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INTRODUCTION TO DEPSIT MOBILISATION

Deposit mobilization is an integral part of banking activity. Mobilization of savings through intensive deposit -
collection has been regarded as the major task of banking in India today. Acceptance of deposits is the primary
function of a bank. As such, deposit mobilization is one of the basic innovations in current Indian banking activity.

TYPES OF DEPOSITS

1. CURRENT ACCOUNT DEPOSITS:


Current accounts are basically meant for businessmen and are never used for the purpose of investment or
savings. These deposits are the most liquid deposits and there are no limits for number of transactions or the
amount of transactions in a day. Most of the current account is opened in the names of firm/company accounts.

2. SAVINGS DEPOSIT:
These deposits accounts are one of the most popular deposits for individual accounts. These accounts not only
provide cheque facility bur also have lot of flexibility for deposits and withdrawal of funds from the account.
Most of the banks have rules for the maximum number of withdrawals in a period and the maximum amount of
withdrawal, but hardly any bank enforces these.

3. TERM DEPOSITS:

Term deposits also known as fixed deposits and they are a genuine savings medium. They have different
maturity period on which depend the rate of interest.

4. CASH CERTIFICATE:
It is same as fixed deposits. These certificates are issued for a period of 1 year to 10 years.

5. RECURRING DEPOSITS:
Recurring deposits are gaining wide popularity these days. Under this type of deposits, the depositor is required
to deposit a fixed amount of money every month for a specific period of time. Each installment may very from
rs.5/- to rs.500/- or more per month and the period of account may vary from 12 months to 10 years. After the
completion of the specified period, the customer gets back all his deposits along with the cumulative interest
accrued on the deposits.
INTRODUCTION TO ADVANCES:
Advances are loans granted by the bank to its clients. Banks give loans to individuals, firms companies and
cooperative for various purposes like floating a new business, expansion or diversification of an existing one or
revival of ailing business. Bank loans are for meeting woeking capital need of business. Loans and advances are
granted to:-

a) Business and trade:-

Banks grant short-term loans to business and trade activities in following forms:

1.Overdraft:-
Commercial banks grant overdrat facility to current account holders under this system a borrower is allowed to
draw more than what is deposited in his accounts. The borrower is granted to a fixed additional amount against
collateral security. Interest is charged for actual amount drawn.

2.Cash credit:-
Cash credit is given by the bank to anybusinessman to meet regular woeking capital needs, against the security
of goods or personal security, interest is charged on actual amount drawn by the customer.

3.Discounting of bills:-
When the holder of the billis not in a position to wait till the maturity of the bill and requires cash urgently, he
sells the bill of exchange to bank. Bank advance credit bydiscounting bills of exchange, government securities
oor any approved financial instruments. The bank purchases the instruments at a discount.
4.Money at call:-
Banks also grant loans for a very short period, generally not exceeding 7 days. Such advances are repayable
immediately at a short notice hence they are called as money at call or call money; these loans are given to
dealers or brokers in stock market against collateral securities.

5.Direct loans:-
Loans are given to customers against the security of moveable properties. Their maturity varies from 1 to 10
years. Interest has to be paid on entire loan amount sanctioned. Loans are of many types like:- personal loans,
term loans, call loans, participative loans, collateral loans etc.

b) Loans to agriculture:-
Banks grant short-term credit to agriculture at a lower rate of interest. Loans are granted for irrigation,
ppurchase of equipment, inputs, cattle etc.

c) Loans to industries:-
Banks grant secured loans to small and medium scale industries to meet their woeking capital meeds. The time
period may be from one to five years. It may be in the form of overdraft, cash credit or direct loan.

d) Loans to foreign trade:-


Loans are granted to export and import in the form of direct loans, discounting bills, guarantee for deferred
payments etc. here the rate of interest is low.

e) Consumer credit/personal loans:-


Banks also grant credit to household in a limited amount to buy some durable consumer goods like television
sets, refrigerators, washing machine etc. such consumer credit is repayable in installments. The scope of
consumer credit has been extended to cover expenses on marriage, funeral etc., as well.

f) Miscellaneous advances:-
Banks also gives advances like packing credits to exporters, export bill purchased or discounted, import finance
to self- employed, credit to weaker sections of soxiety at concessional rates etc. These are all comes under
preliminary expenses in simple words preliminary expenses are the expenses that spent by the promoters before
the incorporation of company.

INTRODUCTION TO INVESTMENT

Now a day’s bank also participates in the activities of investment at national or international level of investment
banks. They help companies and government to raised money by issuing and selling securities‘ in the capital
markets. They provide necessary financial guidance to its customers for effective investments in stock and
mutual funds. Some banks also have specialized offices for this purpose.

Meaning of Investment:

investment is the employment of finds with the aim of achieving additional income or growth in value. The
essential quality of an investment is that is involves 'waiting’ for a reward. It involves the commitment of
resources which have been saved or put away from current consumption in the hope that some benefits will
accrue in future.

Objectives of Investments:

1. Income: To provide a steady stream of income through regular interest/dividend payment.

2. Growth: To increase the value of principal amount through capital appreciation.

3. Stability: To protect the principal amount invested from the risk of loss.

Basic Features of Investment:


1. It is a commitment of funds with the exception of a return in future.
2. Every investment requires to be analyzed within the framework of risk and return.
3. When a single investment security is analyzed is called security analysis. But when securities are combined
to give a maximum return it is called portfolio analysis.
4. Investment brings about either appreciation or reduction in the value of the Capital invested.
5. When any investment appreciates there is gain and if due to market process of risk due to mismatch of
demand and supply, it reduces, there is loss.

6. All investors employ their funds with the aim of additional income or growth in value. Which is the price
of 'waiting’ or a reward for not spending money for current consumption.

7. Investments require to be analyzed to find out their quality and benefits because once the funds have been
invested the forces of risk and return begin to operate.

8. In the financial sense investment differs from its use in the economic sense. To the economist, ’Investment’
means the net additions to the economy's Stock. To the financial investor investment is a transfer of financial
asset from one person to another either directly or through institutions.

9. Investment also differs from speculation. Investment is a long term analysis whereas speculation is like
gambling for short term gains.

From the point of view of people who invest their funds, they are the suppliers of 'Capital’ in this context, the
term investment, therefore, implies the formation of new and productive capital in the form of new
construction, new producers, durable equipment such as plant and equipment. Inventories and human capital
are included in the economist’s definition of investment.

The financial and economic meaning of investment are related to each other because investment is a part of the
savings of individuals which flow into the capital market either directly or through institutions, dividend in
‘New’ and second hand capital financing. Investors as ’Suppliers’ and investor as ’Users’ of long term fund
find a meeting place in the market.

Features of an Investment Programme:

1. Safety of Principal:

The investor, to be certain of the safety of principal, should carefully review the economic and industry trends
before choosing the types of investment. Errors are avoidable and therefore, to ensure safety of principal, the
investor should consider diversification of assets. Adequate diversification involves mixing investments
commitments by industry, geographically, by management, by financial type and by maturities. A proper
combination of these factors would reduce losses. Diversification to a great extent helps in proper investment
programmed but it must be reasonably accomplished and should not be carried out to extremes.

2. Liquidity: Even investor requires a minimum liquidity in his investment to meet emergencies. Liquidity will
be ensured if the investor buys a proportion of readily saleable securities out of his total portfolio. He may
therefore, keep a small proportion of cash. fixed deposits and units which can be immediately made liquid
investments like stocks and property or real estate cannot ensure immediate liquidity.

3. Income stability :

Regularity of income at a consistent rate is necessary in arty investment pattern. Not only stability, it is also
important to see that income is adequate after taxes. It is possible to find out some good securities which pay
practically all their earnings in dividends. it is also important to see that income is adequate after taxes.

4. Appreciation and Purchasing Power Stability :

Investors should balance their portfolio to fight against any purchasing power instability. Investor should judge
price level inflation, explore the possibility of gain and loss in the investment available to them, limitations of
personal and family considerations. The investors should also try and forecast which securities will possibly
appreciate. A purchase of property at the right time will lead to appreciation in time. Growth stock will also
appreciate over time. These, however. should be done thoughtfully and not in a manner of speculation or
gamble.

5. Legality and Freedom from care:

All investments should be approved by law. Law relating to minors. estates. trusts. shares and insurance should
be studied. Illegal securities will bring out many problems for the investor. One way of being free from care is
to invest in securities like Unit Trust of India. Life insurance Corporation or Savings Certificates. The
management of securities is then left to the care of the Trust who diversifies the investment according to safety.
stability and liquidity with the consideration of their investment policy. The identity of legal securities and
investment in such securities will also help the investor in avoiding many problems.

6. Tangibility: Intangible securities have many times lost their value due to price level inflation, confiscatory
laws or special collapse. Some investor prefers to keep a part their wealth invested in tangible prope ties like
building, machinery and land. It may, however, be considered that tangible roperty does not yield an income
apart from the direct satisfaction of possession.

Investment Process-Sta~ es in Investment:

Stage 1: Investment Policy:

The first stage determines and involves personal financial affairs and objectives before making investments. It
may also be called preparation of the investment policy stage. The investor has to see that he should be able to
create an emergency fund, an element of liquidity and quick convertibility of securities into cash. This stage
may, therefore, be considered appropriate for identifying investment assets and considering the various features
of investment.

Stage 2: Investment Analysis:

When an individual has arranged a logical order of the types of investment that he requires on his portfolio, the
next step is to analyses the securities available for investment. He must make a comparative analysis of the type
of industry, kind of security and fixed vs. variable securities. The primary concerns at this stage would be to
form beliefs regarding future behavior or prices and stocks, the expected returns and associated risk.

Stage 3: Valuation of Securities:

Third step is perhaps the most important consideration of the valuation of investments. Investment value, in
general, is taken to be present worth to the owners of future benefits from investment. The investor has to bear
in mind the value these investments. An appropriate set of weights have to be applied with the use of forecasted
benefits to estimate the value of investment assets. Comparison of the value with the current market price of the
assets allows a determination of the relative attractiveness of the asset. Each asset must be valued on its
individual merit. Finally, the portfolio should be constructed.

Stage 4: Portfolio construction:

Portfolio construction requires knowledge of different aspects of securities. These are briefly recapitulated here,
consisting of safety and growth of principal, liquidity of assets after taking into account the stage of involving
investment timing, selection of investment, and allocation of savings to different investments and feedback of
portfolio.

While evaluating securities, the investor should realize that investment are made under conditions of
uncertainty. These cannot be a magic formula which will always work. The investor should be concerned with
concepts and applications that will satisfy his investments objectives and constantly evaluate the performance
of his investments. If need be, the investor may consider switching over to alternate proposals.

Conclusion:

This stage may, therefore, be considered appropriate for identifying investment assets and considering the
various features of investment. The primary concerns at this stage would be to form beliefs regarding future
behavior or prices and stocks, the expected returns and associated risk.

Importance of Investment:

Retirement outlets Taxation Investment Incomes Interest Inflation

l. Longer Life Expectancy or planning for retirement: Increase in the working

population, proper planning for life span and longevity have ensured the need for balanced investments.

2. Increasing rates of taxation: Taxation is one of crucial factors in any country, which introduces an element of
compulsion in a person’s savings.
3. High interest rates: The investor has to include in his portfolio several kinds of investments. Stability of
interest is as important as receiving a high rate of interest.

4. High rate of inflation: The investor will try and search an outlet, which will give him a high rate of return in
the form of interest to cover any decrease due to inflation.

5. Larger incomes: The employment opportunities give rise to both male and female

working force. More incomes and more avenues of investment have led to the ability and willingness of
working people to save and invest their funds.

6. Availability of a complex number of investment outlets: Apart from putting aside savings in savings banks
where Interest Is low, Investors have the choice of a variety of instruments. The question to reason out Is which
Is the most suitable channel? Which Investment will give a balanced growth and stability of return? The
Investor In his choice of

Investment will have to try and achieve a proper mix between high rate of return and stability of return to reap
the benefits of both.

investment Media or investment Pattern:

Many types of investment media or channels for making Investments are available. A sound investment
programmed can be constructed if the investor familiarizes himself with the various alternatives investments
available. Investment media are of several kinds. Some media are simple and direct, others present complex
problems of analysis and Investigation. Some are familiar, other are relatively new and unidentified. Some
investments are the appropriate for one type of investor and another may be suitable to another person.

The ultimate objective of the investor Is to derive a variety of investments that meet the preference for risk and
expected return. The investor will select the portfolio which maximise his utility. Securities present a wide
range of risk from risk free instrument to highly speculative shares and debentures. From this broad spectrum
the investor will have to select those securities that maximize his utility. The investor, in the other words has an
optimization problem. He has to choose the security which maximizes his expected return subject to certain
considerations. The investment decision is an optimization problem but the objective function varies from
investor to investor. It is not only the construction of a portfolio that will promise the highest expected return
but, it is the satisfaction of the need of the investor. For instance, one investor may face a situation where he
needs extreme liquidity. He may also want safety of securities. Therefore, he will have to choose a security with
low return. Another investor would not mind high risk because he does not have financial problems but he
would like a high return.

Such an investor can put his savings in growth shares as he is willing to accept risk. Another important
consideration is the temperament and psychology of the investor. Some investors are temperamentally suited to
take risks; there are others who are not willing to invest In risky securities even if the return is high. One
investor may prefer safe government bonds whereas another may be willing to invest in blue chip equity shares
of the company.

Many alternative investments exist. These may be categorized in many ways. The investment alternatives are
given below:

1) Direct Principal Investments

A. Fixed Principal Investment

1. Cash
2. Savings Account
3. Savings Certificate
4 Governments Bonds
5. Corporate Bonds and Debentures

B. Variable Principal Securities


1. Equity Shares
2. Convertible Debentures or Preference Securities

C. Non-Security Investments
1. Real Estate
2. Mortgages
3. Commodities
4. Business ventures
5. Art, Antiques and other valuables

2) Indirect Investment Alternatives

1. Pension Fund

2. Provident Fund

3. Insurance

4. Investment companies

5. Unit Trust and other trust funds

Direct and Indirect investment

These investment alternatives have basically been categorized as direct and indirect investment alternatives.
Direct investments are those where the individual makes the individual makes his own choice and investment
decision. indirect investments are those in which the individual has no direct hold on the amount he invests. He
contributes his savings to certain organisations like Life lnsurance Corporation (DC) or Unit Trust of India
(UTI) and depends upon them to make investment on his and other people's behalf. So there is no direct
responsibility or hold on the securities.

Fixed principal investments are those who are principal amount and the terminal value are known with
certainty. Cash has a definite and constant rupee value, whether it is deposited in bank or kept in a cash box. It
does not earn any return. Savings accounts have a fixed return; they differ only in terms of time period. The
principal amount
Is fixed plus interest earned. Savings certificates are quite recent-some examples being National Savings
certificate, Bank Savings Certificates and Postal Savings Certificates. Government bonds and corporate bonds
and debentures are sold having a fixed maturity value and a fixed rate of income over time.

The variable principal securities differ from the fixed principal securities because their terminal values are not
known with certainty. The price of preference shares is determined by demand and supply forces even though
preference shareholders have a fixed return. Equity shares also have no fixed return or maturity date.

Convertible securities such as convertible debentures or preference shares can convert themselves into equity
shares according to certain prescribed conditions and thus have features of fixed principal securities
supplemented by the possibility of a variable terminal value.

Debentures, preference shares and equity shares are examples of securities sold by corporations to investors to
raise necessary funds. 'Non-Security lnvestments’ differ from securities in other categories. Real estate may be
the ownership of a single home or include residential and commercial properties. The terminal value of real
estate is uncertain but generally there is a price appreciation, whereas depreciation can be claimed in tax. Real
estate

is less liquid than corporate securities. Mortgages represent the financing of real estate. It has a periodic fixed
income and the principal is recovered at a stated maturity date.

Commodities are bought and sold in spot markets; contracts to buy and sell commodities at a future date are
traded in future markets. Business ventures refer to direct ownership investments in new or growing business
before firms sell securities on a public basis. Art, antiques and other

valuables such as silver, fine chain and jewellery are also another type of Specialized investments which offer
aesthetic qualities also.

The organization like LIC or UTI, Provident funds is managed according to their investment policy by a group
of trustees on behalf of the investor. The examples of indirect investment alternatives are an important and
rapidly growing segment of our economy. In choosing specific investments, investor will need definite ideas
regarding a number of features that their portfolio should have. These features should be consistent with the
investors’ objective and in addition should have additional conveniences and advantages. The following
features are suggested for a successful selection of investments.

Scope of Investment Pattern or Portfolio management:

A good portfolio of growth stocks satisfies the entire objectives outline above. Portfolio management is a
continuous process. It is a dynamic activity. The following are the basic operations of a portfolio management.

a) Monitoring the performance of portfolio by incorporating the latest market conditions. b) ldentification of the
investor’s objective, constraints and preferences.

c) Making an evaluation of portfolio income (comparison with targets and achievement. d) Making revision in
the portfolio.

e) Implementation of the strategies in tune with investment objectives.

THE INVESTOR CLASSIFICATION:

Income Group

Risk Group

A) RISK GROUP:

Investor can be classified into different groups depending on their attitude towards risk. Each Investor also has
an indifference point at which his own expectations of return match with the risk that he can take. A well
diversified portfolio carefully chosen from the numerous securities available in the market will help the investor
in achieving his objectives. The investor should also be able to assess his own behavior pattern before he aims
at a particular goal which he wishes to attain. Broadly, he should be able to identify whether he is at risk
averter, risk neutral or risk taker. If he identifies himself as risk averter his normal behaviour patter will show
his preference for investments of low market rate risk and
interest rate risk. He would prefer government securities.

CLASSIFICATION OF INVESTORS:

TYPE RISK TYPE OF BEHAVIOUR ACCEPTABL INVETSMENT RISK NO RISK LIFE INSURANCE
WILL PAY LESS AVERTE UNITCERTIFICATES FOR RS GOVT.CERTIFICATE UNCERTAIN ACTION.
RISK SOME RISK COMMON WILL PAY NEUTRA STOCKS, UNITS, EQUAL TO LS LIFE POLICIES.
EXPECTED RETURN OF UNCERTAIN RISK HIGH RISK COMMON WILL PAY TAKERS STOCKS,
MORE THAN BONDS, EXPECTED CONVERTIBLE VALUE FOR AN SECURITIES. UNCERTAIN

ACTION.

While investors can be classified in categories of high risk, no risk and medium risk takers, it can

be said that the major group of investors are those who can absorb medium risk. Most investors are willing to
sacrifice some expected income or return if the income is certain.

b INCOME GROUP:

The income group of an investor evokes responses to an available investment outlet. The higher the income
group of an investor the greater will be his desire for purchasing assets which will give him a favourable tax
treatment. The source of income usually has a bearing on deduction of tax. Certain sources of income are taxed
like ordinary income.

Other income may be exempted from income tax. The investments must be geared in a manner that combines
the features of low risk and low taxation to the maximum benefits. Low income

group investor will not look towards tax benefits. His maximum utility will be at a point of greater reward.

EXPECTATION LEVEL OF INVESTORS

INCOME RETURN RISK ELK GROUP BENEFITS


Low HIGH MEDIUM NIL MEDIUM HIGH MEDIUM SOME

HIGH HIGH MEDIUM MAXIMUM

GENERALLY THERE ARE TWO TYPES OF INVESTMENTS THEY ARE:

1. CHOOSE IN POSSESSION:

It is that type of investment, which results in creation of real assets like fixed assets and movable assets.

2. CHOOSE IN ACTION:

It is that type of investment under which only right of future receivables are held. These types of assets are also
called as financial assets. The following are some of the examples of financial assets. i.e. when the interest rates
reduce the price of securities increases

vice/verse.

Up to September 2000, in terms of RBI circular the investments of banks comprised SLR and non-SLR
securities. The classification in the balance sheet, for disclosure, is under four groups

via, (i) State and Central government securities. (ii) Other trustee securities. (iii) Shares. (iv) Others
(commercial papers, mutual funds, etc.)

Bank’s were earlier advised that for the purpose of valuation the investments of banks in SLR securities should
be bifurcated in to ’CURRENT’ and ’PERMANENT’, with the prescription that the ’CURRENT’ Investments
are less than 75% of the total SLR securities, excluding the new banks set up after 1993 in the private sector
which were required to include their entire SLR investments under 'CURRENT’ category and ’CURRENT’
category of SLR investments and the entire portfolio of non-SLR investments should be marked to market.

RBI has also been issuing detailed guidelines to be followed for valuation of the investments and making them
to market every year. Besides, to facilitate valuation of investments which are not quoted Yield to Maturity
(YTM) rates for government securities of different maturities of different maturities, as on march 31, are also
being issued annually.

YTM: Yield to maturity of security is that rate at which point the present value of inflows during the life of the
bond is equal to present value of the bond; YTM is the point at which

NPV of the bond is equal to zero.

REVIEW: With this introduction of prudential norms on capital adequacy, income recognition, asset
classification and provisioning requirements the financial position of banks in india has improved in the last
few years. Simultaneously, trading in the securities market has improved in terms of turnover and the range of
maturities dealt with. In view of these developments and takings in to consideration the evolving international
practices, are informal working group in the bank has reviewed the existing instructions on the classification
and valuation of the investment portfolio.

The guidelines on classification and valuation of investments by banks have been revised on the basis of the
recommendation of the informal group to bring them in consonance Wlth the

best international practices.

CATEGORIZATION

The entire investment portfolio of the banks (including SLR securities and non-SLR securities) will be
classified under three categories viz.

o 'Held on maturity’ o 'Held for trading’ 0 ’Available for sale’

However, in the balance sheet, the investments will continue to be disclosed as per the existing of our
classification.Viz.

6' Government securities '1' Other trustee securities


'2‘ In shares of co-operative institutions '3‘ Others (Cp, Mutual fund units, etc.)

DEFINITIONS:

1. Held on Maturity:

The securities acquired by the banks with the intention to hold them u

. p to maturity wrll be classified under this

Held for maturity:

The bank’s holding of investments in ’Held for maturity’ category is 18.28% of DTL of the second preceding
fortnight and the same is equal to 56.97% of its total investments and the excess of ’Held for maturity' category
is investments over 25% of total investments will continue to be

disclosed as per the existing six classifications, viz.

° Government securities

° Other approved securities

v Shares

t° Debentures and bonds

" Subsidiaries and joint ventures


" Others (Cp, Mutual fund, units etc.)

O.

.0

O.

Held for maturity:

The bank’s holding of investments in ’Held for maturity’ category is 18.28% of DTL of the second preceding
fortnight and the same is equal to 56.97% of its total investments and the excess of 'Held for maturity’ category
is investments over 25% of total investments comprises of SLR securities. The Banks holdings in Held to
maturity category of investments are within the overall limits stipulated by RBI. 'Held for maturity’ but will not
be counted for the purpose of ceiling of 25% specified for this category.

i Re-capitalization bonds received from Government of India towards Their re-capitalization requirement and
held in their investment portfolio. > This will not include re-capitalization bonds of other banks acquired for
investment purposes. > investment in subsidies and joint ventures (A joint venture would be one in which the
bank along with its subsidiaries, holds more than 25% of the equity).

The following investments will be classified under Debentures/bonds must be treated in the nature of all
advances when

> The Debenture/bond are issued

)9 as a part of the proposal for project finance and the tenure of the debenture is for a period of three years and
above or )9 The Debenture/bond are issued .

VALUATION:

Investment classified under “Held to maturity” category need not be marked to market and will be carried at
acquisition cost unless it’s more than the face value in which case the premium should be amortized over the
period remaining to maturity.”Held to maturity" category are carried at acquisition cost unless it is more than
the face/redemption value, in which case the premium is amortized over the period remaining to maturity using
the constant yield method. Any diminution is other than temporary in nature. Such diminution is determined
and provided for each investment individually.

Available for sale and held for trading:

The banks will have the freedom to decide on the extent of holdings under available for sale and held for
trading categories. This will be decided by there after considering various aspects such as basis of intent,
trading strategies, risk management capabilities, tax planning, manpower skills, capital position.

The investment classified under held for trading category would be those from which the bank expects to make
a gain by the movement in the interest rates/market rates. These securities are to be sold within 90days. If the
bank is not able to sell the security within 90days clue to exceptional circumstances such as tight liquidity
conditions, or extreme volatility,

0r market becoming unidirectional, the security should be shifted to the available for sale category subject to
items 1 & 2 below. Profit or loss on sale of investments in both the categories will be taken to the profit and
loss account.

Shifting among categories:

Banks may shift investments to from ’held to maturity’ category with the approval of the board of directors
once a year. Such shifting will normally be allowed at the beginning of the accounting year. In case of
exigencies, such shifting may be done with the approval of the chief executives of the bank/head of the ALCO,
but should be ratified by the board of directors/ALCO.

Shifting of investments from 'held for trading’ category for sale category is generally not allowed. Subject to
depreciation, if any, applicable on the date of transfer, with the approval of the board of
directors/ALCO/investment committee.

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