2. The stress tests conducted by RBI are very primitive. Anyways They are no silver bullet either. Banks passing stress tests have failed in eu. The rigor is no where close to what we see in us or uk/eu. That stems primarily from lack of data and controls. No stress test can capture control failure in cases like mallaya or nimo, and effect capture would be inadequate coz of poor data and crude models. You're spot on for contagion. That's why RBIs push back on dividend and PCA.
The RBI has autonomy to implement proper stress testing norms - the inability to do so is entirely theirs. There's no political interference preventing them from stress testing banks, is there ? RBI has come up short on several measures here, including their management of banks auditing processes, the SWIFT process management that was central to the Nirav Modi case, and stress testing norms. It's odd of them to claim lack of autonomy without demonstrating ability.
The RBI has autonomy to implement proper stress testing norms - the inability to do so is entirely theirs. There's no political interference preventing them from stress testing banks, is there ?
Basic Hygiene:
1. Given the level of derailing of thread and its asymptotic approach towards political threads on GDF, I am intentionally ignoring the political dimension
2. Please let me know if this discussion on ST needs to be continued in banking thread. Given that Suraj sir is mod and is engaging here, I think this is fine for now.
3. There is some confusion in Suraj and my previous posts between central bank's role as a supervisor and its role as a monetary policy setter/executor. I will focus on first and not the second.
4. Unless clarified, please assume it for PSB only
Coming to RBI's competence. Based on my discussion with guys who had indirect roles in designing stress test in FinMin & RBI and in FRB NY (all three different persons at different times). They spoke the same point in diff words, "Dont shoot the survivors". In terms of ST(Stress Tests) they meant that the banks are not mature to have a mature guidance. They do not have sufficient/adequate data, infrastructure and resources to undertake this exercise. So the seemingly incapability of RBIs is intentional.
Yes they should ask banks to get the areas I mentioned. But it would also mean significant costs along with attrition of tenured resources due to increasingly tech heavy demands from role. All this would mean investments by capital starved banks, increase in execution costs and also increase in short term frauds/credit/market losses. The approach chosen, like most things in India, is evolutionary. You may not like it but thats the "paradigm" or doctrine in our indian banking sector.
With regards to the ST, I was fine with the way RBI started, but the evolution is at a glacial pace, if at all. As for RBI guidance, it has not been updated since 2013 end. I would have expected them to at least publish a roadmap towards a horizontal stress testing and increasing sophistication. However, as of today, they cann't go advanced, because a failure of most banks in ST can unnecessarily create panic in capital markets, in addition to challenges I mentioned above. For this IMHO, we should follow the the non disclosure way similar to CAMEL ratings days. Nevertheless things should move forward and should now. What I hear is that everyone is so busy cutting trees that they dont have time to sharpen the axe.
Bringing specific details on gaps for stress testing.
1. The data systems for Indian banks is still in a primitive stage. They can't drill down from aggregate exposures to a granular level. Systems don't support efficient analytical slicing and dicing of data, what to speak of modeling or early warning. This is inexplicable since CBS was almost done by 2005 and Basel II started in 2007. Historical data is so effed up. Linkages across products for same customer are inaccurate. People are so busy in adhaar enrolling but they dont realize its power in this aspect. People haven't even woken up to Big data
2. Even with poor data, robust reporting and monitoring through open eyes can detect issues earlier than any quant model or ML technique. I do not see even that happening at a granular level
3. Indian banks have bureaucratic rules for hiring consultants and employees (no surprise) and are fiefdom for Big 4 audit (alternating between audit and consulting) +Big 2-3 consulting. The same PO type exam formats coupled with low pay and hassles result in "chalta hai". Things did start to change but they are still not able to higher reasonable talent laterally. This is sad, because there is no dearth of talent in India in the field of Risk. All major global FIs have at least some analytics being done out of India, some almost fully. Even Pvt banks are at par with global ones. ICICI, HDFC and Axis lead the pack.
Long story short, Public sector bankers did not see value in any of it. Did US return RRR/VA did anything material on it well not that I am aware of. Could they have done more yes, but there are always bigger fires to douse, within a single bank, what to speak of a central bank, in such a political charged environment.
RBI has come up short on several measures here, including their management of banks auditing processes, the SWIFT process management that was central to the Nirav Modi case, and stress testing norms. It's odd of them to claim lack of autonomy without demonstrating ability.
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For failures on ST i have already answered.
For bank Audit, Yes that is what I found shocking too, Failed lending could have been at political behest or can be blamed at branch employees' collusion or sheer negligence. But not Auditing is inexplicable, IIRC all bank branches have to be audited annually. Even if the audit involves taking auditors to good hotels good restaurants to avoid getting an adverse comment. But the auditors have to at least turn up. The reason I hold them less guilty than others is because, RBI forms the zeroth line (while setting the policies) and the 4th line of defense (while reviewing the execution/review by remaining three: Business, Risk and Audit). They can set the policies and procedures but to validate their actual implementation. Majority of reliance is through Internal/external auditors or validators rather than the central bank. Even the US banks and regulators were found woefully short in 2007-09 period. In the end, the first responsibility is of bank management, then internal risk unit, Internal/external auditors. Ratings agencies, while not directly responsible. If these can't find the gap in execution very unlikely a central regulator can find a gap. What were the shareholders, board of directors (GoI and their nominees) doing , when they know LoUs or foreign branches were resulting in high losses. There are segment level reportings also required as per IFRS. Why was the audit report with adverse findings not paid attention to by shareholders. These are more pertinent questions.
That said, there is no excuse on earth for not auditing a top 5 bank for 9-10 years and that does not absolve RBI. Those responsible should at least face consequences. but in order of priority probably the last, after the banker & the statutory Auditors. Even then RBI asking for more authority is not unjustified. Taking global example, after 07-09 recession, all bankers were found lacking. That didn't mean their autonomy/responsibilities were cut. In fact it was opposite, despite of OTS being shunted, FRB assumed much more powers through Dodd Frank. Same was true everywhere.
We also have to keep in mind that this govt has kept RBI very busy in bringing inflation down, Demo and NPA assessment. With the level and number of resources, I am not displeased with what RBI and Finmin have accomplished.
PS: My friend in FinMin & RBI were in know of happenings. You can treat them as the anonymous sources of DDM.