In India, the securities traded in stock exchanges are held in demat accounts maintained by two depositories--National Securities Depository Limited (NSDL) and Central Depository Services Limited (CDSL), which are independent of a stockbroker and stock exchange’s operation. In the US, the clients' securities are held in a ‘books and records’ system which is maintained by the stockbrokers themselves. So, while US stockbrokers can lend these securities freely and earn interest income, Indian brokers cannot do that with retail securities. In India, there is a Securities Lending and Borrowing protocol, which retail investors can avail but they have to voluntarily participate in this, unlike in the US.