Industry Research Desk: Regulatory authorities including Bangladesh central bank continued its efforts to improve the performance of the banking sector and ensure a sound, efficient and resilient financial system. In FY16, Bangladesh Bank (BB) adopted a number of policy measures to emphasise risk management and corporate governance in the banks, periodic review of stability of the individual bank as well as the whole banking system, stress testing, monitoring of large borrowers, fraud-forgeries and strengthening internal control and compliance through self assessment of anti-fraud internal controls.
Monitoring of investment in shares by the scheduled banks has been stringent in light of the amendment brought in the Bank Company Act, 1991 (amended up to 2013). Risk Management Committee at the board level has made mandatory, with regular evaluation. A revised risk guideline has already been put into effect for banks to improve resiliency. Besides, all core risks management guidelines including Asset Liability Management Guideline have been revised recently for timely identification, measurement, control and monitoring of all existing and probable risks of banks.
Banking Sector Performance
The banking sector in Bangladesh comprises four categories of scheduled banks- state-owned commercial banks (SCBs), state-owned development financial institutions (DFIs), private commercial banks (PCBs) and foreign commercial banks (FCBs). As of December 2016 there are 57 banks in Bangladesh and the number of bank branches increased to 9397 from 9040 as of December 2015 due mainly to opening of new branches by the banks during the year. At the end of June 2017, the total number of bank branches increased further to 9655.
In 2016, the SCBs held 27.5 percent share of the total assets which was the same as in 2015. PCBs’ share of the total assets increased from 63.3 percent in 2015 to 64.5percent in 2016. The FCBs held 5.2 percent share of the total assets in 2016, showing a decline of 0.3 percentage points over the previous year. The DFIs’ share of the total assets was 2.8 percent in 2016 against 3.7 percent in 2015 as one bank of this group was categorised as SCB.
Total deposits of the banks in 2016 rose to Tk 7928.6 billion from Tk 6965.1 billion in 2015 showing an overall increase of 13.8 percent. The SCBs’ share in deposits slightly increased from 28 percent in 2015 to 28.4 percent in 2016. PCBs’ deposits in 2016 amounted to Tk 5110.4 billion or 64.5 percent of the total deposit compared to Tk 4449.4 billion or 63.9 percent in 2015. FCBs’ deposits in 2016 slightly increased by Tk 10.8 billion over the year 2015 though its contribution to total deposits decreased to 4.3 percent from 4.7 percent. The DFIs’ deposits in 2016 was Tk 226.6 billion against Tk 237.6 billion in 2015 showing a decrease of 4.6 percent over the year.
Aggregate Balance Sheet
Total assets of the banking industry in 2016 have increased by 12.8 percent over 2015. During this period, the assets of the SCBs increased by 12.8 percent and those of the PCBs increased by 15.0 percent. Loans and advances stood at Tk 5846.2 billion which constituted the most significant portion (56.7 percent) of the sector’s aggregate assets of Tk 10314.7 billion. Cash in hand including foreign currencies was Tk 92.3 billion; deposits with BB were Tk 666.3 billion; other assets were Tk 1880.0 billion and investment in government bills & bonds were Tk 1830.0 billion.
Deposits served as the main sources of funds for the banking industry and constituted 76.9 percent (Tk 7928.6 billion) of total liability in 2016. Capital and reserves of the banks were Tk 753.5 billion (7.3 percent of the liability) in 2016 compared to Tk 741.3 billion (8.1 percent) in 2015.
Capital adequacy measures the loss absorption capacity of the banks, related to credit, market, operation, interest rate, liquidity, reputation, settlement, strategy, environment and climate change. Under Basel-III, banks in Bangladesh are instructed to maintain the Minimum Capital Requirement (MCR) at 10 percent of the Risk Weighted Assets (RWA) or Tk 4 billion as capital, whichever is higher. Under the Supervisory Review Process (SRP), banks are directed to maintain a level of “adequate” capital which is higher than the minimum required capital and sufficient to cover for all possible risks in their business. This higher level of capital for the banks is usually determined and finalized through SP-SREP (Supervisory Review Evaluation Process, the central bank’s assessment) dialogue. The amount of capital was Tk 753.5 billion at the end of December 2016.
On 31 December 2016, in aggregate, the SCBs, DFIs, PCBs and FCBs maintained CAR of 6.4, -32.0, 12.4 and 25.6 percent respectively. But individually, four SCBs, two PCBs and two DFIs did not maintain the minimum required CAR. The CAR of the banking industry as a whole was 10.8 percent at the end of December 2016 as against 11.3 percent at the end of 2015. The CAR of the industry was 10.3 percent at the end of June 2017.
Loans and advances constitute the largest share of assets. The high concentration of loans and advances can increase credit risk.
The most important measure of asset quality is in the non-performing loans (NPLs) ratio. At the end of December 2016, PCBs had the lowest and DFIs had the highest ratio of gross NPLs to total loans. PCBs’ gross NPLs to total loans ratio was 4.9 percent, whereas that of SCBs, FCBs and DFIs were 21.5, 7.8 and 23.2 percent respectively. The gross NPL ratios to total loans for the SCBs, PCBs, FCBs and DFIs were recorded as 25.7, 5.4, 8.3 and 26.1 percent respectively at the end of June 2017.
NPL had shown a declining trend from its peak (34.9 percent) in 2000 up to 2011 (6.1 percent). But the ratio increased in 2012 (10.0 percent), then decreased to 8.8 percent in 2016. The decline in NPLs to total loans ratio in recent years till 2011 can be attributed partly to some progress in recovery of long outstanding loans, write-off of loans classified as ‘bad’ or ‘loss’ and rescheduling and restructuring of non-performing loans. But it went up again in 2012 and 2014 due to the implementation of new loan classification and a few notable irregularities in the banking industry.
The SCBs and DFIs continued to have high level of NPLs mainly due to poor underwriting standards. Poor appraisal and inadequate follow-up and supervision of the loans disbursed by the SCBs and DFIs in the past eventually resulted in these poor quality assets. Furthermore, these banks were reluctant to write-off the historically accumulated bad loans because of poor quality of underlying collaterals. Recovery of NPLs has witnessed some signs of improvement, mainly because of the steps taken with regard to internal restructuring of these banks to strengthen their loan recovery mechanism and recovery drive and write-off measures initiated in recent years.
In 2016, the ratio of net NPLs (net of provisions and interest suspense) to net total loans (net of provisions and interest suspense) was 2.3 percent for the banking sector. DFIs’ ratio of net NPL to total loans decreased to 6.9 percent in 2016 from 25.5 percent in 2015. This significant decline of DFIs’ net NPL ratio to total loans occurred mainly because one of the DFIs has migrated into SCBs. The net NPLs to net total loan ratios were 9.2, 0.6 and -0.2 percent for SCBs, PCBs and FCBs at the end of December 2016.The ratios were 11.8, 10.8, 0.6 and 0.9 percent for SCBs, DFIs, PCBs and FCBs respectively at the end of June 2017.
The amount of NPLs of the SCBs increased from Tk 127.6 billion in 2008 to Tk 272.8 billion in 2016. The amount of NPLs of the PCBs increased by Tk 196.3 billion to Tk 253.3 billion in 2016 from Tk 57.0 billion in 2008 while those of the DFIs increased to Tk 49.7 billion in 2016 from Tk 37.3 billion in 2008. The amount of NPLs of the FCBs increased from Tk 2.9 billion in 2008 to Tk 18.2 billion in 2016.The amount of NPLs of SCBs, DFIs, PCBs and FCBs stood at Tk 300.8, 58.2, 253.2 and 21.6 billion respectively at the end of June 2017.
The required loan loss provision and the actual provision maintained by the banks from 2008 to 2016. There were gaps in the adequate provisioning. Banks maintained 92.7 percent of the required provisions in 2008 which increased thereafter to 103.0 percent in 2011, then declined to 99.0 percent in 2013 and 86.1 percent in 2016. In June 2017, it increased again 87.7 percent.
The main reason for the shortfall in provision against NPLs was the inability of some SCBs, DFIs and PCBs including those in the problem bank category due to inadequate profits and provision transfer for write-offs. On the other hand, the FCBs were in a much better position as they were able to make adequate provisions. A comparative position of loan loss provisions at the end of 2014, 2015 and 2016.
37 out of 39 PCBs were able to maintain the required provision at the end of December 2016, but the remaining two failed due to their poor asset portfolios and earning levels.
A uniform guideline for write-off was introduced in 2003 to create resilience in the banking system. According to the policy, banks may write off bad and loss loans at any time. The loans classified as bad and loss for the last 5 years or more with 100 percent provisions embarked are written-off.
It is difficult to conclusively draw any conclusion about the quality of management based solely on the quantitative indicators. Nevertheless, the total expenditure to total income, operating expenses to total expenses, earnings and operating expenses per employee, and interest rate spread are generally used to determine management soundness. Technical competence and leadership of mid and senior level management, compliance with plan and response to changing circumstances are also taken into consideration in evaluating the quality of management.
In 2016, the expenditure-income (EI) ratio of the DFIs was the highest among the bank categories which was mainly attributable to high administrative and operating expenses.
The EI ratio of the DFIs increased from 99.5 percent in 2015 to 113.9 percent in 2016. In 2016, the EI ratio of SCBs, PCBs and FCBs were 84.5 percent, 75.5 percent and 47.0 percent respectively which remained almost unchanged as compared to the previous year. At the end of June 2017, the EI ratio of SCBs and DFIs increased to 99.2 and 132.2 percent respectively whereas those of PCBs and FCBs decreased slightly to 73.5 and 45.0 percent respectively.
Earnings and Profitability
Although there are various indicators of earnings and profitability, the most representative and widely used one is return on assets (ROA), which is supplemented by return on equity (ROE) and net interest margin (NIM).
Earnings as measured by ROA and ROE differ greatly within the banking industry. Analysis of these indicators reveals that the ROA of the SCBs and DFIs was less than the industry average. The ROA of SCBs and DFIs have not improved much. PCBs’ ROA showed a consistently strong position up to 2010, but it was in a decreasing trend during 2011-2012 due to declining net profit. But after 2012 it is consistently increasing. FCBs’ ROA had been consistently strong during the last couple of years.
ROE of the SCBs was -1.5 percent in 2016, but improved compared to negative 13.6 percent in previous year. ROE of the DFIs was also negative. ROE of the PCBs slightly increased to 10.8 percent in 2016 from 10.3 percent in 2015. ROE of the FCBs declined to 14.6 percent in 2016 from 17.7 percent in 2015.
Aggregate net interest income (NII) of the banking industry in 2016 stood at Tk 292.9 billion which was Tk 274.2 billion in 2015. NII of the SCBs increased to Tk 40.4 billion in 2016 from Tk 39.7 billion in 2015. NII of the DFIs decreased to Tk 1.7 billion in 2016 from Tk 2.1 billion in the previous year. PCBs held the major portion (76.0 percent) of NII in 2016 like previous years. NII of the PCBs increased to Tk 222.6 billion from Tk 205.8 billion in the last year. NII of FCBs also increased slightly from Tk 26.6 in 2015 to Tk 28.2 billion in 2016.
SCBs have been able to increase their net interest income (NII) by reducing their cost of funds from 2008 to 2011. In 2012, the NII of SCBs dropped, and deteriorated afterwards. The NII of the PCBs had been significantly high since 2008. Overall NII of the banking industry showed a consistently upward trend from 2008 to 2016 though it went reverse in 2013 due to a lackluster performance of the SCBs.
Currently, the scheduled commercial banks have to maintain a CRR (cash reserve ratio) averaging 6.5 percent daily on a biweekly basis against average total demand and time liabilities (ATDTL) of the second preceding month, with an obligation to maintain daily minimum 6.0 percent cash against the same ATDTL held by the bank. The current rate of SLR (statutory liquidity reserve) for conventional banks is 13 percent of ATDTL. In case of Islamic Shariah-based commercial banks, the rate of SLR is 5.5 percent of their ATDTL. Three banks (two specialised banks and BDBL) are exempted from maintenance of SLR, but they have to maintain the CRR at the stated rate. The banks maintain CRR in cash with Bangladesh Bank. However, they are allowed to hold government approved securities (unencumbered portion) for maintenance of the SLR.
The FCBs have the highest liquidity ratios followed by the SCBs. There is an overall steady trend in the percentage of liquid assets in total assets of the banks during the last year although the ratio for DFIs is zero as they do not need to maintain SLR.
CAMELS rating is a supervisory tool to identify to improve financial health of banking industry. The previous CAMELS rating guideline has been reviewed by the Department of Off-site Supervision of central bank with a view to adopting international best practices, upgrading with modern banking activities and assessing the banks’ soundness more accurately. The updated CAMELS rating guideline has been followed since December 2013.
The revised CAMELS rating guideline has brought not only major changes in ratios or indicators but also modifications in the qualitative evaluation questionnaire. Basel-III principles related to capital adequacy have been reflected in the guideline. Along with emphasising best quality capital, investments in the capital market, the amount of off balance sheet items in comparison to the capital of the banks, large loan exposures to capital are considered to calculate capital adequacy. HHI (Herfindahl-Hirschman Index) has been incorporated in the updated CAMELS rating guideline to analyse loan portfolio concentration, as a complement to percentages of classified loans and provisioning in the evaluation of asset quality. The amount of loan disbursed to different risk associated sectors has been included as well.
Under this rating system, banking companies are assigned two sets of ratings- (i) performance ratings, based on six individual ratings that address six components of CAMELS — capital, assets, management, earnings, liquidity and sensitivity to Market Risk and (ii) an overall composite rating, based on a comprehensive assessment of the overall condition of the banking company.
Both ratings are expressed by using a numerical scale of “1” to “5” in ascending order of supervisory concern, “1” representing the best rating, while “5” indicating the worst. Any bank rated 4 or 5, i.e., ‘Marginal’ or ‘Unsatisfactory’ under the composite CAMELS rating is generally identified as a problem bank, and the activities of these banks are closely monitored by central bank.
Bangladesh Bank has introduced the early warning system (EWS) since March 2005 to address the difficulties faced by the banks in any of the areas of CAMELS. Any bank found to have difficulty in any areas of operation, is brought under the Early Warning category and monitored very closely to help improve its performance. Presently, no banks are monitored under EWS.
In December 2016, CAMELS rating, 7 banks were rated ‘1’ or ‘Strong’; the rating of 32 banks was ‘2’ or ‘Satisfactory’; rating of 10 banks was ‘3’ or ‘Fair’; five banks were rated ‘4’ or ‘Marginal’ and 3 banks received the rating of ‘5’ or ‘Unsatisfactory’.
Risk Based Capital Adequacy (RBCA) for Banks
To comply with international best practices and to improve financial stability, Bangladesh Bank has commenced implementation of Basel III capital adequacy framework since January 2015. According to Pillar-1 of Basel-III, RWA of banks is calculated against credit risk, market risk, and operational risk. BB announced the Roadmap for implementing Basel III in Bangladesh and issued Guidelines on Risk Based Capital Adequacy (Revised Regulatory Capital Framework for banks in line with Basel III) in 2014. After successful completion of Basel-II in December 2014, BB has started implementation of Basel-III in a phased manner which has already been started since January 2015.
Banks were instructed to submit their Capital Adequacy Statements to BB following new Basel-III accord from the quarter ended in March 2015. At the end of June 2017, CRAR of the banking industry stood at 10.3 percent while CET1 was 7.5 percent which fulfilled Basel-III capital adequacy requirements. However, at individual level, seven banks out of 57 scheduled banks failed to maintain CET1 and CRAR requirements as per Basel-III.
In order to avoid building-up excessive on and off-balance sheet leverage in the banking system, a simple, transparent, non risk based leverage ratio has been introduced. In Bangladesh the minimum requirement of leverage ratio is 3 percent. Instructions mentioned in the Guidelines will be adopted phase by phase, with full implementation of capital ratios by December 2019. Phase-in-arrangement of minimum capital requirements is depicted. Under the new capital adequacy framework, all banks will be required to maintain the following ratios on an ongoing basis:
i. Common Equity Tier-1 (CET1) of at least 4.5 percent of the total RWA.
ii. Tier-1 capital will be at least 6 percent of the total RWA which means that additional Tier-1 capital can be admitted maximum up to 1.5 percent of the total RWA or 33.33 percent of CET-1, whichever is higher.
iii. Minimum capital to risk-weighted asset ratio (CRAR) of 10 percent of the total RWA i.e. Tier-2 capital can be admitted maximum up to 4.0 percent of the total RWA or 88.89 percent of CET-1, whichever is higher.
iv. In addition to minimum CRAR, Capital Conservation Buffer (CCB) of 2.5 percent of the total RWA is being introduced which will be maintained in the form of CET-1.
Considering the recent scenario of country’s banking industry, section 3.3 of Guidelines on Risk Based Capital Adequacy has been revised as “the entire general provision maintained against unclassified loans and advances as per regulations will be considered as capital under Tier-2”.
The Supervisory Review Evaluation Process (SREP) of BB includes dialogue between BB and the bank’s SRP team, followed by findings and evaluation of the bank’s Internal Capital Adequacy Assessment Process (ICAAP). During the SRP-SREP dialogue, BB reviews and determines any additional capital that would be required for banks on the basis of quantitative as well as qualitative judgment. The first SREP dialogue was initiated in 2011. Afterwards, to facilitate the dialogue, BB prepared a revised evaluation process document in May 2013.
Under the process document, BB provided guidance to calculate required capital against residual risk, credit concentration risk, interest rate risk, liquidity risk, reputational risk, settlement risk, strategic risk, appraisal of core risk management practice, environmental & climate change risk and other material risks in a specified format and to submit the same to BB. Information of banks’ ICAAP is counter checked with the information available from both on-site inspection and off-site supervisory departments of BB. During the SRP-SREP dialogue, if the bank fails to produce their own ICAAP report backed by proper evidence and rigorous review regarding risk management, the SREP team of BB applies their prudence and also uses the available information from the inspection departments in determining the adequate capital. The process document was further revised in May 2014. On the basis of the revised process document and return format, all 57 banks submitted their ICAAP report based on 31 December 2014 and one to one meeting with BRPD and SRP team of 57 banks have already been completed.
Loan Classification and Loan-Loss Provisions
BB has changed its policies on loan classification and loan-loss provisions near the end of FY13. BB also introduced and clarified the difference between a “defaulted loan,” which is a legal concept granting the bank the right to take certain actions against the borrower, and a “classified loan,” which is an accounting concept that implies a certain required level of provisioning for expected losses.
Loan restructuring policy for large borrowers having multiple bank exposures was revised. Considering the contribution of the large borrowers to the socio-economic development and employment generation of the country, and to support the loan recovery efforts of the banks, the Board of Directors of Bangladesh Bank recommended necessary policy support in line with international best practices for the affected large borrowers.
Accordingly, large loan restructuring policy was issued and was valid till 30 June 2016. According to the policy, loans of a particular borrower or group in a bank, singly or in clubbed together form, shall be eligible for restructuring. Borrower having exposure in multiple banks may also be eligible for loan restructuring by forming a consortium.
Minimum outstanding loan amount for restructuring shall be Tk 5 billion or above in aggregate. Under this policy, banks can provide restructuring facility to a particular loan account only once and the restructured loan shall have a maximum tenure of twelve years for term loan(s); in case of demand and/or continuous loan(s), the tenure shall be maximum six years. However, borrowers indulging in frauds and forgeries will not be eligible for loan restructuring. Under the large loan restructuring policy, Tk 145.7 billion has been restructured with the approval of Bangladesh Bank. Respective banks have recovered Tk 1.9 billion as down payment and Tk 5 billion as installment from various borrowers up to 30 June 2017. Almost of the borrowers are enjoying moratorium period, the recovery of installment from all borrowers have not been fully started yet.
Corporate Governance in Banks
Bangladesh Bank has undertaken a number of measures in the recent years to establish good corporate governance in the banking sector. These include a “fit and proper” test for appointment of chief executive officers of PCBs, specifying the constitution of audit committee of the Board, enhanced disclosure requirements, etc. In continuation of the above reforms, the roles and functions of the board and management have been redefined and clarified with a view to specifying the powers of the management and restricting the intervention of directors in day to-day management of the bank. In this connection, related clauses of the Bank Company Act, 1991 have already been amended.
Supervision of Banks
With a view to promoting and maintaining soundness, solvency and systematic stability of the financial sector as well as protecting the interest of depositors, BB carries out two types of supervision namely
(i) off-site supervision and
(ii) on-site supervision.
Department of Off-site
Supervision (DOS) is vigilant to conduct offsite supervision on banks. Recently, DOS has made an innovation regarding banking supervision.
Off-site Monitoring of Banks
Off-site monitoring continued as a necessary complement to on-site inspection in FY16 with its various tools and procedures for intensive and rapid analysis of the financial health of the banking sector.
Banking Supervision Specialists
In order to strengthen banking supervision, BB has recently formed six Banking Supervision Specialist Sections in the Department of Off-site Supervision (DOS). Each section is headed by a Banking Supervision Specialist (BSS), at the Deputy General Manager level. Banking Supervision Specialists maintain extensive familiarity with the performance, risks, corporate governance and corporate structure of the portfolio banks.
They collect executive summary reports of comprehensive inspections carried out by Departments of Banking Inspection and take actions accordingly. They coordinate with inspection departments to get update on recent supervisory developments. Junior Banking Supervision Specialists monitor treasury functions, capital adequacy, ADR, etc. of the portfolio banks and prepare diagnostic review report (DRR) on audited financial statements. They also examine the internal control systems to improve its resilience.
5.44 BSSs monitor the progress of memorandum of understanding (MoU) with the SCBs and specialised banks and report the findings/progress of those banks immediately to the concern senior management. To enhance the standard of credit management and internal control system, a special inspection on internal control & compliance system of four state owned commercial banks (Sonali Bank Ltd., Janata Bank Ltd., Agrani Bank Ltd. and Rupali Bank Ltd.) was conducted by Bangladesh Bank. Meanwhile, the government has injected Tk 12 billion to BASIC Bank Ltd. in December 2015 as recapitalisation. On the other hand, BKB and RAKUB are also being monitored and reviewed under the MoUs of FY16. Preparation of MoUs for BKB and RAKUB for FY17 is currently under process.
Risk Management Activities of Banks
Bangladesh Bank has issued six core risks management guidelines (revised during 2015-2016), risk based capital adequacy guideline and stress testing guideline to ensure robustness, efficiency and effectiveness of risk management systems for the banking sector. On 15 February 2012, BB issued another guideline called Risk Management Guideline for banks. This guideline promotes an integrated, bank-wide approach to risk management which will facilitate banks in adopting contemporary methods to identify, measure, monitor and control risks throughout their institutions.
In 2016, BB introduced two reporting formats in the name of comprehensive risk management report (CRMR) and monthly risk management report (MRMR) for banks in place of previous risk management paper (RMP). To make the risk management activities more effective, various types of contemporary risk issues and a questionnaire (related to risk management structure, credit policies & procedures, evaluation process of credit proposals, post sanction process, follow up & monitoring of loans, operation level risk verifications, liquidity risk, etc.) are included in the CRMR which is submitted on a half-yearly basis. To ensure close monitoring, BB is analysing the risk management of banks on a monthly basis along with half-yearly basis.
Recently, banks have been instructed to determine their risk appetite on a yearly basis for all possible measurable risk areas in line with the objectives of business growth and to send the statement to DOS by the end of first quarter of every year after taking board approval.
Banks have been instructed to establish Risk Management Division (RMD) in place of previous Risk Management Unit and to appoint a chief risk officer (CRO) from a senior management position (at least from the Deputy Managing Director level) to give more emphasis on risk management practices. BB has instructed the banks to form a risk management committee whose members will be nominated by the board of directors from themselves and the company secretary of the bank will be the secretary of the risk management committee. DOS regularly evaluates the risk management activities of each bank based on the CRMR and MRMR and provides constructive recommendations to improve their conditions. Banks have to execute all the recommendations and submit their compliance reports within a specified time frame.
A risk rating procedure has been developed to quantify all possible risks based on available information in the CRMR, minutes of RMD and board risk management committee meetings, compliance status of previous quarters submitted by banks and other sources. This risk rating is done on a half yearly basis and carries 15 percent weight in the management component of CAMELS rating. Therefore, a bank’s risk management practices will have a significant effect on its CAMELS rating. Besides, this rating plays an important role in getting branch licence, AD licence, permission for dividend declaration, etc. for banks. According to the rating of December 2016, out of 57 scheduled banks, 24 banks were rated as low risk, 23 as moderate and the rest nine as high risk category banks.
Banks are now bound to submit a self-assessment report on internal control systems. The objective of this self-assessment process is to keep the operational risk at a minimum level by strengthening the internal control and compliance system of a bank. In this regard, BB has formulated a reporting format with 53 questionnaires on anti-fraud internal controls and a statement of fraud and forgeries that have taken place during a period along with the action taken against those incidences. BB is analysing these reports on a quarterly basis and providing proper instructions to the banks. The information provided in that report is sent to the on-site supervision departments for verification through on-site inspection also.
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