Rbi in need to act efficiently, effectively and pragmatically

EDITORIAL
* Mr. Vinod Jain, FCA, FCS, FICWA, LL.B., DISA (ICA), Chairman, INMACS and Vinod Kumar & Associates. vinodjain@inmacs.com, vinodjainca@gmail.com, +91 9811040004
contd......Pg.3
RBI- In need to act efficiently, effectively
and pragmatically
1JANUARY 2016
RBI has been among the best
regulators in the world, managing
the financial markets and various
other important aspects of the
Indian economy with a visionary,
practical, positive and dynamic
approach during more than last 5
decades.
In recent past, it has been observed
that the basic values and virtues
built by RBI are being pierced, one
after another. A recent informal
directive (advisory) to all the public
sector and private sector banks, to downgrade, more than
150 top borrowers as Non-Performing Assets and to make
retrospective provisioning is one such example. The NPA
provisioning norms have been one of the tightest regulations
in the world. In terms of the latest directive, exposure of
the banks in three categories is proposed to be downgraded,
based on asset quality review. The exposure of Indian
banking sector to such accounts is estimated in the range
of Rs 1.5 lakh crore to about Rs 2 lakh crore, which will
be about 3% of the total credit exposure of the banking
sector.The real concern of RBI about asset quality has to
be adressed in stages. The impact will be more than serious
on fund based and non-fund based exposures as well as
working of the industry.
Regulations are to ensure fair play and cannot be a
burden. No regulation should hurt or kill the genuine
business activity.
Backdrop
The global economy including China, Europe and all major
economies have been facing steep challanges. The Indian
Economy has passed through a fairly tough time during
about last 5 years and more specifically in last 3 years.
Almost all the major borrowing sectors had been suffering
CA Vinod Jain*
Convener National Economic
Forum, Former Chairman BoS
and Member Central Council
Institute of Chartered
Accountants of India
due to policy bottleneck. The credit off take has reduced
very sharply. The fresh investments have not been forth
coming except in limited sectors like e-commerce. IIP index
is showing a negative growth. Some of the prominent
sectors impacted by slow down, for example:
Power Sector- no further disbursement in spite of
financial closure for many years. No additional
sanctions or disbursements for new projects. Recent
innitiatives of government are in right direction.
Roads and Highway Sector- NHAI has recently come
out with suitable solutions for recommencement of
construction, in most of the projects which were
standstill for more than 3 years.
Real-estate and Infrastructure are creating new
records of downfall in prices and substantial negative
growth. Housing sector has specially suffered.
Commodities- International and National commodity
prices, in most of the cases, are ruling at their last 10
year low thereby impacting steel industry, construction,
and other commodity based sectors. The Chinese,
European and American markets are leading the
commodity prices free fall.
Implications
The Government of India has taken major steps and policy
initiatives to revive the economy, in spite of, international
economic challenges. The Finance Minister has committed
to the nation that no retrospective amendments or
regulations are brought in.
In case the advisory of RBI is accepted, including
retrospective provisioning, without taking corrective action,
including special dispensation for certain specific ailing
sectors, the following implications may arise out of
retrospective provisioning at such a large magnitude:
Declared financials of these banks for earlier years will
be proven wrong.
Volume XXVII | No. 1 | January 2016

2
THE CHARTERED ACCOUNTANT WORLD
JANUARY 2016
LATEST IN FINANCE
2
1.0 UDAY – Target linked MoU designed, no
benefits if discoms default
The Centre is hopeful of getting at least 21 states
on board for Ujjawal Discom Assurance Yojana
(UDAY) reforms
For the states that sign up for UDAY, one of the
first steps is to take over 75 per cent of DISCOM
debt as on September 30, 2015 over two years -
50 per cent in 2015-16 and 25 per cent in 2016-17.
The state borrowing would be issued as
Non-SLR State Development Loans.
With loans being part of the capital expenditure
in the state’s Budget, the Centre is hopeful of
bringing down interest rates further.
The Bait
Waiving unpaid overdue interest payment of
discoms
Additional grant under Centre-sponsored schemes
Increased supply of domestic coal
Faster completion of intrastate transmission lines
The Switch
No future lending by PSU banks and FIs
2.0 Line of credit – streamlined
The government has approved the new Indian
Development Assistance Scheme (IDEAS) to
streamline Lines of Credit (LOC) offered to
various countries in South Asia, SE Asia, Africa
and Central America emphasizing on timely
completion of projects. The initiative includes
provisions to provide better terms of credit.
Several changes have been made in the operational
guidelines such as making Detailed Project Report,
strengthening of monitoring system, pre-
qualification of competent companies and
requirement of regular reports by the borrowing
governments.
3.0 Roads – a big opportunity
Road projects worth Rs. 50,000 crore to be offered
under PPP in FY17
This will be the largest chunk of projects to be
awarded by ministry under PPP mode in a single
financial year.
5000 km roads to be awarded to private players
for construction
LATEST IN FINANCE
Bids for religious tourism circuit programme
including Char Dham connectivity and the Bharat
Mala project will also be invited.
4.0 Steel ministry for removing duty exemption
categories
After anti-dumping and safeguard duties, the
Union ministry of steel wants to plug another
trade route to prevent cheaper imports. It has
recommended that Rule 11(1)(c) for imposition
of countervailing duty (CVD) be amended, so that
a duty can be imposed on exempted categories
of steel imports.
Domestic industry has been complaining about
below-cost import from China and Korea.
Increased import has pushed domestic companies
into losses.
5.0 Solar Power : Cost cut imminent
Indicating a continued downward slide in solar
photovoltaic (PV) power project tariffs, the
Central Electricity Regulatory Commission
(CERC) has proposed nearly 20% cut in the
benchmark capital cost of such projects for FY17
compared to the current financial year.
While the average tariff for the bids invited by
states this year has hovered around Rs. 6 per
unit, the recently concluded bid under the national
solar mission saw the solar tariff plummeting to
a historic low of Rs. 4.63 per unit.
6.0 Smart City project may give municipal bonds
fresh lifeline
The government is making a fresh push for Tier-
II and Tier-III cities to issue municipal bonds, as
this would help in financing projects under the
Smart Cities initiative.

3
ALL INDIA CHARTERED ACCOUNTANTS’ SOCIETY
JANUARY 2016
EDITORIAL
Given the magnitude, the very credibility of the
Indian banking sector, Statutory auditors and RBI
itself will be questionable, having serious economic
ramifications, including all sovereign credit rating
of India.
Capital adequacy and share prices including
valuations thereof will be negatively impacted. The
Indian public as well as investors will feel cheated
and will lose confidence even in the financial
markets impeding future investments in debt-
equity of the banks.
International branches of the banks will face
closure or substantial reduction in their business
due to lack of necessary capital adequacy, negative
outlook and further potential asset quality risk.
In fact, RBI itself is responsible for the current
changing scenario:
RBI permitted, inspite of repeated opposition by
ICAI, appointments of branch auditors as well as
central statutory auditors of the banks to be made
by banks management itself. The number of
branches subject to audit reduced dramatically,
thereby reducing financial discipline and control
by independently appointed auditors.
Strategically sidelining Chartered Accountant
directors by a series of negative initiatives
including restricting their numbers, maximum 6
year limit on Board removing experienced
Directors from banking system, restricting their
number and role in credit monitoring.
Permitting banks to continue to charge extremely
high interest rates, including gross spread of 4%
to 6%, as compared to international practice of
0.25% to 0.75%.
Very stiff norms on international investments over
regulations in P Note, External Commercial
Borrowing and restricting M3 and availability of
credit at reasonable terms and basis.
Direct interference into day to day management
of banks, especially public sector banks, including
appointment of CMDs (resulting in very poor
selection) and substantial delay,
Appointment of consultants to select CMD, having
no understanding of Indian financial markets.
Recent interference in the setting up of proposed
Banks Board Bureau (BBB)
............from Pg. 1
andpragmatically
EDITORIAL RBI has made Open-disclosure of confidential,
vulnerable issues now publically in a series of
structured disclosures rather than confidential and
effectively managing the problems of Indian
borrowers. This has embarrassed Industry as well
as current Indian Government.
The Indian businesses are competing with
international companies borrowing at the rate of 3%
to 4 % (LIBOR of US $ is 0.13%), while bearing
12% - 18% interest payment to the banking sector
and 15% - 36% interest to Non Banking Finance
Companies and unorganized financial market.
Certain Solutions to be examined
Special nursing programmes for each suffering
economic sector.
A special debt restructuring scheme for various
sectors which need nursing, rather than trying to
kill the industry and businesses by downgrades.
The schemes could be positively planned similar
to UDAYbrought out for power sector (DISCOM)
by the Government.
The government may empower banks to take over
all major economic powers from the existing
management, in carefully selected cases.The day
to day management can continue as it is, while
CFO and other observers are to be appointed by
banks to ensure financial discipline.
A part of the debt of the industry can be converted
into equity or optionally / mandatorily fully
convertible bonds (with a sell back option) to have
the upside of the well performing units.
The interest burden of the industry, business,
services sector as well as real estate and
infrastructure need to be curtailed down
substantially with ease of credit offtake.
The penal interest, interest on interest and interest
charged over and above the base rate can be
waived partly or fully in a judicious manner.
The Government may consider to permit one time
settlement scheme with payment of principal and
simple interest within 3 months by the industry
from any source, without any tax implication and
complete immunity from PMLRA and similar
other legal provisions.
SME sector will need special scheme for their
revival. The credit availability has to improve and
too much dependence on collateral is impacting
reasonable growth. contd......Pg.8

4
JANUARY 2016
LATEST IN FINANCE / BANKING / INSURANCE
7.0 New system for more secure online banking
A new system that uses images and a one-time
numerical code may provide a secure, inexpensive
and easy to use alternative to current password
systems used in online banking and other such
services, a new study suggests.
BANKING
1.0 RBI fixes 9.45 per cent base rate for NBFC-
MFIs
In line with falling lending rates, Reserve Bank
today fixed Base Rate or the Minimum Lending
Rate at 9.45 per cent for NBFC Micro Finance
Institutions (MFIs). The new base rate is effective
quarter beginning January 1.
2.0 RBI issues norms for pricing banks’ advances
The Reserve Bank of India (RBI) notified
guidelines for banks for pricing their advances
with reference to the Marginal Cost of funds
based Lending Rate (MCLR). Currently the base
rate, the minimum lending rate, is priced with
reference to the average cost of funds.
Banks may specify interest reset dates on their
floating rate loans and they will have the option
to offer loans with reset dates linked either to the
date of sanction of the loan/credit limits or to the
date of review of MCLR.
3.0 Reserve Bank revises norms for ‘when
issued’ security to boost trading
To encourage trading in ‘When Issued’
transactions in government securities, the
Reserve Bank allowed banks to take short
positions in this segment of trading, while mutual
funds, insurance and pension funds, NBFCs and
others are permitted to take long positions.
4.0 SC raises serious issues against RBI
The Supreme Court held that RBI should take
rigid action against those banks and financial
institutions which have been indulging in
“disreputable business practices” and said it
cannot withhold information on defaulters and
other issues covered under the RTI Act.
“We have surmised that many financial
institutions have resorted to such acts which are
neither clean nor transparent. The RBI in
association with them has been trying to cover
up their acts from public scrutiny. It is the
responsibility of the RBI to take rigid action against
those banks which have been practicing
disreputable business practices,” a bench comprising
Justices M Y Eqbal and C Nagappan said.
RBI and the Banks have sidestepped the general
public’s demand to give the requisite information
on the pretext of ‘Fiduciary relationship’ and
‘Economic Interest’. This attitude of the RBI will
only attract more suspicion and disbelief in them.
RBI as a regulatory authority should work to make
the Banks accountable to their actions.
5.0 Lending to foreign step-down arms of Indian
firms gets costlier
The Reserve Bank of India (RBI) said banks
should make provisions of two per cent against
loans given to a foreign step-down subsidiary of
an Indian company.
6.0 Central bank plans to monitor peer-to-peer
lending
The Reserve Bank of India (RBI) will soon release
a discussion paper on unregulated peer-to-peer
lending (P2PL) arrangements, which is lending
money to unrelated individuals without assistance
from any financial intermediary.
Several online portals have sprung up in India to
facilitate such lending, some even getting private
funding from investors, but it is still at a nascent
stage.
INSURANCE
1.0 Crop Insurance
Given the tepid performance of current schemes,
the government plans to launch a new scheme
that would cap the premium paid at about 3% of
the insured value, cover a substantial part of India’s
farmland and crop output and make processing
of claims hassle-free.
2.0 Universal Health Insurance Plan- A better
cover
After providing life cover and accident cover,
the government is now working on a universal
health insurance plan. To begin with, it will
provide a seamless solution to the existing
cashless health schemes in states by integrating
those with the Centre’s direct benefits transfer
(DBT) platform. Later, these would be scaled up.

5
JANUARY 2016
INSURANCE / CORPORATE & ALLIED LAWS
3.0 IRDAI tweaks norms for insurance
marketing firms
The Insurance Regulatory and Development
Authority of India (IRDAI) has said insurance
marketing firms can procure products from two
insurers each from the life, general and health
categories, giving due intimation to the regulator.
4.0 IRDAI proposes changes in trade credit
insurance norms
Trade credit insurance is an insurance policy
offered by private insurance companies and
governmental export credit agencies to business
entities wishing to protect their accounts
receivable from loss due to credit risks such as
protracted default, insolvency or bankruptcy.
Insurance Regulatory and DevelopmentAuthority
of India (IRDAI) said it proposes to allow
issuance of trade credit insurance policy to RBI
registered entities, for conducting factoring
business in line with The Factoring Act, 2011.
“This cover shall be restricted to short-term
financing against receivables, representing supply
of goods, materials and services,” said the exposure
draft.
CORPORATE & ALLIED LAWS
1.0 Enforcement Directorate probes PACL
The Enforcement Directorate (ED) has initiated
an inquiry against PACL for alleged money
laundering under the Prevention of Money
Laundering Act.
SEBI had found that the company had raised about
Rs 49,100 crore from 50 million investors through
a collective investment scheme, which is illegal.
The mobilisation of funds by PACL dates back
to 1990s.
The ED’s decision comes on the heels of a SEBI
order, issued a fortnight ago, to attach all the
assets of the company and its directors.
2.0 Private Placement Amnesty
In respect of cases prior to April 01, 2014
involving issuance of securities to more than 49
persons but up to 200 persons in a financial year,
the companies may avoid penal action if they
provide the investors with an option to surrender
the securities and get the refund amount at a price
not less than the amount of subscription money
paid along with 15% interest p.a. thereon or such
higher return as promised to investors.
Source: CIR/CFD/DIL3/18/2015 dtd. December 31, 2015
3.0 Payment of Bonus (Amendment) Bill
The Payment of BonusAct has enhanced the limit
of salary for availing bonus from Rs. 10,000 to
Rs. 21,000.
4.0 Cheque Bounce Cases now to be filed where
presented
Parliament has passed a law allowing cheque
bounce cases to be filed at the place where the
cheque is presented for clearance and not the
place of issue, a change that is expected to go a
long way in improving legal recourse in such
cases.
5.0 Family accord prevails over law suits
The Supreme Court last week gave thumbs up to
settlement of disputes against litigation among
business family members when it ended three-
decade row in the case, Rajni Sanghi vs Western
Indian State Motors Ltd. The court ruled that if
the parties settled their differences amicably, their
agreement shall prevail though there were other
proceedings like arbitration. Even if there is an
arbitration award, which has not been made into
a decree of the court, the family arrangement
will override it.
6.0 Transfer of shareholding on basis of disputed
MOU was clear act of oppression by
respondent
The High Court of Bombay held that where
respondent group on basis of a disputed MOU
with appellant group had held board meeting,
issued duplicate shares and transferred
shareholding of appellant group in its favour at
valuation which was not acceptable to appellant
group, action of respondent group was a clear
calculated act of grossest oppression.
Nafan B.V. v. SAF Yeast Company (P.) Ltd. [2015] 64
taxmann.com 55
7.0 In case of Buragohain Tea Co. Ltd., the High
Court of Delhi held that where Court in principle
agreed to sanction scheme of amalgamation
whereby entire undertaking of transferor
company was proposed to be transferred to
transferee company but found exchange ratio to

6
JANUARY 2016
CORPORATE&ALLIED LAWS/CAPITALMARKET/DIRECTTAXATION
be unfair and unjust and not based on market
realities, Registrar of Companies was to be
directed to examine matter through experts and
determine a fair and just exchange ratio. [2015]
64 taxmann.com 11
CAPITAL MARKET
1.0 Basic Services Demat Account (BSDA) –
Mandatory
DPs are advised to convert all eligible demat
accounts into BSDA unless such Beneficial
Owners (BOs) specifically opt to continue to avail
the facility of a regular demat account.
Source: CIR/MRD/DP/20/2015 dated December 11,2015
2.0 Top 500 companies – Additional disclosure
SEBI has mandated that top 500 listed companies
to include ‘Business Responsibility Report’ in their
Annual Returns, earlier the said requirement was
for top 100 companies only.
Source:SEBI/LAD-NRO/GN/2015-16/27dtdDecember22,2015
3.0 IPO irregularities: SEBI to refund disgorged
funds to investors
The Securities and Exchange Board of India
(SEBI) will distribute among eligible investors
the funds it has collected through disgorgement
orders in cases of IPO irregularities - a move
that will benefit as many as 463,000 investors.
The total amount to be distributed is about Rs 18
crore, which includes Rs 7.35 crore recovered
by Sebi through exercise of its newly conferred
recovery powers.
SEBI has already distributed Rs 23.28 crore to
1.3 million investors in April 2010, out of which
799,000 investors were paid the full eligible
amounts.
DIRECT TAXATION
1.0 Finance Ministry releases draft guidelines for
Place of Effective Management Control
Place of Effective Management (POEM) means
a place where key management and commercial
decisions that are necessary for the conduct of
the business of an entity as a whole are, in
substance, made,” said the Central Board of
Direct Taxes, adding that it would be determined
based on whether the company is engaged in
active business outside India.
The CBDT, however, stressed that a foreign
company would not be considered a resident
taxpayer just because it is fully owned by an
Indian firm, or some of its directors or local
management is in India or existence of support
functions in the country.
A company’s head office is not necessarily the
same as the place where the majority of its
employees work or where its board typically
meets,” it has clarified.
Under earlier guidelines, a company was
considered a resident in any previous year, if it
was an Indian company or if during that year,
the control and management of its affairs was
situated wholly in India.
Moreover, cases selected for limited scrutiny can
be converted to complete scrutiny only with the
approval of the Principal Commissioner of Income
Tax or Commissioner of Income tax if the
potential income escaping assessment exceeds a
certain monetary limit.
2.0 SEBI – registered FPIs get I-T filing relief
The Central Board of Direct Taxes (CBDT)
clarified that incomplete or deficient returns filed
by Foreign Portfolio Investors (FPIs) would not
be treated as “defective” if the entities were
registered with SEBI and do not have a permanent
base in India. This would provide relief to over
500 FPIs.
3.0 Tax department to quote email, phone no. in
notices
The Finance Ministry has asked Income Tax
department officials to mandatorily mention their
email and official phone numbers in letters,
notices and other email based communication to
taxpayers.
4.0 Computer based Scrutiny by CBDT
The process of selecting tax cases for scrutiny
on a random basis is being replaced by a system-
based centralized approach.
The Central Board of Direct Taxes (CBDT) has
devised a system-based method in a centralised
manner through CASS (Computer Assisted
Scrutiny Selection) whereby the selection is made
on the basis of detailed analysis of risk parameters
and 360 degree data profiling of taxpayers.

7
JANUARY 2016
DIRECT TAXATION / ACCOUNT & AUDIT
6.0 15CA, 15CB rules eased for payments to NRIs
The Income Tax department (I-T Department)
has simplified the disclosure norms for payments
to non-residents, with most of these up to Rs 5
lakh in a year no longer to be disclosed in forms
15CA and 15CB.
Beside, payment for imports do not require these
two forms. Also, a certificate from a chartered
accountant is only required for such payments
which are taxable. The forms would have to be
filled if the amount of payment in a year exceeds
Rs 5 lakh.
No forms 15CA and 15CB will be required to be
furnished by an individual for remittance not
requiring Reserve Bank approval under its
Liberalised Remmittace Scheme.
7.0 Tax disputes up to Rs. 20 lakh to be dismissed
The Central Board of Direct Taxes (CBDT)
recently increased the monetary limit for filing
appeals by the Income Tax (I-T) department at
the Tribunal to Rs 10 lakh from Rs 4 lakh; and to
Rs 20 lakh from Rs 10 lakh at the high court.
This means, the department cannot go for an
appeal in cases where the disputed amount is
below this threshold.
Since it is with retrospective effect, it applies to
existing appeals filed, but pending decision. This
means, all such appeals will be immediately
withdrawn. However, CBDT has maintained the
limit for appeals to be filed at the Supreme Court
at Rs 25 lakh.
ACCOUNTS & AUDIT
1.0 Rules eased: auditors need to report to
Centre corporate frauds of over Rs. 1 crore
Statutory auditors will now have to mandatorily
report to the Centre all corporate frauds
amounting to 1 crore or above. By specifying a
threshold of 1 crore, the Ministry of Corporate
Affairs (MCA) has now done away with the
requirement to report immaterial frauds to the
Centre.
The auditor must first report the fraud to the
company’s audit panel
The audit panel will have to give its views in 45
days
Within 15 days of that, the auditor will have to
send his report to the Centre
Frauds amounting to less than Rs. 1 crore will
need to be reported only to the company’s audit
panel.
2.0 Railways to introduce online system for
tracking costs, Asset creation
The Railways is introducing an online system for
tracking cost and output creation at divisional
level for better Financial Management and
Reporting that will usher in more transparency
and efficiency in the system.
To be called "Performance and Activity Based
Unit Costing", the process is expected to produce
an outcome budget for the railways where it will
be able to analyse stepwise costing of every asset
created and services delivered.
5.0 Mandatory Quoting of PAN Card

8
JANUARY 2016
Contact details : Dharampal (9013363257) All India Chartered Accountants’ Society - CFO World 909, Chiranjiv Tower, 43, Nehru Place, New Delhi-110019.
Ph: 26223712, 26228410, 26226933 E-mail:aicas.cfo@gmail.com / cfoworld@gmail.com EDITOR: Pankaj Gupta, LLB, FCS E-mail: pankajguptafcs@gmail.com
PUBLISHED & PRINTED: At New Delhi by Satish Chandra, Administrative Officer, on behalf of All India Chartered Accountants’ Society, 4696, Brij Bhawan, 21A,
Ansari Road, Darya Ganj, New Delhi-110 002 Phone 23265320, 23288101 E-mail : aicas.cfo@gmail.com Printed at: EIH Ltd., Unit : Printing Press, No. 7, Sham
Nath Marg, Delhi-110054. Views expressed by contributors are their own and the Society does not accept any responsibility.
If undelivered, please return to :
All India CharteredAccountants’Society
4696, Brij Bhawan 21A, Ansari Road,
Darya Ganj, New Delhi-110 002
Date of Printing : 12th
January, 2016
R.N.I. No. 50796/90
Posting Date: 14th
-15th
January, 2016
Registration No. DL(c)-01/1268/2015-17
Licenced to post without prepayment No. U-(C)-82/2015-17
8
FINANCIAL INDICATORS
CurrentRate* PreviousMonth 3 Month ago 6 Month ago
3 Month LIBOR (%) 0.138 0.492 0.3206 0.2858
SENSEX 24825 25252 26904 27573
NIFTY 7563 7683 8143 8328
CRR (%) 4 4 4 4
REPO (%) 6.75 6.75 6.75 7.25
REVERSE REPO (%) 5.75 5.75 5.75 6.25
Gold (per 10 gm) 26071 25324 26568 26014
Silver (per kg) 33481 33841 36560 35217
Crude (USD/bbl) 32.9 40.45 49.95 58.73
` vs USD 66.91 66.79 64.72 63.37
` vs Euro 72.77 73.46 73.59 70.43
` vs 100 Yen 56.78 54.91 53.86 51.97
` vs RMB 10.15 10.37 10.25 10.20
` vs Pound 97.28 101.36 99.29 97.65
MCX Aluminium (per kg) 99.05 98.75 103.85 104.7
MCX Copper (per kg) 297.2 304.05 336.55 357.25
*As on January 10, 2016 (Sources: MoneyControl, NSE, BSE, RBI, MCX)
............from Pg. 3
andpragmatically
The interest rate spread for the banking sector to be
brought down in the range of 1% to 2% with
effective interest rate between 7% to 10 % to industry
and businesses.
Professionalise the management with detailed internal
and statutory audit and independent auditors.
The aforesaid analysis may look highly critical to
certain quarters for which an open debate is needed
to address all issues on a war-footing basis.
We cannot allow certain hidden hands to forge a
conspiracy against our Great Nation and specially
banking sector being the backbone of our
economy.
EDITORIAL

Rbi in need to act efficiently, effectively and pragmatically

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