Insolvency and Bankruptcy Code - FEBRUARY 2018 - ficci
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Financial Foresights
Editorial Team
Jyoti Vij
Contents
jyoti.vij@ficci.com
1. INDUSTRY INSIGHTS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3
Abha Seth n Insolvency and Bankruptcy: Will the Recovery Game Change in India?. . . . . . . . . . 5
Sankar Chakraborti
abha.seth@ficci.com
Chief Executive Officer & Executive Director
SMERA Ratings Limited
Anshuman Khanna
n Evolution of I&BC - Initial Impressions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8
anshuman.khanna@ficci.com
Sanjeev Krishan
Leader, Deals and Private Equity
Financial Foresights PwC India
Team n Role of ARCs in the post IBC era . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11
Birendra Kumar
Supriya Bagrawat Managing Director & CEO
supriya.bagrawat@ficci.com International Asset Reconstruction Company Private Limited (IARC)
n Asset Reconstruction under IBC regime - Advantage ARCs . . . . . . . . . . . . . . . . . . . . 14
Amit Kumar Tripathi Jaisry Mani
amit.tripathi@ficci.com Chief Manager - Law
Edelweiss Asset Reconstruction Company Limited
Chikku Bose n Insolvency & Bankruptcy Code - A Brief Analysis on Recent Market Trends . . . . 17
chikku.bose@ficci.com Abhishek Pandey
Managing Director
Duff & Phelps
About FICCI
n Insolvency and Bankruptcy Code – Resolution Applicant's Perspective . . . . . . . . . 23
FICCI is the voice of India's
Babu Sivaprakasam
business and industry. Partner & Head - Banking & Finance Practice
Established in 1927, it is India's Economic Law Practice (ELP)
oldest and largest apex n Impact of Insolvency and Bankruptcy Code, 2016. . . . . . . . . . . . . . . . . . . . . . . . . . . . . 27
business organization. FICCI is Madhukar R.Umarji
Former Executive Director
in the forefront in articulating Reserve Bank of India
the views and concerns of
n Challenges to the Insolvency and Bankruptcy Code, 2016 . . . . . . . . . . . . . . . . . . . 31
industry. It services its Bahram Vakil
members from the Indian Partner
private and public corporate AZB & Partners
sectors and multinational n Bankruptcy Code: Not a Panacea but Start of a New Era . . . . . . . . . . . . . . . . . . . . . . . 34
Rakesh Valecha
companies, drawing its Senior Director & Head - Core Analytical Group
strength from diverse regional India Ratings & Research Pvt. Limited
chambers of commerce and 2. FICCI'S DATA CENTRE. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 37
industry across states, reaching
n Equity Capital Markets . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 39
out to over 2,50,0000
n Mergers & Acquisitions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 42
companies.
n Debt Capital Markets . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 44
Disclaimer n Loan Markets. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 46
n Project Finance . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 48
All rights reserved. The content
of this publication may not be n Investment Banking Revenue . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 50
reproduced in whole or in part
without the consent of the 3. FINANCIAL SECTOR ENGAGEMENTS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 51
publisher. The publication does
not verify any claim or other
information in any
advertisement and is not
responsible for product claim
& representation.
Articles in the publication
represent personal views of the
distinguished authors. FICCI
does not accept any claim for
any view mentioned in the
articles.
Financial Foresights 1Industry Insights
Insolvency and Bankruptcy:
Will the Recovery Game Change in India?
Sankar Chakraborti
Chief Executive Officer & Executive Director
SMERA Ratings Limited
Introduction short term. It may be argued that Rehabilitation of these so called
such bad loans are a side effect of Non Performing Assets (NPAs) has
The process of corporate bad loan
rapid expansion, which the Indian been tedious as debtors continued
recoveries in India has been very
economy underwent during its to hold the controlling power and
long and often extending up to 15 growth phase of 2004-09. As were unable to make progress on
years, as historical data suggests. profitability and revenues were on the resolution process. The
According to World Bank, India the rise in almost every sector, Government of India and the RBI
takes over 4 years to declare a corporates anticipated future introduced several initiatives to
promoter or a company insolvent demand and rapid capacity expedite the resolution and
which is more than twice the time augmentations became a norm. The restructuring of bad debt, however
taken in China and USA. story however didn't end well - this too was not successful with
Consequently, Indian banks have post the 2009 financial crisis, the recoveries averaging less than 20%.
been observed to recover only 25 return on investments were Initiatives such as Joint Lender
cents to a dollar compared to 36 nowhere to be seen. With slowing Forums (JLF) on the other hand
cents in China and as much as up to exports and subdued domestic
were formed to get all lenders on
80 cents in USA. demand, corporates sat on
one platform but it was plagued by
The Insolvency and Bankruptcy excessive capacities and utilization
regulatory complications. Also,
Board of India (IBBI) is the levels languished at near 65%
multiple lenders to one account
country's attempt to safeguard levels. Further, regulatory changes
made matters complex as resolution
in certain sectors such as power,
creditor interests and builds a of every NPA account with
coal and telecom had also led to
framework that will introduce multiple lender parties required an
stress in several loans. The most hit
specialist recovery agents as soon as approval constituted by at least
were large borrowers (corporates),
an event is triggered. Now 60% by number and 75% by
with larger exposures. Since most
widespread in most prominent quantum. Lending banks therefore
slippages were in exposures of the
economies, the 'in -place' system continued to accumulate non-
Rs. 200 million category and over,
will aid speedy resolutions of bad performing assets without any
lenders comprising mainly of
debt as India evolves into a full- resolutions, over heating their
commercial banks and bond
fledged market economy. balance sheets. The provisioning
holders found themselves at risk.
Public sector banks were the most made for such accounts mounted
The rise of insolvency
vulnerable and were holders of additional pressure on bank Net
and bad debt nearly 75% of these loans and Interest Margins and caused
Bad loans are estimated to be nearly therefore potentially $60-$100 lending resources to diminish. In
8.4% of Indian GDP and are billions of loans are in systemic lock the scenario, without NPA
estimated to rise moderately in the out. resolutions, banks have become
Financial Foresights 5Industry Insights
increasingly conservative in their the National Company Law committee will receive an extension
lending operations adversely Tribunal (NCLT) then authorizes of 90 days beyond which
impacting offtake. the process and gives a go ahead to liquidation will be initiated. The
the IRP. This is followed by the entire process will be under the
The initiation of creation of a Creditor Committee supervision of a registered
Insolvency Resolution (CC) that decides upon the fate of Insolvency Professional (IP), who
Process (IRP) the failing company. Notably, the will be appointed by the IBBI. The
Creditor Committee composes not IP will also oversee the liquidation
The introduction of the Insolvency
only of the large secured creditors of the company in an event when
and Bankruptcy laws is expected to
(namely commercial banks) but also the CC has been unable to reach a
restore the control to the creditors
workmen (employees) whose dues decision within the stipulated 270
and hence is an attempt to
are outstanding along with bond days of the proceedings.
safeguard their interests. The
holders. Also, worth mentioning is Furthermore, dedicated
Government's vision is to build a
the fact that Government's share in Information Utilities (IU) will be
framework that will introduce
the debt outstanding is considered appointed to assist the IRP. These
specialist actors as soon as an event
junior to all other obligations. IUs will be specialist information
is triggered. Now widespread in
Within the new waterfall archivers, which will facilitate the
most prominent economies, the in -
mechanism, the former's share is proceedings through supply of
place system will aid speedy
classified as subordinated and credible financial information
resolutions of bad debt as India
follows private parties and pertaining to the company in
evolves into a full-fledged market
workmen. This is done to question. It must be noted that the
economy. Under these laws, an
encourage unsecured parties and period for which the IRP is in place,
Insolvency Resolution Process (IRP)
deepen India's bond markets. there will be a moratorium, within
is triggered by a creditor as soon as
Once the IRP is initiated, the CC is which no claims will be settled.
a default event occurs. The process
given 180 days for the debt Proceedings will culminate into a
starts with an intimation sent by
resolution, if no decision is reached dispute resolution encompassing all
any creditor to the defaulted entity,
within the timeframe, the parties involved.
The IRP Process Diagram
Secured Creditors,
Insolvency Workmen, Bond
Creditor Committee (CC)
Professional (IP) Holders,
Government
Information Utility (IU)
Company in Default
Financial Foresights 6Industry Insights
Benefits also reduce the time involved and help reform defaulter apathy
offer an alternate path. Importantly, towards creditors. With a dedicated
l Transfer of control to creditors
for individuals with annual income standardized process in place that
l No disparity between secured of less than Rs. 60,000, the IBBI involves specialized actors
and unsecured creditors provisions a 'Fresh Start' that committed to resolve a default
l Introduction of a specialized basically allow entrepreneurial scenario in a time bound fashion -
framework and actors spirits to continue. we expect significant impact on the
l Speedy resolution (provision of very perception of default. As
Conclusion
180 days and maximum of 270 things stand today, even though it
We believe that the IBBI will is still too early to assess the real
days)
eventually subsume most changes that will be brought about
l Government dues treated as
bankruptcy and insolvency by the IBBI, it is clear that debt
junior debt within the water fall
instruments such as SARFAESI Act, restructuring or eventual
mechanism
RDDBFI Act, S4A and SDR and liquidation will be a speedier
Systematic insolvency and allow more transparency and exercise and hopefully less
bankruptcy proceedings for accountability. The impact of the frustrating for the stakeholders. n
individuals on the other hand will IBBI will be far reaching and will
Sankar Chakraborti is Independent Director on the Board of Indian Oil Corporation Limited, India's largest and a Fortune
500 company and
l Member of the Working Group constituted by the Insolvency and Bankruptcy Board of India for recommending the
strategy and approach for implementation of the provisions of the Insolvency and Bankruptcy Code, 2016.
l Member of FICCI's Capital Markets Committee
l Member of IBA's Standing Committee on MSMEs
l Member of the Board of Studies (Finance) of SIES College of Management Studies (SIESCOMS)
At SMERA, Sankar is leading SMERA's transformation from being world's first SME focused credit rating agency to a
technology and innovation driven global knowledge company. SMERA has completed rating of over 47,000 entities. To know
more about SMERA click here.
Prior to SMERA, Sankar has worked for CRISIL, Centre for Monitoring Indian Economy (CMIE) and Capital Market
Magazine. He was part of the founding team of CRISIL Research and CRISIL's Bank Loan Rating businesses. He was also
deputed to S&P's Tokyo office in 2006.
Sankar is a sought after speaker at universities, seminars and thought leadership forums.
Sankar aims to assist businesses make informed and better decisions to achieve profitable growth, and to help bring in
transparency to financial transactions, through independent & unbiased opinion. He firmly believes that trust, innovation,
excellence and service are the four values of a rating agency which is going to keep it relevant and meaningful in the coming
decades.
Financial Foresights 7Industry Insights
Evolution of I&BC -
Initial Impressions
Sanjeev Krishan
Leader, Deals and Private Equity
PwC India
In one year, Insolvency & where cases have to be resolved usage of IBC can be estimated by
Bankruptcy Code (IBC) has come a within 180/270 days, failing which simply looking at the data provided
long way with 2,434 fresh cases the corporate debtor will have to by Lok Sabha. Since the
being referred to NCLT. The undergo liquidation. Prior to the introduction of IBC, 2,434 new cases
Economic Survey 2017-18 tabled in code, it used to take multiple years have been filed before NCLT and
the last week of January 2018, for creditors to resolve NPA. IBC 2,304 winding up cases have been
described IBC as a mechanism has also been instrumental in transferred from High Courts
which is being used actively to consolidating multiple debt across India as of 30th November,
resolve NPA problem of the resolution/ recovery platforms such 2017. These numbers clearly show
banking sector. IBC has been cited as DRT, SICA, SARFAESI and High that IBC has become the preferred
as one of the most significant Court. Now creditors have a clear route to resolution for the creditors.
reforms introduced by the current guideline to follow that clarifies Also, the rate at which NCLT is
government. Government has also details till last mile including the either accepting or rejecting
been proactive in introducing manner of distribution of recovery applications is commendable as it
various amendments strengthening proceeds. encourages more and more
the bankruptcy framework. The IBC brings about a paradigm shift creditors to take this route for
real impact of the code will be seen in recovery/ resolution process by efficient NPA resolution.
upon completion of the resolution introducing the concept of creditor
process of the first twelve cases
Key amendments and
in control from debtor in
where insolvency proceedings were possession. This encourages value their likely impact
filed by banks mid - last year. enhancement of the corporate After the introduction of this Code,
However, early positives have been debtor as once this process start, the it was felt that promoters may be
seen in World Bank's ranking board cedes control of the company able to bid for their businesses /
where India's position in ability to and insolvency professional along assets and possibly get back at a
handle insolvency cases improved with the help of professional heavy discount through
by 33 places to 103rd position. This advisors start managing the participation in resolution process
jump contributed significantly in company. and start afresh with clean balance
India's ease of doing business sheet. As this was something
Post admission of 12 largest NPA
ranking by 30 places to join top 100 undesirable, government came up
cases, banks have been gearing up
countries club. with a major amendment to the
to refer majority of cases from RBI's
One of the main attractive features second list of 28 accounts, which is Code which has made it extremely
of the IBC is its time bound nature under progress. Magnitude of difficult for defaulting promoters to
Financial Foresights 8Industry Insights
participate in the resolution process ensure that all legitimate result in an approval from
of the corporate debtor. In case such creditors are considered in the mentioned regulatory bodies.
promoters want to participate in the resolution plan. Additionally, Accordingly, it is suggested
resolution process, they must repay clarification with respect to that Code clarifies highlighting
their dues in a month time. Post this handling past liabilities, that such grants and requests
amendment, many people have contingent liabilities and made by the successful
debated if such a restriction will ongoing material litigations resolution applicant are heard
reduce competition among will also be a big positive for and closed in a time-bound
bidders. Similarly, MSME that are interested applicants. manner.
relatively smaller in size, might not Corporate debtor might have
l The Code does not provide for l
attract any bidders. Such a scenario third party agreements that
the management of the
would increase the haircut for the might be detrimental to the
corporate debtor during the
creditors or worse, a large number period between NCLT company. It is felt that Code
of cases would end up in approval and transfer of should empower successful
liquidation causing loss of jobs and ownership. Post NCLT resolution applicant to modify
destruction of enterprise value. The approval, the successful bidder such agreement in best
jury is still out on the impact of this has to perform various interests of the company
amendment on resolutions under transaction related activities in without facing any penalties
the code. addition to obtaining approvals that might be applicable as per
On the other hand, in order to from multiple regulatory previous agreements.
ensure large pool of investors, bodies and other authorities. l NCLT's objective of completing
amendment brought relief by During this significantly long resolution and keeping
allowing asset reconstruction period, the Code should detail liquidation as a last resort
companies, alternative investment out the environment in which should also reflect in the voting
funds (AIFs) including private the company will operate. An requirement. Currently,
equity funds to participate in the example in this regard is the requirement of 75% votes for
bidding process. moratorium period that ceases approval of plan (i.e.
While NCLT will keep on working to have any effect once NCLT resolution) means that a small
towards improving the Code, it is approval is obtained. However, percentage (25%) of votes can
important that industry change of control in the take the company to
participants who are involved in company happens much later. liquidation.It is felt that a
the process also provide their Also, what is the role of the requirement like this results in
feedback and suggestions which Insolvency professional and high probability of liquidation
they are doing through IBBI. IBBI under what terms do they get which is not ideally desirable.
has been proactively engaging with engaged during this period, if In order to derive maximum
Insolvency Professionals to collect at all. value from the corporate
reports of and feedback on ongoing l There is a major challenge debtor, it will be in best
cases. We feel that there are certain currently present in completing interests of all stakeholders if
areas in the Code that can be the ownership change due to voting criteria is revisited.
modified for more clarity and various approval conditions. Reducing the percentage based
smooth transaction process. In most cases successful on value and also introducing a
resolution applicant has to take concept of percentage by
l There might be cases where
approvals from bodies such as number could be more
creditors do not submit claims
SEBI, RBI, NSE, BSE, CCI and equitable.
or claims which have been
submitted are under dispute. others. However, these bodies l With the framework evolving,
Code should explore clarifying are not bound by NCLT and an role of Insolvency Professional
treatment of such cases to approval from NCLT might not (IP) is also becoming more
Financial Foresights 9Industry Insights
challenging. One major issue control of the company or visit cases come to a close and set
faced by IP is that the claims the premises. precedents for future. While IBC
are to be collected within a has provided creditors with a new
l It is unclear how transactions
fixed specified period. As per tool to manage their relationship
will unfold what terms
our experience, this is a with debtors, its impact on
identified during lookback improving future credit scenario in
difficult task as claims keep on
period review. Also, given the India and on avoiding bad debts
coming during the entire life of
short time frame for corporate going forward is yet untested.
process that makes list of
insolvency resolution process, However IBC has the potential to
creditors dynamic in nature. So
level of detailing in 2 year be a game changer for the Indian
far, we have seen slow
lookback review is debatable. economy. Not only would it help
developments in the formation
The public sector banks who banks release capital which is
of information utilities. In a
are under the scepter of locked-in in NPAs, it will also instill
year's time, only one
CVC/CBI are also reluctant to credit discipline among bank
information utility has come
initiate/progress such audits. officials. Promoters also will have a
into existence. We can expect a
One suggestion could be that higher sense of responsibility and
few more of such entities companies are expected to be
transactions above a certain
coming up which would be a identified as stressed at an early
threshold (for example,
big plus for claim verification stage. This framework also presents
transaction amount as a % of
and will be of significant a huge opportunity for Indian debt
turnover) should only be
assistance to the IP. market where majority of
looked.
l NCLT should also identify investments are private in nature.
IBC can present itself as a friendlier With debt resolution picking pace,
bodies that can provide
environment for all the Indian debt market has the
security to IP in case company
stakeholders by focusing on above potential to become vibrant with
officials do not cooperate due
mentioned areas. Clarifications are increasing share of public
to which IP is unable to take
likely to keep coming as current investments. n
Sanjeev Krishan is a partner in Financial Advisory Services with over 20 years of professional experience in carrying out due
diligence reviews, share and business valuations, business plan and working capital reviews for multi-national clients as well
as domestic clients, both in the private and public sectors.
Sanjeev worked with PwC Stockholm for a period of 20 months between 1998 and 2000 where he gained exposure in working
with financial investors and also worked with numerous strategic investors. Apart from India and the Scandinavian countries,
he has worked on deals in United States, United Kingdom, Continental Europe, Indonesia, Bangladesh, Japan, Thailand and
Middle East.
He is the Private Equity leader of PwC India and does a lot of work for private equity clients in India, and also co-ordinates
and leads efforts regarding outbound transactions. Some of his private equity clients include Apollo, AION, Apax, JP Morgan,
Carlyle, Sequoia, Advent, AMP, CVC, GIC, Providence, Macquarie, TA Associates, amongst others. Sanjeev works with
clients from a cross-section of industry segments.
On a functional basis, Sanjeev works across the deal continuum, with a focus on due diligence / valuation and post deal
services, specifically including review of sale and purchase agreements, negotiation support, transaction structuring and post
closing and integration advisory.
The article has been co-authored by Ankur Kedia. Ankur is Associate Director of Business Recovery Services and specializes
in the field of distressed debt and business turnaround solutions. He has more than 10 years of professional experience
spanning across corporate banking, asset reconstruction and advisory. He has experience across the entire spectrum of debt
financing. As a advisory professional he has helped companies syndicate, refinance, restructure and settle their balance sheet
debt. As part of the investment team of an asset reconstruction company he has made successful investments in companies
facing financial stress.
Financial Foresights 10Industry Insights
Role of ARCs in the post IBC era
Birendra Kumar
Managing Director & CEO
International Asset Reconstruction Company Private Limited (IARC)
Introduction clean the NPAs off the bank's books uniqueness of the IBC, the biggest
but also to turnaround the sick change that the IBC seeks to bring
The trigger for the enactment of the
units to the path of profitability. to the table is to instill a sense of
SARFAESI Act in 2002 and for the
While the principle of the discipline amongst trade and
Insolvency and Bankruptcy Code in
enactment was laudable, and ARCs industry regarding the need of
2016, is the same - the need to
have indeed emerged as a viable timely payments by providing the
resolve the problem of the ever
option for banks to clean their unpaid vendor with an effective
mounting non-performing and
books, the results have been well remedial tool. It also aims to bring
stressed assets in the banking
short of expectations and the the essence of 'time'amongst
system. In the fourteen years that
volume of stressed assets in the lenders, judicial fora and
have passed between the two
books of banks has only increased professionals - a quintessential
enactments, much has been done to
over time. The stories of factor for preserving the value of an
improvise the remedies available to
turnaround post restructuring by enterprise which is on the verge of
banks and financial institutions.
ARCs have been few and far in bankruptcy. The swiftness with
While the legislature has amended
between. While the purpose of this which the Government, the
the existing laws like the Recovery
article is not to discuss the reasons Regulators (IBBI, RBI and SEBI) and
of Debts due to Banks and Financial
for the above, factors such as the the judiciary are acting, is
Institutions Act, (RDDB) and the
capital crunch with ARCs, the issue unprecedented and sets the tone for
SARFAESI Act, the Regulator has
of price expectations between ARCs all else to emulate. Whether they
introduced new schemes like the
and seller banks, the lack of a like it or not, decision making in the
Strategic Debt Restructuring (SDR)
favorable legal environment to banking system right from the
and S4A to fight the menace. Much
support recovery efforts have been branches to the head offices, will
recovery has happened owing to
some of the contributing factors. need to be quick, as delays can be
the above initiatives, but certainly
fatal. Consensus and solution
not enough to give the bankers, the Why is the IBC a game oriented approach amongst the
government and the regulator a changer? creditors sitting on the committee is
sound sleep.
Just like when the RDDB Act and yet another factor which banks will
Asset Reconstruction Companies have to deal with - as deadlocks
the SARFEASI Act were introduced
(ARCs), at the time of their birth in will lead to liquidation.
in 1993 and in 2002 respectively,
2002 were seen as a panacea for the
many have raised doubts as to how Why the IBC is also a game changer
resolution of the NPA problem.
the IBC will be successful in doing is because, while it builds upon the
ARCs were conceptualized as
what those Acts have not been able laudable aim of rehabilitation just
specialized companies with the
to do. While much has been like the Sick Industrial Companies
onerous responsibility to not only
written and discussed on the Act, this new law is circumspect of
Financial Foresights 11Industry Insights
the pitfalls that SICA faced and is ticket accounts that have been there is enough value still
thus decisive on the outcome of a taken to the NCLT fall in the existing in the asset.
failed attempt of restructuring and second or third category - lack Second, the ARC, having
that too within a time limit. of or no bidders. Given that bought the account at a
banks have to provide 50% discount from the original
ARCs in the IBC era? provisioning in their profit and lender bank, is in a better
Over the past fifteen years, the loss account once an account is position than that bank to
number of ARCs has increased to referred to the NCLT, the pinch negotiate a competitive deal
24 and there are more awaiting is painful especially where the with a prospective bidder.
regulatory clearances. Many of resolution plan is dependent ARCs' ability to aggregate the
these are backed by strong domestic upon the sale to bidders. It is debt also favorably assists it to
and international financial even more painful given the gain a majority voting share on
institutions and have developed fact that provisioning increases the Committee of Creditors and
capability to turn around ailing to 100% in case the resolution drive the resolution plan.
industrial undertakings. As banks plan fails for want of bidders or
l Interim financing
look at IBC favorably as an otherwise and the debtor goes
effective means to recover their into liquidation. A bank is, The IBC defines 'interim
dues, thus pops the question therefore, in a catch 22 situation finance' as any financial debt
whether ARC - the child of where if it accepts to sell to the raised by the resolution
SARFAESI - would continue to bidder it has to suffer a huge professional during the
remain relevant? The answer is a haircut and if it doesn't and insolvency resolution process.
clear yes, and is based on three allows the account to go into From where the resolution
fundamental principles - The IBC is liquidation, then it stands to professional shall raise this
primarily intended to be a means of lose a larger portion of the finance is not specified and
reviving and rehabilitating units at money lent. hence is open to all who may be
the verge of failure and not a willing to provide. It is
This paradox throws open two
recovery tool. The business of unlikely that a bank, with its
opportunities for ARCs. One,
banks is banking and not recovery; loan unrecovered on the one
not all lenders to the debtor
ARCs are meant to be strategic hand and the burden of
would have felt the need to
restructuring specialists and not provisioning on the other,
initiate the insolvency process.
extended hands of banks for would want to risk additional
Initiation of IBC proceedings
recovery. funds by way of interim
by some other financial or even
financing to a borrower
Given the above principles, ARCs operational creditor would
undergoing corporate
have a very unique and important mean forced 50% provisioning
insolvency process. ARCs can
role to play in the IBC regime. by each lender bank.
fill this vacuum and provide the
l Provisioning woes of banks Commercially, it may make
much-needed finance required
and debt aggregation ability sense for the bank to assign the
to fund the operations.
of ARC loan to an ARC than to commit
However, in the event of
50% provisioning and then
A good sale is when you can liquidation of the debtor,
wait for its money to be
negotiate amongst competing interest payable on such interim
recovered upon success of a
multiple bidders. Lack of financing should not be
resolution plan. This is
multiple bidders means you are restricted to the liquidation
especially true for SMA
forced to put up with a limited commencement date. Clarity
category of accounts (which are
few and sell in a buyers' from the RBI would perhaps
not yet declared as NPAs),
market. No bidders mean you help whether interim financing
where little cushion exists in
write off a loss. Unfortunately, by ARCs, especially when they
the form of provisions and
most of the small and medium
Financial Foresights 12Industry Insights
are not a financial creditor to financial sponsors, as are undertaking changes within to
the debtor under insolvency, mentioned earlier, are suitably meet the aims of this new law,
would be in consonance with placed to tie the lose ends and ARCs too will have to change and
their permitted activities under submit a viable resolution plan. evolve. The IBC is a golden
the SARFAESI Act. opportunity for the ARCs to assert
Conclusion
l Match making their unique position and leverage
The IBC is a game changing law. from their experience gained over a
The recent Ordinance followed
The new game demands to be decade and a half. They will have to
by the amendment to the IBC
played according to new rules and rise to the occasion as the real
has restricted the eligibility as
hence each player will have to turnaround experts - a laudable aim
to who can be a resolution
either transform or perish. As that SARFAESI intended but
applicant. As such, ARCs -
given the specialized expertise, various stakeholders - trade, somehow got lost in practical
industry knowledge and with industry, banks, insolvency difficulties -because opportunity
the backing of their strong professionals, courts and regulators seldom knocks the door twice.n
Birendra Kumar is Managing Director & CEO of International Asset Reconstruction Company Private Limited (IARC).
Mr. Kumar has been a career banker with over 5 decades of rich and diverse experience in commercial, investment &
international banking in India and abroad. He was the Deputy Managing Director & Chief Credit Officer of State Bank of
India, the largest public sector Bank in India. Prior to that, he was the MD & CEO of SBI Capital Markets Limited for a
period of over three years.
Mr. Kumar has wide experience in the stressed asset sector, having been Advisor, Financial Advisory Services, PwC, Mumbai
from 2002 to 2007 wherein he was instrumental in initiating and leading Business Recovery Services (Distressed Debt
Advisory) practice of PwC in Mumbai. He was actively involved in advising ARCs on positioning strategy, formulation of
business plan and operationalization strategy and in developing policies and procedures.
Mr. Kumar has served on several Expert Groups set up by the Reserve Bank of India and Government of India. He was a
Special Invitee nominated by RBI on the in-house working group set up to examine issues pertaining to development of market
for asset securitization and for high level meeting convened by Government of India in January 2002 on setting up the first
Asset Reconstruction Company. He was the member of the PwC team for undertaking a study on behalf of Asian Development
Bank and Government of India to suggest regulatory changes for creating an enabling environment for successful functioning
of Asset Reconstruction Companies in India.
Mr. Kumar was the member of Key Advisory Group set up by the Government of India to study and recommend measures to
improve the functioning of ARCs. He was also Member of Ministry of Corporate Affairs Working Group on operationalization
of the Insolvency & Bankruptcy Code. He is currently Member of FICCI's Core Group on Insolvency Laws & Chairman,
Association of ARCs in India.
Financial Foresights 13Industry Insights
Asset Reconstruction under
IBC regime - Advantage ARCs
Jaisry Mani
Chief Manager - Law
Edelweiss Asset Reconstruction Company Limited
The idea of Asset Reconstruction reforms in the insolvency and Insolvency professionals and the
Companies (ARCs) was conceived bankruptcy regime are critical for transactions under Corporate
during the previous banking crisis improving the business Insolvency Resolution Process. It
under the SARFAESI Act, 2002. The environment, the Government has has the power to frame and enforce
powers conferred on the ARCs taken concrete measures to prove rules relating to corporate
under the legislation to repossess that with the successful insolvency resolution, corporate
secured assets and sell without the implementation of the Code, there liquidation, information utilities,
intervention of courts worked well will be a greater impact on the individual insolvency and
in the initial phase. However, over economy and the financial sector of bankruptcy.
the past 15 years, its effectiveness the country which will promote
and efficiency seem to be restricted entrepreneurship & revival of sick Post- IBC- shift in
to small mortgage loans and SMEs units. This law along with all the approach
where asset stripping is the primary underlying rules, regulations and
resolution strategy. Asset various amendments have paved Time bound resolution is the key
reconstruction or any meaningful the way for setting up of 11 objective of the Code. IBC seeks to
resolution in medium and large National Company Law Tribunals promote entrepreneurship and
assets, particularly manufacturing (NCLTs) across the country before availability of credit for revival.
assets relatively has not been whom cases for Corporate The Code also seeks to promote re-
possible due to multiplicity of laws Insolvency Resolution Process organisation of the company in a
and judicial forums under the could be filed by a Financial systematic manner, failing which
prevailing legal framework which Creditor/ Operational Creditor/ the liquidation of the concerned
hindered effective recovery, revival Corporate Debtor itself. The Code entity is invited. The Code
or liquidation. also laid the path for envisages a "Creditor in Control
individual/partnership Regime" with the Committee of
In the above backdrop, Insolvency Creditors (CoC) playing a vital role
insolvencies provisions of which
and Bankruptcy Code, 2016 in the whole process. The Code
are yet to be notified. The
(IBC/Code) has emerged as a envisages that any action with
Insolvency and Bankruptcy Board
pragmatic law conceived with the respect to the corporate debtor
of India (IBBI) being the sole
primary objective of facilitating under the Code needs the
regulator was set up on 1st October,
time bound resolution failing which consent/vote of at least 75% of the
2016 under the Code which
liquidation. Recognizing that voting share of the financial
regulates the profession of
Financial Foresights 14Industry Insights
creditors/ CoC. The CoC Preponderance of liquidation cases statutory approvals; which in a
comprising of financial creditors are in the initial phase of IBC Code is given case may be difficult and
in a position to identify early probably on account of large time consuming thereby
insolvency symptoms of a number of erstwhile BIFR cases resulting in the delay of
borrower. which got filed under the Code and implementation of the
hence may not be a true pointer of Resolution Plan.
Enhanced role and the trend of things to unfold in
l Multiple Resolution Plans: It
relevance of ARCs post future. Legal and administrative
is possible that the Resolution
issues continue to be ironed out by
the IBC Code Plan voted by the CoC may not
the capable jurisprudence of the
go through and if the second
ARCs as assignees of secured debt NCLTs including the Hon'ble
plan is not kept alive, then the
of banks/financial institutions Supreme Court and the Hon'ble
CoC will not have a fall back
including NBFCs are at an High Courts. The receptiveness of
mechanism and the company
advantageous position due to their all the stakeholders including the
will go into liquidation,
ability to aggregate debt from all or Government, regulators, the
therefore multiple Resolution
majority lenders with necessary judicial system, and secured
plans should be allowed.
expertise as well as focus to turn creditors augur well for a smooth
around stressed and distressed implementation of the Code. l Recourse against the
assets or companies. With such guarantors: Normally a
expertise along with majority debt Key challenges faced Resolution Plan would
holding and the willingness / under the Code envisage haircuts and would
appetite to take additional exposure entail release of guarantees by
by way of priority loans in select l Related party under Section demand or by implication.
5(24) of Code: Inclusion of However if the Resolution Plan
cases, ARCs would be able to chalk
Banks, FIs, ARCs who have fails, the recourse to the
out an appropriate resolution plan
converted part of Debt into guarantors would be lost,
for revival of stressed/distressed
Equity in the definition of therefore the Creditors must be
industries where by interest of
'Related party' disentitles them allowed recourse against the
every stakeholder is considered on
to be a part of the CoC if the Guarantors in case the
equitable grounds and adequately
equity held by these Banks, FIs Resolution Plan fails.
protected.
and ARCs is more than 20%.
l Group restructuring: Presently
Journey so far under the l Amendment Bill & Ordinance: no provision under the Code
Code Prohibition of all promoters and/or regulations
from Bidding and not allowing contemplates a common
As on date more than 500 cases
genuine and bona-fide resolution plan being
have been admitted under
promoters to bid may result in implemented in respect of
Corporate Insolvency Resolution
reduction in the number of multiple entities within the
Process (CRIP); 115 cases are
competitive bids and may also same group.
admitted under Voluntary
lead to liquidation if no
Liquidation Process and about 38 l Cross border insolvency: These
Resolution Applicant comes
cases under Liquidation. Out of sections though notified, these
forward.
these cases, resolution plan for by itself may not be enough for
insolvency resolution of the l Statutory approvals: A the actual implementation of an
corporate debtors have been Resolution Plan may provide efficient and feasible cross-
approved by NCLT in many cases. for application for fresh border insolvency regime.
Financial Foresights 15Industry Insights
l Liquidation value due to the corporate debtor and may the CoC in control, the turnaround
dissenting financial creditors: fail to attract good or viable of the Company if found viable will
As per Regulation 38 of the resolution plans. be the foremost step taken by the
CIRP Regulations, Liquidation CoC for maximization of value of
l Funding of the resolution
value due to dissenting the assets. Early identification and
plans: A Resolution Applicant
creditors needs to be paid prior corrective actions on the part of
may have a suitable plan to
to any recoveries by consenting various authorities will help make
help the Corporate Debtor
creditors. The Corporate the Code a robust law to tackle the
come out of the CIRP process,
Debtor/ Resolution Applicant malaise of NPA early. After the
but it may be possible that such
may not have funds to pay amendment of the ordinance, many
a Resolution Applicant requires
these dissenting financial borrowers/companies are
funding for such Resolution
creditors immediately. desperate to make at least some
Plans.
payments to the banks to be
l Challenges in obtaining
stopped from being classified as
interim finance: Presently Journey ahead
NPAs. Exciting times lie ahead for
there are many challenges in
The positivity around the all lenders, ARCs, borrowers,
obtaining Interim finance from
implementation of the Code shown potential resolution applicants,
existing banks due to
by the regulators and the professionals and experts to
provisioning and asset
Government is not only reassuring experience and work together to
classification norms. Also it is
but is also sending a clear message make the most practical and
not clear whether the interim
that resolving the NPA problem consolidated law a success for
finance provider can charge
faced by the country is certainly the many years to come. This is
interest on the interim finance
top most priority and Insolvency expected to place India in the race
after the commencement of
and Bankruptcy Code is the law by of countries for 'ease of doing
liquidation.
which this problem can be businesses. Although the law is still
l Markets for interim finance: addressed in a systemic and in a in its nascent stage, the overall
The Corporate Debtor usually time bound manner. With the feeling of the stakeholders is that
do not have adequate liquid option of providing Interim Finance the Insolvency and Bankruptcy
assets to continue its to such Corporate Debtors, the Code, 2016 is a game changer and a
operations, in that case, it may Companies can immediately start to paradigm shift in the laws relating
reduce the enterprise value of function as a going concern. With to Insolvency.n
Jaisry Mani is Chief Manager, Law at Edelweiss Asset Reconstruction Company Limited. Prior to joining Edelweiss Asset
Reconstruction Company Limited, she was a practicing lawyer associated with law firms with over 6 years experience in
Arbitration (International and Domestic), litigation and non-litigation matters. Having joined Edelweiss in 2016, she is
currently managing the Insolvency and Bankruptcy matters along with other recovery matters of the Company
Financial Foresights 16Industry Insights
Insolvency & Bankruptcy Code
A Brief Analysis on Recent Market Trends
Abhishek Pandey
Managing Director
Duff & Phelps
IBC: The much awaited cleanup exercise in India's history. Resolution Process (“CIRP”) in a
The Corporate Insolvency nutshell is as follows:
reform?
The Insolvency and Bankruptcy
Code has been in force for more
than a year, and given its ambitious Default by company
objectives and impact, it continues
to make front page news. Following
the footsteps of bankruptcy laws in Filing of Application before
Adjudicating Authority
developed economies like the UK
and USA, IBC provides an excellent
single framework to deal with Appointment of an Insolvency
Professional (IRP/RP)
insolvent and bankrupt firms. The
most important function served by
the Code is that it makes a clear Moratorium Period
(180/270 days)
distinction between insolvency and
bankruptcy, the former being a
short-term inability to meet the CoC Formation
firm's liabilities, and the latter being
a long-term view of the firm's
ability to meet its liabilities. Since
Resolution Plan Proposed
insolvency is a short-term situation,
it is extremely important to
distinguish it from bankruptcy and
provide a chance to the business to 75% of
Goes into Implement the
turn around. So far, more than 500 No Creditors to Yes
Liquidation Resolution Plan
Approve Plan
companies have been brought to
court by banks under IBC, leading
to what is possibly the largest NPA
Figure 1: Brief Description of CIRP under IBC, 2016
Financial Foresights 17Industry Insights
The Code was also hailed for days or 270 days as the case may However, it is interesting to note
addressing the problem of delays in be, the corporate debtor is that as per a recent article by
the system by prescribing a clear liquidated as per the orders of the Hindustan Times, a fifth of all IBC
timeline for the process. NCLT. This aspect of the process
cases have already crossed the 180-
makes it look like an attractive
If the corporate resolution plan is day deadline. The article mentioned
route for recovery of bad debts. The
not complied with within the official timeline of the process can that out of 525 cases admitted in
moratorium period of either 180 be seen below: NCLT so far, resolution plans had
only been approved for 10
companies and liquidation orders
were passed only for only 30
No. of days companies. None of the big fish out
Day –ve 14
of the first list of 12 companies
Filing of
application singled out by Reserve Bank of
to NCLT India have reached a conclusive
stage so far. It appears as if the
Admission of initial heat around IBC is beginning
Declare moratorium 0 application
to wane and it might not end up
providing the time- bound relief to
creditors. However, it would
NCLT to appoint interim 14 interesting to wait and watch the
resolution professional 16 Public
announcement progress over the next year and the
banking sector cleanup continues.
Appoint 2 registered
21 valuer to calculate
liquidation value
IBC: Standards of value
IRP to constitute CoC and 30 to 44
submit 30 to 44 report As per section 35 (1) of the
Insolvency and Bankruptcy Code,
37 Creditors to
submit claims 2016 (“IBC”), “Liquidation Value is
the estimated realizable value of the
1st CoC assets of the corporate debtor if the
51
meeting corporate debtor were to be
liquidated on the insolvency
65 Preparation commencement date”. Further,
of IM
section 35 (2) of IBC requires the
Submission of plan 150 valuer to determine liquidation
value using internationally
accepted valuation standards.
CoC's approval of
resolution plan According to the International
Application for Valuation Standards (“IVS”) 104,
170
NCLT approval “Liquidation Value is the amount
that would be realized when an
180 Initiation of
liquidation asset or group of assets are sold on
a piecemeal basis, that is without
Figure 2A: Timeline of CIRP under IBC, 2016 consideration of benefits (or
Financial Foresights 18Industry Insights
detriments) associated with a period of time to find a purchaser circumstances will depend upon a
going-concern business”. (or purchasers), with the seller number of factors such as available
being compelled to sell on an “as-is, time for disposal, market depth, etc.
According to the Indian Banks'
where-is basis”. It may also reflect the consequences
Association (IBA), ”Liquidation
The reasonable period of time to for the seller on failing to sell
Value describes the situation where
find a purchaser (or purchasers) within the period available.
a group of assets employed
depends upon asset type and As such, the premise of Liquidation
together in a business are offered
market conditions. Forced sale Value for the said purpose is
for sale separately, usually
describes a premise where a seller is Liquidation Value of the assets on a
following a closure of the business”.
under compulsion to sell and that, standalone basis (in most cases) or
An orderly liquidation-based value as consequence, a proper marketing in some cases group of assets in an
is the one that could be realized in a period is not possible. The price orderly sale.
liquidation sale, given a reasonable that could be obtained in these
+
Typically, acquisition value by a
Businesses Synergistic Value
strategic buyer
with no
imminent
Orderly Typically, acquisition value by a
fear of
Transaction in no nancial buyer
liquidation
Distress Situation
Orderly Transaction Based on
in Distress Situation Sale as a going concern
Resolution
(business sale) rather than individual assets
Plan
Businesses
Orderly liquidation Liquidation Sale as individual assets
facing
(piecemeal basis) Value where sufcient time available
liquidation
Estimate for transaction
Forced liquidation Sale as individual assets
(piecemeal basis) where sufcient time not available
for transaction
-
Figure 2B: Brief Description of Standards of Value under IBC, 2016
Breaking down the glut – points towards the cooling real defaulters (public companies only)
estate market and its impact on the being approximately INR 95,600.0
who's going bankrupt? Cr as of December 31, 2017.
associated industries. Delayed
implementation of projects due to Downturn in the commodities
Real estate, construction and
land acquisition and environmental markets, coupled with low
engineering segment made up
international competitiveness of
about 21.8 percent of all publicly clearances further adds to their
Indian firms in the global market
listed companies by asset value obstacles to generate revenue.
has made it difficult for this
with combined asset size of industry to revive. In cases like
The Metals industry (17.3 percent)
approximately INR 91,260 Crore Bhushan Steel, significant capacity
has also been significantly affected
(“Cr”) as of December 31, 2017. This with a total asset size of all expansion was undertaken at the
Financial Foresights 19Industry Insights
peak of the commodity price cycle, industry is going through Kalyanpur Cements Limited, Amit
leading to investments which never significant downsizing. Spinning Industries Limited and
generated enough return. Jenson & Nicholson (India) Limited.
Key trends 5.4 percent of all publicly listed
The Technology industry (1.8
percent) saw the least number of defaulters filed for insolvency/
16.2 percent of all publicly listed
defaults, primarily due to lower bankruptcy with NCLT fall in the
defaulters filed for insolvency/
financial leverage requirements in range of INR 50,000.0 - 1,00,000.0
bankruptcy with NCLT fall in the
the industry, resulting in lower Cr, including companies like
range of less than INR 100.0 Cr.,
cases filed with NCLT. This, Bhushan Steel Limited and Lanco
however, may change as the including companies like
Infratech Limited.
Total Assets (Size Segmentation)
5.4%
16.2%
Less than INR 100.0 Cr 13.5%
INR 100.0 - 1,000 Cr.
INR 1000.0 - 10,000.0 Cr
INR 10,000.0 - 50,000.0 Cr 29.7%
35.1%
Greater than INR 50,000.0 Cr.
Figure 3: Range of Total Asset values of public companies led with NCLT under IBC, 2016
Public defaulters led with NCLT under IBC, 2016 (Industry-wise Segmentation)*
Automobile (3) 6.4%
Consumer Servicers (2) 8.2%
Electricals (5) 6.4%
Energy (1) 6.4%
Food and Beverages (5) 6.4%
Healthcare (2) 4.5%
Metals (9) 17.3%
Real Estate, Construction & Engineering (11) 21.8%
Technology (2) 1.8%
Textiles (4) 4.5%
Others (7) 16.4%
0.0% 5.0% 10.0% 15.0% 20.0% 25.0%
Figure 4: Industry-wise Segmentation of public companies led with NCLT under IBC, 2016
*Number of public companies considered under each industry are indicated in brackets.
Financial Foresights 20Industry Insights
Stock price analysis – Healthcare and Electricals Industry median discount of 1.6 percent
accounted for the highest median despite comprising the highest
How is the market
discount of 54.1 percent and 43.0 proportion of defaulters.
reacting? percent, respectively. Interestingly,
We also tried to understand the
this includes Inox Wind, which was
We tried to analyze the impact of trend of discounts based on the
dragged to court for claims worth
bankruptcy proceedings on stock total asset size of the companies.
INR 56 lakhs and the share price
price of the defaulting companies. Although no clear trend emerged
tanked despite the company issuing
Ideally, the market should price in
for the analysis, the highest median
clarifications. Companies in the
the probability of default and give
metals industry recorded the least discount was recorded by
an indication of liquidation value of
the companies. To weed out the
effect on infrequent trading prices,
we excluded the thinly traded
stocks as well as companies with Discounts on stock prices (Asset-wise Segmentation)
less than INR 100 crores of market
capitalization. Our final sample size
consisted of 37 companies.
Less than INR 100.0 Cr 10.2%
Comparing the stock price of each
stock as of the date of admission
into NCLT with its price 6 months
INR 100.0 - 1,000 Cr. 30.1%
prior, we computed the discount
for each stock. We observed an
average and median discount for all
defaulters to be 25.7 percent and INR 1000.0 - 10,000.0 Cr 26.7%
23.2 percent, respectively.
Interestingly, some of the
prominent defaulters like Bhushan
Steel, Jaypee Infratech, Jyoti INR 10,000.0 - 50,000.0 Cr 11.8%
Structures, Monnet Ispat & Energy
and S.A.L. Steel, actually observed
an increase of about 30.0 percent in
Greater than INR 50,000.0 Cr 24.4%
their stock price. Incidentally, these
companies also attracted significant
buyer interest at the resolution
stage. It appears as if the market
does not expect these companies to Figure 5: Stock Price discounts of public companies led with NCLT under IBC,
go into liquidation despite the high 2016 (Asset-wise Segmentation)
leverage.
Financial Foresights 21Industry Insights
companies in the range of INR 100.0 not seen major decline in stock acquired by a market participant in
- 1,000.0 Cr at about 30 percent. prices/ marginal increase in stock the near future. n
prices reflect their potential to be
We can infer that firms that have
Discounts on stock prices (Industry-wise Segmentation)*
Automobile (3) 28.2%
Consumer Servicers (1) 23.2%
Electricals (4) 43.0%
Energy (1) 28.7%
Food and Beverages (5) 26.3%
Healthcare (2) 54.1%
Metals (6) 1.6%
Real Estate, Construction & Engineering (8) 29.1%
Textiles (3) 16.0%
Others (4) 14.7%
0.0% 10.0% 20.0% 30.0% 40.0% 50.0% 60.0%
Figure 6: Stock Price discounts of public companies led with NCLT under IBC, 2016 (Industry-wise Segmentation)
*Number of public companies considered under each industry are indicated in brackets, differs from previous page due to thinly trading
analysis and consideration of public companies only above market capitalization of INR 100.0 Cr.
Abhishek Pandey is the managing director at Duff & Phelps and is based in Mumbai Abhishek is part of the national
management in India. He is responsible for overseeing key engagements, relationships and strategic initiatives for the Indian
operations. He is also responsible for driving M&A advisory in India.
He has more than a decade long experience in managing a range of financial advisory engagements across various industries.
He has provided financial advisory to clients for purposes including, mergers and acquisitions. Negotiations, In the area of
valuation settlement of disputes, accounting and tax reporting, and strategic assessment. He has also helped companies to
develop business strategies for expansion and pricing, and in evaluating possible financial strategies.
Abhishek has managed assignments such as swap ratio determination, portfolio valuation, equity valuation, valuation of
financial instruments (such as complex convertible instruments, ESOPs and other hedging instruments), purchase price
allocation and impairment assessment (per IFRS, US GAAP and Indian income tax). He has handled several complex cross
border engagements where teams from multiple countries were working simultaneously. Abhishek has advised on transactions
in Consumer, Technology and Industrials vertical.
Abhishek has been speaker at conferences organised by forums such as ASSOCHAM and VC Circle on valuation and M&A
related topics. Abhishek's prior work experience include stints with corporate finance and advisory division of Deloitte and
Grant Thornton. At Deloitte he was part of Industrial M&A team.Abhishek holds a Master of Business Administration degree
from INSEAD (France).
This article has been written with valuable contributions from Aviral Jain, Director, Ayushi Sharma, Senior Consultant &
Sarvang Sawalka, Trainee from Duff & Phelps team.
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