Saturday, 23 February 2019

Farmers main difficulty not allowing him to become rich

Agriculture in India contributes 17 percent to Rs150 trillion economy,has remained relatively untouched by reforms with growth rates averaging below three percent over as many decades. Lack of technology, inefficient markets and small landholdings combined with insufficient storage and logistics facilities along with the fact that available storage infrastructures are far away from the field farms, have worsened to multiple challenges.

About a quarter Indian farmers live below the official poverty line, while 52 percent of farming households are indebted in spite of guaranteed prices for crop purchases by the federal government on at least three crops -- wheat, rice and cotton.

The agricultural sector plays a pivotal role in the growth and development of the Indian economy. It fulfils the food and nutrition requirements of 1.3 billion Indians as well as creates employment opportunities for the majority of the population.
A clear indication of growth can be seen in increased investor activity in the Agritech start-up space.  2018 saw a investment in Indian agriculture, which is a 21per cent increase from the previous year. While this demonstrates progression, the sector still struggles behind in certain segments such as storage and supply chain management. With this growing demand, there is a need for agri-entrepreneurs to employ innovative models and solve the problems in this sector such as dissemination of information, farm management, capital availability, farm mechanization, improved cultivars, environment-friendly pesticides and fertilizers and agricultural supply chain. There are various segments lacking development, which open up opportunities for entrepreneurs:

Traditional methods are still used by farmers today, driven by experiences, which are not practical today. With the development and integration of new equipment, practices and types of seeds, these tasks can be handled with much more efficiency. The available data could be utilized and worked on to benefit cultivation across the board.

Lack of correct tools and machines can lead to a lot more damage than anticipated, but it may not be affordable by many farmers. This can be rectified by agro-dealers who can offer rental services of farm machinery. Knowledge of machinery and its appropriate utilization is another invaluable service that should be provided to farmers.

After harvesting of crops, processing, cleaning and packaging must be executed before the crop becomes fit for human consumption. This is a necessary step that cannot be done without the right tools. The profits are greatly amplified by pre post-harvest processing.
Infrastructure: The quality of produce is enhanced with improved transport facilities. It helps create a market for agricultural produce and facilitates interaction among geographical regions. Over 35% of produce is often damaged and rendered wasteful due to lack of proper storage and transportation. Therefore, proper stacking and transportation is a dire necessity of the time.
With the growing demand and advancement in technology, there is a constant need for the development of new methods and seeds in the agricultural industry. This can only be done through research and development. Farmers can access these researches to overcome issues like seed problems, crop sustainability, pests and diseases etc. Research can also ensure the development of quality and environment-friendly agrochemicals.
Every stage in the value chain is important and dependent on one another to function properly and every stage is profitable. With the current challenges and opportunities prevalent in our country, entrepreneurship can provide innovative solutions to solve some of the critical issues in the agricultural sector.
For further queries about Warehousing facilities and technical details, kindly approach us.

www.drarorawarehousing.co.in

Thursday, 21 February 2019

increasing demand for quality warehousing spaces in India.

Increasing industrial investments in manufacturing (near Chennai) and IT investments (in Bangalore and other southern cities) are expected to drive the growth of retailing especially in south India, thus pushing the demand for modern warehouse space. In addition, the increasing relationships of logistics players–DHL, FedEx, Gati, with retail companies–Celio, Pantaloons, Future Group, Danone, are increasing the demand for quality warehousing spaces in India.

The retail segment also demands the highest quality of service from logistics solution providers. Global benchmarks are being increasingly applied to retail operations in India. Not only do logistics service providers require breadth of transportation network but also expertise in storage and value-added services to cater to such a dynamic market.Food retailing has also gained importance in the recent past. India’s food retail sector, worth around ` 3.1 trillion is expected to more than double, to ` 6.7 trillion by 2025, riding on the emerging organised retail as well as the change in consumption patterns along with fast-changing demographics and habits. As food products are perishable, there arises the need for temperature-controlled warehousing and transportation services, thus opening up investment opportunitiesin cold storages for multinational companies and private equity firms.Apart from foods retailing, the changing spending patterns in rural areas have also been attracting retailers to establish their bases in there. As rural areas do not have well-developed infrastructure, retailers are investing in cold storages and customised warehouses nearer to the farms and manufacturing places to avoid damage during transportation and to reduce costs.
Therefore, there is unimaginable scope of warehousing in retail and the retail in food items including processed foods,clothes, consumables, electronic goods, pharmaceuticals, auto- parts,as is evident from the data of increased sales recently through online retail business on B2B and B2C.

Sunday, 10 February 2019

Incressing global need for cold storage

From 2017 the global need for cold storage space increased dramatically, driven by growth in the world’s population, increased varieties of perishable commodities and the global consumer demand for fresh produce year-round.  And these factors are pushing occupancy rates at cold-storage facilities to an all-time high. During this period the big players are also starting to build just-in-time inventories.  Furthermore, with the growth of world population now standing at 7 billion people and with approx.12.5% of the world land estimated to be under cultivation, the annual global food production (animal & seafood) reached to an estimated level of 6.8 billion tons during 2014-15. The FAO estimates that by the year 2050, food production will have to increase globally by 70% (about 4400 million tons) to feed an additional 2.3 billion people. Our global population are said to need over 1850 million product tons of cold storage facilities for all kinds of food products. During 2016 the IARW estimated that global cold storage capacity for 52 countries reported that approx. 600 million cubic meters of global refrigerated warehouse space have been constructed & commissioned – mainly public refrigerated warehouse facilities (private refrigerated facilities are not considered significant).  From the above , India (population 1260 million) surpassed the US and had biggest cold storage capacity in the world with 131 million cubic meter space (USA had 115 million, China 78 million, Brazil 16 million & Indonesia 12 million cubic meter space).

It is estimated that every second, 66 tons of food products are either lost or thrown away, according to a recent report by the Boston Consulting Group. This amount translates into 1.7 billion tons of food a year, 
that is about one fourth of the food produced across the world. While this huge amount of food is lost between the farm and the fork, the United Nations Food and Agriculture Organization (FAO) says over ten percent of the world's population are suffering from chronic undernourishment.

With the fact that the nutritional energy (calorie content) of our produced food seems in excess of those required to feed the world population,  it is hoped that with the infrastructure of road construction and the emergence of additional refrigerated vehicles such as vans , trucks semi-trailers & 40 ft trailers  (all of  which are desperately being sought by China & India for a combined fleet of 500,000 vehicles) together with recruiting of many qualified drivers & system repair technicians , storage & logistics;  the tragic global malnutrition phenomena (which now account to over one billion) is anticipated to be significantly minimized by  contribution to addressing the issue of undernourishment,  particularly in the deprived sectors of the world.

Refrigeration inhibits the development of bacteria and toxic pathogens, reduces the need for chemical preservatives in food thus preventing food borne diseases.  According to WHO within 50 years a substantial decrease of stomach cancer was achieved due to application of cold chain industries.
Besides cold storage increases rhe shelf life of all the vegetable,fruits,poultry dairy and meat products besides some grocery items and pharmaceutical products.
Therefore now the time has come when almost many products will be used for consumption which come from the cold storage.

Wednesday, 6 February 2019

Strategies to be devised to increase the registration of warehouse for issue of NWRs

1.The regulations are for day to day activities of warehousing business and need modification up gradation from time to time and Government approval procedure takes lengthy time to solve the issues at proper time, for which Government approval is not necessary. The WDRA shall be empowered to make regulations by its own for which no approval of central Government shall be necessary.

2 The confidence level of the depositors for keeping their goods in privately owned warehouses registered with WDRA is very low, due to which the owners also do not find any initiative for getting their warehouses registered. It was discussed that there is no comfort level in getting the registration done, because recoveries due to losses is very uncertain as the punishment provisions provided in the WDR Act, 2007 are off course deterrent to such losses but there is no solution for grievances of the depositors and Banks for recovery of their losses which are not covered under any insurance policies.
Therefore Authority has to devise some preventive methods to eliminate chances of losses such as to ascertain good background and good track history of the owner/Warehouseman or by appointing some outsourced agencies who can work as collateral Managers also of such warehouse which are registered by WDRA, or by taking help of state Govt. appointed licensing authorities whose basic duty also is to ensure fair and proper running of warehouses before granting them the licenses for warehousing. This will bring confidence amongst depositors and Banks.

3  Besides, The Act shall provide penalty and punishments for the registered warehouses for violating the provisions of the Act but surprisingly there is no punishment/penalty for unregistered warehouses violating   the same provisions of the Act. This non inclusion of punishment/penalty for unregistered warehouse is a like an incentive for violating all norms and regulations of the Act and getting scot free.

4  The Act shall provide provision for indemnity fund.
The indemnity fund is a type of insurance program that protects the farmer from loss of value should the grain be destroyed or damaged beyond its economic value while in storage. Without the indemnity protection, the risk of storing the grain for sale at a future time might be too high. The indemnity fund shall give a financial support system for the recovery of loss to the depositors/beneficial owners in the event of any failure of the warehouseman to deliver the goods or pay compensation as per its commitment, because the Act provides for punishments including recovery but which may take years for the metropolitan court to decide.  Besides recoveries are also not possible in certain cases like bankruptcy and other reasons such as force measures and natural losses due to moisture driage etc.

Therefore, the Act shall provide provision of some corpus fund which may be in the name of indemnity fund to mitigate financial risks which cannot be recovered under any circumstances but are protected under various provisions of the Act by the Government.  This will protect integrity of NWR system and therefore NWR issued by a warehouseman  under the Act will be a “good title”

5. WDRA shall have judicial status with powers to settle disputes of all types in different warehousing activities to be notified.

6The registration of warehouses shall be in the name of warehouseman along with the name of owner and name of company, to have more clarity on the part of fixation of responsibility.

7 The Act shall include provisions for indemnity fund to mitigate financial risk of stake holders i.e. depositor, banker, financer, holder of warehouse receipt in whose name the depositor has endorsed.

8.The activities of logistics and supply chain management shall also be covered under the preview of WDRA.

9. The clarity is required for getting the registration done by a warehouseman for a part of the warehouse in the form of minimum one compartment/shed/godown.

10.Scope of offences and penalties may be broadened by way of notification of authorizing WDRA nominated officer to seal a godown which shall be duly protected by police.

11. The scope of WDRA shall also be broadened in formulating various standards, code of practices, designs and standardization of all procedures of different activities pertaining to all warehousing activities. 

12.The section 43, 44 and 45 prescribes punishments of imprisonment up to three years but does not empower WDRA to recover the damages/losses under the Act.

13. Provision shall be there in the Act to include banker and endorse, as their right to verify physical condition /physical presence of the stock along with the value mentioned in NWR to increase the comfort level.

14.Norms of storage losses due to natural driage shall be included in the Act for various commodities.

15. Provision shall be there in the Act to include the condition that the endorsement done by the depositor shall be immediately informed along with name and address of endorsee.

16. The WDRA role shall be as a regulator to ascertain that all activities of warehousing in India are in accordance of the norms and procedures prescribed by WDRA and to deal with the matters accordingly.

17.Min.of Finance May issue guidelines to all banking regulators and financial institutions to devise attractive schemes for popularising NWRs

18. WDRA in consultation with MEA ,RBI and NABARD may make regulations for making rating of warehouses based on proposed standards which may result into reflecting different level of confidence of different registered warehouses.

19. Banks may be advised to prioritise loans to WDRA registered warehouses,for which Banks may be empowered at local branch level to reduce rate of interest 2-3%,depending upon ratings as per the said regulations laid down.

20. All APMCs,local warehousing license issuing authorities may also be given space in the regulation making process.

21 Example  of MP Govt, may be followed by other state govts.to give priority to WDRA registerd warehouses,wherein more % of share to owners of warehouses is given which are registered with WDRA,in storage of govt.procured food grains.

22.  The FMC had issued circular dated 30.08.2013 for the mandatory registration of Exchange-accredited warehouses with the WDRA, accordingly the WDRA has been receiving following feedback for doing registration of  exchange accredited warehouses:-
Since the failure of the warehouse receipt system appears to be one of the main reasons for the crisis in the NSEL, the mandatory registration provides an opportunity and a challenge to the WDRA to establish a regulatory mechanism for oversight and integrity of the warehouse management system as follows:-
  AWherever not full but part of the warehouse is required by the Exchange, the WDRA should protect the interest of other depositors, and look into the warehouse as a whole.
In devising the mechanism and the framework, the WDRA should study all the lessons learnt from the NSEL and provide safeguards to prevent recurrences.

   B“Fit and proper conditions” for WSPs should be worked out and specified by the WDRA.

   C.The WDRA should specify comprehensive norms for insurance as mandated under the W(D&R) Act.The WDRA should evolve suitable norms on capitalisation, ownership, financial adequacy, etc. of the WSPs.

    D The WDRA should revisit the norms for the infrastructure, maintenance and quality standards for the Exchange-accredited warehouses.
   E.The WDRA should also work out a financial support system for the recovery of loss to the depositors/beneficial owners in the event of any failure of the WSP to deliver the goods or pay compensation as per its commitment.
     F. A robust ongoing inspection system should be put in place.in which the regulations may be formed for allowing ex/retired employees of different warehousing organisations after taking security deposit of some amount say Rs5 lakhs in the form of Bank guarantee or Bank FD so that most of the intelligent and devoted and highly experienced persons with integrity and devotions could be utilised in the nation's interest as the present appointed agencies are totally having no background and experience of warehousing and rather they are exploiting the same manpower which is proposed in this request.This action will enhance the fiscal trust of the financial institutions if the no of such inspecting persons are appointed to the tune of 100 in nos,so that each and every warehouse is inspected at least once in a quarter to boost the confidence of all the stake holders. Govt may sanction a budget on this account exclusively for the inspections of registered warehouses,as the preventive strategies are always healthy for the health of the warehousing ecosystem rather than taking curative treatments after the system becomes sick and if not treated in time then it may die also.

Wednesday, 23 January 2019

The bottom line and the bottom of the pyramid

Creating sustainable for-profit  businesses that target people at the bottom of the income pyramid is a topic of growing interest to development finance institutions, private investors, and local entrepreneurs to support poverty reduction through private sector business opportunities.

With increasing focus on this lower income segment, companies both large and small have started to recognize that there is a large market potential represented by the base of the income pyramid.

For multilateral development banks, like ADB, this is an important way to mobilize and engage the private sector to achieve poverty alleviation and reduce income inequalities in developing countries.

The good news is that the Asia and Pacific region is already demonstrating how innovative, inclusive finance can make a difference, but much more can be done. In India, for example, the government has prioritized financial inclusion and, as a result, great strides have been made in opening bank accounts for millions of the previously unbanked.

Banks and non-banking financial companies such as IFMR Holdings have developed business models that have as their core business strategy a target of financing lower income people. IFMR Capital innovatively works to mobilize capital markets funding for microfinance institutions, which traditionally have limited access to this financing base.  

Other successful examples of bottom-of-the-pyramid funding are being seen in Central Asia through the Access Microfinance Holding network and through the pioneering work of the Kashf Foundation in Pakistan.

Mountain Hazelnuts, an agribusiness firm, has been a pioneer of bottom-of-the-pyramid solutions in Bhutan. It grows and exports hazelnuts to the People’s Republic of China, where it has found a niche in capturing the increasing demand for higher-end agricultural products from the Chinese market. At the same time, it is increasing livelihoods for thousands or rural workers – mostly women.

Of course, these solutions do not happen without finance. Leading global banks such as Credit Suisse see that bottom-of-the-pyramid investments can be good business. But the market is far from saturated. With over 2 billion consumers spread across developing Asia, the opportunities are limitless for financial institutions that take the time to understand their clients and develop the kind of innovative solutions that can serve this underserved market.

Modi Govt is now trying the same idea for achieving political gain by investing in the rural india,as the interim budget on 1st Feb 2019 provision for farming & agriculture can be anything between 11 lakh crore to 15 lakh crore.
My suggestion to the govt is that it should utilize and spend money mostly of investment in nature for the rural upliftment to touch the bottom of the heart of the bottom line of the pyramid to get the ballot support from the rural masses, because other methods such as MSP,Loan waiver and other schemes may not be attractive to the masses because these all schemes are reaching  only to 20% to 30 % of the rural masses. Besides rural population has many other non farmer and non farming labours. Who will take care about their grievances? They also form a great chunk of rural population.
Regards,
DR N K ARORA

Thursday, 17 January 2019

Income support scheme under DIT( Direct income transfer) to tje rural farmers of india.

Odisha Govt under the  Krushak Assistance for Livelihood and Income Augmentation (Kalia)  will transfer the amount under the scheme comprises three components: a) Rs 5,000/family per crop season to over 30 lakh small and marginal farmers having less than 5 acres of land, b) Rs 12,500/family per year to 10 lakh landless agriculture labourers and c) Rs 10,000/family to 5 lakh ‘vulnerable’ farmers every year.

The cost for the whole scheme has been estimated at Rs 10,180 crore in five seasons starting rabi 2018-19.
While Telangana is giving Rs 4,000/acre each season to all land-owing farmers, Odisha has restricted it to Rs 5,000/family as it has also announced scheme for landless farmers.

State Govt of Telangana has been implementing an income support scheme for farmers called Rythu Bandhu since May 2018 paid Rs 5,256 crore to about 51 lakh farmers during kharif 2018 under the Rythu Bandhu for purchase of inputs like seeds, fertilisers, pesticides and labour costs.

The Centre is now also reportedly considering an income support scheme (which may be announced in the interim Budget to be presented on February 1),

I doubt that the said scheme of income
support can be implemented in the right spirit because all other states are also rolling out one or the other income support scheme and there will be a total chaos due to duplication of the income support schemes at the state level and center level both to claim the contribution of the respective political party or the concerned Govt.
Therefore the central government shall roll out the income support scheme very cautiously so that the real benefit goes to the real and needy poor and mass farmers.As the govt of telangana and odisha has been giving benefit to only approx 1 crores farmers and landless farmers. It will be a harculrean task for the central govt to handle all the farmers and landless farmers which are to the tine of more than 10 crores landholdings.
As per Registrar General of India & Census report 2011 the total farmers or cultivators population of India is 118.7 million (2011) & 144.3 million agricultural workers/labourers which consists 263 million ot total rural  population means 26 crore.
I don't think that it is a easy job for the central govt to roll out a i come support scheme in such a small period of approx 2 weeks time by 1st Feb 2019  for such a large population data of rural india. Govt should rethink and replan by allocation of funds to states for devising their own policies of i come support, because different states having different agricultural ecosystems with different problems of the agricultural it related issues and they have to be first understood and then the scheme can be devised by the respective States. Otherwise if the central government wants to take credit for the benefit of the farmers then they must derive some scheme of assuring income through MSP already declared and to be implemented through already legal instruments in existence by the government of India which are Aadhar/WDRA and ENWR which can be linked with each other and the government can transfer the amount of MSP to the respective farmers and this is the only way where in the smallest available time it can be implemented with very proper accuracy otherwise it may be failure.

Growth of electronic negotiable warehouse receipt under regime of warehousing development and regulatory authority (WDRA)

History of WR ( warehouse receipt) started from the day of 1960s  when the warehouse receipt used to be issued by warehouse man under the different state warehouses act. Thereafter in the years of 1980s this instrument of warehouse receipt became the symbol of hundi where  the traders and farmers used to keep this warehouse receipt in the custody of landlords and money lenders and took loan and Finance against the warehouse receipt hypothecated with the landlords /money lenders, is this instrument of warehouse receipt used to be considered as a safety or the guarantee from the warehouse is that there the stock mentioned in the warehouse receipt is safe and can be handed over to the person in whose name the endorsement is given by the owner of the warehouse receipt. This way the confidence built up started amongst the Financial Institutions also against the guarantee being given and understood to be given by the warehouse man for the stocks and details mentioned in the warehouse receipt. Thereafter this became the practice of the day and there used to be huge financial transactions of the cost of commodities along with the quality and quantity mentioned in the warehouse receipts.
But in the above practice off day today transactions and transfers of warehouse receipts from one person to another person there started some legal complications also when the dishonest elements came into the scene of warehousing and then it was realised that some legal status has to be given to this warehouse receipt so that legal problems may not arise and the transfer of warehouse receipt becomes smooth and easy and with this idea concept of Negotiable warehouse receipt started on which various committees of the government along with the committee of Reserve Bank of India started working on it and came out with the suggestion of making negotiable warehouse receipt and its regulation by some authority and later on this concept was tabled in the form of Bill in the Parliament and and Act was passed named as warehousing development and Regulation Act 2007 under which authority named as w d r a came into existence in 2010 under which provision for converting of these warehouse receipts into electronic negotiable warehouse receipt was mentioned and after making great efforts by various experts on this field concept of electronic negotiable warehouse receipt emerged and wdra started working on this concept and came out with a idea of making available the services of electronic repository for keeping the  data  store  of different commodities  being stored in the warehouses and details their of are issued in the form of warehouses receipt, just on the line of the depositories keeping the records of dats being stored for the stocks like, equities and shares.
To bring about the above concept of eNWR into practice, WDRA came with appointing two repositories namely NERL and CCRL in September 2017 after making detailed guidelines for the repositories.

The eNWRs issued by the warehoused are kept and stored on the electronic platform of the repositories and are just like digital  money, wherein the farmers can sell the commodities mentioned on these enwr when the farmer finds that the price of the commodity is reasonable and to his satisfaction for which he has expected the price for the commodities produced by him so that he is suitably compensated for the labour and investment he has made in producing the agricultural commodities. And in case he does not get the desired price then he has another option of this platform of repository by keeping his eNWR under pledge so that the same stocks can be his source of raising loans from the Financial Institutions and banks.

It would be a game-changer for farmers. when their commodities are dematerialised in the repositories, wherein all the. Data and details of commodity under storage in a warehouse is accessible online to the banks and other financial institutions so that they are fully convinced that stocks being kept under pledge with them is guaranteed for the money recovery and hence they will be very happy to give loans to the owner of the stocks, who is either a farmer or a trader, and they would have easier access to institutional farm loans, at lower rates also.

The eNWRs have distinct advantages over the paper-based receipts. They allow farmers or depositors to have access to a large number of buyers across the country and thus would increase their bargaining power. They can do multiple transfers without physical movement of goods.

Moreover, farmers don’t even have to cart their produce to the market for selling. Once sold, the buyer would be able to pick up the purchased commodity from where it has been stored.

Even consumers of these agricultural commodities such as industries, processors, wholesalers and retailers benefit as they will be able to procure graded produce with a seal of quality assurance, 

Although the repository namely NERL is making good efforts with Quality Services being given to all the respective stakeholders , whether it is the warehouse man or a farmer or a trader or a repository Participant, it is the NERL, which is making full efforts   every time with  all the dedication for increasing its services by making more and more eNWR, in its repository and facilitating the transfer and pledging of the commodity for the help of the depositors and farmers  to get the remunerative prices of the producers and relieve them from the financial stress.
For achieving above target of relieving farmers from the financial stress and getting the remunerative prices the nerl is making all efforts as its team and key management personnel are very much devoted and in spite of many bottlenecks.

In order to review and assess viability and functioning of the repository nd also for easy movement and transfer of eNWR,and the bottlenecks in the existing system, it is very much essential to have a proper analysis about the functioning of the whole ecosystem of the eNWR.
All across globe, a well-functioning warehouse receipt financing system based on public warehouses has the potential to reduce risks and transaction costs in collateralised financing, which may result in broad-based access to such financing and low costs. However, for this to be achieved, an enabling legal environment and institutional set-up need to be in place to instil trust in the system among financiers and commodity market participants and to safeguard its integrity. Only when the financial community has a high degree of confidence in the system will it lend against warehouse receipts, and interest rates will be reduced. Core elements of a well-developed warehouse receipt system include:

  1 an enabling legal and regulatory framework;

 2 a regulatory and supervisory agency;

 3 licensed and supervised public warehouses;

 4 insurance and financial performance guarantees;

 5 banks familiar with the use of warehouse receipts.

Despite the differences among countries and legal traditions, an enabling legal framework should clearly define the following issues and related rules and procedures: i) the warehouse receipt’s legal status as a document of title or pledge; ii) rights and obligations of the depositor and the warehouse operator; iii) perfection of security interests (registration of the warehouse receipt or pledge); iv) protection of the warehouse receipt against fraud, and financial performance guarantees; v) priority for the claims of the holder of the warehouse receipt in case of borrower default or bankruptcy; and vi) clear procedures in case of bankruptcy of the warehouse operator and for the administration of financial performance guarantees.

Warehousing development & regulation Act 2007 was also meant to achieve the same objects, but the Act has not been designed to sync the basic and fundamental principles of commodity market financing as the Act has to achieve the basic goal of guarantee and trust of the warehouse receipt because of no powers to authority (WDRA) and hence teeth-less and which has to depend again on juridical proceedings for taking action against the defaulters. Secondly punitive actions are so harsh that no warehouse service provider will like to opt for registration. The punishments shall be for the regulatory lapses in the mechanism and system.But surprisingly the Act directly jumps into conclusive frauds and losses. It is a common sense that if the detailed mechanism for lapses found in different stages are worked out in the rules and the financial punitive powers are given to the Authority, then definitely a sense of regulatory control will lead to the desired level of collateral trusts in the ecosystem of financial performance guarantee..