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Individual Credit Rating in India
A Primer for Individuals
When it comes to risk management in Banks, the
risk that takes the priority is "the credit risk".
The credit risk by definition means, risk of loans disbursed
to various corporate and retail clients will be paid back
or not. For layman's understanding, a bank broadly has two
main functions viz. Assets and Liabilities. The main job of
the liabilities side of a bank, is to channelise savings in
the economy, designs various instruments, by which, money
can be collected from the economy. This could be in the form
of saving bank accounts, current accounts, FDs etc. The money
so collected, is a liability on the bank as it has to repay
the same to its customers with certain prevailing rate of
interest and hence the function is called Liability. Once
money is collected from various sources, the same has to be
deployed at a profitablen rate of return. The deployment could
be in the form of corporate lending, investing in projects
or simply retail lending in the form of Personal Loans, Vehicle
loans, home loans, SME lending etc.
The basic principle of managing Credit Risk, is diversification
of portfolio. This means, that lending to corporate borrowers
is diversified in terms of different industries and within
an industry to different corporates. Lending is based on as
per the underwriting standards of the bank e.g. the repute
of the company, past financials of the company including profitability
over last several years, shareholding pattern, qualitative
study of management, project feasibility of the project to
be funded, future cash lows etc. Although all banks into corporate
lending develop their own individual underwriting policies,
they also depend on the credit rating of a corporate by accredited
Credit Rating Agencies like CRISIL, ICRA and CARE. Even the
Basel Committee on Banking Regulation has accentuated on the
importance of use of external credit ratings.
The retail segment in India, however, has been devoid of
external agencies, which are into credit rating of individuals
i.e. retail customers. The lending to retail customers is
done basis purely on the lending policy of the bank, which
vary from bank to bank, depending on the banks risk appetite.
In the United States, there are government funded repositories
like Equifax, Trans-world, Trans Union, Dun & Bradstreet
etc, which act as credit rating agencies for retail borrowers.
They provide member banks/NBFCs with credit history of an
individual in terms of loans that he has paid in the past,
loans that he is currently running, Credit Cards that he has
held or currently active with repayment history of the same.
There are other vital information that the agency report provide
viz., if the borrower has ever filed for bankruptcy or if
there is any litigation, court case etc. pending against him.
Based on the overall credit history of the customer, he/she
is given a credit rating, more popularly called, FICO score.
This may vary from agency to agency but the variation may
not be more than 10%..
However, the US system of credit rating individual could
not be replicated in India because of some practical difficulties.
The most important being, absence of a mechanism for identifying
an individual. In the United States, each individual is issued
a Social Security Number or the SSN, when he/she is born.
This SSN is a unique number and all information related an
individual, including social history, financial history, criminal
history etc is linked to ones SSN and therefore, collecting
information about individual becomes much easier. This is
further facilitated by the presence of a system, which ensures
that the information flows freely between well co ordinated
government and public departments. Hence, information related
to individual can be stored at a common place and retrieved
when required. Also, there are proper laws in place, which
requires all the public/private entities like banks, NBFCs
etc. to share their customer related data with the credit
rating agencies.
In India, the scenario has been different. The is no concept
of Social Security Number to identify an individual. The only
way to identify a customer is through name, address, Date
of Birth (DoB) etc. However, with no sanctity of DoB proofs
or address proofs, it is very easy to fool the system. Till
sometime bank, the only way for a bank to know the credit
history of a prospective customer was through its collection
or field verification agencies, which may or may not had information
about the customer. Besides, banks also did not pay any strict
attention to the data sanctity of the customer at their end.
This is, particularly true to banks issuing Credit Cards.
With rising competition in the retail sector, there was a
sharp rise in delinquency level of banks. The need for Credit
Rating Agency which could work like a repository for credit
information of individual, was widely felt. As a first attempt
in this direction, The Credit Information Bureau of India
Ltd or the CIBIL was incorporated in 2000. CIBIL was an effort
of The Government of India and the Reserve Bank of India.
The first promoters and the member banks were the State Bank
of India (SBI) and HDFC. Necessary logistics and technology
was provided by internationally reputed credit rating agencies
like Dun & Bradstreet and Trans-union. However, the attempt
was not efficacious initially, since most banks were reluctant
about sharing their customer data with other banks. This was
further aggravated by the fact that the banks were not under
any legal obligation to share their data. However, with RBI's
efforts, more and more banks and NBFCs have joined hand in
providing customer data to CIBIL and in return get data on
the customers on payment of some fees from CIBIL. This initiative
called CIBIL has really been helpful in curbing delinquency
and banks have starting weaving their credit lending policy
around CIBIL.
The quality of CIBIL reports have further been helped by
certain government measures like introduction of PAN numbers
and making the same mandatory for availing most banking services.
The PAN number may be considered as a very crude form of a
Social Security Number, since only tax paying individuals
apply for it i.e. people not falling in tax bracket or not
wanting to pay tax, may or may not have PAN no. But with regulators
like RBI, Tax Departments etc making PAN no. mandatory for
availing banking and investment services, more and more percentage
of population (at least those wanting to avail credit) are
now having a valid PAN no., which to a large extent has done
the same job what SSN does in the United States.
Any technological advancement in future, which may lead to
better networking between banks, government agencies like
judiciary, RBI and CIBIL will only further improve the quality
of CIBIL reporting. As of now, CIBIL has not introduced any
system of assigning any Credit Rating to individuals like
the FICO scoring as mentioned above. But this may be just
round the corner. Also, a competition in the credit rating
field i.e. more set ups like CIBIL will not only see a further
improvement in quality in terms of services being provided
to the banks and NBFCs but will also see cost rationalization.
Prior to CIBIL and along with CIBIL, there was information
available in the market but it was more scattered and specific.
For example, Satyam Database, more popularly known as MCNF
database (Master Card Negative Feedback), is available in
the market. The MCNF database is the data of database of all
delinquent customers who have defaulted in their Master Card
Credit Card. The customer could belong to any bank which issues
Master Card Credit Card. Besides this, most of the verification
agencies in any particular area, are a rich source of credit
information, specially derogatory. Since most of these verification
agencies are also invariably collection agencies for multiple
banks, they have their own database for derogatory customers.
There is a basic limitation to both MCNF database and data
available with verification agencies. One the data is very
limited and does not cover sizable proportion of the credit
seeking population. MCNF covers only Master Card Credit Card
while verification agencies have data of their client banks
only. Most of these verification agencies have their area
of operation limited to only one city or couple of cities
in the same state but not beyond that. Second, the MCNF and
Verification Agencies have only derogatory data. So, if a
match is found, then, the customer is a bad credit or risky
to lend, but if there is no match, it will not be prudent
to assume that the customer is a good credit or not risky
to lend. CIBIL is however, a balanced approach, as it contains
all the credit history available for the customer, both good
and bad.
With set ups like CIBIL, there is a free flow of credit information
between banks. All members have access to the CIBIL database.
Hence, it is becoming, increasingly difficult for chronic
defaulters to obtain credit from the banks. As mentioned before,
most bank are weaving their credit policy around CIBIL, MCNF
and Verification Agency records, it is very important for
individuals to be aware and sensitive to their credit history.
It is a common observation with the people of younger age
group, that, they carry multiple credit cards, more as a matter
of style statement, than, having an actual requirement of
the same. This is coupled with over spending and in their
juvenile spirit, not paying. What they do not realize is that
this derogatory information is actually being stored against
their name, add or PAN no. somewhere, and when, later in their
life, they are in actual need for credit, they do not get
it. The above given example is of a willful customer, but
there are also common instances service related issues with
the banks, specially, credit card issuing banks e.g. annual
fee levied when free credit card promised or insurance premium
charged without customer's knowledge. Instances could be numerous,
but unfortunately, it is the individual, who is impacted negatively
in such a situation. Often, after charging multiple late fees,
interests etc, the default amount reported to CIBIL or Satyam
database, is quite high. Lending institution, prima facie,
do not investigate in the derogatory information and decline
a loan or a credit card application upfront. Since, all banks
are free to make their own credit policy, a bank with low
risk appetite and hence strict credit policy, is not likely
to reconsider credit application, even if, in reality, it
was not customer's fault.
The importance of a clean credit history is understood when
emergency credit is required, for example, a personal loan
in order to meet immediate medical expenses or a home loan
and the same is denied because one did not bother to repay
his credit card debts or his auto loan EMI or resolve the
dispute with a financier in the past
Since, most of us, specially in the middle class, salaried
or businessmen, will require a credit at some point of time
either for a personal need, building a house or for business
purpose or a credit card, there are a few precautions that
an individual must take in his financial dealings. One must
be very diligent and disciplined in repaying his debts, EMIs,
Credit Card payments etc. In rarity, if there is a delay in
payment, one should make sure, that, the payment with late
payment charges if any, should not cross 30 days past due.
If late payment charges or any other charges are waived off
by the bank specifically in written, then only, such charges
are not to be paid. If there is a dispute in payment, specially
in credit card related payments, one should make sure that
the dispute is resolved and he has a written record of the
same in his possession. Some people think, that settling an
account for something less that what is actual due is an easy
way out. The settlement will only give them a settlement letter,
which is an indicator that they did not pay the full amount.
Neither is their name or record taken off from the derogatory
history of the bank and hence CIBIL/Satyam records. In case,
the bank is at a fault, which it agrees on also, it is very
important to acquire an apology letter from the bank, clearly
stating the issue and bank's apology on the same.
Most of us, keep getting calls from various Credit Card issuing
bank's DSA (Direct Selling Associates), which would make loads
of promises and would request us to at least keep the card
for a year and then destroy the same after informing the bank
of your intention of not using the same. Such offers should
be avoided, if one is NOT in need of that credit card. Since,
one does not need that card, it will be lying dormant in his
pocket for a year. He would even forget the date as to when
the card is to be blocked. Since the card is free for only
the first year, next year beginning, he would receive a statement
with annual fees levied. He will dispute it, not pay it. The
bank will keep following up and levying late payment and other
incidentals charges, and report it as a derogatory card to
the CIBIL. The bank cannot blamed for the same, since, as
per its terms and conditions, the card was free for first
year only and the customer did not bother to cancel it at
the end of the year. So, why, unnecessarily, call for a problem,
when it can be easily avoided by politely declining to accept
for the card in the first place. The principle is simple.
Do NOT avail a credit if you DON'T need it.
I had a Smart Credit Account with Standard
Chartered Bank and Credit Card with SBI. Also I have 2 loans
with ICICI bank.
For 6 months I was not in job and failed to pay many of the
dues. However, I managed to pay my ICICI creidit card payment
till date (So they even sent me a birthday as I used to pay
interest close to Rs.2000).
I got setlement letters fron Standard Chartered bank and SBI.
I am paying the ICICI Bank loan EMI and the minimum due to
the ICICI Credit Card.
I would like to know my credit rating. How do I get that information
either from Credit Information Bureau (India) Limited or from
Satyam Database?
Author's Reply
Unfortunately, CIBIL does not account for the human
aspect of a financial contract. It only provides with the
data and the rest is up to the bank/financial institution
using the data. Some banks have lenient policies around CIBIL
but most are very stringent around the same.
It was very unfortunate that the person in question, was
without a vocation for couple of months. However, as I keep
reiterating, one should be spending according to the current
necessity and future repayment capacity, which most of us
tend to overlook and end up over spending and then fall short
of our promise to repay to the bank on time. Like I mentioned
in my article, this often, is a very expensive proposition,
since the interest charged by the bank may go up to as high
as 60%. This start pinching when heavy late payment or non
payment charges keep accruing to the customer's account and
before he/she realises, his/her interest component will be
much higher than the actual principle that he/she is liable
to pay. This is the origin of all disputes leading to collection
issues and sometime culminating into what we recently witnessed
in ICICI TW case, where the customer, resolved to ending his
life.
For the case, in the first place, NEVER get into settlement
mode with the bank. Often, this is a cheaper way out. While
for some people, it is a matter of habit of taking loan or
availing credit on a credit card, disputing it and then settling
it for lesser amount. For other not so aware customers, they
fall easy prey to not so scrupulous Collection agencies, who
make more money, as a commission from the bank, on settlement
cases, than when the customer makes the full payment. Ideally
the person should have directly contacted the SBI or the SCB
to explain his/her problem and his/her intention to repay
whenever his/her capacity issue is resolved. He/she could
have, probably bargained on or requested for waiving the late
payment and other incidental charges. Besides it is also very
important to request for the cards to kept live by the bank
and once the payments on the credit cards would have got regularised,
he/she could have sent in a request for cancellation of the
unwanted cards. This way, the CIBIL data will show delinquency
strings on the credit cards data but will not show the card
as completely delinquent.
As far as knowing any persons CIBIL rating or report,
this will NOT be possible as CIBIL does not cater to individual
requests. It will only cater to banks which are members of
CIBIL fraternity. Since both SCB and SBI are members of CIBIL,
in all probabilities, the delinquent data will figure out
in the CIBIL report of the person, if he/she applies for a
loan or a credit card to a bank and the bank generates a CIBIL
report for him/her. What final decision the bank takes on
whether to approve or decline his/her request will totally
depend on the bank's risk policy.
V. Rawat
1st July 2007
Similar Articles
Indian Credit Rating - An Insight by V. Rawat
The author of the article is working with a leading Multinational
Bank and has over 7 years of experience in the credit policies
being followed in Indian and US retail lending market.
Last Updated 10 April 2008
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