The Reserve Bank of India (RBI) has introduced a Prompt Corrective Action (PCA) framework to improve the condition of weak Urban Cooperative Banks (UCBs). 

Reasons for replacing Supervisory Action Framework (SAF)

• More Flexibility: The PCA framework allows for more tailored actions based on the specific problems of each bank, unlike the SAF which had a one-size-fits-all approach.
• Focus on Larger Banks: The new system will pay more attention to larger UCBs, which need closer supervision.
• Simpler System: The PCA framework is less complicated than the SAF, making it easier to understand and implement.
• Alignment with Other Banks: The PCA framework is similar to the systems used for regular commercial banks and other financial institutions, creating a more consistent approach.
• Effective Monitoring: The RBI believes the PCA framework will help identify problem banks sooner and take quicker action to fix them.

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About PCA Framework

PCA stands for Prompt corrective action. It is a system imposed by the RBI on banks in case of financial stress. This framework will replace the existing Supervisory Action Framework (SAF).

• It will be effective from April 1, 2025.

Key Features of the PCA Framework

• Applicability: The PCA framework is for UCBs with deposits above Rs 100 crore.
• Categorization of UCBs:
  • Tier 1: UCBs with deposits up to Rs 100 crore.
  • Tier 2: UCBs with deposits above Rs 100 crore and less than Rs 1,000 crore.
  • Tier 3: UCBs with deposits above Rs 1,000 crore and less than Rs 10,000 crore.
  • Tier 4: UCBs with deposits above Rs 10,000 crore.
• Exclusion of Tier 1 UCBs: Tier 1 UCBs are not included in the PCA framework but will continue to be closely monitored.

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Norms for Invoking the PCA Framework

The RBI will put a UCB under the PCA framework if it meets any of the following conditions:

• Low Capital: The bank’s capital adequacy ratio (CAR) is up to 250 basis points below the required level.
• High Bad Loans: The bank has a high percentage of bad loans (non-performing assets or NPAs) between 6% and 9%.
• Consecutive Losses: The bank has incurred losses for two years in a row.
• Breach of Risk Thresholds: Any breach of these risk thresholds may result in PCA invocation.

What Happens When RBI Puts a Bank under PCA?

When RBI puts a bank under PCA, it imposes restrictions and offers guidelines to help improve the overall financial health of the bank. 

• Mandatory Restrictions: 
  • Branch Expansion: The Bank cannot open new branches. 
  • Dividend payment: It is restricted from paying dividend to its shareholders. 
  • Remuneration of Director: Limits are imposed on how much remuneration to be paid to directors. 
• Discretionary  Actions by RBI 
  • Business model review: The bank’s board can be asked to review and reassess their business model and operations to ensure profitability of the business. 
  • Plans and Strategy of Business: The RBI may advise banks to replan and re-evaluate its strategies for making changes in the management. 
  • Resolution plan: The bank board will have to create a resolution plan subject to RBI approval to address financial issues. 
  • Hiring Restrictions: Banks might face restrictions in hiring new employees.
  • Capital expenditure: The banks would be confined to  spend money on upgradation of technology within pre-approved limits. 

Monitoring and Implementation

• Supervisory Focus: The framework focuses more on larger UCBs needing intensive monitoring.
• Annual Financial Results: Banks will be placed under PCA based on reported and audited annual financial results and ongoing supervisory assessments.
• Flexibility: The framework allows for tailored supervisory action plans based on specific risks for each entity.
• Capital Expenditure Restrictions: The previous hard limit of Rs 25,000 on capital expenditure under SAF is removed, allowing supervisors to set limits based on their assessment.

Benefits of the New Framework for Urban Cooperative Banks

• Stronger Oversight of Larger Banks

  • Focused Attention: The framework targets larger UCBs (Tier 2, 3, and 4) with significant deposits.
  • Better Resource Allocation: The RBI can efficiently use its supervisory resources by focusing on higher-risk banks.

• Early Warning System

  • Proactive Action: The framework detects banks with potential issues early by monitoring financial health indicators like capital, bad loans, and profits.
  • Preventive Measures: Early detection allows the RBI to intervene and improve the bank’s condition before problems escalate.

• Flexible Approach

  • Tailored Solutions: The RBI can design specific improvement plans for each bank based on its unique challenges.
  • Reduced Rigid Rules: The new framework offers the RBI more flexibility in deciding how to assist struggling banks compared to the old system.

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• Improved Bank Health

  • Stronger Capital Position: Banks are encouraged to maintain better capital levels to avoid falling under the framework.
  • Reduced Bad Loans: Emphasis on reducing bad loans will encourage banks to recover overdue loans and lend more responsibly.
  • Profitability: Banks will strive to become profitable to avoid being flagged under the framework.

The new framework aims to strengthen the banking system by identifying and addressing issues in urban cooperative banks early on, ensuring the safety of depositors’ money.

Challenges of the PCA Framework for Urban Cooperative Banks (UCBs)

• Identifying Weak UCBs

  • Subjective Criteria: Determining which banks are “weak” based on capital adequacy, bad loans (NPAs), and consecutive losses can be subjective and might not capture all risks.
  • Delayed Response: Triggering PCA after two consecutive years of losses could result in delayed intervention.

• Implementation Issues

  • Supervisory Resources: Effective implementation of PCA requires sufficient supervisory resources, which might be challenging, especially for smaller UCBs.
  • Data Accuracy: Reliable and timely financial data is essential for assessing bank health, and data quality issues in UCBs could hinder effective PCA application.
  • Flexibility: While the framework allows for case-by-case assessments, it might still be too rigid in some situations, limiting tailored interventions.

• Impact on UCBs

  • Reputation Damage: Being placed under PCA can harm a bank’s reputation and reduce customer confidence.
  • Business Limitations: Restrictions on capital expenditure and other limits under PCA can impede a bank’s growth and development.
  • Exit Difficulty: The stringent criteria for exiting PCA might make it hard for banks to recover and improve.

• Overall Effectiveness

• • Focus on Larger UCBs: Although the framework prioritizes larger UCBs, it is crucial to ensure that smaller UCBs with potential risks are not neglected.

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