47
Page 1 of 47 Appendix – I LOAN POLICY – FY 2018 PARA NO. CONTENTS PAGE NO. 1 OVERVIEW 3 1.1 PREFACE 3 1.2 FRAMEWORK OF THE LOAN POLICY 3 1.3 OBJECTIVES OF THE LOAN POLICY 4 1.4 OVERVIEW OF LOAN POLICY 4 1.5 VALIDITY/ AUTHORITY OF LOAN POLICY 4 2 CREDIT MANAGEMENT POLICY 5 2.1 THRUST/NICHE BUSINESS AREAS 5 2.2 MICRO, SMALL & MEDIUM ENTERPRISES 6 2.3 PRODUCT MANAGEMENT 6 2.4 PROCESS MANAGEMENT 7 3 EQUITY & RISK CAPITAL ASSISTANCE 9 3.1 INTRODUCTION 9 3.2 PRODUCT PROFILE 10 3.3 DUE DILIGENCE 11 3.4 ASSISTANCE THROUGH FOCUSED EQUITY AND VENTURE DEBT FUNDS (VCFs / PE FUNDS) 11 4 ASSISTANCE FOR SERVICE SECTOR 12 4.1 INTRODUCTION 12 4.2 THRUST BUSINESS AREAS 12 4.3 APPROACH TO FINANCING SERVICE SECTOR 12 5 ASSISTANCE TO SECTORS UNDER MAKE IN INDIA 13 6 ASSISTANCE FOR SUSTAINABLE DEVELOPMENT 14 6.1 INTRODUCTION 14 6.2 OBJECTIVES 14 6.3 SCHEMES OF ASSISTANCE FOR SUSTAINABLE DEVELOPMENT 14 7 ASSISTANCE FOR RECEIVABLE FINANCE 16 7.1 INTRODUCTION 16 7.2 THRUST BUSINESS AREAS 16

LOAN POLICY FY 2018 - :: Small Industries Development · PDF fileLOAN POLICY – FY 2018 ... procedural aspects of credit appraisal, processing, ... under guarantee schemes operated

Embed Size (px)

Citation preview

Page 1: LOAN POLICY FY 2018 - :: Small Industries Development · PDF fileLOAN POLICY – FY 2018 ... procedural aspects of credit appraisal, processing, ... under guarantee schemes operated

Page 1 of 47

Appendix – I

LOAN POLICY – FY 2018

PARA

NO.

CONTENTS PAGE

NO.

1 OVERVIEW 3

1.1 PREFACE 3

1.2 FRAMEWORK OF THE LOAN POLICY 3

1.3 OBJECTIVES OF THE LOAN POLICY 4

1.4 OVERVIEW OF LOAN POLICY 4

1.5 VALIDITY/ AUTHORITY OF LOAN POLICY 4

2 CREDIT MANAGEMENT POLICY 5

2.1 THRUST/NICHE BUSINESS AREAS 5

2.2 MICRO, SMALL & MEDIUM ENTERPRISES 6

2.3 PRODUCT MANAGEMENT 6

2.4 PROCESS MANAGEMENT 7

3 EQUITY & RISK CAPITAL ASSISTANCE 9

3.1 INTRODUCTION 9

3.2 PRODUCT PROFILE 10

3.3 DUE DILIGENCE 11

3.4 ASSISTANCE THROUGH FOCUSED EQUITY AND VENTURE DEBT FUNDS (VCFs /

PE FUNDS) 11

4 ASSISTANCE FOR SERVICE SECTOR 12

4.1 INTRODUCTION 12

4.2 THRUST BUSINESS AREAS 12

4.3 APPROACH TO FINANCING SERVICE SECTOR 12

5 ASSISTANCE TO SECTORS UNDER MAKE IN INDIA 13

6 ASSISTANCE FOR SUSTAINABLE DEVELOPMENT 14

6.1 INTRODUCTION 14

6.2 OBJECTIVES 14

6.3 SCHEMES OF ASSISTANCE FOR SUSTAINABLE DEVELOPMENT 14

7 ASSISTANCE FOR RECEIVABLE FINANCE 16

7.1 INTRODUCTION 16

7.2 THRUST BUSINESS AREAS 16

Page 2: LOAN POLICY FY 2018 - :: Small Industries Development · PDF fileLOAN POLICY – FY 2018 ... procedural aspects of credit appraisal, processing, ... under guarantee schemes operated

Page 2 of 47

7.3 PRODUCT RATIONALISATION 17

8 INDIRECT LENDING 17

8.1 INTRODUCTION 17

8.2 ASSISTANCE TO STATE FINANCIAL CORPORATIONS (SFCs) 18

8.3 MONITORING OF SFCs 18

8.4 ASSISTANCE TO SCHEDULED COMMERCIAL BANKS 18

8.5 ASSISTANCE TO SCHEDULED COOPERATIVE BANKS (SCBs) & REGIONAL

RURAL BANKS (RRBs) 18

8.6 ASSISTANCE TO SIDCs/SIICs 18

8.7 ASSISTANCE TO NBFCs 19

8.8 ASSISTANCE TO SMALL FINANCE BANKS 19

9 ASSISTANCE FOR INFRASTRUCTURE PROJECTS 19

10 WORKING CAPITAL ASSISTANCE 20

Page 3: LOAN POLICY FY 2018 - :: Small Industries Development · PDF fileLOAN POLICY – FY 2018 ... procedural aspects of credit appraisal, processing, ... under guarantee schemes operated

Page 3 of 47

PARA

NO.

CONTENTS PAGE

NO.

11 SIDBI FOUNDATION FOR MICRO CREDIT (SFMC) 20

11.1 INTRODUCTION 20

11.2 MICRO FINANCE SECTOR UPDATE 20

11.3 FOCUS 22

11.4 PRODUCT PROFILE 23

12 CREDIT RISK MANAGEMENT 24

12.1 CREDIT RISK STRATEGY 24

12.2 RISK MEASUREMENT 25

12.3 RISK MITIGATION 25

12.4 EXTERNAL RATINGS 26

12.5 PRICING 26

12.6 RISK CATEGORISATION OF CUSTOMERS FROM AML PERSPECTIVE 26

12.7 MANAGEMENT OF ASSET CONCENTRATION 26

13 CONCLUSION 27

ANNEXURE – I: BENCHMARKS FOR SANCTION 28

ANNEXURE - II: HIGHER INVESTMENT GRADE RATINGS – SELECT SECTORS 31

ANNEXURE – III: EXPOSURE CAPS 32

Page 4: LOAN POLICY FY 2018 - :: Small Industries Development · PDF fileLOAN POLICY – FY 2018 ... procedural aspects of credit appraisal, processing, ... under guarantee schemes operated

Page 4 of 47

LOAN POLICY – FY 2018

1. OVERVIEW

1.1 PREFACE

The significant role played by the Micro, Small and Medium Enterprises

[MSMEs] in the Indian Economy is well known. MSMEs make significant

contributions to India’s gross domestic product [GDP], manufacturing output,

exports and employment generation. The MSME sector is the second largest

contributor to country’s GDP. MSMEs also help address geographic disparities

through dispersal of entrepreneurial activities. They are considered to be the

nurseries for entrepreneurship, often driven by individual creativity and

innovation. MSMEs are important for the national objectives of growth with

equity and inclusion.

In order to address the challenges of the MSMEs to scale up their performance

and competitiveness, the Bank has adopted a multi-pronged approach to meet

their requirement of capital, term credit, working capital, receivable finance,

infrastructure (in the cluster), etc., through various instruments/products of

assistance.

1.2 FRAMEWORK OF THE LOAN POLICY

1.2.1 The Policy lays down broad approach, which the Bank adopts in respect of

different credit processes, credit risk management, control and monitoring

and is supplemented by specific circulars, manuals, guidelines issued from

time to time. The policy will be amended from time to time in the light of

changing business and economic environment and will be reviewed

annually. The focus of the Loan Policy 2018 is on quality asset growth

coupled with growth in net income in each segment of business while

maintaining the focus on customer needs.

Page 5: LOAN POLICY FY 2018 - :: Small Industries Development · PDF fileLOAN POLICY – FY 2018 ... procedural aspects of credit appraisal, processing, ... under guarantee schemes operated

Page 5 of 47

1.2.2 The Bank would also pursue the ways for generating non-interest / fee

based income. As regards indirect finance business, cautious dispensation of

credit with regard to state level institutions would continue.

1.2.3 The Loan Policy covers rupee as well as forex lending, risk capital and micro

finance operations of the Bank. Operations under Bank’s Treasury are

excluded from the purview of this policy.

1.2.4 The Bank would provide financial assistance to MSMEs for the eligible

activities, irrespective of the nature of constitution of the enterprise.

Accordingly, assistance could be extended by the Bank to an individual,

proprietorship, association of persons, partnership firm, limited liability

partnership, company, society or trust.

1.3 OBJECTIVES OF THE LOAN POLICY

The broad objectives of the Loan Policy of the Bank are outlined hereunder:

(i) To build and sustain a high quality portfolio well diversified in terms of

clients, markets and products with an acceptable risk adjusted yield.

(ii) To establish a comprehensive credit strategy to fulfill the corporate

mandate as per the SIDBI Act, 1989, amended from time to time, and

undertake all such activities, directly or indirectly, that supports the MSME

sector.

(iii) To pursue product innovation by the Bank based on market requirements.

(iv) To promote inclusive growth through micro finance and risk capital.

(v) To strengthen the risk management systems for appropriate pricing of

credit risks and ensure close monitoring of the credit portfolio.

(vi) To build strong alliances with intermediaries for tapping new business

areas.

1.4 OVERVIEW OF LOAN POLICY

Page 6: LOAN POLICY FY 2018 - :: Small Industries Development · PDF fileLOAN POLICY – FY 2018 ... procedural aspects of credit appraisal, processing, ... under guarantee schemes operated

Page 6 of 47

The strategy for lending takes into account the Bank’s approach for developing

a healthy credit portfolio, its management and risk mitigation. Accordingly, the

Loan Policy of the Bank broadly covers the following aspects:

Credit Management Policy

Business Policy of Verticals

Credit Risk Management

1.5 VALIDITY/ AUTHORITY OF LOAN POLICY

1.5.1 The Loan Policy is the principal document for the credit operations of the

Bank, duly approved by the Board of Directors and is expected to serve as the

guiding document for lending operations of the Bank.

1.5.2 This Loan Policy shall remain in force till the next revision is carried out and

disseminated, which will be on annual basis.

1.5.3 The Regional Offices (ROs)/ Central Loan Processing Cells (CLPCs)/ Branch

Offices (BOs) including XBOs are authorized to act upon this Policy on its

issuance by Head Office (HO). Clarifications / further guidelines, if needed,

would be issued by Risk Management Vertical (RiMV)/ concerned Business

Vertical.

1.5.4 The Loan Policy guidelines will be applicable to all the facilities extended to

various customers.

1.5.5 The Bank will abide by all the guidelines, directives and advices of Reserve

Bank of India as may be in force from time to time. The product verticals

would align their guidelines/ master circulars relating to the products,

procedural aspects of credit appraisal, processing, sanction, documentation,

etc. with the Loan Policy framework.

2. CREDIT MANAGEMENT POLICY

Page 7: LOAN POLICY FY 2018 - :: Small Industries Development · PDF fileLOAN POLICY – FY 2018 ... procedural aspects of credit appraisal, processing, ... under guarantee schemes operated

Page 7 of 47

The business development strategy would be supported by a prudent Credit

Management Policy. The market demand to improve products & processes

would be balanced with exercise of sufficient control on the credit delivery

processes so that exercise of prudence is not sacrificed.

2.1 THRUST/NICHE BUSINESS AREAS

The Bank has identified the following to be the thrust/niche business areas:

• Sectors under important missions of the central government such as “Make

in India”, “Zero Defect Zero Effect” and “Digital India” etc.

• Green finance to promote environmental sustainability through energy

efficiency, cleaner technologies and adoption of renewable energy etc.

• Equity and mezzanine products like Risk Capital (including structured debt),

Start-up schemes, Growth Capital, Fund-of-Funds, etc.

• Service sector

• Receivable finance

• Indirect lending viz. refinance to banks/ Financial Institutions (FIs),

assistance to microfinance institutions (MFIs) and non-banking finance

companies (NBFCs), resource support to public financial institutions (PFIs)

and public sector undertakings (PSUs) benefiting MSME sector, etc.

• MSME linked infrastructure finance

• Cluster level interventions

While the Bank will maintain its emphasis on financing niche areas, it shall

continue to provide assistance to all eligible MSMEs to meet their various

fund and non-fund requirements.

Page 8: LOAN POLICY FY 2018 - :: Small Industries Development · PDF fileLOAN POLICY – FY 2018 ... procedural aspects of credit appraisal, processing, ... under guarantee schemes operated

Page 8 of 47

2.2 MICRO, SMALL and MEDIUM ENTERPRISES

The definitions adopted for manufacturing and service sector activities under

Micro, Small and Medium Enterprises Development (MSMED) Act, 2006 are as

under:

For manufacturing enterprises, a list of equipments to be excluded for

ascertaining the eligible investment in plant and machinery is already notified

under MSMED Act.

The activities being financed/to be financed by the Bank, would include

enterprises eligible under the definition of MSMED Act, both manufacturing

and service enterprises and also, other service sector projects as approved by

the Bank with focused approach on the MSME linkages of the assisted

projects.

The Bank also extends assistance to MSME units which would graduate out of

the MSME category with the said assistance from the Bank, with appropriate

checks.

2.3 PRODUCT MANAGEMENT

Enterprise

Category

Manufacturing

(Original Investment in P&M)

Services

(Original Investment in

Equipment)

Micro Up to `25 lakh Up to `10 lakh

Small Upto `500 lakh Upto `200 lakh

Medium Upto `1000 lakh Upto `500 lakh

Page 9: LOAN POLICY FY 2018 - :: Small Industries Development · PDF fileLOAN POLICY – FY 2018 ... procedural aspects of credit appraisal, processing, ... under guarantee schemes operated

Page 9 of 47

2.3.1 Benchmarks for Sanction:

The benchmarks for sanction [BfS] as applicable to various products of the

Bank are given in Annexure I. Relaxation cap has also been prescribed against

BfS norms. However, in respect of renewals at current level or reduced level,

delegated authority may relax the BfS norms, beyond relaxation caps specified

for the respective Committees, provided suitable risk mitigants are put in

place.

Further, Central Credit and Investment Committee [CCIC] - CGM for proposals

up to the delegation of Regional Credit, Settlement and Investment Committee

[RCSIC], CCIC - DMD for proposals up to the delegation of CCIC-CGM and in

other cases, Executive Committee [EC], can consider relaxations beyond the cap

prescribed in the Policy on the merits of individual credit proposals. However,

it should be ensured that rationale for seeking such relaxations/deviations

together with risk mitigation measures are suitably brought out in the

appraisal memorandum. Further, additional risk premium, if any to be charged

for such relaxations beyond cap, would be decided by the delegated authority.

2.3.2 Facilitation for Product Development /Innovation

2.3.2.1 The Bank has put in place a suitable mechanism to understand the

business needs of the customer and address them swiftly. Accordingly, Product

Innovation and Review Committee (PIRC) at the HO level consider and approve

product innovations and their test marketing. A suitable exposure cap could

also be fixed for such test marketing proposals to be monitored by the

concerned product vertical.

2.3.2.2 Apart from approving products, PIRC also approves structuring of

specific arrangements in a cluster or around a large corporate/ OEM where

several MSMEs are expected to be benefited. Such arrangements could have

different dispensations than those followed for regular credit products.

Page 10: LOAN POLICY FY 2018 - :: Small Industries Development · PDF fileLOAN POLICY – FY 2018 ... procedural aspects of credit appraisal, processing, ... under guarantee schemes operated

Page 10 of 47

2.3.2.3 The areas generally expected to be amenable to product innovation are

service sector segments like organized retailing, IT & IT enabled services,

entertainment, cash flow/ rent discounting, cash flow management products

for MSME segment, cluster specific products, etc.

2.3.2.4 The new credit products proposed to be introduced or major changes

in existing products / credit processes would be duly signed off by Risk

Management Vertical.

2.3.3. Coverage under Guarantee schemes

The credit facilities to the eligible MSE customers may be generally covered

under guarantee schemes operated by Credit Guarantee Fund Trust for Micro

and Small Enterprises (CGTMSE), National Credit Guarantee Trustee Company

(NCGTC) etc., as applicable.

2.3.4. Cross-selling with Government Schemes

The products of the Bank would also be dovetailed with the schemes of

Government of India [GoI] and state governments, wherever feasible, to

improve the viability of the assisted projects and growth in overall asset base

of the Bank.

2.4 PROCESS MANAGEMENT

2.4.1 Delegation of Powers

The key tool for managing the internal processes of the Bank is the Delegation

of Powers (DoP) to various committees and the individual functionaries of the

Bank. It also puts in place suitable system of checks and balances in the credit

or investment related decision processes.

2.4.2 Appraisal process

Page 11: LOAN POLICY FY 2018 - :: Small Industries Development · PDF fileLOAN POLICY – FY 2018 ... procedural aspects of credit appraisal, processing, ... under guarantee schemes operated

Page 11 of 47

2.4.2.1 The credit proposals for term loan and working capital assistance to

MSMEs would be appraised in Credit Appraisal and Rating Tool (CART).

However, credit proposals falling under commercial real estate (CRE), secured

business loan (SBL), asset light1 and other cash flow based financing

categories. Infrastructure and any other new products may be appraised

outside CART in detailed appraisal note (DAN).

2.4.2.2 In view of relatively high delinquency levels in certain sectors, the Bank

would adopt a cautious/selective approach for financing under these sectors

with better risk mitigation. Currently these sectors are textiles, drugs &

pharmaceuticals, hotels, infrastructure, food & food products, hospitals and

iron & steel. The list may be modified during the year based on review of NPA

performance and other factors.

2.4.2.3 There exists significant opportunities for assistance to Commercial Real

Estate (CRE) projects, particularly keeping in view the significant MSME linkages

of such proposals. In view of risks inherent in such projects, risk mitigants at

project/ proposal specific level would be incorporated with due care while

structuring the assistance.

2.4.2.4 The Bank’s current guidelines on due diligence with regard to obtaining

satisfactory credit reports, undertaking visits, due diligence of suppliers

/contractors etc., checking of CIBIL/Credit Information Companies (CICs)

database for consumer/commercial credit information reports, KYC and AML

norms, checking of RBI defaulters list, and CRILC database, caution advices etc.,

guidelines on connected lending, multiple banking arrangements, NOC from

existing lenders, etc., wherever applicable, shall be followed.

1 Projects in the service sector which do not create substantial tangible fixed assets and invest in light

assets but generate comfortable cash flows.

Page 12: LOAN POLICY FY 2018 - :: Small Industries Development · PDF fileLOAN POLICY – FY 2018 ... procedural aspects of credit appraisal, processing, ... under guarantee schemes operated

Page 12 of 47

2.4.2.5 No additional facilities would be granted by the Bank to the wilful

defaulters as identified by it and those appearing in the list as

published/disseminated by RBI/CICs. In addition, such companies/ entities

(including their entrepreneurs / promoters) where the Bank has identified

siphoning / diversion of funds, misrepresentation, falsification of accounts and

fraudulent transactions would be debarred from the Bank’s exposure, for

floating new ventures for a period of 5 years from the date of removal of their

name from the list of wilful defaulters.

2.4.3 Fair Practices Code for lenders/ Code of commitment to Micro and Small

Enterprises [MSEs]:

Fair Practices Code for Lenders, as per RBI guidelines, has been adopted by the

Bank and hosted on Bank’s website. The Code sets out the guidelines for

processing of loan applications, appraisal, disbursement, post-disbursement

supervision, etc. A Grievance Redressal Mechanism has also been put in place

to resolve the disputes arising out of the Fair Practices Code. The Bank has

adopted the Code of commitment to Micro and Small Enterprises (MSEs) of

Banking Codes and Standards Board of India (BCSBI).

BUSINESS POLICY OF VERTICALS [3-11]

3. EQUITY & RISK CAPITAL ASSISTANCE

3.1 INTRODUCTION

3.1.1 MSMEs are largely dependent on the promoters’ resources, borrowings from

friends and relatives and secured loans from banks/financial institutions for

meeting their financial requirements. However, while promoters’ resources are

limited, bank finance is also restricted due to various norms such as asset

Page 13: LOAN POLICY FY 2018 - :: Small Industries Development · PDF fileLOAN POLICY – FY 2018 ... procedural aspects of credit appraisal, processing, ... under guarantee schemes operated

Page 13 of 47

coverage ratio, DER, etc., which adversely impact the flow of financial

assistance to MSMEs and in turn constrain their credit absorption capacity and

consequent growth.

3.1.2 Focus

SIDBI Foundation for Risk Capital for MSMEs was set up in FY 2008-09 with a

view to addressing the issues related to existing gaps in the funding of

MSMEs. Over the last 8 years, SIDBI has introduced risk capital products for

MSMEs with potential for high growth for various needs like meeting financing

gaps while implementing capex, expenditure on intangibles like R&D,

marketing, product development expenses, etc. and other bonafide financial

requirements for growth. The simple structure of mezzanine instruments has

resulted in acceptance of the product by MSMEs in various geographies across

the country. During the year, the Bank will continue its efforts for creating

awareness of quasi-equity schemes among MSMEs as well as the banking

sector. SIDBI would also carry out policy advocacy for wider acceptance of the

products by the institutional players in the country.

In view of the above, the focus of the Policy for FY 2018 is aimed at improving

the off-take taking into consideration the felt needs of the sector and building

up of quality portfolio.

3.1.3 Direct assistance

The Bank provides risk capital to MSMEs using appropriate quasi-equity

products based on best practices being followed in other parts of the world.

The Bank uses a mix of standardized products and structured products (where

assistance is customized for each customer on a case to case basis) for faster

dispensation of mezzanine debt instruments to eligible MSMEs.

3.2 Product profile

(i) Start-up Assistance Scheme (SAS)

Page 14: LOAN POLICY FY 2018 - :: Small Industries Development · PDF fileLOAN POLICY – FY 2018 ... procedural aspects of credit appraisal, processing, ... under guarantee schemes operated

Page 14 of 47

Under the Start-up Assistance Scheme, the Bank considers assistance to early

stage enterprises, preferably in technology and innovation space and where

revenues have commenced with product acceptability by customers. The

product could be structured flexibly to support the early stage operations of

these Start-ups.

Since the assistance is in the form of debt and its timely servicing assumes

significance, under the scheme, those enterprises which have received equity

funding from Venture Capital Funds (VCFs), Angel Network, investors, etc will

be given thrust. Such investors may add value to the start-up enterprises by

helping them to get customers, build teams; provide strategic/operational

guidance besides providing equity support that an early stage enterprise

needs. Considering that start-up enterprises stand high on the fatality scale, in

order to enhance its returns from successful enterprises, the Bank may

negotiate for higher equity kicker while extending assistance under the

scheme.

(ii) Growth Capital and Equity Assistance Scheme for MSMEs

(GEMS)

The objective of the Scheme is to provide growth capital to deserving MSMEs

for:

a Bridging the gap in the means of finance for expansion/ modernization/

scaling up. New businesses/ diversification by entrepreneurs with

established track record can be considered, selectively (along-with direct

finance assistance).

b Intangibles or non-asset creating investments viz. product development,

marketing related expenditure, R&D, etc., besides investments in quality

control/energy efficiency equipment etc.

Page 15: LOAN POLICY FY 2018 - :: Small Industries Development · PDF fileLOAN POLICY – FY 2018 ... procedural aspects of credit appraisal, processing, ... under guarantee schemes operated

Page 15 of 47

c Margin money for working capital. While normal working capital [WC]

requirements should generally be met under normal WC arrangement,

need based gap in WC requirements (where the borrower has

arrangements for major part of its WC requirements tied up) could be

considered, selectively, based on merits of the case and with justification.

However, the Bank would not consider funding of working capital as well

as margin for the same under the scheme.

d Any other bona-fide expenditure required for growth of the business

which may not qualify for assistance through normal banking channels.

The scheme provides for faster dispensation of risk capital through various

instruments viz. debt based instruments like Subordinated debt and convertible

instruments viz. Optionally Convertible Subordinated Debt (OCSD), Optionally

Convertible Debt (OCD), Optionally Convertible Debentures (OCDR) and

Optionally Convertible Cumulative Preference Shares (OCCPS) etc., to the

existing customers of the Bank and also to new customers with good past

track record.

3.3 Due diligence

In order to build a quality Risk Capital portfolio, the Bank would generally

carry out an independent due diligence of MSMEs by an external agency viz.

audit firm, law firm etc. to support the investment process under GEMS, for

exposure of `1 crore and above or such other threshold as may be decided

from time to time.

3.4 Assistance through focused equity and venture debt funds (VCFs / PE

Funds)

The Bank provides corpus support to MSME and Startup focused Alternative

Investment Funds (AIFs) managed by Investment Managers with relevant

Page 16: LOAN POLICY FY 2018 - :: Small Industries Development · PDF fileLOAN POLICY – FY 2018 ... procedural aspects of credit appraisal, processing, ... under guarantee schemes operated

Page 16 of 47

expertise in equity transactions, monitoring and hand holding of investee

companies. The Bank invests in such funds as per the policy framework

approved by the Board and within the overall guidelines stipulated by RBI from

time to time.

With an objective of making available equity capital to the MSMEs, the Bank

has launched the India Aspiration Fund (IAF), a Fund of Funds in August 2015,

that invests in AIFs predominantly investing in MSMEs.

As part of Startup India Action Plan announced by Hon’ble Prime Minister in

January 2016, the Bank is mandated by Department of Industrial Policy &

Promotion (DIPP), Ministry of Commerce & Industry, Government of India to

manage Fund of Funds for Startups (FFS) with a corpus of `10,000 crore.

Contribution out of FFS would be extended to AIFs which are predominantly

focusing on Startups as per the operational guidelines issued by DIPP from

time to time.

The Bank is also mandated by Ministry of Micro, Small & Medium Enterprises,

Government of India to manage ASPIRE Fund having corpus of `60 Crore.

Contribution under ASPIRE Fund would be extended to AIFs which have focus

on agro-based industries as per the operational guidelines issued by Ministry

of MSMEs from time to time.

To augment the sources of patient capital for the growth of MSMEs of the

country, the Bank has entered into Memorandum of Understanding (MOU)

with Life Insurance Corporation of India (LIC) for contributing to the Corpus of

AIFs which are supported by the Bank under IAF. Such arrangements will not

only facilitate early financial closure of Funds being raised by AIFs but also

bring more institutional investors in the eco system.

4. ASSISTANCE FOR SERVICE SECTOR

4.1 INTRODUCTION

Page 17: LOAN POLICY FY 2018 - :: Small Industries Development · PDF fileLOAN POLICY – FY 2018 ... procedural aspects of credit appraisal, processing, ... under guarantee schemes operated

Page 17 of 47

The Policy is aimed at identification of thrust areas for lending under service

sector, charting out a focused business development strategy, encouraging

product innovation suited to the needs of the industry, improving credit

delivery and having in place a pricing policy which supports business growth

and links it to risk.

4.2 THRUST BUSINESS AREAS

While the Bank would consider support to all eligible service sector activities,

the following areas would be accorded due emphasis for faster asset growth

during the year:

(i) Logistics & supply chain management

(ii) Organized retail outlets/ Retail Chains/dealerships

(iii) Restaurants/food chains/Quick Service Restaurants etc.

(iv) Healthcare/Diagnostic Chains/Specialty Clinics etc.

(v) Lifestyle, media & entertainment

(vi) Tourism related services

(vii) IT / IT enabled services

(viii) Franchisee chains of well known brands,

(ix) Warehouse

4.4 APPROACHES TO FINANCING SERVICE SECTOR

For the purpose of this policy, the assistance to service sector has been

broadly divided into three categories viz. (a) asset backed term loan assistance,

(b) term loan assistance to asset light service sector enterprises, (c) assistance

for facilitating payments to MSMEs in Construction Sector (i.e., for CRE

exposure).

(a) Asset backed assistance to service sector enterprises

Asset backed term loan assistance would include assistance towards

projects involving substantial primary and /or collateral security in the form

Page 18: LOAN POLICY FY 2018 - :: Small Industries Development · PDF fileLOAN POLICY – FY 2018 ... procedural aspects of credit appraisal, processing, ... under guarantee schemes operated

Page 18 of 47

of fixed assets like immovable properties and equipment, etc. Hotels,

hospitals, warehouses etc., would generally fall under this category.

(b) Term loan assistance to asset light service sector enterprises

Some of the projects in the service sector do not create tangible fixed

assets and invest in light assets and, therefore, may not meet security

related norms of asset backed assistance, but these are found to generate

comfortable cash flows. These segments include IT and other knowledge

based industries, organized retail chains, restaurant chains, diagnostic/

specialty clinics, IT/ BPO services etc. As there is good potential for

considering assistance to these sectors, proposals of deserving customers

could be considered for Bank’s financial support based on merits.

(c) Assistance to CRE/construction entities for facilitating payments to

MSME suppliers/ vendors.

The Bank shall selectively consider assistance to construction sector/ CRE

projects with linkage/support services to MSMEs. The assistance provided

shall be under the purview of CRE guidelines issued by RBI from time to

time.

5. ASSISTANCE TO SECTORS UNDER MAKE-IN INDIA

The Central Government launched an ambitious ‘Make in India’ campaign in

FY 2016 to make India a manufacturing hub and has identified 25 sectors

under the ‘Make in India’ initiative. In order to facilitate MSMEs take part in

the Government’s ‘Make in India’ initiative, the Bank has launched a

Scheme “SIDBI Make in India Loan for Micro, Small & Medium

Enterprises (SMILE)” with a fund corpus of ` 10,000 crore to be met out of

the Budget allocation. The objective of SMILE is to provide soft loan in the

Page 19: LOAN POLICY FY 2018 - :: Small Industries Development · PDF fileLOAN POLICY – FY 2018 ... procedural aspects of credit appraisal, processing, ... under guarantee schemes operated

Page 19 of 47

nature of quasi-equity and term loan on relatively soft terms to eligible new

and existing MSMEs in India. Within the corpus of `10,000 crore, a suitable

sub-limit would be fixed on assistance by way of soft loan. The Bank will

focus on making the scheme customer friendly and endeavour maximizing

utilisation of the fund. The Bank is also operating "Make in India fund" of `

1000 cr. out of its own resources to provide concession in the interest rate

working capital scheme to encourage MSMEs take part in the above

initiative of the Government.

6. ASSISTANCE FOR SUSTAINABLE DEVELOPMENT

6.1 INTRODUCTION

The Bank has recognized sustainable developmental of the MSME sector as

one of the high potential areas for strengthening the competitiveness of

MSMEs in India. The Bank has been operating Lines of Credit from various

multilateral/ bilateral agencies viz. Kreditanstalt fur Wiederaufbau (KfW),

Germany, Japan International Cooperation Agency (JICA), Japan, Agence

Francaise de Developpement (AfD), France, for financing energy efficient and

cleaner environment investments in MSMEs.

6.2 OBJECTIVES

(i) To promote the use of energy efficient and cleaner technologies by

MSMEs.

(ii) To reduce energy consumption, enhance energy efficiency, reduce CO2

emissions and improve the profitability of the Indian MSMEs in the long

run.

(iii) To support promotion of renewable energy, energy efficiency and

sustainable development in MSME sector under existing products / by

Page 20: LOAN POLICY FY 2018 - :: Small Industries Development · PDF fileLOAN POLICY – FY 2018 ... procedural aspects of credit appraisal, processing, ... under guarantee schemes operated

Page 20 of 47

introducing new products with an element of some concessionality in

interest rates.

(iv) To encourage innovation in technology, products and delivery, particularly

aimed at supporting the supply side.

(v) To support MSMEs towards development, up-scaling, demonstration and

commercialization of innovative technology based project.

(vi) To strengthen MSMEs active on the supply side of clean technologies and

which are engaged in development and adaptation, demonstration,

deployment and commercialization of innovative clean technologies,

products, processes and services including those MSMEs which provide

services like energy service companies (ESCOs) / renewable energy service

companies (RESCOs).

6.3 SCHEMES OF ASSISTANCE FOR SUSTAINABLE DEVELOPMENT

6.3.1 International / Multilateral Lines of Credit for Sustainable Finance:

Recognizing the importance of Energy Efficiency (EE) & Cleaner Production

(CP) in tackling the challenge of climate change and curtailing the demand for

energy from fossil fuels, SIDBI has been operating Lines of Credit from various

multilateral/ bilateral agencies. These EE/CP investments will result in energy

savings and reduction in global Green House Gas (GHG) emissions. Besides, it

also strengthens the competitiveness of MSMEs in India and in global markets.

6.3.2 The 4E (End-to-End Energy Efficiency) -

Solutions and Financing schemes:

The End to End Energy Efficiency Solutions (4E Solutions) launched by SIDBI

provides technical support to its MSMEs to improve their energy savings by

availing the services of Technical Consultant / ESCOs at a reasonable cost with

Page 21: LOAN POLICY FY 2018 - :: Small Industries Development · PDF fileLOAN POLICY – FY 2018 ... procedural aspects of credit appraisal, processing, ... under guarantee schemes operated

Page 21 of 47

assurance on the quality of services. This 4E Solution will be implemented by

SIDBI branches in association with India SME Technology Services Limited

(ISTSL), an associate institution of SIDBI utilizing the services of specialized

energy professionals. To facilitate implementation of energy efficiency

measures by the MSMEs after their detailed energy audit under the 4E

Solutions Scheme, a revolving fund has been created with the support of

World Bank (WB)-Global Environment Facility (GEF) to provide loans to MSMEs

at concessional interest rates and soft terms (4E Financing Scheme).

6.3.3 Partial Risk Sharing Facility (PRSF) for Energy Efficiency Project:

The Bank is the Project Executing Agency (PEA) for the World Bank Project, viz.

“Partial Risk Sharing Facility for Energy Efficiency (PRSF)”. The objective of the

project is to support the GoI efforts to transform the energy efficiency (EE)

market in India by promoting increased level of EE investments, particularly

through energy service performance contracting (ESPC) delivered through

ESCOs.

Under the project, SIDBI (PEA) provides partial risk coverage to the extent of

75% of the loans given by Banks / FIs / NBFCs (including SIDBI loans) to ESCOs

and ESCO-implemented projects. Minimum loan size eligible for coverage

under PRSF is `10 lakh and the maximum loan eligible for coverage is `15 crore

per project.

6.3.4 Assistance for Technology Innovation Projects

Need for developing national capabilities to innovate and create business

opportunities in emerging technology areas has been acutely felt as there

continues to be a dearth of early stage funding for commercialization of

innovations by MSMEs due to higher risks of investment in unproven

technologies. Thus, major proportion of the available funding gets invested in

Page 22: LOAN POLICY FY 2018 - :: Small Industries Development · PDF fileLOAN POLICY – FY 2018 ... procedural aspects of credit appraisal, processing, ... under guarantee schemes operated

Page 22 of 47

relatively lower risk/proven technologies, thereby limiting innovations to reach

the market. In order to address these constraints, the Bank has joined hands

with Technology Information Forecasting and Assessment Council (TIFAC),

Dept. of Science & Technology, Govt. of India for implementing Technology

Innovation Programme (SRIJAN Scheme) and with Kreditanstalt fur

Wiederaufbau (KfW), Germany for implementing KfW Innovation Finance

Programme. Financial products on soft terms and mechanism has been

developed and being implemented.

7. ASSISTANCE FOR RECEIVABLE FINANCE

7.1 INTRODUCTION:

MSME Receivable Finance Scheme (MSME-RFS) is being operated by the

Bank for more than two decades to mitigate the receivables problem of

MSME sellers and improving their cash flow / liquidity.

RFS covers discounting/purchasing of bills/invoices arising out of sale of

indigenous components/ parts/ sub-assemblies/ accessories/ intermediates

manufactured/ job work done/ services provided by MSMEs and eligible

service providers to Large Purchaser Corporates. The scheme also allows

coverage of bills relating to Small Road Transport Operators (SRTOs), being

service providers.

The Bank has been making need based modifications/ simplifications/

rationalization in the scheme considering inter-alia the changing business

environment, demand of the customers, feedback from the operating

offices and for increasing the reach of the Scheme for the benefit of a large

number of MSMEs.

End-use of funds is verified by undertaking visits to select MSME

beneficiary units and random verification of the purchased/discounted

Page 23: LOAN POLICY FY 2018 - :: Small Industries Development · PDF fileLOAN POLICY – FY 2018 ... procedural aspects of credit appraisal, processing, ... under guarantee schemes operated

Page 23 of 47

invoices / bills to ensure utilization of funds as per objectives of the

Scheme.

In order to improve the quality of overall portfolio and to address

inadequacies of existing internal rating system, external rating has been made

mandatory under MSME RFS, where the limits are not backed by collateral

security. Further, residual charge / second charge, would be explored in respect

of such limits not backed by collateral security for customers with external

rating lower than ‘AA’. Wherever possible, personal guarantees of directors

would also be obtained for such facilities. More thrust is given for creating a

portfolio of secured/partially secured limits and limits not backed by collateral

security with external rating of ‘AA’ and above. For existing customers, the

thrust would be on retaining customers with a good track record.

7.2 THRUST BUSINESS AREAS:

i) The scheme basically covers bills raised by MSME units engaged in

manufacturing / job works / service sector. Keeping in view the increasing

share of service sector, business opportunities in these sectors will be

identified. However, In view of the perceived higher risks in financing the

service sector under the scheme, the Bank would adopt a cautious

approach, with improved focus on customer selection and account

monitoring.

ii) Keeping in view the focus on serving MSMEs and improving the quality of

the portfolio, greater thrust is accorded to extend seller-wise receivable

finance [SRFS] limits directly to MSMEs to improve under the cash flow &

liquidity position of MSMEs / Service providers by providing them with

financial assistance against the goods sold and / or services rendered to

purchaser companies with satisfactory market standing. The focus would

also be on extending assistance through purchaser-wise limits or purchaser

Page 24: LOAN POLICY FY 2018 - :: Small Industries Development · PDF fileLOAN POLICY – FY 2018 ... procedural aspects of credit appraisal, processing, ... under guarantee schemes operated

Page 24 of 47

wise exposure with seller wise limits/ arrangements to top rated corporates

thereby increasing MSME outreach.

iii) In line with the national agenda for moving to electronic mode across all

financial products, the bank would focus on bringing more business under

direct E-discounting module developed in-house by the Bank.

iv) To help existing customers, the entire credit purchases both from MSMEs

and non-MSMEs, can be covered under Trade Finance Scheme/ Raw

Material Assistance Scheme, after ensuring that there is no double

financing. The scheme is also being extended to new customers with certain

additional criteria.

7.3 PRODUCT RATIONALISATION:

Over a period of time, MSME RFS has been improvised to meet the growing

business requirements like MSME RFS without Bills of Exchange, MSME RFS

backed by L/C, Seller wise Receivable Finance Scheme [SRFS], Modified Invoice

Discounting Scheme, E-discounting and Trade Finance Scheme/Raw Material

Assistance Scheme. The process of rationalization would continue during the

year as per requirement.

8. INDIRECT LENDING

8.1 INTRODUCTION

The indirect lending portfolio of the Bank consists predominantly of refinance

to Primary Lending Institutions (PLIs), comprising State Financial Corporations

(SFCs), State Industrial Development/ Investment Corporations (SIDCs / SIICs)

[collectively referred to as State Level Financial Institutions (SLFIs)], Scheduled

Commercial Banks, Scheduled Cooperative Banks, Regional Rural Banks, Small

Finance Banks and select financial institutions. In addition, the portfolio also

Page 25: LOAN POLICY FY 2018 - :: Small Industries Development · PDF fileLOAN POLICY – FY 2018 ... procedural aspects of credit appraisal, processing, ... under guarantee schemes operated

Page 25 of 47

includes resource support/ term loan to Public Sector Undertakings benefiting

the MSMEs.

8.2 ASSISTANCE TO STATE FINANCIAL CORPORATIONS [SFCs]

Broadly, the support to SFCs would continue to be based on the overall

exposure norms, financial health, compliance of performance parameters as

approved by the Board.

8.3 MONITORING OF SFCs

Given the sizeable exposure of the Bank to the SFCs, the performance of all

the SFCs would continue to be closely monitored both by way of on-site and

off-site mechanisms. Further, with a view to bringing about convergence in

the regulatory framework, vis-a-vis the industry practices, the Bank has been

advising the SFCs to comply with prudential norms prescribed by RBI. SFCs

shall also comply with other regulatory directives such as adoption of accrual

system of accounting, income recognition and asset classification [IRAC] norms,

KYC / AML norms, industry wise exposure norms, valuation of assets, etc.

8.4 ASSISTANCE TO SCHEDULED COMMERCIAL BANKS

The strategy adopted in FY 2017 to create long term assets under the scheme

would continue to be the thrust area for FY 2018 also. Banks would be

encouraged to avail longer term refinance. Exposure to the scheduled

commercial banks by way of refinance during FY 2018 would be encouraged

but within the individual counterparty exposure limits fixed by the Bank. The

individual bank wise caps are fixed on the basis of category of the bank, its

net worth and risk rating.

8.5 ASSISTANCE TO SCHEDULED COOPERATIVE BANKS [SCBs] & REGIONAL

RURAL BANKS [RRBs]

Page 26: LOAN POLICY FY 2018 - :: Small Industries Development · PDF fileLOAN POLICY – FY 2018 ... procedural aspects of credit appraisal, processing, ... under guarantee schemes operated

Page 26 of 47

Over the years, Scheduled Co-operative Banks (SCBs) have registered

significant growth in the number, size and volume of business handled. Some

of the RRBs are also now profit driven and, in addition to commercial lending

such as agriculture and MSME's, these banks also compete with scheduled

commercial banks for fee and commission, incomes from remittances, sale of

insurance products and mutual fund schemes. Counterparty exposure limits

to these banks shall be decided on a case to case basis, depending on risk

rating and other factors such as net worth of the bank, eligible MSE portfolio,

overall financial health, compliance with regulatory directives, etc.

8.6 ASSISTANCE TO SIDCs/SIICs

The Bank would continue to make a conscious attempt, as hitherto, to reduce /

exit from the existing exposures to weaker SIDCs / SIICs (including TFIDCs).

8.7 ASSISTANCE TO SFBs:

Refinance from SIDBI, which is exempt from CRR / SLR requirements, is

expected to be one of the major forms of support to SFBs in their initial years,

particularly until they are able to build up a resource base from public

deposits. As per the Scheme for Refinance to SFBs approved by the Board,

counter party exposure to each individual SFB shall be capped based on its

internal rating. As regards pricing, it is expected that interest rate shall be fixed

broadly at a level which is between the prevailing rates offered for refinance to

Private Sector Banks and that applicable for term loan assistance to

NBFCs/NBFC-MFIs. The rates are proposed to be finalized on a case to case

basis based on relevant factors / prevailing market conditions at the time of

sanction.

Page 27: LOAN POLICY FY 2018 - :: Small Industries Development · PDF fileLOAN POLICY – FY 2018 ... procedural aspects of credit appraisal, processing, ... under guarantee schemes operated

Page 27 of 47

In addition to the above Scheme for Refinance to SFBs, subject to their

meeting prescribed eligibility criteria, SFBs would also be considered for

refinance under MSME Refinance Fund [as already permitted by RBI] / SIDBI’s

Refinance Scheme for Micro & Small Enterprises on terms and conditions as

applicable for such refinance.

8.8 ASSISTANCE TO NBFCs

8.8.1 The NBFCs (both in the category of Deposit taking and Non Deposit taking)

registered with RBI which are engaged in financing MSMEs and in business for

the last 5 years, are, prima facie, eligible for resource support from the Bank

subject to meeting the prescribed BfS norms relating to net owned funds,

capital adequacy ratio, gross NPA, recovery percentage, minimum investment

grade external rating and compliance with all the prudential guidelines

prescribed by RBI from time to time.

The Bank provides term loan / resource support to Asset Finance Companies.

The assistance is also extended to Loan Companies, if the loan is given for

income generating activities. The assistance could also be extended to

Infrastructure Finance Company (IFC) with the other lenders in financing the

infrastructure projects provided such projects benefit the MSMEs.

8.8.2 The assistance to NBFCs would be secured by, first exclusive charge on the

assets financed / first pari-passu charge with other lenders by way of

hypothecation of book debts of the NBFC with suitable margin, collateral

security etc.

8.8.3 Direct Assignment: Purchase of pool of MSME asset from NBFC will be

considered on a case to case basis in accordance with Bank’s internal norms

and the extant RBI guidelines in this regard.

Page 28: LOAN POLICY FY 2018 - :: Small Industries Development · PDF fileLOAN POLICY – FY 2018 ... procedural aspects of credit appraisal, processing, ... under guarantee schemes operated

Page 28 of 47

9. ASSISTANCE FOR INFRASTRUCTURE PROJECTS

Availability of adequate and quality infrastructure facilities is a key component

for speedy growth of the MSME sector. It has positive impact in terms of

creation of employment, efficiency in operations and waterfall effect on the

entire economy. The Bank has been providing assistance for infrastructure

projects in the areas of industrial parks, transportation, etc. after satisfying the

MSME linkages of the assisted projects.

The infrastructure sector provides adequate scope for up-scaling of lending by

the Bank. While assistance for infrastructure projects in other areas would be

extended through consortium/ multiple banking arrangements, assistance to

industrial infrastructure projects could be considered on a standalone basis.

Within infrastructure sector, the projects from tourism, warehousing

infrastructure, cold chain sub-sectors, etc., having linkage with MSMEs, could

be explored. Further, projects of common waste management facilities and

effluent treatment plants at industrial clusters, renewable energy projects, may

be considered for coverage under the scheme after satisfying itself on MSME

linkages and benefits.

10. WORKING CAPITAL ASSISTANCE

Working Capital Assistance would be considered selectively to:

(i) existing customers who are solely banking with the Bank ;

(ii) existing customers of the Bank (who are also banking with other banks)

and have placed major share of immovable security with the Bank;

(iii) existing well performing entities who are new to the Bank and do not

enjoy working capital facility with any other bank;

(iv) New entities where term loan is considered by the Bank.

Page 29: LOAN POLICY FY 2018 - :: Small Industries Development · PDF fileLOAN POLICY – FY 2018 ... procedural aspects of credit appraisal, processing, ... under guarantee schemes operated

Page 29 of 47

Takeover of working capital accounts, as a part of term loan take over, may be

considered subject to compliance of take over guidelines.

11. SIDBI FOUNDATION FOR MICRO CREDIT [SFMC]

11.1 INTRODUCTION

The Micro Finance sector is on a growth path after its revival post AP crisis

with regulator viz., RBI and the newly created Self Regulatory Organizations

(SROs), viz., MFIN / Sa-Dhan, ensuring a strong and clear regulatory framework

for MFIs to operate efficiently. The guidelines also entailed the MFI lenders to

assess the MFIs’ performance in terms of sustainability as well as regulatory

compliance. Flow of funds from banks to MFIs has risen substantially enabling

the sector to register impressive growth. SIDBI, being a pioneer financial

institution in the micro finance space, continued to provide financial assistance,

in the form of equity, quasi-equity and term loans, etc., while advocating and

implementing various responsible finance practices, viz., Code of Conduct

Assessment (COCA), etc.

11.2 MICRO FINANCE SECTOR UPDATE

The microfinance industry in India has been a strong enabler in including the

financially underserved and unserved in the formal financial ecosystem. The

positive role played by this sector is evident from the awarding of universal

banking and small finance bank licenses to the top MFIs in India. The RBI

constituted Mohanty Committee in its report (December 2015) on “Medium

Page 30: LOAN POLICY FY 2018 - :: Small Industries Development · PDF fileLOAN POLICY – FY 2018 ... procedural aspects of credit appraisal, processing, ... under guarantee schemes operated

Page 30 of 47

term Path on Financial Inclusion”, inter-alia states that “Microfinance

institutions (MFIs) fill the niche that is mostly under-served by main stream

financial institutions and to that extent play a critical role in furthering financial

inclusion. The Committee recommends that bank credit to MFI’s should be

encouraged. MFIs have consistently added value to customers’ livelihood

through partnerships with various stakeholders like investors, banks, other

financial institutions, credit bureaus and other emerging agencies. However,

the growth has also been accompanied by challenges such as increase in risks

due to geographical concentration, increase in cash carrying costs, rise in cases

of fraud and high churn in human capital employed by these institutions.

To maintain growth and reduce costs while overcoming the challenges, MFIs

will have to develop a holistic strategy based on several external and internal

factors. Externally, MFIs need to address customer requirements, navigate

lenders and investors, build effective partnerships with financial and

nonfinancial institutes for sales, and cross-sell and adhere to guidelines issued

by regulators and self-regulatory organisations. On the internal front,

operations, technology, risk management and human capital together play an

integral role in all activities undertaken by MFIs. Institutions need to innovate

their operations and develop products to add value to their customers’

economic and social conditions while concentrating on under penetrated

markets in India. Technology needs to be leveraged not just to reduce costs

but also to increase geographical reach and, thus, the top line. MFIs also need

to adopt HRM best practices, thereby providing tools to help individuals

remain highly motivated and contribute to their success.

The MFI sector, in a short time of just over 15 years has effectively contributed

towards providing financial services to the unbanked population of the country

through its deep penetration in the difficult geographical parts with

Page 31: LOAN POLICY FY 2018 - :: Small Industries Development · PDF fileLOAN POLICY – FY 2018 ... procedural aspects of credit appraisal, processing, ... under guarantee schemes operated

Page 31 of 47

approximately 150 big and small microfinance institutions. The gross

outstanding loan portfolio of NBFC-MFIs which represents major portion of the

MFI outstanding stood at `54,129 crore as on December 31, 2016, with a client

base of over 3.38 crore across 30 states/union territories of the country with

equitable distribution across all regions having an outreach of 33% in the

south, 27% in North, 24% in West and 16% in the East (as per the MFIN

Micrometer for quarter ended December 2016).

There has also been an increase in new entrants with various banks especially

private sector banks, directly lending to the microfinance segment as well as

lending through Business Correspondents. Further, inspired by the profitability

of the MF market and putting in practice the belief that the poor are an

interesting market, the presence of banks as providers of microfinance is

scaling up. They are integrating microfinance into their mainstream commercial

retail lending, which is evident from the acquisition of certain NBFC-MFIs by

large scheduled commercial banks in India.

The move of giving licenses to small finance banks has been the major step

towards pushing financial inclusion in the country. This put the spotlight on the

microfinance sector as 8 out of the 10 newly licensed small finance banks are

MFIs. The entry of MFIs in SFB segment who are familiar with the nuances of

banking with poor borrowers, by getting access to banking these entities can

tap public deposits which will significantly lower their cost of borrowing and

enable them to bring down rate of interest on loans.

The Reserve Bank of India (RBI) and the Government of India (GoI) have

announced a number of regulations and developments supporting financial

inclusion and thereby created conducive policy and regulatory environment.

The demonetization in November 2016 has impacted the industry severely,

Page 32: LOAN POLICY FY 2018 - :: Small Industries Development · PDF fileLOAN POLICY – FY 2018 ... procedural aspects of credit appraisal, processing, ... under guarantee schemes operated

Page 32 of 47

however, the situation seems to be improving and stabilizing. Overall, the

impact of demonetization on the sector is expected to be positive with MFIs

emerging stronger, adopting better risk management practices and bringing

greater focus on cashless operations through digital channels.

With the sector regaining confidence and momentum, the Bank has also

adopted a ‘growth strategy’ approach for the Micro Credit business. It is

proposed to continue the same strategy during FY 2018.

11.3 FOCUS

On asset quality, focus would continue to be on risk management through the

assessment, monitoring and exposure management. Recently, Bank introduced

internal rating module for MFI to bring more objectivity in assessing the risk in

the loan proposals. Bank focuses on MFIs and NBFCs with good track record

of resource mobilization, capital infusion, strong systems, compliances with

regulatory guidelines, adherence to responsible lending practices and long

term sustainability in terms of financial and operational efficiencies. Bank’s Fair

Practices Code, Grievance Redressal Mechanism and RBI’s guidelines to all

India FIs on connected lending are applicable for assistance under SFMC.

From SIDBI’s perspective, the differentiated banking architecture in the form of

SFBs offers opportunities for a greater role for SIDBI as an apex institution for

promotion, financing and development of MSMEs. 9 out of the 10 entities

selected by RBI for SFB Licence at in-principle stage were SIDBI partners. SIDBI

therefore would continue to actively engage with the prospective SFBs as a

natural extension of the existing relationships when they were NBFC / NBFC-

MFIs.

11.4 PRODUCT PROFILE

Page 33: LOAN POLICY FY 2018 - :: Small Industries Development · PDF fileLOAN POLICY – FY 2018 ... procedural aspects of credit appraisal, processing, ... under guarantee schemes operated

Page 33 of 47

(a) Support to MFIs and NBFC- MFIs:

SFMC shall continue with term loan, subordinate debt, long tenor loans, to

MFIs for on-lending to micro enterprises and to service providers. Bank’s equity

and related investments in MFIs will be guided by statutory guidelines. In order

to support well performing MFI customers, the Bank had introduced modified

Privileged Customer Scheme for MFIs to provide loan funds on the basis of

simplified application/appraisal process.

The Missing Middle Financing activities of the Bank through PFIs are being

funded by KfW as well as out of the Bank’s funds. Under the product segment,

assistance will continue to be extended to PFIs to enable them to extend loans

in the Missing Middle segment.

(b) India Microfinance Equity Fund (IMEF)

To provide equity and quasi equity support to smaller MFIs to help them

maintain growth and achieve scale and efficiency in their operations, India

Microfinance Equity Fund (IMEF) was launched with funds from GoI. Initially,

the corpus was of `100 crore (subsequently enhanced to `300 crore). Under the

Scheme, assistance in the form of sub-debt, Equity and quasi-equity is

provided to Smaller Socially Oriented Micro Finance Institutions, operating

mostly in underserved / unserved areas of the Country. In order to increase the

outreach / impact, modifications in the scheme guidelines, viz., increase in the

quantum of assistance, norms for eligible borrower, greater flexibility in equity

investment pricing, etc., have been sought from Government of India. The

focus on increasing the overall investments under the scheme to benefit large

number of smaller MFIs would continue.

(c) Support to Small Finance Banks during FY 2017

Page 34: LOAN POLICY FY 2018 - :: Small Industries Development · PDF fileLOAN POLICY – FY 2018 ... procedural aspects of credit appraisal, processing, ... under guarantee schemes operated

Page 34 of 47

To support the SFBs during their transformation phase the Bank introduced

facilities to augment resource base through term loan and also provide

assistance by way of domestic equity as under:

Resource Support by way of term loan to NBFC-MFIs / NBFC

transforming into SFBs with a provision to convert the assistance into

Refinance on conversion into SFB; and

Equity Investment for setting up / capitalization of the SFB to help

transforming entities meet initial equity / capital gap, in particular, equity from

domestic sources.

12. CREDIT RISK MANAGEMENT

RBI had issued guidelines that the banks should have a robust Credit Risk

Management (CRM) system which is sensitive and responsive to the credit risks

emanating from its dealings with individuals, corporates, banks, FIs or

sovereign. According to the RBI guidelines, banks have to devise a risk

management framework oriented towards their requirements, dictated by size,

complexity of business, risk philosophy, marketing perception, etc.

The dimensions of credit risk to which the Bank is exposed to fundamentally

emanate from exposure to MSME enterprises/ sector which are characterized

by weaknesses in corporate structure, systems, accounting standards, lack of

availability/ reliability of information and vulnerability to external

developments, risk concentration in exposure to the MSME sector.

12.1 CREDIT RISK STRATEGY

In line with the strategy for managing risks in the credit portfolio, following

tenets have been incorporated in the Loan Policy:

Page 35: LOAN POLICY FY 2018 - :: Small Industries Development · PDF fileLOAN POLICY – FY 2018 ... procedural aspects of credit appraisal, processing, ... under guarantee schemes operated

Page 35 of 47

(a) Monitoring exposure to SFCs/ SIDCs as a percentage of total portfolios.

(b) Use of internal rating models to measure credit risk for majority of the

customer categories. Use of internal/external ratings in the decision

making process for lending would eventually lead to improvement in the

overall credit quality and better risk management of the Bank’s portfolio.

(c) Risk control, inter alia, through implementation of exposure limit

framework for different segments of customers.

(d) Implementation of processes to ensure that initiative to increase lending

by innovation in products, target clients, etc., does not lead to

deterioration of the asset quality of the Bank’s portfolio.

(e) Installation of an enabling framework capable of grading the risk and

eventually linking pricing to internal ratings as suited to the Bank’s

requirements.

12.2 RISK MEASUREMENT

12.2.1 Internal Credit Rating Systems

The Bank uses Credit Appraisal and Rating Tool [CART] to process loan

proposals (Greenfield and existing units) and rating of loan proposals

received from existing units fulfilling certain criteria.

For loans outside the purview of rating in CART, Risk Assessment Models

(RAMs) are being used

12.2.2 Investment Grades

Proposals with internal obligor risk rating at the time of appraisal between S1

to S8 in RAM (equivalent grade in CART) are considered as ‘investment

grade’ i.e. suitable for extending credit facility. However, in respect of certain

sectors, higher investment grade ratings have been stipulated for greater

Page 36: LOAN POLICY FY 2018 - :: Small Industries Development · PDF fileLOAN POLICY – FY 2018 ... procedural aspects of credit appraisal, processing, ... under guarantee schemes operated

Page 36 of 47

selectivity and credit quality as indicated in Annexure – II with minimum

internal rating grade specified. Changes to this list may be made from time

to time based on internal review.

12.3 RISK MITIGATION

The present credit risk mitigation strategies in vogue would be continued

which are primarily being applied at two levels. At the project specific level

[transaction level], efforts are made to identify critical risk factors and suitable

mitigation measures are explored and stipulated, wherever possible. Risk rating

would be used for objective grading of risk. At the portfolio level, the Bank has

been following a strategy of exposure management and prudential caps on

credit exposures under various activity/ industry /type of customer. The Bank

has also been working out the portfolio rating of the operating offices on an

annual basis for internal purposes. In order to build a strong portfolio, the

Bank would adopt a rating grade wise exposure.

12.4 EXTERNAL RATINGS

In respect of MSME-RFS limits without collateral security and resource support

to NBFCs, external rating (Long term rating) by RBI accredited rating agencies

is considered for the purpose of eligibility and pricing with minimum specified

external rating grade.

12.5 PRICING

12.5.1 In the existing scenario of dynamic interest rates, competition and the need

for the Bank to expand the direct finance portfolio with addition of quality

assets, a dynamic pricing strategy has become sine qua non. The pricing of

loans is carried out as per the gradation of risk determined by the internal

ratings for various customer segments. With a view to remaining competitive

in the market, the existing practice of fixing the interest/ discount rate

depending upon competitiveness/ demand, asset cover and such other

Page 37: LOAN POLICY FY 2018 - :: Small Industries Development · PDF fileLOAN POLICY – FY 2018 ... procedural aspects of credit appraisal, processing, ... under guarantee schemes operated

Page 37 of 47

factors, may continue. As regards assistance sanctioned to infrastructure

projects and such other projects under joint finance / consortium

arrangement, the interest rate stipulated by the lead institution / other banks

would normally be followed.

12.5.2 In case of projects involving multiple/joint/consortium financing, interest rate

reset clauses would be in line with the practice obtaining with other banks /

institutions.

12.6 RISK CATEGORISATION OF CUSTOMERS FROM AML PERSPECTIVE

In compliance with the Policy Guidelines on KYC Norms and Anti Money

Laundering (AML) Standards, the process of risk categorization of customers

has been put in place depending upon their activity, location, constitution, etc.

12.7 MANAGEMENT OF ASSET CONCENTRATION

12.7.1 Exposure Caps and Counterparty/Activity/Industry exposure

Asset concentration is being managed by the Bank by way of various

exposure caps/ norms for credit deployment which have been fixed, as under,

taking into account the norms prescribed by RBI. Internal caps have been laid

down in respect of different schemes of direct assistance and for various

industrial sectors as summarized in the table at Annexure – III.

12.7.2 Policy on Group Lending

The Bank considers assistance to large groups only under select schemes such

as MSME-RFS, NBFC and Infrastructure Scheme. Decisions on sanction/

continuation of exposure on a concern whose group/ associate concern(s) has

defaulted to the Bank and / or to other banks/ FIs are being taken on case

specific merits. The practice would be continued and a final view on such cases

would be taken by the delegated sanctioning authorities.

12.7.3 Restricted industries

Page 38: LOAN POLICY FY 2018 - :: Small Industries Development · PDF fileLOAN POLICY – FY 2018 ... procedural aspects of credit appraisal, processing, ... under guarantee schemes operated

Page 38 of 47

The extant instructions for a cautious approach in respect of industries such as

chemical dyes & dye intermediates, industrial oxygen, distilleries, etc., would

continue. Assistance to deserving units in the list could be considered if they

have an internal obligor risk rating of S7 or above. Industries consuming /

producing ozone depleting substances viz. Chlorofluorocarbons (CFCs), Halon,

Carbon tetrachloride, Methyl chloroform, Hydro bromo-fluorocarbons (HBFCs),

hydrochloro-fluorocarbons (HCFCs), Methyl bromide, Bromochloromethane

(BCM), etc., would not be assisted at all.

13. CONCLUSION

Efficient credit delivery is the key to quality portfolio build up and customer

retention. The Loan Policy gives adequate flexibility to develop viable business

proposals. The Policy has also put in place a suitable structure for approval /

clearance of new products. Hence, any business proposition considered to be

viable and bankable should not be lost on account of non-availability of a

suitable scheme/product. It will also be the endeavor of the Bank to further

simplify and streamline procedures/processes to expedite the credit delivery

besides making efficient use of IT for internal credit monitoring.

Page 39: LOAN POLICY FY 2018 - :: Small Industries Development · PDF fileLOAN POLICY – FY 2018 ... procedural aspects of credit appraisal, processing, ... under guarantee schemes operated

Page 39 of 47

Annexure - I

Benchmarks for Sanction (BfS)

A. Term Loan

Sl. No. Parameters BfS Norm Relaxation Cap

1 Prudential Rating S8 No relaxation

2 Debt-equity Ratio (DER)2 3:13 No relaxation

3 Promoters’ contribution4

New entity5 33% 25%

Existing entity6 25% 20%

4 Projected DSCR7 1.50 1.25

5 Fixed asset coverage Ratio (FACR)

New entity 1.00

0.908

Existing entity

Asset light & Cash-flow based 0.50 0.40

6 Asset coverage Ratio (ACR)

New entity 1.40 1.30

Existing entity 1.30 1.20

Asset light & Cash-flow based 1.30 1.00

B. Working Capital

Sl. No. Parameters BfS Norm Relaxation Cap

1 Prudential Rating S8 No relaxation

2 Interest coverage ratio (ICR)9

New entity 1.50 No relaxation

2 For the company/entity as a whole after considering sub-debt [SD] and interest-free unsecured loans [IFUSL] as

quasi equity

3 4:1 for Fleets/Vehicles under logistics (Service Sector)

4 (a) Not applicable for secured business loan (SBL) & privileged customer scheme (PCS) and (b) 15% for

proposals under SMILE

5 A “New entity” is an entity newly set up/proposed to be set up. This would also include entities established in

the past but with nil/ insignificant commercial production.

6 An “Existing entity” is one which has already been established and is engaged in commercial production (with or

without SIDBI's financial assistance) for minimum one year and audited accounts thereof are available.

7 1.25 for service sector with no relaxation

8 Applicable for customers having top 2 valid SME Credit rating/Bank loan rating of BBB+ & above

9 ICR = Earnings before Depreciation, Interest & Tax [EBDIT] / Interest expenses

Page 40: LOAN POLICY FY 2018 - :: Small Industries Development · PDF fileLOAN POLICY – FY 2018 ... procedural aspects of credit appraisal, processing, ... under guarantee schemes operated

Page 40 of 47

Existing entity10 1.25 1.10

3 Fixed asset coverage Ratio (FACR)

New entity 0.75 No

Existing entity 0.65

4 Asset coverage Ratio (ACR)

New entity 1.40 1.30

Existing entity 1.30 1.20

5 Current ratio

New entity 1.25 1.10

Existing entity 1.25 0.90

6 TOL to TNW ratio

New entity 4:1 5:1

Existing entity 4:1 6:1

7 Margin on stocks of raw materials, receivables/book debts etc.

New entity 30% 25%

Existing entity 30% 20%

C. Commercial Real Estate (CRE)

Sl. No. Parameters BfS Norm Relaxation Cap

1 Prudential Rating S8 No relaxation

2 Debt-equity Ratio (DER) 3:1 No relaxation

3 Promoters’ contribution

New entity 25% No relaxation

Existing entity

4 Projected DSCR 1.50 1.25

5 Fixed asset coverage Ratio (FACR)

New entity 1.50 No

Existing entity 1.35

6 Asset coverage Ratio (ACR)

New entity 2.00 1.80

Existing entity 1.75 1.60

D. MSME – Receivable Finance

10 Based on last audited accounts

Page 41: LOAN POLICY FY 2018 - :: Small Industries Development · PDF fileLOAN POLICY – FY 2018 ... procedural aspects of credit appraisal, processing, ... under guarantee schemes operated

Page 41 of 47

Sl.

No.

Parameters Secured Clean/

not backed by collateral

BfS

Norm

Relaxation

Cap

BfS

Norm

Relaxation

Cap

1 Prudential Rating S8 No AA A-

2 Fixed asset coverage Ratio (FACR)11

New customer 0.75 No Not applicable

Existing customer 0.65

3 Asset coverage Ratio (ACR)12

New customer 1.25

No Not applicable

Existing customer 1.10

4 Current ratio

New customer 1.25 1.05 1.25 1.10

Existing customer 0.85 0.90

5 Quick Ratio

New customer 0.50

0.40 0.50

0.40

Existing customer

6 TOL to TNW ratio

New customer 4:1

5:1 4:1

5:1

Existing customer 6:1 6:1

E. Equity & Risk Capital

Sl. No. Parameters BfS Norm Relaxation Cap

1 Prudential Rating S8 No relaxation

2 Debt-equity Ratio (DER) 3:1 No relaxation

3 Projected DSCR 1.50 1.25

11 Not applicable in respect of proposals backed by LC / BG / Co-acceptance / 100% FD

12 1.00 for exposure backed by LC/BG/Co-acceptance / 100% FD

Page 42: LOAN POLICY FY 2018 - :: Small Industries Development · PDF fileLOAN POLICY – FY 2018 ... procedural aspects of credit appraisal, processing, ... under guarantee schemes operated

Page 42 of 47

F. Resource support to NBFCs

Sl. No. Parameters BfS Norm Relaxation Cap

1 Prudential Rating S7/BBB+ BBB-13

2 Recovery Performance 95% 90%

3 Gross NPA <5% < or = 6%

4 CRAR >or =15% No relaxation

G. Micro Credit – Resource support to MFIs

Sl. No. Parameters BfS Norm Relaxation Cap

1 Prudential Rating MfR5 No relaxation

2 Debt-equity ratio (DER) 10:114 No relaxation

3 CRAR15 >or =15% No relaxation

4 Portfolio at Risk >90 days <5% <7%

5 Operational self sufficiency (OSS) 100% 90%

Note:

a. The product verticals would align their operational guidelines with the Loan Policy framework.

b. Relaxation of BfS norms within the cap may be considered for maximum 3 [three] parameters.

Additional risk premium, if any, to be charged for such relaxations, will be decided by the

delegated authority.

c. In respect of renewals at current level or reduced level, the delegated authority may relax the

BfS norms suitably provided proper risk mitigants are put in place. The exit strategy, if any,

would be decided by the delegated authority.

13 Applicable for existing customers with satisfactory financials and repayment track record

14 15:1 for Section 8 companies and Societies/Trusts

15 Applicable for NBFC-MFIs

Page 43: LOAN POLICY FY 2018 - :: Small Industries Development · PDF fileLOAN POLICY – FY 2018 ... procedural aspects of credit appraisal, processing, ... under guarantee schemes operated

Page 43 of 47

Annexure – II

Higher investment grade ratings – Select Sectors

Sr. No. Particulars of industry Minimum

obligor rating

1 Iron & steel industry

S7

2 Textiles*

3 Drugs & Pharmaceuticals

4 Hotels

5 Hospitals

6 Food & Food Products

7 Leather & Leather Products

8 Power sector projects

9 Wind mill projects (stand alone16)

10 Deserving units in the restricted list of

Industries such as Chemical dyes & dye

intermediates, industrial oxygen, distilleries

etc.

* Except knitting cluster at Tirupur.

16 Minimum obligor rating of windmill projects taken up by existing companies primarily for depreciation

benefit/captive use/sale to SEB would be S8

Page 44: LOAN POLICY FY 2018 - :: Small Industries Development · PDF fileLOAN POLICY – FY 2018 ... procedural aspects of credit appraisal, processing, ... under guarantee schemes operated

Page 44 of 47

Annexure – III

Exposure Caps

17 Exposure has been defined as under:

Product Exposure computation

Fund based & Non-fund based

facilities

Limit sanctioned or outstanding

whichever is higher.

18 Includes exposure from MUDRA Ltd. (a wholly owned subsidiary of the Bank)

S. No. Activity / Industry Exposure cap

1 Individual / Group Exposure17

(a) Direct assistance to MSMEs & specialized organizations marketing MSME products

(i) Single borrower 1% of capital funds of the Bank

(ii) Proprietorship entities `10 crore

(iii) Group exposure 3% of capital funds of the Bank

(b) NBFCs & private sector corporations

(i) Single borrower 15% of capital funds of the Bank – Asset

Finance Companies (AFCs)

10% of capital funds of the Bank –

others

(ii) Group exposure 40% of capital funds of the Bank

(c) MSME Receivable Finance Scheme (MSME-RFS), direct resource support & such other

form of bulk lending (except refinance and BRS) to public financial institutions, public

sector undertakings and corporates

(i) Single borrower 15% of capital funds of the Bank

(ii) Group exposure 25% of capital funds of the Bank

(d) MFIs18

(i) Single borrower 10% of capital funds of the Bank – NBFC-MFIs

3% of capital funds of the Bank – other MFIs

(ii) Group exposure 15% of capital funds of the Bank – NBFC-MFIs

Page 45: LOAN POLICY FY 2018 - :: Small Industries Development · PDF fileLOAN POLICY – FY 2018 ... procedural aspects of credit appraisal, processing, ... under guarantee schemes operated

Page 45 of 47

19Includes exposure to activities in various sub-sectors under infrastructure

20 Subject to compliance with capital market exposure limit

21 Excluding NBFCs

5% of capital funds of the Bank – other MFIs

2 Bills Finance

MSME-RFS without collateral 30% of capital funds of the Bank

3 Infrastructure activities/projects

(a) Total portfolio19 10% of capital funds of the Bank

(b) Power sector including generation,

transmission and distribution.

15 % of capital funds of the Bank

S. No. Activity / Industry Exposure cap

4 NBFCs

(a) Exposure cap: BBB and BBB- rated `100 crore

(b) Exposure cap: NBFC-MFIs 30 % of capital funds of the Bank

(c) Overall Exposure cap 75 % of capital funds of the Bank

5 Contribution to Venture Capital Funds20 40 % of capital funds of the Bank

6 Resource Support21 50 % of capital funds of the Bank

7 Services Sector

Exposure cap in service sector projects 40 % of capital funds of the Bank

8 Industry Exposure

(a) Cap on exposure to a particular industry

other than those at (b) below

10 % of capital funds of the Bank

(b)

(i) Transport Equipment (including Auto and

auto components)

30 % of capital funds of the Bank

(ii) Textiles / readymade garments and hosiery 30 % of capital funds of the Bank

(iii) Engineering industry 30 % of capital funds of the Bank

(iv) Electronics and electrical products 30 % of capital funds of the Bank

(v) Agro based industries 30 % of capital funds of the Bank

Page 46: LOAN POLICY FY 2018 - :: Small Industries Development · PDF fileLOAN POLICY – FY 2018 ... procedural aspects of credit appraisal, processing, ... under guarantee schemes operated

Page 46 of 47

(vi) Commercial Real Estate 25 % of capital funds of the Bank

(vii) Petroleum & Petroleum Products 30 % of capital funds of the Bank

9 Direct Assignment business 10 % of capital funds of the Bank

10 Ceiling on Exposure in unsecured advances

[including MSME-RFS without collateral at

1(a) above]

100% of capital funds of the Bank

11 Individual bank/institution wise limit

Refinance/Co-accepted Bills/

BRS/LOCFC/Resource Support [per institution]

(a) State Bank of India and Nationalized Banks Individual bank/FI-wise limit as approved

by the Board.

(b) Private sector banks/ foreign banks

(c) SFCs [per institution] 15% of capital funds of the Bank

(d) SIDCs including TFIDCs [per institution] 1% of capital funds of the Bank

(e) SSIDCs [per institution] 0.5% of capital funds of the Bank

(f) Scheduled Co-operative banks 5 % of capital funds of the Bank

(g) Regional Rural Banks [per institution] 2.5% of capital funds of the Bank

Page 47: LOAN POLICY FY 2018 - :: Small Industries Development · PDF fileLOAN POLICY – FY 2018 ... procedural aspects of credit appraisal, processing, ... under guarantee schemes operated

Page 47 of 47

**********

22 Excluding SFCs and SIDCs

S. No. Activity / Industry Exposure cap

(h) Small Finance Banks 15% of capital funds of the Bank

11 Aggregate exposure to

(a) All SFCs (Aggregate) `2000 crore

(b) All SIDCs including TFIDCs (Aggregate) 5 % of capital funds of the Bank

(c) State Bank of India and all Nationalized Banks

(aggregate)

500% of capital funds of the Bank

(d) All FIs (aggregate)22 100 % of capital funds of the Bank

(e) Private Sector Banks (aggregate) 500% of capital funds of the Bank

(f) Foreign Banks (aggregate) 100 % of capital funds of the Bank

(g) Scheduled Co-operative banks (aggregate) 10 % of capital funds of the Bank

(h) Regional Rural Banks (aggregate) 5% of capital funds of the Bank

(i) Small Finance Banks (aggregate) 40% of capital funds of the Bank