PART ANALYSIS OF CHAPTER NO 3 : BROADENING ACCESS TO FINANCE
(From the Study Report titled, “A Hundred Small Steps”) by students of Era Business School, New Delhi (PGDM 2012-14)
PART ANALYSIS OF CHAPTER NO 3 : BROADENING ACCESS TO FINANCE (From the Study Report titled, “A Hundred Small Steps”)
1. Era Business School 1
PGDM 12’14 Batch
ASSIGNMENT : FMS
PART ANALYSIS OF CHAPTER NO 3 : BROADENING ACCESS TO FINANCE
(From the Study Report titled, “A Hundred Small Steps”)
By: Group No 2/PGDM 12‟14
Submitted to: Prof RA Chopra
1- What is it?
1.1
Document
The publication, “A Hundred Small Steps”, is factually a Report on Financial Sector
Reforms by a Committee that had been constituted by Planning Commission of India with an
aim of outlining a comprehensive agenda for the evolution of the financial sector indicating
especially the priorities and sequencing decisions which the decision makers must keep in
mind during the long drawn process of decision making. Given its mandate through a
government order, the Committee had been headed by present Governor of RBI, Sh.
Raghuram G Rajan (then Professor, Graduate School of Business, University of Chicago)
and comprised of some of the very well-known names from the industry.
1.2
Mandate
The study by the Committee was bound by certain important terms of references and
same have been reproduced below:(a)
To identify the emerging challenges in meeting the financing needs of the
Indian economy in the coming decade and to identify real sector reforms that would
allow those needs to be more easily met by the financial sector.
(b)
To examine the performance of various segments of the financial sector and
identify changes that will allow it to meet the needs of the real sector.
(c)
To identify changes in the regulatory and the supervisory infrastructure that
can better allow the financial sector to play its role, while ensuring that risks are
contained; and
(d) To identify changes in other areas of the economy—including in the conduct of
monetary and fiscal policy, and the operation of the legal system and the educational
system—that could help the financial sector function more effectively.
1.3
Layout
The publication is laid out in eight chapters with the first chapter giving out Executive
Summary of the whole document, including gist of 35 proposals as made by the Committee
over next seven chapters. Running into well over 200 pages, the Report covers a canvas
covered over three years, ie between 2007 (when the Committee was constituted) and 2009
when the Report was published in the present form.
1.4
Relevance
Today, we are in a different decade as also in a different Five Year Plan and yet the
study Report holds relevance in the sense that it throws open certain issues that may be
analysed by the students of a PG course in Management to understand not only the macrolevel thinking that goes into formulation of such important documents but also the timelines
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that get involved in decisions at macro-level (after all, not many of the proposals, despite
their absolute relevance have been implemented till date). At the same time, a study of the
Report would also help a reader (read student) understand what Report has to say about „reintroduction‟ of earlier ideas during any fresh policy formulation process.
1.5
Scope
Our group (Group No 2) has been tasked with analysis of Chapter No 3, titled,
“Broadening Access to Finance” and to that extent, whatever follows hereafter, would
relate to that very chapter in particular with some relevant pointers to other chapters in
general.
2 – What is it About?
2.1
About the Chapter
The ibid chapter is all about different aspects (like need, importance, pitfalls,
suggested methodology and such like issues) as these pertain to the process of inclusion
and holistic coverage of masses as far as financial inclusion is concerned. At the very outset,
the Report has been quick to point out that certain steps have already been taken by the
government in this direction even though the whole issue needs to be looked at differently
and there is a definite need to have a paradigm shift in this regard. Very deliberately and
through use of common sense as well as hard logic, the Report has tried to highlight the fact
that mere expansion of credit coverage does not and should not qualify to be called or seen
as financial inclusion.
The Report meticulously highlights the fact that instead of a credit centric myopic
approach towards the financial coverage and inclusion, it is not only pertinent but also
utmost important to look at such an inclusion in terms such as payments services, savings
products, insurance products, and inflation-protected pensions. It would only be when such
an all-inclusive approach is taken by the policy makers that this aspect of the financial sector
reform will eventually get addressed. It is understood that no matter what policies and
decisions regarding financial sector reforms are taken, if the masses at the grassroots levels
are left out of the implementation framework, no good would come to our economy as a
whole. The ever increasing poor-rich (and not urban-rural, as the Report highlights) divide
does not augur well for the nation and such a trend needs to be effectively curbed. The
Report, as it moves along, keeps referring to certain steps that have already been taken or
measures that have already been instituted but without any real effect on the situation on
ground.
The Report, through various proposals and suggestions, spells out the possibility of
providing financial coverage to as many as 90% of the households in the country provided
certain steps are taken and such aims are set. The Report re-visits some of the steps that
have been taken through decades after independence, especially the nationalisation of
banks and creation of priority sector lending, but laments the fact that the approach that was
centred around opening up of more and more branches, setting up of rural banks and
cooperatives, and setting targets for wider inclusion and such like ways, has shown mixed
results and whatever results have been forthcoming, have hit the state of diminishing
returns. The Report, therefore, justifies the thought process that feels that unless some
radical steps are taken the system will remain ineffective and only partially successful.
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Looking back, the Report tries to bring in a change in the focus by stating a few hard
facts about the myopic view associated with credit expansion in isolation, overlooking the
need for the poor to have vulnerability reducing instruments, limited focus on sectors and not
segments till now and so on and so forth. The Report also tries to identify the possible
reasons for such a dismal state of affairs by bringing up the following issues to the fore:(a)
Rural branches are seen as a burden rather than an opportunity by the
increasingly profit-oriented public sector.
(b)
The priority sector norms are now so broad in coverage; banks migrate
towards the bankable within the priority sector rather than the excluded.
(c)
The mandated low interest rates, in an area where risks are high, do not
impress banks. The corruption that gets associated in such a scenario, defeats the
whole exercise.
(d)
The Committee recognises, however, that a greater commercial viability
cannot be truly achieved for all sections of the poor, and therefore some kind of
mandated coverage will always be required. The key is to move the primary strategy
towards innovation and commercial viability, with more carefully targeted mandates
seen as filling the gaps, rather than having broad mandates as the central instrument
as is the current practice.
(e)
The rich-poor divide has replaced the conventional rural-urban divide in
access to financial services, as measured by the distribution of savings accounts.
(f)
The poor have no more access in the richly branched urban areas than in the
rural areas.
3 – Why is it Important?
3.1
In Few Words
The importance of the Report can be realised by having a look at the summary of
certain very important points, as enumerated below (brief explanations of these points would
then follow):(a)
Pragmatic recognition of needs of poor.
(b)
A balanced assessment of existing strategy that has been adopted for a
perceived view of inclusion till now.
(c)
A proposed strategy to have a more balanced, much more holistic and a
meaningful inclusion of those who matter the most.
As can be seen in the above summary, the Report appears to ‘know the way‟ and is
not only willing to „show the way‟ but also „go the way’! That is where the real importance
of the Report lies. In the following paragraphs, we would briefly see the details of each one
of the ibid points.
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3.2
Need Recognition for Poor
The Committee, with well researched data to back up its claims, has pointed to the
fact that India‟s poor, many of who work as agricultural and unskilled/semi-skilled wage
labourers, micro-entrepreneurs and low-salaried worker, are largely excluded from the
formal financial system and, thus, too large a proportion of the poor lie outside the formal
banking system. While trying to highlight the fact that the rich-poor divide has replaced the
conventional rural-urban divide in access to financial services, the Committee has cited
another fact that rich, irrespective of their rural or urban landings, will always get bank
access while poor masses, both in rural and urban India, are denied the same. The divide,
therefore, is not along rural-urban but along rich-poor lines. A matter of concern to the study
group is the extent to which the poor use financial services, but sourced from the informal
rather than the formal financial system. The Committee goes on to spell out needs of those
deprived of any institutionalised financial inclusion and highlights the fact that such needs
can no longer be ignored. The needs, in brief, are as under:(a)
Savings.
In the lowest income quartile, the most preferred savings
instruments were bank savings accounts though only 50 per cent of those with
savings had bank accounts. Life insurance and informal savings schemes like selfhelp groups and microfinance institutions were the other preferred instruments. Over
20 per cent of respondents in the lowest income quartile held savings in chit funds
and self-help groups/microfinance. Over 50 per cent of the clients saving with
SHGs/microfinance institutions were agricultural wage labourers and self-employed
farmers, while 30 per cent of chit fund members belonged to this category. Therefore,
the poor have largely missed out on the boom in the equity markets for a number of
reasons, including a high priority on security and liquidity, and perhaps a limited
understanding of the economic effects of inflation on savings. Worse, the tax on bank
deposits has increased the gap in returns between bank savings and equity.
(b)
Insurance.
The participation of low-income groups in life insurance, the
second most preferred savings instrument after bank savings deposits, is still very
limited. As low as 14% of lowest quartile population is covered by insurance and that
too inadequately. The policy lapse rate is also the highest amongst the poor.
(c)
Credit.
Well about 70% of the poor borrow predominantly from
informal sources, especially moneylenders and relatives/friends. Nearly 90 per cent
of Survey respondents in this quartile relied on informal sources for credit. The high
dependence on informal sources, in turn, implies that bulk of the borrowing by the
very poor is at very high interest rates that go as high as 36% as a routine. As a
result, large segments of India‟s poor households continue to be shut out of
mainstream finance. More worrying, according to some measures, access is actually
declining.
3.3
Strategy in Vogue
The Report identifies the real basis of the existing strategy for inclusion. As the
Report has analysed, the strategy relied primarily on the following pincers:(i)
Expanding branching into rural areas;
(ii)
Setting up special purpose government sponsored institutions (such as
regional rural banks and cooperatives); and
(iii)
Setting targets for credit to broad categories of the excluded.
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The inefficacy of opening more and more branches has already been highlighted in
the analysis. Unfortunately, however, the rural branches have not been profitable, and there
is little interest among private and public sector banks in opening new branches there. The
issue with staff from urban backgrounds getting posted to such branches and then decision
making resting with head offices that are located in faraway cities, together, have led to
downfall of the system. Thus, the predominant lender to the poor is still the moneylender, in
part because he is flexible, does not need documentation, is prompt, and can respond to his
client‟s emergency needs very well. Further, the loan assessment and monitoring in the
cooperative movement in India has been much more lax, in part because of the easy
availability of refinance from outside, and because of limited control exercised by those
whose funds are being employed.
Dilution in priority sector norms also contributed to a reduced focus on underserved
segments. The bulk of increase in credit to agriculture was accounted for by increase in
indirect finance to agriculture, which includes activities that can be considered commercially
viable. There is a delicate balance in setting priority sector norms and eligible categories.
High priority requirements and narrow eligible categories targeted at those who truly do not
have access could lead to greater access to credit, but could reduce bank profitability
considerably. Essentially, banks would be making transfers to the needy; a role better played
by the government and that is where the problem lies as far as this policy is concerned.
The experimentation with risk mitigation through National Agricultural Insurance
Scheme (NAIS) for farmers has led to a situation wherein premium inflows have been far
exceeded by insurance outflows, primarily because of some really unrealistic parameters.
The highly subsidized nature of this insurance has distorted farmers‟ views on what the true
price of insurance should be, and discouraged private initiatives to provide crop insurance.
Subsidized livestock insurance schemes have had a similar effect. Insurance against
agricultural price fluctuation has been hampered, as small farmers are unable to exercise
hedging options that are available to larger farmers.
To summarise the existing strategy, the study Report is of the conclusion that the
past strategy for inclusion had mixed results. While the public sector did create a rural
network, that network did not bring enough of the poor into the formal system, and the rural
network weighs on public sector bank profitability. The cooperative system is in serious
financial difficulty. Narrowly defined priority sector norms can force banks to lend, but again
by impairing profitability. The focus on increasing credit in the absence of appropriate
products for risk mitigation led to over-indebtedness among the poor. As the financial sector
becomes more competitive, and as banking privileges get eroded, it will become more
difficult and unwise to compromise bank profitability by mandating that banks take on the
burden of financing inclusion. Instead, the approach has to be to make inclusion more
profitable.
3.4
A Fresh Approach to Strategy Formulation
Based on the facts analysed and certain comparisons made with better strategies
being followed elsewhere, the Committee is of the view that any comprehensive and
sustainable response to addressing issues of financial inclusion must necessarily factor in
the role of the market. This is because efficiency, innovation and cost-effectiveness are key
to serving the financial needs of the poor. The financial sector does not ignore the poor
because of biases, but because the transaction costs in serving them are high. Initiatives
that reduce these costs will allow service providers to begin thinking of financial services for
the poor as a business opportunity and not as an act of charity. Also, any new strategy for
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increasing access to financial services will require the creation of a vibrant ecosystem that
supports financial inclusion.
In the backdrop of the above, the Committee has identified six major areas that need
certain changes (both in approach and functioning) to make the dream of financial inclusion
a reality. The areas and the proposed changes have been enumerated below:(a)
Overall Organisational Structure. It is important that the organizational
architecture supports and creates institutions that can reach the poor. The
Committee recommends a two-pronged approach—first, to facilitate the creation of
small finance banks, and second, to strengthen the linkages between large and small
financial institutions. The Committee believes that notwithstanding the checkered
history of small banks in India, a strong emphasis on good quality lending, low cost
structures, effective governance and management, and tight prudential norms, could
make small banks very useful to provide financial services to the poor. The
Committee recommends, therefore that the regulator allow more small finance banks
to be established, with the ability to provide both asset and liability products to their
clients.
(b)
Focus on Risk Mitigation. The Committee is of the view that the levels of
risk, that poor face, may have to be first brought down through physical methods—
soil and water conservation for reducing drought risk in case of crop insurance; herd
vaccination in case of livestock insurance; and preventative health care, safe drinking
water and sanitation, in case of health insurance. A key policy implication therefore is
to increase investments that lead to intrinsic risk reduction so that insurance can be
offered at premia that minimize the need for subsidies. Once this is done, it will be
useful to use public funds to build awareness about insurance as a critical financial
service, since greater demand for insurance can bring down costs due to scale
economies. At the same time, the customer service issues in terms of claim
processing delays and deductions need to be monitored tightly and penalties
enforced on erring companies. Finally, to mitigate the risk arising out of exploitation
of poor farmers by big traders, ITC‟s e-chaupal method or facilities of storing produce
in the warehouses need to be formally implemented.
(c)
Targets, Subsidies and Public Goods.
Summarised as under:-
(i)
The imbalance in the priority sector lending has been correctly pointed
out by the Committee. The Report strongly recommends the political will to
revisit the norms. Failing that, it suggests the categories that truly impact the
underserved (such as direct agriculture and the weaker sections category) be
preserved and strictly enforced even as the process of broadening other
categories continues. It further recommends that all banks—domestic and
foreign—should be subject to uniform priority sector lending requirements.
With the weaknesses observed in RBI‟s proposed The inter-bank participation
certificates (IBPC) scheme, the Committee proposes the scheme of tradable
„Priority Sector Lending Certificates‟ (PSLC) for loans beyond 180 days and
the whole process monitored by an agency like NABARD.
(ii)
Further, a liberalized interest rate regime should be accompanied by a
transparent way of communicating to borrowers up front what the all-in cost of
a loan will be (a simple number which reflects the effective interest rate they
are being charged when all fees are included), public disclosure of margins
on loans to the priority sector relative to reasonable cost benchmarks, and an
effective system for tackling consumer grievances.
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(iii)
The Committee believes that well-targeted subsidies provided directly
to the poor are a more useful option than subsidies to financial entities for
provision of services. Notwithstanding this belief, there is still a case for the
provision of subsidies for services in remote areas or to target underserved
segments. Another useful step would be to provide existing subsidies and
cash transfers to the poor via bank accounts to encourage their use of the
banking infrastructure.
(iv)
Public intervention may be needed to promote simple low-fee savings
instruments that are indexed to the stock market and available for purchase in
small units by small investors, savings funds, etc. This would allow small
investors to tap into the large gains that equity market investors have enjoyed
the world over in recent times. It would also allow them a better savings
instrument than savings accounts that have given them miserable real returns
in the past. Currently, the lack of PAN numbers among the poor prevents the
wider dissemination of such products. There may be a case to subsidize the
provision of PAN numbers for poor clients who wish to participate in this
scheme.
(d)
Cost Control Through Use of Technology.
The
transaction
and
operating costs can be reduced by some innovative use of technology by banks. The
Committee cites the example of mobile service providers to make the point. A system
of common payments, systems with participation by multiple banks, can reduce
transaction costs and substantially increase the deployment and utilization of POS
terminals. Further, technology can be significantly leveraged for acquiring customers
through Banking Correspondents who would have unique identities and access
based on technology. Finally technology has to be used to reduce provisions for bad
debt. Credit ratings for retail customers and a unique citizen ID are critical in this
regard. Capturing all the transactions electronically and mandatory sharing of data
with a credit bureau would significantly help in this direction.
(e)
Infrastructure for Financial Inclusion.
The Committee believes that it is
important to improve the infrastructure for inclusion. In other words, the issue of
credit infrastructure, including the creation of a national ID, the use of land as
collateral, and personal bankruptcy, which are all measures that would improve the
poor‟s access to financial services. Another area that falls broadly in the ambit of
financial infrastructure for inclusion is the provision of interest-free banking. Certain
faiths prohibit the use of financial instruments that pay interest. The non-availability of
interest-free banking products results in some Indians, including those in the
economically disadvantaged strata of society, not being able to access banking
products and services due to reasons of faith. This non-availability also denies India
access to substantial sources of savings from other countries in the region. The
Committee recommends that measures be taken to permit the delivery of interestfree finance on a larger scale, including through the banking system.
(f)
Financial Literacy. The Committee is of the considered view that a good
understanding of the costs and benefits of various financial services, the impact of
inflation on savings, and the trade-off between risk and return can help households
choose the right products for their needs and weed out dubious schemes from truly
beneficial ones. The Committee believes that efforts to promote financial literacy
should start early. Starting around Vth standard, students could be introduced to
terms such as income, expenditure, savings, deposits, interest, insurance, etc. In
addition, TV channels could be encouraged to run educational programmes on
financial issues such as household budgeting, savings, insurance, and pensions.
Group Members: Richa Dev, Manoj Kajla, Pawan Kumar & Col Ajay K Raina, SM
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4 – What has been Implemented?
4.1
Focus
To analyse the developments since submission and publication of this Report well
over four years ago, we may focus on the six key recommendations made by the
Committee. All the six proposals have been listed in the previous section under serial 3.4,
including its sub-sections. The analysis is au under:(a)
Overall Organisational Structure. In one word, “Nothing” has moved on
this proposal and political will, as it is paralysed for quite some time now, may be
seen as the real cause of such a lack of progress. The recent action of allowing
more bank licenses cannot be seen as implementation of this proposal since the
basic ideas behind two issues are absolutely divergent.
(b)
Focus on Risk Mitigation. Yet again, no progress has been made beyond
existing schemes related to soil conservation and testing, water conservation and
many kinds of insurances that collectively, unfortunately, remain on paper in most of
the cases. Commodity exchanges are still beyond reach of common farmers because
of technical issues related to quantity aggregation and price assessment.
Warehousing Development and Regulatory Authority (WDRA) had already been
formed before the publication of this Report. Though some developments have taken
place in this regard, the ones as visualised by the Committee, are yet to see light of
the day. Sadly, the WDRA‟s efficacy or rather lack of it has stood out during recent
NSEL crisis.
(c)
Targets, Subsidies and Public Goods. Interestingly,
priority
sector
lending guidelines were being revised roughly at the same time when this Committee
was beginning its work in 2007. Another revision of the same did take place in 2011
(http://www.rbi.org.in/scripts/NotificationUser.aspx?Id=7460&Mode=0) and same are
valid as of now. A close look at the 2011 guidelines does show a few changes,
though subtle, in line with the Report under analysis. While issues like loan for bailing
out distressed farmers (who have taken loans from non-institutionalised sources),
loan against warehouse receipts as well as future crops, special attention to the
marginalised sections of farmers, provision of IBPCs, overdrafts of Rs 50,000 from
no-frill accounts, investment in securitised assets, no processing fee for loans up to
Rs 25,000 and definite instructions on occurrence of shortfall in such lending have
been steered into a direction as sought by the Report, many other issues like special
treatment to foreign banks, huge allocation towards educational loans vis-à-vis
agricultural loans, non-initiation/non-introduction of PSLC, de-regulation of interest
rate ceilings and enforcement issues with usury laws remain unaddressed. While no
one would expect a 100% implementation of the Report in our context, the real
implementation still falls short of fraction that could have been fairly expected.
Subsidy-related recommendations, likewise, remain unimplemented till date. Bank
transfers have been started for payments towards NREGA but focus has suddenly
shifted towards LPG and Food Security provisions and unfortunately, both the
processes are marred by numerous hiccups.
(d)
Cost Control Through Use of Technology.
With the introduction of
mobile banking and removing transaction fees on electronic transactions by public
sector banks, some headway has been made. But a true multi-bank ATM system is a
far cry, especially in light of the resistance raised by banks when free unlimited usage
of ATMs of one another was being formulated. Today, ceiling is at five transactions
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per month. No concrete data, however, is available about the actual costs post
implementation of electronic banking but it can be estimated safely that huge strides
must have been made over intervening years since 2007/08. Undoubtedly, electronic
banking (online as well as mobile) has come a long way since then.
(e)
Infrastructure for Financial Inclusion.
The recommendations/proposals
in this regard have largely been on the drawing board for long and appear to be in an
inert state as of now. Some developments, however, appear to be taking place.
Kerala state now has a few banks working on zero-interest basis but such a
development has been very narrow. A bit of personal bankruptcy clause stands
addressed in the 2011 guidelines on priority sector lending, as indicated above.
(f)
Financial Literacy. The dream of financial education at a young
impressionable age remains a dream and yet it is worth the mention that CBSE has,
of late, introduced projects and such like curriculum at 10+2 level. One is not sure
about the actual connect between recommendations of the Report and
implementation of project work curriculum by CBSE but for an optimistic mind, there
appears to be some connect, even though it may not be formal.
5 – What Next?
5.1
Dynamics of Implementation
At one point in the Report, the Committee had hinted towards the fact that in our
country, decisions take long times and many old studies (done and forgotten) suddenly
come into play once such decisions are taken. Also, in light of a more than obvious paralytic
state of policy making over past few years, change of cabinet ministers heading MoF, global
financial uncertainties, and a potential backlash against financial liberalization, the Report
has not been used as a guide for implementation. And yet, in a country where such Reports
are suddenly dusted out of the cupboards when decisions are taken in the future, the Report
has done a great job of agenda-setting, which will be extremely fruitful in coming years.
5.2
Future
The timing of this analysis, as a matter of co-incidence, closely follows a news Report
that had appeared in the Economic Times on 16 September 2013
(http://articles.economictimes.indiatimes.com/2013-09-16/news/42114164_1_financialsector-raghuram-rajan-hundred-small-steps). As per the said Report, (we quote), “Next up
on India's reforms agenda is the financial sector. After retail, aviation and fuel prices, the
government is getting ready to roll out the long-overdue, next generation of measures aimed
at freeing up the country's financial sector and a framework for this could be in place as early
as next month……. The plan to kick off the process, stalled for many years, was discussed
in the run-up to the appointment of Raghuram Rajan as Reserve Bank of India governor and
has the highest political sanction. The reforms blueprint will lean heavily on the two highprofile Reports already available with the government, one of them authored by Rajan
himself. "We will have a framework ready soon and will take it to the Financial Stability and
Development Council (FSDC) for deliberation before the measures are rolled out," a senior
finance ministry official told ET…..” (we unquote).
When viewed in light of the fact that post taking over as FM, Mr PC Chidambaram
has been working towards overcoming the policy log-jam and also the fact that chairman of
the ibid Report is now the Governor of the RBI, it appears logical that policy makers have no
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option but to move ahead with long over-due financial sector reforms. Again, expecting the
decision makers to implement the complete Report in letter and spirit would be an unfair
thing to do, especially due to various political and other hurdles and yet even if one third of
all the proposals (ie 12-15) are implemented, it would be a big step forward. Looking at the
things as they stand today, we do not have many options in any case….. or do we?
Submitted By:- Richa Dev
Manoj Kajla
Pawan Kumar
Col Ajay K Raina, SM
Group Members: Richa Dev, Manoj Kajla, Pawan Kumar & Col Ajay K Raina, SM