27
Jul

Contrasting the Regulatory Landscape for Credit Bureaus in India, USA and Australia

By Vineeth Maddi, IFMR Finance Foundation

In this post we have put together an infograph below that highlights some of the aspects pertaining to credit bureau regulatory landscape in India, USA and Australia.

CB_Info

  1. https://www.rbi.org.in/Scripts/BS_PressReleaseDisplay.aspx?prid=14576
  2. https://www.consumer.ftc.gov/articles/pdf-0111-fair-credit-reporting-act.pdf
  3. https://www.legislation.gov.au/Details/C2016C00278/Download
  4. http://www.alrc.gov.au/publications/53.%20Credit%20Reporting%20Provisions/content-credit-information-files
  5. http://www.alrc.gov.au/publications/53.%20Credit%20Reporting%20Provisions/content-credit-information-files#_ftnref40
  6. Insurance companies use credit information to determine premium
  7. Currently being used for postpaid connections, http://www.livemint.com/Money/DAIkDVGe3G5hnFx0V40dSP/How-the-others-interpret-your-credit-score-report.html
  8. https://rbidocs.rbi.org.in/rdocs/Content/PDFs/69700.pdf
  9. https://www.oaic.gov.au/individuals/privacy-fact-sheets/credit-reporting/privacy-fact-sheet-29-who-can-access-your-credit-report
  10. https://rbidocs.rbi.org.in/rdocs/Content/PDFs/69700.pdf
  11. https://www.oaic.gov.au/individuals/privacy-fact-sheets/credit-reporting/privacy-fact-sheet-36-when-will-the-information-on-your-credit-report-be-deleted
  12. Section 18, CIC Act 2005
  13. http://www.alrc.gov.au/publications/59.%20Access%20and%20Correction%2C%20Complaint%20Handling%20and%20Penalties/complaint-handling
  14. http://economictimes.indiatimes.com/wealth/borrow/cibil-may-soon-give-one-free-credit-report-a-year/articleshow/53263370.cms
  15. Section 612 of FCRA 1970
  16. http://www.creditsmart.org.au/getting-free-credit-report

20
Jul

Reorienting Financial Well-being through FWR 2.0

fwr_img_1

By Dhivya S, IFMR Rural Finance

For an institution focussed on delivering high-quality and customised financial services to low-income households, the Wealth Management approach has been the one of the key underlying layers that is core to the KGFS Model. The sole objective of the approach is to maximise the financial well-being of households by offering tailor-made and suitable recommendations to them. Financial well-being, in this case, is to help customer households achieve financial goals, as per their priorities, in a secured and sustainable manner.

We have always believed that this approach of understanding the inherent composition and risks of rural households to help create their financial road-map requires a deep level of expertise. This approach of wealth management proves to be very different from the traditional approach of providing a full suite of products to customers and ask them to choose based on their financial needs. In this context, IFMR Rural Finance (IRF) first designed a Financial Well-being Report (FWR) five years ago to meaningfully engage with the bottom of the pyramid clientele.

The FWR is an automated customer-centric financial planning tool that uses customer data and back-end algorithms to make specific and actionable financial recommendations to enrolled rural households. The concept of devising wealth management conversations with customers takes us to the basic premise that there is a customer touch point that is primarily driven by the front-end staff called Wealth Managers. Wealth Managers across all KGFS branches rely on the FWR report as a guide to provide suitable financial advice aimed at enabling customers to realize their financial goals. To better understand the household, comprehensive data collection process by way of enrolments is undertaken, capturing data on the household’s members, demographics, cash-flows and financial goals. Post on-boarding the customer, a complete cash-flow analysis and risk assessment of the household is done to determine the customer’s financial position. While the data collection process forms the building block; the crux of wealth management however rests with capturing the financial goals of households. This is a continuous process of engagement with the customers that gets refined with subsequent conversations and financial transactions at the KGFS.

FWR in its current version has evolved over the years through a process of continuous improvement. However, there are several substantial improvements that need to undergo in order to make it even more customer-centric. Through anecdotal experiences and client interactions, we realised that wealth management isn’t simply about making financial plans for one’s future but is a means of realising one’s priorities. It is in this process, we realised that the process of customer engagement needs to be improved across various components as a precursor to having quality wealth management conversations. These conversations with customer focus on helping them achieve their financial goals by identifying and prioritizing what is most important to them. This then becomes imperative for us to make the entire process simple, intuitive and easy for both the Wealth Managers as well as the customers to achieve its full potential.

This post explains the perspective on the approach, methodology and design of FWR 2.0 and seeks feedback on improving the tool.

In the latest version of the FWR 2.0, the report aims to build on the legacy of the earlier system and is intended to be a significant leap towards delving much deeper into the financial lives of households. FWR 2.0 is engineered with concepts of Human Centered Design (HCD) to offer more practical and actionable insights keeping the customer interests at its core. The key areas of development that we plan to include in its redesign are:

1) Strengthening the data collection process to ensure high quality inputs from customers to have an in-depth understanding of their financial lives – Data collection is a fundamental process whose quality in turn determines the quality of financial advice given to the customer. For instance, if the Wealth Managers at KGFS are unaware of the customers’ high social expenses or if they have borrowed through informal channels or they are just a few thousands short of cash to achieve their goal; the Wealth Managers would not be able to provide appropriate recommendations which may have an adverse effect on the household’s financial lifecycle.

The scope of FWR 2.0 seeks to bridge the lacunae created through the development of various prototypes of a smart tool and associated processes. The aim is to identify the best technique of asking questions to customers during enrolment in a way that they are able to relate the most. We also plan to design a data quality score to explicitly measure the quality of data captured. This would be one of the key constituents to make sure that the entire wealth management process is based on sound first-principles.

2) Process redesign for achieving customer goals – Greater emphasis would be laid upon the quality of engagement with customers to enable them to reflect on their financial situation, identify and prioritize their individual & household goals. Assuming the data collected is of good quality, there are other important factors impacting the conversation that are to be rethought of. Some of the immediate alterations thought of are related to articulation of goals and logistics of organising wealth management conversations – for instance, should we have these conversations at home or at the branch; should we use laptops or just record customer stories and so on.

3) Better customer connect and usability through intuitive services – In regards to redesigning inclusive and progressive wealth management process, the aim is also to enhance the interface for mobiles and tablets through responsive web design and effective visualisation. The revamp would entail interface and visual improvements that are intuitive enough for the Wealth Managers to have meaningful conversations with customers.

We plan to finalise the above stated areas by creating various contending prototypes that aim to fulfil the stated objectives of FWR 2.0. These sets of prototypes would be tested in KGFS branches with existing and potential customers.  The revamp would entail conceptual, process and system related modifications that would be intuitive enough for both the staff and customers to equally participate in wealth management conversations. We are also scoping through the feasibility of creating a customer version of Financial Well-being Report that can be offered to the customer at the end of every conversation.

FWR 2.0 would not only aid in augmenting KGFS business performance and minimising business related risks due to improper or erroneous recommendation, but most importantly, would lead to an even more improved and meaningful customer engagement and retention.

14
Jul

Thinking about Micro-insurance Penetration and Entrenchment

Guest post by Renuka Sane

Background

Insurance contracts to lower income households (micro-insurance) are typically for one year. This implies that when the contract expires, the household needs to renew the purchase for the next year. It is intuitively appealing to consider that micro-insurance is truly an effective means of smoothing consumption when households continuously renew their contract. The question arises: do households choose to repurchase micro-insurance and enjoy continued cover? In Sane and Thomas (2016), From participation to repurchase: Low income households and micro-insurance, we evaluate this question for life and accident micro-insurance, along with what drives the repurchase. We also ask how long it takes customers to repurchase once the policy has expired. We especially focus on two such drivers: access to credit and wealth.

Data

We use data from the IFMR Rural Channels and Services Private Limited (IRCS) which implements the Kshetriya Gramin Financial Services (KGFS) branch-based model of distributing financial products across India. KGFS branches distribute two insurance products: the term life (TLI) which covers mortality risk, and the personal accident insurance (PAI) which covers mortality risk or permanent disability risk of customers arising due to accident. The data includes demographic and wealth information for 132,000 micro-insurance customers whose first policy expired between March 2011 and March 2014. The data also includes information about micro-credit contracts between KGFS and these customers prior to the purchase of the micro-insurance. To this dataset we add rainfall data gathered for the relevant districts and time periods, to indicate if the policy expired in a period when rainfall was scanty, versus when rainfall was normal.

Findings

We find that 65 percent of the sample renewed their insurance policy at least once, after their first policy expire. Five characteristics stand out:

First, there is a large difference in re-purchase probability (almost 33 percent) between the group with a micro-finance (Joint Liability Group) loan before the original purchase of the insurance policy, compared to those without a JLG loan. What could be the reasons?

When we examined the date of insurance repurchase and the take-up of a JLG loan, we find that 17 percent of those who renew insurance have taken a new JLG loan within 7 days of the insurance purchase, and another 18 percent have taken a new loan within 14 days of the insurance purchase. This suggests that while some part of the loan may be used to pay the insurance premium, it does not appear to be an over-whelming driver for the purchase, at least for two-thirds of those who renewed insurance.

A popular voiced perception is that life or accident insurance acts to protect the credit payments in case the borrower dies or suffers a debilitating injury. In this case however, most lenders would waive repayment of loans in the event of death of the debtor, giving customers little reason to purchase insurance to ensure repayment. Further, the insurance producer has nothing to gain from the point of view of repayment. There is little incentive for either intermediary to push the insurance product only to loan clients.

However, a common financial intermediary for credit and insurance may be important in other ways. Since credit and insurance are offered in the same branch, a higher demand for credit may translate into higher repurchase of insurance as customers visit the branch more frequently, and get more exposed to other financial products, and are perhaps able to build trust about the financial service provider.

Finally, there could be unobserved differences between those who have chosen to take a JLG loan and those who have not. It could be these differences that are driving the result, except that we are unable to test for this in the present data-set.

A second feature is that when the policy expires in months with scanty rainfall, the repurchase probability reduces by almost 7 percent. This is statistically significant at 1 percent. It suggests that collecting premiums during a lean period (caused by poor rainfall) restricts the ability to pay premiums.

The third feature is that repurchase probability rises with assets, but falls for those in the highest asset quartiles. This suggests that individuals only consider the purchase of insurance when they do not have enough buffer stock wealth. Households primarily demand life insurance when they lack accumulated reserves, or wealth, for self-insurance.

A fourth feature is that the largest number of repurchases occur within the first one to two months of expiry. Repurchases then continue to fall further after 12 months. This implies that if an insurance customer does not repurchase her policy within 12 months of expiry, she is unlikely to do so after. This helps to guide policy on improving insurance uptake: the first few months are the right time for an intervention to improve repurchases.

The fifth feature is that only 28 percent of those who repurchase the policy, increase the amount of cover purchased. We also find that 47 percent of those who increased their cover had gone from having one policy (accident cover, for example) to purchasing both policies (accident and term life cover).

Conclusion

Improving insurance participation of low-income households has become an important objective in the access to finance movement. The market for micro-insurance products will mature once people continuously purchase these products, and also make decisions on the sum assured purchased. Our research on understanding repurchases can provide inputs to the design of government programs as well as private sector initiatives. This is also the start of what we hope is an exciting research agenda on the drivers of sustained participation in micro-insurance.

References:

Sane and Thomas (2016), From participation to repurchase: Low income households and micro-insurance, FRG WP. http://ifrogs.org/releases/SaneThomas2016_microInsurance.html

5
Jul

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

Guest post by Liliana Rojas-Suarez, Center for Global Development

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.

30
Jun

A Comparison of Capital requirements for Microfinance and Housing Finance Institutions

By Nishanth K & Deepti George, IFMR Finance Foundation

In this post, we attempt to compare the regulatory landscape for NBFC-MFIs and Housing Finance Companies (HFC) within the broader context of the regulatory landscape for niche credit intermediaries.

Financial Institutions are required to hold regulatory capital to protect retail depositors from unexpected losses they may incur in the course of their business. This takes the form of capital adequacy ratio or the ratio of capital held by an institution to its risk-exposure which is measured by its risk-weighted assets. Among other capital requirements[1], the Reserve Bank of India (RBI) prescribes a minimum capital of 9% of risk-weighted assets[2] for banks. However, commercial banks have maintained levels of capital adequacy (13% as on September 2015[3]) that are higher than the regulatory requirements. Specific categories of NBFCs are typically required to meet higher capital adequacy ratios (CRAR), but are otherwise not prescribed any regulatory requirement. Systemically important NBFCs (with asset size of Rs. 500 crore or more) as well as NBFC-MFIs are required to have a CRAR of 15%. The below table (Table 1) gives the capital adequacy requirements for various types of financial institutions:

Institutions Minimum CRAR (%) Minimum Tier-1 CRAR (%)

Minimum Leverage ratio

(%)

As of Now As of March-2016 As of March-2017
Banks 9 7 (and a max. of 2% Tier-2 CRAR) 4.5
NBFC-D 15 7.5 8.5 10
NBFC-ND-SI 15 7.5 8.5 10
NBFC-MFI 15 Should be greater than or equal to Tier-2 CRAR 7
IFC 15 10
Gold Loan -NBFC 15 12 12 12 7
Non SI, NBFC-ND 7
HFC 12 Should be greater than or equal to Tier-2 CRAR

As you can see from Table 1, regulatory capital requirements are different for the various classes of financial institutions. What would be the basis for such differences? This could be because of the differences in risks that these institutions face as well as risks they pose to the real economy in the event of a crisis. A typical NBFC-MFI offers small ticket, unsecured loans to lower income borrowers. Although, banks too take exposure to such borrowers, the concentration of unsecured lending to relatively unknown customers with little or no credit information and high exposure to socio-political risk is considerably higher for instance in NBFC-MFI books. Credit ratings for NBFC-MFIs have continued to factor in risks associated with unsecured lending, socio-political intervention, geographic concentration and operational risks related to cash-based transactions and as a result called for the need to keep higher capital cushions for these entities.

HFCs offer three products: Housing loans, home improvement loans and Loans against Property, all of which are secured assets. In addition, some HFCs are also allowed to accept public deposits[4]. They are regulated by the National Housing Bank[5] (NHB), an apex development finance institution for housing. With the objective of promoting housing finance institutions, it provides financial and other support incidental to such institutions. While there are several players in the housing finance space, such as scheduled commercial banks, HFCs, other NBFCs, regional rural banks, cooperative banks, agriculture and rural development banks, and state level apex cooperative housing societies, the housing loan market is dominated by SCBs and HFCs.

HFCs have lower capital adequacy requirements in comparison to NBFC-MFIs: Although NBFC-MFIs and HFCs deal with completely different asset classes and are regulated by different entities (RBI and NHB respectively), they are both specialized financial institutions providing niche financial services (predominantly credit intermediation) and are of relatively similar sizes. However, the regulatory capital requirements for these institutions are quite different. HFCs enjoy relatively low risk weights (50%-100%) for home loans and commercial real estate loans for residential projects[6], besides lower CRAR of 12% compared to NBFC-MFIs which provide small ticket unsecured short-term loans to low income individuals (risk weighting of 100% for assets originated, CRAR of 15%).

Capital Adequacy Ratio maintained by HFCs[7]
CRAR 2015 2014 2013 2012
Median of HFCs 18% 17% 17% 15%
Small HFCs 11% 12% 13% 13%
Median of Small HFCs 15% 17% 17% 15%
Large HFCs 12% 12% 13% 13%
Median of Large HFCs 18% 17% 18% 15%
All HFCs 11% 12% 13% 13%

Source: Report, Indian Mortgage Finance Market Updated for 2014-15, ICRA[8] 


Capital Adequacy Ratio of NBFC-MFIs[9]
CRAR[10] 2015 2014 2013 2012 2011
Small MFIs 30% 44% 44% 50% 40%
Medium MFIs 20% 24% 29% 29% 30%
Large MFIs 18% 19% 21% 26% 29%
All MFIs 23% 30% 33% 33% 32%

This is interesting when capital adequacy requirements for these two institutional types are seen against their Expected Loss (EL) and Unexpected Loss numbers[11] calculated using the assumption that recovery rates for HFCs and NBFC-MFIs are 50% and 0% respectively.

Expected Loss (EL) Unexpected Loss (UL)
HFC[12] 0.95%

0.44% (at 50% recovery rate)

0.88% (at 0% recovery rate)

NBFC-MFI[13] 0.74% 0.87% (at 0% recovery rate)


MFIs have higher volatility in their PAR numbers, and this is consistent with their higher capital adequacy requirements.

HFCs have much better access to refinancing schemes: HFCs are accessing more diversified sources of funding, such as borrowings from the market in the form of non-convertible debentures and commercial paper, loans from banks and other institutions, and fixed deposits[14] for some of the large HFCs. However, smaller HFCs with lower or no access to public deposits depend considerably on refinance schemes offered by NHB – NHB refinance formed 23% of the total funding for small HFCs in 2015.

  All HFCs[15] Small HFCs
2015 2014 2013 2015 2014 2013
NCDs and Commercial Paper 52% 48% 49% 30% 27% 27%
Banks 26% 30% 27% 37% 38% 35%
Fixed Deposits 17% 16% 17% 10% 8% 7%
NHB Refinance[16] 4% 4% 4% 23% 20% 19%
Others 1% 3% 2% 9% 7% 3%

In comparison, the majority of funds for NBFC-MFIs came from borrowings from banks and other financial institutions besides equity capital. In 2014-15, NBFC-MFIs (which are a part of MFIN) received a total of Rs. 276.82 billion in debt funding[17] from Banks, which accounts for about 78% of the funding that NBFC-MFIs have access to.

Debt Funding Profile of NBFC-MFIs[18]
Total MFIs Small MFIs(GLP^<Rs 1bn) Medium MFIs(1bn<GLP<5bn) Large MFIs(GLP>Rs 5bn)
2015 2014 2013 2015 2014 2013 2015 2014 2013 2015 2014 2013
Banks 77.90% 79.29% 85.27% 37.75% 42.45% 52.61% 54.77% 63.93% 70.20% 82.39% 82.49%

 

87.71%

 

Other FIs 22.10% 20.71% 14.78% 62.25% 47.55% 47.39% 45.23% 36.07% 29.80% 17.61% 17.51% 12.29%

^GLP – Gross Loan Portfolio

Often, the differences in capital requirements for HFCs and NBFC-MFIs are explained by the inherent differences in the nature of the asset. However, we contest this view as the allocation of risk weights for the calculation of capital adequacy should take into consideration the credit risk associated with the different asset classes. Also, it is interesting to note that HFCs face much higher maturity and liquidity mismatches, a risk that is much easier to control for NBFC-MFIs given their short-term lending profiles.



[1] Master Circular-Prudential Norms for Capital Adequacy, July 2015, RBI
[2] This is higher than the minimum CRAR requirement of 8% suggested by the Basel Committee for Banking Supervision
[3] Financial Stability Report, May 2015, RBI.
[4] As of March 2015, there are 64 Housing finance Companies registered with the NHB out of which only 18 are allowed to take public deposits.
[5] NHB is a wholly owned subsidiary of RBI set up under the National Housing Bank Act, 1987
[6] http://www.nhb.org.in/Regulation/HFC(NHB)-Directions-(As-modified-upto-1st-July-2013).pdf
[7] ICRA defines Large HFCs to include HDFC, LIC HF, Dewan Housing finance limited and Indiabulls Housing finance limited. Small HFCs are HFCs other than the above mentioned.
[8] ICRA report, Performance Review of Housing Finance Companies and Industry Outlook, multiple years
[9] Source: MFIN – the MicroScape, FY2014-15
[10] Proxied by Capital/Total assets ratio. We make this approximation given that microfinance loans have a risk weight of 100%
[11] A rough estimate using methodology as covered in ”An approach to risk-pricing of loans” by Chakrabarti, Ahmed, Mullick
[12] EL: Average of GNPA ratio (PAR 90) for 2005 to 2015; Housing Finance Companies and the Indian Mortgage Finance Market, ICRA Rating Feature, various years. UL: Calculated at 50% recovery rate, at 99% confidence level
[13] EL: Average PAR 90 figures for non-AP MFIs, for 2011 to 2015; MFIN Micrometer, various years. UL: Calculated at 0% recovery rate, at 99% confidence level
[14] Not all HFCs are allowed to take public deposits. The list of those that can is given here
[15] ICRA report, Performance Review of Housing Finance Companies and Industry Outlook
[16] http://www.nhb.org.in/Financial/HFC-Booklet-of-All-Refinance-Schemes.pdf
[17] Micrometer, May 2015, MFIN Publications.
[18] Micrometer, May 2015, MFIN Publications