14 May 2019

DVRs - an instrument whose time has not come

I have a piece in today's ET arguing that the time is not right for the introduction of DVRs in its liberal avatar. In the words of EM Foster 'now here, not now'. Indian minority protection levels need to be substantially strengthened before such an introduction. Here is the piece linked and the entire piece is below:


DVRs - an instrument whose time has not come

In the old adage ‘put your money where your mouth is’ the mouth may be moving away from the money. SEBI’s recent move seeking to amend differential voting rights is a move whose time has not come. Differential voting rights are essentially certain shareholders having different number of votes. So a promoter may have say 10 votes per share, while a mortal shareholder may be lucky to have only one per share. While DVRs have been around for some time under the old Companies Act as also under the 2013 version, SEBI has permitted them for over a decade with the restriction that no company may provide shares with superior voting rights, though it may issue shares with inferior voting rights. This follows a nearly century old jurisprudence, where a shareholder once issued shares cannot be diluted, because he or she never bargained to be short-changed in the future with the promoter getting say ten votes per share.

Lack of demand for DVRs: The popularity of DVRs among investors has not picked up in the Indian securities market. Even though a handful of listed companies have issued DVRs in the past as highlighted in the Consultation Paper itself, they continue to be traded at a steep discount and they are barely liquid even at that price. This goes to show that Indian investors continue to value their voting rights/powers and are not keen on trading it for higher dividends or other benefits. Because of their unpopularity, domestically there is little empirical evidence with respect to such companies.

Inherent disadvantages of issuing DVRs: The known downsides in several western countries are clear. DVRs can mis-align incentives, be a tool for mismanagement and oppression of minority shareholders, encourage entrenchment of promoters with little skin in the game, result in excess compensation and typically companies with DVRs lag other companies in performance if you take out a handful of the super-successful companies like Facebook from the equation. However, they have been allowed on the premise that providing such flexibility would encourage companies where promoters don’t want to give up control, to come to public markets. There is also an argument that promoters would act in the long term interest of the company without regard to the outcome of the next quarter.

SEBI proposes: Now SEBI proposes to introduce superior voting rights (SR). Under the proposed paper of SEBI, superior rights can be issued to promoters before an IPO. SEBI has introduced several dis-incentives so that these are not mis-used. The dis-incentives include lock in of shares, inability to trade them in the market, a sunset or expiry clause on superiority, inability to pledge them, cap on number of votes and DVRs becoming ordinary shares in certain kinds of resolutions.

Dis-enfranchisement: SR shares are just a euphemism for dis-enfranchisement. It is unclear how having superior voting rights and ignoring the votes of the many would improve long term strategy. SEBI should implement evidence based laws and there is no evidence world-wide that providing SR shares improves firm value. In fact, the evidence clearly shows that over the medium and long term they are value destructive. The most comprehensive academic study on dual-class shares published in 2010 by three professors from Harvard, Stanford and Yale found evidence that dual class shares reduce firm value in US companies, result in weakened takeover and market checks, diminished board independence and effectiveness, and reduced institutional investor oversight. Such boards have been shown to be statistically less independent and consequentially more deferential to management. Further, as per the Asia Corporate Governance Association, the introduction of DVRs in Hong Kong and Singapore have adversely impacted the reputation of their securities market. The introduction would take us on a regulatory race to the bottom.

Poor investor protection standards in India: Adopting western standards directly and looking at the benefits without looking at the poor status of investor protection in India, begs the question whether we should transplant a western standard without the investor protection means available to the western investor. Charles Elson, director of the Weinberg Center for Corporate Governance at the University of Delaware, says that “when you have dual-class shares, what you are doing is exporting the monitoring function to third parties - to the government, the courts, the regulators. This is because dual class shares will severely inhibit the role of directors, shareholders and markets in corporate governance.” Issuance of DVRs in this governance vacuum may be detrimental to the interest of the minority shareholders of companies.

India IS different: Usually the statement that India is different, should always be taken with a fistful of salt, but in the case of DVRs, that is indeed the case. With poor investor rights, mis-management rife and a complete lack of class action law suits, India simply doesn’t have the tools to manage even more power to the promoter class. Already, promoters in India own 45% of listed company shares on average. Give both the dominance of promoters and poor minority rights in fact, India is simply not ready to give another tool to corporate India to shortchange regular investors like you and me. Giving the investors a Hobson’s choice of a good company with poor governance is not a standard we should adopt.


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