To The Governor

Reserve Bank of India

Date: 12.05.2023

Dear Sir,

I take this as an opportunity to thank RBI for their continuous support and guideline to us to make our
operations smooth and mitigate the risk. Thank you for the opportunity provided to us to share with
you a few of the issue we are facing.

Sir,

Mann Deshi Mahila Sahakari Bank ltd (Mann Deshi) was formed in 1997 by and for rural women and
promoting members of Mann Deshi are all low income group women having hardly any exposure and
opportunity of higher education. Mann Deshi always dedicated itself to provide the banking facility to
empower women by providing them the micro saving, micro credit, micro pension and micro
insurance. Priority sector lending of Mann Deshi has always been more than 90%.Our majority of
member has first generation banking account

Understanding the fact that only financial elements will not help in broader financial inclusion and
women empowerment, we included financial literacy training and technical assistance services to our
customers, later on we included digital financial literacy program for our customer. We work in rural
area with business correspondence model (We call it Bank Sakhi program).Our Bank Sakhi works with
micro ATM and are facilitating micro withdrawal ,micro saving/deposit, saving account , RD, FD, Utility
bill payment at door step. We provide technical assistance to our customer as well. Mann Deshi
foundation is helping the bank in non-financial training part. We offer our customer UPI, Mobile
banking, CTS, NEFT and RTGS, ATM etc state of art banking services

As on 31st March 2023 we have loan book of Rs. ------------- Deposit of Rs.----------------.Average loan per
customer is Rs. --------------------------.Total member is ---------------------. And our Net worth is Rs. --------
-.We have been consistently profitable,

I take this as an opportunity to bring about in your kind notice a few of the issues we face to have an
expectation that RBI makes review of it.

1. Business Correspondence: Considering the technological development we think that bank can now
serve its customer even at places located more than 30 km of distance from mother branch .Need of
business correspondence is more at distant places rather than nearer places. We are still allowed to
work within a radius of 30 km in rural area and 5 Km in urban area. Ours is a cooperative bank
dedicated to serve women from underserved category of society. This restriction is an impediment to
serve the underserved women beyond 30 km of radius in rural area. We are technologically able to
serve these women with the entire bank’s product at doorstep

We can’t appoint profitable organization as our business correspondence. We believe that Profitable
organizations work with more efficiency than non-profit organization. They can provide dedicated
services to the bank as institutional business correspondent. One institution can work at multiple
locations
 Commercial banks are allowed to work beyond 30 km of operational area and can engage profitable
organization as institutional business correspondence. This makes us less competitive as compared to
commercial banks

In context of above three points we request you

1. To increase the BC service area beyond 30KM for cooperative bank also
2. To allow to engage profitable organization as BC for better efficiency

This modification will make cooperative bank able to serve those customer who are still underserved
beyond 30 KM of radius from mother branch. This will also make cooperative bank competitive with
commercial bank in the segment.

(Ref:RBI Circular RBI/2010-11/308 UBD.BPD. (PCB). Cir. No 28/09.18.300/2010-11 December 10,

2010. (Appointment of business Correspondence: BC)

2. Housing loan priority sector limit: The loans for Housing to the tune of Rs. 28 lakhs and Rs. 10 lakhs
for metro city and Rs. 6 lakhs for non-metro cities for repair of housing is being considered as Priority
Lending. In fact, considering the present inflationary situation, within this stipulated limit, nobody can
purchase or build a house and even cannot repair one's house. Considering this, banks will face
problem in achieving 90% of PSL (specifically in our case we need to have 90% PSL to enjoy enhanced
limit on micro loan).

Therefore, it is our sincere request to give serious thought to the point and these limits need to be
enhanced considerably.

India is presiding G 20 this year, in G 20 empower, our chairman Mrs. Chetna Gala Sinha is chairing
the financial inclusion and women entrepreneurship group under that G-20 empower is also showing
the case study of prime minister scheme under which women is getting house hold property and also
additionally getting household collateral.

3. Extension of government schemes: UCB are not still on boarded for implementation of different
government schemes like subsidy to farmers, credit guarantee schemes, (as our member hardly has
collateral to offer bank for bigger ticket size loan. This will help those women to access bigger ticket
size loan), free membership to UID or any other schemes. We are equipped with the technology to
comply the requirement of these schemes. We request RBI to onboard us too, to different government
schemes meant for bank.

4. Risk and objective based audit/inspection: RBI has shifted to risk and objective based inspection
of the UCB. We faced this inspection recently first time. The Inspection was based on credit risk market
risk and operational risk. We did not receive any guideline and training form RBI regarding this. A
guideline and training from RBI will help us prepare in a better way to mitigate these risk

5. Board tenure: New BR act of RBI has provision for 8 years for board. We elect board members
through election every 5 years. So getting election in next 3 years will be expedient .We request RBI
to make it 10 years so that every 5 years election will an automated route.

6. Individual Women Beneficiaries Exceeding Rs. 1 Lakh Needs to Be Considered As "Priority Section
Category".

As per the RBI circular No. RBI/FIDD/2020-21/72 FIDD.CO.BC.5/04/ 09.01/2020-21 Dated September
4, 2020, it has been advised that the "Individual women beneficiaries up to Rs. 1 lakh per borrower"
need to be considered as lending under Weaker Section Category. Further, the women are unable to
meet their financial exigencies in this short amount of Rs. 1 lakh. We request you to please look into
the matter to waive the restriction on the credit facility particularly availed to the individual women
beneficiaries and consider every credit facility as "Weaker Section" so as to emerge as strongest aspect
of the society as a whole. We request you to include even the OBC in within the cover of weaker
section loan

7. Gold Loan: Current RBI guideline limits UCB to disburse up to only Rs.2 lakhs loan with bullet
repayment facility only. In the villages the biggest asset of women is gold apart from land and they
come to mortgage gold to avail loan to meet either some medical emergencies or to invest in business.
Today the cost of hospitalization and treatment is very high even more than 2 lakhs. One buffalo costs
one lakh. Considering this we request RBI to allow us to disburse loan against gold up to Rs, 5 lakhs
with equated monthly installment basis repayment.

One again many thanks for the opportunity

With regards

Rekha S Kulkarni

CEO