By Saksham Dwivedi, CNLU Patna

Editor’s Note: Ever since the financial sector reforms were introduced in early 90’s the banking sector saw the emergence of new generation of private sector banks. These banks gained at most popularity as they have technology edge and better business models when compared to public sector banks and the most important thing is they are able to attract more volumes simply because they meet their customers requirements under one roof. If the newer players can do that then why can’t the bigger players like the Financial Institutions (FIs) try their hands on it?

Here comes the concept of universal banking, its emergence, merits and related issues. The present project focuses on understanding the concept of universal banking in India and attempts to explain the regulatory role, regulatory requirements, key duration and maturity distinction and lastly the optimal transition path. The project also gives an overview of the international experience and argues in favor of developing a strong domestic financial system in order to compete in the global market.


Universal Banking, a concept that has gained a lot of credence in recent times, can be defined as a multi-purpose and multi-functional supermarket providing both banking and financial services through a single window. In simple words, a Universal Bank is a superstore for financial products[i].

Under one roof, Corporates can get loans and avail of other handy services, while individuals can bank and borrow. As mentioned in the Discussion Paper by Reserve Bank of India[ii], the term Universal banking, in general, refers to the combination of commercial banking and Investment banking i.e., issuing underwriting, investing and trading in securities. In a broad sense, however, the term Universal banking refers to those banks that offer a wide variety of financial services especially insurance (Reddy, 2000).

As per the World Bank, ‘In Universal Banking, large banks operate extensive network of branches, provide many different services, hold several claims on firms (including equity and debt) and participate directly in the Corporate Governance of firms that rely on the banks for funding or as insurance underwriters (Katkar, 2006). In simple words, Universal Banking means the financial entities – the commercial banks, Financial Institutions, NBFCs – that undertake multiple financial activities under one roof, thereby creating a financial supermarket (Chaitanya, 2005). The entities focus on leveraging their large branch network and offer a wide range of services under a single brand name[iii].

Activities of Universal Bank

Presently, all the banking organizations are marching towards Universal banking and as such the distinction in the operations of Commercial banks, Development Financial Institutions and Non-Banking Financial Companies (NBFC) is gradually blurring. The motive of these entities behind their transition towards. Universal banks are to earn as much as profit by way of interest, fee-based income and commission through various diversified activities (Bhaskar, 2005).

In this process, Universal banking adapts, adopts and achieves the basic objectives of business through technology. Universal Banks are characterized by the presence in the breadth and depth of different segments of the financial market particularly debt market (Gurusamy, 2009)[iv]. Banks in India are present in the following areas of the universal banking activity –

  1. Credit market
  2. Consumer finance market
  3. Savings market
  4. Money market
  5. Capital market
  6. Forex market
  7. Commodities market
  8. International banking
  9. Advisory service market (merchant banking)
  10. Investment banking
  11. Insurance market
  12. Factoring
  13. Credit, Debit, and Smartcards
  14. Pension market
  15. Project financing
  16. Venture capital
  17. On-line share broking
  18. Internet banking
  19. Telephone banking
  20. Mobile banking
  21. Securitization

In India, most of the commercial banks are rendering almost all the activities mention above. Except for the ICICI Bank Limited, which enjoys the status of Indian Universal Banks, the other banks which are also rendering the above-mentioned services, however, do not enjoy the same status.

Types of Universal Bank

There are four different types of Universal Banks in the world. They are as follows[v]

1. Fully Integrated Universal Banks: Fully integrated Universal banks are those banks which function as a single institutional entity offering a complete range of banking and financial products and services.

2. Partly Integrated Financial Conglomerates: It is an institutional set-up where the bank offers a range of services, with some of the services such as mortgage banking, leasing, and insurance being provided through wholly owned or partially owned subsidiaries.

3. Bank Subsidiary Structure: These are the banks that offer functions such as investment banking and insurance in addition to focussing on regular commercial banking functions.

4. Bank Holding Company Structure: Bank holding company structure is an institutional set-up where banking and financial products are offered through a financial holding company that owns both banking and non-banking subsidiaries that are legally separate.

The concept of Universal banking is based on two models. One is the German Model, in which banks carry comprehensive banking activities including commercial banking as well as other services such as securities and insurance. The other is the British Model. According to this model, universal banks by way of financial conglomerates offer a full range of financial service in accordance with the change of financial environment, pursuing diversification in securities and investment[vi].

Structure followed in India

In India, the financial services sector has been witnessing a growth in the emergence of financial conglomerates. With increased competition in the financial sector, banking, as well as non-banking entities, have felt the need to opt for diversification of their business line. In the process of offering both banking and financial products, they started to experiment with organizational structures hitherto unfamiliar in India.

However, it has been seen that in India, the Holding Company structure is being commonly followed. Internationally there are mainly two holding company models for bank related conglomerates viz., Bank Holding Company Model and Financial Holding Company Model[vii].

In India, as per Reserve Bank of India, there are major motivations for banks/financial institutions to opt for BHCs/ FHCs.

(a) Firstly, in terms of existing instructions of RBI, a bank’s aggregate investment in the financial services companies including subsidiaries is limited to 20% of the paid up capital and reserves of the bank. In a BHC/FHC structure, this restriction will not apply as the investment in subsidiaries and associates will be made directly by the BHC/FHC. Once the subsidiaries are separated from the banks, the growth of the subsidiaries/associates would not be constrained on account of capital[viii].

(b) Secondly, in the context of public sector banks, the Government holding through a BHC/FHC will not be possible in the existing statutes. However, if statutes are amended to count for effective holding then, the most important advantage in shifting to BHC/FHC model would be that the capital requirements of banks’ subsidiaries would be de-linked from the banks’ capital[ix].

(c) Thirdly, since the non-banking entities within the banking group would be directly owned by the BHC, the contagion and reputation risk on account of affiliates for the bank is perceived to be less severe as compared to the organizational structure where a bank is directly into the non-banking business. Thus, it is anticipated that due to the above motivational factors, financial entities offering diversified products would opt for Holding Company structure. in a banking or financial group, a holding company can be the parent of the group or an intermediate holding company. A multi-layered financial conglomerate may also have a few tiers of intermediate holding companies apart from the holding company at the top

Difference between Universal Banking and Financial Conglomerates

In recent years, the financial services sector in India has been witnessing a growth in the emergence of Financial Conglomerates. A financial conglomerate is a company or a group of companies that have substantial interests in all sorts of financial businesses – banking, insurance, funds management, mutual funds and securities trading (Rajadhyaksha, 2004).

However, Financial Conglomerates are different from Universal Banking in the sense that in respect of Financial Conglomerates various activities are undertaken through different subsidiaries, whereas in the case of Universal Banking, the bank is free to choose the activities it wants to carry out subject to certain regulations (Gurusamy, 2009). As per Reserve Bank of India, a group would be designed as a ‘financial conglomerate’ if –

(a) any group entity coming under the jurisdiction of specified regulators (namely, RBI, SEBI, and IRDA for the present and the Pension Fund Regulatory Authority may be included subsequently) and having a significant presence in the respective financial market segment, and

(b) the group is having operations in at least one more financial market segment[x].

Universal Banking – A Strength and Weakness Analysis

A SWOT analysis of Universal banking system as given below reveals to what extent these organizational structures would be beneficial to the country’s economy as a whole and the financial sector in particular.[xi]


1. Economies of scale and scope: One of the main advantages of Universal banking is that such an entity can maximize economies of scale and scope by ‘bundling’ the production of financial services (Kannan, 2002). This would result in greater efficiency in the form of lower cost, higher output, and better products.

2. One stop shop: A Universal bank would act as ‘one-stop-shop’ for its customers. This would save a lot of transaction costs and increase the speed of economic activities and thereby enhance the profitability of the bank through the sale of different financial products. Moreover, customers would enjoy the benefit of getting various financial products under one roof.

3. Diversification with profit motive: The main objective behind Universal banking is to earn as much profit by way of interest, fees based income and commission through various diversified activities (Bhaskar, 2005). Thus, banks are diversifying into allied areas of business with a motive to enhance the profitability of the organization. This is because synergies in joint production of financial and non-financial services increase economic efficiency, reduce cost and increase earnings (Bhole, 2004).

4. Optimum utilization of resource: A bank possesses information on the risk characteristics of the clients, which it can use to pursue other activities with the same clients (Sensarma, 2001). This eventually saves cost compared to the case of different entities catering to the different needs of the same clients.

Moreover, a bank through its existing network of branches can opt for cross-selling their other products like insurance, mutual funds etc. to its clients. Again, as a part of its business operations, the bank would collect information pertaining to the market trends, risk and return associated with portfolios of Mutual Funds and it can provide this information to its clients also at no extra cost.

5. The advantage of established Brand name: A Universal bank, with an already established brand name, can sell different products like insurance, mutual funds etc. under the same brand through its existing network of branches. As such investment on building a new brand and product marketing would be very less and at the same time, its brand reputation in the market would be a key driver in increasing the sales of its new diversified products.

6. A positive message to the investors: As a part of its business activities, Universal bank is going to hold stakes in other firms also. In such instances, it is going to send a positive message to the investors because the lending bank is in a better position to monitor the firm’s activities.


1. More expensive: In fact, diversification of banking activities need not always result in economies of scale and scope especially if banks are not of appropriate size (Herring & Litan, 2003; Karunagaran, 2005). Sometimes it turns out to be more expensive. This happens when a sufficient number of transactions in each of the specialized financial activity is not even up to the ‘breakeven’ level.

2. Loss of core competence: When a bank offers a variety of products under an umbrella brand, there is a possibility that the multi-product bank would lose sight of their core competence and would face a greater risk by participating in untested activities.

3. Grey area of Universal Bank: The transition path for DFI towards Universal banking is laden with obstacles. The stringent regulatory requirements laid down by the Reserve Bank of India for the DFIs are the major cause of hindrance in the transition process.

The burning issue about universal banking had been about how the institution would go about garnering Rs 18,000 crore to meet statutory obligations and the degree of concessions they would be able to obtain from RBI about the magnitude of CRR, SLR and priority sector lending (Sen, 2002). Moreover, there happen to be differences in regulatory requirements for a bank and DFI in the process of becoming a Universal bank. Unlike banks, DFIs are not required to keep a portion of their deposits as cash reserves.

4. The problem in long term lending: Project finance has been a domain of DFIs since long. In fact, DFIs was established by the Government to finance projects which had a long gestation period. Such financing is done through long term funds. Therefore, a DFI transforming to a bank may not be of much benefit in lending long term funds as banks have access to short term resources and not to long term resources.

5. The problem of NPA: There exists a major problem of NPAs in the DFIs. The problem arose either due to improper use of the funds availed by the borrower from the DFIs or due to a sharp change in the operating environment and poor project appraisals by the DFIs (Katkar, 2006). Whatever be the reason, the problem is likely to be aggravated if a DFI transforms itself into a Universal bank.

This is because there is a chance that due to the sudden expansion in activities, it may fail to make a thorough study of the actual need of the party concerned, the prospect of the business in which it is engaged, its track record, the quality of the management, etc. This may affect the loan recovery process and generate more NPAs[xii].

 The Need of Universal Banking

In India, the concept of Universal banking has gained the momentum only after the second Narasimham Committee Report (1998) which recommended that the Development Financial Institutions, over a period of time should convert themselves into banks (implicitly Universal banks) and that there should eventually be only two forms of intermediation – Banking companies and Non Banking Financial Companies. Moreover, this was followed by a Working

Group chaired by S.H.Khan on ‘Harmonising the Roles and Operations of Development Financial Institutions and Banks’ (1998), which made it more explicit by recommending for a progressive movement towards Universal banking for the DFIs[xiii].

In fact, the pressure in favor of Universal banking comes from the DFIs, with the banks being noticeably reticent in the matter (Rao, 2004). One of the main reasons for which DFIs are making a move towards Universal banking is due to the fact that long term resources are not available to them. To be more specific, the long-term resources earlier provided to the DFIs by the Government are no longer available.

In such a circumstance, the DFIs only have access to short-term resources to fund term loans and as such, they are confronted with the problem of Asset-Liability mismatch.[xiv] This is because their assets are long term while their liabilities are short term. In order to overcome such a problem, the DFIs have little option but to go in for increasing the amount of short-term lending. The obvious step is to transform the DFI into a Universal bank. Moreover, the economic growth of the country requires a sound infrastructure and for infrastructure projects, long term lending is absolutely necessary.

This is the reason why DFIs are set up by the Government. These DFIs should be allowed greater access to long term funds either from insurance companies or from provident funds so that they can finance projects with term loans. In contrast to this, a commercial bank with its insufficient asset base and net worth are not able to fund a large project like Greenfield and Brownfield projects solely. In many occasions, to overcome this problem, they form a consortium of lender especially with other nationalized banks) for funding those projects.

Thus, it implies that there is a need for developing a strong and stable financial sector to cater to the need of the infrastructure as well as the corporate sector. This is possible only when banks/ financial institutions have strong capital/asset base. Thus, it fortifies the need for Universal Banking.[xv]

Universal Banking in India

The explosive growth of the financial market since the early 1980s has resulted in the process of disintermediation (Rajadhyaksha, 2004). As a result of the disintermediation process, there had been exciting and progressive changes in the banking business (Suneja, 1994) and Indian banks have resorted to diversification in a big way. Moreover, the disintermediation process has been followed by financial sector reforms, which was initiated in the early 1990s after the First Narasimham Committee recommendation.

In fact, the disintermediation process and reforms in the financial sector paved the way for diversification of business activities in the banking sector. Today, the financial services industry has become entirely market-oriented (Suneja, 1994). The innovation of new services and the development of new instruments have become an integral and essential part of this market[xvi].

In India, although there is no legislative distinction between Commercial banking and Investment banking or any explicit legislative restriction for the banks to operate in investment banking activities, the banks have traditionally been maintaining the ‘arms length’ distance from investment banking (Karunagaran, 2005). In fact, in India, DFIs and RFIs were meeting needs of specific sectors of the economy and also providing long-term resources at concessional terms, while the commercial banks in general, by and large, were confined to their core banking function of accepting deposits and providing working capital finance to industry, trade, and agriculture.

However, with the financial sector reforms beginning in the 1990s, banks were given abundant freedom to go much beyond their traditional conservative commercial banking and this has facilitated banks in providing a host of financial products to meet customer needs. At the same time, there has been blurring of the distinction between the commercial banking and investment banking.

Later in the year 2000, the issue of universal banking resurfaced after ICICI gave a presentation to RBI to discuss the time frame and possible options for transforming itself into a Universal bank. Reserve Bank of India also spelt out to Parliamentary Standing Committee on Finance, its policy for universal banking. Eventually, the first Indian Universal bank was born on March 31, 2002, with the ICICI Bank formally given the recognition by the Reserve Bank of India. Another mega financial institution, IDBI has also adopted the same strategy, and has transformed itself into a universal bank (Leeladhar, 2005).

Simultaneously, Export Import Bank (EXIM Bank), Industrial Finance Corporation of India (IFCI) and Industrial Investment Bank of India (IIBI) also plunged into the race of becoming Universal banks but things did not materialise.

It is quite interesting to note that in India, although many of the banks are offering a host of banking and financial services like a universal bank but they formally do not enjoy the status similar to the ICICI Bank.

Government of India Regulations on Universal Banking

The salient operational and regulatory issues to be addressed by the FIs for conversion into a Universal Bank as per RBI Circular are as follows[xvii]

1. Reserve requirements: Compliance with the cash reserve ratio and statutory liquidity ratio requirements (under Section 42 of RBI Act, 1934, and Section 24 of the Banking Regulation Act, 1949, respectively) would be mandatory for an FI after its conversion into a universal bank.

2. Permissible activities: Any activity of an FI currently undertaken but not permissible for a bank under Section 6(1) of the B. R. Act, 1949, may have to be stopped or divested after its conversion into a universal bank.

3. Disposal of non-banking assets: Any immovable property, howsoever acquired by an FI, would, after its conversion into a universal bank, be required to be disposed of within the maximum period of 7 years from the date of acquisition, in terms of Section 9 of the Banking Regulation Act.

4. Composition of the Board: Changing the composition of the Board of Directors might become necessary for some of the FIs after their conversion into a universal bank, to ensure compliance with the provisions of Section 10(A) of the B. R. Act, which requires at least 51% of the total number of directors to have special knowledge and experience.

5. Prohibition on floating charge of assets: The floating charge, if created by an FI, over its assets, would require, after its conversion into a universal bank, ratification by the Reserve Bank of India under Section 14(A) of the Banking Regulation Act, since a banking company is not allowed to create a floating charge on the undertaking or any property of the company unless duly certified by RBI as required under the Section.

6. Nature of subsidiaries: If any of the existing subsidiaries of an FI is engaged in an activity not permitted under Section 6(1) of the B R Act, then on conversion of the FI into a universal bank, delinking of such subsidiary / activity from the operations of the universal bank would become necessary since Section 19 of the Act permits a bank to have subsidiaries only for one or more of the activities permitted under Section 6(1) of Banking Regulation Act.

7. Restriction on investments: An FI with equity investment in companies in excess of 30 per cent of the paid up share capital of that company or 30 per cent of its own paid-up share capital and reserves, whichever is less, on its conversion into a universal bank, would need to divest such excess holdings to secure compliance with the provisions of Section 19(2) of the Banking Regulation Act, which prohibits a bank from holding shares in a company in excess of these limits.

8. Connected lending: Section 20 of the Banking Regulation Act prohibits the grant of loans and advances by a bank on the security of its own shares or grant of loans or advances on behalf of any of its directors or to any firm in which its director/manager or employee or guarantor is interested. The compliance with these provisions would be mandatory after conversion of an FI to a universal bank.

9. Licensing: An FI converting into a Universal Bank would be required to obtain a banking license from RBI under Section 22 of the Banking Regulation Act, for carrying on banking business in India, after complying with the applicable conditions.

10. Branch network: An FI, after its conversion into a bank, would also be required to comply with extant branch licensing policy of RBI under which the new banks are required to allot at least 25 per cent of their total number of branches in semi-urban and rural areas.

11. Assets in India: An FI after its conversion into a universal bank, will be required to ensure that at the close of business on the last Friday of every quarter, its total assets held in India are not less than 75 per cent of its total demand and time liabilities in India, as required of a bank under Section 25 of the Banking Regulation Act.

12. Format of annual reports: After converting into a universal bank, an FI will be required to publish its annual balance sheet and profit and loss account in the forms set out in the Third Schedule to the B R Act, as prescribed for a banking company under Section 29 and Section 30 of the Banking Regulation Act[xviii].


The rise of Universal banking or the universalisation of banking is the anticipated result of rapid expansion of banks and their diversification into new financial and ancillary banking services. With financial sector reforms and increase in competition in the Indian Financial System, presently the business focus of the large entities that would emerge would be on profitable lines, such as trade finance, credit cards, consumer finance, foreign exchange dealings, treasury and stock market operations, where the payback period is short and risk is less compared to the traditional project and working capital financing (Srinivasan, 2000).

However, with increased growth, there would be a marked reluctance to enter the smaller end of retail banking. The small borrowers, especially in the rural areas, would find it difficult to access the bank’s services as they may not be significant to the banks’ business volumes or profits. The success of Universal banking would depend to what extent the banking process is technology-driven. With implementation of Information Technology Act, 2000 by the Government, introduction of IT in the banking sector had been possible. Due to these development, ‘Brick and Mortar’ banking has almost given way to ‘Click and Mouse’ banking (Darshan, 2006).

Technology has paved the way to banks to minimise the human interface (and the associated staff costs) with the customer, through ATMs and virtual banking enabling the banks to reduce costs. However, in the rural areas, such technology-led cost reduction would not be possible because of the high infrastructure costs involved and the level of literacy necessary for customers to use the electronic interface. What this portends for rural banking does not seem to be in consonance with the national priorities. Although the Government of India is toying with the idea of converting banks and DFIs into Universal Banks, the country would be benefited only when the benefits of such transition outweigh the costs.

However, the focus of some banks on growth and increasing the balance-sheet size through increased profitability may be adverse to certain sectors of economic activity, and the likely economic costs thereof would be more than the gains of the positive impact on the benefiting banks and financial institutions. In fact, if reforms are warranted, then universal banking has to make adjustments and ensure that financial services are available to all sections of the population at affordable costs and at the same time it should be ensured that access to financial services should not become an elitist privilege.

Formatted on February 17th, 2019.


[i] RBI Circular paper on ‘Salient operational and regulatory issues to be addressed by the FIs for conversion into a Universal Bank.’

[ii] Approach to universal banking, Mid-term Review of the Monetary and Credit Policy of Reserve Bank of India for 1999-2000.

[iii] Bharathi V. Pathak, “Indian Financial System”, Pearson Education, first edition, 2003, pp. 346

[iv] Ibid.

[v] Mor, Dr. Nachiket, “An Indian Perspective on Universal Banking”, paper presented at ‘National Seminar on Financial Markets & Institution’ at Mumbai,1999

[vi] Ibid.

[vii] Nair, Dr. KRS, “Universal Banking”, Indian Management, 1999, pp. 48-51.

[viii] Ibid.

[ix] Ibid. p. 56

[x] RBI Circular paper on ‘Salient operational and regulatory issues to be addressed by the FIs for conversion into a Universal Bank.’

[xi] “Universal Banking”, Banking Briefs (Internal Circulation), SBI Staff College, Sixth edition, 2001, pp. 94-95.

[xii] Ibid. p. 452

[xiii] Ibid. p. 453

[xiv] Supra Note 1

[xv] Supra Note 7, p. 56

[xvi] Chaitanya, Krishna V, Universal Banking. The Indian Perspective, Regional And Sectoral Economic Studies. Aeeade. Vol. 5-1 (2005)

[xvii] Ibid.

[xviii] The Salient operational and regulatory issues to be addressed by the FIs for conversion into a Universal

Bank [RBI circular], 2001

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