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IMPACT OF RBI’s LENDING GUIDELINES

9th September, 2023

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Picture Courtesy: timesofindia.indiatimes.com

Context: The Reserve Bank of India (RBI) has announced new rules that will allow borrowers to switch from a variable interest rate loan to a fixed interest rate one. The RBI said that this move was aimed at addressing the complaints of borrowers who faced longer loan tenures and/or higher EMIs when the benchmark interest rate went up.

Highlights of the Guidelines issued by the Reserve Bank of India (RBI)

  • Board-Approved Policy: Borrowers have the option to switch from floating interest rates to fixed interest rates for their loans, but this transition should be based on a policy approved by the lending entity's board. The policy outlines the conditions and procedures for borrowers to make this switch.
  • Limit on Switching: The lending entity's policy must specify the number of times a borrower can switch between interest rate mechanisms during the loan's tenure. This ensures that switching is not open-ended and is subject to clear limits.
  • Transparency in Charges: Lenders must transparently communicate all relevant charges associated with the transition. This includes interest rate changes, service charges, and administrative costs related to the switch. Borrowers should be fully aware of the financial implications of their decision.
  • Communication of Impact: When a borrower switches from a floating to a fixed interest rate, the lender must communicate the impact of this change. This should occur at the time of loan sanction, ensuring borrowers understand how the switch will affect their Equated Monthly Installments (EMI) and loan tenure.
  • Flexibility in Adjustments: Borrowers have the flexibility to choose how they want to adjust their loans when switching interest rate regimes. They can enhance their EMI, extend their loan tenure, or choose a combination of both options, tailoring their repayment to their financial situation and preferences.
  • Prepayment Option: Borrowers can prepay the loan partially or in full at any point during the loan tenure. However, prepayment may incur foreclosure charges or pre-payment penalties, leading to additional costs.
  • Quarterly Statements: Lending entities are required to provide borrowers with statements at the end of each quarter. These statements should include comprehensive information about the loan, such as principal and interest payments made, current EMI amount, remaining EMIs, and the annualized rate of interest/Annual Percentage Rate (APR) for the entire loan tenure. These statements should be easily understandable.
  • Applicability to Various Loans: These instructions apply to all equated installment-based loans with different periodicities. However, there may be variations in their application based on the nature of the loan, such as home loans, personal loans, or other types of loans.

Key difference between fixed and floating interest rates

Fixed Interest Rates

  • Fixed interest rates remain constant throughout the tenure of the loan. Once you lock in a fixed rate, your interest payments remain unchanged for the entire duration of the loan.
  • Borrowers benefit from predictability and certainty in their monthly payments. This stability helps in budgeting because borrowers know exactly how much they need to pay each month.
  • Fixed-rate loans provide borrowers with security against interest rate fluctuations. Regardless of how market interest rates change, your interest rate remains the same.
  • Fixed interest rates are typically higher than the initial rates offered by floating interest rate loans. For example, if the fixed rate for a home loan is 12%, it would remain at 12% for the entire loan tenure.

Floating Interest Rates

  • Floating interest rates are subject to market dynamics and are linked to a base rate, such as a benchmark interest rate set by the central bank or other financial indicators.
  • Floating interest rates are often initially lower than fixed rates. For instance, if the floating rate for home loans is 10.5%, it may start lower than the fixed rate of 12%.
  • Floating rates can change over time in response to fluctuations in market interest rates. If market rates decrease, borrowers benefit from lower interest payments. However, if market rates increase, borrowers may see higher interest costs.
  • Borrowers who choose floating interest rates face some level of risk associated with potential interest rate hikes. If interest rates rise significantly during the loan tenure, borrowers may experience higher EMIs.
  • Floating interest rate loans typically do not have prepayment penalties. Borrowers can prepay their loans, either partially or in full, without incurring additional charges.

The choice between fixed and floating interest rates depends on individual preferences and financial circumstances. Here are some considerations for borrowers:

  • Fixed Rate: Borrowers who prioritize stability, certainty, and long-term financial planning may prefer fixed-rate loans. This option protects against interest rate volatility but comes with a higher initial interest rate.
  • Floating Rate: Borrowers who are comfortable with some level of interest rate risk and believe that market rates may decrease or remain stable may opt for floating-rate loans. These loans often start with lower interest rates, potentially resulting in savings.

Borrowers need to assess their financial goals, risk tolerance, and expectations for interest rate movements before choosing between fixed and floating interest rates. Additionally, financial institutions are required to provide appropriate guidance and financial literacy to help borrowers make informed decisions regarding interest rate options.

Key points regarding RBI's stance on assessing repayment capacity

  • Mandatory Assessment: Lending entities, which include banks and financial institutions, are required to evaluate the repayment capacity of individuals applying for loans. This assessment is crucial to ensure that borrowers have the financial capability to meet their loan obligations.
  • Optimum Headroom/Margin: The goal of assessing repayment capacity is to provide borrowers with adequate or optimum headroom or margin. In other words, borrowers should have a reasonable buffer in their finances to accommodate changes in loan terms, such as elongation of the loan tenure or an increase in Equated Monthly Installments (EMI).
  • Consideration of Parameters: Lenders must take into account various parameters when assessing repayment capacity. One of these factors mentioned by Governor Shaktikanta Das is the age of the borrower. Assessing how long the borrower's payment capacity will last, especially considering their age and income stability, is crucial in determining the suitability of loan terms.
  • Avoidance of Unduly Long Elongation: RBI cautions lenders against granting loans with excessively long tenures, as this may mask underlying stress in a particular loan. While offering flexible options to borrowers is encouraged, elongation of the loan tenure should be for a "reasonable period" to maintain the loan's financial sustainability.
  • Commercial Decision: RBI acknowledges that determining repayment capacity and structuring loan terms is ultimately a commercial decision for banks and lending institutions. However, the central bank provides broad guidelines to ensure responsible lending practices and protect borrowers from entering into loans they cannot sustain.

Conclusion 

  • The RBI's new guidelines empower borrowers in India by allowing them to switch between floating and fixed interest rates with transparent communication on charges. Borrowers gain flexibility in choosing payment structures, including EMI enhancements and loan tenure elongation, albeit with potential prepayment penalties. The RBI's focus on assessing repayment capacity promotes responsible lending practices. These guidelines enhance borrower choices, transparency, and responsible lending, fostering a more consumer-friendly and informed lending environment in India.

Must Read Articles:

RBI’s Guidelines on Digital Lending and First Loss Digital Guarantee:  https://www.iasgyan.in/daily-current-affairs/rbis-guidelines-on-digital-lending-and-first-loss-digital-guarantee

SWITCH FROM FLOATING TO FIXED RATE REGIME: https://www.iasgyan.in/daily-current-affairs/switch-from-floating-to-fixed-rate-regime

FLOATING RATE LOANS: https://www.iasgyan.in/daily-current-affairs/floating-rate-loans

PRACTICE QUESTION

Q. How do floating-rate loans affect the risk and return profiles of both borrowers and lenders and what are the main factors that influence the pricing and demand of these loans in different market conditions? What are the potential benefits and drawbacks of introducing floating-rate loans in developing countries, and what are the best practices for ensuring their successful implementation and regulation?

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