Monday, 19 January 2015

Update: Creating a smooth Sail for FDI- Easing of the "Optionality rules" by RBI



In a significant move the RBI has proposed relaxation of rules on Call and Put options last week when it allowed buyback of DoCoMo’s shares by Tata-Teleservices in their telecom joint venture. This decision of the central bank reflects a paradigm shift because the last notification by it on “Pricing Guidelines for FDI instruments with optionality clauses”[1] in January 2014, specifically mentioned that the right to exit to a foreign investor will be without any assured return. And in this case the buyback of the shares has been at a “previously assured price” which is allegedly much higher than the independently ascertained value.
It is important to note that the last amendment by RBI on option clauses remained fraught with contentions of having a number of practical challenges in implementing it but that would not be a point of discussion in this post.
Analysis
The RBI has reportedly asked the Finance ministry for downside protection to foreign investors upon their exit and extending the same option to the industry in general. This is thought provoking because one would have expected such a request to come from the ministry to the RBI and not the other way around. Taking such an approach would increase the capital flows in the country and would be in consonance with the government’s current policy of attracting foreign capital. This move will also affect the contracts that the private equity has with Indian companies and where such matters are in arbitrations and where major defence taken by Indian corporates is the fact that Indian law restricts payout at a price based in downside protection.
Assuming that the Finance Ministry agrees to this proposal this move might have the result of increasing the inflow of capital but it may also prejudice the interests of the Indian companies who will at the time of exit of their partners be compelled to pay an assured price which most of the times will be greater than the fair market value. This goes against the logic which used to be forwarded by the Indian regulators prior to 2014 amendment i.e. these protections were necessary owing to weak leverage position of the Indian companies in such contracts.
Nevertheless it is suggested that in order to attract more FDI the government needs to revisit its capital control regime holistically so that once there is more clarity on all options to foreign investors to exit the foreign investment will increase.







[1] A. P. (DIR Series) Circular No. 86 dated 9th January 2014.

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