately not evolved in India as a voluntary commercialSubsequently,
service, in February 1999, a second depository, ca
to be priced attractively for the users but as a compulsoryCentral Depository Services (India) (CDSL), was sponsored
bureaucratic requirement prescribed by SEBI for tradingthe Bombay Stock Exchange. The SEBI Working Group
shares.2
Making demat compulsory and allowing the depositories framework
to for a Depository System, mentioned above,
envisaged a competitive system of multiple depositories bec
exploit their near-monopolistic position by charging whatever
in the
fees they like, is nothing but robbing of the small investors. ThisGroup's opinion, it would be too risky to have a si
is pushing the small investors out of the equity market. depository
Demat in the initial stages (Para 10 of Group's Report).
has never been compulsory in the US. The Working Group, Depositories
set Act 1996, recognised the competitive principl
up by SEBI in 1994, on the legal framework of a depository keeping
system the door open for multiple depositories.
for India,3 had envisaged that "it would be optional for However,
an the bulk of the depository system in India cam
investor to hold and transfer the securities through orbe controlled by NSDL, because, during the period from
outside
vember 1996 up to February 1999 SEBI made trading thro
the depository", although, in long run, the bulk of the securities
depository compulsory and NSDL was the sole depository at
may be held in the depository form. The group also recognised
that "in many cases, investors would be residing at a placetime.
whereThis gave NSDL monopoly power by placing any l
no depository facilities are available and a small investorentrant,
might like CDSL, at enormous disadvantage. The CDSL c
find it costly to transfer the shares through depository." garner only the 'left over' depository business because switc
from one depository to another is too costly to be workabl
Empirical data on the extent of acceptance of the depository
practice.
system among ordinary investors reveals that a vast majority of In this paper, we shall mostly refer to NSDL bec
of its
middle class shareowners in India have preferred not to go for dematdominant and determining role in evolving the syste

Economic and Political Weekly May 17, 2003 1969

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depository charges. For example, when NSDL initiated a change they pay to NSDL. Many DPs levy several miscellaneous ty
from ad valorem principle to flat rate system in April 2002, the of charges too, such as courier charges, interest and penalt
CDSL had to willy-nilly follow. minimum cash deposit with the DP, etc.
The NSDL levies certain fees from Depository Participants The system of DPs' charges to the investors are a virtual jung
The charges differ a great deal, both with respect to the he
(DPs), who are its agencies for providing depository services to
investors. The investors have direct contact only with the DPs
under which they are made and also with respect to the l
and no contact at all with NSDL. of charges. For this reason, the investors have great difficu
in comparing
Around April 2002, the NSDL changed the basic principle for the charges of various DPs to find out the low
charges
charging fees for the various depository services. Its on overall basis. This makes the whole system v
charges
under the old as well as the new system are shown in opaque
Exhibitand
1. obstructs competition. A few actual examples of
How the new system has affected small and big investors varietywill
of DPs' charges are shown in Exhibit 2. These were pi
be explained a little later by a practical example. Theup from
NSDL hasNSDL's site.
laid down a uniform scale of charges payable by all the DPs for
certain specific depository services (like custody of shareholding, Ill
transaction settlement, pledge creation, etc). In addition, NSDL Inequity of NSDL Charges
collects a blanket or lump sum 'annual fee' from each DP.
The NSDL leaves DPs completely free to decide in what manner
A Fundamental Shift in Depository Charges
and how much they will charge to the investors for the depository
services. Most DPs charge for account opening, account Sincemain-
its inception up to around April 2002, NSDL was fol-
tenance, custody, transaction settlement, pledge creation and
lowing the ad valorem principle for all its fees for each specific
closure, etc. The DPs have to charge to investors substantially
depository service (see Exhibit 1). The new system of its charges
more than what the NSDL charges to DPs in total because
has thrown DPs
out the ad valorem principle and adopted flat rates
have to recover their own operational expenses, besides the fee in custody, per transaction settled, per pledge
per shareholding
created, etc, irrespective of the value involved. How the revision
has affected the small and big investors is brought out in the
Exhibit 1 following example.
NSDL's Old and New Fee Structure

Fee Type Old Rate of Fees New Rate of Fees A Practical Example
Custody fee 0.01 per cent Rs 6 per annum per
total holding in a company Under the old system, NSDL annually charged a custody fee to
Transaction fee 0.02 per cent Rs 10 per transaction DPs at the advalorem rate of 0.01 per cent of the value of each
(Charged to seller only) (Charged to seller only)
distinct shareholding in one company. Its revised custody fee is
Pledge creation 0.01 per cent Rs 25 per instruction
Pledge closure 0.01 per cent Abolished a flat rate of Rs 6 per holding in one company, irrespective of
Pledge invocation 0.02 per cent Abolished whether the value of the holding is Rs 10,000 or Rs 10 lakh or
Securities 0.02 per cent Rs 25 per instruction
Rs 10 crore. Thus, whereas earlier, NSDL's annual custody fee
borrowing (0.04 per cent
>3 months) for a small shareholding of, say, Rs 5,000 in a company was only
Rematerialisation 0.02 per cent or Rs 10 per certificate Rs 0.50, (i e, 50 paise at 0.01 per cent of Rs 5,000), the new
Rs 10 per Certificate,
whichever higher
system has raised the same to Rs 6, i e, 12 times of the earlier
Annual fee Rs.1 lakh (min) and Rs 1.5 lakh charge. On the other hand, for a large shareholding of, say, Rs 5
Rs 5 lakh (max) lakh in a company, the custody fee has been reduced drastically
Source: NSDLwebsite. by 88 per cent, i e, from Rs 50 under the old system to just Rs
6 under the new flat rate system; for a still larger shareholding of
Rs 1 crore, the annual custody fee has been reduced from Rs 1,000
under the old system to just Rs 6 under the new system, i e, a
reduction of 99.4 per cent. The NSDL seems to have completely
Exhibit 2 lost sight of the equity principle and the needs of small investors.
Charges Made by a Sample of DPs to Investors
Losers and Gainers
(a) Advance deposit of Rs 1200 (valid for 2 years) and account
maintenance charges of Rs 600 pa but no other charges.
(b) Transaction charge 0.04 per cent (min Rs 20) + NSDL's settlement The losers from the revision of NSDL's custody fees are th
charge. small and medium-sized investors, and the gainers are the b
(c) Transaction charge 0.04 per cent (min Rs 20).
(d) Transaction charge 0.02 per cent (min Rs 10) + NSDL settlement investors and big market operators. Presumably, the NSDL saw
charge. an easy opportunity for securing a huge increase in its profit
(e) Rs 15 per transaction + NSDL settlement charge. as it was in a monopoly position. The number of small investor
(f) Transaction charges Rs 16 for value up to Rs 1 lakh and 0.02 per
cent if value exceeds Rs 1 lakh who were effectively locked in by NSDL, runs into millions a
(g) Account maintenance charge on slab basis. hence the profit realised by NSDL from the higher custody a
(h) Account maintenance charge is found to vary among DPs from zero
transaction fees charged to small investors will, on a rough
to Rs 450 per annum, the most common range being Rs 200-300.
(i) Some DPs demand security deposit. estimate, be around at least half a billion rupee. Switching
(j) Some DPs have a policy of cross-selling among their associated
CDSL, which makes no custody charge, was not practicable f
businesses by giving discounts to the favoured customers.
these investors because of high costs of switching. On the oth
hand, the number of large investors is only a few thousands a

1970 Economic and Political Weekly May 17, 2003

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hence the reduction in the fee realisation from these will be a all income-classes and age-classes are long-term oriented
relatively small amount. On balance, the NSDL will be making shareowners. This is indicated by two sets of data collected
through the survey. One set was based on the expression of
for itself a huge profit at the cost of lakhs of small investors.
The SEBI had appointed a committee in November 2001 on
preference for long-term strategy of investing in shares, and the
'Reduction in Cost for the Investors relating to Demat Opera- second set was based on the frequency of actual buying/ selling
tions'.5 Even before the committee had considered the matter, activity in shares by household investors, as reported by the
the NSDL changed its system of charges from advaloremrespondents
basis to the survey.
Over 60 per cent of the sample households across income-
to a flat rate basis, resulting in raising of charges for all small
investors and reduction for large investors, as already mentioned
classes and age-classes, expressed preference for holding shares
above. The NSDL has tried to justify its new structure of charges
over long periods of several years instead of short-term trading.
by arguing that its own costs were a function of the number of
As regards trading frequency, a little over one-half of the sample
households were found to have undertaken no transaction (neither
transactions and accounts processed and not related to their value.
This may be so, but it cannot be the only consideration. Wesalemust nor purchase) in shares during the whole of preceding 12
also take into account broader considerations, speciallymonths the before the survey in question, implying that they are not
economic effects and equitable sharing of the costs of infrastruc-
frequent traders in shares. In view of the high cost of depository
ture services. The depository service is part of the financial
system for custody purposes alone, an investor, who is not a
infrastructure of the economy. frequent trader, is being quite rational by not going for demat.
The Consumer Education and Research Centre (CERC) of The whole depository system in India seems to have been designed
Ahmedabad collected some feedback from investors about mainly keeping in view the needs of frequent traders and specu-
depository services in order to help the deliberations of the rather
lators SEBI than the needs of long-term investors who may trade
Committee. Apart from numerous irritants faced by investors
only once at
in a while. Perhaps, those who designed the depository
the DP level (e g, delays in demat and procedures not systembeing
were also motivated by the objective of maximising the
investor-friendly), the foremost problem which emergeddepository's
from the income rather than serving the actual needs of the
CERC's survey was the snall investors' complaint about deposi-
clients in the most economical way.
tory charges, as reproduced below:
Dematerialisation should be optional (especially for below par
Data on Spread of Demat among Ordinary Investors
value shares) as small investors find the charges very high. At
times, the cost of the shares is less than the total cost of
The survey findings provide an explanation as to why most
denmaterialisation. Compulsory demat should be abolished and
of the small
transactions should be allowed for physical sale or purchase in and middle-class investors have not gone for demat
case of small investors.6 (Emphasis added) despite demat being made a compulsory requirement for trading
The SEBI Committee brushed aside CERC findings,shares. The main reason is that they don't intend to trade but
and the
Note of Dissent submitted by Manubhai Shah of CERC simply
andhold
as the shares for long term. The survey results
also the objections raised by Kirit Somaiya, MP, whoconclusively
resigned showed that only those who need to trade regularly
or frequently find it worthwhile to join the demat system and
from the committee in protest against raising of depository
charges for the small investors. that too only for those shares in which they want to trade. The
survey
In response to press reports, criticising NSDL's revised found that two-thirds of even those who had opened a
system
of depository charges, the SEBI asked NSDL to review demat account
its did not get all their shareholdings converted to
charges. The NSDL made a very nominal reduction butdemat form but only a part of the holdings (Table 1). This is true
the basic
problem of small investors was left unresolved. across almost all income-classes, as may be observed from Table 1.
We were not able to collect data about individual companies
IV regarding the percentage of their shareholders who still hold
paper certificates. Such percentage is likely to be quite substantial
Adverse Impact of NSDL Charges on Equity
Market's Growth even for the largest companies. SEBI should collect such data
and make it available to facilitate more informed discussion of

This section is based on the data generated by the all-Ini, iathe problem.
Household Investor Survey conducted by the Society for Capital
Market Research and Development during September-OctoberReasons for Not Going for Demat
2002. The survey brought out two inter-related facts, viz, (a) a
majority of middle class households are long-term oriented To a question to the respondents as to why they had not
investors who do not indulge in frequent trading in shares; andconverted all their shareholding into demat, many of them stated
(b) a majority of the middle class shareowners have continuedthat they were long-term holders and hence why should they
to hold paper certificates simply because they find that theunnecessarily pay the high custody and account maintenance
depository system is not cost-effective from the viewpoint of charges annually.
long-term shareholders. Both these behavioral characteristics of We found that less than one-fourth of the total number of
ordinary investors are relevant to the present discussion. shareowners, covered by the SCMRD survey, had all their
shareholdings in demat form. This is true across almost all
income-classes (Table 1). This is a very significant fact because
Long-Term Investors Predominate among
Small Investors it means that even those familiar with the depository system and
processes do not regard it worthwhile to demat all their shares
The SCMRD survey shows that, contrary to the general belief, but only some shares in which they may have to trade. This
between one half to two-thirds of household shareowners across explains why as high as 76 per cent of shareowners in the sample

Economic and Political Weekly May 17, 2003 1971

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of households continue to hold paper certificates: 36 per cent
had paper certificates only without having any demat account
and 40 per cent had paper certificates as well as demat account
for some speculative scrips in which they may like to trade
frequently.
by NSDL from every DP with the result that many small places
have no DP and some places have only one DP. This annual flat
fee discourages the emergence of a new DP as he will take several
years to develop a sufficient volume of business to be able to
recover his fixed costs.

The heavy annual custody and account maintenance charges
penalise the small long-term holders of shares and have the effect
of squeezing them out from the equity market. The small investors
are faced with a serious dilemma. On the one hand, if they demat
the holding, they find that long-term holding of shares in demat
form is too costly due to annual account maintenance and
custody charges. Both these charges go on cumulating over the
years even when the dividend may be nil or negligible and the
holder is not a short-term trader. On the other hand, if they
continue to hold paper certificates, they will have difficulty in
selling their holding as and when they want because trading
arrangements for paper certificates are very inadequate and costly.
Hence, such long-term small investors are gradually quitting the
equity market.
It is the numerous small investors who had lent dynamism to
the Indian equity market over the last three decades. Their gradual
exit has begun to affect the equity market's growth adversely.
The SCMRD investor survey (Sep-Oct 2002) also showed that
household investors as a whole are tending to reduce their
exposure to equity investment and even the size of shareowning
population in India has begun to shrink.
The large institutional holders (like FIIs), holding shares worth
crores of rupees, now pay a negligible custody charge, as we
have shown above. Only for the small investors, the new flat
rate system of charges has become uneconomical. The NSDL
has completely ignored the needs of these small investors.
V have remained outside the depository system.
Concluding Comments
Competition Not Effective
The NSDL has argued that because of the existence of more
than 300 DPs in the country and two competing depositories,
there is sufficient competition in the Indian depository system
to keep depository charges down. This argument is fallacious.
An examination of ground realities shows that competition is
not working for several reasons. Among these are: an opaque
and confusing system of charges at the DP level; substantial costs
and hassles for the investor if he wants to change his DP;
insufficient connectivity between the two depositories (NSDL
and CDSL); and a heavy annual flat fee of Rs 1.5 lakh charged
Switching costs for a DP from one depository (say, NSDL)
to another (like CDSL) are heavy and so also are switching costs
for an investor from one DP to another. A key deterrent to
switching depositories is that transferring one's security holdings
from one depository to another depository is wrongly treated as
'transaction' liable to payment of transaction fee.
J R Varma, a former member of SEBI, has argued that "the
key (to competition) is to reduce switching costs for investors
and depository participants and to ensure fast and easy inter-
connectivity, for a potential new depository".7 However, in our
view, what has seriously gone wrong is not just insufficient
competition (which, in any case, cannot be unrestricted) but the
very philosophy guiding the structure of the depository charges,
as we have specifically pointed out.
Coverage Achieved by the Indian
Depository System
The official claim that almost 99.9 per cent of stock exchange
transactions are being settled electronically through the deposi-
tory system in India creates a false impression about the reality
of coverage achieved by the Indian depository system. Presently,
settlement through the depository system in India represents less
than 20 per cent of total stock exchange trades, as more than
80 per cent of trading has continued to be non-delivery trading
even after the adoption of rolling settlement system in India. Also,
as we have shown earlier, a majority of small long-term investors
The finding of the household survey that the Indian depository
system covers only a small fraction of shareowners is substantia-
ted by the fact that the number of shareholders who have joined the
depository system is only around 40 lakh, whereas the total share-
owning individuals in India, as per independent estimates pro-
vided by the Society for Capital Market Research and Develop-
ment and by SEBI-NCAER survey, is around 2 crore.8 Even if we
allow for some consolidation of shareholding by various members
of the same family for the purpose of opening a single depository
account, it is reasonable to infer that roughly three-fourths of
ordinary investors in shares have not joined the depository
system. Should this fact not worry our authorities? Should they
ignore the needs of such a huge number of small middle class
investors?

Table 1: Per Cent of Shareowners Holding Shares in Demat Form and/or Paper Certificates Form
(Investor Survey of September-October 2002)

Household Income Class

Form of Shareholding All Income- (Household Monthly Income in Rs)
Classes Upto 10,000 10,001-15,000 15,001-20,000 20,001-25,000 Over 25,000

Classification of sample shareowners

(a) Per cent of shareowners who have all their shareholdings
in demat only 23.4 38.2 20.2 17.5 21.6 22.8
(b) Per cent of shareowners who have all their share
in paper certificates only (i e, no demat A/c opened) 36.0 29.4 43.8 43.3 27.5 30.7
(c) Per cent of shareowners having both demat and
paper certificates 40.6 32.4 36.0 39.2 51.0 46.5
Total (a+b+c) 100.0 100.0 100.0 100.0 100.0 100.0
No of shareowners covered (406) (68) (89) (97) (51) (101)

Source: Based on SCMRD survey of household investors.

Economic and Political Weekly May 17, 2003 1973

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 continued parti
Need for Providing Safe-Keeping Depository Service
the market.

Given the Indian situation, our suggestion is that it would be

appropriate for the policy-making and market regulatory authori-
ties to consider the provision of an economical paperless system
for providing purely "safe-keeping" facility for the huge number
of small investors.9 This is an urgent need in the interest of the
whole lot of small- and middle-class investors. Such facility is
likely to help in reviving the equity market by encouraging
Appendix
Domestic Investors vs Flls
In our opinion it is the growth of domestic shareownin
population which will give inherent strength to our equity marke
Hence the growth of domestic shareowners should be emphasis
much more than FII portfolio investment which will alway
remain fickle.
The middle class households have been the backbone of the

Table A 1: Income-Classwise Distribution of Sample Indian equity market over the last three decades. Their withdra
Households
in recent years has weakened the market greatly. Our data sh
Income-Class Questionnaire-1 Questionnaire-2 that a majority of household investors are long-term orient
(Rs per Month) No of Per Cent No of Per Cent This is a healthy feature and ought to be encouraged. Shareown
Respondents Respondents
households in India are just about 4 per cent of the total num
1 Up to 10,000 114 21.47 56 21.54 of Indian households,l? whereas the comparative percentag
2 10,001-15,000 117 22.03 42 16.15
the US is around 50 per cent. Hence, our policies should
3 15,001-20,000 115 21.66 59 22.69
4 20,001-25,000 68 12.81 42 16.15 designed to encourage a greater number of households to inv
5 Over 25,000 117 22.03 61 23.46 in equity shares. Even prime minister Atal Behari Vajpayee h
All income-classes 531 100.00 260 100.00
been strongly urging this but the policy-makers have been una
to get down toof
Table A 2: Age-Classwise Distribution brassHousehold
tacks. New entrants into shareowning
Heads
mostly begin in a small way as small investors only. How
Age Class No of Respondents Per Cent
they begin if the depository system has shut the door for sm
1 Under 30 60 11.30 long-term investors? [i]
2 30 to under 40 144 27.12
3 40 to under 50 165 31.07
4 50 to under 60 101 19.02 Address for correspondence:
5 60 and above 61 11.48 scmrd @bol.net.in
All income-classes 531 100.00

Notes
Table A 3: Occupationwise Distribution of Sample
Occupation No of Respondents Per Cent 1 See SEBI Annual Report, 1996-97, p 20. In May1996, SEBI also notified
1 Govt service 130 24.95
SEBI(Depositories and Participants) Regulations. Following the
2 Other service 190 36.47 notification, National Securities Depository (NSDL) was sponsored by
3 Own business 92 17.66 IDBI, UTI and NSE. The NSDL began its operations in November 1996.
4 Professional practice 42 8.06 2 In January 1998, SEBI had made trading through depository compulsory
5 Retired 61 11.71 for large institutional investors in selected scrips. In January 1999, trading
6 Housewife 6 1.15
through the depository was made compulsory for all investors in selected
All classes 521 100.00
actively traded shares. Only shareholdings upto 500 shares are allowed
Note: Occupational information was available for only 521 out of to be traded in the form of physical certificates but this system is not
531 respondents. working efficiently.
3 The members of the SEBI Working Group on Framework for Depository
Table A 4: Statewise Distribution of Sample Households System were: C Achuttan, L C Gupta, S Murthy and D N Raval. See Report
SI No State/Union Territory No of Respondents Per Cent of the Working Group (August 1994, unpublished), specially para 11.4.
4 The full report of the survey will be published shortly.
1 Andhra Pradesh 33 6.21
5 report of the SEBI Committee on Reduction of Cost for the Investors
2 Assam 11 2.07
3 Bihar 12 2.26
Relating to Demat Operations (1998, unpublished; download from SEBI
web site). The committee had C B Bhave, MD of NSDL as its chairman.
4 Chandigarh 14 2.64
5 Chennai 21 3.95 Other members were: B G Daga (MD of CDSL), B V Goud (MD of
6 Chhattisgarh 1 0.19 Stockholding Corporation), Anand Natarajan (Standard Chartered Bank),
7 Delhi 54 10.17
C Parthasarthy (Karvy Consultants), Kirit Somaiya (MP and president
8 Goa 10 1.88
of Investors' Grievance Forum) and Manubhai Shah (managing trustee,
9 Gujarat 20 3.77 Consumer Education and Research Centre).
10 Haryana 18 3.39
11 Jharkhand 11 2.07 6 The feedback collected by CERC from investors was appended to the
12 Karnataka 45 8.47 Report of the SEBI Committee on Reduction of Depository Cost.
13 Kerala 31 5.84 7 J R Varma, 'Regulatory Implications of Monopolies in the Securities
14 Madhya Pradesh 18 3.39 Industry', IIMA Working Paper Series, No 2001-09-05, September 2001.
15 Maharashtra 45 8.47
8 See SEBI-NCAER Survey of Indian Investors (published by SEBI, June
16 Nagaland 1 0.19
17 Orissa 19 3.58
2000). See also L C Gupta, C P Gupta and Naveen Jain, Households'
18 Pondicherry 12 2.26
Investment Prefrences.: The 3rd All-India Investors' Survey
19 Punjab 25 4.71 SCMRD,2001), specially pp 110-21.
20 Rajasthan 14 2.64 9 It is interesting to note that the Depository Trust and Clearing Corporation
21 Tamil Nadu 30 5.65 (DTCC) of the US provides for the safe-keeping of securities forcustomers.
22 Uttar Pradesh 30 5.65
See News and Information for DTC Customers, October 2002, page 11,
23 West Bengal 56 10.54 attached to its Annual Report, 2001.
Total 531 100.00
10 See Gupta, et al, op cit, pp 120-21.

1974 Economic and Political Weekly May 17, 2003

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