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200     Economic Survey 2020-21   Volume 1


                The prolonged forbearance policies  following  the GFC thus engendered the recent
                banking crisis that brought down investment rates and thereby economic growth in the
                country. The first lesson for policymakers is to treat emergency measures as such and
                not to extend them even after recovery: when an emergency medicine becomes a staple
                diet, it can be counterproductive. Second, while the learnings from the previous episode
                must be employed to avoid a recurrence, ex-post analysis of complex phenomena must
                be  disciplined  by  the  insights  highlighted  in  Chapter  7  of  the  Survey.  Specifically,  to
                enable policymaking that involves an exercise of judgement amidst uncertainty, ex-post
                inquests must recognise the role of hindsight bias and not make the mistake of equating
                unfavourable outcomes to either bad judgement, or worse, malafide intent.



             INTRODUCTION

             7.1  To address the economic challenges posed by the Covid-19 pandemic, financial regulators
             across  the  world  have  adopted  regulatory  forbearance.  India  is  no  exception.  Emergency
             measures such as forbearance prevent spillover of the failures in the financial sector to the real
             sector, thereby avoiding a deepening of the crisis. Therefore, as emergency medicine, forbearance
             occupies a legitimate place in a policy maker’s toolkit; see Box 1 for an explanation of the
             economic rationale for forbearance. However, caution must be exercised so that emergency
             medicine does not become a staple diet because borrowers and banks can easily get addicted to
             such palliatives. When emergency medicine becomes a staple diet, the negative side effects may
             not only be large but may also last for a while. Therefore, carefully examining and understanding
             the implications of previous forbearance episodes is relevant to guide future policy. In 2008,
             anticipating the global financial crisis, RBI introduced the policy of regulatory forbearance. It
             relaxed the norms for restructuring stressed assets - downgrading the asset to non-performing
             status was no longer mandatory and required no additional provisioning; see Box 2 for the
             description and timeline of the same. This chapter studies the impact of the 2008 forbearance
             policy on banks, firms, and the economy in general to glean important lessons for the current
             times. As Spanish philosopher George Santayana cautioned, “Those who do not learn from
             history are condemned to repeat it.”

                                  Box 1: Economic Rationale for Forbearance

                The following illustration describes banks’ choices while dealing with a stressed asset with
                and without forbearance. In this context, we must keep in mind that when a bank creates
                additional provisions to account for loan losses, the bank’s profits decline and thereby lead to
                a reduction in the bank’s equity capital. Therefore, the incentives to provision for bad loans
                gets significantly impacted by regulatory forbearance.

                 Without Forbearance                         With Forbearance
                 1.  If the project is viable, the bank would  1.  If the project is viable, the bank would
                    restructure  the  asset  and  downgrade  it   restructure  the  asset. As  restructured
                    to  a  Non-Performing Asset  (NPA)  and     assets  do  not  require  the  same  level
                    provision for the same.                     of provisioning as NPAs, inadequate
                                                                provisions are made.
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