Earlier this month, guidelines for the Swachh Bharat Mission (Gramin) were released by the Ministry of Drinking Water and Sanitation.  Key features of the Swachh Bharat Mission (Gramin), as outlined in the guidelines, are detailed below.  In addition, a brief overview of sanitation levels in the country is provided, along with major schemes of the central government to improve rural sanitation. The Swachh Bharat Mission, launched in October 2014, consists of two sub-missions – the Swachh Bharat Mission (Gramin) (SBM-G), which will be implemented in rural areas, and the Swachh Bharat Mission (Urban), which will be implemented in urban areas.  SBM-G seeks to eliminate open defecation in rural areas by 2019 through improving access to sanitation.  It also seeks to generate awareness to motivate communities to adopt sustainable sanitation practices, and encourage the use of appropriate technologies for sanitation. I. Context Data from the last three Census’, in Table 1, shows that while there has been some improvement in the number of households with toilets; this number remains low in the country, especially in rural areas. Table 1:  Percentage of households with toilets (national)

Year Rural Urban Total
1991 9% 64% 24%
2001 22% 74% 36%
2011 31% 81% 47%

In addition, there is significant variation across states in terms of availability of household toilets in rural areas, as shown in Table 2.  Table 2 also shows the change in percentage of rural households with toilets from 2001 to 2011.  It is evident that the pace of this change has varied across states over the decade. Table 2: Percentage of rural households with toilets

State

2001

2011

% Change

Andhra Pradesh

18

32

14

Arunachal Pradesh

47

53

5

Assam

60

60

0

Bihar

14

18

4

Chhattisgarh

5

15

9

Goa

48

71

23

Gujarat

22

33

11

Haryana

29

56

27

Himachal Pradesh

28

67

39

Jammu and Kashmir

42

39

-3

Jharkhand

7

8

1

Karnataka

17

28

11

Kerala

81

93

12

Madhya Pradesh

9

13

4

Maharashtra

18

38

20

Manipur

78

86

9

Meghalaya

40

54

14

Mizoram

80

85

5

Nagaland

65

69

5

Odisha

8

14

6

Punjab

41

70

30

Rajasthan

15

20

5

Sikkim

59

84

25

Tamil Nadu

14

23

9

Tripura

78

82

4

Uttar Pradesh

19

22

3

Uttarakhand

32

54

23

West Bengal

27

47

20

All India

22

31

9

II. Major schemes of the central government to improve rural sanitation The central government has been implementing schemes to improve access to sanitation in rural areas from the Ist Five Year Plan (1951-56) onwards.  Major schemes of the central government dealing with rural sanitation are outlined below.

Central Rural Sanitation Programme (1986): The Central Rural Sanitation Programme was one of the first schemes of the central government which focussed solely on rural sanitation.  The programme sought to construct household toilets, construct sanitary complexes for women, establish sanitary marts, and ensure solid and liquid waste management.
Total Sanitation Campaign (1999): The Total Sanitation Campaign was launched in 1999 with a greater focus on Information, Education and Communication (IEC) activities in order to make the creation of sanitation facilities demand driven rather than supply driven. Key components of the Total Sanitation Campaign included: (i) financial assistance to rural families below the poverty line for the construction of household toilets, (ii) construction of community sanitary complexes, (iii) construction of toilets in government schools and aganwadis, (iv) funds for IEC activities, (v) assistance to rural sanitary marts, and (vi) solid and liquid waste management.
Nirmal Bharat Abhiyan (2012): In 2012, the Total Sanitation Campaign was replaced by the Nirmal Bharat Abhiyan (NBA), which also focused on the previous elements.  According to the Ministry of Drinking Water and Sanitation, the key shifts in NBA were: (i) a greater focus on coverage for the whole community instead of a focus on individual houses, (ii) the inclusion of certain households which were above the poverty line, and (iii) more funds for IEC activities, with 15% of funds at the district level earmarked for IEC.
Swachh Bharat Mission (Gramin) (2014): Earlier this year, in October, NBA was replaced by Swachh Bharat Mission (Gramin) (SBM-G) which is a sub-mission under Swachh Bharat Mission.  SBM-G also includes the key components of the earlier sanitation schemes such as the funding for the construction of individual household toilets, construction of community sanitary complexes, waste management, and IEC. Key features of SBM-G, and major departures from earlier sanitation schemes, are outlined in the next section.

III. Guidelines for Swachh Bharat Mission (Gramin) The guidelines for SBM-G, released earlier this month, outline the strategy to be adopted for its implementation, funding, and monitoring. Objectives: Key objectives of SBM-G include: (i) improving the quality of life in rural areas through promoting cleanliness and eliminating open defecation by 2019, (ii) motivating communities and panchayati raj institutions to adopt sustainable sanitation practices, (iii) encouraging appropriate technologies for sustainable sanitation, and (iv) developing community managed solid and liquid waste management systems. Institutional framework: While NBA had a four tier implementation mechanism at the state, district, village, and block level, an additional tier has been added for SBM-G, at the national level.  Thus, the implementation mechanisms at the five levels will consist of: (i) National Swachh Bharat Mission (Gramin), (ii) State Swachh Bharat Mission (Gramin), (iii) District Swachh Bharat Mission (Gramin), (iv) Block Programme Management Unit, and (v) Gram Panchayat/Village and Water Sanitation Committee.  At the Gram Panchayat level, Swachhta Doots may be hired to assist with activities such as identification of beneficiaries, IEC, and maintenance of records. Planning: As was done under NBA, each state must prepare an Annual State Implementation Plan.  Gram Panchayats must prepare implementation plans, which will be consolidated into Block Implementation Plans.  These Block Implementation Plans will further be consolidated into District Implementation Plans.  Finally, District Implementation Plans will be consolidated in a State Implementation Plan by the State Swachh Bharat Mission (Gramin). A Plan Approval Committee in Ministry of Drinking Water and Sanitation will review the State Implementation Plans.  The final State Implementation Plan will be prepared by states based on the allocation of funds, and then approved by National Scheme Sanctioning Committee of the Ministry. Funding: Funding for SBM-G will be through budgetary allocations of the central and state governments, the Swachh Bharat Kosh, and multilateral agencies.  The Swachh Bharat Kosh has been established to collect funds from non-governmental sources.  Table 3, below, details the fund sharing pattern for SBM-G between the central and state government, as provided for in the SBM-G guidelines. Table 3: Funding for SBM-G across components

Component Centre State Beneficiary Amount as a % of SBM-G outlay
IEC, start-up activities, etc 75% 25% - 8%
Revolving fund 80% 20% - Up to 5%
Construction of household toilets 75%(Rs 9000)90% for J&K, NE states, special category states 25%(Rs 3000)10% for J&K, NE states, special category states -- Amount required for full coverage
Community sanitary complexes 60% 30% 10% Amount required for full coverage
Solid/Liquid Waste Management 75% 25% - Amount required within limits permitted
Administrative charges 75% 25% - Up to 2% of the project cost

One of the changes from NBA, in terms of funding, is that funds for IEC will be up to 8% of the total outlay under SBM-G, as opposed to up to 15% (calculated at the district level) under NBA.  Secondly, the amount provided for the construction of household toilets has increased from Rs 10,000 to Rs 12,000.  Thirdly, while earlier funding for household toilets was partly through NBA and partly though the Mahatma Gandhi National Rural Employment Guarantee Scheme (MGNREGS), the provision for MGNREGS funding has been done away with under SBM-G.  This implies that the central government’s share will be met entirely through SBM-G. Implementation: The key components of the implementation of SBM-G will include: (i) start up activities including preparation of state plans, (ii) IEC activities, (iii) capacity building of functionaries, (iv) construction of household toilets, (v) construction of community sanitary complexes, (vi) a revolving fund at the district level to assist Self Help Groups and others in providing cheap finance to their members (vii) funds for rural sanitary marts, where materials for the construction of toilets, etc., may be purchased, and (viii) funds for solid and liquid waste management. Under SBM-G, construction of toilets in government schools and aganwadis will be done by the Ministry of Human Resource Development and Ministry of Women and Child Development, respectively.  Previously, the Ministry of Drinking Water and Sanitation was responsible for this. Monitoring: Swachh Bharat Missions (Gramin) at the national, state, and district levels will each have monitoring units.  Annual monitoring will be done at the national level by third party independent agencies.  In addition, concurrent monitoring will be done, ideally at the community level, through the use of Information and Communications Technology. More information on SBM-G is available in the SBM-G guidelines, here.  

Last month, Reserve Bank of India (RBI) released the report of the Expert Committee on Urban Co-operative Banks (Chair: Mr. N. S. Vishwanathan).  In this blog, we discuss some broader issues with the functioning and regulation of urban co-operative banks (UCBs), and some of the suggestions to address these as highlighted by the committee in its report.

Need for Urban Co-operative Banks

The history of UCBs in India can be traced to the 19th century when such societies were set up drawing inspiration from the success of the co-operative movement in Britain and the co-operative credit movement in Germany.  Urban co-operative credit societies, were organised on a community basis to meet the consumption-oriented credit needs of their members.  UCBs are primary cooperative banks in urban and semi-urban areas.  They are co-operative societies that undertake banking business.  Co-operative banks accept deposits from the public and lend to their members.  Co-operative banks are different from other co-operatives as they mobilise resources for lending and investment from the wider public rather than only their members.

Concerns regarding the professionalism of urban cooperative banks gave rise to the view that they should be better regulated.  Large cooperative banks with paid-up share capital and reserves of one lakh rupees were brought under the scope of the Banking Regulation Act, 1949 with effect from March 1, 1966.  Prior to this, such banks were regulated under the scope of state-specific cooperative laws.  The revised framework brought them under the ambit of supervision of the RBI.  Till 1996, these banks could lend money only for non-agricultural purposes.  However, this distinction does not apply today.  

The Expert Committee noted that UCBs play a key role in financial inclusion.  It further observed that the focus area for UCBs has traditionally been communities and localities including workplace groups.  They play an important role in the delivery of last-mile credit, even more so for those sections of the population who are not integrated into the mainstream banking framework.  UCBs primarily lend to wage earners, small entrepreneurs, and businesses in urban and semi-urban areas.  UCBs can be more responsive than formal banking channels to the needs of the local people.

Over the years, concerns have been raised about non-professional management in UCBs and that this can lead to weaker governance and risk management in these entities.  RBI has also taken regulatory action on several UCBs.  For instance, in September 2019, RBI placed Punjab and Maharashtra Co-operative Bank under restrictions on allegations of serious underreporting of non-performing assets.  The bank could not grant loans, make investments or accept deposits without prior approval from RBI.  While these restrictions were originally put in place for six months, the time frame was extended several times and has now been extended till December 31, 2021.  In addition, low capital base, poor credit management and diversion of funds have also been issues in the sector.

Shrinking share in the banking sector

There were 1,539 UCBs in the country as of March 31, 2020, with deposits worth Rs 5,01,180 crore and advances worth Rs 3,05,370 crore.   Even though 94% of the entities in the banking sector were UCBs their market share in the banking sector has been low and declining and stands at around 3%.  UCBs accounted for 3.24% of the deposits and 2.69% of the advances in the banking sector.  The Committee noted that state-of-the-art technology adopted by new players, such as small finance banks and fintech entities, along with commercial banks can disrupt the niche customer segment of the UCBs.

Figure 1:  Growth in deposits of UCBs (in Rs crore)
  image

Source: Report of the Expert Committee on Urban Co-operative Banks; PRS.

Figure 2:     Growth in advances of UCBs (in Rs crore)
 
image

Source:  Report of the Expert Committee on Urban Co-operative Banks; PRS.

Burden of non-performing assets

UCBs had the highest net non-performing asset (NNPA) ratio (5.26%) and gross non-performing asset (GNPA) ratio (10.96%) across the banking sector as of March 2020.  These levels correspond to around twice that of private sector banks, and around five times that of small finance banks.  The Committee noted that, as of March 2020, UCBs have the lowest level of net interest margin (difference between interest earned and interest spent relative to total interest generating assets held by the bank) and negative return on assets and return on equity. 

Figure 3: Asset quality across banks (in percentage)

image
 
Sources:   Report of the Expert Committee on Urban Co-operative Banks; PRS.

Supervisory Action Framework (SAF):  SAF envisages corrective action by UCB and/or supervisory action by RBI on breach of financial thresholds related to asset quality, profitability and level of capital as measured by Capital to Risk-weighted Asset Ratio (CRAR).  The Committee recommended that SAF should consider only asset quality (based on net non-performing asset ratio) and CRAR with an emphasis on reducing the time spent by a UCB under SAF.  The RBI should begin the mandatory resolution process including reconstruction or compulsory merger as soon as a UCB reaches the third stage under SAF (CRAR less than 4.5% and/or net non-performing asset ratio above 12%).

Constraints in raising capital

The Committee also observed that UCBs are constrained in raising capital which restricts their ability to expand the business.  According to co-operative principles, share capital is to be issued and refunded only at face value.  Thus, investment in UCBs is less attractive as it does not lead to an increase in its value.   Also, the principle of one member, one vote means that an interested investor cannot acquire a controlling stake in UCBs.  It was earlier recommended that UCBs should be allowed to issue fresh capital at a premium based on the net worth of the entity at the end of the preceding year.

Listing of securities:  The Committee recommended making suitable amendments to the Banking Regulation Act, 1949 to enable RBI to notify certain securities issued by any co-operative bank or class of co-operative banks to be covered under the Securities Contracts (Regulation) Act, 1956 and the Securities and Exchange Board of India Act, 1992.  This will enable their listing and trading on a recognised stock exchange.   Until such amendments are made, the Committee recommended that banks can be allowed to have a system on their websites to buy/sell securities at book value subject to the condition that the bank should ensure that the prospective buyer is eligible to be admitted as a member.   

Conflict between Banking Regulation Act, 1949 and co-operative laws 

The fundamental difference between banking companies and co-operative banks is in the voting rights of shareholders.  In banking companies, each share has a corresponding vote.  But in the case of co-operative banks, each shareholder has only one vote irrespective of the number of shares held.  Despite RBI being the regulator of the banking sector, the regulation of co-operative banks by RBI was restricted to functions related directly to banking.  This gave rise to dual regulation with governance, audit, and winding-up related functions regulated by state governments and central government for single-state banks and multi-state banks, respectively.  

2020 Amendments to the Banking Regulation Act: In September 2020, the Banking Regulation Act, 1949 was amended to increase RBI’s powers  over the regulation of co-operative banks including qualifications of management of these banks and supersession of board of directors.  The Committee noted that due to the amendment of the Act, certain conflicts have arisen with various co-operative laws.  For instance, the Act allows co-operative banks to issue shares at a premium, but it is silent on their redemption.  It noted that if any co-operative societies’ legislation provides for redemption of shares only at par, then, while a co-operative bank incorporated under that legislation can issue shares at a premium, it can redeem them only at par.   

Note that on September 3, 2021, the Madhya Pradesh High Court stayed a circular released by the RBI on appointment of managing director/whole-time director in UCBs.  The circular provided for eligibility and propriety criteria for the appointment of such personnel in UCBs.  The petitioner, Mahanagar Nagrik Sahakari Bank Maryadit, argued that the service conditions of the managing director and chief executive officer of co-operative banks are governed by bye-laws framed under the M.P. State Cooperative Societies Act, 1960.  The petition noted that co-operative as a subject falls under the state list and hence the power to legislate in the field of co-operative societies falls under the domain of the states and not the central government.


Umbrella Organisation

Over the years, several committees have looked at the feasibility to set up an Umbrella Organisation (UO) for UCBs.  It is an apex body of federating UCBs.  In 2011, an expert committee on licensing of new UCBs recommended that there should be two separate UOs for the sector.  In June 2019, RBI granted an in-principle approval to National Federation of Urban Co-operative Banks and Credit Societies Ltd to set up a UO in the form of a non-deposit taking non-banking finance company.  The UO is expected to provide information technology and financial support to its federating members along with value-added services linked to treasury, foreign exchange and international remittances.   It is envisaged to provide scale through network to smaller UCBs.  The report of the current Committee recommended that the minimum capital of the UO should be Rs 300 crore.  Once stabilised, the UO can explore the possibility of becoming a universal bank.  It can also take up the role of a self-regulatory organisation for its member UCBs.  The Committee also suggested that the membership of the UO can be opened-up to both financial and non-financial co-operatives who can make contributions through share capital in the UO.

Comments on the report of the Expert Committee are invited until September 30, 2021.