Monday, May 28, 2012

Breaking the Silence- the Forces behind the RBIs First Microfinance Circular.





In 1998 when I joined a start-up microfinance company IASC as its first CEO there were a plethora of challenges to be faced from day one. Of the ninety and odd candidates who applied for the position the onus to run the institution fell on my shoulders. HDFC Ltd was the promoter of the company and had inserted an advertisement inviting candidates for the position of the CEO in the middle of the year 1998. With not many microfinance institutions (MFIs) around we had to create precedence and also set an example for many other MFIs.




We took three months for the preparatory work and started rolling out micro-loans from January 1999. Loans were primarily extended to individuals in Self Help Groups (SHGs) and it was an innovation at that point in time. Being a Section 25 company we had planned to carry on the business of microfinance as a non-profit institution.

We had extended loans to a considerable number of  groups (SHGs) when we had to virtually stop business due to the issuance of an important circular by the RBI. The circular was as an aftermath of a series of steps the RBI had taken after the CR Bhansali Scam came to limelight, the second biggest financial scam then. The circular DNBS (PD) No. CC.10/02.59/98-99 April 20, 1999 stated : “ With a view to imparting greater financial soundness and achieving the economies of scale in terms of efficiency of operations and higher managerial skills, the requirement of minimum NOF of Rs. 25 lakhs has been raised to Rs. 200 lakh for the NBFC which commences business of a non-banking financial institution on or after April 21, 1999. This stipulation will not, however, be applicable to NBFCs which are already registered with RBI or to such companies whose applications for a certificate of registration are submitted on or before April 20, 1999.” The circular further stated “In sum, henceforth, any NBFC making an application to Reserve Bank of India for a certificate of registration should have NOF of Rs. 200 lakhs.” The legal advisors of the company advised us to apply to the RBI for registration as an NBFC as there were no exemptions as such and we were also advised to stop business till the matter was solved.

For the next over nine months we had a tough time managing groups (SHGs) which had come to us for repeat loans. We realised that, if repeat loans were not given the earlier loans may have repayment problems. On one side we were convincing the groups that we would be able to come over the problem and on the other side we were actually working towards the registration of the Section 25 company. Sitting in a small office in the second floor in Marthandam, my friend Jobins and I, were burning the midnight oil to send many concept notes to the RBI through the promoter HDFC. Thanks to the involvement of HDFC, the RBI took a special interest in looking at our application. At one point in time I had sent detailed concept notes describing microfinance, poverty level in India, the need for microfinance, and the modus operandi of our financial model.

As days passed on the RBI started taking a special interest in our case and had worked out some solution in their mind and they came back to us asking for more specific concept notes. The most crucial concept note that I prepared for transmission to the RBI was on who could be called as a typical client for a microfinance institution and the upper limits of loans to the microfinance client. I still remember how Jobins and I used to discuss this matter over dinner at Hotel Taj and come back to the office and spend considerable time building up the concept note.

While considering the client of a microfinance institution, we had suggested to include families categorised under the Economically Weaker Sections (EWS) and to some extent families belonging to the Low Income Group (LIG) for which definitions were already available with the Government. We had also insisted that these were the segments of the society which were neglected by the mainstream banks and were vulnerable due to various uncertainties in their cash flow.

With regard to the upper loan limits we both had the longest discussions and took lot of our time to conceive the most logical limits. Since IASC was already rolling out Micro-Housing Loans of Rs 35,000 per individual at that point in time and as we were also pioneers in extending higher loan sizes to village entrepreneurs and farmers for micro-enterprise loans, we decided to include both micro-enterprise loans and micro-housing loans for consideration of the upper limits. The best thing that happened was the far sightedness we both had when we decided to recommend the upper limits. We presumed that if our suggestion was going to be part of some RBI stipulation we need to have at least the next ten years in mind when we decide the upper limit. We extrapolated the then existing loan sizes for the next ten years and then taking into consideration the inflation rates and a few other considerations we arrived  at the upper limits.  We therefore suggested that an upper limit of Rs 50,000 be fixed for the micro-enterprise loan and Rs 1,25,000 be fixed for the micro-housing loan both for individuals.

We both were the happiest persons on January 30th, 2000 when the RBI’s Department of Non-Banking Services (DNBS) came out with a circular signed by Mr YSN Murthy, NOTIFICATION No. DNBS.138/CGM(VSNM)-2000 dated January 13, 2000. 


While on one side the just emerging microfinance sector had all reasons to be happy to see the first ever circular from the RBI on microfinance loan limits,  I felt extremely gratified by the fact that the RBI had accepted our recommendations on the upper limits as we had suggested. History was also created on that day as the RBI had exempted Section 25 companies from the formal registration with the RBI which meant that we could resume business immediately. Mr Murthy then Chief General Manager who consistently worked on the epoch making circular also needs to be appreciated.


People reading this may wonder as to why I have brought this into the public domain after such a long time.  Well someone rightly said that you have to blow your own trumpet yourself as you alone could play the best tune on it. 

P.Uday Shankar.