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Base Rate: - A Revolution or another Excuse

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India, an emerging economy, has witnessed unprecedented levels of economic
expansion, along with countries like China, Russia, Mexico and Brazil. India, being
a cost effective and labor intensive economy, has benefited immensely from
outsourcing of work from developed countries, and a strong manufacturing and
export oriented industrial framework. With the economic pace picking up, global
commodity prices have staged a comeback from their lows and global trade has
also seen healthy growth over the last two years.

After Independence in 1947, India was under Social Democratic policies until
1991. The economy was characterised by extensive regulation, protectionism,
public ownership, pervasive corruption and slow growth. Since 1991, continuing
economic liberalisation has moved the country towards a market-based economy.
In 1991, after the International Monetary Fund (IMF) had bailed out the bankrupt
state, the government of P. V. Narasimha Rao and his finance minister Manmohan
Singh started breakthrough reforms. The new policies included opening for
international trade and investment, deregulation, initiation of privatization, tax
reforms, and inflation-controlling measures. The overall direction of liberalisation
has since remained the same, irrespective of the ruling party, although no party
has yet tried to take on powerful lobbies such as the trade unions and farmers, or
contentious issues such as reforming labor laws and reducing agricultural
subsidies.

Monetary Policy of India:-

The Monetary and Credit Policy is the policy statement, through which the
Reserve Bank of India seeks to ensure price stability for the economy. These
factors include - money supply, interest rates and the inflation. In banking and
economic terms money supply is referred to as M3 - which indicates the level
(stock) of legal currency in the economy.

Besides, the RBI also announces norms for the banking and financial sector and
the institutions which are governed by it. These would be banks, financial
institutions, non-banking financial institutions and primary dealers (money
markets) and dealers in the foreign exchange (forex) market.

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The Monetary Policy has become dynamic in nature as RBI reserves its right to
alter it from time to time, depending on the state of the economy. However, with
the share of credit to agriculture coming down and credit towards the industry
being granted whole year around, the RBI since 1998-99 has moved in for just one
policy in April-end. However a review of the policy does take place later in the
year.

The Monetary Policy regulates the supply of money and the cost and availability
of credit in the economy. It deals with both the lending and borrowing rates of
interest for commercial banks. The Monetary Policy aims to maintain price
stability, full employment and economic growth. The Reserve Bank of India is
responsible for formulating and implementing Monetary Policy. It can increase or
decrease the supply of currency as well as interest rate, carry out open market
operations, control credit and vary the reserve requirements.

The Monetary Policy is different from Fiscal Policy as the former brings about a
change in the economy by changing money supply and interest rate, whereas
fiscal policy is a broader tool with the government.

The Fiscal Policy can be used to overcome recession and control inflation. It may
be defined as a deliberate change in government revenue and expenditure to
influence the level of national output and prices. For instance, at the time of
recession the government can increase expenditures or cut taxes in order to
generate demand.

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On the other hand, the government can reduce its expenditures or raise taxes
during inflationary times. Fiscal policy aims at changing aggregate demand by
suitable changes in government spending and taxes.

The annual Union Budget showcases the government's Fiscal Policy.

Talking about the uses of Monetary Policy:-

1. Monetary policy cannot change long-term trend growth.


2. There is no long-term tradeoff between growth and inflation. (High
inflation can only hurt growth).
3. What monetary policy – at its best – can deliver is low and stable
inflation, and thereby reduce the volatility of the business cycle.
4. When inflationary pressures build up:
raise the short-term interest rate (the policy rate) which raises real
rates across the economy which squeezes consumption and investment.

SCENARIO PRIOR TO RECENT LIBERALISATION:-


Prior to recent liberalisation, the RBI resorted to direct instruments like interest
rates regulation, selective credit control and CRR (cash reserve ratio) as monetary
instruments.

One of the risks emerging in the past 5-7 years (through the capital flows and
liberalisation of the financial sector) is that potential risk has increased for
institutions. Thus, financial stability has become crucial and there are concerns
relating to credit flows to the agricultural sector and small-scale industries.

Instruments of Monetary Policy in India:-

1. Net loans to central government (i.e. open market operations)


2. Net purchase of foreign currency assets
3. Change in cash reserve ratio
4. Changes in repo rate and reverse repo rate
5. Bank rate

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CRR & SLR:-

CRR, or cash reserve ratio, refers to a portion of deposits (as cash) which banks
have to keep/maintain with the RBI. This serves two purposes. It ensures that a
portion of bank deposits is totally risk-free and secondly it enables that RBI
control liquidity in the system, and thereby, inflation.

Besides the CRR, banks are required to invest a portion of their deposits in
government securities as a part of their statutory liquidity ratio (SLR)
requirements. The government securities (also known as gilt-edged securities or
gilts) are bonds issued by the Central government to meet its revenue
requirements. Although the bonds are long-term in nature, they are liquid as they
can be traded in the secondary market.

Since 1991, as the economy has recovered and sector reforms increased, the CRR
has fallen from 15 per cent in March 1991 to 5.5 per cent in December 2001 and
currently it is 6.0 percent as on August 2010.

Every bank is required to maintain at the close of business every day, a minimum
proportion of their Net Demand and Time Liabilities as liquid assets in the form of
cash, gold and un-encumbered approved securities. The ratio of liquid assets to
demand and time liabilities is known as Statutory Liquidity Ratio (SLR). Present
SLR is 25% (As on August 2010). RBI is empowered to increase this ratio up to
40%. An increase in SLR also restricts the bank’s leverage position to pump more
money into the economy.

SLR, or Statutory Liquidity Ratio is the amount of liquid assets, such as cash,
precious metals or other short-term securities, that a financial institution must
maintain in its reserves.

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The objectives of SLR are:

1. To restrict the expansion of bank credit.


2. To augment the investment of the banks in Government securities.
3. To ensure solvency of banks. A reduction of SLR rates looks eminent to
support the credit growth in India.

Talking about the Interest rates:-

Bank rate is the minimum rate at which the central bank provides loans to the
commercial banks. It is also called the discount rate.

Usually, an increase in bank rate results in commercial banks increasing their


lending rates. Changes in bank rate affect credit creation by banks through
altering the cost of credit. The bank rate signals the central bank's long-term
outlook on interest rates. If the bank rate moves up, long-term interest rates also
tend to move up, and vice-versa.

Banks make a profit by borrowing at a lower rate and lending the same funds at a
higher rate of interest. If the RBI hikes the bank rate, the interest that a bank pays
for borrowing money (banks borrow money either from each other or from the
RBI) increases. It, in turn, hikes its own lending rates to ensure it continues to
make a profit.

Currently the bank rate is 6% (As on August 2010).

Repo or Repurchase rate is the rate at which banks borrow funds from the RBI to
meet the gap between the demand they are facing for money (loans) and how
much they have on hand to lend.

If the RBI wants to make it more expensive for the banks to borrow money, it
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increases the repo rate; similarly, if it wants to make it cheaper for banks to
borrow money, it reduces the repo rate.

Currently as on August 2010, Repo rate is 5.75 %.

Reverse Repo rate is the rate at which Reserve Bank of India (RBI) borrows money
from banks. Banks are always happy to lend money to RBI since their money are
in safe hands with a good interest. An increase in Reverse repo rate can cause the
banks to transfer more funds to RBI due to this attractive interest rates. It can
cause the money to be drawn out of the banking system.
Due to this fine tuning of RBI using its tools of CRR, Bank Rate, Repo Rate and
Reverse Repo rate banks adjust their lending or investment rates for common
man.

Currently as on August 2010, Reverse Repo rate is 4.50 %.

Till the late 1980’s, interest rates were more directive in nature as one would
expect them to be in a centrally planned economy. They were used to direct
investments in or out of various sectors, geographical areas, demography and
areas of business activity which the government believed were economic
priorities.

In 2003, the BPLR was introduced to provide a basis for loans pricing in order to
remedy the complex interest rates structure after they were gradually
deregulated. Somewhere down the line banks were permitted to lend at sub PLR
rates to credit worthy borrowers, a term usually taken to mean every borrower
who is sanctioned a loan – could the bank ever lend to a borrower who is not
considered credit worthy? Many banks then progressed to using different
reference rates for different customer segments/ products.

Around this time banks had also discovered the virtues of ‘consumer lending’ the
western oriented term for commoditised mass retail lending. They had realised
that, the retail borrower could be priced liberally due to their comparative smaller
ticket sizes, lack of market information and negotiation power. Gradually, though
as competition gathered and pricing became increasingly irrational.

The evolution of the BPLR can be traced back to September 1990 when the first
attempt to rationalise the administered lending rate structure was made by
removing multiplicity and complexity of interest rates. According to this structure,
the advances of scheduled commercial banks were divided into six slabs and

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progressively higher interest rates were prescribed for larger advances (subject to
a floor rate).

While for the lowest slab consisting of advances amounting up to Rs. 7,500, a
minimum interest rate of 10 per cent per annum was prescribed, advances of
above Rs. 2 lakh, which fell under the highest slab, were prescribed a minimum
rate of interest of 16 per cent per annum. While the above structure was applied
to both working capital and term loans, concessional rates were offered on term
loans to agriculture, small-scale industry and specific transport operators.

The next major step in the evolution of BPLR took place in April, 1993, in the
backdrop of the financial sector reforms of the early 1990s wherein the credit
limit size classes of scheduled commercial banks, on which administered rates
were prescribed, were reduced into three slabs; (i) advances up to and inclusive
of Rs. 25,000; (ii) advances over Rs. 25,000 and up to Rs. 2 lakh; and (iii) advances
over Rs. 2 lakh.

In October of the next year with the intent of deregulation of lending rates, it was
decided that banks would determine their own lending rates for credit limits over
Rs.2 lakh in accordance with their risk-reward perception and commercial
judgment. However, banks were required to declare their prime lending rate
(PLR) i.e. the rate charged for the prime borrowers of the bank, with the approval
of their boards taking into account their cost of funds, transaction cost, etc.

There were however, two main reasons why banks found it difficult to fairly price
lending. Firstly, most commercial banks were not computerised and hence
gathering interest pricing information proved cumbersome.

Also, changing interest rates across manual ledgers spread across hundreds of
branches, in response to market movements was equally difficult. Secondly,
banks had the vast majority of their deposits in the less than one year maturity
buckets and CASA (Current Account and Savings Account) deposits.

This is evident in the fact that, when interest rates were going up to reflect the
monetary tightening between March 2004 and September 2009, banks responded
quite well. However, they were extremely sluggish when reducing them later in
2009 because; the 11% rate in March 2009 did not decline by more than about
100 basis points despite the sharper drop in market rates.

Actually it was till as recent as August 2004, that, many banks could only stake
claim to very crude price levying and monitoring mechanisms. Therefore, in most
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cases whilst new loans were fixed at current market rates, old loans invariably
continued at old interest rates. Most of the retail loans were funded from near
term liabilities and it was only when the average yield on these loans started
dropping as a result of increase in money market rates, that, banks realised the
need to respond with aggressive re-pricing of their historical book.

It is obvious therefore, that, banks found it more comfortable to increase interest


rates than decrease them considering that, the former was always less riskier
when seen in light of possible revenue losses resulting from loss in margins. In
effect, borrowers were paying the price for operational inefficiencies.

The worst outcome of these inefficiencies is that, the smaller, retail loans which
were priced much higher would end up subsidising the larger borrowers. This was
of course gradually set right after, private retail lenders gradually convinced bank
treasuries to introduced effective ‘funds transfer pricing mechanisms’. It is
therefore; hardly surprising that, banks gradually moved to high yielding retail
assets whilst business lending became increasingly shorter term.

All is certainly not well and it was only right that, the RBI initiated a Working
Group in its 2009-10 Annual policy to review everything about the infamous BPLR.

Over 70 per cent of bank loans were at sub PLR rates thereby making loans pricing
completely opaque to the policy makers.

It was therefore, obvious that, the main issue to be addressed was to get loan
pricing transparent to all stakeholders and particularly to the RBI allowing it to
measure the responsiveness of bank interest rates to changes in policy rates.
Without this happening how can deregulation of interest rates ever become
useful in terms of their influence to our economy?

Reserve Bank of India constituted a Working Group on Benchmark Prime Lending


Rate (Chairman: Shri Deepak Mohanty) to review the present benchmark prime
lending rate (BPLR) system and suggest changes to make credit pricing more
transparent.

The Working Group in October 2009, made two important recommendations:

- Introduce a Base Rate to replace the BPLR. All loans pricing will happen over the
base rate by including premiums to represent specific product operating risk,
credit and tenor risk.

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- The constituents of the Base Rate being; the card interest rate on retail deposits
(below Rs 15 lacs) of maturity less than 1 year. This rate will be adjusted the
impact of CASA and for the negative impact of the CRR and SLR. It will be further
adjusted to provide for overhead costs and average return on net worth.

The Base Rate system has replaced the BPLR system with effect from 1st July 2010,

Computation of the Base Rate:-

Base rate = a + b + c + d

Where

a is the Cost of Deposits/funds = Dcost


b is the Negative Carry on CRR and SLR =

[[{Dcost – (SLR * Tr)} / {1- (CRR + SLR)}] * 100] - Dcost

c is the Unallocatable Overhead Cost = (Uc / Dply) * 100

d is the Average Return on Net Worth = [(NP / NW) * (NW / Dply)] * 100

Where:
Dcost : Cost of Deposits/funds
D: Total Deposits = Time Deposits + Current Deposits + Saving Deposits

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Dply = Deployable Deposits
= Total deposits less share of deposits locked as CRR and SLR balances, i.e.
= D * [1 – (CRR+ SLR)]

CRR: Cash Reserve Ratio


SLR: Statutory Liquidity Ratio
Tr : 364 T‐Bill Rate
Uc : Unallocatable Overhead Cost
NP : Net Profit
NW : Net Worth = Capital + Free Reserves

Unallocatable Overhead Cost:-


Unallocatable Overhead Cost = (Uc / Dply) * 100

Unallocatable Overhead Cost is calculated by taking the ratio (expressed as a


percentage) of unallocated overhead cost and deployable deposits.

Average Return on Net Worth:-


Average Return on Net Worth = [(NP / NW) * (NW / Dply)] * 100

Average Return on Net Worth is computed as the product of net profit to net
worth ratio and net worth to deployable deposits ratio expressed as a percentage.

Since no bank will be permitted to give loans below the base rate, large
companies, which had been getting loans lower than the benchmark prime
lending rate, will now have to pay as much as 200 basis points more as per the
Bankers.

The most important thing to keep in mind is that the cost of money is not
changing, i.e., if my car loan cost about 12% or home loan cost 9%, this rate of
interest charged to me will be no different going forward. It’s just that the
method used to arrive at this will be clearer. So, interest rates aren’t coming
down as a result of this base rate implementation.

Following on from this, EMI on an existing loan is also not going to change. We
will continue to pay whatever we were paying up to last month in future months
as well.

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The most common question that has been arising in the minds of the people is
that should they shift to the Bank with the lower base rate? But shifting to the
Bank with lower base rate will not be able to do major difference. Banks will now
be more precise in selecting the premium for risk and tenure, resulting in an
increase in the loan rates to the corporate sector, Cost of borrowing will slightly
increase, and to the extent money is borrowed from the banks. Once a base rate
is determined, bank will not be able to give a loan to any corporate below the
base rate. At this moment, there are some AAA companies who are enjoying a 7–
7.5 per cent rate according to the bankers.

At least six other public sector banks, including Punjab National Bank and Bank of
Baroda, announced their base rate—all pegging it at 8%. Private Banks, including
ICICI Bank Ltd, India’s second largest lender.

For every bank, the base rate is lower than the BPLR which it replaces, but that
does not necessarily mean that the cost of money will decline for borrowers. This
is because no bank will be allowed to price loans cheaper than the base rate.

The new regime has been put in place by the Reserve Bank of India to ensure that
small businesses don’t end up subsidizing below-BPLR borrowings by top-rated
firms that have been able to raise funds at much lower rates.

Until now, around 70% of borrowers have been raising money at below BPLR.
Although the BPLR of most public sector banks ranges between 11.5% and 12.5%,
triple A-rated corporate borrowers were raising short-term loans at a rate as low
as 6.75-7%. Private Banks are expected to set their base rate lower, but their
public sector counterparts are not worried about losing customers to the
competition.

The Price of growth:-

Despite banks' success with informal channels, reaching rural customers comes
with a price tag. The main challenge, bankers point out, lies in financial education:
helping the masses to understand these products, and the benefits of saving and
investing. The faster users of banking services learn of the benefits, the shorter
will be the bank's gestation period in recovering its investments.

In response, financial literacy centers are being set up across India. Members of
SEWA Bank -- a cooperative bank established in 1974 by 4,000 self-employed
women -- have held three-day financial education camps in the state of Orissa.

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Such centers provide individual counseling services on responsible borrowing and
early savings.

As incomes grow and awareness increases, aspirations rise among the poor.
Moreover, rural savings deposits tend to remain in customers' accounts. In the
long run, this reduces a bank's dependence on bulk deposits, minimizing the risk
posed by sudden large withdrawals.

Therefore now a days, banks are stressing on increasing their rural customers
which will help them to increase their customer base and help in generating more
revenues. Deregulation of lending rates will promote financial inclusion with
greater credit flow to agriculture and small business. This, together with other
specific measures taken by the Reserve Bank for financial inclusion, will draw
borrowers away from the informal financial sector to the formal financial sector
and thus, facilitate credit penetration.

Improvement of Operational efficiency:-

Bankers say the base rate system will help cut the arbitrage advantage some top
corporate borrowers enjoyed. They say loans extended to larger companies lately
have been under-priced and the volumes lent too have been very large. Banks will
now be compelled to tap cost effective resources, improve operational efficiency,
and include profit spread margin and risk premium along with the client’s
credibility while determining the base rate. This will cut down on under-pricing of
loans and bring uniformity in the system.

In the recent circular of State Bank of has linked all small and medium enterprise
(SME) loans with the base rate, which became effective on July 1, 2010. SBI has
linked all the new SME loans disbursed from July 1 to the base rate, with effective
interest rate continuing at the existing level.

State Bank of India has fixed the base rate at 7.5 per cent, much lower than BPLR
rate of 11.75 per cent that it charged before the base rate became effective. SBI
has fixed the base rate at 7.5 per cent, much lower than BPLR rate of 11.75 per
cent that it charged before the base rate became effective this month.

The effective interest rates for all existing SME loans will remain unchanged, it
said. The loan given to SME sector depending on various conditions varies in
between 8.5 per cent to 12 per cent.

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The interest rates will remain valid until further notice or unless the base rate is
revised in the meantime, it added. Meanwhile, the bank has extended its 8 per
cent concessional home loan scheme for another three months till September,
2010.

For the first year, home loan would carry eight per cent interest rate and for the
second and third years it would attract nine per cent rate.

From the fourth year onwards, the rate is linked to base rate, and the effective
rate is 9.25 per cent for loans upto Rs 50 lakh and 9.75 per cent for loans above Rs
50 lakh at present.

Car loan is also available at 8 per cent concessional rate and 10 per cent fixed for
the second and third years.

Expected impact of Base rate:-

It is expected that base rate system will increase transparency in credit pricing
and address the shortcomings of the BPLR system. Benchmark rate of most of the
banks will decline to single digit. Again with the base rate, including negative carry
on Cash Reserve Ratio (CRR) and Statutory Liquidity ratio (SLR) it is anticipated
that base rate will be directly impacted by the monetary measures initiated by the
RBI. Taking the calculation of RBI, Ceteris paribus, with an increase of 75 bps in
the CRR, the base rate increases by 8 bps to 8.63% and an increase of 100 bps in
the SLR from 24% to 25% could push up the minimum lending rate by 12 bps to
8.67%.

Small borrowers such as farmers who are close to BPLR rates would get credit at
reasonable rates after the introduction of base rate. At the same time, large
corporations that earlier utilized their negotiating power and bargained with
banks in order to obtain loans at sub-BPLR rates, could find it difficult due to the
minimum rate fixed by banks.

What this means for banks:-

Large banks that have higher percentage of low cost deposits and better
operating efficiency will have a lower base rate and thus they will be able to price
their loan products competitively. Small banks on the other hand will face
problems in extending credit to large corporate. This would render a number of
banks uncompetitive and enable big banks to increase their business.

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The base rate regime will have minimal impact on the fixed rate home loan
customer apart from the fact that at the time of signing up for the loan s/he will
know the bank's base rate and the associated spread. The greater transparency
will help her/him in taking a more informed decision.

Otherwise, s/he will service her/his loan at the same rate of interest for the
remaining tenor.

The impact of the base rate will be clearly understood by the floating rate
customer. A revision in the interest rates (upward/downward) will impact the
base rate, the spread remaining constant and the final lending rate to the
consumer will change by the amount of increase/decrease in the base rate.

Say, for example, the interest rate was 10 per cent at the time of signing up for
the loan (base rate: 8 per cent + other charges 2 per cent). Say the base rate
changes by 50 basis points (100 basis points = 1 per cent) due to an upward swing
in the deposit rates which means now the new interest rate will be 10.5 per cent
for the customer (base rate 8.5 per cent + other charges 2 per cent).

A similar computation will take effect if the rates have a downward swing. This
will address issues of 'downward stickiness' of rates in case of the BPLR regime.

While the actual change in the interest rate will be nominal if any, the new system
ushers in greater transparency. This will also mean an end to the teaser home
loan campaigns launched since banks can no longer lend below their base rate.
Most banks have published their base rate in a public domain.

If someone would have brought home loan at a higher rate of interest and are still
in the interest paying phase, he/she can re-negotiate home loan with bank and
shift to the new base rate regime at no extra cost. For new buyers, this new
transparency empowers him to take better informed decisions.

But please do note that these new guidelines are impacting only banks. Other
NBFC lending institutions do not come under the purview of the base rate and
can still lend basis the erstwhile BPLR system.

RBI exemption to exporters from base rate system:-

The rupee loans to exporters engaged in four labour-intensive sectors—


handicrafts, carpets, handlooms and SMEs— will be exempt from the base rate
system, but the lending rate to these sectors cannot fall below 7%. However the

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lending rate to these sectors cannot fall below 7%. If the interest rate charged to
exporters (of the above sectors) goes below the base rate, such lending will not
be construed to be violative of the base rate guidelines according to the
notification. Initially the government provides interest subsidy of 2 percentage
points on these loans subject to the condition that banks will charge interest rate
not exceeding the benchmark prime lending rate (BPLR) minus 4.5%.

Base Rate for different Banks:-

Public Sector Banks

Banks Base Rate (p.a.)


State Bank of India 7.50%
Federal Bank 7.75%
State Bank of Mysore 7.75%
Corporation Bank 7.75%
Bank of India 8.00%
Punjab National Bank 8.00%
Bank of Baroda 8.00%
Union Bank 8.00%

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Central Bank of India 8.00%
Indian Bank 8.00%
Uco Bank 8.00%
IDBI Bank 8.00%
Indian Bank 8.00%
Canara Bank 8.00%
Vijaya Bank 8.25%
Indian Overseas Bank 8.25%

Private Sector Banks

Banks Base Rate (p.a.)

HDFC Bank 7.25%

ICICI Bank 7.50%

Dhanlaxmi Bank 7.75%

Bank of Rajasthan 8.00%

Karur Vysya Bank 8.50%

HSBC Bank 7.00%

The Base Rate system would be applicable for all new loans and for those old
loans that come up for renewal. Existing loans based on the BPLR system may
run till their maturity. In case existing borrowers want to switch to the new
system, before expiry of the existing contracts, an option may be given to them,
on mutually agreed terms. Banks, however, should not charge any fee for such
switch-over.

Since the Base Rate will be the minimum rate for all loans, banks are not

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permitted to resort to any lending below the Base Rate. Accordingly, the current
stipulation of BPLR as the ceiling rate for loans up to Rs. 2 lakh stands withdrawn.
It is expected that the above deregulation of lending rate will increase the credit
flow to small borrowers at reasonable rate and direct bank finance will provide
effective competition to other forms of high cost credit.

Although the base rate may come down in the long-run, immediately the large
borrowers, particularly good borrowers, who had enjoyed funds at less than the
BPLR will have to shell out more towards interest as they cannot borrow at less
than the base rate. This may naturally lead them to resort to some other means
to raise funds or banks will be compelled to compensate them to retain as their
customers which is not desirable.

They may go in for Commercial papers or external commercial borrowings or raise


deposits from the public directly at less than the base rate. In any case, this will
have an adverse impact on banks' funds management and profitability. In such a
situation, banks will be forced to entertain comparatively risky borrowers adding
to their non-performing loans and consequent problems.

Although, the concept of base rate is good to establish healthy credit market and
improve banks' asset liability management down the years, it may in the
immediate future upset the corporates' borrowing programmes and bring some
visible changes in the money market operations. In case the base rate stabilizes, it
may also pave way to develop corporate bond market in a big way. Present
surplus liquidity situation in the economy and continued persistence of higher
level of inflation, however, supports a higher base rate and from that angle the
timing of introduction of base rate seems well intended and justifiable.

The Base Rate is still on a temporary basis i.e. In order to give banks some time to
stabilize the system of Base Rate calculation, banks are permitted to change the
benchmark and methodology any time during the initial six month period i.e. end-
December 2010.

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