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Mid-term Review of Monetary and Credit Policy for the year 2001-2002              Click here for FULL credit policy

Financial Sector Reforms and Monetary Policy Measures

42. The Reserve Bank has, in recent years announced various structural measures to strengthen the financial system and improve the functioning of the different segments of financial markets. The annual policy Statements and the mid-term Reviews assess the progress in these areas and also propose appropriate additional measures as necessary, in the light of experience and after appropriate consultations with banks, other financial institutions, and experts. As financial markets in the last few months have been affected by several uncertainties and some turbulence, it may be useful to review the impact of recent developments on long-term objectives of financial sector reforms before we deal with some of the specific measures.

Recent Financial Market Developments

43. Developments in equity market since March 2001, and involvement of a few banks in providing substantial support to a few stock - broking entities, contrary to RBI guidelines and normal prudential requirements, have raised concerns regarding the potential vulnerability in India’s financial sector. Fortunately, so far as the banking sector is concerned, the unethical and unwarranted lending practices on a significant scale were confined to only a few relatively small private sector banks, and one fairly large Urban Co-operative Bank (UCB). As such, it was possible, through temporary and limited liquidity support measures, to avoid the "contagion" spreading from their activities in the equity market to the banking sector as a whole or to other important segments of the financial sector, particularly the money and government securities markets. Nevertheless, the recent experience in equity market, and its aftermath, have thrown up new challenges for the regulatory and supervisory system as well as for standards of corporate governance in banks.

44. First and foremost, it is essential to enforce all prudential norms and strengthen them further in order to minimise the possibility of contagion spreading from one segment of the market to another or from one defaulting institution to a number of inter-connected financial entities. The scope for "regulatory forbearance" has to be minimised in the event of emerging weaknesses in a financial institution (irrespective of whether its ownership is co-operative, public or private). In the past few years, the Reserve Bank has introduced a series of prudential measures for capital adequacy, income recognition and provisioning in respect of NPAs, disclosure and transparency in accounting, and risk containment. Certain additional legislative and other measures are also under consideration of the Government. It is of utmost importance that all deposit-taking financial intermediaries - irrespective of whether they are in the public sector or in the private sector, whether they are commercial banks or co-operative banks, whether they are non-banks or financial institutions - should fully adhere to the prudential guidelines. 

45. The Reserve Bank recognises the need to strengthen its monitoring system for enforcement of prudential and risk management guidelines, and for taking swift action, wherever possible under relevant laws, against defaulting entities. Measures for off-site monitoring and inspection, particularly in respect of weak banks and co-operative institutions, have already been introduced. RBI proposes to further strengthen its monitoring and supervisory machinery and procedures, in consultation with banks and other financial institutions, as necessary. 

46. As pointed out in the annual policy Statement of April 2001, the prudential norms and the regulatory system prescribed for UCBs have traditionally been relatively soft, in comparison with those for commercial banks. This is partly on account of historical reasons, and partly due to their size being generally small and the preferential treatment of co-operative structure in general. At present, three authorities are involved in regulatory and promotional aspects concerning UCBs - the Central Government (in case of banks having multi-state presence), State Governments and RBI. At times, this results in overlapping jurisdiction and difficulties in carrying out administrative/prudential measures with the required speed and stringency. The recent experience has also shown that irresponsible and unethical behaviour on the part of even a few co-operative banks in the country can have some contagion effect beyond the particular area or the State concerned and may cause severe harm to depositors, including smaller co-operative banks and impair confidence in the system. It is, therefore, necessary to ensure that prudential guidelines in respect of these banks are strengthened to protect public deposits, pending legal and institutional reforms. 

47. The April 2001 policy Statement had, therefore, proposed some new prudential measures, particularly in regard to maintenance and safety of securities held under the prescribed SLR, lending against shares, and the degree of access to call money market. In order to minimise any immediate financial impact on UCBs, precautions were taken to introduce new prudential measures with a prospective date and allow sufficient time for UCBs to implement them in the interest of their members. Some State level apex co-operative banks have represented against these measures on the ground that they may affect their financial operations and reduce their flexibility. 

48. The Reserve Bank welcomes the on-going constructive dialogue with UCBs and their representative associations. It will be prepared to further improve/modify specific measures subject only to one condition, i.e., providing an adequate, workable and transparent mechanism for protection of public deposits held in the co-operative sector. Needless to say that a viable co-operative financial system has to be such that interests of both the "borrowing" entities as well as the "depositing" public are protected. Past experience, even though confined to some errant co-operative banks, has made it abundantly clear that inter-bank co-operative deposits and lack of adequate secured liquid assets have substantially compromised the depositors’ interests. As a result, public confidence in the co-operative banking sector as a whole has also been shaken. In the interest of the growth of the co-operative sector itself, there is no option but to devise a viable and transparent system for reasonable protection of public deposits. 

49. As mentioned earlier, three authorities (Central and State Governments and RBI) are presently involved in regulating, supervising and/or administering UCBs. There are as many as 2,084 UCBs of which 51 are scheduled and the rest are non-scheduled UCBs. In view of their large number as well as their dispersed and local character, their supervision and inspection pose special problems. At present, while accounts of UCBs are required to be audited by State Governments, there has been substantial delay in completing audit of a large number of UCBs. RBI conducts statutory inspections normally once in two years in respect of scheduled UCBs, once in two to three years in respect of non-scheduled UCBs, while the identified weak banks are inspected on annual basis. Several committees, including a high power committee set up by RBI in May 1999 under the Chairmanship of Shri K. Madhava Rao, have made wide-ranging recommendations for eliminating dual control and for improving the functioning of the co-operative banks. Most of these recommendations have been accepted by RBI, but recommendations requiring legislative action at the level of State Governments have yet to be implemented. 

50. In order to overcome supervisory problems arising from the present three-pronged and multi-level institutional system (consisting of the Centre, States and RBI), the Reserve Bank has suggested setting up of a new Apex Supervisory Body for the entire urban co-operative banking sector. It has proposed that this Apex body could be under the control of a separate high-level supervisory Board consisting of representatives of the Central Government, State Governments, RBI as well as experts and it could be given the responsibility of inspection/and supervision of UCBs and ensuring their conformity with prescribed prudential, capital adequacy and risk-management norms. The Reserve Bank has also forwarded its detailed proposals to the Central Government for setting up the Apex Supervisory Body. 

51. Recent events have also brought to the fore the need for Boards of banks and financial institutions to exercise proper vigilance and supervision over the functioning of commercial banking and other financial institutions. In recent years, as part of on-going financial sector reforms, much greater autonomy and powers have been entrusted to their Boards, to lay down effective internal guidelines and procedures for transparency, disclosure, risk and asset-liability management. Yet, it has been noticed that in some cases, the policy laid down by the Boards was either flouted with impunity or the Board itself had failed to lay down appropriate internal guidelines for minimising risks and over-lending to certain entities without adequate security. If problems of the type which have surfaced recently are to be avoided in the future, within the framework of a deregulated and liberal financial system, the role of Boards becomes crucial. The Reserve Bank proposes to set up a consultative group of directors of a select group of commercial banks and financial institutions to suggest, for consideration by the Government/RBI, measures that should be taken to strengthen the internal supervisory role of Boards. 

52. In the rest of this section, an attempt is made to review the progress in respect of various monetary and other measures announced in recent years, and to propose some further measures of immediate as well as long-term importance. 

Monetary Measures 

(a) Bank Rate 

53. On the basis of a review of macroeconomic and monetary developments, the Bank Rate is being reduced by 0.50 percentage point from 7.0 per cent to 6.50 per cent with effect from the close of business today (October 22, 2001). At this level, it is the lowest Bank Rate since May 1973. 

(b) Cash Reserve Ratio - Reduction and Rationalisation 

54. All scheduled commercial banks [excluding Regional Rural Banks (RRBs)] are, at present, required to maintain with the Reserve Bank of India a cash reserve ratio (CRR) of 7.5 per cent of their net demand and time liabilities (NDTL). While the statutory minimum requirement of CRR maintenance at 3.0 per cent is obligatory on the banks, additional CRR, ranging between 4.5 per cent and 12.0 per cent since 1981, has been imposed from time to time in order to reduce the overflow of liquidity due to excessive money supply in the economy. At the same time, over a period, various exemptions given to the banks on certain specific categories of liabilities for the CRR requirement resulted in the effective CRR being different from the prescribed level in respect of individual banks. The effective CRR for different banks vary depending upon the composition of their liabilities, and for the banking system as a whole, effective CRR, at present is of the order of 6.3 per cent. Exemptions and multiple prescriptions over time made in response to specific requirements have increased the complexity of CRR as an instrument of liquidity management. With a view to rationalizing CRR prescription and moving towards the long-term goal of keeping CRR normally at the statutory level, important changes are proposed below in respect of the coverage as well as the level of CRR for the banking system: It is proposed to reduce the CRR by 200 basis points to 5.50 per cent from 7.50 per cent of NDTL. Effective from the fortnight beginning November 3, 2001, CRR will be reduced to 5.75 per cent; and effective fortnight beginning December 29, 2001, the CRR will be reduced further to 5.50 per cent of NDTL. At the same time, all the exemptions on the liabilities will be withdrawn except inter-bank liabilities, for the computation of NDTL (for requirement of maintenance of CRR) with effect from fortnight beginning November 3, 2001. 

55. It is expected that these changes will facilitate the development of a short term yield curve, develop money market, reduce the regulatory arbitrage between banks and non-banks, enhance the availability of lendable resources with the banks and improve the efficiency of indirect instruments in the conduct of monetary policy. At the present level of NDTL, the combined impact of the above two measures will result in augmenting lendable resources of the banking system by about Rs.8,000 crore (about Rs.6,000 crore effective from November 3, 2001). 

56. It may, however, be emphasized that while the proposed CRR reduction is consistent with the medium term objective, and the current circumstances of relatively low level of economic activity and reasonable inflation, RBI will continue to use the CRR instrument in both directions for liquidity management in addition to other instruments (such as, the LAF.) 

c) Interest on Cash balances Maintained with RBI 

57. All scheduled commercial banks (excluding Regional Rural Banks) are paid interest on eligible cash balances maintained with RBI under CRR requirement at the rate of 6.0 per cent per annum effective April 21, 2001 against 4.0 per cent earlier. In the annual policy Statement of April 2001, it was announced that at a subsequent stage, interest will be paid at the Bank Rate. Accordingly, with effect from fortnight beginning November 3, 2001, the interest paid on eligible cash balances will be at the Bank Rate (i.e., 6.5 per cent). 

Liquidity Adjustment Facility - Progress 

58. The Liquidity Adjustment Facility (LAF), introduced since June 5, 2000, has emerged as an effective and flexible instrument for influencing liquidity on a day-to-day basis. A package of measures was announced in the annual policy Statement in April 2001 encompassing changes in operating procedures of LAF, a strategy for smooth transition of call money market to pure inter-bank market and a programme for rationalisation of liquidity support available to the system. A set of complementary measures in money and government securities markets was also introduced. 

59. On the whole, this package of measures had a positive impact. The LAF has rendered the necessary flexibility to RBI to operate on liquidity and to some extent to signal interest rates in the short-term money market. The LAF operations, combined with strategic OMO, have evolved into the principal operating procedure of monetary policy of the Reserve Bank in the short-run. The effectiveness of LAF would be further strengthened as the system moves towards a pure inter-bank call/notice money market coupled with the growth of a deep and liquid repo/reverse repo market for non-bank participants. Effective May 2001, non-banks are permitted to lend upto 85 per cent of their average daily lending during 2000-01. This has not caused any strain on the market with average daily aggregate lending in call money market improving to Rs.19,600 crore during May-September 2001 compared to Rs.10,900 crore during the corresponding period of the previous year. Volatility in call money rates has also come down significantly. It is encouraging to note that the volume of repo operations by non-bank participants has been increasing in the recent period. 

60. In the context of improving the effectiveness of LAF, it is reiterated that in addition to overnight repos, RBI will also have the discretion to introduce longer-term repos upto 14-day period as and when required. 

Commercial Paper - Dematerialised Holding 

61. RBI issued fresh guidelines for issuance of Commercial Paper on October 10, 2000 relaxing the terms and conditions and streamlining the procedures. As indicated in the annual policy Statement of April 2001, banks, Financial Institutions (FIs), PDs and Satellite Dealers (SDs) are now permitted to make fresh investments and hold CP only in dematerialised form, effective June 30, 2001. In this context, Fixed Income Money Market and Derivatives Association of India (FIMMDA) circulated a "Report of FIMMDA Working Group on Primary Markets Relating to Market Conventions and Guidelines for Commercial Paper". After extensive discussions on legal and related issues with depositories and RBI and after considering suggestions received from corporates, members of FIMMDA and other market players, the operational guidelines in respect of CP in dematerialised form were made public by FIMMDA on June 29, 2001. Further, to facilitate conversion of physicals into demat, FIMMDA, in consultation with market participants, depositories and RBI, prepared the related guidelines and made them public on October 3, 2001. These guidelines seem to be working reasonably well, and no changes are being proposed at present. 

Development of Government Securities Market (click here for details)

Prudential Measures 

(a) Credit Information Bureau 

65. A mention was made in the annual policy Statement of April 2001 about the setting up of the Credit Information Bureau (CIB) to collect, process and share credit information on the borrowers among banks and FIs. With a view to strengthen the legal mechanism, a draft legislation covering, inter alia, responsibilities of the Bureau, rights and obligations of the member credit institutions and safeguarding of the privacy rights has been forwarded to the Government. Pending such amendments, as a first step towards activating CIB, it has been decided to initiate the process of collection and dissemination of some relevant information, within the existing legal framework. 

66. In order to operationalise the process of collection and dissemination of the data on credit information by the CIB, RBI will constitute a Group drawing representation from CIB, Indian Banks’ Association (IBA), select banks and FIs. The Group will examine the possibility of the CIB performing the role of collecting and disseminating information on the list of suit-filed accounts and the list of defaulters, including willful defaulters, which is presently handled by RBI. The Group will also examine the other aspects of information collection and dissemination, such as, the extent, periodicity and coverage including the feasibility of supplying such information on-line, to members in future. Ideally, it should also be possible to work out in future a ‘query mode’ to provide any additional information needed and considered appropriate, on specific requests from members, including particulars relating to directors in the defaulting companies, as long as it is legally permissible. The Group will study all these issues and submit a report in one month’s time. The transfer of work will be notified separately, thereafter. 

(b) Non-SLR Investments by Banks and Financial Institutions 

67. It has been observed that, of the investments by banks, a significant proportion of the banks’ investments in non-SLR securities is through the private placement route. The non-transparent practices in this market could be a matter of concern. RBI had accordingly issued guidelines in June 2001 regarding the due diligence to be undertaken, the disclosures to be obtained and the credit risk analysis to be made in regard to privately placed investments especially for unrated instruments. Banks have been advised to adopt an internal system of rating for issues of non-borrowers, whether rated or otherwise, and adopt prudential limits to mitigate adverse impact of concentration and illiquidity. Banks have also been advised to put in place proper risk management systems for capturing and analysing the risks so as to take timely remedial measures. A further review of non-SLR investments in the light of recent developments reveals that the ease of mobilising funds through privately placed debt issues could lead to the use of such funds for risky purposes other than what is disclosed in the offer document. 

68. In order to contain the risks arising out of non-SLR investment portfolio of banks and FIs, in particular through the private placement route, it is proposed to issue further prudential guidelines to be observed by banks. These guidelines, inter alia, would cover: (i) the need for strengthening of internal rating systems, periodically tracking the rating changes in respect of issuers; (ii) fixing of prudential limits, with separate sub-limits for unrated, unquoted and privately placed instruments; (iii) review by Board on total investments/disinvestments, regulatory compliance, rating changes in respect of issuers and non-performing investments; and (iv) disclosures in ‘Notes on Accounts’ regarding issuer composition and non-performing investments. A draft of detailed operating guidelines are being issued separately, which will be finalised after further consultation with banks and FIs. 

69. For effective risk management, it is necessary to put in place appropriate arrangements for collecting and sharing of information regarding amounts of debt raised by corporates from the market, including through CPs, etc. It is proposed to constitute a Working Group to evolve a framework for collecting and sharing by banks/FIs of information on private placement of debt with CIB as a convenor, and representatives, inter alia, of banks, FIs and RBI. The proposed Working Group will, inter alia, analyse the status in regard to existing stock of debt, and its use for the purpose of evolving suitable guidelines in this regard. The Group will give its report in one month. 

70. There is also a need for dissemination of information on secondary market trades in privately placed debt and to this end, banks and FIs have already been advised that effective October 31, 2001, they will be permitted to make fresh investments and hold bonds and debentures, privately placed or otherwise, only in dematerialised form. Outstanding investments should also be converted into demat form by June 2002. Transactions in such bonds could be reported by the National Securities Depository Limited/Central Depository Services Limited (NSDL/CDSL), with whom transfers of title are reported. To enable the transparency of the trades including nomenclature of the bonds, amount traded and the price at which traded, banks and FIs could evolve a reporting mechanism and the NSDL/CDSL can in turn disseminate such information to the market. 

71. The above arrangements would apply uniformly to all bonds issued by corporates, banks, FIs and State and Central Government sponsored institutions directly or as Special Purpose Vehicles (SPVs). In regard to bonds guaranteed explicitly or implicitly through letters of comfort, etc., mere availability of such guarantee should not determine the credit decision, and banks and FIs should undertake due diligence on the intrinsic viability and bankability of projects financed through issuance of such bonds. This will go a long way in ensuring efficient use of resources made available by banks and FIs, besides ensuring their creditworthiness. Overall, any proposal of direct or indirect financing of government budgets, directly or through SPVs should be eschewed and proposals should be for specific monitorable projects, particularly in capital-intensive and high-cost sectors, including infrastructure. Components of financing and returns need to be well defined and assessed.

 (c) Transparency and Accounting Standards 

72. Over a period, banks were advised to disclose in the ‘Notes on Accounts’ in the balance sheet, the details of the maturity pattern of loans and advances, investments, deposits and borrowings, movements in NPAs, exposure to sensitive sectors, etc. As a further step in ensuring transparency and credibility of their financial positions, it has been decided that banks should furnish the following additional disclosures in the ‘Notes on Accounts’ in their balance sheets, from the year ending March 2002: (i) movement of provisions held towards NPAs and (ii) movement of provisions held towards depreciation on investments. 

73. The Accounting Standards issued by the Institute of Chartered Accountants of India (ICAI) establish the standards which have to be complied with by corporate entities so as to ensure that they present a true and fair view of the financial position of the entity. These standards are periodically being revised by ICAI, consistent with international accounting standards. Certain difficulties in the adoption of the standards as finalised by the ICAI have been reported by banks. It has, therefore, been decided to set up a Working Group comprising representatives of ICAI, banks and RBI to identify the compliance as also gaps in compliance with the accounting standards and recommend steps to eliminate/reduce the gaps. 

Supervision and Monitoring 

74. The Reserve Bank had introduced in 1999 off-site returns to monitor liquidity and interest rate risks on quarterly basis with the intention to finally move over to a fortnightly reporting system. The quarterly system has now stabilised. Further progress made in respect of certain announcements made in the annual policy Statement of April 2001 is reviewed below: The Basel Committee on Banking Supervision (BCBS) released the second set of consultative documents on New Capital Accord. RBI has forwarded its comments to Basel Committee, which have also been put on RBI website in May 2001. A scheme of Prompt Corrective Action (PCA), based on pre-determined trigger points, is planned as part of continued efforts to enhance the existing supervisory framework. The Reserve Bank, after examining the comments/suggestions received from scheduled commercial banks on the scheme, has sought the Government’s views before implementation. In order to involve banks in the smooth switch-over to Risk-based Supervision (RBS) process, the Reserve Bank has released a discussion paper seeking comments/suggestions of experts/public. The discussion paper highlights the initiatives and action required in setting up of a comprehensive risk management system, adoption of risk-based audit system, upgradation of management information and information technology systems, establishment of dedicated compliance units and resolving HRD and training related issues. It is planned to hold a pilot run of the RBS approach in due course. 

Settlement of Non-Performing Assets 

75. In July 1995, RBI had issued broad guidelines to scheduled commercial banks for compromise or negotiated settlement of NPAs. In May 1999, in order to facilitate settlement of NPAs in the small sector, the Reserve Bank issued guidelines for the constitution of Settlement Advisory Committees (SACs) in public sector banks. Banks had, however, represented that much progress could not be made in the recovery of NPAs despite setting up of SACs. Accordingly, in July 2000, in consultation with the Government, RBI had circulated simplified, non-discretionary and non-discriminatory guidelines to provide a one-time impetus to reduction of the stock of chronic NPAs by the recovery of dues relating to public sector banks which covered accounts upto Rs.5 crore in all sectors including the small scale sector, but excluded any cases of willful default, fraud or malfeasance. These guidelines specified the coverage of the scheme, the settlement formula including the amount and cut-off date, and the manner of payment of the settled dues. 

76. The settlement scheme laid out by these guidelines was operative till June 2001 and all applications received upto this date were to be processed by September 30, 2001. Under this scheme, the public sector banks have recovered a total sum of Rs.2,192 crore in respect of 5.23 lakh accounts as on July 30, 2001. 

77. Some representations have been received for further extension of the scheme. Given that the purpose of these guidelines was to provide an opportunity for "one-time settlement" within the specified time period, and sufficient time has already been provided, it is not proposed to extend this scheme. However, the broad framework provided for settlement in the 1995 guidelines will continue to be in place, and banks are free to design and implement their own policies for recovery and write-off incorporating compromise and negotiated settlements with the approval of their Boards, particularly for old and unresolved cases falling under the NPA category. In this respect, the experience with the one-time settlement scheme may also be taken into account. It is important, however, to ensure that any scheme formulated by bank Boards is simple, non-discriminatory and transparent so that all eligible cases are accorded equal treatment. 

Urban Co-operative Banks (click here for details)

Credit Delivery Mechanism (click here for details)

Universal Banking (click here for details)

Non-Banking Financial Companies (click here for details)

89. The Reserve Bank had received applications for Certificate of Registration (CoR) from 36,505 Non-Banking Financial Companies (NBFCs), of which, 13,815 applications were approved and 18,355 were rejected as at the end of August 2001. Only 776 NBFCs have been permitted to accept public deposits, of which 27 NBFCs were holding public deposits of Rs.50 crore and above. 

90. The companies whose applications for CoR have been rejected or the companies whose CoR has been cancelled, should continue to repay their deposits on due dates and dispose of their financial assets within three years. They are also advised to submit the returns at prescribed periodicity to RBI. 

91. The ALM guidelines issued in June 2001 would become fully operational by March 31, 2002. The NBFCs were, however, advised to commence trial run of the ALM process for the half year ended September 30 and for the half year beginning October 2001. The NBFCs may bring to the notice of RBI any difficulties being faced by them for appropriate consideration. 

92. As pointed out in earlier policy Statements, RBI places substantial importance to further development of the NBFC sector along prudent lines. NBFCs are in a position to deliver credit to the decentralised sector and to small borrowers at the local level in response to local requirements, particularly for financing of transport and other equipment. RBI has, therefore, been discussing with the informal Advisory Group of NBFCs, and also with various NBFC associations, the need to promote the formation of a Self Regulatory Organisation (SRO), particularly for the benefit of smaller NBFCs. So far, there has not been much progress by the NBFC sector in finalising a scheme for formation of SRO. RBI would continue with its efforts to encourage the NBFC sector to devise a viable mechanism for instituting a self regulatory system for this sector. 

Technology Upgradation (click here for details)

Rationalisation of Current Account Facility by the Reserve Bank 

95. Since banks having large network of branches are the eventual payment service providers to the rest of the non-banking community and also the essential conduits, apart from PDs, through which RBI effects its LAF and in the context of the recommendations of the Technical Group on phasing out of non-banks from call/ notice money market, a need was felt to rationalise/review the present policy of current account facility provided by RBI. Further, the operationalisation of the CCIL and the proposed implementation of NDS would also obviate the need for having current account with RBI by some of the non-bank entities. To look into all the above aspects, an internal Group was set up which has since submitted its Report. The Report has been placed on RBI’s website and a copy of the Report has also been sent to all the current account holders for their comments. These recommendations are also being examined by the Reserve Bank. 

Legal Reforms (click here for details)

International Financial Standards and Codes 

97. The annual policy Statement of April 2001 mentioned about the significant progress made by the Advisory Groups on International Financial Standards and Codes. All the Advisory Groups constituted by the Standing Committee on International Financial Standards and Codes have submitted their Reports to the Chairman of the Standing Committee and these reports are placed on RBI Website www.rbi.org.in for wider dissemination. Copies of the Reports are being sent to various experts, economists, professionals, academicians, banks and institutions for their comments. The Chairmen of individual Advisory Groups have been requested to explore the possibility of organising seminars on the themes. The Standing Committee will also prepare its own report indicating, inter alia, the course of follow-up/reforms required and the regulatory agencies involved in such follow-up actions.

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