Specialist in Indian Banking and Economic Research

Hemindra Hazari

Nearly a year after <a href="https://www.smartkarma.com/entities/axis-bank-ltd" target="_blank" data-smartkarma-citation="entities:768:1" rel="noopener">Axis Bank Ltd (AXSB IN)</a><a href="https://hemindrahazari.com/2020/01/09/axis-bank-hollowing-out-the-crucial-role-of-the-cro/" target="_blank" rel="noopener">truncated</a> the responsibilities of its Chief Risk Officer (CRO) by transferring corporate credit risk to the role of the newly created Chief Credit Officer (CCO) who reported only to the CEO, <a href="https://www.smartkarma.com/entities/hdfc-bank-ltd-4b6b7a92-9087-468d-9dbe-ab169e77f014" target="_blank" data-smartkarma-citation="entities:558:1" rel="noopener">HDFC Bank (HDFCB IN) </a>has <a href="https://archives.nseindia.com/corporate/HDFCBANK_14122020145644_SEIntimationCRO.pdf" target="_blank" rel="noopener">decided</a>  to go a step further. It has transferred corporate and retail credit risk to a similarly newly created role of a CCO (no business targets), who will report only to the CEO, and transferred the earlier CRO to the CCO post. HDFC Bank also <a href="https://twitter.com/MDahariya/status/1341597883225825285?s=20" target="_blank" rel="noopener">shifted</a> individuals in the CRO handling credit risk to the CCO, and made the latter accountable for credit decisions.  The rationale provided by HDFC Bank is that in its future credit expansion it wants greater underwriting focus and accountability and therefore wants an experienced individual to accept responsibility for the CCO post who will report to the CEO.In Indian banks credit risk is the major risk and in HDFC Bank credit risk assets constitute 83% of total risk weighted assets. In this organisational restructuring, the CRO will only be left with non-credit risk management and secondary credit risk-related functions like stress testing the credit portfolio, concentration risk and determining limits (such as sector, group, company, geography).  For some inexplicable reason, even the <a href="https://www.linkedin.com/in/sameer-ratolikar-13b1725/?originalSubdomain=in" target="_blank" rel="noopener">Chief Information Risk Officer</a>  has been made to report to the CCO. Therefore the CRO’s role in HDFC Bank has been drastically downsized.The new CRO at HDFC Bank maintains his prior designation of senior executive vice-president, while the earlier CRO had the designation of group head. This change has downgraded the position of the CRO within the senior management. As HDFC Bank’s own disclosures reveal, while the earlier CRO’s experience, age, and remuneration was similar to the others in the senior management, the new CRO is the junior-most in all these parameters.  For most practical purposes, the erstwhile CRO post has been re-named “CCO”, with one crucial difference: he does not report to the Board’s Risk Management Committee, but only to the CEO. It appears that creating the new designation, and maintaining a stripped-down CRO post as well, merely serves to confuse the public and distract from the nature of this disturbing change.The Basle Committee and the Reserve Bank of India (RBI) have been trying to enhance the role of the CRO (<a href="https://www.bis.org/bcbs/publ/d328.pdf" target="_blank" rel="noopener">here</a> and <a href="https://www.rbi.org.in/Scripts/BS_CircularIndexDisplay.aspx?Id=10948" target="_blank" rel="noopener">here</a>) and insulate the CRO from business and even pressure from the CEO, by making the post report to the risk management committee of the board with a dotted line reporting to the CEO. It is perplexing that, at the same time, two prominent private sector banks in India, with full support of their boards of directors, are undermining the foundations of the CRO by taking away (in Axis Bank only corporate credit risk) the core credit risk function.

Nearly a year after Axis Bank Ltd (AXSB IN)truncated the responsibilities of its Chief Risk Officer (CRO) by transferring corporate credit risk to the role of the newly created Chief Credit Officer (CCO) who reported only to the CEO, HDFC Bank (HDFCB IN) has decided  to go a step further. It has transferred corporate and retail credit risk to a similarly newly created role of a CCO (no business targets), who will report only to the CEO, and transferred the earlier CRO to the CCO post. HDFC Bank also shifted individuals in the CRO handling credit risk to the CCO, and made the latter accountable for credit decisions.  The rationale provided by HDFC Bank is that in its future credit expansion it wants greater underwriting focus and accountability and therefore wants an experienced individual to accept responsibility for the CCO post who will report to the CEO.In Indian banks credit risk is the major risk and in HDFC Bank credit risk assets constitute 83% of total risk weighted assets. In this organisational restructuring, the CRO will only be left with non-credit risk management and secondary credit risk-related functions like stress testing the credit portfolio, concentration risk and determining limits (such as sector, group, company, geography).  For some inexplicable reason, even the Chief Information Risk Officer  has been made to report to the CCO. Therefore the CRO’s role in HDFC Bank has been drastically downsized.The new CRO at HDFC Bank maintains his prior designation of senior executive vice-president, while the earlier CRO had the designation of group head. This change has downgraded the position of the CRO within the senior management. As HDFC Bank’s own disclosures reveal, while the earlier CRO’s experience, age, and remuneration was similar to the others in the senior management, the new CRO is the junior-most in all these parameters.  For most practical purposes, the erstwhile CRO post has been re-named “CCO”, with one crucial difference: he does not report to the Board’s Risk Management Committee, but only to the CEO. It appears that creating the new designation, and maintaining a stripped-down CRO post as well, merely serves to confuse the public and distract from the nature of this disturbing change.The Basle Committee and the Reserve Bank of India (RBI) have been trying to enhance the role of the CRO (here and here) and insulate the CRO from business and even pressure from the CEO, by making the post report to the risk management committee of the board with a dotted line reporting to the CEO. It is perplexing that, at the same time, two prominent private sector banks in India, with full support of their boards of directors, are undermining the foundations of the CRO by taking away (in Axis Bank only corporate credit risk) the core credit risk function.  

HDFC Bank: Honey, I Shrunk the Chief Risk Officer

Silver Point

Thomas J. Monaco

Independent Insight Provider

Silver Point is a boutique research firm that focuses on the broader financial services sector, with a particular focus on troubled institutions globally. 

Asia Ex Japan

Thematic (Sector/Industry)

*New Circular, New Loopholes: The Reserve Bank of India (RBI) has proposed capping non-bank financial company (NBFC) dividend payout ratios to a maximum of 50%. The methodology is predicated on the net NPL ratio and CAR. The new proposal is riddled with loopholes, as NBFCs can easily manipulate these ratios; and*Well-Placed NBFCs: Excluding LIC Housing Finance (LICHF.IN) and Shriram Transport (SHTF.IN), most large NBFCs are well placed to meet the proposed dividend cap if the guidelines are made applicable from the previous year.

*New Circular, New Loopholes: The Reserve Bank of India (RBI) has proposed capping non-bank financial company (NBFC) dividend payout ratios to a maximum of 50%. The methodology is predicated on the net NPL ratio and CAR. The new proposal is riddled with loopholes, as NBFCs can easily manipulate these ratios; and*Well-Placed NBFCs: Excluding LIC Housing Finance (LICHF.IN) and Shriram Transport (SHTF.IN), most large NBFCs are well placed to meet the proposed dividend cap if the guidelines are made applicable from the previous year.

Reserve Bank of India – Nothing Changes

Head of Research, IPOs & Placements, Aequitas Research

Sumeet Singh

Head of Research, IPOs & Placements

IPOs and Placements coverage across Asia Pacific

Aequitas Research

We cover all listing across the Asia Pacific along with follow-up placements. As of Dec 2020, our team had covered 539 IPOs with a hit rate of 73.5% and 685 placements with a hit rate of 66.8%.

We combine fundamental bottom-up views with our proprietary quantitative framework to provide a holistic coverage across new listings and placements. Our coverage includes pre-IPO notes before the deal is launched, follow-up analysis once the deal is live and post-listing trading analysis as well.

Equity Capital Markets

Home First Finance / Equity Capital Markets

<div>Home First Finance (HFF) is an affordable housing finance company targeting first time home buyers in low and middle-income groups. The company aims to raise around US$200m in its India IPO. It is backed by True North, GIC and Bessemer and has recently obtained an investment from Warburg Pincus as well.</div><div>HFF has grown rapidly over the past few years, driven by an expansion in its branch network and large number of new customers. Over FY17-19, HFF’s loan grew at CAGR of 70%, while its earnings grew even faster with NII growing at 76.2%, PPoP at 145% and PAT at 160% CAGR.  It still remains largely focussed on housing loans and has pristine asset quality.</div><div>
However, its funding sources lack diversity and its margin is artificially inflated by its high capitalisation. Furthermore, the company talks a lot about tech but a lot of its functions appear to be still very contact heavy and hence, salesforce/customer service dependant.
I have covered various aspects of the deal in, <a href="https://www.smartkarma.com/insights/home-first-finance-pre-ipo-riding-on-affordable-housing" target="_blank" rel="noopener">Home First Finance Pre-IPO - Riding on affordable housing</a>. In this note I’ll talk about the updates from the company’s re-filed DRHP.
</div>

Home First Finance (HFF) is an affordable housing finance company targeting first time home buyers in low and middle-income groups. The company aims to raise around US$200m in its India IPO. It is backed by True North, GIC and Bessemer and has recently obtained an investment from Warburg Pincus as well.HFF has grown rapidly over the past few years, driven by an expansion in its branch network and large number of new customers. Over FY17-19, HFF’s loan grew at CAGR of 70%, while its earnings grew even faster with NII growing at 76.2%, PPoP at 145% and PAT at 160% CAGR.  It still remains largely focussed on housing loans and has pristine asset quality.
However, its funding sources lack diversity and its margin is artificially inflated by its high capitalisation. Furthermore, the company talks a lot about tech but a lot of its functions appear to be still very contact heavy and hence, salesforce/customer service dependant.
I have covered various aspects of the deal in, Home First Finance Pre-IPO - Riding on affordable housing. In this note I’ll talk about the updates from the company’s re-filed DRHP.


Home First Finance Pre-IPO - Earnings Not Showing the COVID Strain but Other Metrics Are

Equity Bottom-Up

*Management Call Doesn’t Allay Fears: FY 2Q21 results were significantly driven a loan loss provision decline of INR 18.1 bn (16.0%) despite much weaker credit metrics.  We find that reserves were light in the neighborbood of INR 1.1 tn  - nearly four years of pre-tax results or 61% of market-cap. The recent virtual call held by a competitor unfortunately did not allay our concern; and*Other Items Discussed: State Bank of India (SBIN.IN) [SBI] did reiterate its guidance for problem loan formation (slippages and restructuring) at 2.5% of loans outstanding in FY21. While SBI’s CET 1 ratio stood at 10.5% as of FY 2Q21,our calculated loss reserve shortfall would suggest that SBI has further wood to chop in this area.In addition, SBI is confident that it will be able to enhance its digital platform YONO into a more robust and scalable platform.

*Management Call Doesn’t Allay Fears: FY 2Q21 results were significantly driven a loan loss provision decline of INR 18.1 bn (16.0%) despite much weaker credit metrics.  We find that reserves were light in the neighborbood of INR 1.1 tn  - nearly four years of pre-tax results or 61% of market-cap. The recent virtual call held by a competitor unfortunately did not allay our concern; and*Other Items Discussed: State Bank of India (SBIN.IN) [SBI] did reiterate its guidance for problem loan formation (slippages and restructuring) at 2.5% of loans outstanding in FY21. While SBI’s CET 1 ratio stood at 10.5% as of FY 2Q21,our calculated loss reserve shortfall would suggest that SBI has further wood to chop in this area.In addition, SBI is confident that it will be able to enhance its digital platform YONO into a more robust and scalable platform.

State Bank of India – Reserve Shortfall Needs To Be Addressed

It was unfortunate that <a href="https://www.smartkarma.com/entities/hdfc-bank-ltd-4b6b7a92-9087-468d-9dbe-ab169e77f014" target="_blank" data-smartkarma-citation="entities:558:1" rel="noopener">HDFC Bank (HDFCB IN) </a>decided to provide selective disclosure at a <a href="https://www.bseindia.com/xml-data/corpfiling/AttachHis/bb1870e3-1806-443f-8dc0-c81358e0d28a.pdf" target="_blank" rel="noopener">conference call</a> hosted by Jefferies. Only 63 institutional investors participated on the evening of December 9, 2020, where the bank publicly disclosed what went wrong at its recent digital outages. More importantly, in the opinion of this analyst, it provided market sensitive information in the form of the time span it would take to rectify some of the information technology issues raised by the Reserve Bank of India (RBI).  The bank disclosed the conference audio link to the exchanges nearly 16 hours later (at the latter half of the trading day). Such sensitive information should have been disclosed via a specially arranged press conference followed by an analyst conference, instead of providing such information to an exclusive audience of 63 institutional investors. Pertinently, HDFC Bank’s share price on December 10 closed 1.5% lower than the previous day, as compared with a 0.4% fall in the Nifty-50. This analyst understands that in future the Bank will disburse such information through a wider dissemination rather than such selective disclosure.At the conference call, the Bank acknowledged that its critical disaster recovery system required manual intervention to be activated, and that it would take 3 weeks for the automation to be implemented. This is a very important disclosure as this was not communicated to customers in its  <a href="https://v1.hdfcbank.com/htdocs/common/other/download/app1.html" target="_blank" rel="noopener">'Forget Cash...Go Digital'</a>  publicity campaign or in its ‘Digital 2.0’ strategy to stakeholders. It is disappointing that even though the RBI released guidelines for Business Continuity Planning (BCP) in <a href="https://www.rbi.org.in/SCRIPTs/BS_CircularIndexDisplay.aspx?Id=6366" target="_blank" rel="noopener">April 2011</a>, more than 9 years later, India’s most valuable bank, which markets its digital prowess, has been found to being so exposed and vulnerable at its backbone of banking operations.

It was unfortunate that HDFC Bank (HDFCB IN) decided to provide selective disclosure at a conference call hosted by Jefferies. Only 63 institutional investors participated on the evening of December 9, 2020, where the bank publicly disclosed what went wrong at its recent digital outages. More importantly, in the opinion of this analyst, it provided market sensitive information in the form of the time span it would take to rectify some of the information technology issues raised by the Reserve Bank of India (RBI).  The bank disclosed the conference audio link to the exchanges nearly 16 hours later (at the latter half of the trading day). Such sensitive information should have been disclosed via a specially arranged press conference followed by an analyst conference, instead of providing such information to an exclusive audience of 63 institutional investors. Pertinently, HDFC Bank’s share price on December 10 closed 1.5% lower than the previous day, as compared with a 0.4% fall in the Nifty-50. This analyst understands that in future the Bank will disburse such information through a wider dissemination rather than such selective disclosure.At the conference call, the Bank acknowledged that its critical disaster recovery system required manual intervention to be activated, and that it would take 3 weeks for the automation to be implemented. This is a very important disclosure as this was not communicated to customers in its  'Forget Cash...Go Digital'  publicity campaign or in its ‘Digital 2.0’ strategy to stakeholders. It is disappointing that even though the RBI released guidelines for Business Continuity Planning (BCP) in April 2011, more than 9 years later, India’s most valuable bank, which markets its digital prowess, has been found to being so exposed and vulnerable at its backbone of banking operations.

Selective Disclosure of Sensitive Information? HDFC Bank’s Conference Call on Its Digital Outages

India

HDFC Bank Ltd. offers a wide range of services to the global corporate sector. The Bank provides corporate banking and custodial services and is active in the treasury and capital markets. HDFC also markets project advisory services and capital market products such as Global Deposit Receipts, Euro currency loans, and Euro currency bonds.

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HDFC Bank (HDFCB IN)

HDFC Bank: Honey, I Shrunk the Chief Risk Officer

HDFC Bank with full support of its boards of directors, has undermined the foundations of the Chief Risk Officer by taking away the core credit...

Hemindra Hazari

Reserve Bank of India – Nothing Changes

RESERVE BANK OF INDIA: New proposed dividend cap on Nonbank financials companies, while trying to rein-in systemic risk, is laden with loopholes.

Thomas J. Monaco

Home First Finance Pre-IPO - Earnings Not Showing the COVID Strain but Other Metrics Are

Home First Finance is an affordable housing finance company targeting first time home buyers. It aims to raise US$200m in its India IPO. It is...

Sumeet Singh

State Bank of India – Reserve Shortfall Needs To Be Addressed

STATE BANK OF INDIA: Recent Call Suggests No Real Progress On Significant Reserve Shortfall, And That Another Capital Raise Not Out Of Question

Thomas J. Monaco

Selective Disclosure of Sensitive Information? HDFC Bank’s Conference Call on Its Digital Outages

HDFC Bank provided sensitive information in the form of the time span it would take to rectify some of the IT issues raised by the RBI at a sell...

Hemindra Hazari

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