DAMODARAM SANJIVAYYA NATIONAL LAW UNIVERSITY, SABBAVARAM,

VISAKHAPATNAM, A.P., INDIA

PROJECT TITLE:

LAW AND POLICY REGULATING THE URBAN COOPERATIVE BANKING IN

INDIA

SUBJECT:

LAW OF BANKING AND NEGOTIABLE INSTRUMENTS

NAME OF THE FACULTY:

PROFESSOR POOSARLA BAYOLA KIRAN

NAME OF THE CANDIDATE

SHEHNAZ TASNIM KHALEEL

ROLL NUMBER:

20LLB106

SEMESTER VI
 ACKNOWLEDGEMENT

I would like to express my sincere gratitude towards my Law of Banking professor, Mr

Poosarla Bayola Kiran, for his help and guidance throughout the making of this project. This
would have not been possible without his insight and kindness.
 TABLE OF CONTENTS

1. Abstract

2. Synopsis

3. Introduction

4. Duality of control on urban co-operative banks in India

5. Banking regulation (amendment) act, 2020

6. Regulatory framework by rbi

7. Conclusion

8. Bibliography

ABSTRACT
The term Urban Co-operative Banks (UCBs), though not formally defined, refers to primary
cooperative banks located in urban and semi-urban areas. These banks, till 1996, were
allowed to lend money only for non-agricultural purposes. They essentially lend to small
borrowers and businesses. Today, their scope of operations has widened considerably.
The origins of the urban cooperative banking movement in India can be traced to the close of
nineteenth century when, inspired by the success of the experiments related to the cooperative
movement in Britain and the cooperative credit movement in Germany such societies were
set up in India. Cooperative societies are based on the principles of cooperation, - mutual
help, democratic decision making and open membership. Cooperatives represented a new and
alternative approach to organization as against proprietary firms, partnership firms and joint
stock companies which represent the dominant form of commercial organisation.1
In this Project, we will see the law and policy regulating Urban Co-operative Banking in
India as well recent developments and suggestions for further improvement for this banking
sector along with statistical information.

SYNOPSIS

Objective of the Study

1
“TNAU Agritech Portal :: Banking & Credit” (TNAU Agritech Portal :: Banking & Credit)
<https://agritech.tnau.ac.in/banking/crbank_coop_urban_bank_home.html>.
 1. To understand what an Urban Cooperative Bank under Indian Banking Laws is.
2. To understand how a UCB may be regulated and controlled so that it complies to
normal banking standards in India.
3. To understand how RBI and State Governments work together to ensure cohesive
control over the licensing and functioning to protect depositors.

Literature Review

The researcher has gone through various dictionaries, journal articles and books

Research Methodology

It is a doctrinal form of research. The research methodology adopted mainly consists of

gathering information, analysing it and approaching a reasonable conclusion.

Style of Citation

Oxford style of citation has been done in this project. (OSCOLA 4th edn)

Scope of the Study

The study is limited to the Law AND Policy regulating the urban cooperative banking in
India.

Significance of Study

This study will help us in understanding what are rights and how they came to be and why
they are so important. It will make us see why collective security is so important and how it is
influenced by national security interests. The last thing would be to see which of the two is
more important in the long run.

Research Questions
1. Is the Banking Regulation (Amendment) 2020 adequate to meet the previously
existing statutory gaps?

INTRODUCTION

The first known mutual aid society in India was probably the 'Anyonya Sahakari Mandali'
organised in the erstwhile princely State of Baroda in 1889 under the guidance of Vithal
Laxman Kavthekar. Urban co-operative credit societies organised on a community basis to
meet the consumption-oriented credit needs of their members. From its origins then to today,
the thrust of UCBs, historically, has been to mobilise savings from the middle- and low-
income urban groups and purvey credit to their members - many of which belonged to
weaker sections. The enactment of Cooperative Credit Societies Act, 1904, however, gave the
real impetus to the movement. The first urban cooperative credit society was registered in
Canjeevaram (Kanjivaram) in the erstwhile Madras province in October 1904. The most
prominent amongst the early credit societies was the Bombay Urban Cooperative Credit
Society, sponsored by Vithaldas Thackersey and Lallubhai Samaldas established on January
23, 1906.2

The Cooperative Credit Societies Act, 1904 was amended in 1912, with a view to broad
basing it to enable organisation of non-credit societies. The Maclagan Committee of 1915
was appointed to review their performance and suggest measures for strengthening them. The
committee observed that such institutions were eminently suited to cater to the needs of the
lower and middle income strata of society and would inculcate the principles of banking
amongst the middle classes. The committee also felt that the urban cooperative credit
movement was more viable than agricultural credit societies. The recommendations of the
Committee went a long way in establishing the urban cooperative credit movement in its own
right. The Government of India Act in 1919 transferred the subject of "Cooperation" from
Government of India to the Provincial Governments. The Government of Bombay passed the
first State Cooperative Societies Act in 1925. Other States followed. This marked the
beginning of the second phase in the history of Cooperative Credit Institutions. There was the
general realization that urban banks have an important role to play in economic construction.
This was asserted by a host of committees. The Indian Central Banking Enquiry Committee
(1931) felt that urban banks have a duty to help the small business and middle-class people.
The Mehta-Bhansali Committee (1939), recommended that those societies which had
fulfilled the criteria of banking should be allowed to work as banks and recommended an
Association for these banks. The Co-operative Planning Committee (1946) went on record to
say that urban banks have been the best agencies for small people in whom Joint stock banks
are not generally interested. The Rural Banking Enquiry Committee (1950), impressed by the
low cost of establishment and operations recommended the establishment of such banks even
in places smaller than taluka towns. The first study of Urban co-operative banks was taken up

2
<http://pdvpmtasgaon.edu.in/uploads/dptsncommerce/ChapterNo-II.pdf>, accessed 1 April 2023.
by RBI in the year 1958-59. The Report published in 1961 acknowledged the widespread and
financially sound framework of urban co-operative banks; emphasized the need to establish
primary urban cooperative banks in new centres and suggested that State Governments lend
active support to their development. In 1963, Varde Committee recommended that such
banks should be organised at all urban centres with a population of 1 lakh or more and not by
any single community or caste. The committee introduced the concept of minimum capital
requirement and the criteria of population for defining the urban centre where UCBs were
incorporated.3

DUALITY OF CONTROL ON URBAN CO-OPERATIVE BANKS IN

INDIA

3
Ibid (n2)
Per Section 56 of the Banking Regulation Act, 1949 4 , a primary co-operative bank
(Urban Co-operative Bank or UCB) means a co-operative society, other than a
primary agricultural credit society, whose,

(i) Primary or principal business is a transaction of banking business.

(ii) Paid-up share capital and reserves of which are not less than one lakh of
rupees.
(iii) And the byelaws of which do not permit admission of any other co-
operative society as a member.

As stated above, co-operative banks, including Primary Co-operative Banks (Urban Co-
operative Banks or UCBs), are co-operative societies that transact the business of banking.
While co-operative credit societies provide financial accommodation to its members by
accepting deposits from its members and lending to them, co-operative banks provide
financial accommodation by accepting deposits from the public and lending to its members.
For a co-operative bank, the distinction between the deposit of a member and non-member
ceases and in view of the normal regulatory capital requirements applied to them, they are
able to work with a high leverage. As such, co-operative banks are exceptions in the co-
operative sector, wherein the resources used for lending and investment come from the public
rather than just their members. As per the Constitution, states can legislate on the
incorporation, regulation and winding up of co-operative societies. 5 States regulate co-
operative societies under their respective Co-operative Societies Acts, through the Registrar
of Co-operative Societies (RCS).  The first watershed moment in the evolution of regulatory
framework for co-operative banks in India came when they were brought under the purview
of the Banking Regulation Act, 1949 Act in the year 1966. Owing to certain characteristics of
the co-operative banks, distinct from the banking companies, a separate chapter was added in
the Act. Certain provisions of the Banking Regulation Act, 1949 (BR Act) were made
applicable to co-operative banks.6  This gave Reserve Bank of India (RBI) some powers to
regulate co-operative banks.   This was done to protect the interests of depositors and extend
deposit insurance coverage to these banks.  RBI regulates state co-operative banks, district
(central) co-operative banks and primary co-operative banks (also called urban co-operative
banks).  It regulates banking-related activities of these banks such as issuance of licenses for
new banks/branches and investment and loan policies.  RBI also prescribes norms for capital

4
Banking Regulation Act, 1949 s56
5
Entry 32, List II, Schedule VII.
6
Banking Laws (Application to Co-operative Societies) Act, 1965
adequacy, asset classification, liquidity requirements and exposure norms.7 However, some of
the important provisions, mainly related to governance, capital, audit and resolution including
winding up were not applied on the co-operative banks as RCS in each state regulates
incorporation, registration, management, recovery, audit, supersession of Board of Directors
and liquidation of co-operative societies registered with it.8

Since then, there is duality of control over these banks with banking related functions being
regulated by the Reserve Bank and management related functions regulated by respective
State Governments/Central Government. The regulation of co-operative banks by the RBI
(done by RBI’s Urban Banks Department) so far has largely been restricted to certain aspects
of their functions, mainly those directly related to ‘banking’, giving rise to the dual
regulation, with governance, audit and winding-up related functions largely being in the
domain of the State Governments in case of ‘single-state’ banks (i.e. banks whose area of
operation is confined to a single state) and the Central Government in case of multi-state
banks. Governance functions have rather been loosely regulated even by the Governments
because of the perception of them being democratic institutions. The Reserve Bank regulates
the banking functions of StCBs/DCCBs/UCBs under the provisions of Sections 22 and 23 of
the Banking Regulation Act, 1949 (As Applicable to Cooperative Societies (AACS). UCBs
are primarily registered as cooperative societies under the provisions of either the State
Cooperative Societies Act of the State concerned or the Multi State Cooperative Societies
Act, 2002 if the area of operation of the bank extends beyond the boundaries of one state.9

The legal status of co-operative banks is akin to banking companies in many ways. Both are
body corporates by the name in which they are registered, with limited liabilities, which can
sue and be sued in their own name, with independent legal personalities distinct from their
shareholders/members, with power to acquire, hold and dispose of property and enter into
contract. However, there are certain vital distinctions between the two types of banks,
primarily arising out of their structure, which need to be considered while formulating a
regulatory regime for UCBs. The most fundamental difference between the banking

7
‘Developments in Co-operative Banking, Report on Trends and Progress in Banking 2018-19, Reserve Bank of
India’, <https://rbidocs.rbi.org.in/rdocs/Publications/PDFs/05CHPT5_24122019878A5AF64EB74900B7AD6F
F7093EE45F.PDF.>, accessed April 1, 2023.
8
“Report of the Expert Committee on Urban Co-Operative Banks” (Chaired by Dr N S Vishwanathan, Reserve
Bank of India 2021) <https://www.rbi.org.in/Scripts/PublicationReportDetails.aspx?UrlPage=&ID=1185#F2>
accessed April 1, 2023.
9
<http://xn--https-hw3b//Rbi.Org.in/Scripts/FS_Overview.Aspx?Fn=2755%E2%80%9D%20%3Chttps://
rbi.org.in/scripts/FS_Overview.aspx?fn=2755%3E. > accessed April 1, 2023.
companies and co-operative banks is in the rights of the shareholders to vote in resolutions.
While in the case of a banking company, each share has a vote (subject to the limitations
imposed by Section 12 of the BR Act), in the case of a co-operative bank, each shareholder
has only one vote irrespective of the number of shares held.10

Major reasons for the failure of cooperative banks in India is the vague and unclear
distribution of regulatory powers over the Cooperative banks amongst the Registrar of
Cooperative Societies (ROCS) and the Reserve Bank of India (RBI).  While the Registrar of
Cooperative Societies regulate the administrative aspects of these banks, which include the
control of management elections and audit related matters, the RBI is empowered with
regulating the aspects pertaining to liquidity like license, maintaining cash reserve, statutory
liquidity and capital adequacy ratios, and inspection. This bifurcation of powers amongst two
regulatory bodies is termed as the problem of dual regulatory framework for regulating the
conduct of cooperative banks. With the enactment of the Banking Regulation (Amendment)
Act, 2020, the statutory gaps have been addressed to a very large extent. The amendment,
which was brought up in the backdrop of the PMC Bank scam, seeks to strengthen co-
operative banks by increasing professionalism, enabling access to capital, improving
governance and ensuring sound banking through the Reserve Bank of India.11 The
developments in the economy as a whole, and the banking sector, has paved its way to
modify the parent act. The Banking Regulation (Amendment) Act, 2020 replaced the
Banking Regulation (Amendment) Ordinance, 2020. Certain amendments were considered
necessary in the said Act to provide for better management and proper regulation of co-
operative banks and to ensure that the affairs of the co-operative banks are conducted in a
manner that protects the interests of the depositors, by increasing professionalism, enabling
access to capital, improving governance and ensuring sound banking through the Reserve
Bank of India.12

BANKING REGULATION (AMENDMENT) ACT, 2020

The Banking Regulation (Amendment) Bill, 2020 amends the BR Act to expand RBI’s
regulatory control over co-operative banks in terms of management, capital, audit and

10
Ibid (n8)
11
Nikuj Mehta, “Implications of the Banking Regulation (Amendment) Bill 2020 ” (blog.ipleaders.in, October
2020) <https://blog.ipleaders.in/implications-banking-regulation-amendment-bill-2020/
#History_of_dual_regulatory_framework_in_India>, accessed 2 April, 2023.
12
Banking Regulation (Amendment) Act, 2020.
liquidation. The Bill makes two kinds of changes: (i) extending previously omitted provisions
of the BR Act to co-operative banks, and (ii) amendments to certain provisions of the Act that
apply to all banks. 

Co-operative Banks

 Prescription of qualifications for management: Co-operative banks are excluded from

provisions of the BR Act with respect to conditions on employment and qualifications
for the Chairman and Board of Directors.  The Bill provides that co-operative banks
cannot employ as Chairman, someone who is insolvent or has been convicted of a
crime involving moral turpitude, among other restrictions.  It empowers RBI to
remove the Chairman if he is not fit and proper and appoint a suitable person if the
bank does not do so. 
 The Bill provides that the Board of Directors must have not less than 51% of
members who have special knowledge or practical experience in areas such as
accountancy, banking, economics or law among others.  It allows RBI to direct a bank
to reconstitute the Board if it does not conform to the requirements.  If the bank does
not comply, RBI may remove individual directors and appoint suitable persons.
 Supersession of Board of Directors: Under the BR Act, RBI is empowered to issue an
order to supersede the Board of Directors of multi-state co-operative banks for a
maximum period of five years and appoint an Administrator.  Multi-state co-operative
banks are co-operative banks with operation in two or more states, and are registered
under the Multi-State Co-operative Societies Act, 2002.  For other co-operative banks,
RBI may approach the RCS to supersede the Board.   The Bill extends RBI’s power to
supersede Board of Directors to all co-operative banks.  In case the bank is registered
with a state RCS, RBI may issue the order in consultation with the concerned state
government, seeking its comments within such period as specified by RBI.
 Audit and winding up: Under the Bill, audit of co-operative banks would be
conducted on par with scheduled commercial banks.  Accounts would be audited by a
qualified person and RBI approval would be required before appointing, re-appointing
or removing an auditor.  RBI may order a special audit for such transactions and such
periods as specified in the order.  Previously, RBI could issue an order for an
additional audit for co-operative banks, in addition to the audit required under Co-
operative Societies Acts. 
  The Bill makes applicable certain provisions relating to winding up and special
provisions for speedy disposal of winding up proceedings of banks will now be
applicable to co-operative banks. 
 Issuance of shares and securities: Co-operative banks are excluded from the provision
on issuance of shares and securities under the BR Act.  Other banks are allowed to
issue equity or preference shares and RBI is empowered to impose conditions on issue
of preference shares.  Voting rights are typically allotted on the basis of one share one
vote.  The Act (read with RBI Directions) imposes a ceiling of 15% on voting rights
exercised by an equity shareholder.  
 The Bill modifies the relevant provision of the BR Act to provide that co-operative
banks may, with prior approval of RBI, issue equity, preference or special shares at
face value or at a premium to members or other persons residing within the banks’
area of operation.   Banks may also issue unsecured debentures or bonds with
maturity of not less than 10 years.  Banks cannot withdraw capital without permission
from RBI.  Further, members are not entitled to payment from the bank against the
surrender of shares.   
Formulation of scheme for reconstruction or amalgamation without moratorium

 Under the BR Act, RBI may, after placing a bank under moratorium, prepare a
scheme for reconstruction or amalgamation of the bank.   This may be done to secure
proper management of the bank, or in the interest of depositors, general public, or the
banking system.  Banks placed under moratorium do not face any legal action for up
to six months.   Further, banks cannot make any payment or discharge any liabilities
during the moratorium.  The Bill allows RBI to initiate a scheme for reconstruction or
amalgamation of a bank without imposing a moratorium.
While RBI regulates licensing and loan policy, prescribes prudential norms and conducts
inspection of UCBs, it requires the assistance of RCS to act against the management, or
undertake restructuring or liquidation of these banks.  For effective regulation of UCBs, the
HPC (2015) had suggested that RBI be given powers to constitute and supersede the Board of
Directors, remove the Chairman, conduct audits, and wind up UCBs.  RBI exercises these
powers with regard to all other banks regulated under the BR Act.  The Bill empowers RBI to
exercise control over co-operative banks in terms of management, capital, audit and winding
up.  Note that such additional powers may increase pressure on the supervisory capacity of
RBI.   Currently, RBI regulates and supervises 86 scheduled commercial banks, 45 regional
rural banks and 10 small finance banks.  The Bill extends RBI’s regulation and supervision to
1,544 UCBs, 363 district (central) co-operative banks and 33 state co-operative banks. 13 In
Reserve Bank of India vs Big Kancheepuram Cooperative Town Bank Ltd 14, the Supreme
Court transferred all writ petitions which have been filed before various High Courts
challenging the validity of the Banking Regulation (Amendment) Act 2020 to the Madras
High Court. The court noticed that writ petitions in this matter are pending before the High
Courts of Andhra Pradesh, Chhattisgarh, Karnataka, Kerala, Madhya Pradesh, Madras,
Punjab and Haryana, Uttarakhand, Allahabad, Rajasthan and Bombay. The contentions raised
are mainly that (1) the Act takes away the legislative power of States under item 32 in List II
in the 7th schedule of the Constitution and whether it is liable to be declared as
unconstitutional. Another contention (2) Part IXB of the Constitution of India has been struck
down by the Supreme Court of India in Union of India Vs. Rajendra N. Shah15 where the
bench unanimously held that the 97th Constitutional Amendment required ratification by at
least one-half of the state legislatures as per Article 368(2) of the Constitution, since it dealt
with an entry which was an exclusive state subject (co-operative societies). Since such
ratification was not done in the case of the 97th Constitutional amendment, it was liable to be
struck down. and thus, the basis of promulgating Banking Regulation (Amendment) Act,
2020 has been struck down by the Supreme Court of India.

REGULATORY FRAMEWORK BY RBI

The UCBs are diverse in terms of their size and operations. Given this
heterogeneity, a differentiated regulatory regime is followed by RBI and thus, the
UCBs are categorised under Four Tiers as per the Revised Regulatory Framework -
Categorization of Urban Co-operative Banks (UCBs) for Regulatory Purposes notified 1
December, 2022. The UCBs can be split into four categories — Tier-1 All unit UCBs and salary
earner’s UCBs (irrespective of deposit size), and all other UCBs having deposits up to ₹100
crore; Tier-2 with deposits between ₹100- ₹1,000 crore, Tier-3 with deposits between ₹1,000

13
“The Banking Regulation (Amendment) Bill, 2020” (The Banking Regulation (Amendment) Bill, 2020,
September 14, 2020) <https://prsindia.org/billtrack/the-banking-regulation-amendment-bill-2020-1054>,
accessed 4 April 2023
14
2022 LiveLaw (SC) 850
15
LL 2021 SC 312
crore to ₹10,000 and Tier-4 with deposits of over ₹10,000 crore, the panel said.16 UCBs shall
have minimum net worth as under:

• Tier 1 UCBs operating in a single district shall have minimum net worth of ₹2 crore.

• All other UCBs (of all tiers) shall have minimum net worth of ₹5 crore.

• UCBs which currently do not meet the minimum net worth requirement, as above, shall
achieve the minimum net worth of ₹2 crore or ₹5 crore (as applicable) in a phased manner.
Such UCBs shall achieve at least 50 per cent of the applicable minimum net worth on or
before March 31, 2026 and the entire stipulated minimum net worth on or before March 31,
2028.

Minimum capital to risk weighted assets ratio (CRAR) requirement

Tier 1 UCBs shall maintain, as hitherto, a minimum CRAR of 9 per cent of Risk Weighted
Assets (RWAs) on an ongoing basis. Tier 2 to 4 UCBs shall maintain a minimum CRAR of
12 per cent of RWAs on an ongoing basis. UCBs in Tier 2 to 4, which do not currently meet
the revised CRAR of 12 per cent of RWAs, shall achieve the same in a phased manner. Such
UCBs shall achieve the CRAR of at least 10 per cent by March 31, 2024, 11 per cent by
March 31, 2025, and 12 per cent by March 31, 2026.

The Reserve bank of India (RBI) in March 2022 released a new set of guidelines for the
issue and regulation of share capital and securities for Primary Cooperative Banks
The 2022 notification specifies that UCBs can raise capital through three broad methods, viz: -
issuance of equity shares, preference shares, and debt instruments. First, UCBs can raise funds by
issue of equity to enrolled members within the area of operation or through additional equity shares to
existing members. Second, UCBs can augment Tier – I & Tier – II capital by issuing Perpetual
Cumulative & Non-Cumulative Preference Shares, and, Redeemable Cumulative & Non-Cumulative
Preference Shares. Third, UCBs can issue Perpetual Debt Instruments (PDIs) for Tier – I Capital and
Long-Term Subordinated Bonds as Tier – II Capital. It can be issued to institutional investors also,
with the consent of the depositors. 

It may be pertinent to understand that Tier – I Capital is the primary funding source of the
bank. It entails shareholder equity and retained earnings disclosed in their financial
statements. On the other hand, Tier – II Capital or supplementary capital includes undisclosed

16
‘Revised Regulatory Framework - Categorization of Urban Co-operative Banks (UCBs) for Regulatory
Purposes’, Reserve Bank of India, December 01, 2022
funds, revaluation reserves, hybrid capital instruments, junior debt securities, general loan-
loss, uncollected reserves, etc.  The notification specifies that such fundraising capital
instruments can be issued by the UCBs with the prior approval of RBI. UCBs must seek
permission via application to the regional office of RBI. The application shall be
accompanied by an offer document, prospectus, information memorandum, a compliance
certificate from a Chartered Accountant, and relevant disclosures.  The notification also lays
down the terms of issue specifying the eligibility, limits, amount, maturity, options, dividend/
coupons, classification on the balance sheet, payment of dividend/ coupons, seniority of
claim, voting right, discount, disclosures, due diligence, rate of interest, investment, advances
for purchase of certain instruments and lock-in clause.  Further, UCBs that issue the
aforementioned regulatory capital instruments shall adhere to certain conditions.
Accordingly, banks ought not to use their fixed deposit rate as a benchmark for debt
instruments with a variable interest rate, or floating rate instruments. Secondly, the investors
shall undertake in the common application form for the proposed issue that they have
understood the features and risks thus associated. Third, UCBs must provide a disclaimer that
these capital instruments are different from a fixed deposit and not covered by deposit
insurance. Further, it is mandatory to specify the procedure for the transfer to legal heirs in
the event of the death of a subscriber. Investors may note that the UCB shall not withdraw or
reduce its share capital except if approved by RBI. In such a scenario, the UCB shall refund
the share capital to their members, nominees, or heirs on demand. Finally, the borrowings
from UCBs shall be linked to shareholdings of borrowing members on the basis of security.
These aforementioned conditions are to be fulfilled for the purpose of enhancing investor
education on the risk characteristics of regulatory capital requirements.17

CONCLUSION
Co-operative banks function as intermediaries for last mile credit delivery and promote
financial inclusion. Over the years, the Reserve Bank has been initiating reforms to
strengthen the cooperative banking structure. Its two-pronged strategy consists of statutory
reforms and regulatory support. The amendment to the Banking Regulation Act, 2020 has
eased capital raising constraints of urban co-operative banks (UCBs). The Reserve Bank has
been empowered to reconstruct or amalgamate them. The Reserve Bank also revised the
regulatory framework governing UCBs on July 19, 2022. The vision guiding the framework
17
“New RBI Guidelines on Urban Cooperative Banks Explained | The Financial Express” (New RBI guidelines
on urban cooperative banks explained | The Financial Express, March 19, 2022)
<https://www.financialexpress.com/industry/banking-finance/new-rbi-guidelines-on-urban-cooperative-banks-
explained/2465423/>.
is to consolidate their position as friendly neighbourhood banks by catering to the
heterogeneity in the customer base, while offering more operational flexibility to strong
UCBs in order to enhance their contribution to credit intermediation.

BIBLIOGRAPHY

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banking-regulation-amendment-bill-2020-1054>
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