COMMENTARY
primary agricultural credit societies (PACS)
Rural Short-term Cooperative
Credit Structure
This article critiques the package initiated by the government of India that aims at reviving the rural short-term cooperative credit structure in the country.
We thank Jesim Pais and an anonymous referee for valuable comments. All errors are ours.
Mandira Sarma (mandira@icrier.res.in) and Rajiv Kumar (rkumar@icrier.res.in) are with the Indian Council for Research on International Economic Relations, New Delhi.
Economic & Political Weekly
EPW
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Overview
The RSTCCS is structured as a three-tiered federal structure – with state cooperative banks (SCBs) at the state (apex) level, district central cooperative banks (DCCBs) at the district (intermediate) level and average every seventh village has a primary agricultural credit society. This, along with more than 125 million members of the PACS, makes the RSTCCS India’s most extensive network of rural institutional credit.
Notwithstanding the impressive spread, the RSTCCS, particularly the PACS, is severely impaired by financial sickness and problems of management and governance. If energised and made to work efficiently, this network has the potential to have a real impact on credit access in rural India. Table 1 (p 15) presents some aggregate data relating to India’s RSTCCS for the year 2005-06. As shown in the table, a large number of SCB and DCCB branches – about 58 per cent of the SCB and about 71 per cent of the DCCB branches reported profit in the year 2005-06. However, as far as PACS are concerned, only about 42 per cent were profit-making and about 50 per cent reported a loss during the same period. Thus, in 2005-06, at an aggregate level, SCBs and DCCBs recorded profits while PACS recorded a loss.
Asset quality and recovery performance of the RSTCCS are not satisfactory, as per the data shown in Table 1. The
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non-performing assets (NPA) level in the RSTCCS was very high compared to that in the commercial banking system in India. In 2005-06, while the NPA in total credit was between 16 and 30 per cent for the RSTCCS, the same for public sector banks was only about 3 per cent. The debt-equity ratio for the entire structure, however, was lower when compared to the commercial banking system, reflecting a less risky capital structure than the commercial banking system. In 2005-06, the debt-equity ratio for the RSTCCS was 0.6 when compared with the debt-equity ratio for the commercial banking sector, which was 8.2. The credit deposit ratio (CD ratio) was 82 per cent, 87 per cent and 265 per cent respectively for SCBs, DCCBs and PACS in 2005-06, higher than the CD ratio of commercial banks in India for the same period, which was 70 per cent. The high CD ratios of the RSTCCS reflect what the Vaidyanathan Committee calls the “borrower-driven” feature of the RSTCCS.
Revival Initiative
In order to analyse the problems faced by the RSTCCS and suggest an action plan for reviving the rural cooperative credit structure, the government of India set up a task force in August 2004. The task force, also known as the Vaidyanathan committee after its chairperson, submitted its report on February 2005. The committee has examined the prevailing state of affairs of the RSTCCS and analysed the causes of financial sickness of the structure. It has recommended several measures for the revival of the entire structure, the major recommendations being: financial revival; upgradation of skill, capacity building and technical assistance; and institutional, legal and regulatory reforms.2
The revival package based on the committee’s recommendations initiated by the government in 2006 is an “integrated package” incorporating all the above recommendations. The National Bank for Agriculture and Rural Development (NABARD) has been delegated the task of implementing the revival package, under the guidance and supervision of a national implementing and monitoring committee (NIMC) chaired by the governor of the Reserve Bank of India (RBI).
As of December 2007, 13 states have signed a memorandum of understanding (MoUs) with the government of India and NABARD for the implementation of the revival package – Andhra Pradesh (AP), Arunachal Pradesh, Bihar, Chhattisgarh, Gujarat, Haryana, Madhya Pradesh (MP), Maharashtra, Orissa, Rajasthan, Uttarakhand, Uttar Pradesh (UP) and West Bengal (WB). Many other states have also, in principle, decided to avail of the revival package.3 The committee has advised that the revival scheme be kept open for two years for the states to decide on their participation. Accordingly, the government of
March 1, 2008
COMMENTARY
India has decided to wait until March 2008 for the states to make a decision in this regard. It is not clear to us whether a state has the option of not participating in the revival plan after this period is over.
Table 1: Summary of Rural Short-term Cooperative Credit Structure in India (as on March 31, 2006)
Item | SCB | DCCB | PACS |
---|---|---|---|
Total no of banks/societies | 30 | 370 | 106384 |
No of branches | 962 | 12991 | |
(i) Profit-making | 561 | 9225 | 44321 |
(58.3) | (71.0) | (41.7) | |
(ii) Loss-making | 254 | 2777 | 53050 |
(26.4) | (21.3) | (49.9) | |
Total membership (in 000) | 154 | 2268 | 125197 |
Total no of employees (in 000) | 15 | 213 | 242 |
Financial summary (in Rs crore) | |||
Paid-up capital (I) | 109424 | 4511 | 5644 |
of which govt contribution | 13912 | 770 | 623 |
(12.7) | (17.1) | (11.0) | |
Total reserves (II) | 7343 | 14083 | 3648 |
Total deposits (III) | 47672 | 86652 | 19561 |
Total borrowings (IV) | 16872 | 23202 | 41018 |
Working capital (WC) (V) | 74544 | 131242 | 73387 |
Total loans issued (VI) | 48804 | 69318 | 42920 |
Total loans outstanding (VII) | 38961 | 76737 | 51779 |
Total amount of profit | 450 | 1379 | 1064 |
Total amount of loss | 274 | 405 | 1920 |
Aggregate profit/loss (-) (VIII) | 176 | 974 | -856 |
Total amount of NPA (IX) | 6072* | 14520* | 15476** |
NPA as % of (VII) | 16.3* | 19.9* | 29.9 |
Debt-equity ratio | 0.2 | 5.1 | 7.3 |
Credit deposit ratio (%) | 81.7 | 88.6 | 264.7 |
Cost of management to WC (%) | 1.2 | 2.3 | NA |
Figures in parenthesis are percentage in total.
* Relates to March 2005. ** Total overdues, NA implies not available. Sources: Report on Trend and Progress of Banking in India, 2005-06, RBI, NAFSCOB and authors' calculation.
The 13 participating states together represented 78.8 per cent of the total number of PACS in India in 2005-06. Tables 2 and 3 present some data on the PACS of these states. As can be seen from Table 3 (p 16), majority of the states have low government shareholding in their PACS. Only three of the states, viz, Arunachal Pradesh, Bihar and West Bengal have more than the stipulated value (stipulated by the revival package) 30 per cent) seem to dominate the list of participating states.
Observations
The recommendations of the committee are being implemented in the form of an integrated revival package incorporating the financial, technological, institutional, legal and regulatory aspects of the recommendations. Here we review two particular recommendations and consequently the revival package. The first relates to the risk management system in rural cooperative banking and the second to the participation of the government in the system in the form of owning share capital.
Capital to Risk-weighted Asset Ratio (CRAR): The committee has recommended that all tiers of the cooperative credit structure be brought under the CRAR framework. The committee has noted that under the present regulatory framework, commercial banks are required to maintain a minimum CRAR of 9 per cent. In view of the requirements of the commercial banking system, it recommended that all tiers of the RSTCCS be initially supported with external resources to achieve a minimum CRAR of 7 per cent. The CRAR may be increased further through internal accretions within three years from the date of capitalisation to 9 per cent, and further to 12 per cent in the next two years.
Retirement of Government Share Capital: The committee has also recommended that the equity capital received by the cooperative credit institutions from the state governments over time must be returned. This, the committee opined, would pave the way for cooperatives to transform into member-driven and member-centric institutions. The revival package stipulates that the government shareholding in each cooperative credit institution be brought down to a maximum limit of 25 per cent.
Some Issues Relating to CRAR: Prudential regulations such as CRAR norms are aimed at ensuring financial discipline for the long term financial health of the structure. The computation of the CRAR is a complex issue involving “risk-weighing” of assets. The committee, however, does not provide practical advice on implementing CRAR calculation. It has recommended that all cooperative credit structure units be supported by the government through a soft loan in the form of tier II capital to achieve a CRAR of a minimum of 7 per cent.
Presently, the commercial banking system in India follows Basel-I norms of CRAR calculation, and will be implementing Basel-II norms this year. As the commercial banking system is moving towards Basel-II with respect to CRAR, the commercial banks and the RBI already face a plethora of challenges [Sarma and Nikaido 2007]. These include replacement of the existing framework of risk-weighted asset calculation by a more complex framework, requirement of extensive data, sophisticated software, increased level of capital requirements, and consequently, higher implementation costs. While the
Table 2: Profile of PACS in States That Have Signed MoU (2005-06)
State | No of PACS | Villages Covered | Members (in 000) | ||||||
---|---|---|---|---|---|---|---|---|---|
Total | Profit-Making Loss-Making | Total | Per PACS | Total | SC/ST | Small/Marginal Rural Artisans | |||
Farmers | |||||||||
AP | 4491 | 1002 (22.3) | 3194 (71.1) | 27551 | 6 | 22010 | 4879 (22.2) 16594 (75.4) | 534 (2.4) | |
Arunachal | 31 | 20 (64.5) | 6 (19.4) | 3649 | 118 | 18 | 18 (100) | 0 (0) | 0 (0) |
Bihar | 5936 | 1168 (19.7) | 3953 (66.6) | 77694 | 13 | 3671 | 624 (17.0) | 3025 (82.4) | 22 (0.6) |
Chhattisgarh | 15 | 14 (93.3) | 1 (6.7) | 22 | 2 | 2.86 | 0.46 (16.1) | 2.29 (80.1) | 0.11 (3.8) |
Gujarat | 8487 | 5027 (59.2) | 2880 (33.9) | 17209 | 2 | 2613 | 644 (24.6) | 1889 (72.3) | 81 (3.1) |
Haryana | 2441 | 1198 (49.1) | 1243 (50.9) | 7077 | 3 | 2748 | 582 (21.2) | 1862 (67.8) | 304 (11.1) |
MP | 4633 | 1792 (38.7) | 2450 (52.8) | 54706 | 12 | 5108 | 1556 (30.5) | 3197 (62.6) | 355 (7.0) |
enthusiastic about the revival package. Further, the NPA levels of the PACS | Maharashtra Orissa | 21045 3860 | 7507 (35.7) 13365 (63.5) 1415 (36.7) 2352 (60.9) | 59662 43221 | 2 11 | 10702 17216 | 1595 (14.9) 13767 (80.0) | 8898 (83.1) 2794 (16.2) | 209 (2.0) 654 (3.8) |
---|---|---|---|---|---|---|---|---|---|
(defined as total overdues as percentage of total loans outstanding) in these states (Table 5, p 17) reveal that the states in which the PACS have high NPA values (i e, higher than the all-India average of | Rajasthan 4772 3060 (64.1) 1300 (27.2) Uttarakhand 446 262 (58.7) 100 (22.4) UP 8929 4536 (50.8) 1968 (22.0) WB 18780 8178 (43.5) 10113 (53.8) Figures in parenthesis are percentage in total. Source : NAFSCOB. | 40709 5900 112804 179176 | 8 13 13 9 | 3788 2748 2748 17872 | 1304 (34.4) 2300 (60.7) 2347 (85.4) 401 (14.6) 2347 (85.4) 401 (14.6) 5319 (29.8) 11793 (66.0) | 185 (4.9) 0 (0.0) 0 (0.0) 761 (4.3) | |||
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COMMENTARY
commercial banks are preparing to meet share of tier I capital to its desired level of Further, the committee’s recommendasuch challenges, cooperative banks will at least 50 per cent. By these estimates, the tion that the CRAR be raised to 12 per cent find the imposition of such complicated total additional tier I capital requirement in the future is far too stringent, given that and stringent norms extremely burden-to the PACS is Rs 23,229 crore. internationally a CRAR of 8 per cent is the some. Given the low level of technical The natural question that then arises is accepted norm, and a CRAR of minimum 9 knowhow, the lack of computerisation and how are the PACS going to raise this capi-per cent is adopted in India’s commercial lack of funds with the cooperative banks, tal? The committee has recommended banking system. challenges of CRAR calculation will indeed that government support should be limbe daunting for the RSTCCS. ited to soft loans, in other words, tier II Government Shareholding and Per-
Even under the assumption that CRAR capital. Since the PACS in these states formance of PACS: According to the implementation for the RSTCCS will be already have tier II capital in excess of Vaidyanathan Committee, one of the most important reasons
Table 3: Financial Summary of PACS in States That Have Signed MoU (2005-06, in Rs lakh)
for the poor perform-
State Paid-up Of which Total Total Total Total Working Total Total Total Total Total Aggregate Capital (I) Government Reserve Deposit Borrowing Resource Capital Loans Loans Overdues Profit Loss Profit/Loss ance of PACS in India is Contribution (II) (III) (IV) or Tier II (I+II+III+ Issues Out-(-)
excessive interference
Capital IV) standing
from the state govern-
AP 46521 1271 (2.7) 18390 77040 565913 707864 564249 240369 519158 179639 4015 17851 -13836
ments. The committee
Arunachal 105 79 (75.2) 156 0 411 672 1636 77 87 61 24 8 16 Bihar 8506 3588 (42.2) 247 5986 49975 64714 44337 23448 35116 33026 520 64 456 points out that “most
Chhattisgarh 8137 1493 (18.3) 3027 16879 50072 78115 87193 5301 18377 33809 115273 168102 -52829 state governments com-
Gujarat 44477 829 (1.9) 41881 17838 368668 472864 529421 357048 388727 126612 3763 3487 276 bine the roles of domi-
Haryana 32121 1178 (3.7) 1964 31961 319210 385256 503523 17431 59452 142328 3709 3906 -197 nant share holder, man-
MP 303042 5360 (17.7) 8416 42436 217277 571171 348022 164234 205854 84775 6007 12847 -6840
ager, regulator, concur-
Maharashtra 136405 4123 (3.0) 43503 13643 783436 976987 1023270 474757 718917 223187 43941 38836 5105
rent supervisor and
Orissa 27182 5744 (21.1) 18022 226859 159120 431183 496403 292859 289033 44186 1290 4757 -3467
auditor”, and “intrusion
Rajasthan 24396 4685 (19.2) 6266 19433 134224 184319 210347 10481 27537 50381 11825 3303 8522
by state governments in
Uttarakhand 1250 285 (22.8) 890 2925 6187 11252 11830 3562958 3414739 33669 107 37 70
the affairs of coopera-
UP 19247 4250 (22.1) 2784 6820 97076 125927 125927 110425 115658 65749 1774 153 1621
tives is enabled and
WB 29149 8882 (30.5) 87232 88973 169191 374545 367807 49971 77240 66311 1615 2918 -1303 Figures in parentheses are percentage in total. justified by their con-Source : NAFSCOB.
tribution to the share under the Basel-I rules (which are simpler tier I capital, this would further worsen capital of cooperatives”. Therefore, in than Basel-II rules), there are some issues the situation. the view of the committee, “...time has that remain unaddressed. First, under An alternative could be that the tier I now come for cooperative credit instithese rules, at least 50 per cent of a bank’s capital be raised by the PACS by raising tutions to return the equity received capital base should consist of its core (or equity capital from their members. Then by them from the state governments tier I) capital, comprising of equity capital the average amount to be paid by a mem-over time”.and disclosed reserves. Data on the capital ber would range between Rs 180 for mem- A look at the available data, however, structure of the PACS in various states bers in Uttarakhand and Rs 12,407 for shows that government shareholding in show that the share of tier I capital in the members in Gujarat. Given
Table 4: Structure of Tier I and Tier II Capital for PACS in States total capital base is much less than this that most of the members in that Signed MoU (2005-06, in Rs lakh)
State Tier I Tier II Total % of Tier I Additional Tier I Capital
requirement. Table 4 presents the struc-the PACS are from a rural
Capital Capital Capital Capital Requirement ture of tier I and II capital for the PACS in and agricultural background (Equity Plus (Borrowings) in Total In % In Rs Lakh
Reserves)
the 13 participating states. and about a third are from
(1) (2) (3) (4) (5) (6) (7)
As shown in column 5 of Table 4, the disadvantaged communi-
AP 46521 565913 612434 7.6 42.4 519392
PACS of only one state, Madhya Pradesh, ties, this may not be a feasi-
Arunachal 105 411 516 20.3 29.7 306
has more than 50 per cent tier I capital in ble option. Further, given
Bihar 8506 49975 58481 14.5 35.5 41469 the total capital base. The other 12 states that the number of mem-Chhattisgarh 11164 50072 61236 18.2 31.8 38908 have a tier I capital of less than 20 per cent bers is large, raising such Gujarat 44477 368668 413145 10.8 39.2 324191 in the total capital. The share is as low as 8 capital may be im practical. Haryana 32121 319210 351331 9.1 40.9 287089 per cent for Andhra Pradesh and about 10 Second, a scheme for MP 303042 217277 520319 58.2 0.0 0
Maharashtra 136405 783436 919841 14.8 35.2 647031
per cent for Gujarat and Haryana. Thus, assigning risk-weights to the
Orissa 27182 159120 186302 14.6 35.4 131938
large additional tier I capital would be assets for CRAR calculation
Rajasthan 24396 134224 158620 15.4 34.6 109828
required by these states to adhere to the 50 will have to be designed.
Uttarakhand 1250 6187 7437 16.8 33.2 4937
per cent target. These risk-weights should be
UP 19247 97076 116323 16.5 33.5 77829
The last two columns in Table 4 present designed such that the agri-
WB 29149 169191 198340 14.7 35.3 140042
the additional tier I capital requirement for cultural credit risk is ade-
Total 2322960 each of these states needed to bring the quately reflected in them. Source: Authors' calculation based on data from Table 3.
16 March 1, 2008
COMMENTARY
the RSTCCS is not so high – it is 13, 17 and 11 per cent respectively for SCB, DCCS and PACS at aggregate levels (Table 1). This is considerably lower than the government shareholding of India’s public sector commercial banks, ranging between 50 and 90 per cent in various public sector banks.
Further, the available data do not suggest that low government shareholding in the PACS would necessarily be associated with better performance of the PACS. Table 5 presents select financial indicators of PACS in all states in India, as
Table 5: Select Financial Indicators of PACS, All States
(as at March 2006, in %)
State | Govt Shareholding | NPA | Profitability |
---|---|---|---|
Andaman and Nicobar | 29.4 | 18.521968 | -0.5 |
Andhra Pradesh | 2.7 | 34.6 | -2.0 |
Arunachal Pradesh | 75.2 | 70.5 | 2.5 |
Assam | 76.6 | 82.6 | -49.5 |
Bihar | 42.2 | 94.0 | 0.7 |
Chandigarh | 0.0 | 25.4 | -33.4 |
Chhattisgarh | 18.3 | 181.8 | -0.7 |
Dadra Nagar Haveli | 33.3 | 72978.615 | 0.0 |
Goa | 29.6 | 18.0 | 2.3 |
Gujarat | 1.9 | 32.6 | 0.1 |
Haryana | 3.7 | 239.4 | 0.0 |
Himachal Pradesh | 27.6 | 42.6 | 1.0 |
Jammu and Kashmir | 14.5 | 33.1 | -1.0 |
Jharkhand | 42.9 | 18.9 | 5.0 |
Karnataka | 18.8 | 304.6 | -1.5 |
Kerala | 9.2 | 9.1 | -0.3 |
Madhya Pradesh | 17.8 | 41.2 | -2.3 |
Maharashtra | 3.0 | 31.0 | 0.0 |
Manipur | 81.4 | 78.2 | -0.4 |
Meghalaya | 60.9 | 17800.1 | -0.5 |
Mizoram | 0.9 | 3530.5 | 35.0 |
Nagaland | 39.6 | 43.1 | 0.0 |
Orissa | 21.1 | 15.3 | -0.8 |
Pondicherry | 66.4 | 12.3 | 0.0 |
Punjab | 2.1 | 23.4 | 0.6 |
Rajasthan | 19.2 | 183.0 | 4.6 |
Sikkim | 61.4 | 1.2 | 1.5 |
Tamil Nadu | 10.4 | 20.8 | -8.1 |
Tripura | 72.1 | 0.8 | -0.3 |
Uttar Pradesh | 22.1 | 56.8 | 1.3 |
Uttarakhand | 22.8 | 1.0 | 0.6 |
West Bengal | 30.5 | 85.9 | -0.3 |
For definitions of NPA and profitability see the text. Source: Authors' calculation based on NAFSCOB data.
in March 2006. As shown in the table, government shareholding of PACS varies between 0 per cent (in Chandigarh) and 81 per cent (in Manipur) with a standard deviation of 25. The average value of government shareholding across states is
29.9 per cent.
As far as NPA (defined as total overdues as percentage of total loans outstanding)
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is concerned, Uttarakhand has the lowest value (at about 1 per cent) while Andaman and Nicobar, Dadra Nagar Haveli, Meghalaya and Mizoram have extremely high value of more than 1,000 per cent. Some states such as Haryana, Maharashtra and Mizoram that have high NPA, have very low government shareholding while some other states such as Sikkim, Tripura and Uttarakhand having lower NPAs have very high government shareholding.
Profitability, defined as aggregate profit as percentage of total resource, varies widely across states. Assam has recorded the largest negative profitability, followed by Chandigarh. There were 15 states having negative profitability, five states with zero profit and altogether 12 states have reported positive profitability in 2005-06. Mizoram has recorded the highest profitability of 35 per cent during this period.
The correlation coefficient between government shareholding and NPA is found to be 0.07 and that between government shareholding and profitability is found to be -0.20. Both these correlation coefficients are statistically insignificant with the corresponding values of the t-statistic being 0.37 and -1.11 respectively.4 Thus, the available data do not reveal a statistically significant relationship between government shareholding and performance of the PACS.
At this juncture, it seems that the impairment in governance and management of PACS in particular and the RSTCCS in general could be more due to the “borrower-driven” nature of the structure, poor human resources and lack of standardised business models. The poor management of the RSTCCS could also be due to the dual-control of the cooperative structure by state governments and the RBI. Based on these observations, we recommend that policy attention be focused more on enhancing human resource quality and technical and managerial capability, in addition to an improvement of the accounting system.
Why a Three-tier Structure? As des cribed earlier, the RSTCCS in India is a three-tier pyramid structure. One of the important gaps of the committee report is that the pros and cons of having such a structure have not been examined.
While the three-tier structure is supposed to be a federal one, with higher tiers acting as federation of the lower tiers, providing for economies of scale and risk sharing, in many states this is not the case [Sen 2005]. It has been found that the three-tier structure has in fact posed inefficiency and high transaction cost in the credit delivery system. The Vyas Committee on Flow of Credit to Agriculture had recognised the inefficiencies posed by the three-tier structure in the rural cooperative credit institutions. It pointed out that “In the three-tier cooperative credit structure, each tier adds its costs and margins to the interest rates and ultimately, the borrower gets credit at a relatively higher rate of interest...The rates of interest charged to the ultimate borrower by the cooperatives have been in the range of 12 to 14 per cent” [Vyas Committee 2004]. This is much higher than the short-term lending rates of commercial banks, which hovered between 10.25 and 11 per cent during the period 2001-05.
Thus, the poor recovery level of the cooperative banks can be explained, at least partially, by the high lending rates, caused by, among other things, the threetiered structure itself.
The committee did not address the important issue of the present structure of the system. In its recommendation to first revive the PACS and then the higher tiers, it takes the view that the status quo should be retained, despite the evident inefficiencies.
Concluding Remarks
In spite of significant development in India’s financial sector over the last decade, a large number of rural poor, particularly from the marginal communities remain “financially excluded” even today. Given its impressive network and its spread to the rural poor, the RSTCCS could easily play an important role in enhancing “financial inclusion” in India. But this can be achieved only if the present state of financial sickness of the structure is adequately addressed. In this article we review the committee’s recommendations and government of India’s revival package for the short-term rural cooperative credit structure. We have presented a few observations, viz, those relating to the
COMMENTARY
difficulties of implementation of CRAR structure without the intermediate layer, the DCCBs.
norms, lack of strong relationship between
2 For details of the recommendations refer to government shareholding and perform-Vaidyanathan Committee (2005). 3
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References
Sen, Abhijit (2005): ‘Rural Cooperative Banks: Their Present Problems’ in V K Ramachandran and Madhura Swaminathan (eds), Financial Liberalisation and Rural Credit in India, Tulika Books, pp 137-46.
Vaidyanathan Committee (2005): ‘Report of the Task Force on Revival of Rural Cooperative Credit Institutions’, report submitted to the ministry of finance, available at http://finmin.nic.in/downloads/reports/ReportTFCoopCrIns.html
Vyas Committee (2004): ‘Report of the Advisory Com
mittee on Flow of Credit to Agriculture and
Notes
Sarma, M and Y Nikaido (2007): ‘India’s Capital Related Activities from the Banking System’,
In the north-east Indian states and some small Adequacy Regime’, Economic & Political Weekly, available at http://www.rbi.org.in/scripts/BS_
states of India, RSTCCS is organised as a two-tier Vol 42, No 43, pp 66-71. ViewBulletin.aspx?Id=5505
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