## Tuesday, November 13, 2018

### There be dragons: Off-balance-sheet liabilities of the Indian State

by Ila Patnaik and Ajay Shah.

Conventional fiscal stability analysis looks at the stock of debt and wonders whether a country can pay off this debt, under reasonable scenarios for future interest rates and fiscal surpluses. In many countries, though, the fiscal sustainability story has turned on promises made by a government which were not explicitly counted in the debt. There are obvious liabilities that are kept off the books - such as debt in public sector companies or state electricity boards. In this article we look deeper, at less obvious ways in which off-balance-sheet liabilities have arisen, and the checks and balances that can contain them.

### Off balance sheet liabilities of the government

Off balance sheet items come in two kinds.

1. A promise that looks like the cashflows on a bond. Example: A pension promise to a person is no different from a series of coupons that are paid out every year. Promising a pension is exactly like issuing that comparable bond.
2. A promise that looks like an option payoff. Example: If a government is in hock to pay the lenders of a firm when it goes bankrupt, it is much like being the seller of an option. When governments write guarantees, this changes the risk profile of the exchequer and generates possibilities of large payouts when those options mature in the money.
It should be noted that organisations backed by statute are not automatically backed by a government guarantee. As an example, in the UTI crisis of 2001, the government had no legal obligation to make good the losses of investors, but a political decision was made to use fiscal resources to pay half the loss. There is a mixture of financial risk ("Will X get into trouble?") and political risk ("Will the government backstop X?").

A correct reckoning of the liabilities of a government should add in these off-balance-sheet liabilities of both kinds. The FRBM Act brought control on one kind of off-balance-sheet liability of the Indian State: explicit guarantees given by the government. But there is more to the problem of off-balance-sheet liabilities than explicit guarantees.

#### Differences in cost versus differences in transparency

In the field of pensions, an interesting distinction is made between an unfunded defined benefit program vs. a funded defined benefit program that has assets invested in government bonds. In the conventional wisdom, a funded DB program is always superior to a pay-as-you-go unfunded program.

However, these two approaches are exactly the same in terms of the cashflows: both involve a highly predictable set of claims on the exchequer at future dates. To promise a pension is to implicitly issue a bond. This equivalence, between the cashflows of a bond and the cashflows of a pension, has an interesting implication. Consider a funded DB public pension program that invests in government bonds. The two streams of cashflows cancel out.

This approach to funding (holding government bonds) does not make things cheaper: it is only superior in that it is transparent and connects into the fiscal planning process. Cost savings only come about when a funded DB program invests in higher return assets, such as equities, through which the claims upon the exchequer at future dates are reduced on expectation.

#### What are the important off-balance-sheet liabilities of the Indian State?

Some important components of the off-balance-sheet liabilities are:

• Promises made for defined benefit pensions of civil servants, in particular the new one rank one pension' (i.e. wage indexed) pensions for uniformed folk, and the underfunded Employee Pension Scheme' (EPS) that is run by the EPFO. For the civil servants recruited after 1/1/2004, there is no such problem, as these new recruits are in the New Pension System.
• Promises made in a variety of health-related entitlement programs (Patnaik et. al., 2018).
• The temptation to make good the promises made by public sector financial firms, that experience distress in the future, even when there is no explicit guarantee. Of these, LIC has a balance sheet of Rs.28 trillion.
• The temptation to make good the promises made by private financial firms that experience distress in the future, even when there is no explicit guarantee. As an example, will the failure of IL&FS -- a private financial firm -- induce a direct or indirect fiscal impact upon the exchequer? So far, the government has not put money on the table, but could this change?
• The use of fiscal resources in responding to a full blown financial crisis, that may occur at a future date.
• The Parliament has enacted many laws, which could potentially evolve into large inflexible expenditures. These include Right to education', Right to food' and NREGS. On a similar note, the promises which are being made under `minimum support price' (MSP) could turn into large expenditures if the future brings together a certain combination of political pressures, jurisprudence and development of State capacity. Until repeal, these laws are a genotype that could, under the right combination of events at future dates, get expressed in a way that involves major fiscal risk.

These liabilities add up to large sums of money, of the same order of magnitude as the overt stock of public debt. Hence, off-balance-sheet liabilities should become more prominent in the Indian fiscal discourse.

#### How do the incentives of politicians and officials change?

At present, there is no check-and-balance influencing these opaque promises and risks. Each party in power looks to enter into greater off-balance-sheet obligations so as to get re-elected. How might this change?

The key thing that shapes these incentives is financial repression. At present, government debt is mostly sent into involuntary lenders. When the fiscal system graduates from financial repression to voluntary lenders, off-balance sheet liabilities would matter. There are numerous gains from removing financial repression: voluntary borrowing is more efficient than forced borrowing, the magnitude of resources available in a crisis would become greater, etc. But this requires a government that faces a skeptical bond buyer who demands a risk premium based on the extent to which the Indian State may engineer inflation or default.

In India today, there are many loose ends, which periodically induce fiscal surprises. This creates an adverse risk profile of Indian government bonds, and would drive up the required interest rate for borrowing when faced with voluntary buyers of bonds. In such a world of market discipline, when a government dips into LIC's resources, this would induce a higher cost of borrowing.

In India today, most of the attention in fiscal reforms lies upon tax policy reforms, such as the GST and the Direct Tax Code, and there is some interest in FRBM. There is much more to a mature fiscal system, including the issues of tax administration, debt management, the bond-currency-derivatives nexus, off-balance-sheet liabilities, accrual-based accounting, and the budget process. We need to broaden our research and policy work to address this full range of problems.

Tracking and understanding off-balance-sheet liabilities, communicating them to lenders, and communicating these concerns back into the budget process, is part of the work program of the future Public Debt Management Agency (PDMA) (Pandey and Patnaik, 2017). A Fiscal Council will help. Accrual based accounting will help.

Once we start paying attention to off-balance-sheet obligations, this creates fresh impetus for economic reform in many areas. As an example, if a monsoon failure induces a farm loan waiver paid for by the government, this is like a monsoon derivative that has (maybe) been written by the government. When reforms of personal insolvency and reforms of agriculture remove this possibility, the risk profile of the Indian exchequer will improve, and the cost of borrowing will go down.

#### Off-balance-sheet liabilities and financial reform

There is a close connection between public finance and finance, centering around the government bond market and the PDMA. For public finance, PDMA and the government bond market are the source of debt. For finance, the PDMA is the biggest investment banker of the country and the government bond market is the tool for low risk transfers of resources across time. What is less widely noticed is the intimate connection, between public finance and finance, through the question of off-balance-sheet liabilities.

How will off-balance-sheet liabilities change when micro-prudential regulation improves and the resolution corporation is setup? Financial firms will face distress less often, we will discern that distress early, and we will have an institutional mechanism to put the distressed firm down. Conversely, under present conditions, we get surprised by the difficulties in an IL&FS or in a UTI. These crises lead to a political question being thrust upon the leadership: Will you make liability-holders happy by using taxpayer money? We should, of course, have a mature political system which is able to turn down such requests most of the time, but we should have a mature financial regulatory system so that these situations do not arise in the first place.

Governments worldwide have faced claims on fiscal resources when dealing with full blown financial crises. The probability of occurrence of such crises, and the severity of such crises, is shaped by the institutional capacity in systemic risk regulation. The FSLRC apparatus for systemic risk regulation -- the Financial Stability and Development Council (FSDC) and its information system, the Financial Data Management Centre (FDMC) -- will reduce fiscal risk and thus the cost of government borrowing. As an example of the work program which should take place through FSDC/FDMC: At present, we have the possibility of runs on mutual funds (Sane et. al., 2018), which can lead to a full blown financial crisis, which requires policy thinking and reforms on a financial system scale.

Our objective in financial economic policy should be: to be as sparing as possible in ever asking for resources from public finance policy. For a sound fiscal system, we require financial sector reform. This will have a beneficial impact upon contingent off-balance-sheet liabilities and thus the cost of borrowing.

#### The need for a research community and a research literature

A remarkable feature of the existing Indian policy process is that no fiscal estimation was done in the policy process that led up to the announcements  about one rank one pension, or the various health insurance programs.

Even if policy makers had tried to reach into the research community to obtain such estimates, the state of data and knowledge is weak, and it is difficult for policy makers to obtain policy support from researchers. Some early work on the civil servant's defined benefit pension (Bhardwaj and Dave, 2005), one rank one pension (Sane and Shah, 2015) and banking (Shah and Thomas, 2000) is available. Much more needs to be done in this important field.

In an ideal world, record level data would be available from the government which would permit estimation of the value of the implicit debt or the implicit derivatives that the government has issued. The state of information systems and transparency of government is often a bottleneck, and creative research strategies have to be employed. As an example, Bhardwaj and Dave, 2005, utilise data from a national scale household survey to identify present and future beneficiaries of the traditional DB civil servants pension, and extrapolate the sample estimates to an estimate of the implicit pension debt associated with the traditional civil servant's DB pension. Similarly, Shah and Thomas, 2000, exploit information in stock prices to estimate the equity capital gap in banks, which helps overcome the opacity of banks and banking regulation.

A research community is required, which will build a research literature in estimating these expenditures based on exploiting diverse datasets. There will, of course, be multiple different estimates, as different researchers search for useful approximations through different assumptions and modelling strategies. A coherent picture will emerge from these debates. The PDMA, and buyers of government bonds, will be important users of this research community.

#### Off balance sheet liabilities and GDP growth volatility: A conjecture

There is a big gap between short spurts of GDP growth and sustained GDP growth. A mature market economy is a turtle, it plods along for a century, obtaining a low rate of growth on average, and harnessing the power of compounding. Poor countries fail to get sustained growth. The striking fact in cross-country comparisons is how volatile the GDP growth of poor countries is.

What might be going on? An analogy from a different field is useful. A well known problem in financial portfolio management is the returns that can be obtained, in the short term, by selling out-of-the-money options. For some time, the option seller seems to make a lot of money. But in time, some of those options get exercised and the portfolio gets into a lot of trouble. In similar fashion, for some time, a government that takes on option-like off-balance-sheet liabilities can gain votes and possibly accelerate economic activity, at the cost of sustainability.

Perhaps one element of the high GDP growth volatility of poor countries runs as follows. Mature fiscal systems create checks-and-balances which reduce the extent to which debt or off-balance-sheet liabilities can surge. Perhaps less developed countries have weak institutions, and then the political leadership sees a different optimisation. Short bursts of GDP growth can then be achieved in many bad ways, such as a surge in debt, piling up off-balance-sheet liabilities, etc. But this is not sustained growth: We get a spurt of high growth, and then things go wrong. This yields one more element of the translation of bad institutions into high GDP growth volatility.

#### References

Bhardwaj, Gautam and Surendra A. Dave, 2005. Towards estimating India's implicit pension debt, Working paper.

Pandey, Radhika and Ila Patnaik, 2017. Legislative strategy for setting up an independent debt management agency. NUJS Law Review, 10(3).

Patnaik, Ila, Shubho Roy and Ajay Shah, 2018. The rise of government-funded health insurance in India. NIPFP Working paper.

Sane, Renuka and Ajay Shah, 2015. What is the cost of one-rank-one-pension? The Leap Blog.

Sane, Renuka, Ajay Shah, Bhargavi Zaveri, 2018. Runs on mutual funds, The Leap Blog.

Shah, Ajay and Susan Thomas, 2000. Systemic fragility in Indian banking: Harnessing information from the equity market. IGIDR Working Paper.

The authors are researchers at the NIPFP in New Delhi. We are grateful to Shubho Roy, M. Govinda Rao and Arbind Modi for useful discussions.

1. a good way is to figure out a methodology to incorporate all these off balance sheet activities in sovereign rating framework.

The sovereign rating framework currently being in use by agencies do not have any explicit use of official debt. A starting way would be to adjust india rating by including top public sector banks debts and known estimate of implicit pension debt.

My internal estimates shows a downgrade by 2 notch by just including top 11 public sector banks.

In addition, off balance sheet items are supposed to have a contagion effect as their realization will mainly happen in stressed years. In effect, they will add a lot more to tail risk

2. Following is the methodology:

The objective of this methodology to estimate the additional credit cost of Indian government (GOI) as an implicit guarantor of off balance liabalities (OFL). The effective credit cost of the government will be sum of the following two components:

1) stress in sovereign balance sheet on account of its official funded liabilities
2) political demand on government for cash conversion of unfunded balance sheet

As a result of simultaneous pressure on off balance, there would be cases when sum of sovereign own liabilities plus cash conversion requirement of off balance exceeds the terminal asset of the sovereign. We call the likelihood of such events as “Effective Sovereign PD”. This PD reflects not only the repayment capacity of the sovereign for its own debt but to even take care of the debt of the stressed banks. The repayment capacity of the sovereign with respects to its own debt is termed as “Standalone PD” in this methodology. The ratio of effective sovereign PD to standalone PD can be considered as a proxy for spillover impact of off balance sheet.

The spill over impact is going to be high for the following cases:

1) likelihood of off cash conversion requirement of off balance sheet is high (for example defined benefit pension scheme)
2) High Level of off balance sheet amount
2) High level of correlation of off balance stress with sovereign balance sheet (for example, during times of cash conversion of off balance item, government revenues are lower).
3) High Correlation between off balance sheet items (for example EPFP, ILFS and LIC fall at the same time)

Methodology

We can use the stochastic asset growth – fixed default barrier framework (Merton Model) to analyze the impact of implicit guarantees for off-balance sheet liabilities. In this methodology, an obligor has a stochastic asset growth process. At the end of the assessment horizon, the obligor defaults if its terminal asset falls below the fixed debt level.

The above framework can be easily applied to analyse the level of spillover risk due to simultaneous occurrence of cash conversion of off balance sheet. In case the sovereign is an guarantor, the concept of fixed debt barrier does not hold. In case of any of the entities related to off balance sheet is in problem, the sovereign is expected to pay for them In other words, effective sovereign debt at the end of the horizon is the sum total of following:

1) Sovereign own debt
2) cash for off balance

As a result, there would be cases when sum of sovereign own debt plus cash for off balance exceeds the terminal asset of the sovereign. We call the likelihood of such events as “Effective Sovereign PD”.

The following inputs would be required:

1) standalone pd of soverign (pd) : this can be extracted from external ratings

2) likelihood of cash conversion for each entity (q) : this can extracted from indian evidence. For example, in last 22 years, we have two cases (UTI & ILFS), hence we can say (1/22) for any given year

3) Current marketable asset, mean and volatility of asset return of soverign (back calculation from sovereign rating)

4) Current marketable asset,mean and volatility of asset return of off balance related entities (like EPFPO, LIC etc)

5) Correlation between asset returns of sovereign and off balance related entities (this can be assumed to be 100%)

6)Correlation within off balance related entities

Please note: Comments are moderated. Only civilised conversation is permitted on this blog. Criticism is perfectly okay; uncivilised language is not. We delete any comment which is spam, has personal attacks against anyone, or uses foul language. We delete any comment which does not contribute to the intellectual discussion about the blog article in question.

LaTeX mathematics works. This means that if you want to say $10 you have to say \$10.