Banking I: The Financial System, Banks, the RBI and Reforms

Unit 7 is the Indian financial system from the top down, and this first chapter covers its architecture: what the system is for, the kinds of bank that operate inside it, the central bank that regulates them and manages money, the reforms that reshaped banking after 1991, and the three markets — money, capital and government securities — through which funds move. The paper asks it as a system of named parts, and marks turn on placing each part correctly: which body regulates cooperative banks, which Basel pillar is which, which instrument belongs to which market.

1. The Indian financial system: an overview

A financial system moves savings from those who have them to those who can use them, and it does so through four components that the paper treats as a list: financial institutions, which intermediate; financial markets, where instruments are traded; financial instruments, the claims themselves; and financial services, the activities that support the other three. Its functions are mobilising savings, allocating them to productive use, providing liquidity, transferring and pooling risk, and settling payments.

The institutions divide into banking and non-banking. A bank accepts deposits repayable on demand and creates credit; a non-banking institution may lend and invest but cannot accept demand deposits or operate the payments system. The markets divide by maturity into the money market, for instruments of up to one year, and the capital market, for longer-term claims, and by whether the instrument is new or already issued into the primary and secondary markets.

2. Types of banks

The banks the syllabus names
TypeWhat it isRegulated byPoint the paper tests
Commercial banksPublic sector, private sector and foreign banks accepting deposits and lending for profitRBI under the Banking Regulation Act, 1949Scheduled banks are those in the Second Schedule of the RBI Act, 1934
Regional Rural BanksSet up under the RRB Act, 1976 to lend to small farmers, artisans and rural labourRBI regulates; NABARD supervisesOwned 50:35:15 by the Centre, the sponsor bank and the State
Foreign banksBanks incorporated abroad operating through branches or wholly owned subsidiaries in IndiaRBISubject to priority sector lending at a threshold that depends on branch count
Cooperative banksMember-owned; urban cooperative banks, and a rural three-tier structure of State, district central and primary societiesDual — RBI for banking functions, the Registrar of Cooperative Societies for incorporation and managementThe dual control is the examinable weakness, tightened by the 2020 amendment
⚠️ Scheduled means listed in a schedule, not large
A scheduled bank is one included in the Second Schedule of the Reserve Bank of India Act, 1934, which requires a minimum paid-up capital and reserves and satisfaction that the bank's affairs are not conducted against depositors' interests. Scheduled banks can borrow from the RBI at the bank rate and must keep the cash reserve ratio with it. Many cooperative banks are scheduled and some are not, so the word describes a legal status rather than a size or a type.

3. The Reserve Bank of India: functions and monetary policy

The RBI was established under the Reserve Bank of India Act, 1934, began operations in 1935 and was nationalised in 1949. Its functions are asked as a list: sole issuer of currency notes other than the one-rupee note, which the Government issues; banker to the Government and to banks, and lender of last resort; custodian of foreign exchange reserves and manager of the exchange rate; regulator and supervisor of banks; controller of credit through monetary policy; and developmental functions that have since largely been spun off to NABARD, SIDBI and the NHB.

Monetary policy is decided by the six-member Monetary Policy Committee constituted under the 2016 amendment to the RBI Act — three from the RBI including the Governor, who has a casting vote, and three appointed by the Government — with a statutory inflation target of 4% consumer price inflation within a band of 2% to 6%. The instruments divide into quantitative, which act on the volume of credit, and qualitative or selective, which act on its direction.

The quantitative instruments
InstrumentWhat it isTo tighten money
Repo rateThe rate at which banks borrow overnight from the RBI against securities — the policy rateRaise it
Reverse repo and SDFThe rate the RBI pays banks to park surplus with it; the standing deposit facility does so without collateralRaise it
Bank rateThe rate for long-term lending to banks, now aligned with the marginal standing facilityRaise it
Cash reserve ratioThe share of net demand and time liabilities a bank must hold as cash with the RBI; earns no interestRaise it
Statutory liquidity ratioThe share of NDTL a bank must hold in cash, gold or approved securities, with itselfRaise it
Open market operationsOutright purchase or sale of government securities by the RBISell securities
🧠 CRR sits with the RBI; SLR sits with the bank
Both are reserve requirements and both are expressed as a fraction of net demand and time liabilities, which is why they are confused. The difference is where the reserve is kept and in what. CRR is cash held with the Reserve Bank and earns nothing; SLR is held by the bank itself in cash, gold or approved securities, and the securities earn interest. Qualitative instruments — margin requirements, credit rationing, moral suasion, direct action — are the other family and act on which sectors get credit rather than how much there is.

4. Reforms: Narasimham, Basel, risk and non-performing assets

Banking reform in India runs from the two Narasimham Committees. The first, in 1991, recommended lowering the SLR and CRR, deregulating interest rates, prudential norms for income recognition, asset classification and provisioning, capital adequacy, and entry for new private banks. The second, in 1998, recommended stronger capital norms, narrow banking for weak banks, asset reconstruction companies, and reduction of government shareholding. Most of what banking looks like today was proposed in one of the two.

The Basel accords
AccordWhat it added
Basel I (1988)A minimum capital to risk-weighted assets ratio of 8%, with capital in two tiers and assets weighted for credit risk only
Basel II (2004)Three pillars — minimum capital now covering credit, market and operational risk; supervisory review; and market discipline through disclosure
Basel III (2010)Higher and better-quality capital, a capital conservation buffer and a countercyclical buffer, a leverage ratio, and two liquidity standards — the liquidity coverage ratio and the net stable funding ratio

A bank's risks are named and matched to the pillar that captures them: credit risk that a borrower will not repay, market risk from movements in rates and prices, operational risk from failed processes, people, systems or fraud, and liquidity risk that the bank cannot meet obligations as they fall due. Asset-liability management is the practice of matching the maturity and rate sensitivity of what the bank owes against what it owns.

ℹ️ Non-performing assets: the ninety-day rule and the ladder
A loan becomes non-performing when interest or principal remains overdue for more than ninety days. It is then classified as substandard for up to twelve months, doubtful thereafter, and a loss asset once identified as uncollectible, with provisioning rising at each step. Gross NPA is the total; net NPA deducts provisions already made. The tools for resolution are the SARFAESI Act, 2002, which lets a secured creditor enforce security without a court; the Insolvency and Bankruptcy Code, 2016, which puts a defaulting company through a time-bound process; asset reconstruction companies, which buy bad loans; and the NARCL, a government-backed bad bank set up in 2021.

5. Money, capital and government securities markets

Instruments by market
MarketMaturityInstrumentsRegulator
Money marketUp to one yearCall and notice money, treasury bills, commercial paper, certificates of deposit, repo, collateralised borrowingRBI
Capital marketOver one yearEquity and preference shares, debentures and bonds; primary through IPO, FPO, rights and private placement; secondary on the exchangesSEBI
Government securities marketBoth — T-bills short, dated securities longTreasury bills of 91, 182 and 364 days; dated securities; State development loans; sold by auction on the RBI's electronic platformRBI, as the Government's debt manager
⚠️ Commercial paper is issued by companies; certificates of deposit by banks
Both are short-term, unsecured, discounted instruments of the money market, which is why they are set against each other. Commercial paper is the promissory note of a highly rated corporate borrowing directly from the market instead of from a bank; a certificate of deposit is a negotiable receipt for a deposit placed with a bank or a financial institution. Treasury bills are also discounted instruments, but the issuer is the Government and the maturities are fixed at 91, 182 and 364 days.

Key takeaways

  • A bank accepts demand deposits and creates credit; a non-banking institution may lend but cannot. Scheduled means listed in the Second Schedule of the RBI Act, a legal status and not a size.
  • Cooperative banks are under dual control — the RBI for banking and the Registrar for incorporation — and RRBs are owned 50:35:15 by the Centre, the sponsor bank and the State.
  • The MPC has six members and a 4% target within 2% to 6%; CRR is cash with the RBI earning nothing, SLR is held by the bank itself in cash, gold or approved securities.
  • Basel II brought three pillars and Basel III brought buffers, a leverage ratio and two liquidity standards; a loan is non-performing after ninety days overdue and climbs substandard, doubtful, loss.
  • Commercial paper is a company's, certificates of deposit are a bank's, treasury bills are the Government's at 91, 182 and 364 days; the money market is the RBI's and the capital market is SEBI's.

Practice questions (9)

Attempt each one before opening the answer. Every explanation names the tempting wrong option as well as the right one, because that is where marks are lost.

  1. The cash reserve ratio differs from the statutory liquidity ratio in that the CRR:

    1. Is held as cash with the Reserve Bank and earns no interest
    2. May be held in gold and approved securities with the bank itself
    3. Is fixed by SEBI rather than the RBI
    4. Applies only to cooperative banks
    Show answer

    Answer: A — Is held as cash with the Reserve Bank and earns no interest

    Both ratios are fractions of a bank's net demand and time liabilities and both are set by the RBI, so the difference lies in where the reserve sits and in what form. The CRR is a balance the bank must keep as cash with the Reserve Bank, on which nothing is earned, which is why a rise in CRR is a direct cost to banks. The SLR is maintained by the bank itself in cash, gold or approved government securities, and the securities earn interest. SEBI regulates the capital market and has no role in reserve requirements, and both ratios apply to scheduled commercial banks, not to cooperative banks alone.
  2. A loan is classified as a non-performing asset when interest or principal remains overdue for more than:

    1. 90 days
    2. 30 days
    3. 180 days
    4. One year
    Show answer

    Answer: A — 90 days

    The RBI's prudential norms treat a loan as non-performing once interest or an instalment of principal has been overdue for more than ninety days, a threshold tightened from 180 days in 2004 as part of convergence with international practice. Once classified, the asset moves down a ladder — substandard for up to twelve months, doubtful thereafter, and loss when identified as uncollectible — with provisioning rising at each step. Thirty days is the point at which a special mention account is flagged, before the loan turns non-performing, and one year is the boundary between substandard and doubtful rather than the NPA threshold itself.
  3. Certificates of deposit in the Indian money market are issued by:

    1. Banks and eligible financial institutions
    2. Highly rated non-financial companies
    3. The Government of India
    4. Stock exchanges
    Show answer

    Answer: A — Banks and eligible financial institutions

    A certificate of deposit is a negotiable, discounted receipt for a term deposit placed with a bank or an eligible financial institution, which is what makes it a bank's instrument. Commercial paper is the parallel instrument on the corporate side — an unsecured promissory note issued by a highly rated company borrowing directly from the market — and the two are routinely set against each other for exactly this distinction. The Government's short-term instrument is the treasury bill, issued at 91, 182 and 364 days, and stock exchanges provide a secondary market for capital market securities rather than issuing money market paper.
  4. The three pillars of Basel II are:

    1. Minimum capital requirements, supervisory review and market discipline
    2. Credit risk, market risk and liquidity risk
    3. Tier 1 capital, Tier 2 capital and Tier 3 capital
    4. The leverage ratio, the liquidity coverage ratio and the net stable funding ratio
    Show answer

    Answer: A — Minimum capital requirements, supervisory review and market discipline

    Basel II organised bank regulation around three pillars: the first sets minimum capital against credit, market and operational risk, the second gives supervisors the power to review a bank's own assessment of its risk and require more capital, and the third uses disclosure to let the market discipline banks. The list of risks is what the first pillar measures rather than the pillars themselves, and liquidity risk was not addressed by Basel II at all. The tiers describe the quality of capital, not the pillars. The leverage ratio and the two liquidity standards are the additions of Basel III, introduced after the 2008 crisis exposed what Basel II had left out.
  5. Regional Rural Banks are owned by the Central Government, the sponsor bank and the State Government in the ratio:

    1. 50:35:15
    2. 51:49:0
    3. 33:33:34
    4. 60:20:20
    Show answer

    Answer: A — 50:35:15

    The Regional Rural Banks Act, 1976 set the share capital of each RRB to be contributed by the Central Government, the sponsoring commercial bank and the State Government in the proportion 50:35:15, which is the figure the paper asks. The design gives the Centre a controlling stake, ties each bank to a commercial bank that provides management and support, and involves the State in whose districts it operates. RRBs are regulated by the RBI and supervised by NABARD, and successive rounds of amalgamation have reduced their number while keeping this ownership structure intact.
  6. The Monetary Policy Committee of the RBI consists of:

    1. Six members, three from the RBI and three appointed by the Government, with the Governor holding a casting vote
    2. The Governor alone, advised by the Deputy Governors
    3. Twelve members drawn equally from the RBI, the Finance Ministry and public sector banks
    4. The Finance Minister and the Governor jointly
    Show answer

    Answer: A — Six members, three from the RBI and three appointed by the Government, with the Governor holding a casting vote

    The 2016 amendment to the RBI Act created a six-member Monetary Policy Committee: the Governor, the Deputy Governor in charge of monetary policy and one officer nominated by the RBI's central board, together with three external members appointed by the Central Government for a fixed term. Decisions are by majority, and the Governor has a second, casting vote in the event of a tie. The committee is charged with meeting a statutory inflation target of 4% consumer price inflation within a band of 2% to 6%. Before 2016 the Governor decided policy alone with a technical advisory committee, which is the arrangement the first wrong option describes.
  7. Cooperative banks in India are subject to dual control, meaning that they are regulated by:

    1. The RBI for banking functions and the Registrar of Cooperative Societies for incorporation and management
    2. SEBI and the RBI jointly
    3. NABARD and SIDBI jointly
    4. The Central and State Governments directly
    Show answer

    Answer: A — The RBI for banking functions and the Registrar of Cooperative Societies for incorporation and management

    Cooperative banks are cooperative societies first and banks second, so two laws reach them: the State Cooperative Societies Act, administered by the Registrar, governs their registration, membership, elections and management, while the Banking Regulation Act, administered by the RBI, governs their banking business. This division is the examinable weakness of the structure, because supervisory gaps opened between the two authorities, and the Banking Regulation (Amendment) Act, 2020 extended the RBI's powers over cooperative banks' management to narrow them. SEBI regulates securities markets, and NABARD supervises rural cooperatives and RRBs rather than regulating urban cooperative banks.
  8. The SARFAESI Act, 2002 enables a secured creditor to:

    1. Take possession of and sell the security for a defaulted loan without the intervention of a court
    2. Write off the loan against the Government's guarantee
    3. Convert the loan into equity of the borrower automatically
    4. Refer the borrower to the Monetary Policy Committee
    Show answer

    Answer: A — Take possession of and sell the security for a defaulted loan without the intervention of a court

    The Securitisation and Reconstruction of Financial Assets and Enforcement of Security Interest Act, 2002 gave banks and financial institutions a route around the slow civil courts: after a loan is classified non-performing and a sixty-day notice has expired, the secured creditor may take possession of the secured asset, take over its management, or sell or lease it, and the borrower's remedy is an appeal to the Debts Recovery Tribunal. The Act also provided the legal basis for asset reconstruction companies. It provides no government guarantee, no automatic conversion to equity, and the Monetary Policy Committee has nothing to do with individual loan recovery.
  9. Treasury bills in India are issued for maturities of:

    1. 91, 182 and 364 days
    2. 1, 3 and 5 years
    3. 7, 14 and 28 days only
    4. 10, 20 and 30 years
    Show answer

    Answer: A — 91, 182 and 364 days

    Treasury bills are the Government of India's short-term borrowing instrument, issued at a discount and redeemed at par, and they are auctioned by the RBI at three maturities — 91, 182 and 364 days. Being a money market instrument they never exceed one year. Government borrowing for longer periods is done through dated securities, which run from a few years to as long as forty, and those are the maturities the last option confuses with bills. Very short tenors of a week or two are the territory of the call and notice money market and of repo, not of treasury bills.