Study of Indian Money Markets
Study of Indian Money Markets
PROJECT ON:
STUDY
Submitted:
In Partial Fulfillment of the requirements
For the Award of the Degree of
MASTERS OF COMMERCE
( BANKING & FINANCE )
BY
RIDDHI J SANGOI
ROLL NO : 47
1
DECLARATION
DATE:
PLACE: MUMBAI
SIGNATURE OF STUDENT
( RIDDHI J SANGOI )
CERTIFICATE
This is to certify that MISS RIDDHI J SANGOI, studying in Mcom (BANKING
& FINANCE) PART 2 (SEM-III), ROLL NO. 47, academic year 2016-2017 at
[Link] COLLEGE OF ARTS, SCIENCE & COMMERCE has
completed the project on STUDY OF INDIAN MONEY MARKETS
under the guidance of Proff. SHAMA SHAH
The information submitted herein is true and original to the best of my
knowledge.
____________________
___________________
[PROJECT GUIDE]
____________________
EXTERNAL EXAMINER
[PRINCIPAL]
___________________
MR. RAVIKANT
[CO-ORDINATOR]
DECLARATION BY GUIDE
I, the undersigned Prof. has guided MISS RIDDHI J SANGOI ROLL NO. 47
for her project. She has completed the project on STUDY OF INDIAN
MONEY MARKET. successfully.
I, hereby declare that information provided in this project is true as per the
best of my knowledge.
Prof.
Project Guide
ACKNOWLEDGEMENT
INDEX
SR
NO
CHAPTER NAME
PAG
E
NO
12
18
21
32
CONCLUSION
36
BIBLOGRAPHY
37
CHAPTER 1
INTRODUCTION
6
Money market refers to the market where money and highly liquid marketable securities are
bought and sold having a maturity period of one or less than one year. It is not a place like the
stock market but an activity conducted by telephone. The money market constitutes a very
important segment of the Indian financial system. The highly liquid marketable securities are
also called as money market instruments like treasury bills, government securities, commercial
paper, certificates of deposit, call money, repurchase agreements etc.
The major player in the money market are Reserve Bank of India (RBI), Discount and Finance
House of India (DFHI), banks, financial institutions, mutual funds, government, big corporate
houses. The basic aim of dealing in money market instruments is to fill the gap of short-term
liquidity problems or to deploy the short-term surplus to gain income on that.
The money market is a market for lending and borrowing of short-term funds.
Money market deals in funds and financial instrument having a maturity period of one
day to one year.
The instruments in the money market are close substitutes for money as they are of shortterm nature and highly liquid.
that
deal
in
the
various
grades
of
near
money."
These definitions help us to identify the basic characteristics of a money market. A money
market comprises of a well organized banking system. Various financial instruments are used for
transactions in a money market. There is perfect mobility of funds in a money market. The
transactions in a money market are of short term nature.
The issue of whether non-bank participants should constitute part of call/notice/term money
market could be traced first in the Report of the Committee to Review the Working of the
Monetary System (Chairman: S. Chakravarty) in 1985. Since then, the Report of the Working
Group on the Money Market (Chairman : N. Vaghul) in 1987 and the Report of the Committee
on Banking Sector Reforms (Chairman : M. Narasimham) in 1998 had also deliberated on this
issue. It needs to be appreciated that the particular set of recommendations from these three
Committees have to be assessed against the specific objectives for which these Committees had
been constituted as well as the differing initial conditions reflecting the state of Indian financial
market which were prevailing at that particular point of time.
The Narasimham Committee II (1998) concurred with the Vaghul Committee as it also observed
that call/notice/term money market in India, like in most other developed markets, should be
strictly restricted to banks. It, however, felt that exception should be made for Primary Dealers
(PDs) who have been acting as market makers in the call money market and are formally treated
as banks for the purpose of their inter-bank transactions and, therefore, they should remain as
part of call money market. With regard to non-banks, it expressed concern that these participants
"are not subjected to reserve requirements and the market is characterized by chronic lenders and
chronic borrowers and there are heavy gyrations in the market". It felt that allowing non-bank
participants in the call market "has not led to the development of a stable market with liquidity
and depth and the time has come to undertake a basic restructuring of call money market". Like
the Vaghul Committee, it had also suggested that the non-bank participants should be given full
access to bill rediscounting, Commercial Paper (CP), Certificates of Deposit (CDs), Treasury
Bills (TBs) and Money Market Mutual Funds (MMMFs) for deploying their short-term surpluses
Providing an equilibrium mechanism for ironing out short-term surplus and deficits.
It
means to keep a balance between the demand for and supply of money for short term
monetary transactions.
Providing a focal point for central bank intervention for the influencing liquidity in the
economy.
To promote economic growth. Money market can do this by making funds available to
various units in the economy such as agriculture, small scale industries, etc.
10
To provide help to Trade and Industry. Money market provides adequate finance to trade
and industry. Similarly it also provides facility of discounting bills of exchange for trade
and industry.
CHAPTER 2
11
Every money is unique in nature. The money market in developed and developing countries
differ markedly from each other in many senses. Indian money market is not an exception for
this. Though it is not a developed money market, it is a leading money market among the
developing countries.
Indian Money Market has the following major characteristics:
Seasonality: The demand for money in Indian money market is of a seasonal nature. India
being an agriculture predominant economy, the demand for money is generated from the
agricultural operations. During the busy season i.e. between October and April more
agricultural activities takes place leading to a higher demand for money.
Multiplicity of Interest Rates: In Indian money market, we have many levels of interest
rates. They differ from bank to bank from period to period and even from borrower to
borrower. Again in both organized and unorganized segment the interest rate differs. Thus
there is an existence of many rates of interest in the Indian money market.
12
Lack of Organized Bill Market: In the Indian money market, the organized bill market is
not prevalent. Though the RBI tried to introduce the Bill Market Scheme (1952) and then
New Bill Market Scheme in 1970, still there is no properly organized bill market in India.
Absence of Integration: This is a very important feature of the Indian money market. At
the same time it is divided among several segments or sections hitch are loosely
connected with each other. There is a lack of coordination among these different
components of the money market. RBI has full control over the components in the
organized segment but it cannot control the components in the unorganized segment.
High Volatility in Call Money Market: The call money market is a market for very short
term money. Here money is demanded at the call rate. Basically the demand for call
money comes from the commercial banks. Institutions such as the GIC, LIC, etc suffer
huge fluctuations and thus it has remained highly volatile.
Limited Instruments: It is in fact a defect of the Indian money market. In our money
market the supply of various instruments such as the Treasury Bills, Commercial Bills,
Certificate of Deposits, Commercial Papers, etc. is very limited. In order to meet the
varied requirements of borrowers and lenders, It is necessary to develop numerous
instruments.
13
operations. There is also, at the same time, a greater need for closely monitoring the movements
of call money rates.
Extension of the Repo Market
It has been the endeavor of the Reserve Bank to develop the repo market not only for easing
pressure from the uncollateralized call money market but also to facilitate the emergence of a
short-term rupee yield curve for pricing fixed income securities. At present, only Central and
State Governments securities are eligible for market repo. However, State Government securities
do not have wider acceptability as there are hardly any repo operations based on them. As the
fixed income money market has been overwhelmingly dependent upon Central Government
securities, there is a need to consider broad-basing the pool of eligible securities. In future, the
growth of market repo will be driven by the short selling activity in the government securities
market as a reposed security can now be delivered up to five days in view of the recent changes
in the regulations governing short sales
Development of a Vibrant Term Money Market
The term money market has not developed for several reasons. One of the major reasons for this
is that market participants have been unable to take a long-term view of interest rates despite
availability of Treasury Bills of varying maturities and a reasonably developed swap market. In
order to enable market participants to take a long-term view on interest rates, it is imperative that
the ALM framework is strengthened and greater flexibility is allowed to the personnel managing
treasury operations in banks. The skewness in liquidity in the money market in terms of chronic
lenders and borrowers would get corrected as banks develop better ALM systems. The
development of the term money market is vital for strengthening proper linkages between the
foreign exchange market and the domestic currency market, which, in turn, would provide an
impetus to the derivative segment.
Relook at Inter-Bank Participation Certificates
15
Inter-Bank Participation Certificates, which can be used for evening out short-term liquidity
mismatches by banks, were introduced in October1988 in order to infuse greater degree of
flexibility in their credit portfolios. In view of rapid credit growth in recent years, interest in
IBPCs has again arisen. In this context, since considerable time has elapsed since the guidelines
on the scheme of IBPCs were issued, the IBPC scheme with respect to duration, quantum in
terms of the proportion to the loan amount, eligible participants and transferability of IBPCs
needs a thorough review. Depending on the results of such a review, extending the use of this
instrument could also facilitate the asset liability management by banks,
improve day-to-day liquidity management and help develop a market for credit risk transfer
instruments between banks.
Futures on Policy Linked Interest Rates
Going forward, an Indian variant of the Federal Funds Futures on interest rates linked to the
Reserve Banks key policy rates may emerge. Trading in the futures market would reveal
important information about market expectation on the future course of monetary policy. For
instance, the trading of the Federal Funds Futures provides key information to the Federal Open
Market Committee (FOMC) in the US in formulating its monetary policy.
Promoting Financial Stability
Default risk in the money market has the potential to create a contagion in the financial markets
and, therefore, needs to be mitigated. In this regard, experiences of developed economies show
that generally the self-regulatory organizations (SROs) regulate activities of participants in the
money market in terms of their capital adequacy and conduct of business. Also, default
resolution in most of these markets is undertaken through the Contract Law and the Bankruptcy
Law. In view of international experience, there may be a case for empowering a suitable selfregulatory organization appropriately to act as a catalyst for the development of market
microstructure.
One of the fundamental forces that could contribute to more organic integration across various
segments of the financial market is the technological up gradation of the payment and settlement
16
system. The accomplishment of virtual Public Debt Office (PDO) and Deposit Accounts
Department (DAD) at the Reserve Bank, coupled with the operationalization of the centralized
funds management system (CFMS).
17
CHAPTER 3
Participants in the Money Market
The transactions in the money market are of high volume involving large amount. So, money
market is dominated by a small number of large players.
Some of the important players in the money market are:
Financial Institution.
The reserve Bank of India is the most important player in the Indian Money Market.
The Organized money market comes under the direct regulation of the RBI.
The RBI operates in the money market is to ensure that the levels of liquidity and shortterm interest rates are maintained at an optimum level so as to facilitate economic growth
and price stability.
RBI also plays the role of a merchant banker to the government. It issues Treasury Bills
and other Government Securities to raise funds for the government.
The RBI thus plays the role of an intermediary and regulator of the money market.
*GOVERNMENT:
The Government is the most active player and the largest borrower in the money market.
The funds may be raised through the issue of Treasury Bills (with maturity period of
91day/182day/364 days) and government securities.
*CORPORATE FIRMS:
Corporate firms operate in the money market to raise short-term funds to meet their
working capital requirements.
They issue commercial papers with a maturity period of 7 days to 1 year. These papers
are issued at a discount and redeemed at face value on maturity.
These corporate firms use both organized and unorganized sectors of money market.
*BANKS:
19
The collective operations of the banks on a day to day basis are very predominant and
hence have a major impact and influence on the interest rate structure and the liquidity
position.
*FINANCIAL INSTITUTIONS:
Since, they transact in large volumes, they have a significant impact on the money
market.
*INSTITUTIONAL PLAYERS:
They Consist of Mutual Funds, Foreign Institutional Players, Insurance Firms, etc.
For instance the level of participation of the FIIs in the Indian money market is restricted
to investment in Government Securities.
20
Discount Houses discount and rediscount commercial bill and Treasury Bills.
Primary Dealers were introduced by RBI for developing an active secondary market for
Government securities.
CHAPTER 4
21
Structure
The Indian money market consists of two main sectors:
1) ORGANISED SECTOR:
The RBI is the apex institution that controls and monitors all the organizations in the
organized sector.
Also, the organized money market is composed of various components/ instruments that
are highly liquid in nature.
22
The instruments traded are call money, treasury bills, commercial bills, certificate of
deposits, commercial papers, repos etc.
The organized money market is further diversified with the establishment of the Discount
and finance House of India, and Money market Mutual Funds.
i) CALL
MONEY AND
NOTICE
MONEY MARKET:
The
the
most important
segment of the Indian
money
market. It is also
called
as inter-bank call
money
market.
23
Under call money market, funds are transacted on an over-night. Generally, banks rely on
call money market where they raise funds for a single day.
The notice money market funds are transacted for a period of 2 to 14 days. The loans are
to be repaid at the option of either the lender or the borrower.
The rate at which funds are borrowed / lent in this market is called the call money rate.
The main participants in the call money market are commercial banks (excluding RRBs),
co-operative banks and primary dealers.
The Discount and finance House of India and non-banking financial institutions like LIC,
GIC, UTI, NABARD, etc, also participate in the call money market.
Call money markets are generally concentrated in large commercial centre like Mumbai,
Delhi, Chennai, Kolkata and Ahmadabad.
The RBI intervenes in the call money market because it is highly sensitive and it is the
indicator of liquidity position in the organized money market.
The call money rate (that depends on depends on demand for and supply of funds) is
highly variable from day to day and from centre to centre.
Treasury bills are short-term securities issued by the RBI on behalf of the Government of
India.
24
Treasury bills are of three types: 91 day treasury bills, 182 days treasury bills and 364 day
treasury bills.
Since these bills are issued through auctions, interest rates on all types of treasury bills
are determined by market forces.
Treasury Bills are available for a minimum amount of Rs 25000 and in multiples of RS
25000.
Treasury Bills are traded in the secondary market. Commercial banks, Primary Dealers,
Mutual Funds, Corporate, and Financial Institutions, Provident / Pension funds and
Insurance companies participate in the treasury Bills Market.
Such bills are called trade bills / bills of exchange and when they are accepted by banks,
they are called commercial bills.
Generally the bill is payable at a future date (mostly, the maturity period is up to 90
days).
During this period, the seller may discount the bill with the banks. The commercial banks
may rediscount these bills with FIs like EXIM bank, SIDBI, IDBI, etc.
Thus, commercial bills are very important for providing short-term credit to trade and
commerce.
CDs are marketable receipts of funds deposited in a bank for a fixed period at a specified
rate of interest.
CDs were originally introduced in India to enable commercial banks to raise funds from
the market.
The RBI has modified its original scheme for CDs. the following are the recent guidelines for the
issue of CDs:a. ELIGIBILITY: CDs can be issued by commercial banks (except RRBs and Local Area
Banks) and financial institutions that have been permitted to raise short-term loans by
RBI.
26
b. AMOUNT: while banks can issue CDs depending on the requirements, financial
institutions can issue CDs within the limit fixed by the RBI.
c. MINIMUM SIZE: the minimum size of an issue for a single investor is Rs 1 lakh and it
can be increased in multiples of Rs 1 lakh.
d. DISCOUNT RATE: CDs are issued at a discount to face value. Bank / Financial
institutions are free to determine discount rates on floating rate basis.
e. INVESTORS: CDs are issued to individuals, corporations, companies, trusts, etc.
f. TRANSFERABILITY: CDs are freely transferable by endorsements / delivery.
However demitted CDs have to transfer as per specified procedures. There is no lock-in
period for CDs.
g. MATURITY: Commercial banks can issue CDs with a maturity period between 7 days
to 1year. Financial institutions can issue CDs with amaturity period between 1 year to 3
years.
h. RESERVE REQUIREMENTS: CDs are subject to CRR and SLR since banks have to
report CDs to RBI.
i. LOANS / BUY-BACK: Commercial banks / FIs cannot give loans against CDs.
Similarly, they cannot buy-back their own CDs before maturity period.
j. FORMAT: Banks /FIs should issue CDs only in the dematerialized form. However,
investors have the option to seek CDs in physical form.
v) COMMERCIAL PAPERS:
27
Commercial paper is an unsecured, highly liquid money market instrument in the form of
a promissory note / a dematerialized form through any of the depositories registered with
SEBI.
It has fixed maturity whereby the purchaser is promised a fixed amount at a future date.
Commercial papers are issued by leading nationally reputed manufacturing and finance
companies (Public / private sector).
Commercial papers are issued (by corporate / primary dealers / all India financial
institutions) on the following conditions:
a) The tangible net worth of the issuing company should not be less than RS4 crores.
b) The working capital limit of the company has been sanctioned by banks /financial institution.
c) The borrowal a/c of the company is rated as a standard asset by banks /financial institutions.
Commercial Papers have maturity period between 7days and 1year from the date of issue.
Individuals, banks, corporate bodies, NRIs and FIIs can invest in commercial papers.
Every issuer must appoint an IPA (Issuing and Paying Agent) for issuance of commercial
papers. Only a scheduled commercial bank can act as an IPA.
The RBI achieves the function of maintaining liquidity in the money market through
REPOS / REVERSE REPOS.
28
The repo / reverse repo is a very important money market instrument to facilitate shortterm liquidity adjustment among banks, financial institutions and other money market
players.
A repo / reverse repo is a transaction in which two parties agree to sell and repurchase the
same security at a mutually decided future date and price.
From the sellers point of view, the transaction is called a repo; whereby the seller gets
immediate funds by selling the securities with an agreement to repurchase the same at a
future date.
Similarly, from the buyers point of view, the transaction is called a reverse repo,
whereby the purchaser buys the securities with an agreement to resell the same at a future
date.
The RBI, commercial banks and primary Dealers deal in the repos and reverse repo
transactions.
The financial institutions can deal only in the reverse repo transactions i.e. they are
allowed only to lend money through reverse repos to the RBI, other banks and Primary
dealers.
a. Inter-bank repos (the transaction takes place between banks and DFHI).
b. RBI repos (The repos / reverse repos are undertaken between banks and the RBI to
stabilize and maintain liquidity in the market).
a.
b. to create an equilibrium between the demand for and supply of short-term funds.
c.
The Discount and Finance House of India is jointly owned by the RBI, the public sector
banks and all India financial institutions.
The DFHI helps in developing and stabilizing the money market by stimulating activity
in the money market instruments and developing secondary market in those instruments.
The DFHI deals in treasury bills, commercial bills certificates of deposits, commercial
papers, short term deposits, call money market and govt securities. It also participates in
repo operations.
Thus, the DFHI has helped corporate entities, banks and financial institutions to invest
their short-term surpluses in money market instruments.
The RBI introduced Money Market Mutual Funds to enable small investors to participate
in the money market. Thus, MMMFs mobilizes saving of mutual funds and invest them
in such money market instruments that mature in less than one year.
30
a.
MMMFs can be set by scheduled commercial banks and public finance institutions.
2) UNORGANISED SECTOR:
The unorganized Indian money market mainly comprises of indigenous bankers, money
lenders and unregulated non-banking financial intermediaries.
Though they may exist in urban centers, their activities are mainly concentrated in rural
areas. In fact, 36% of rural households depend on these for their financial requirement.
i) INDIGENOUS BANKERS:
These financial intermediaries operate as banks by receiving deposits, giving loans and
dealing in hundies (The hundi is a short term indigenous bill of exchange)
31
However they do not solely depend on deposits, they may use their own funds.
They are called by different names like Kathawals, Saraf, Shroffs,Chettis, etc.
The main advantages of indigenous bankers are simple and flexible operations, informal
approach, personal contact, quick services and availability of timely funds.
However, they have their drawbacks like a very high rate of interest (18%to 36%),
combining banking with trade, interest in non-banking activities like general merchants,
brokers, etc.
ii)MONEY LENDERS:
Money lenders predominate in villages and they deal in the business of lending money.
Loans are given to agricultural labourers, marginal and small farmers, artisans, factory
workers, etc for unproductive purposes.
CHAPTER 5
The Growth of Money Market in India
32
While the need for long term financing is met by the capital or financial markets, money market is
a mechanism which deals with lending and borrowing of short term funds. Post reforms period in
India has witnessed tremendous growth of the Indian money markets. Banks and other financial
institutions have been able to meet the high expectations of short term funding of important sectors
like the industry, services and agriculture. Functioning under the regulation and control of the
Reserve Bank of India (RBI), the Indian money markets have also exhibited the required maturity
and resilience over the past about two decades. Decision of the government to allow the private
sector banks to operate has provided much needed healthy competition in the money markets,
resulting in fair amount of improvement in their functioning.
Quantum of liquidity in the banking system is of paramount importance, as it is an important
determinant of the inflation rate as well as the creation of credit by the banks in the economy.
Market forces generally indicate the need for borrowing or liquidity and the money market adjusts
itself to such calls. RBI facilitates such adjustments with monetary policy tools available with it.
Heavy call for funds overnight indicates that the banks are in need of short term funds and in case
of liquidity crunch, the interest rates would go up.
Depending on the economic situation and available market trends, the RBI intervenes in the money
market through a host of interventions. In case of liquidity crunch, the RBI has the option of either
reducing the Cash Reserve Ratio (CRR) or pumping in more money supply into the system.
Recently, to overcome the liquidity crunch in the Indian money market, the RBI has released more
than Rs 75,000 crore with two back-to-back reductions in the CRR.
In addition to the lending by the banks and the financial institutions, various companies in the
corporate sector also issue fixed deposits to the public for shorter duration and to that extent
become part of the money market mechanism selectively. The maturities of the instruments issued
by the money market as a whole, range from one day to one year. The money market is also
closely linked with the Foreign Exchange Market, through the process of covered interest arbitrage
in which the forward premium acts as a bridge between the domestic and foreign interest rates.
33
differentiate between short term and long term finance and between the purposes of finance.
This puts a limit on the RBIs control over the money market.
3. LACK OF INTEGRATION: The RBI finds it difficult to integrate the organized and the
unorganized money market. While the RBI can control and supervise the working of the
organized sector effectively, the heterogeneous unorganized sector is out of RBIs control.
There is no uniformity in the practices and operations of the unorganized money market.
Moreover, the interest rates in both the markets are also different. Thus there is lack of
integration in the Indian money market.
4. MULTIPLICITY IN INTEREST RATES: There is diversity in rates of interest in the
Indian money market. This multiplicity in the interest rates is due to lack of mobility of funds
from one section of the money market to another. The rates differ from institution to
institution even for funds of the same duration. Although the wide differences are being
narrowed down, the existing differences do hamper the efficiency of the money market.
5. ABSENCE OF ORGANISED BILL MARKET: The existence of a well-organized bill
market is essential for effective linking up various credit agencies. It refers to a mechanism
where bills of exchange are purchased and discounted by commercial banks / financial
institutions. The bill market is not yet developed in India due to the following reasons:
35
with funds especially in urban area as people prefer to invest their money with banks rather
than keeping them as deposits in the unorganized sector.
7. SEASONAL STRINGENCY OF MONEY: Since agriculture continues to play a major role
in the Indian economy, farm operations do influence the demand for and supply of money.
Thus seasonal stringency of money and high interest rate during the busy season (November
to June) is a striking feature of the Indian money market. Also, there a wide fluctuations in
the interest rates from one reason to another. However, the RBI makes attempt to reduce the
fluctuations by adding money into the money market during the busy season and
withdrawing the funds during the slack season.
8. INADEQUATE CREDIT INSTRUMENTS: The Indian money market lacked adequate
short-term paper instruments till1985-86. Only call money market and bill market existed.
Also there were no specialized dealers / brokers in the money market. After 1985-86 the RBI
Introduced new credit instruments in the market like CDs, CPs, MMMF, etc, but they are not
yet fully developed in India.
9. ABSENCE OF a WELL-ORGANISED BANKING SECTOR IN RURALAREA: There
is poor banking system in the rural area due to the problems of overheads and maintenance of
branches. The commercial bank branches in rural area are only 40% of the total bank
branches. This also hampers the development of money market in India.
10. INEFFICIENT AND CORRUPT MANAGEMENT: Faulty selection, lack of training,
poor performance appraisal and faulty promotions result in inefficiency and corruption in the
banking sector. This adversely affects the success and performance of money market. These
are some of the major drawbacks of the Indian money market; many of these are also the
features of our money market.
Conclusions
36
The money market is a vibrant market, affecting our everyday lives. As the shortterm market for money, money changes hands in a short time frame and the players
in the market have to be alert to changes, up to date with news and innovative with
strategies and products. The withdrawal of non-bank entities from the inter-bank
call-money market is linked to the improvement of settlement systems. Any timebound plan for the evolution of a pure inter-bank call/notice money market would
be ineffective till the basic issue of settlements is addressed.
In brief, various policy initiatives by the Reserve Bank have facilitated
development of a wider range of instruments such as market repo, interest rate
swaps, CDs and CPs. This approach has avoided market segmentation while
meeting demand for various products. These developments in money markets have
enabled better liquidity management by the Reserve Bank
Biblography
37
[Link]
[Link]
RBIs site --- [Link]
SBI DFHIs site --- [Link]
Indian Institute Of Banking & Finance --- [Link]
[Link]
[Link]
[Link]/weekly statistical supplement/ various [Link]
[Link]
[Link]
[Link]
[Link]
[Link]
38
39