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Public and Private Sector Banks: Convergence in Performance

This article examines the performance of public sector banks and the new private sector banks over the period 2005-06 to 2010-11. What emerges is that while the relative performance of public sector banks had improved signifi cantly by 2005-06, the new private sector banks had moved ahead by 2010-11. It appears that early gains by public sector banks may have been the result of initial slack in the system and new gains will require radical changes in human resource management and corporate governance practices. Such reforms are urgent in the light of the proposal to issue new banking licences.

COMMENTARY

lower in PSBs than in private and foreign

Public and Private Sector Banks banks, though this could be attributed to

the larger spread of PSBs.

Convergence in Performance  Politically-influenced process of ap

pointing board members.

 Bureaucratic system of appointing Sidharth Sinha chief executives.

This article examines the performance of public sector banks and the new private sector banks over the period 2005-06 to 2010-11. What emerges is that while the relative performance of public sector banks had improved significantly by 2005-06, the new private sector banks had moved ahead by 2010-11. It appears that early gains by public sector banks may have been the result of initial slack in the system and new gains will require radical changes in human resource management and corporate governance practices. Such reforms are urgent in the light of the proposal to issue new banking licences.

Sidharth Sinha (sidharth@iimahd.ernet.in) is with the Indian Institute of Management, Ahmedabad.

A
ccording to the Report on Currency and Finance 2006-08,1 “the ownership of public sector banks is not an issue from the effi ciency viewpoint as public sector banks in India now appear to be as efficient as new private and foreign banks”. This view was also highlighted by the governor of the Reserve Bank of India (RBI)2 in a 2010 speech,

Importantly, the performance of public sector banks has converged with that of new private sector and foreign banks. Even, more importantly, contrary to popular perception, there is also no signifi cant relationship between ownership and efficiency – the most efficient banks straddle all three segments – public sector banks, private sector banks and foreign banks.

This is surprising given the general conclusion regarding government ownership of banks. While state ownership of banks may contribute to fi nancial stability and financial inclusion, it usually results in loss of efficiency and productivity. For example, the Committee on Financial Sector Assessment (CFSA) points out the following “cons” of government ownership of banks in India:3  The functioning of public sector banks (PSBs) is often subject to infl exible and, at times, dated rules. The layered decision-making process and uniformity in rules across the banks could impinge on their flexibility in operations. The stringent Central Vigilance Commission guidelines, which the PSBs are subjected to, make it difficult for them to innovate and compete with the private sector and foreign banks who enjoy relatively greater flexibility in operations. Human resource (HR) issues, such as development of core competence, appropriate and market-related incentive structure, and attractive career paths make it diffi cult for PSBs to attract and retain talent. The productivity of human capital, which is measured in terms of business per employee, is observed to be

The question of state ownership of banks and its implications for effi ciency acquires importance when considering the entry of new private sector banks. The RBI has proposed to issue licences to a limited number of new banks. According to the RBI Consultation paper, “A larger number of banks would foster greater competition, and thereby reduce costs, and improve the quality of service”.4 If ownership patterns affect performance then it may be necessary to either alter the ownership structure of PSBs or restructure corporate governance to mitigate the negative effects of state ownership prior to introducing competition. In the absence of such restructuring, PSBs may face similar problems that Air India and BSNL/MTNL are facing because of heightened private sector competition.

This article examines the relative performance of public and private sector banks during the period 2005-06 to 2010-11. This is a period of high growth for the Indian economy and includes both a “boom” period and a period of stress for financial institutions around the world. The comparison is based mainly on data from the RBI annual publication, A Profile of Banks.

PSBs are statute-based banks. They are regulated by their respective statutes of Parliament in addition to some important provisions of Banking Regulation Act, 1949 as enunciated in Section 51. Primarily, PSBs constitute the following:

  • (a) State Bank of India (SBI) and the subsidiary banks: SBI is regulated by the State Bank of India Act, 1955; subsidiary banks of the State Bank of India regulated by the State Bank of India (Subsidiary Banks) Act, 1959.
  • (b) Nationalised banks regulated by the Banking Companies (Acquisition and Transfer of Undertakings) Act, 1970 and 1980.
  • The erstwhile Imperial Bank, a private bank, was nationalised in 1955 and was christened SBI. The bank operates as the substitute for RBI where the central bank does not have a physical presence. SBI

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    COMMENTARY

    has the largest branch network and its government business operations are massive. Unlike SBI, the major private banks of the day were nationalised in two tranches in 1969 and 1980.

    As per the provisions of their respective statutes, the central government is mandated to hold a minimum percentage of shareholding which is 51% in the case of nationalised banks and 55% in the case of SBI. The shareholding of the SBI cannot go below the minimum of 51% of the total shareholding in the subsidiary banks. Foreign investment in any form cannot exceed 20% of the total paid-up capital of the PSBs. The PSBs are

    Table 1: Growth Rate (%) of Advances

    2006-07 2007-08 2008-09 2009-10 2010-11 CAGR

    SBI 30 23 25 16 1622

    NB 30 26 26 21 25 26

    PSB 30 25 26 20 2224

    Old pvt 12 20 15 20 20 17

    New pvt 40 26 10 7 28 22

    Private 33 25 11 10 26 21

    Source: A Profile of Banks (RBI).

    Table 2: Growth Rate (%) of Deposits

    2006-07 2007-08 2008-09 2009-10 2010-11 CAGR

    SBI 17 22 30 10 12 18%

    NB 26 23 2523 21 24

    PSB 23 23 27 19 18 22

    Old pvt 6 20 20 15 15 15

    New pvt 39 23 5 10 25 20

    Private 29 22 9 12 22 19

    Source: Same as Table 1.

    Table 3: Share (%) in Total Advances and Deposits of All Banks

    Advances Deposits 2005-06 2010-11 2005-06 2010-11

    SBI 2523 25 22

    NB 48 54 50 56

    PSB 73 77 75 78

    Old pvt 5 4 6 5

    New pvt 15 14 14 13

    Private 21 19 20 18

    Foreign 6 5 5 4

    Source: Same as Table 1.

    permitted to divest their holdings subject to the minimum holding by the central government.

    Private sector banks comprise two distinct categories; the professionally managed new private sector banks and the old private sector banks. The old private sector banks are typically smaller banks catering mainly to a specifi c geographic location.

    For a proper understanding of the relative performance of banks it is important to look at data disaggregated across the four bank categories – SBI, nationalised banks (NBs), old private sector banks (old pvt) and new private sector banks (new pvt). From a competitive perspective, it is more appropriate to compare the performance of PSBs with new private sector banks since they represent the future competition for PSBs.

    Business Profi le

    There has been a significant growth in bank advances and deposits during the period 2005-06 to 2010-11. Nationalised banks have the highest compound annual growth rate (CAGR) for both advances and deposits (Table 1). The CAGR for SBI and new private sector banks are similar. However, there is a sharp difference among the bank groups in their response to the fi nancial crisis. In the case of new private sector banks, the growth rate of advances drops in 2008-09 and further in 2009-10 before recovering to pre-crisis levels in 2010-11. However, in the case of PSBs, the drop in growth rate in advances happens later in 2009-10 with the growth rate of nationalised banks recovering in 2010-11 but not in the case of SBI.

    In the case of deposits, the most outstanding impact of the fi nancial crisis is a sharp increase in the growth rate for SBI and drop in the growth rate of new private sector banks during 2008-09, a manifestation of “flight to safety”. As pointed out by Acharya and Kulkarni (2011),5 this was not because state-owned banks were considered more resilient than their private sector counterparts, but because of explicit and implicit

    Table 4: Share of Rural Branches in Total Branches (%)

    Name of the Bank Branches
    Rural Semi- Urban Metro
    urban politan
    PSBs 33 26 22 20
    State Bank group 35 30 19 16
    Nationalised banks 32 24 23 21
    Private sector banks 11 33 29 27
    Old private sector banks 16 36 28 20
    New private sector banks 8 31 29 32

    Source: Appendix Table IV.9, Trend and Progress of Banking in India 2010-11.

    Table 5: Priority Sector Lending by Public and Private Sector Banks

    Public Sector (%) Private Sector (%) 2010 2011 2010 2011

    Priority sector advances 42 41 46 47

    Of which Agriculture 18 17 19 16

    MSMEs 13 15 14 16

    Per cent to Net Bank Credit/Adjusted Net Bank Credit (ANBC)/Credit Equivalent Amount of Off- Balance Sheet Exposures (CEOBSE), whichever is higher. Source: Table IV.22: Trend and Progress in Banking in India, RBI, 2011.

    government backing of PSBs. There is a sharp drop in growth rates for SBI in 2009-10 with no signifi cant recovery in 2010-11 (Table 2). In the case of new private sector banks, the growth rate has

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    may 19, 2012 vol xlvii no 20

    COMMENTARY

    recovered to pre-crisis levels by 2010-11. Interestingly, the nationalised banks seem to be virtually unaffected by the fi nancial crisis in terms of deposit growth rates.

    With the above pattern of growth, the share of PSBs in deposits and advances has increased over the period (Table 3, p 26). This is mainly because of the increase in share of nationalised banks at

    Table 6: Return on Assets (%)

    2005-06 2006-07 2007-08 2008-09 2009-10 2010-11

    SBI 0.87 0.86 0.97 1.02 0.91 0.79

    NB 0.89 0.94 1.01 1.03 1.00 1.03

    PSB 0.88 0.92 1.00 1.02 0.97 0.96

    Old pvt 0.64 0.78 1.14 1.15 0.95 1.12

    New pvt 1.22 1.09 1.13 1.12 1.38 1.51

    Private 1.07 1.02 1.13 1.13 1.28 1.43

    Return on assets for a group is obtained as weighted average of return on assets of individual banks in the group, weights being the proportion of total assets of the bank as percentage to total assets of the group. Source: Same as Table 1.

    Table 7: Other Income/Net Interest Margin (%)

    2005-06 2006-07 2007-08 2008-09 2009-10 2010-11

    SBI 45 45 52 59 58 45
    NB 34 34 50 51 49 31
    PSB 38 38 51 53 52 35
    Old pvt 30 35 47 47 49 36
    New pvt 72 87 83 68 69 57
    Private 59 74 76 64 65 52

    Source: Same as Table 1.

    the expense of SBI, and to some extent, private and foreign banks.

    One important feature of the business profi le of PSBs is the signifi cantly higher proportion of rural branches. At the end of 2010-11, while 35% of the SBI branches were in rural areas (Table 4, p 26), the corresponding figure for the new private sector banks was only 8%. This is consistent with the general belief that private sector banks target the more affl uent segments of the population. This will have implications for cost and profi tability.

    However, there does not seem to be much difference in the priority sector Return on Assets: The most comprehensive measure of performance is the return on assets (ROA). This is defi ned as net income or profit as a percentage of total assets. This is different from return on equity (ROE), which is defined as net income as a percentage of equity. ROE will, therefore, be higher than ROA with the difference depending upon the leverage (Table 6).

    The ROA of private sector banks have consistently been higher than that of PSBs. The difference in ROA appears to have increased in the post-fi nancial crisis period. For example, the difference in ROA increased from about 13 basis points in 2007-08 to almost 50 basis points in 2010-11. During this period there was a significant drop in ROA for SBI; nationalised banks managed to maintain their ROA; and new private sector banks managed to increase their ROA signifi cantly.

    Other Income: Other income is increasingly becoming an important source of income for banks (Table 7). Other income includes commission, exchange

    Table 8: Net Non-Performing Assets (%)

    2005-06 2006-07 2007-08 2008-09 2009-10 2010-11

    SBI 1.63 1.32 1.43 1.47 1.5 1.49

    NB 1.16 0.94 0.77 0.68 0.91 0.92

    PSB 1.32 1.06 0.99 0.94 1.1 1.09

    Old pvt 1.66 0.96 0.66 0.90 0.82 0.53

    New pvt 0.78 0.97 1.21 1.40 1.09 0.56

    Private 1.01 0.97 1.09 1.29 1.03 0.56

    Source: Same as Table 1.

    Table 9: Sector-wise NPAs as Percentage of Total NPAs for the Bank Group

    Priority Sector Non- Priority Agriculture SSI Others Total Sector

    Public sector 20 20 18 58 42

    Nationalised 22 24 14 60 40

    SBI 19 14 23 55 45

    Private 12 7 8 27 73

    Old 11 15 17 43 57

    New 12 5 5 23 77

    the new private sector banks. The difference shrunk during the fi nancial crisis but increased thereafter. As pointed out by the CFSA,6 “Generating innovative ways of increasing fee income by diversifying income sources remains an ongoing challenge for public and old private sector banks”.

    Other income is related to the treasury operations of banks. According to an IBA-McKinsey study, as quoted in the Raghuram Rajan Committee Report,7 treasury operations are a signifi cant contributor to bank earnings in India and important for managing capital market businesses and credit and market risk. It adds, while many foreign and new private sector banks are using sophisticated and world standard risk management techniques, public sector

    Table 10: Capital to Risk (Weighted) Assets Ratio

    (%)

    2005-06 2006-07 2007-08 2008-09 2009-10 2010-11

    SBI 12 12.3 13.2 14 13.5 12.3

    NB 12.3 12.4 12.1 13.2 13.2 13.5

    PSB 12.2 12.4 12.5 13.5 13.3 13.1

    Old pvt 11.7 12.1 14.1 14.8 14.9 14.6

    New pvt 12.6 12 14.4 15.3 18 16.9

    Private 12.4 12 14.3 15.2 17.4 16.5

    For the years 2008-09 to 2010-11, bank-wise CRAR is given as per Basel-II; For the year 2007-08, wherever CRAR as per Basel-II is not available CRAR as per Basel-I is given. For the year 2006-07, CRAR is given as per Basel-I. Source: Same as Table 1.

    banks have fallen behind often simply conforming to regulatory and compliance measures.

    Non-performing Assets: Table 8 shows the net non-performing assets (NPAs) as a percentage of net advances.

    The SBI stands out in terms of consistently higher NPA ratio. It appears to have managed to reduce its NPA just prior to the financial crisis, but there is a signifi cant increase following the fi nancial cri

    lending and its composition in terms of All 19 18 16 52 48 sis. The nationalised banks show a simi

    agriculture and micro, small and medium enterprises (MSMEs). In terms of revised guidelines on lending to priority sector, broad categories include small enterprise sector, retail trade, micro- credit, education and housing (Table 5, p 26).

    Performance Metrics

    While there are several performance evaluation metrics for banks, we focus on certain broad performance indicators.

    Source: Table IV.18: Trend and Progress in Banking in India, RBI, 2011.

    and brokerage; net profit (loss) on sale and revaluation of investment; net profi t (loss) on exchange transactions; and miscellaneous income. The contribution of other income can be assessed as a proportion of net interest margin (interest income less interest expended).

    Other income as a percentage of net interest margin is consistently higher for lar performance though at signifi cantly lower levels of NPA. The new private sector banks also experienced an increase in NPA, but have managed to reduce it from 1.4% in 2008-09 to 0.56% in 2010-11. Overall, the NPAs of the private sector banks are significantly lower than those of the PSBs in 2010-11.

    One important difference between the bank groups is the proportion of priority sector NPAs in total NPAs (Table 9).

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    COMMENTARY

    In March 2011, priority sector NPAs account for 58% of the public sector NPAs, but only 23% of the new private sector NPAs.

    Table 11: Price-Earnings Ratio

    SBI Nationalised New Private Old Private Banks End March 2011 2010 2011 2010 2011 2010 2011 2010

    Mean 16.4 11.2 7.1 6.2 22.4 24.2 12.6 12.6

    Median 16.4 11.2 6.5 5.8 21.3 21.0 9.5 8.9

    Source: Appendix Table IV.7, Trend and Progress in Banking in India, RBI, 2011.

    (Rs/lakhs)

    Table 12: Business and Profit Per Employee

    Business Per Employee Profit Per Employee
    2005-06 2010-11 2005-06 2010-11
    SBI 338 793 2.20 4.20
    NB 383 1,145 2.23 6.95
    PSB 367 1,014 2.22 5.93
    Old pvt 417 815 1.69 5.63
    New pvt 889 826 6.92 8.93
    Private 671 823 4.50 8.10

    Business per employee (or profit per employee) is computed by dividing the total business (or profit) for the group by the number of employees in the group. Business is defined as deposits plus advances. Source: Same as Table 1.

    Capital to Risk Weighted Assets (CRAR) Ratio: There were only marginal differences between the CRAR of the public sector and private sector banks till 2006-07 (Table 10, p 27). However, since 2007-08 the difference has widened in favour of private sector banks. By 2010-11, the private sector CRAR was about 3 percentage points higher than the new private sector banks.

    Capital raising by PSBs from fi nancial markets is constrained by the need for the government to maintain its minimum shareholding. As of end March 2011, there were 10 nationalised banks with government shareholding in the range of 57% to 58.5%; the government holding in SBI is 59.4%; and the government shareholding is in the range of 65-85% for the remaining nationalised banks. While the minimum government holding is not binding for any bank at present it could become binding for some banks in the future. For example, one of the reasons cited for the recent downgrade of SBI by Moody’s was the uncertainty about how quickly it could raise fresh capital.

    Price-Earnings Ratio: The price-earnings (PE) ratio (Table 11) provides an important market assessment of the relative valuation of banks. The PE ratios capture the effect of both growth and risk. A higher PE ratio indicates either a higher growth or lower risk or both.

    The PE ratio of the new private sector banks are almost three times that of nationalised banks and twice the PE ratio of SBI in 2010. The relatively higher PE ratio of SBI in 2011 is perhaps due to the abnormally low profi ts of SBI in 2010-11 because of higher provisioning.

    Human Resource Management

    The Report of the Committee on HR Issues of Public Sector Banks8 highlights serious deficiencies in human resource management in PSBs. According to the report:

    PSBs today are seriously handicapped visà-vis their competitors in the market place, on account of huge human capital defi cit. Their employee compensation package, skill sets, skewed age profile, restrictive deployment, performance management system are the major issues placing PSBs somewhat at a disadvantage.

    There has been a sharp increase in the two measures of employee productivity for PSBs (Table 12). By 2010-11, business per employee for nationalised banks exceeded that of new private banks. However, profit per employee of new private sector banks is almost twice that of SBI and higher than that of the nationalised banks.

    The high growth in business per employee of the PSBs was the result of high growth in business (as already documented) with almost no change in the number of employees (Table 13).

    Another important difference is the relatively higher proportion of “clerks” and “subordinates” in the PSBs (Table 14). As pointed out by the Committee on HR issues, in the post-core banking system environment, PSBs need to seriously deliberate on the future requirement of clerical staff. It goes on to recommend that each PSB should, “lay a road map for reaching officer-clerk ratio of 1:0.50 for metro and urban branches and 1:0.75 for rural and semi-urban branches in the next three years”.

    The committee also highlights weak

    nesses in the area of performance
    m anagement:
    may 19, 2012

    The appraisal system is routinely administered and generally not used for developmental interventions. Further, much of the appraisals and ratings have upward bias, with 8090% of the appraisees getting “excellent” rating. This does not lend to distinguishing performers from non-performers. This, in turn, has dampening effect on performers. Further, it has in many cases cascading effect leading to mediocrity.

    Another well-recognised problem pointed out by the committee is the “fear of vigilance”, a general concern among bank managements across cadres about

    Table 13: Total Number of Employees

    2005-06 2010-11

    SBI 2,70,608 282,453

    NB 473,725 475,082

    PSB 7,44,333 757,535

    Old pvt 51,138 55,075

    New pvt 59,367 163,604

    Private 1,10,505 218,679

    Source: Same as Table 1.

    Table 14: Composition of Employees, March 2010(%)

    SBI NB Private

    Officers 36 40 66

    Clerks 43 39 27

    Subordinates 21 21 7

    Source: Table 52: Handbook of Statistics on the Indian Economy.

    risk aversion. According to the committee this may be related to the absence of a staff accountability policy in most banks.

    Corporate Governance of PSBs

    The problem of corporate governance of public sector banks is highlighted in the following excerpt from a recent speech by the RBI governor9

    …an important question is whether effective and autonomous corporate governance is compatible with public ownership of banks. The question arises because publicly owned banks render accountability to the government and to the democratic institutions. The government judges them on criteria quite different from those used by the market. How can we resolve this dilemma? Is it possible to stay with public ownership but still give near total autonomy to the boards? Is it, in particular, possible to cede the power to appoint the CEO to the board, but make the board accountable to the government and the shareholders for the performance of the bank?

    Unfortunately, the governor does not provide any answers to these questions. Some answers are available in the 2009 Finan cial Sector Assessment Report

    vol xlvii no 20

    COMMENTARY
    Table 15: Summary of Performance Metrics for

    ROA Other Income NPA CRAR Median (%) (%) (%) (%) P-E ratio

    SBI 0.79 45 1.49 12.25 16.4

    NB 1.03 31 0.92 13.47 6.5

    PSB 0.96 35 1.09 13.08

    Old pvt 1.12 36 0.53 14.56 9.5

    New pvt 1.51 57 0.56 16.87 21.3

    Private 1.43 52 0.56 16.46

    As pointed out the SBI P-E ratio may be abnormally high because of abnormally low profits reported for the year ended 31 March 2011. Source: Same as Table 1.

    (page 564). The report points to the need to enhance corporate governance of banks by improving the bank management’s flexibility in decision-making, unhindered by the government interference. It notes that PSBs do have managerial autonomy on issues like technology upgrading and lateral recruitment of specialists. However, it feels that only if the government ceases to be the majority shareholder, the PSBs would be in a better position to attract talent in large numbers as they would not be constrained by government pay structure.

    This would further facilitate technology upgrading and lateral recruitment of specialists with appropriate skill sets in larger numbers. It recommends that,

    Once an enabling legal provision is available, selective relaxation could be granted to PSBs that have government shareholding at the borderline of 51% and the extent of dilution can be decided on a case-by-case basis. Once the process of dilution of government shareholding below 51% in select public sector banks is begun, such banks would be able to operate in ways similar to the new private sector banks. Such a process would be effective in introducing increased competition and, hence, increased efficiency in the Indian banking system.

    Similarly, the Raghuram Rajan Committee believes the way forward is to make institutions “ownership neutral”. For the public sector, this implies removing the overlay of costs and benefi ts imposed by government ownership. One alternative is bank privatisation, or reducing the government’s majority stake so that even if the government has de facto control, the bank is not “public sector”. The other is through serious governance reform. The committee believes that while this debate has become entangled in politics and ideology, pragmatic steps are possible in both directions so that experience can guide future moves. The committee makes the following specifi c proposals:

    Create stronger boards for large public sector banks, with more power to outside shareholders (including possibly a private sector strategic investor), devolving the power to appoint and compensate top executives to the board. After starting the process of strengthening boards, delink the banks from additional government oversight, including by the Central Vigilance Commission and Parliament, with the justifi cation that with governmentcontrolled boards governing the banks, a second layer of oversight is not needed. Further ways to justify reduced government oversight is to create bank holding companies where the government only has a direct stake in the holding company.

    Conclusions

    By 2005-06 the performance of public and private sector banks appeared quite similar with some edge for the new

    COUNCIL FOR SOCIAL DEVELOPMENT, NEW DELHI SANGHA RACHANA, 53 LODI ESTATE, NEW DELHI -110003 (INDIA) Training Workshop on Planning and Management of Resettlement The Council for Social Development is organizing its next one-week annual training programme on the above noted subject at New Delhi from 26 to 30 November 2012. The broad objectives are to familiarize the participants with the complex issues surrounding land acquisition, compensation and resettlement and to develop among them resettlement planning, implementation and monitoring skills. It has been planned keeping in view the training needs of senior/middle level government officials, industry managers, NGOs, academics and also those working on internationally-funded projects. The charges for this programme per participant are Rs.10000.00. For students and NGOs, the charges are only Rs.3000.00. The charges includes course material, lunch, mid-morning and afternoon tea/coffee. For international participants, the charges (inclusive of accommodation for six nights) are Rs.50000.00. The last date for receiving nominations is 31 October 2012. For further information contact: (Ms. Purtika Kalra) Programme Coordinator E-mail: purtika@csdindia.org Telephone No: 91-011-24615383, 24611700

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    COMMENTARY

    private sector banks. However, as the summary Table 15 (p 29) indicates, the difference appears to have widened during the subsequent period of high growth and the financial crisis. This is reflected in both accounting measures such as return on assets and market measures such as price-earnings ratios.

    One Explanation

    One possible explanation for the widening of the gap in performance measures may be that PSBs have exhausted the easy opportunities for productivity and efficiency gains, the so-called “lowhanging fruits”. One piece of evidence consistent with this explanation is that of adoption of new technologies, but also because of the existing slack in human resources.

    Any further gains would now be constrained by corporate governance and human resource problems that would require radical changes. It is important that these constraints be quickly removed so that PSBs are able to succeed in the face of heightened competition with entry of both domestic and foreign banks. The alternative of not undertaking these reforms and instead protecting the PSBs by postponing new entry would be unwise.

    Notes

    Mumbai on 3 December 2010.

    3 India’s Financial Sector Assessment, Volume II overview report, Committee on Financial Sector Assessment, March 2009, p 106.

    4 “Entry of New Banks in the Private Sector”, Consultation paper, RBI, August 2010.

    5 V V Acharya and N Kulkarni (2011): “What Saved the Indian Banking System: State O wnership or State Guarantees?”, The World Ec onomy.

    6 India’s Financial Sector: An Assessment, Volume III, Advisory Panel on Financial Stability Assessment and Stress Testing, Committee on Financial Sector Assessment, RBI, March 2009, p 86.

    7 “A Hundred Small Steps, Report of the Committee on Financial Sector Reforms” (Raghuram Rajan Committee), Government of India, Planning Commission, New Delhi, 2009.

    8 Committee on HR Issues of PSBs (Khandelwal Committee), June 2010, Ministry of Finance, Department of Financial Services (px).

    during this period PSBs maintained an 1 Report on Currency and Finance 2006-2008, 9 “Corporate Governance of Banks in India in RBI, para 11.37. Pursuit of Productivity Excellence”, Inaugural

    average annual growth rate in deposits 2 “Five Frontier Issues in Indian Banking”, inau-address of Governor, Reserve Bank of India at

    and advances of 20% without increasing

    gural address by Duvvuri Subbarao, governor, the FICCI-IBA Conference on “Global Banking: employment. This may be partlybecause Reserve Bank of India at BANCON 2010 in Paradigm Shift” on 23 August 2011 at Mumbai.

    may 19, 2012 vol xlvii no 20

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