Banking
Banking
Banking
By making these debt instruments available in the markets, the organization manages to
make their assets liquid and can then use the funds for some other productive business.
When an investor buys these debt instruments, the investor is given a PTC. However, this
does not mean that the investor owns the assets. Rather, when the original lender recovers
money from the original borrower (as interest or otherwise), it is then passed on to the SPV,
which then disburses it to the investor in the form of fixed income.
Slide 4
Banks and NBFCs were forming pacts to pursue new markets well before the introduction of
CLM. Previously, RBI had released a notification on 21st Sept 2018 titled ‘Co-origination of
loans by Banks and NBFCs for lending to priority sector‘ highlighting rules and regulations
for the parties involved in co-lending.
On 5th Nov 2020, RBI released another notification titled ‘Co-Lending by Banks and NBFCs
to Priority Sector‘ that served as a revision to the 2018 directions.
Under this new version, all NBFCs (including HFCs) can enter co-lending pacts with partner
banks. RBI mandated that some bank categories under Scheduled Commercial Banks (SCBs)
cannot enter co-lending pacts with NBFCs. These banks include:
Regional Rural Banks (RRBs)
Small Finance Banks (SFBs)
Urban Co-operative Banks (UCBs)
Local Areas Banks (LABs)
Slide 5
Benefits
Benefits for Banks and NBFCs
Better Risk Management
NBFCs are in a position to manage and spot risk much better compared to large banks.
NBFCs and HFCs are more adept at assessing the creditworthiness of niche customer
segments, which are usually not the core target group of banks. With a more structured
approach, local focus and specialised skill set, they can evaluate credit applications better
and reduce the risk exposure for themselves and banks.
A modern Loan Management System can help tackle challenges like proportionate
sharing of risks and rewards, especially when an NBFC has multiple co-lending partners.
Increased Reach of the Lending Ecosystem
Co-origination is based on the symbiotic association between NBFCs and banks. Public
Sector Banks (PSBs) in India have access to the most affordable source of funds in the
economy, and banks release 80% of the credit, which reduces the overall cost of funds.
NBFCs can benefit from this and offer loans to their customers at lower rates vis-a-vis their
competitors.
PSBs stand to gain from a partnership with NBFCs and fintechs as it enhances their last-mile
reach. Instead of a one NBFC one bank contract, co-lending can be imagined as an open
digital marketplace in the future. The co-lending framework will enable smooth and faster
credit flow to SMEs, with NBFCs acting as the last mile link.
Efficiency In Operations
With the use of automation and decision-making tools, co-lending allows lenders to have
higher margins by processing more applications and disbursing more loans in a shorter
span. The deployment of Artificial intelligence can help FIs analyse customer patterns and
predict default probability, helping them make faster and more data-backed decisions.
Prevents Systemic Liability
Banks and NBFCs can manage capital efficiently and decrease their liability through co-
lending. They can scale their operations by finding lending partners with a good product-
market fit. To ensure no negative impact on the profit and loss statement, the on-balance
sheet spread that is lesser than or at most equivalent to the off-balance sheet spread can
prevent any negative impact on the profit and loss statement.
As co-lending is a collaboration between banks and NBFCs, both partners focus on increased
compliance and maintain it, thus preventing system liability.
Slide 9 – Outsourcing or DA
Whether the bank will provide an irrevocable commitment to take over a loan originated by
NBFC?
This looks like NBFC is carrying out the outsourcing function on behalf of the bank or it can
be said that bank has outsourced its function to NBFC.
The conclusion one gets from the above is as follows:
The essence of co-lending arrangement is that the participating bank relies upon the lead
role played by the originating bank. The originating bank is the one playing the fronting role,
with customer interface. The credit screens, of course, are pre-agreed and it will naturally be
incumbent upon the originating bank to abide by those. Hence, on a case by case basis or so-
called “cherry picking” basis, the participating bank is not selecting or dis-selecting loans. If
that is what is being done, the transaction amounts to a DA. Subject to the above, the
participating bank is expected to have its credit appraisal process still on.
Where it finds deviations from the same, the participating bank may still decline to take its
share. It is important to note that if DA comes into play, the requirements such as MHP,
MRR, true sale conditions will also have to be complied with.
However, co-lending transactions do not have any MHP requirements, unlike in case of
either DA or securitiastion. Of course co-lending transactions do have a risk retention
stipulation, as the CLM require a 20% minimum share with the originating NBFC. Hence,
the intent of the RBI is that co lending mechanism must not turn out to be a regulatory
arbitrage to carry out what is virtually a DA, through the CLM.