A STABLE REGIME FOR THE RAPID GROWTH OF E-

PAYMENTS

Laveesh Bhandari (laveesh@indicus.net)

Version: May 28, 2007

A. Introduction and Background

This note investigates the emerging and proposed regime governing the prepaid stored value
electronic payment systems (such as smart cards, multipurpose prepaid cards). It recognizes
that such payment mechanisms are likely to emerge as a major tool in ensuring financial
systems’ accessibility to the large un-banked masses. It also recognizes that the emerging
interaction and communication technologies such as the internet will only require greater
and greater use of such systems. In such an environment the proposed Payments and
Systems Bill achieves special significance. What vision does it lay out for this sector? Can it
be strengthened? These issues are covered in this note. In the process this note also looks
at the vision laid out by the key actor in this space – the Reserve Bank of India. It is
essential to gauge the RBIs position on this matter as the proposed Bill allows high levels of
flexibility to the RBI. Last, this paper suggests specific points that should be included in the
proposed bill, or a completely new bill that is focused on regulation of electronic money
issuers needs to be put in place for the RBI to be better able to carry out its assigned task.

B. Payments and Settlements Bill

The proposed PAYMENTS AND SETTLEMENTS Bill seeks to enable the RBI to
comprehensively monitor and regulate the various payment systems in operation. As per the
‘Statement of Objects and Reasons’ of the proposed bill, ‘…the payment and settlement
systems serve as a backbone of financial system of a country.’ The Bill recognizes that there
are a range of systems both electronic and non-electronic that are operation and the lack of
comprehensive legislation in the past needs to be remedied.

Some of the payment systems currently in operation include:

• Manual paper based clearing
• Real Time Gross Settlement (RTGS) System for facilitating non cash mode of
payments
• MICR Clearing,
• Electronic Funds Transfer Systems (including the Electronic Clearing Services),
• Card Based Payment Systems,
• Government Securities Clearing,
• Forex Clearing, etc.
As per the objectives laid out in the bill, it was considered necessary to enact “a specific
legislation which would empower the Reserve Bank of India to act as the designated
authority with the following powers and functions, namely:—
(a) to regulate and oversee the various payment and settlement systems in the country
including those operated by non-banks like CCIL, card companies, other payment system
providers and the proposed umbrella organization for retail payments;
(b) lay down the procedure for authorization of payment systems as well as revocation of
authorization;
(c) to lay down operational and technical standards for various payment systems;
(d) to call for information and furnish returns and documents from the service providers;
(e) to issue directions and guidelines to system providers;
(f) to audit and inspect the systems and premises of the system providers;
(g) to lay down the duties of the system providers;
(h) to levy fines and impose penalties for not providing information or documents or
wrongfully disclosing information, etc.; and
(i) to make regulations for carrying out the provisions of the proposed legislation.”

In other words, the bill does not provide any direction or vision but is an empowering one.
It will enable the RBI to set up a comprehensive regime that would bring together various
types of ‘payment systems’ under a single regulatory framework. But what should be the
overall vision of such payment systems, who should it include, what should be provided
greater weight – competition, innovation, and growth of coverage, or financial security?
These issues are missing from the law.

This is brought out quite clearly “The Bill, inter alia, seeks to provide for the following
matters, namely,…to designate the Reserve Bank of India as the designated authority for the
regulation and supervision of payment systems in India for their smooth operations…”

As such it is difficult to critique the bill, it does not get into any specifics except empowering
the RBI to do so. Therefore to better understand the status we need to better understand
what directions the RBI has been taking. We come across four documents. The first are the
10 core principles put out by the Bureau of International Settlements. The second is the
RBIs vision document on payment systems. The third is one related only indirectly – on
electronic funds transfer. And the fourth is the report of the Cama working group by the
RBI on E-payments.

C. Ten Core Principles for Systemically Important Payment Systems

The Committee on Payment and Settlement Systems (CPSS), of the Bank for International
Settlements (BIS) published 10 core principles for systemically important payment systems.
Moreover, with IOSCO, the (International Organization for Securities Regulators), it has put
forth a set of recommendations for securities settlement systems and one for central
counterparties. Together, these form a body of standards, codes and best practices that are
form the basis of financial architecture worldwide. The Core Principles for Systemically
Important Payment Systems, published in January 2001 are not specific blueprints but
suggestions of what the key characteristics should be.

These general suggested ‘best practices’ however do not deal explicitly with issues related to
pre-paid or stored value electronic cards, in fact they are not really designed to apply to
them. As is stated in the introductory statement of the principles they ‘are a benchmark for
high value payment systems’. Moreover, they are mostly aimed at risk mitigation.
Nevertheless, it is recognized that such mitigation should not be at the cost of ‘fair and open
excess’ and ‘a transparent and publicly disclosed criteria for participation’.

In other words, these best practices do not provide further direction as to the principles that
will guide the RBIs take on electronic payments. For that we need to understand the RBIs
documents. These are discussed below.

Box: Ten Core Principles

The following ten principles were published by the Committee on Payment and Settlement Systems (CPSS) of
the BIS in January 001. These principles still provide the benchmark by which high value payment systems are
judged:
1. The system should have a well founded legal basis under all relevant jurisdictions.
2. The system’s rules and procedures should enable participants to have a clear understanding of the system’s
impact on each of the financial risks they incur through participation in it.
3. The system should have clearly defined procedures for the management of credit risks and liquidity risks,
which specify the respective responsibilities of the system operator and the participants and which provide
appropriate incentives to manage and contain those risks.
4. The system should provide prompt final settlement on the day of value, preferably during the day and at a
minimum at the end of the day.
5. A system in which multilateral netting takes place should, at a minimum, be capable of ensuring the timely
completion of daily settlements in the event of an inability to settle by the participant with the largest
single settlement obligation.
6. Assets used for settlement should preferably be a claim on the central bank; where other assets are used,
they should carry little or no credit risk and little or no liquidity risk.
7. The system should ensure a high degree of security and operational reliability and should have contingency
arrangements for timely completion of daily processing.
8. The system should provide a means of making payments which is practical for its users and efficient for
the economy.
9. The system should have objective and publicly disclosed criteria for participation, which permit fair and
open access.
10. The system’s governance arrangements should be effective, accountable and transparent.
* Systems should seek to exceed the minima included in these two core principles.

D. Payment Systems in India – Vision 2005-08

As per this RBI document published in 2005, the objective of any payment systems regime is
the ‘establishment of safe, secure, sound and efficient payment and settlement systems’. It
recognizes that the primary goal of a national payment system is to enable the circulation of
money. The document also states that public policy objectives are to protect the rights of
users of payment systems, enhance efficiency and competition, and ensuring a safe, secure
and sound payments system. This can be achieved through four tenets:
 • Safety will relate to addressing risk, so as to make the systems risk free or with
minimal risk
• Security will address the issues relating to confidence, with specific reference to the
users of these systems
• Soundness will be aimed at ensuring that the systems are built on strong edifices
and that they stand the test of time
• Efficiency will represent the measures aimed at efficiencies in terms of costs so as to
provide optimal and cost effective solutions.

These are all quite standard points for any payment system, but do not provide any sense of
the direction on any specific issues. Issues of who, how and coverage are all missing. As far
as pre-paid e-payments are concerned there is no explicit vision set out by the RBI.

But the vision document does devote a full section on the rural sector. It states that ‘the
benefits of improvements in payment and settlement systems should be fully available for
the rural population of the country…[and] the general thrust of all the action points would
encompass the requirements of the rural populace…’. It then identifies the following action
points:

1. Improve the availability and coverage of the new delivery channels. This will be in
the form of extension of facilities such as the Automated Teller Machines for cash
payments.
2. Facilitate large scale deployment and use of multi application smart cards which
would also be used for storage and transfer of small value payments in electronic
mode. This would be achieved by means of introduction of easy to use, small and
cost effective hand held devices for transfer of value between cards in a secure
manner.
3. Increase the reach of electronic modes of funds transfer at rural areas by providing
variations of such modes, but with a rural bias. The proposed NEFT system would
be modified such that the non-networked branches in rural areas can access the
NEFT branches of banks for transfer of fund.
4. Increasing the reach of payment services by means of tie up and collaboration with
other large coverage entities such as the Post Offices.
5. Providing support for new modes of traditional facilities such as ATM-based Kisan
cards.

These action points reveal an RBI that is quite forward looking in its interest to expand the
usage of newer forms of payment mechanisms. However it only mentions smart cards.
Other forms of card based e-payment mechanisms such as stored value cards, prepaid cards
etc are not yet judged to be important enough possibilities. In other words, some
recognition of the importance of newer modes exists, but again no sense of any internal
thinking.

If the RBI does not have an internal vision, and a vision is not being explicitly mentioned by
the government then the question is still open. Another RBI initiative provides a better
understanding of the RBIs internal thinking on the matter.
E. Study Group on Migration from Paper Based Funds Movement to Electronic
Funds Transfer

The study group investigated issues related to the migration from paper based funds
movement to electronic modes. The group recommended the following as feasible options:
1. Levying a charge for all paper based cheques which will be borne by the customer.
Presently the service charges for MICR processing are borne by the banks. Banks
may have to educate their customers on the need to migrate to electronic processing
and in case the paper based cheques are continued, the service charges relating to the
processing of such cheques may be passed on to them.
2. Providing disincentives to customers for using paper based cheques vis-à-vis
electronic modes
3. Making electronic funds transfers cheaper than paper modes. To begin with ECS
based transactions should be free and this could continue for another three years.
The payee of a cherub has certain legal protection under Negotiable Instruments Act
against dishonor of such instruments. Similar comfort should be available for
electronic mode of funds transfer.
4. For certain transactions which are essentially used for effecting non-paper based
funds settlement - such as for reimbursement of credit card dues; payment by banks
to card accepting member establishments for transactions settled through the Point-
of-sale (POS) terminals etc., it is recommended that such payments should not be
through paper based cheques; … A similar approach could be adopted for mobile
phone payments as well.
5. Adopting a differential pricing pattern for paper based Demand Drafts, Pay orders
and Bankers’ Cheques issued by banks - these could be priced higher than electronic
transactions
6. Making internet based transactions free of charge for the customers, since banks
would be saving on costs involved if these transactions were to be processed by
them as paper based transactions or serviced by tellers at the counters of branches.

Three of the action points above emphasize the importance of keeping costs of electronic
modes low and encouraging them vis-à-vis paper modes. Apart from this aspect there is no
mention of importance of prepaid and stored value cards. That gets us to the next RBI
initiative that has more direct ramifications on the matter at hand.

F. Report of the Working Group on Electronic Money, 2002

This working group was predominantly comprised of persons belonging to the banking
sector. It is differentiates between the following types of pre-paid stored value cards
1. Single purpose: where the issuer and the acceptor are identical. That is, it is designed
to facilitate only one type of transaction such as store-specific cards, telephone calls,
etc.
2. Closed system or limited purpose: where a limited set of very well defined points
within well defined locations may accept the card such as in university campuses.
 3. Multi-purpose card: Also sometimes referred to as open-loop cards. These are cards
that are accepted by several vendors. Credit cards, debit cards, stored value cards are
some examples. These are also the cards that typically are the most used over the
Internet.

The working group recognizes that the risks are limited where single or limited purpose
cards are concerned, and concentrates a large part of its recommendations on multi-purpose
e-money. It states the following: “multipurpose e-money may be permitted to be issued only
against payment of full value of central Bank money, or against credit, only by the banks…”

The groups key concerns are the possibility of monetary policy becoming less sensitive to
Central bank action, if such payment forms become prevalent. By placing these instruments
solely in the hands of the Banks it felt that RBI would be better able to monitor as well as
implement its monetary policy objectives. The group goes on to state various reasons for its
preference for Banks, these include:
a) implication of e-money on accelerating velocity of money
b) impact on access by the RBI to the latest monetary statistics
c) option to impose reserve requirement on e-money
d) concerns on e-money being issued as credit and also technical security.

This is a highly flawed set of arguments. First, velocity of money is affected by many factors,
it has been increasing consistently and is likely to continue to do so. Velocity is affected by a
range of factors including how long Banks are open, access to ATMs, the availability of
notes and coins of different denominations and so on. There is no reason why putting e-
money only in the ambit of banks will help reduce money velocity, and there is no evidence
that lower money velocity will help either the country’s growth or equity objectives or safety
of its financial system.

The fact that e-money is used electronically also implies that there will be more information
generated. Further, since such information would be electronic, it would be much easier to
access. In effect paper money is always worse at generating information for the regulator
than e-money. Again there is no reason why the banks need to be the sole issuers. Non-
banking entities can generate the same information as banking entities.

While all other documents call for a low cost e-money option the group considered
imposing reserve requirements on e-payments. The prepaid stored value cards ensure that
instead of carrying paper money the individual provides that to the card provider and the
card provider then pays to the vendor. Reserve requirements will only affect the range of
services available to the consumers. But again this is not good enough a reason for limiting
to Banks. Moreover, if e-money cannot be issued on credit then all the more reason why e-
money should not be limited to banks, and a whole range of entities should be allowed to
issue them.

But the banker dominated group was quite categorical “non-banks should not be permitted
to issue multipurpose e-money…” unless other non-bank issuers also confirm to certain
prudential norms. We prefer to take this route than limit non-banks. That is, have certain
norms and make them open to whoever can fulfill these norms rather than limit to the banks
who anyway have been quite unsuccessful at reaching the underprivileged and rural
hinterlands.

The key direction taken by the working group was that preservation of financial stability
should not be compromised and it associated the non-banks’ e-money to be more likely to
compromise the integrity of the financial system. There are other ways of meeting these
objectives.

A summary discussion

In short, the RBI itself has not revealed much on its position on e-payments and specially
those related to multipurpose prepaid stored value systems. When RBI documents do
mention these forms of payments it is in passing. This could mean that either these are not
yet considered to be important enough options for the RBI to officially state its position, or
the RBI has yet to develop a position on this matter. In any event, what is quite clear is that
the proposed Payment Settlement Bill is quite vague and ambiguous on many important
issues. It leaves such issues to the RBI to deal with, but itself provides no direction or grand
vision towards e-payments. On its part as well, the RBIs grand vision on payment systems
also does not include any specific mention on such prepaid and stored value systems. The
RBI and other monetary authorities will tend to follow the BIS’ 10 core principles. However
those core principles also do not apply to the low value prepaid stored value cards. The only
indication is the working group on e-payments that seeks to create Banks’ monopoly in this
segment of the financial sector.

Two other issues need to be addressed hat are not mentioned in the above documents. The
first is related to security issues and the second money laundering. Security: Many law
breakers have been arrested on the basis of tracking made possible by following their
payments trail. It has been sometimes argued that e-payments would not enable this as easily
as was possible through the paper payments trail. To the contrary, e-payments make it
possible to track certain cards on a real time basis and may even better facilitate security
agencies in their tasks. The only requirement would be the proper identification of the
person purchasing the card/service. Just as is done today with mobile phones. Money
laundering: Since these cards can be purchased at various points and then used to purchase,
many believe that such systems will make it easier to use and even launder illegal money.
This is perhaps one of the more fallacious arguments against e-payments. If the user were to
identify himself to the seller who then can potentially share the information with the
government, money laundering can be dealt with better. But there is a more practical
argument as well. Such cards are typically low value cards. Money laundering however
typically is on a very large scale. Large purchases of pre-paid cards would be a very
impractical method of laundering money. There are far more efficient and low effort ways
through which money can be laundered.

Given these ambiguities we are left with no option but to ourselves suggest certain principles
and specific characteristics of s regulation that is essential for our objectives of growth and
equity.
G. Proposed Character of Multipurpose Stored Value E-payment Bill1

The following recommendations incorporate the overall objectives of the desired bill, and
how they should be put in place. They include efficiency, economy, innovation, competition
and management responsibility.

Efficiency and economy are self explanatory and need not be elaborated, in that transaction
costs of the system should not be inordinately high. The principle of proportionality
essentially ensures that unnecessarily stringent regulations are not put in place relative to the
size of the benefits. This is important as in the initial stages the benefits are unlikely to be
high and therefore overly stringent regulations will impede growth. Of course, the larger the
sizes of the market, the greater can regulatory oversight become.

Innovation in this space is essential for it to succeed. Already many consider smart cards to
have been a failure in countries such as Sweden. The experience in USA of prepaid cards
has been one of high costs. In India as well, the experiments are still going on and no
unqualified success example has yet been put forward. As a consequence, system providers
will need to experiment before an India relevant model is derived.

Competition is always essential for efficiencies to be sustained. Competition needs to come

in both from incumbents as well as new entrants. At the same time secrit and efficiency
should not be compromised and therefore appropriate regulatory oversight would be
required on that front. Last, recognizing that the senior management is responsible for its
action will enable to the regulator to not put in too many pre-emptive rules.

The Proposed Addition to the Payments and Settlements Bill – Prepaid Stored Value Cards.

Motivation:
India has a large segment of its population that is currently deprived of accessing
banks. This un-banked population earns, spends and saves in large numbers. Its per
household earning, spending, or saving capacities however tends to be quite low.
Despite intensive efforts a large part of this population remains un-banked. This un-
banked population remains in urban as well as rural areas and has been deprived of
many of the services. As e-governance and other efforts of the government
accelerate, we need to bring such groups rapidly into the banking fold. However, it
is well known that this would be difficult if not impossible for many reasons, three of
the most important being – high levels of illiteracy and therefore fear of banks;
problem of access specially in the rural hinterland, and high cost of servicing
remotely located customers. Moreover internet and other electronic modes of
interaction are rapidly becoming more and more important as a source of
information on professional as well as personal fronts. As a consequence it is the

1
See “The regulation of electronic money issuers”, Financial Services Authority, UK, consultation Paper
117, December 2001. Also see “A Summary of the Roundtable Discussion on Stored Value Cards and
Other Prepaid Products” The Federal Reserve Borad, New York (Undated).
 governments desire to ensure that such or other payments systems are able to
empower the masses in a short enough period of time.

Objectives:
• Empower the masses to be able to use electronic payments
• Ensure safety and security
• Promote efficiency

Principles:
a) Efficiency and Economy
b) Proportionality
• Restrictions imposed on firms and markets should be in proportion to the
expected benefits for consumers and the industry.
• Avoid unnecessarily distorting, entry barriers or impeding competition

c) Innovation
• facilitate innovation, for example by avoiding unreasonable barriers to entry for
banks and non-banks or restrictions on existing market participants
• facilitating launch of new financial products and services.

d) Competition
• facilitate entry of all who can offer services
• ensure entry along with security and efficiency.
e) Role of Management:
• responsible for its activities
• business is conducted in compliance with regulatory requirements.

Proposed directions aimed at facilitating progress of the e-payments sector

Topic Specifics Notes

Definition e-money: monetary value stored on
an electronic device and accepted
as a means of payments by third
parties
Inclusion e-money includes a range of modes
and media, specifically including
but not limited to value being
carried in various types of
electronic devices including smart
cards, magnetic strip based media,
etc.; Can be used to purchase
products and services, redeemed
for cash, and whose value can be
updated;
Issuer Both banks and non-banks are
Allows for all types of systems, based on
cards or other means and removes single
purpose cards
Various new forms are going to emerge
that are currently difficult to predict; the
definition should be inclusive.
The regulatory framework needs to be
technology neutral
A level playing field between banks and
Topic Specifics
allowed to issue; certain norms,
reporting and information criteria
etc. Also small issuers should be
encouraged to enter.
For limited use e-money options
the requirements should be less
stringent. This should include
Prohibited Granting of credit through e-money
by non-banks
Risk mitigation Payment system to build in the
(tech.) following risks and associated
costs: unauthorized creation,
transfer or redemption; incorrect
attribution of funds, etc.
Use of deposits The payment from the consumer
to the issuer will need to be
protected. There are many ways of
doing so including adequacy
norms, restrictions on usage of
deposits received, etc.
Authorization Only granted to those who meet
(Entry) the following criteria related to
explicit:
Legal status and identity, pre-
specified threshold conditions,
Supervision The laws should allow for
supervision including ability of the
regulator to examine all
transactions of the issuer; all
transactions also need to be
maintained in clearly laid out
uniformly implemented database
and data warehousing systems.
Enforcement Enforcement powers should rest
with regulator which would include
cancellation of permissions, fines
and censures, prohibition of
activities and individuals, initiation
of court proceedings etc.
In case of non-compliance of the
regulators orders, or in case of
Notes
non-banks needs to be established and
this needs to be explicitly recognized.
Most criticism of non-banks entry into
this sector comes from this possibility.
BY removing this we do away with such
criticism. That is, it does away with the
fear of monetary authority losing its
powers to affect the economy
Build in monitoring processes of the
same in the regulatory framework.
Concerns of risks many times get
translated into limiting activity. Better
reporting can eliminate many of these
concerns.
This is the key concern for allowing
non-banks. By ensuring better
protection of the users non-bank entry
will be made easier in this field.
This procedure needs to be as smooth
and as open as is possible. It should
explicitly be recognized that small
issuers’ entry should be facilitated and
not barred in the interest of financial
stability concerns.
The regulator should be able to cross-
check various informational claims made
by the issuers in case it so desires.
A balance would need to be ensured
between two forces – the need to
provide adequate powers to the
regulator. And the need to maintain
some third party oversight over the
regulator as well.
Topic Specifics Notes
some disagreement between the
regulator and the issuers some
arbitration/resolution mechanism
would be built in.

Prudential Corporate structure: a formal With cleanly laid out systems of

Requirements structure of the entity undertaking
this activity should be essential
Capital A minimum initial capital
requirement is one such option.
Scales dependent upon the amount
of initial capital could be another
possibility that would enable both
small and large players to enter.
Asset-liability Non-bank issuers must have
management investments of an amount not less
than outstanding e-money liabilities
Liquidity Issuers must have sufficiently
liquid assets; such norms can be
easily specified.
Safety and Security Money Laundering: monitor,
training, awareness
User Identification Details of user logged onto central
system; no issuance without
identification
commands
The minimum initial capital amount
should not be too high; this would
ensure that scales are not necessarily
high and unprepared entities are also
kept out.
To ensure both stability and confidence
in the system
By ensuring that databases can be shared
with the regulator real time monitoring
of criminal activities as well as money
laundering is possible.
By ensuring identification of user as a
precondition for its sale/use, many
concerns related to misuse can be
addressed.

H. Summary Conclusion

The proposed Payments and Settlements Bill is a document that is difficult to critique as it
merely places the overall payment and settlements regime in India within the ambit of the
RBIs powers. The RBI itself appears to be a bit ambiguous on the various options that are
likely to be available. But what is clear is that there is a great need for a framework to be
developed. The RBIs various documents do not show light on the matter. But all
indications are that, the government and the RBI still do not fully appreciate the possible
positive impact of the e-payment systems. The proposed Payments and Settlements Bill
does not contain important questions that need to be addressed. The first is related to the
government’s vision of e-payment and what it seeks to achieve.

This paper therefore calls for a document that explicitly states what the regulatory system
that oversees the consumer e-payment systems should be like. It suggests certain important
characteristics that ensure:
(a) stability
(b) innovation, entry and competition
 (c) entry of small players into e-payment services
(d) secure and safe e-payment system

We are therefore able to answer some important questions that are not addressed adequately
by the proposed bill.

1. Whether prepaid cards fit into the definition of System Providers is not clear; but as
that flexibility of defining such providers has been given to the RBI in the proposed
bill it will only become clear what route the RBI will take later. However it is clear
that some legislation will be put in place to ensure completeness of the regulatory
regime. Given that a regulatory structure will come up, the question arises – who
should the regulator be? The answer is quite apparent, it will have to be the Reserve
Bank of India.
2. The next question is: Should this segment which is at such a nascent stage be
regulated? On the one hand regulation will impose costs with little immediate
benefits at this point and therefore some may prefer regulation to be delayed. On the
other, if regulations ensure entry with safety and security, they will only accelerate the
spread of the e-payments system.
3. The question of entry is important, as undue regulation will prevent entry and
therefore competition from the non-bank sector. Here it is essential that all
segments, not just the Bank sector, should be able to provide such payment system
services. Moreover explicit mention should be made on facilitating the entry of small
players.
4. Fears such as money laundering or use in illegal cross border trade are quite
unfounded as there are other much easier means to undertake these tasks. However,
as long as basic monitoring and reporting systems are being followed, these can be
directly addressed. With electronic payments it would be easier to trace as well as
well as identify both activities as well as persons indulging in such activities.

IN conclusion, the current bill should be updated to include broad principles that should be
followed by the regulatory entity. The government needs to specifically mention these
specific principles related to entry, competition, innovation, and growth. The reason is the
regulator will always be most interested in maintaining security and stability and may not give
enough weight to the fact that a growing inclusionary economy needs many different types
of providers to meet the demands of the different types of potential users. The poor and
rural users, the un-banked population, small groups, payment over the internet, etc. all need
to be facilitated and coverage growth needs to be accelerated. This broad vision is currently
missing and needs to be incorporated to act as a guide and constant reminder and beacon for
the RBI

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