: April 26, 2011 |
: Company Law
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An Emerging Concept In The Perspective Of The Indian Economy
In the post nationalization era the banking sector witnessed flow of substantial amount of resources while the banking network underwent an expansion phase without comparables in the world. Credit came to be recognized as a remedy for many of the ills of the poverty. Credit packages and programmes were designed based on the experience gained.
Microfinance is a general term to describe financial services to low-income individuals or to those who do not have access to typical banking services.
Microfinance is also the idea that low-income individuals are capable of lifting themselves out of poverty if given access to financial services. While some studies indicate that microfinance can play a role in the battle against poverty, it is also recognized that is not always the appropriate method, and that it should never be seen as the only tool for ending poverty.
Microfinance: A CONCEPT
"Microfinance is the supply of loans, savings, and other basic financial services to the poor."
As these financial services usually involve small amounts of money - small loans, small savings, etc. - the term "microfinance" helps to differentiate these services from those which formal banks provide.
Why are they small? Someone who doesn't have a lot of money isn't likely to want or be able to take out a Rs.50,000 loan, or be able to open a savings account with an opening balance of Rs.1,000.
It's easy to imagine poor people don't need financial services, but when you think about it they are using these services already, although they might look a little different.
"Poor people save all the time, although mostly in informal ways. They invest in assets such as gold, jewelry, domestic animals, building materials, and things that can be easily exchanged for cash. They may set aside corn from their harvest to sell at a later date. They bury cash in the garden or stash it under the mattress. They participate in informal savings groups where everyone contributes a small amount of cash each day, week, or month, and is successively awarded the pot on a rotating basis. Some of these groups allow members to borrow from the pot as well. The poor also give their money to neighbors to hold or pay local cash collectors to keep it safe.
However widely used, informal savings mechanisms have serious limitations. It is not possible, for example, to cut a leg off a goat when the family suddenly needs a small amount of cash. In-kind savings are subject to fluctuations in commodity prices, destruction by insects, fire, thieves, or illness (in the case of livestock). Informal rotating savings groups tend to be small and rotate limited amounts of money. Moreover, these groups often require rigid amounts of money at set intervals and do not react to changes in their members' ability to save. Perhaps most importantly, the poor are more likely to lose their money through fraud or mismanagement in informal savings arrangements than are depositors in formal financial institutions.
"The poor rarely access services through the formal financial sector. They address their need for financial services through a variety of financial relationships, mostly informal."
Different types of financial services providers for poor people have emerged - non-government organizations (NGOs); cooperatives; community-based development institutions like self-help groups and credit unions; commercial and state banks; insurance and credit card companies; telecommunications and wire services; post offices; and other points of sale - offering new possibilities.
These providers have increased their product offerings and improved their methodologies and services over time, as poor people proved their ability to repay loans, and their desire to save. In many institutions, there are multiple loan products providing working capital for small businesses, larger loans for durable goods, loans for children’s education and to cover emergencies. Safe, secure deposit services have been particularly well received by poor clients, but in some countries NGO microfinance institutions are not permitted to collect deposits.
Ideas relating to microcredit can be found at various times in modern history.
Jonathan Swift inspired the Irish Loan Funds of the 18th and 19th centuries. In the mid-19th century, Individualist anarchist Lysander Spooner wrote about the benefits of numerous small loans for entrepreneurial activities to the poor as a way to alleviate poverty. Ideas relating to microcredit were mentioned in portions of the Marshall Plan at the end of World War II.
The origins of microcredit in its current practical incarnation, with attention paid by economists and politicians worldwide, can be linked to several organizations founded in Bangladesh, especially the Grameen Bank in the 1970s and onward, for which its founder Muhammad Yunus was awarded the Nobel Peace Prize in 2006.
Microcredit is based on a separate set of principles, which are distinguished from general financing or credit.
Microcredit emphasizes building capacity of a micro-entrepreneur, employment generation,trust building, and help to the micro-entrepreneur on initiation and during difficult times.
Microcredit is a tool for socioeconomic development.
IV. Evolution Of Microfinance In India
The NABARD has successfully spearheaded the microfinance programme through partnership with various stakeholders like non-governmental organisations (NGOs),banks, cooperatives, etc, in the formal and informal sector, with support from both the government of India (GOI) and the Reserve Bank of India (RBI) since the early1990s. The SHG-bank linkage programme . The SHG-bank linkage programme(BLP) was launched by NABARD as a pilot project in 1992 against the backdrop of a huge banking structure unable to adequately address the microcredit needs of the poor.
1. Microfinance and Social Empowerment
The SHG-BLP itself has had a profound social impact. A number of studies conducted on the effectiveness of the programme, have highlighted its impact on the social empowerment process. Important findings with respect to the SHG programme are:
o It has enabled households to spend much more on education than non-client households. Families participating in the programme have reported better school attendance and lower dropout rates.
o It has empowered women by enhancing their contribution to household income, increasing the value of their assets and generally by giving them better control over decisions that affect their lives.
o In certain areas, microfinance has reduced child mortality, improved maternal health and the ability of the poor to combat disease through better nutrition, housing and health – especially among women and children.
o It has contributed to reduced dependency on informal moneylenders and other non-institutional lenders in rural areas.
2. Microfinance and Economic Growth
Economic growth requires many things—from relatively stable governments to alleviation of poverty to the creation of a formal business sector to access to clean water, education, and healthcare. Long term growth can be achieved by
1. Putting an emphasis placed on improving overall quality of life, Public goods are missing from many of the small villages and poor slums in which microcredit is extended. Lack of safe wells, paved roads, and so on, limits the growth that successful and entrepreneurial microcredit borrowers can experience.
2. A focus on real businesses (which very possibly means not lending to the poorest of the poor, but lending to the better off who can create real enterprises and employ their less able neighbors) is necessary to create self-sustaining small companies, and to make the push toward a formal sector. Because MFIs have maintained their strong reputation and their ability to reach millions of people, they possess the necessary qualities to bring change.
While projects of this caliber may sound too lofty, it is absolutely necessary to consider using microfinance on a slightly larger, more innovative scale. There is no accessible data to say that these types of projects in conjunction with MFIs have been tested or tried, therefore it cannot be stated that microfinance used in other ways would not lead to more successful, and developed towns, villages and cities. Because microfinance is still a relatively new idea, MFIs are not eager to switch practices. But there are some changes that need to take place...
VI. Microfinance Providers
A microfinance institution (MFI) is an organization that provides microfinance services. MFIs range from small non-profit organizations to large commercial banks.
Historical context can help explain how specialized MFIs developed over the last few decades. Between the 1950s and 1970s, governments and donors focused on providing subsidized agricultural credit to small and marginal farmers, in hopes of raising productivity and incomes. During the 1980s, micro-enterprise credit concentrated on providing loans to poor women to invest in tiny businesses, enabling them to accumulate assets and raise household income and welfare. These experiments resulted in the emergence of nongovernmental organizations (NGOs) that provided financial services for the poor. In the 1990s, many of these institutions transformed themselves into formal financial institutions in order to access and on-lend client savings, thus enhancing their outreach.
Established by NABARD in accordance with the provisions of the NABARD Act, 1981, the Research and Development Fund aims at acquiring new insights into the problems of agriculture and rural development through in depth studies and applied research and trying out innovative approaches backed up by technical and economic studies. The R&D Fund is utilized for the formulating policies on matters of importance to agricultural operations and rural development.
1. The Banking Regulation Act , 1949empowers NABARD to undertake inspection of the RRBs and Co-operative banks .
2. Any RRB or Co-operative banks taking permission from RBI for opening new branches will have to obtain recommendation of NABARD.
3. RRBs and Co –operative are required to file returns and documents with the NABARD.
It has been entrusted with the statutory responsibility of the conducting responsibility of con
Ducting inspections of the State Cooperatives Banks, District Central Cooperative Banks and regional Rural Banks under the provisions of The Banking Regulation Act , 1949. In addition it conducts periodic inspections of state level co-operative institutions on the voluntary basis.
NABARD is an apex involved in refinancing credit needs of major financial institutions in the country engaged in the offering Financial assistance to agriculture and rural development operations and programmes , is undertaking and sharing with the RBI certain supervisory functions in respect of Co-operative banks and regional rural banks such as :
1. Inspection of RRBs and Co-operative Banks under the provisions of The Banking Regulation Act , 1949.
2. Inspection of State Cooperative Agriculture and Rural Development banks and apex non-credit cooperative societies on a voluntary basis.
3. Portfolio inspections , system study and off-site surveillance of Co-operative Banks and RRBs.
4. Recommendations to RBI on opening of new branches by State Cooperative Banks and RRBs.
5. Administering the Credit Monitoring Arrangements in the State Cooperative Banks, District Central banks.
The day to day functioning of the the supervised banks is being monitored through various statutory returns prescribed by the RBI/NABARD including OSS returns.
VII. The SHG system
The launching of pilot phase of SHG programme in February 1992 was a landmark development in banking with poor. SHG informal thrift and credit groups of poor came to be recognized as the bank clients under the Pilot phase.
According to NABARD, almost 3 million SHGs have linked to nearly 500 banks since the program started, reaching over 11 million households across.
The members form a group of around twenty members. The group formation process may be facilitated by an NGO or by the MFI or bank itself, or it may evolve from a traditional rotating savings and credit group (ROSCA) or other locally initiated grouping. The process of formal ‘linkage’ to an MFI or bank usually goes through the following stages, which may be spread over many years or which may take place within a few months
• The SHG members decide to make regular savings contributions. These may be kept by their elected head, in cash, or in kind, or they may be banked.
• The members start to borrow individually from the SHG, for purposes, on terms and at interest rates decided by the group themselves.
• The SHG opens a savings account, in the group’s name, with the bank or MFI, for such funds as may not be needed by members, or in order to qualify for a loan from the bank.
• The bank or MFI makes a loan to the SHG, in the name of the Group, which is then used by the Group to supplement its own funds for on-lending to it members.
The SHG need never go through all these stages; it may satisfy its members’ needs quite effectively if it only goes to the second or even to the first stage, saving money and possibly not even withdrawing it .
The SHG carries out all the same functions as those required by the Grameen system, but they do this on their own behalf, since the SHG is effectively a micro-bank, carrying out all the familiar intermediation tasks of savings mobilisation and lending. The MFI or bank may assist the SHG in record keeping, and they may also demand to know who are the members and impose certain conditions as to the uses of the loan which they make to the SHG, but the SHG is an autonomous financial institution in its own right.
The SHG system is mainly found in India, where it is used by both MFIs and banks. There also some important users in Indonesia, parts of South East Asia, Africa and elsewhere. The SHG system in India was initiated by NGOs, and is used for financial intermediation both by commercial banks and by MFIs.
Commercial banks, regional rural banks (RRBs) and cooperative banks primarily fund the SHG-Bank Linkage Programme, and NABARD in turn re-finances them. Credit lines to SHGs are critically limited, as they are based on a certain multiple of SHG members' savings accounts within banks. While the cumulative savings of SHGs could serve as a low-cost source of funds for onlending, their potential is limited by the lack of aggregated savings across SHGs. Commercial equity investments are not available to for SHGs due to their informal status
Illusive socio-economic impacts
SHGs form a critical link for poor women to access a variety of financial services. They are effective platforms for women to participate in politics through awareness campaigns and community action. SHGs have also emerged as "last mile" channels for government to distribute financial benefits and for corporations to retail their products through member-entrepreneurs. Even so, questions remain about the ability of SHGs to attain a primary objective - economic empowerment of poor women.
VIII. Costs, Interest Rates, and Sustainability Interest Rates (They're High)
There are three kinds of costs the MFI has to cover when it makes microloans. The first two, the cost of the money that it lends and the cost of loan defaults, are proportional to the amount lent. For instance, if the cost paid by the MFI for the money it lends is 10%, and it experiences defaults of 1% of the amount lent, then these two costs will total $11 for a loan of $100, and $55 for a loan of $500. An interest rate of 11% of the loan amount thus covers both these costs for either loan.
The third type of cost, transaction costs, is not proportional to the amount lent. The transaction cost of the $500 loan is not much different from the transaction cost of the $100 loan. Both loans require roughly the same amount of staff time for meeting with the borrower to appraise the loan, processing the loan disbursement and repayments, and follow-up monitoring. Suppose that the transaction cost is $25 per loan and that the loans are for one year. To break even on the $500 loan, the MFI would need to collect interest of $50 5 $25 = $80, which represents an annual interest rate of 16%. To break even on the $100 loan, the MFI would need to collect interest of $10 1 $25 = $36, which is an interest rate of 36%. At first glance, a rate this high looks abusive to many people, especially when the clients are poor. But in fact, this interest rate simply reflects the basic reality that when loan sizes get very small, transaction costs loom larger because these costs can't be cut below certain minimums.
IX. MICRO-FINANCE RBI’S APPROACH
Banks were advised to consider the lending to SHGs as part of their mainstream credit operations , to identify branches with the potential to link with the SHGs and provide the necessary support services to such branches with the potential to link with the SHGs and provide the necessary services to such branches , while including the SHG lending within their service area plan .
Furthermore, subsequent to the Monetary and Credit Policy announcement for 1999-2000, banks were advised that interests rates applicable to loans given by banks to micro credit organizations or by the micro credit organizations to SHGs /member beneficiaries would be left to their discretion . Also the SHGs were free to decide on the interest rate to be charged their members , provided the rate of interest was not excessive.
The term ‘micro finance’ has been given a working definition by the Task Force on the Supportive Policy and Regulatory Framework for the Micro Finance set up by NABARD which states: ‘provision of thrift, credit and other financial services and products of very small amounts to the poor in rural, semi-urban areas for enabling them to raise their income levels and improve living standards.
MFIs & SHG-Bank Linkage Programme
In a joint fact-finding study on microfinance conducted by the Reserve Bank of India and a few major banks, the following observations were made:
Some of the microfinance institutions (MFIs) financed by banks or acting as their intermediaries or partners appear to be focusing on relatively better banked areas, including areas covered by the SHG-Bank linkage programme. Competing MFIs were operating in the same area, and trying to reach out to the same set of poor, resulting in multiple lending and overburdening of rural households.
Many MFIs supported by banks were not engaging themselves in capacity building and empowerment of the groups to the desired extent. The MFIs were disbursing loans to the newly formed groups within 10–15 days of their formation, in contrast to the practice
obtaining in the SHG – Bank linkage programme, which takes about six to seven months for group formation and nurturing. As a result, cohesiveness and a sense of purpose were not being built up in the groups formed by these MFIs.
Banks, as principal financiers of MFIs, do not appear to be engaging them with regard to their systems, practices and lending policies with a view to ensuring better transparency
X. Legislation Affecting Institutions Engaged in Micro-Finance (Directly or indirectly)
· The Legal formats of MFIs that are provided by Indian law can be classified by the profit motive:
· Not-For-Profit Entities are trusts, societies and section 25 companies.
· For-Profit enterprises are Non-Banking Financial Companies (NBFCs).
· The following legislations regulate the functioning of MFI’s in India
(i) Reserve Bank of India Act, 1934 –
The Reserve Bank of India Act 1934 establishes the central bank (Banking Regulatory Authority of India). It is of interest to the question of the regulation of micro-finance in that under a 1977 Amendment it contains provisions for the establishment and operations of non-bank finance companies (Chapter 3-B, Sections 45-I). The non-banking institutions can be a company, a corporation or a cooperative society. A non-bank financial company (NBFC) is a non-banking institution company and takes deposits. NBFCs are registered under this Act (Second Schedule).
(ii) Banking Regulation Act 1949 –
The Banking Regulation Act 1949 covers “banking companies”. It does not apply to primary agriculture credit societies, cooperative land mortgage banks and any other cooperative society. It is not directly relevant to micro-finance, other than the fact that it coves local area banks and commercial banks, which are involved in linkage operations. The Banking Regulation Act provides the basis for the licensing of local area banks and mutual benefit societies.
(iii) Companies Act 1956 –
The companies Act 1952 provides the basis for the incorporation of Local Area Banks, Non-Bank Finance Companies, non-for-profit “Section 25 Companies” and Nidhis under Section 620.
Certain revisions have been proposed in the Companies Act which would allow cooperatives in the form of companies and could offer micro-finance services
(iv) Co-operative Societies Act of 1904; Mutually Aided Co-operative Societies Act in 1995 (Andhra Pradesh) Societies Registration Act of 1860 and Indian Trusts Act -1882.
The term “cooperative” covers a range of institutions, both formal (stated-owned cooperatives banks) and semi-formal (cooperative societies), which are regulated and/or unregulated.
Enterprises registered under the Societies registration or Indian Trusts Acts are semi-formal institutions engaged in micro-finance. The Acts do not provide a basis for any of regulation so far. There is a tax problem in that societies and trusts cannot engage in for-profit activities, including financial services.
Co-operative Societies Act of 1904 covers cooperative, SEWA Bank is registered as a co-operative society, under this act but is regulated by the RBI from which it obtained a banking license.
1. Programme Design and Impact Assessments: ‘Success’ of Microfinance in Perspective- Sayantan Bera
The enviable success of microfinance programmes in terms of high repayment rates, vis-à-vis state-led subsidized credit programmes of the past, has mostly been attributed to the group lending aspect with the much celebrated “joint liability” feature. But in practice, such programmes use a host of other dynamic and static incentives features, engage in meticulous designing of financial products and use different models of service delivery, going beyond “group lending with joint liability”.
2. Commercialization of Microfinance in India: A Discussion of the Emperor’s Apparel-M S Sriram
Most of the early microfinance in India happened through donor and philanthropic funds, which were channeled to not-for-profit organizations. As the activities scaled up, microfinance moved to a commercial format. Using publicly available data, this paper examines the growth imperatives and the transformation processes of four large microfinance institutions in India. It studies the implications of the transformation process and its effect on the personal enrichment of the promoters of the MFIS. It examines the governance processes in these institutions and questions the moral and ethical fabric on which these institutions are built.
3. Microfinance: Lessons from a Crisis - Tara S Nair
The rural distress in Andhra Pradesh has been more than evident in reported incidents of farmers’ suicides and hunger deaths. The incidence of indebtedness, particularly among small and marginal farming households in the state, is the highest in India. By passively encouraging microfinance institutions to expand without limits in a policy and institutional vacuum, the state had created the conditions for a crisis. This is the time for finding out the pros and cons of completely trusting a credit-based poverty reduction strategy to the neglect of more critical structural and institutional solutions.
6. Microfinance: A Fairy Tale Turns into a Nightmare- M S Sriram
It was inevitable that the commercial model of microfinance in India, with its minimalist and standardized model of lending, would grow into a bubble and run into trouble. Many microfinance commercial organizations have entered the market in search of profits and are competing to lend to the poor. In the process they have put the “understanding” of the needs of the poor aside and have started chasing targets and numbers. For these institutions, the poor are not seen as human beings having individual identities and needs. Instead they are seen as data points that add up in their profit statements. The anxiety for growth is dictated by the fact that the investors in the market-based models are impatient and look for high returns – and then exit!
7. ‘Modern’ Sahukars
The institution of the sahukar has been thriving in its modern avatar – as for-profit microfinance.
The state government has reacted by issuing an ordinance to regulate and monitor the functioning of microfinance institutions (MFIs), prompting the Microfinance Institutions Network (MFIN) to challenge the law in court. Are the MFIs what they claim to be – agents of “empowerment” of the poor? Or, are they “modern” sahukars/mahajans?
Indeed, the declared mission of microfinance companies is to “empower” the poor, especially women, by providing access to collateral- free loans for their micro-businesses – in agriculture, livestock, trade (e g, vegetable vending), proto-industry (e g, basket weaving and pottery), services (like beauty parlors), and so on.
The National Bank for Agriculture and Rural Development (NABARD) and the Reserve Bank of India (RBI) had been promoting microfinance through the self-help group (SHG)-bank linkage route.
However, the problem is that the business model of SKS Microfinance and its like is not viable because it undermines the creditworthiness of the client. Neoliberals have a radically different perspective on viability and they may well be right. After all, starryeyed, we are looking at the microfinance business from the perspective of its social mission. But then, from the vantage point of the for-profit “players” on the supply side.
· Sustainability of MFIs: The interest rates charged by MFIs are a matter of concern. It has been noted that MFIs charge high rates of interest to attain sustainability and pass on the higher cost of credit to their clients who are “interest insensitive” for small loans. This may not be true when loan sizes increase. It is, therefore, necessary for MFIs to develop strategies for increasing the range and volume of their financial services to attain sustainability while charging reasonable rates of interest to cover costs and risks.
· Lack of Capital: Another area of concern is that MFIs, which are on the growth path, face paucity of owned funds as a critical constraint for scaling up. Many of them are socially-oriented institutions and thereby have little access to financial capital. As a result, they have high debt equity ratios. The Microfinance Development Fund, set up with NABARD, has been augmented and re-designated as the Microfinance Development Equity Fund (MFDF) for meeting the equity needs of MFIs.
· Borrowings: In comparison with earlier years, MFIs now find it relatively easier to raise loan funds from banks. This change has come after 2000, when the RBI allowed banks to lend to MFIs and treat such lending as part of their priority sector-funding obligations. Private sector banks have since designed innovative products (such as the bank partnership model of the ICICI Bank) to fund MFIs and have also started viewing the sector as a sound business proposition. Banks need to work on finding the right systems to assess the risk of funding to MFIs. They would also do well to improve their capability of appraising such MFIs and assessing their credit needs. Appropriate credit rating of MFIs will help in increasing the comfort levels of the banking system for bulk landings. It may be of interest to note that NABARD has a grant-based scheme under which 100% of the cost of the initial rating of MFI will be borne by it.
· Capacity Building of MFIs: It is now widely recognized that widening and deepening the outreach of the poor through MFIs has both social and commercial dimensions. As the sustainability of microfinance institutions and their clients complement each other, it follows that building up the capacities of MFIs and their primary stakeholders are necessary pre-conditions to the successful delivery of flexible client responses and innovative microfinance services to the poor.
Microfinance: Recommendations for Success
Working within the logic of maximizing investor returns , strategic focus of Indian MFIs seems to have shifted from serving the investor returns, strategic focus of the Indian MFIs seems to have shifted from serving the poor borrowers to chasing profits . The commercial transformation of MFIs has been accompanied by changes in the structure of ownership, management and nature of their stalk holder commitment.
Currently the Micro Finance sector in India stands clearly divided into three segments:
· Slow growing, informal community based.
· Moderately growing not for profit
· Fast growing, regulated and commercial.
First of all, microfinance donors should focus their support on (and encourage) MFIs who operate in countries who are making consistent efforts to improve regulation, institutions, and legal systems. If governments of developing countries are looking to lead their countries out of poverty, perhaps this might create incentives for governments to increase transparency and regulatory systems.
Secondly, MFIs need to rethink their target recipients. This is a more difficult way of handling microfinance. Yes, at first glance it may seem unfair to stop lending to poorest people who need it the most, but at a closer look it becomes clear that these people are not benefiting from their loans long term, or making business ventures that are sustainable. The more well off, who can still benefit from a microcredit loan to expand their business, buy more equipment, and employ more people, should be the main recipients of loans. These types of enterprises have the capacity for self-sustainability and revenues. Businesses under this category include (but is not limited to) those that have steady markets, some kind of office to operate out of, and room for expansion. More formal sector businesses such as these will create more growth and development than loans to informal sector businesses will.
Thirdly, using microfinance to increase access to public goods is an innovative and new way of improving quality of life for people. For instance, MFIs could offer low interest rates on village loans that will be used to build a well or a small school. While these loans would be larger and probably riskier, the condition of group lending makes it feasible. Arrangements could be made for urban districts interested in public good improvements. Default would cause the village or district to forego monies for future improvements. With this incentive, members of the group are keen on monitoring their fellow members and ensuring that everyone involved makes their repayments. While, such projects would certainly be more complicated than basic microfinance loans, perhaps that is the key to paving the way toward growth.
Within the existing legal framework and institutional structures, there are several operational issues that could be addressed through the coordinated efforts of the Central government , state governments, regulators, banks and NABARD . The RBI has an interest in pursuing the subject as part of its thrust towards financial inclusion . as the Micro credit approach yields place to a more encompassing micro- finance approach , coordinating mechanisms amongst financial sector regulators and institutional regulators have to be considered.
Training and capacity building is high priority area which coupled with the widespread use of technology could reduce transaction costs and improve overall effectiveness while imparting robustness to the movement.
In conclusion it is necessary to recognize that we in India have to focus on extending financial services to both rural and urban areas to ensure the financial inclusion of all segments of the population.
At the same time one should avoid the temptation of creating one set of banking and financial institutions to cater to the poor or the unrecognized, and another for the rest.
# Economic & Political Weekly EPW August 9, 2008
# Economic & Political Weekly EPW June 12, 2010 vol xlv no 24
# Economic & Political Weekly EPW February 5, 2011 vol xlvi no 6
# October 23, 2010 vol xlv no 43 EPW Economic 10 & Political Weekly
# Economic & Political Weekly EPW october 23, 2010 vol xlv no 43
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Circular NHB (ND)/DRS/POL.16/2006 dated September 5, 2006 advised Housing Finance Companies (HFCs) to formulate suitable Fair Practices Code with the approval of their Board. The Guidelines have been amended vide Circular NHB/ND/DRS/Pol-No.34/2010-11 dated October 11, 2010 to bring more clarity & transparency and to cover all aspects of loan sanctioning, disbursal and repayment issues. The Guidelines have been discussed ...
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