Session 1

Commercial Banking

Banking Regulation Act 1949

Section 5(c) :
A banking company is a company which transacts the business of banking in
India

Section 5 (b) :
Banking means accepting , for the purpose of lending or investment , of
deposits of money from the public, repayable on demand or otherwise , and
withdrawable, by cheque, draft,order or otherwise

1.

Maintaining deposit accounts

2.

Issue & Pay Cheques

3.

Collect cheques for the banks customers

Payments
Traditional
Options (Cheques,
DD)
Modern ( Wire
transfers, ECS)

Financial
Intermediation

Financial
Services

Take deposits
Lend
Address safety and
liquidity, growth
needs

Forex
Wealth Mgmt
Insurance
Investment
Banking

First known banks : Ancient Temples

Safe Places : Gold, agricultural tools & implements

Various Factors : Historical crusades shaped the methods &practices

Greeks: Used credit notes

Egyptians : Used Grains

Romans : Coins

Years : 1100-1300
Large trade volumes in agricultural commodities, cloth, leather .Trade combines
became powerful since specialization brought with it need for more investment

1786

18091843

1921

General Bank of India

Estb in Kolkatta

3 Presidency Banks established

Banks of : Bengal, Bombay, Madras

3 Presidency Banks amalgamated
Imperial Bank of India European control.

1865

Allahabad Bank
Estb purely by Indians

1894

Punjab National Bank

Estb in Lahore

19061913

BOI, CBI, BOB, Can Bank, Indian Bank

established

 RBI established
1935

1949

Banking Companies Act : changed to Banking Reg

Act

19551959

SBI formed
SBI Act passed enabling SBI takeover 8
subsidiaries

 14 banks nationalized
1969
6 more banks nationalized
Objective: Social & rural impetus better control
1980

1990s

Narasimhan Committee Reforms

Entry of new Pvt sector, Foreign banks

Financial
System

Central Banking
Authority

Capital Markets
Regulatory
Authority

Insurance and
Pension
Regulators

RBI

SEBI

IRDA

RBI

IDBI

Small
Industries Dev
Bank of India

NABARD

Exim Bank

National
Housing Bank

RBI
Co-Operative
Banks

Commercial
Banks
Schld

Private
Sector

Public
Sector

Foreign
Banks

Non

State

RRBs

District

Primary Credit

Nationalized
Banks

Soc

SBI &
Assoc

Other PSU

Old Age

New Age

Scheduled Banks : Those listed in 2nd Schedule of RBI Act 1934.Banks need to fulfill Sec 42 (6)(a) to be incld in schedule

PSU Banks:
GOI is the majority stakeholder
27 PSU banks (19 + SBI & 6 subsidiaries)
Have taken a lead role in branch expansion rural areas
SBI : Banker to every Indian

Regional Rural Banks(RRBs):

Established 1976-1987: Develop rural economy.
Jointly owned by Central Govt + State Govt +sponsor PSU
Target customers : Farmers, artisans etc
Decline in numbers : 196 in March 2005 81 as on date.
Examples: Maharashra Gramin Bank, Saptagiri Grameena
Bank

Private Sector Banks

Majority share capital is held by corporates/pvt parties
Banks not nationalized 1969/1980 : Old age-Pvt sector
Post 1992-93 reforms (Narasimhan Committee) entry
permitted
7 New age banks & 15 Old age banks : March 2009
Examples: Yes Bank, Jammu &Kashmir Bank

Foreign Banks:
HO: outside India but operate through branches or rep
offices
As on June 30 2009: 28 foreign banks operating in India.
Target customers : Corporates, HNIs, urban middle class
Examples : Standard Chartered,HSBC

Co-operative Banks:
Governed by Co-operative Societys Act & Banking
Regulation Act.
Eg: Abhudaya Co-Operative Bank, Saraswat Co-Op Bank

Co-Operative Banks:
Comprise of UCBs: operations lmtd across one state or stretch across states
Rural Co-Operative Banks

State Co-Operatives
District Co-Operatives
SCARDBs: State Co-Op Agricultural & Rural Development Banks
PCARDBs : Primary Co-Operative Agricultural & Rural Development Banks

Large Network:
53 scheduled UCBs as per RBI website
30 State Co-Operative Banks

Target customers : Farmers, self employed businessmen/traders

Examples : UCBs Rupee Co-Operative Bank, Cosmos Co-Operative Bank
SCBs: Sikkim State Co-Operative Bank

Harshad Mehta Scam

Approx Rs 4000 Crores

involved
Banking System misused
Small Investors wiped
out

Liberalization of the
Banana Republic

Rajiv Gandhi Govt

Propogates liberalization

Narasimhan
Committee
Recommendations

Banking Sector Reforms

Stage set for major
overhaul

Ready Forward
Txns

Bank Receipts

Borrowing Bank gives securities to the lending bank

in return for funds
Typically was used for short term loans (15 days)
and against govnt securities
Supposed to be used issued against Govt securities
and given by the borrowing bank to the lending
bank
Harshad Mehta :Broker/Fee
Misused the system and involved Bank of Karad
&Metropolitan
Bank:funds
Fake BRs
Fake
BRs usedCo-Op
to borrow
and purchase
shares and drive up prices

Banks
manipulated

BRs repaid by sale proceeds

Once the scam broke banks left with worthless BRs
Small savings wiped out(Approx Rs 4000 crores
involved)

1st Wave: Post nationalization -1969

19th July 1969 Govt nationalized 14 banks

Saraiya Commission appointed to examine the banking system
Recommend ways to make it work with Govts plan of
economic development
Sec 19 of BR Act ammended to allow formation of
subsidiaries.

2nd

Wave: Narasimhan Committee Report #1

Commissioned on August 14, 1991

Set-Up to address the need for the fortification of system
Report #1 submitted on 16th November 1991
Masterprint : First Phase of banking reforms 1992-93
Theme : Operational Flexibility & Functional Autonomy
Country reeling under the aftermath of the Harshad Mehta
scam

Main Recommendations: Glimpse

SLR to be to 25% over a period of 5 years

CRR component to be reduced progressively
No bar to open banks in the private/foreign category
Bifurcation of Banks Investment Portfolio.
Categorization& Provisioning of loan assets

Standard Assets (0.25%)

Sub-Standard (10% of total outstanding)
Doubtful(100%+ 20/30/50%depending upon age
Loss Assets : 100% outstanding

Gradual Approach: RBI-Committees

Banks have expanded their product offerings: Insurance/Wealth Mgmt etc

Lead to a healthy competition: Transformation of some PSU banks (Eg

BOB,SBI)

Encouragement to do something novel:

Refinance of MFI loans
Factoring/Forfaiting

Modern Banking Products : Internet Banking/Mobile Banking

Infusion of Capital into Banks : Capital Adequacy

Type of Bank

1969

2004

2009

Rural Branches
on June 30, 2009

Rural Branches
as % age of all
branches on
June 30,2009

SBI & Assoc

2462

13621

16294

5619

34.4

Nationalize
d Banks

4553

33359

39703

13425

33.8

RRB

14486

15199

11644

76.6

Tot PSU
Banks

7015

61466

71196

30688

43.1

Oth Schld
Comm
Banks

900

5807

8979

1126

12.5

Foreign
Banks

130

218

295

1.4

Non Schld
Comm
Banks

217

32

44

11

25

Grand
Total

8262

67523

80514

31829

39.5

Source:
Economic

Commenced operations on April 1 1935 in Kolkatta.

Constituted to take over activities being performed by the Imperial Bank &
Comptroller of Currency.
Regulate the issue of bank notes
Maintain reserves to secure monetary stability
To operate the credit and currency system efficiently

Served countrys agenda : Rural development I nstitutional

development Bank Supervision &Regulation Financial
Markets

Acts as the currency authority

Controls money supply
Manages foreign exchange
Banker to the Government
Banker to banks
Supervises banks

Holds part of the cash reserves of banks

Provides them with centralized clearing
Safe and economic remittance facilities
Controls licensing, branch expansion, amalgamation etc
Inspection: Seeks information through returns, inspections
/meetings

Intermediaries that compete /complement banks

NBFCs
Mutual Funds
Insurance Companies
Term Lending Institutions

NBFCs:

Compete aggressively for business with banks

Cannot
Accept demand deposits
Issue cheques - not part of the payment system
No deposit insurance cover

Main activities include loans, leasing, hire purchase

NBFCs:

Need to be registered with the RBI.

Set-up : Companies Act 1956

NBFCs registered with other regulators exempted:

Merchant Banking Cos-SEBI
Insurance Company-IRDA
Housing Finance Cos-NHB

NBFCs:

Classified under 3 categories by the RBI

Asset Finance Companies (AFC) : Birla Global Asset Finance
Investment Company (IC) :
Loan Company (LC)

Only NBFCs holding a valid Certificate of Registration

Accept deposits

NBFCs:

Min / Max tenure for Dep Acceptance:12 months / 60 months

Cannot offer > 12.5% p.a current celing.

NBFCs (except certain AFCs- CRAR of 15% +) minimum investment grade rating.

FA- from CRISIL, MA- from ICRA , CARE BBB, FITCH tA-)

NRE/FCNR funds out of bounds (April 2004).Only NRO funds

Default : Law, Company Law Board

Prepayment of Deposits :
Not encouraged
Minimum 3 month lock-in
Possible :Death of Depositor

NBFCs:

Examples :
Deposit Taking :
Mahindra &Mahindra Financial Services-Mumbai
Bajaj Auto Finance Pune
NON Deposit Taking
Citicorp Finance (India)Ltd-Mumbai
IDBI Gilts-Mumbai
SKS Microfinance Ltd-Hyderabad

Insures deposits in all

Commercial banks
Foreign banks functioning in India,
Regional Rural Banks
Cooperative Banks

Maximum of Rs.1,00,000 (Rupees One Lakh) across all

branches
Deposits across different branches of the same bank are
aggregated
Deposits across banks are covered individually.

Deposits have to be held in same capacity.

Sole Proprietorship clubbed with individual account .

Deposit Insurance coverage compulsory

Term Lending Institutions:

Provide loans : Medium to Long Term maturities

Customers : Companies operating in industry, service&
infrastructure sectors
State Level:

SFCs: State Finance Corp

SIDCs: State Industrial Development Corporation
NEDFI : North Eastern Development Financial Institution Ltd

Term Lending Institutions:

All India Level:

EXIM Bank
SIDBI
PFC
IFCI

Typically specialize-catering to specific sectors (Refer

handout)

Central
Board of
Directors

Governor
( Mr D
Subbarao)
Deputy Governor
(Ms Usha Thorat)

Deputy Governor
(Mr S Gokarn)

Deputy Governor
(K.C
Chakrabarty)

Deputy Governor
(Shyamala
Gopinath)

National Housing Bank (NHB)

National Bank for Agriculture & Development (NABARD)

Deposit Insurance & Credit Guarantee Corp (DICGC)

Bharatiya Reserve Bank Note Mudran Pvt Ltd (BRBNMPL)

RBI
Umbrella Acts
*RBI Act:1934
*Banking Reg Act :
1949

Specific Functions
*Indian Coinage Act
*FEMA
*Public Debt Act
*Securities Contract Act
1956

Banking Operations
*Companies Act 1956
*Banking Co (Acq & Transfer
of Undert)
*Bankers Book Evidence
*NI Act 1881

Dept of Currency Mgmt

Urban Banks Dept

Rural Planning &Credit Dept

Foreign Exchange Dept

Financial Supervision

Dept of Banking Supervision

Dept of Non Banking Supervision

Dept of Banking Operations & Development

Dept of IT

Legal Dept

Monetary Policy Dept

Internal Debt Mgmt Dept

Dept of External Investments & Operations

Dept of Govt & Bank Accounts

Dept of Economic Analysis & Policy

Dept of Statistical Analysis & Computer Services

Dept of Payment & Settlement Systems

Funds
mobilization
(Deposits)

Bank
(Financial
Intermediation)

Allocation
(Lending)

Time

Demand

FDs
CDs

Savings A/Cs
Current A/Cs

Demand Deposits:
Payable on demand : Cheque /Cash
No fixed term/lock-ins
Eg: Current/Savings Account

Time Deposits:
Fixed term : Eg Term Deposits

Functions of Various Business Units

Example Raising & Deployment of Funds

Inform BSMG abt
the receipt of funds

Bank Branch

Cust. 1

Cust. 2

Customer approaches bank to

deposit funds in the form of
CA/SA/Term deposits

BSMG
Decides about
funding strategy

Decides about deployment tenure, currency and rate for

fresh lending and asks business
group abt the availability of funds

Sales Team gets in touch with

its clients to deploy the funds

Cust 3
Cust. 1

Cust. 2

Cust 3

Bank Group

2003

2008

2009

PSU Banks

79.6

73.9

76.6

Nationalized

50.8

48.4

49.1

SBI Group

28.8

23.8

24.8

2.2

2.8

Private Sector

15.3

20.3

18.1

Old Pvt Sector

6.7

5.0

4.9

New Pvt Sector

8.5

15.3

13.2

Foreign Banks

5.1

5.8

5.3

Total SCBs

100

100

100

Others

Note : Data as at March

31 2010 (in percent)

RBI License required

Conditions to be satisfied:

Ability to financially service clients

Management
Company Conduct
Capital Structure and Earning Prospects
Impact and justification vis a vis alternates
Public Interest (Foreign Banks)
Compliance with BR Act ( Foreign Banks)
Non discrimination ( Foreign Banks)

KYC:

Involves checking identity :PAN

Sources of income
Location
Rural inclusion : some relaxation

KYC:
Essence is to know the true profile and the genuineness
of the users of the banking channel.

KYC:
Method:
Screening and verifying customers identity

Accepting only genuine customers

Avoid introduction of unaccounted money at all

costs into the banking system

Relaxation in KYC norms

At bank officials discretion

Subject to satisfactory introduction by existing account
holder ( > 6 months old)

Bal in all accounts not to exceed Rs 50K

Total credits in all accounts not to exceed Rs 100000

KYC:
Method:
Screening and verifying customers identity

Accepting only genuine customers

Avoid introduction of unaccounted money at all

costs into the banking system

Designation of a senior officer to monitor risk

compliance
Employee Orientation and training of employees

Avoid

Records to be maintained for cash transactions of Rs 10

Lacs or more in INR or equivalent in foreign currency

Series of cash txns connected to each other of below Rs

10 Lacs or its equivalent in fx within a month and where
the aggregate value exceeds10 Lacs

Cash transactions in forged or counterfeit notes and

suspicious transactions

Property derived from money laundering can be

confiscated(Eg : Satyam )

Records pertaining to money laundering need to be

preserved for a period of 10 years

FIU ( Financial Intelligence Unit) set up to track and

curb such offences

Banks/FIs/Brokers :Report non cash trxs over Rs 1

Crore and cash txns of Rs 10 lacs

Property derived from money laundering can be

confiscated

Records pertaining to money laundering need to be

preserved for a period of 10 years

FIU ( Financial Intelligence Unit) set up to track and

curb such offences

Banks/FIs/Brokers :Report non cash trxs over Rs 1

Crore and cash txns of Rs 10 lacs

Eligibility

Current A/Cs :

Individuals
Firms
HUFs
Societies
Public/Pvt Ltd Companies

Minimum Balance:

Requirements vary from bank to bank

Charges levied for not meeting criteria
No-frills Account: special S/B Account

Account Operation

Mode of Operation
POA
Nomination

Minors Accounts:

Opened under guardianship of parents/legal guardian

Minor : Decide upon attaining majority
Contract with minor : Void ab initio
Under NIA-can bind others except self
Can be admitted to benefits of partnership-can repudiate his
liability within 6 months.

Savings Accounts (3.5% p.a)

Till March 31 2010-calculation on minimum balance between

10th to last date(30/31st)of the month

Effective April 1 interest will be calculated on daily balance

Credited twice a year :31st March / 30th Sepetmber

Dhanalaxmi15%

Axis22%

HDFC24%

SBI-27%

Cup of Cheer!
Percentage of total customer liabilities

Fed
Bank20%

Date

Deposit

Withdrawal

Balance

10th July

50,000

Nil

50,000

18th July

Nil

48,000

2,000

25th July

25,000

Nil

27,000

31st July

Nil

2,000

25,000

Used in the Old Method

Calculation in the Old Method:

Calculation in the New Method

2000*3.5%*1/12=Rs 5.83

a)
b)
c)
d)

50,000*3.5%*1/365=Rs 4.79
2,000*3.5%*1/365= Rs 0.19
27,000*3.5%*1/365= Rs 2.58
25,000*3.5%*1/365= Rs 2.39

Total accrued July Rs = 9.95.

Will be applied = Sept 30
Incremental Gain = Rs 4.1

Minimum tenor: 7 days

Banks free to decide interest rates

Discrimination on rates : Not possible on dep< Rs 15

lacs

Above Rs 15 Lacs : Differential rates ok

Savings Accounts (3.5% p.a)

Till March 31 2010-calculation on minimum balance between

10th to last date(30/31st)of the month

Effective April 1 interest will be calculated on daily balance

Credited twice a year :31st March / 30th Sepetmber

Tool for deposit mobilization

Minimum amount Rs 1 Lac and multiples
Can be issued by scheduled commercial banks except RRBs
and Local Area Banks (LABs)
Issued only in Demat form : Negotiable instrument
No loan possible against CDs
Premature withdrawal : Not allowed
Interest Rate : At bank discretion

Due Diligence Process:

Compliance with KYC guidelines
Involves the bank having adequate knowledge about a
customers :

Identity
occupation
sources of income
address / location

KYC norms have been relaxed to promote financial

inclusion in rural /BPL areas

Minimum Balance :
Usually stipulated as part of terms & conditions of opening
a bank account
No Frills accounts are special savings bank accounts
where no minimum balance reqd
Banks may place restriction on number of withdrawals,
transactions during a period

Satisfactory Conduct :Customer &Bank

Customer should ensure that the account is conducted as per
the banks specifications
Bank should safeguard the customers interest and any
information used for cross selling etc must be with express
consent
Operation of the accounts must be as per mandate specified

Types :

Non-resident Ordinary account (NRO)

Non-resident External account (NRE)
FCNR-B

As per FEMA 1999 an NRI means :

Non-Resident Indian National (i.e Non-resident

holding Indian passport.

Eg: 1) Mr X working in the USA on a Green card.

2) Ms Y deputed to Infosys USA from the Indian office.
Working on a work/business visa.

Persons of Indian Origin ( Non-residents holding

foreign passports)

Eg: 1) Mr X is born in the USA. His parents moved to the USA

from Haryana twenty years ago.

2) Mr Y moved to the USA after his B.Tech. After living there

for nearly 10 years, he applied for and is a naturalized US
citizen .

The definition includes

a)

Indians going abroad for business/work /vocation indicating

an indefinite period of stay.

b)

Indian citizens working abroad on assignment with Foreign

Governments, Govt. agencies or in UNO and its affiliates
IMF,IBRD etc.

c)

Govt. officials (both central and state) and other officials of

PSU's deputed abroad on assignments or posted abroad
including Diplomatic Missions

PIO (Person of Indian Origin)is defined as a citizen of any

country except Bangladesh or Pakistan if :
a)

He/she has, at any time held an Indian passport. OR

b)

He /she or either of his parents or any of his grand parents was a

citizen of India OR

c)

The person is a spouse of an Indian citizen or a person referred to

in a) or b)

NRE Accounts : ( held in INR)

Need to be opened with funds remitted from abroad

Fully repatriable : P+I
Minimum Tenor: 7 Days
Transfer to another NRE Act/FCNR
Local payments can be made
Local credits not permissible (eg: rental income)
Interest rates on NRE accounts(Savings+Term Dep) : RBI
controlled
Exchange Risk

FCNR(B) Accounts : ( held in FX)

USD,GBP,CAD,AUD,EURO,JPY
Fully repatriable : P+I
Transfer to another NRE Act/FCNR and vice-versa.
Opened only as term deposits
No Exchange Risk since deposits held/repaid in Fx.
Tenor: 1 -3 years

NRO Accounts : ( held in INR)

When a resident becomes a non resident-account

converted into NRO account.
Legitimate Credits accrued in India-Rent, Income from
investments
Can be opened as Savings, Current,Term Deposit
Principal non repatriable. Interest earned is repatriable
Upto US$ 1 million per financial year can be repatriated.

Permissible Credits/Debits:

Credits:

Proceeds of inwards remittance into India through normal

banking channels
Legitimate income in India : Rent, pension, interest etc
Sale proceeds of assets (including immovable
property)acquired out of rupee/foreign currency funds or
any inheritance.

Credits:
Any foreign currency which is freely convertible tendered by the
account holder during his/her temporary visit to India
Foreign currency exceeding USD 5000 or its equivalent in cash should
be supported by a CDF (Currency Declaration Form)

Rupee funds should be supported by an encashment certificate , if they

represent funds brought from outside.

Debits:

All local payments in rupees including payments for investments in India

(s.t compliance with RBI)

Remittance outside India of current income like rent, dividend, pension ,

interest in India of the account holder

Remittance upto USD 1 million per financial year (April-March)for all

bonafide purposes s.t approval by the AD.

Remittance of Assets

By NRI/PIO:
Can remit an amount not exceeding USD 1 million per financial year out
of balances held in NRO account/sale proceeds of assets/assets in
India acquired by way of inheritance
Document Required : Paperwork supporting the acquisition or any
inheritance along with an undertaking by the remitter duly certified by a
C.A in the format prescribed by CBDT(Central Board of Direct Taxes)

Remittance of Assets

By NRI/PIO:
Can remit an amount not exceeding USD 1 million per financial year
from the sale proceeds of immovable property purchased as a resident or
as an NR/PIO without any lock-in period
This facility not available to citizens of Pakistan,
Bangladesh,SriLanka,China,Afghanistan,Iran,Nepal and Bhutan

Foreign nationals on a visit to India (non-Indian origin)

NRO ( Current/Savings) account can be opened

Funds to open the account can be remitted from outside India through
banking channels or sale of foreign exchange brought to India.
The funds in such accounts can be converted back into foreign currency
at the time of departure of the foreign national ( provided account less
than 6 months old) and no local funds have been credited
If account tenure > 6 months RBI approval required

Resident to Non-Resident:
When a individual leaves the country(except Nepal/Bhutan) for an
overseas job business etc indicating intention to stay outside account to
be converted to NRO.
If the destination is Nepal/Bhutan : The account will continue as
resident

When such a person working abroad, carrying on business etc comes to

India:
temporarily account remains NRO
For good : Re-designate account to resident

Resident to Non-Resident :
Loans Given: While resident but becomes non resident.
Bank discretion and judgement to continue the arrangement
Can allow payment of interest and loan either through local
sources or through inward remittance

Non resident nominee : Credit NRO Account of nominee

Resident nominee: Credit resident account of nominee

POA holder can be a resident.

POA holder can make following payments:

All local payments including payments for eligible investments
Remit outside India the current income of the NR after taxes
POA can remit only to account holder and cannot repatriate funds to any
other account

 POA holder cannot gift any funds from NR account to a

resident on behalf of the NR.

Cannot transfer funds to another NRO account.

Can be issued to NRI/PIO without RBI approval

Payments can be settled by inward remittance or out of

balances in NRE/NRO/FCNR accounts

Domestic/NRO Accounts:
Minimum tenor is 7 days

NRE/FCNR(B) Term Deposits:

Minimum tenure is 1 year
Maximum tenure is 3 years
Banks can accept NRE deposits of tenure greater than 3
years but the rate of interest will be capped at the rate for 3
years

NRE term deposit into FCNR (B) and vice versa before
maturity subject to penalty

NRSR/NRNR into NRO deposit before maturity subject to

penalty

If NRE term deposit withdrawn prematurely for conversion

into RFC Account NO PENALTY.

If such a deposit has remained with the bank for a period less
than 1 year , interest can be paid at savings bank rate provided
such a request is made by the NRE account holder
immediately on return to India.

Since NRNR / NRSR schemes have been discontinued

effective April 1 2002,maturity proceeds of NRNR deposits
can be credited to NRE Accounts on maturity but not
FCNR(B) accounts

Maturity proceeds of NRSR deposits to be credited to NRO

accounts only.

Premature withdrawals of NRNR / NRSR deposits to be

credited to NRO accounts only

Satisfied :

Dissatisfied :

Growth of the Bank

Look for a resolution

Internal : Complaint to the Bank

External : RBI

Banking Ombudsman

Came

into effect on Jan 1 2006

The

aggrieved customer or his representative

can file a complaint

Written or via E mail

A complaint was made to the bank and no response

received within a month

Non satisfactory response received

Complaint should not pertain to the a matter pending or

dealt by the Ombudsman or which proceedings are pending
before a court

Complaint is within the limitation period under the Indian

Limitation Act 1963

Process

Aggrieved customer contacts ombudsman

Ombudsman sends the complaint to the bank for redressing

If not settled within a month of receipt, ombudsman awards /

rejects

Customer can appeal to the Appellate (Dy Governor) if

dissatisfied

Banks can appeal after taking consent from CMD