Intellectual Thoughts by Sanjay Panda: October 2007

Mid Term policy review- Copious foreign flows

The surging capital inflows continue to pose a policy challenge for the Reserve Bank of India (RBI), as it undertakes its mid-term policy review on October 30, despite some measures taken to contain unregulated inflows. The central bank is unlikely to signal any easing of monetary policy with surplus liquidity in the system, as any lowering of interest rates at this point, could hold upside risks to inflation.The copious capital inflows have forced the RBI to mop up close to $43 billion of foreign exchange since April and $20.5 billion since September alone, to curb rupee appreciation. The rupee has appreciated by over 11 per cent against the dollar since January.

The Prime Minister's Economic Advisory Council had estimated that an increase in the forex reserves of the RBI of $26 billion in 2007-08 could be consistent with the current real growth of the economy, moderate monetary expansion ( 17.5 per cent) and a tolerable inflation rate (4 per cent). "In the current financial year up to early October 2007 itself, forex reserves have increased by over $50 billion and tackling this problem is the most crucial policy dilemma.Of the Rs 1,75,000 crore infused into the system on account of RBI's intervention in the forex market, the RBI has absorbed Rs 1,12,000 crore through issue of bonds under its market stabilisation scheme (MSS) and around Rs 31,500 crore through increase in cash reserve requirements, leaving Rs 30,000 crore of liquidity infused via interventions in the foreign exchange market still to be sterilized.

The central bank has in the last one year raised the CRR or the portion of deposits that banks are required to park with it, by 200 basis points to 7 per cent to absorb the surplus liquidity. The RBI in consultation with the government has also successively raised the MSS ceiling to Rs 2,00,000 crore.The outstanding MSS as of October 26 was around Rs 1,77,000 crore. Out of the margin of Rs 23,000 crore, the RBI will absorb Rs 11,000 crore under its MSS in the two days following the policy review.

The government, however, is not likely to hike the MSS ceiling further this year, considering the fiscal cost involved. At Rs 2,00,000 crore outstanding, the annual cost to the government is already around Rs 14,000. The RBI could by raising the CRR by 50 basis points, absorb another about Rs 15.000 crore.However, the RBI may not want to hike the CRR in the upcoming policy, instead awaiting further curbs by the government on capital inflows.

Sebi has imposed controls on use of participatory notes for investments in equities to stem surging capital flows and make them more transparent. These measures are however unlikely to have any significant impact on foreign portfolio inflows.The RBI Governor, in his speech at the Peterson Institute for International Economics in Washington earlier this month, said, "Risks from global developments continue to persist, especially in the form of inflationary pressures, re-pricing of risks by financial markets and the possibility of a downturn in some of the asset classes. Excessive leveraging has enhanced the vulnerability of the global financial system."

While, there has been a slowdown in credit growth to 23 per cent year-on-year, on October 12, from 29 per cent a year earlier, it is close to the RBI's projected growth of 24-25 per cent for 2007-08. With credit off take expected to pick up in the second half of the year, the RBI may not want to endanger the gains on inflation control front, by lowering either the repo or the reverse repo rate. The wholesale price index inflation stood at 3.3 per cent y-o-y for the week-ended September 29, though the consumer price index at 7.3 per cent, was seen hardening further. The high growth in money supply, at 21.8 per cent, is still above the RBI's target of 17-17.5 per cent. The concerns about overheating of the economy also persist against the backdrop of continued high growth in gross domestic product. According to the Central Statistical Organisation, during the first quarter of 2007-08, the real GDP grew by 9.3 per cent on the back of 9.1 per cent in the last quarter of 2006-07.


SEBI recommendations on P-Notes issuance

This paper sets out the proposed policy measures on Offshore Derivative Instruments (Participatory Notes).

With a view to monitoring the investment by FIIs through Offshore Derivative Instruments (ODIs) such as Participatory Notes (PNs), Equity Linked Notes, Capped Return Notes, Participating Return Notes etc., SEBI had prescribed reporting of issuance / renewal / cancellation / redemption of the ODIs on a monthly basis since October 2001. The figures submitted by the FIIs on a month to month basis showed an increasing trend.

In the latter half of 2003, a Technical Committee of SEBI Regulated Entities was constituted by the HLCCFM to examine the issues pertaining to P-Notes more closely. The Committee, comprising representatives of RBI, IRDA, SEBI and NSE met in October, 2003 and extensively discussed the issues like:

* Whether PNs should be allowed to be issued at all,

* Whether restrictive use of PNs is possible,

* Monitoring of compliance

* Phasing out of PNs that are non-compliant with new restrictions, etc.

The Committee, having examined the concerns raised by the participants, felt that while these issues and concerns would have to be addressed in the interest of the market, the measures taken should be practical, pragmatic, non-disruptive and enforceable without great difficulty. Recognizing that it may be difficult to enforce a complete ban on PNs, the Committee made certain recommendations which included issuance of PNs only to regulated entities subject to KYC requirements. The same was implemented through suitable amendment to FII regulations.

However, the year on year increase in ODIs, the anonymity that the ODI provides to the investors and the copious inflows into the country from foreign investors has been engaging the attention of the Government and the regulators such as the Reserve Bank of India and SEBI. This has been a topic for discussion in many fora such as HLCC and various committees set up by the Government/ regulators.

Current Scenario:
Currently 34 FIIs / Sub-accounts issue ODIs. This number was 14 in March 2004. The notional value of PNs outstanding which was at Rs.31,875 crores (20% of AUC [1]) in March 2004 has grown to Rs.3,53,484 crores (51.6% of AUC) by August 2007. The value of outstanding ODIs with underlying as derivatives currently stands at Rs1,17,071 crores, which is approximately 30% of total PNs outstanding. The notional value of outstanding PNs, excluding derivatives as underlying as a percentage of AUC is 34.5% at the end of August 2007.

Proposed Measures:
Following consultation with the Government, the following measures are proposed to be implemented urgently:

1) FIIs and their sub-accounts shall not issue/renew ODIs with underlying as derivatives with immediate effect. They are required to wind up the current position over 18 months, during which period SEBI will review the position from time to time.

2) Further issuance of ODIs by the sub-accounts of FIIs will be discontinued with immediate effect. They will be required to wind up the current position over 18 months, during which period SEBI will review the position from time to time.

3) The FIIs who are currently issuing ODIs with notional value of PNs outstanding (excluding derivatives) as a percentage of their AUC in India of less than 40% shall be allowed to issue further ODIs only at the incremental rate of 5% of their AUC in India.

4) Those FIIs with notional value of PNs outstanding (excluding derivatives) as a percentage of their AUC in India of more than 40% shall issue PNs only against cancellation / redemption / closing out of the existing PNs of at least equivalent amount.

Our real challenges lie at home - Internal security concerns

The internal security situation in India continues to remain a cause of concern for the Central/ state governments and all the citizens alike. Out of the many challenges we face at home, the internal security challenge is one of the key one. Violent incidents continue in some states of the North-East, particularly in Assam, Manipur and Nagaland. The ethnic overtones of violent acts in Assam are particularly disturbing. While the situation in Jammu & Kashmir has shown some overall improvement, apart from the bombings by the terrorists which are happening in several areas throughout India in regular intervals.

To control/reduce them we need better security forces, better in all senses, be it training, be it skills, be it equipment, be it resources, be it mobility or be it attitudes and the police forces should not be in control of the politicians. We need superior intelligence capabilities which can alert us to the impending threats. We need greater discipline, lesser politicisation and zero corruption.

We need to work with greater commitment for eliminating the threats posed by Naxalism. In the past that there are many dimensions to the problems of Naxalism. Concerted efforts can be made on the development front to remove any feeling of alienation, the security forces need to redouble their efforts to control the spread of this phenomenon.

Terrorism has become a global phenomenon of our times. In terrorist organisations, we face determined, committed and highly motivated adversaries working with evil design and evil intent. We need to go far beyond conventional responses in facing the severe terrorist threats. The government should work on many fronts — through dialogue processes, through development activities and through improved communication links — to tackle these problems.