Chairman
Nout Wellink, Governor Noyer, distinguished academics and fellow central bankers,
I
am thankful to the Banque de France for giving me this opportunity to participate
in the International Symposium on "Globalisation, Inflation and Monetary
Policy". I will present some of the aspects of the Indian experience on the
subject and conclude by briefly flagging select issues in the light of recent
global developments.
Financial Sector Reforms
In
India, reforms to improve efficiency and soundness of the financial sector started
early in the reform cycle that commenced in 1991 - in some ways anticipating the
gains that would accrue from the resultant flexibility in product and factor markets.
However, the process of strengthening of the functioning of the financial institutions
in terms of prudential framework, operational efficiency and regulatory / supervisory
regimes has been gradual. It was also calibrated with the development of money,
forex, government securities and equity markets. At the same time, the pace and
content of reforms in banking, financial and external sectors are closely aligned
with the progress in reforms in the real and fiscal sectors and in the public
sector as a whole, considering in particular that the banking sector in India
is dominated by the public sector. Our attempts to align the financial sector
with the global best practices do take into account progress achieved in public
policy in regard to similar alignments in related areas, especially the real sector
flexibilities, fiscal health and overall governance standards.
In
the Indian context, considerable weight is currently accorded by the Reserve Bank
of India (RBI) to price and financial stability while recognising its twin objectives
of growth and stability. The large segments of the poor tend to reap the benefits
of high growth with a time lag while the rise in prices affects them instantly.
Further, we recognise the limited capacity of the poor to bear risks that may
occur in the real sector by virtue of developments in the financial sector, in
the absence of social security mechanisms and public safety net.
Let
me illustrate with two examples of emphasis on stability in relation to financial
institutions and financial markets. First, the centrality of the banking sector,
especially the retail deposit base and credit disbursement, is maintained while
gradually expanding the practice of diversified universal banking. Second, in
regard to financial markets, in view of a persisting, though moderating, high
combined (i.e. federal and provincial debt together) public debt to GDP ratio
of over 70 per cent, coupled with current levels of fiscal deficits, almost the
whole of sovereign debt, mostly at fixed interest rates, is denominated in domestic
currency and is held almost entirely by residents. A small component is open to
Foreign Institutional Investors and multilateral / bilateral agencies. At the
same time, the government securities market is well developed and is paving the
way for the healthy development of an expanding corporate bond market.
Capital
Account Liberalisation
Liberalisation of the capital
account has been a gradual process with a distinction being made between households,
corporates and financial intermediaries, along with the recognition of a hierarchy
of preferences for capital flows. The equity markets are more liberalised, relative
to debt markets. Experience has shown that investment in equities, especially
in terms of foreign direct investment, may bring in collateral benefits such as
technological and organisational know-how. There is, therefore, considerable openness
in regard to equity along with active management of external debt.
While
the policy readily recognises the benefits of liberalisation of trade, it constantly
weighs the risks and rewards based on both domestic developments and global conditions
in regard to management of capital account. Thus, the process of liberalisation
of the capital account reckons the pace of concomitant developments in domestic
financial sector, fiscal health and flexibilities in the real sector.
Capital
Account Management
It is possible to argue that
just as 'stabilisation funds' take care of current account shocks, capital account
management and market interventions are justifiable to take care of cognisable
capital account shocks.
A continued focus on financial
market development and its sophistication would, no doubt, mitigate the challenge
of capital flows in the medium term. However, it is important to recognise that
maturation of financial markets takes time. Hence, sometimes capital flows may
have to be managed through other instruments in the short term, while continuing
to work on development of the financial markets.
Increase
in absorptive capacity of the economy could be a mitigating factor in the context
of large inflows. It is not easy, however, to develop absorptive capacity of an
economy in the short run and in any case it is very difficult to calibrate the
absorptive capacity of an economy to match capital flows if they happen to be
volatile. Furthermore, the level of current account deficit in respect of emerging
market economies that is generally considered as sustainable by the global financial
markets may be lower than the sheer volume of capital inflows in these economies.
It is sometimes suggested that encouraging outflows would
be a good solution to manage surging inflows. While there is some merit in this
approach, liberalising outflows may not be of great help in the short run because
a more liberalised regime generally attracts higher inflows. Hence, such a policy
has to be combined with other measures which could help to effectively manage
the flows.
In implementing a calibrated process of liberalisation
of capital account, co- terminus with developments in other sectors, there are
several issues that are addressed in regard to managing capital flows in the short
run. These are: (a) whether the capital flows are judged to be large and lumpy;
(b) whether they are assessed to be temporary; (c) the limits to effectiveness
of interventions if the exchange rate movements are unidirectional; (d) the desirable
extent of sterilisation, considering costs and the available instruments; and
(e) above all, the likely impact of the relevant policy stance and procedural
measures on the exchange rate expectations. Needless to say, monetary and exchange
rate and reserve management are rendered complex in the context of the well known
'trilemma', especially in the current global environment.
Monetary
Policy
Monetary policy recognises the growing importance
of global factors but the domestic developments play a dominant role. No doubt,
the structural transformation underway and the continued significance of public
sector in financial sector as well as notable prevalence of administered interest
rates make the tasks particularly complex. While there has always been a dual
mandate of the RBI, it has, in recent years, successfully articulated a self-imposed
tolerance limit of five per cent on headline inflation. The tightening of monetary
policy commenced in October 2004 and there have been seven increases of 0.25 per
cent in the repo rates till March 2007, to address early signs of possible overheating
during the period. To meet the challenges of excess liquidity on account of surge
in capital flows, the cash reserve ratio in regard to banking system has been
increased in ten instalments since September 2004 till date, aggregating three
hundred basis points. Currently, there are acute policy dilemmas arising from
global food and energy prices as also from financial market turbulence that need
to be factored-in in evolving appropriate policy responses.
Supervision
of Banks
In recent years, partly reflecting the
buoyant economy, credit growth has been very high, particularly, in select segments
and the asset prices have been accelerating. The RBI made it clear that while
it does not have a view on the market valuations, it would like to sensitise the
banking system to the potential risks of rapid escalation in prices. The actions
taken since December 2004 to address these issues include increase in risk weights
in respect of housing loans and sensitive sectors viz., commercial real estate
and capital market exposure. Further, since November 2005, provisioning requirement
for standard advances, except for agriculture and SMEs, were increased while the
increases in respect of sensitive sectors were steeper. Several procedural &
suasive measures, and supervisory review processes over select banks were also
undertaken to sensitise them in this regard. In particular, the RBI’s concerns
about credit quality in the expansion phase of credit, the recourse to non-deposit
resources to fund their assets, the uncomfortable loan-to-value ratios and excessive
reliance on wholesale deposits were repeatedly expressed, and this has been followed
up with interactions with select banks, as needed. As a result, overall credit
growth as also advances to sensitive sectors have since moderated. The RBI has
been urging the banks to also monitor carefully larger unhedged foreign exchange
exposures of their corporate clients.
In view of the tendency
of some of the banks to utilise non banking financial companies as conduits to
channelise funds leading to regulatory arbitrage and discomfort, limits on both
direct and indirect exposures were imposed and transparency in their relationship
with banks was insisted. Further, supervisory review process has been undertaken
in regard to the few banks that rapidly expanded their off-balance sheet exposures
so as to secure supervisory comfort.
As regards complex
financial products, the structured credit market is in its infancy. Both mortgage-backed
and asset-backed securities are in vogue, but in the light of differing market
practices and concerns relating to accounting, valuation and capital adequacy
treatment of such products, the RBI issued guidelines on securitisation of standard
assets in February 2006. Permitting introduction of credit derivatives, currency
futures as well as interest rate futures with modified product design in India
are under active consideration and the process of extensive consultations with
market participants is underway.
Regulatory focus on
liquidity
The overall liquidity in the system is actively
managed by the RBI mainly through the operation of Liquidity Adjustment Facility
on a daily basis in addition to sterilisation through several instruments.
While
the RBI has prescribed prudential guidelines for asset liability management by
the banks and they have flexibility in devising their own risk management strategies
as per Board-approved policies, subject to regulatory limits on mismatches prescribed
for short-term time buckets, the RBI has taken steps to mitigate risks at the
system level as well.
RBI had, early on, recognised the
risks of allowing access to the unsecured overnight market funds to all categories
of entities and, therefore, restricted the overnight unsecured market for funds
only to banks and primary dealers.
Like other supervisors,
the asset liability management guidelines for dealing with overall asset-liability
mismatches have been issued by the RBI. Since excessive reliance on call money
borrowings by banks could cause systemic problems, prudential limits in relation
to net worth have been stipulated on both lending and borrowing in call money
market in addition to those on inter-bank liabilities.
The
guidelines on securitisation of standard assets have laid down detailed regulations
on provision of liquidity support to Special Purpose Vehicles (SPVs). It inter
alia enables grant of liquidity facility, by the originator or a third
party, to help smoothen the timing differences faced by the SPV between the receipt
of cash flows from the underlying assets and the payments to be made to investors.
The liquidity facility is subject to certain conditions to ensure that the liquidity
support was only temporary and gets invoked only to meet cash flow mismatches
and for absorbing losses. Any commitment to provide such liquidity facility is
to be treated as an off-balance sheet item and attracts 100 per cent credit conversion
factor as well as 100 per cent risk weight.
Select issues
Keeping in view the Indian experience and recent global
developments, I will venture to pose some select issues for consideration. First,
arguably globalisation had helped to bring down inflationary pressures. An interesting
issue would be as to whether globalisation of trade has contributed more to such
a process than globalisation of finance or whether it is a combined effect. China's
manufacturing industry and to some extent, India's services sector, have admittedly
contributed to the downward inflationary pressures while more recent upward pressures
on prices of food and fuel do not suggest significant role for finance relative
to trade. The impact of extensive use of derivative instruments in respect of
commodity trade on oil and food prices is still indeterminate.
Further,
as illustrated by China and perhaps India, major contributors to the price moderation
so far, consequent upon global integration, have remained relatively less open
on capital account and have a moderately integrated financial sector.
Second,
the link between open capital account and growth performance is not fully confirmed
by the experience of the two largest emerging markets, though such a link is not
entirely refuted either. In view of limited experience so far it is also useful
to explore the link between movement in asset prices and financial integration
vis-à-vis trade integration. In any case, the assumption that a managed
capital account generates adverse sentiments in financial market is not fully
borne out so far by the two aforesaid examples which experience large capital
inflows. This points to the need for assigning greater weight to macro-economic
fundamentals than to the state of capital account openness.
Third,
recent turbulence in financial markets/institutions and the importance of harmonised
and coordinated response of public policies indicate the significance of countercyclical
fiscal and monetary policies. Is it possible to argue that similar harmonisation
between monetary policy and prudential policies would be of some value as part
of counter cyclical measures?
Fourth, in regard to regulation
and supervision over banks, it is useful to explore whether the special status
of banks in the financial system and the need for active coordination among regulators
/ supervisors needs to be reaffirmed. Further common persons in most of the societies
would like to have a set of institutions where almost total safety of funds is
assured and these traditionally are the banks. Hence, if the concept of reasonable
expectation in public policies is accepted in regard to banks (as evidenced by
the experience with Northern Rock), the pre-eminence of depositors' interests
come out prominently. In this light, a reassessment of 'originate-to-distribute'
models, off balance sheet items and liquidity requirements of banks may warrant
a closer examination in regard to banks. Moreover, the debate on financial innovation
and regulation has to be considered in terms of potential and systematic relevance
of such innovations besides the capabilities for bringing them effectively under
the regulatory umbrella. The extent of relevance of reputational risks in the
conduct of the banking business relative to the past may also be worth considering.
Fifth,
relative to trade in goods, externalities are more prevalent in regard to financial
sector, especially the banking sector. Hence, some regulation is essential and
it tends to be national. However, the financial flows are rapid due to modern
technology and could be quite substantial, but in view of global scale, it becomes
extremely difficult to identify or enforce the rules of origin in regard to financial
flows. In this regard, the scope of and limit to global harmonisation of banking
regulations in a convincing and enforceable manner may have to be continuously
assessed so that the national regulators appropriately build into their regulatory
regimes the requisite global requirements and domestic compulsions of reasonable
expectation from the common person that ought to govern the public policy.
Sixth,
currently there appear to be simultaneous challenges from several angles to the
conduct of monetary policy emanating from recent financial turbulence. These relate
to abrupt and large shifts in monetary policy measures of the major economies,
major realignments in exchange rates within a short period and unprecedented inflationary
pressures due to food and energy prices. These warrant significant and innovative
ways of cooperation among the central bankers.
Finally,
from a purely academic perspective, it may not be out of place to explore the
issues concerning international policy coordination including the political economy
considerations, in terms of interaction between governments and the financial
sector, which may have been influenced by not only by the growing importance of
finance but also the cross-border linkages in the financial flows. Recent debates
on the Northern Rock, Sovereign Wealth Funds and financial innovations being ahead
of regulation, are symptomatic of this broader issue. If I recall, Prof. McKinnon
and Prof. Jagdish Bhagwati, among others, had alluded to some of these aspects
some years ago.
Thank you.
*Remarks
of Dr. Y V Reddy, Governor, Reserve Bank of India at the International Symposium
of the Banque de France on Globalisation, Inflation and Monetary Policy, held
in Paris on March 7, 2008