How Do India’s Payments Banks Measure Against Key Principles for Financial Inclusion?

Only about half of Indian adults have access to an account of any kind. The number is even lower for the poorest 40 percent (World Bank, Global Findex 2014). Furthermore, there are only 13 commercial bank branches per 100,000 adults (IMF, Financial Access Survey 2014). Keeping in mind the low levels of financial inclusion in the country, the Indian authorities have developed a broad strategy to improve access to financial services, as outlined in the report by the Committee on Comprehensive Financial Services for Small Business and Low Income Households, led by Nachiket Mor. Among the committee’s recommendations, payments banks are one innovative tool to further India’s goal of greater financial inclusion.

Payments banks are different from regular banks. They can only accept deposits up to Rs. 1 lakh per person, roughly $1500, and cannot grant loans. Furthermore, payments banks can only invest their money in safe government securities and other highly liquid assets. Their primary objective is to further financial inclusion by providing access to small savings, payments and remittance services to low-income customers without compromising financial stability. By leveraging technology and tapping into their large networks, these banks might potentially allow millions more people, many in remote corners of India, to operate bank accounts, with often very small sums of money. In August 2015, the Reserve Bank of India (RBI) granted “in-principle” licenses to eleven entities to launch payments banks.

While it is too early to assess results, as these banks are not operational yet, a valid question is whether the regulations governing these payments banks are consistent with fundamental regulatory principles for improving financial inclusion while protecting financial stability and integrity. To answer this question, I compare key characteristics of the payments banks against major recommendations in the recently released report, Financial Regulations for Improving Financial Inclusion, by the Center for Global Development (CGD), a Washington-based think tank. Prepared by a high-level Task Force, the report advances three major recommendations (among others) for expanding financial inclusion in a safe and sound manner:

• Encourage competition by allowing new and qualified providers to enter the market
• Create a level playing field between different providers by making the regulatory burden proportional to the risk posed by providers to individual customers and the overall stability of the financial system
• Apply risk-proportionate Know-Your-Customer (KYC) rules to balance financial integrity and financial inclusion

How do India’s payments banks measure against these recommendations?

Enhancing Competition Among Providers of Financial Services

Payments banks certainly encourage the entry of new, qualified and innovative players. The entities licensed to become payments banks encompass a broad range of sectors, including telecommunications, finance and banking, IT, and postal services. The first payments bank is expected to be operational by the end of this financial year.

The licensing of payments banks is contingent upon various players meeting the appropriate entry criteria. The approved entities need to have a solid track record and ability to conform to the highest standards of service. More details about the licensing process can be found here. A thorough regulatory and licensing regime is crucial for financial stability. After all, India’s experience with expanding rural banks in 1976 without a proper regulatory framework ended in huge losses in 1991. India’s clear licensing requirements for payments banks are consistent with the CGD report’s recommendation to encourage entry of a wide variety of qualified providers of financial services. Of course, given the restrictions on payment banks’ activities, the implications of “fit and proper” are quite different for these banks compared to traditional banks.

Leveling the Playing Field Between Providers of Financial Services

Since payments banks do not undertake credit risk, the RBI has stipulated a minimum capital requirement of Rs. 100 crore ($15 Mn) for payments banks (among other requirements), unlike traditional banks that must meet a capital requirement of Rs. 500 crore ($75 Mn). As these payments banks assume lower risk, it only makes sense that they have to carry a lower regulatory burden.

However, if the entities licensed to become payments banks wish to expand their activities beyond those allowed for payments banks, they would need to be licensed to become full-service banks. Similarly, if the payments bank reaches a net worth of Rs. 500 crore and becomes critical to the stability of the financial system, diversified ownership will be mandatory within three years. Such a risk-based approach is essential to ensure a balance between fostering innovative financial services and ensuring the safety and soundness of the financial system, as recommended in the CGD report.

Applying Know-Your-Customer (KYC) Rules

India has already encouraged improvement in financial access as well as up-take of national ID (Aadhaar) by allowing people to open restricted bank accounts subject to later showing proof of identity. These restricted bank accounts have limits on balances and activities. Similarly, simplified KYC requirements would be applied to “small accounts” transactions through payments banks. Payments banks are expected to encourage the expansion of these types of “small accounts” through their extensive networks. Furthermore, Aadhaar will play a key role in facilitating the take-up of “small accounts” with simplified risk-based KYC processes, as recommended in the CGD report.

While there is no one-size-fits-all solution to improve financial inclusion, there are important lessons to be learned from India’s step to approve payments banks. After India’s previous experiments with different efforts to improve financial inclusion, payments banks offer one promising way towards better financial access. India’s forward-looking vision to leverage digital finance combined with innovation-friendly regulations could pave way for a bright and safe future for payments banks.