We have tried to effect inclusion in the past through mandateswhether it be through direction on branch opening or on lending to priority sectors. That we are still far short of our goals has led some critics to suggest we should abandon mandates because the market will take care of needs; If the poor have demand for financial services, the critics say, providers will emerge to supply it. Markets do respond to need, and competition is a very healthy force for improvement, but market functioning can be impeded by poor infrastructure, uneven regulation, natural or regulatory monopolies, and even cartelisation.
While enlisting competitive forces wherever possible to compete for the bottom of the pyramids business, as a development central bank we also need to offer a supportive hand. We have to encourage the development of the products, institutions, and networks that will foster inclusion.
Let us start with products. We have been trying for decades to expand credit. We have focused much less on easing payments and remittances or on expanding remunerative savings vehicles or on providing easy-to-understand insurance against emergencies. We should try to expand financial inclusion by encouraging these other products, and allow credit to follow them rather than lead. Indeed, many successful organisations working with the poorest of the poor try to get them to put aside some money as savings before giving them loans. Some of our self-help groups (SHGs) work on this principle. Not only does the savings habit, once inculcated, allow the customer to handle the burden of repayment better, it may also lead to better credit allocation. With the power of information technology, perhaps the analysis of the savings and payment patterns of a client can indicate which one of them is ready to use credit well.
One roadblock to access, even to something as simple as a universal
basic savings account, is Know Your Customer (KYC) requirements. Experts have emphasised the need to make it far simpler to open basic accounts, and have suggested minimising the required documentation. The Nachiket Mor Committee recommends requiring proof of only a permanent address. This is nevertheless more onerous than current RBI norms, which allow an applicant to self-certify her address and other details for accounts below R50,000. But despite RBIs exhortations, few banks have reduced their demand for documentation. The acceptance of third party KYC certification is particularly difficult.
Today, stringent KYC norms keep too many out of the banking system, and lead to unnecessary harassment for others. Banks may adopt these norms more because of regulatory or legal liability than to safeguard against true criminal or terrorist activity. Cant we do better Some bankers suggest that by monitoring activity patterns in accounts carefully, even while putting some limits on basic accounts, much of the suspicious activity can be detected and stopped. Could we allow a commercial bank some regulatory dispensation in case there is minor mischief in some low value accounts, provided the bank has a reliable system in place to detect greater mischief Could the gains in easing widespread access to safe accounts outweigh the costs of minor fraud How can we get entities within the system to rely on each others KYC, without the process having to be continuously repeated How can technology assist in effectively addressing the above issues These are questions we have to examine and address.
The broader issue is whether through sophisticated state-of-the-art technology, we can offer customers products that are simple, low-cost, and easy to use. We have done this with mobile phones, can we do it with banking Payments may be another obvious product. The payments infrastructure in India is very advanced. We have three large RBI technology centres devoted to supporting payments. For large value transactions, we have a state-of-the-art Real Time Gross Settlement System (RTGS). In the National Electronic Funds Transfer (NEFT) system, our flagship retail funds transfer system, we have near-real time transaction processingwe continuously send messages to banks even though net settlement takes place at hourly intervals. We also send a positive confirmation to the remitter after the funds have been credited to the beneficiarys account.
We have introduced an additional factor of authentication for all e-commerce transactions, and are swiftly moving to Chip and PIN technology for credit card transactions. SMS alerts for bank and credit card transactions are a welcome advance relative to even the United States. All this means that we have the infrastructure to provide cheap and safe payments and remittances. What we need are non-governmental players to utilise this infrastructure to provide the products and access that people want.
A lot is already happening. Real-time funds transfer through the Immediate Payment Service (IMPS) put in place by NPCI has contributed significantly towards growth of mobile banking. The Aadhaar Payment Bridge System (APBS) allows government benefits to be transferred through the use of unique identification number given to the citizens. But we are still not where we should be either on mobile payments or on direct benefit transfers.
With over 900 million mobile phones, the potential for mobile banking as a delivery channel for financial services is a big opportunity in India. We have consciously adopted the bank-led model for mobile banking, while the non-banks, including Mobile Network
Operators, have been permitted to issue mobile wallets, where cash withdrawal is not permitted as of now. The key to cheap and universal payments and remittances will be if we can find a safe way to allow funds to be freely transferred between bank accounts and mobile wallets, as well as cashed out of mobile wallets, through a much larger and ubiquitous network of business correspondents. The Nachiket Mor Committee suggests the creation of Payment Banks as a step towards this goal. Other suggestions include interoperable business correspondents who will get the scale economies to serve in remote locations, and the usage of NBFCs as banking correspondents. We will examine all this.
In the meantime, interesting solutions are emerging. Cashing out is important for remittances, because we have a large recipient population in the country, most of whom do not have access to formal banking services. We have recently approved the in-principle setting up of a payment system which will facilitate the funds transfer from bank account holders to those without accounts through ATMs. Essentially, the sender can have the money withdrawn from his account through an ATM transaction. The intermediary processes the payment, and sends a code to the recipient on his mobile that allows him to withdraw the money from any nearby banks ATM. The system will take care of necessary safeguards of customer identification, transaction validation, velocity checks, etc. We need more such innovative products, some of which mobile companies are providing.
Finally, let me turn to consumer literacy and protection. As we reach more and more of the population, we have to be sure that they understand the products they are being sold and have the information to make sensible decisions. Caveat emptor or let the buyer beware is typically the standard used in financial marketsthat is, so long as the buyer is not actively misled, she is responsible for researching her product choices and making purchase decisions. While this puts a lot of burden on the buyer to do due diligence, it also gives her a lot of freedom to make choices, including of course the freedom to make bad choices.
But with poorly informed and unsophisticated investors, we should consider the Nachiket Mor Committees recommendation of setting some guidelines on what products are suitable for different categories of investors. The more complicated the product the more sophisticated should be the target customer. Should we move to a norm where a suite of simple products is pre-approved for dissemination to all, but as products get more complicated, financial sector providers bear more and more responsibility to show that the buyer was sophisticated and/or appropriately counselled before she purchased
The longer run answer is for customers to become more savvy. Can the technology sector help educate people in financial matters After all, finance is not something most people learn in schools, but it is something they encounter every day in the world. Low cost but high quality distance finance education is something the country very much needs.
One caveat. Technology can magnify the reach of finance for bad purposes as well as good. Many of you must receive frequent emails, purportedly from me, informing you of a large sum of money that awaits you at RBI, and urging you to send me your account details so that I can transfer the money to you. Let me assure you that RBI does not give out money, I do not send these emails, and if you do fall for such emails, you will lose a lot of money to crooks and be reminded of the adageif anything looks too good to be true, it probably is not true.
Of course, technology can also offer answers to check fraud. Can we enlist social media in enabling the public to identify fraud and help regulation How can we do this in a responsible way Again, these are questions at this point, but I am sure we will find the answers.
Technology, with its capacity to reduce transaction costs, is key to enabling the large volume low ticket transaction that is at the centre of financial inclusion. By collecting and processing large volumes of data easily, technology can also improve the quality of financial decision making. When products have network effects, technology can ensure not just interoperability but also security.
Excerpted from Rajan's address at the NASSCOM India Leadership Forum in Mumbai on February 12
Rajan is the Governor, Reserve Bank of India