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Bitcoin – hype or reality?

| 08-01-2018 | Lionel Pavey |

Having spent my working life in international finance, I have patiently listened to all the news about the Bitcoin over the last few years. During 2017 whilst the Bitcoin was on a spectacular price rise, my interest was awakened in this new phenomenon – is this the future? I attended seminars, read articles, learnt the difference between the Bitcoin and the Blockchain, searched and investigated via the web, and tried to form an opinion. These are my findings:

Here is a technology that has recently been created – started in 2009 – that has caused a huge debate and led to passionate arguments on its merits or demerits. Those in the know understand its concept – the rest are baffled by its very existence. At essence it is a digital currency – there are no coins or notes in existence. It is decentralized – there are no governments controlling it. If you own it, your identity is anonymous to others – transactions take place via encryption keys. The supply is limited – protocol dictates that a maximum of 21 million Bitcoins can be produced. At the end of 2017 there were 16,774,500 coins in circulation – roughly 80% of the maximum allowed. So, the supply is clearly limited, but they have no real intrinsic value – they do not represent a claim on an asset.

My main area of interest has been on the price – the rise in 2017 of more than 1,400% is astounding. I decided to collate some information and have a chart showing Bitcoins price of the last 2 years.

Such a stellar performance should mean that the trade volume has increased dramatically.

Well……. here is another chart

The daily volume in September 2017 when the price was about $4,000 was the same as the start of February 2016 when the price was about $400. I had to create this chart as all the data I could find related to the $ value of turnover – which was phenomenal – and not the actual number of Bitcoins traded. Normally, when an asset sees a huge increase in price, this goes together with a corresponding increase in turnover. Clearly this has not happened with Bitcoin – why?

There appears to be a “strategy” of buying Bitcoin to hoard them. There does not appear to be a sizeable free float of Bitcoin. If there is more demand than supply, then obviously the price will increase dramatically. Bitcoin is touted as an alternative currency, yet the advocates do not seem to want to spread it around with everybody else. It is a currency that is not used to settle transactions – this makes it difficult to consider Bitcoin becoming a recognized mechanism for payments. One of the criteria of money is that it is a “medium of exchange” – yet again Bitcoin, which appears to be hoarded, does not meet the criteria.

How can a cryptocurrency replace a conventional fiat currency if it is not freely tradeable? Furthermore, if you hold Bitcoin and want to take your profit, then this will be realized in a fiat currency. As Bitcoin is generally quoted and traded in $, this means receiving your profit in an antiquated currency that your cryptocurrency wishes to replace – ironic?

The underlying technology – Blockchain – is here to stay. As to whether Bitcoin is here to stay – if people hoard Bitcoin, it will exist. What the value of Bitcoin should be – whatever someone is prepared to pay for it. Will it replace fiat currency – maybe one day, but not in its present Bitcoin form.

Lionel Pavey

Cash Management and Treasury Specialist

Forward Rate Agreement (FRA)

| 05-01-2018| Arnoud Doornbos |

Money Market outlook

At the press conference on 14 December 2017, the ECB announced that expectations for economic growth and inflation have been adjusted upwards. But despite optimistic growth, the ECB is not yet fully convinced of a continued upward trend in domestic price pressures. And thus Draghi: “An ample degree of monetary stimulus … is necessary for underlying inflation pressures to continue to build up.”

For this reason, the ECB will maintain the buying program at least until September 2018. And only then will an increase in policy rates come into the picture. Since the beginning of 2017, investors have seen the chance that the ECB will implement an increase in policy interest rates. This has not yet had an effect on the three-month Euribor rate. This has been stable at around -0.3% for the whole of 2017, and we expect that this will be the case in the vast majority of 2018 as well.

But markets will go up again for sure during time and borrowers need to prepare themselves for that moment. A good interest rate risk management can help to extent the pleasure of using favorable low interest rates for your company. Hedging your short term interest rate exposure with FRA’s could be a good idea. Good timing is essential.

Definition

A Forward Rate Agreement’s (FRA’s) effective description is a cash for difference derivative contract, between two parties, benchmarked against an interest rate index. That index is commonly an interbank offered rate (-IBOR) of specific tenor in different currencies, for example LIBOR in USD, GBP, EURIBOR in EUR or STIBOR in SEK. A FRA between two counterparties requires a fixed rate, notional amount, chosen interest rate index tenor and date to be completely specified.

FRAs are not loans, and do not constitute agreements to loan any amount of money on an unsecured basis to another party at any pre-agreed rate. Their nature as a IRD product creates only the effect of leverage and the ability to speculate, or hedge, interest rate risk exposure.

How it works

Many banks and large corporations will use FRAs to hedge future interest or exchange rate exposure. The buyer hedges against the risk of rising interest rates, while the seller hedges against the risk of falling interest rates. Other parties that use Forward Rate Agreements are speculators purely looking to make bets on future directional changes in interest rates.

In other words, a forward rate agreement (FRA) is a tailor-made, over-the-counter financial futures contract on short-term deposits. A FRA transaction is a contract between two parties to exchange payments on a deposit, called the Notional amount, to be determined on the basis of a short-term interest rate, referred to as the Reference rate, over a predetermined time period at a future date.

At maturity, no funds exchange hands; rather, the difference between the contracted interest rate and the market rate is exchanged. The buyer of the contract is paid if the published reference rate is above the fixed, contracted rate, and the buyer pays to the seller if the published reference rate is below the fixed, contracted rate. A company that seeks to hedge against a possible increase in interest rates would purchase FRAs, whereas a company that seeks an interest hedge against a possible decline of the rates would sell FRAs.

Valuation and Pricing

The cash for difference value on a FRA, exchanged between the two parties, calculated from the perspective of having sold a FRA (which imitates receiving the fixed rate) is calculated as:

where N is the notional of the contract, R is the fixed rate, r is the published -IBOR fixing rate and d is the decimalized day count fraction over which the value start and end dates of the -IBOR rate extend.

For USD and EUR this follows an ACT/360 convention and GBP follows an ACT/365 convention. The cash amount is paid on the value start date applicable to the interest rate index (depending in which currency the FRA is traded, this is either immediately after or within two business days of the published -IBOR fixing rate).

For mark-to-market (MTM) purposes the net present value (PV) of an FRA can be determined by discounting the expected cash difference, for a forecast value r:

where vn is the discount factor of the payment date upon which the cash for difference is physically settled, which, in modern pricing theory, will be dependent upon which discount curve to apply based on the credit support annex (CSA) of the derivative contract.

Quotation and Market-Making

FRA Descriptive Notation and Interpretation

How to interpret a quote for FRA?

[EUR 3×6 -0.321 / -0.301%p.a ] – means deposit interest starting 3 months from now for 3 month is -0.321% and borrowing interest rate starting 3 months from now for 3 month is -0.301%. Entering a “payer FRA” means paying the fixed rate (-0.321% p.a.) and receiving a floating 3-month rate, while entering a “receiver FRA” means paying the same floating rate and receiving a fixed rate (-0.321% p.a.).

Due to the current negative Money Market rates means receiving actually paying and the other way around.

Arnoud Doornbos

Interim Treasury & Finance

Cashforce: Treasury year-end meetup

Onderstaand een kort verslag van ons Treasury year-end meetup-event van eind 2017.

Tim (Jonk – Thomson Reuters) en Martijn (Duijnstee – Cashforce) trapten af met een (uiterst!) korte terugblik op 2017 want alle ogen waren eigenlijk al gericht op het progamma waarin de 3. Top-challenges 2018 voor corporate treasurers de revue zouden passeren.

Nicolas (Christiaen – Cashforce) gaf inzicht in wat er bij komt kijken om, in 6 stappen, een daadwerkelijk nauwkeurig en geautomatiseerd 1. Cash forecasting-proces in te richten. No more Excel!

Bart-Jan (Roelofsz – HERE Technologies) kwam letterlijk net uit ‘de vlieger’ uit Chicago stappen en kon gelijk door naar het podium waar hij een bijzonder aansprekende presentatie gaf over 2. Financing in het algemeen en de transitie van bedrijfsactiviteiten en opbouw van het Treasury en Finance Team in een snel groeiende organisatie. Top!

Alex (Goraieb – Thomson Reuters) nam het stokje over en gaf ons meer dan een kijkje in de wondere wereld van 3. Risk Management. Een wereldreis in de achtbaan van volatiele markten en valuta, via de onderliggende techniek van trading in grote posities naar een lesje ‘hoe selecteer ik de beste bank’. Well done!

En toen was het snel! naar de borrel want in het kader van ‘Act Global, drink Local’ stond het Ijndejaarsbier van Brouwerij ‘t Ij koud en op fust te wachten, en wat had iedereen toch een dorst gekregen…

Tijdens de borrel werden er meerdere robbertjes uitgevochten tijdens de Kick-off 2018 games op de Cashforce-voetbaltafel.

Voor hen die er waren, dank voor jullie komst en voor hen die er niet waren: volgend jaar een nieuwe kans want wat ons betreft zeker voor herhaling vatbaar!

Nicolas Christiaen

Managing Partner at Cashforce

Commercial Paper – alternative short term funding

| 03-01-2018 | treasuryXL |

There are many different products that a company can use to meet its funding requirements. These products mainly fall into (but are not exclusive to) 2 major categories – equity or debt. Within both categories that are many different bespoke products that can be used. Debt can be either for long term or short term – both in respect to the tenor and the interest rates. Furthermore, interest rates can be fixed or floating. In this series we shall be looking at popular products that are used to help fund a business.

Definition
Commercial Paper is a money market product issued by large companies to receive funding for short term needs. The tenor (maturity) is normally for a short period up to 270 days. The paper is a promissory note that is unsecured – there is no collateral/security offered against the paper. As such Commercial Paper is normally only ever issued by large well-known companies who have credit ratings.

How it works
When a company needs short term funds it can issue paper (promissory note) against receiving the funds. Issuance can take place either via a recognized dealer who can sell the paper into the money markets, or paper is directly issued to an investor who wishes to buy and hold the paper until maturity. Paper is normally issued at a discount to its face amount and redeemed at par.

The programme
Commercial Paper is subject to a company issuing a programme. This provides details as to the maximum amount that can be borrowed; the lifetime of the programme; registered dealers etc.

Why borrow?
Commercial Paper allows a company to be flexible in its short term funding. Yields are, traditionally, lower than bank borrowings and are not subject to additional bank covenants. A company can benefit quickly from changes in interest rates. It is both a quick and inexpensive way to raise short term working capital.

Why lend?
It allows lenders to get a better yield than available if they placed their funds on deposit with a bank. The paper is negotiable – this means that the paper can be sold on in a secondary market. If a lender suddenly had a funding issue, they could sell the paper to a third party, rather than approaching their bank for funding. As the issuers have credit ratings, it is possible to apply your own criteria with regards to who you will accept as a counterparty.

Lionel Pavey

Cash Management and Treasury Specialist

2018 – the black swan could be China

| 21-12-2017 | Rob Beemster |

Chinese gross domestic product (GDP) is forecasted to end 2017 at around $12 trillion, while the total debt to GDP is about 400%. The economic growth has been impressive as well is its nominal (but also relative) rise of the total debt.

The Chinese economy has grown from the start of its GATT membership in 1995 from around $750 bio to $12trl now. However, total credit grew much more, from around 100% of GDP in 2000 to more than 400% of GDP now.

Credit growth is still surging. This is one reason why the Chinese want their economy to expand at a speed of more than 10%. They need to hold this pattern for some years to come. When the Chinese government is able to put a brake on the growth of credit, GDP is allowed to decrease speed. We see comments from those in power about their wish to slow credit growth. But doing this is like changing the course of a tanker in a canal. In other words.

If Chinese GDP growth would decrease, and credit growth continues to surge, then a big disaster is to happen. The huge mountains of debt have to be financed, when this gets tougher, one can imagine that it will result in a Chinese economic slowdown.

If the credit bubble bursts, it will result in a devaluation of the yuan. This will have effect on the whole world economy. During the Asian crisis in 1997, China was a tiny economy, now it is huge. So not only mature economies like the ones of America and Europe will feel the pain but the surrounding countries and Africa will suffer heavily.

The outcome for the dollar overall, is fairly vague to me. Some economists see a Chinese devaluation as highly deflationary for the global economy and therefor a dollar bullish event. I have got doubts to the last part of that view. China has got an enormous stock of dollar bonds. It would not surprise me if they start selling these during an economic crisis.

If you are a corporation trading with China, 2018 might become an exciting year. As said, my story is about a black swan so most probably this doom story will not happen. And I hope it will not. But: hedging your currency flow is highly recommended. Even when you pay your producer in dollars or your Chinese client pays you in dollars, your risk is the CHINESE YUAN. It is NOT a dollar risk. The same must be said if you transmit your goods with Euro.

Creating a decent yuan hedge will be very important. Again, it is not a dollar or euro risk. When the yuan devaluates, the costs have to be paid somewhere. Don’t let it be you!

Barcelona valuta experts can attend you in creating a decent risk process, so your cash flow will be protected.

Rob Beemster

Owner of Barcelona valuta experts BV

Bitcoin mania: what is it not?

| 20-12-2017 | Carlo de Meijer |

During our stay in South Africa I was reading an article in Die Burger (newspaper for Afrikaners) where a spokesman of Cape town-based PWC gave his ideas on the recent rise of Bitcoin and the future of Blokketting (Afrikaans for Blockchain). This inspired me to write this blog. Since I started writing about blockchain I categorically refused to use the term Bitcoin. But this time it is different. As Bitcoin nears the end of a record-breaking year, it seems an appropriate time to dive into this – by many traditional players said – over-hyped thing. Others describe this fascination for Bitcoins as a “speculative mania”. The broader public has discovered this phenomenon. I will not say it is (already) the end of the rise in Bitcoins or other crypto currencies. But let me be clear: Bitcoin is a lot not!

Bitcoin rate explodes

Since April this year the Bitcoin (but also crypto currencies like Ether and Bitcoin Cash) is showing a continuous rising trend and in the past few months it even exploded to unexpected levels. In one month time the rate of the Bitcoin almost doubled. In the meantime the Bitcoin rate increased further to reach almost 20.000 dollar, before falling back to 16.000 dollar. But now it is back at 19.000 dollar. At the beginning of this year the Bitcoin rate was not even 1000 dollar. The total market capitalisation of Bitcoin is now exceeding that of a company like Boeing and that of New Zeeland’s GDP.

Bitcoins traded on futures market

The recent firm rate rise of the Bitcoin has much to do with the launch of Bitcoin future contracts. Before that Bitcoins could only be sold or bought via internet platforms. Last week the trade of future contracts in Bitcoin started on the Chicago Options Exchange ( CBOE). These futures enable speculators (without having Bitcoins) to buy or sell Bitcoins by betting via the leverage instrument on future increases of the Bitcoin or an eventual decrease thereby hedging against fluctuations. In total 500 contracts were traded on the first trading session. The rate of Bitcoins increased nearly 2.000 dollar to 18.700 dollar. On the American market place Coinbase the Bitcoin even reached 20.000 dollar, after having raised 40% in the two previous days. This indicates that investors do not (yet) expect a crash short term.

In the meantime also the Chicago CME, the world’s largest exchange, started trading Bitcoin futures and the Nasdaq is also in the race to enable the trade in these future contracts. Many professional investors however did not yet enter this market because the difference between bid and offer rates is still much too large. This indicates there is too less liquidity in this market. There is also insufficient clarity of the required margins, trade limits, stress tests and clearing.

What is Bitcoin not?

Read the full article of our expert Carlo de Meijer on Finextra

Carlo de Meijer

Economist and researcher

Credit ratings Healthcare- a Fitch seminar

| 19-12-2017 | Lionel Pavey |

On 29^th November treasuryXL attended a seminar organized by Fitch Ratings in Utrecht. It was a presentation by Fitch that explained the approach they had taken to determine credit ratings for 2 different entities within the Dutch healthcare industry: Stichting Elisabeth-Tweesteden Ziekenhuis in Tilburg – a hospital, and Stichting GGZ Noord-Holland Noord – a mental healthcare institute. There was a fair amount of interest in this seminar as more than 35 people attended, representing banks, financial advisors, healthcare industry and insurance companies.

Whilst both entities are in the healthcare industry there are distinct differences in focus and size: Elisabeth-Tweesteden caters to the surrounding area and had 632,000 hospital visits in 2016 and 4,000 FTEs, GGZ has 10,000 patients and 1,240 FTEs.

What is a credit rating?

A credit rating agency (Fitch) attaches a credit rating to an entity (debtor). A rating is an opinion as to the entity’s ability to meet financial commitments on a timely basis. It measures the ability of the debtor to repay principal and interest of loans on time and in full, together with the probability of default. To be able to come to a conclusion for the rating, the entity needs to supply all relevant information to the rating agency, which can then perform the necessary analysis to judge their creditworthiness.

Applying the criteria

Fitch uses two criteria to rate healthcare entities: the recently updated Government Related Entities Rating Criteria (currently published as an exposure draft) and the Revenue Supported Debt Rating Criteria. The first determines the likelihood of exceptional support in the case of financial difficulties at the Government related entity. The latter determines the Standalone Credit Profile.

An entity is defined as being government related if they are semi-publicly owned/controlled by the government and/or local authority has majority economic or voting control over the entity. Fitch assesses whether a government is likely to support an entity in financial distress to avoid negative socio-political repercussions of a default, or if the entity fulfills an important public policy mission. The Government Related Entity Criteria covers four key factors:

Status and control
Support track record and expectations
Socio-political implications of default
Financial implications of default

In order to determine the Stand-alone credit profile the Revenue Supported Debt Criteria is used that covers revenue defensibility, operating risks and financial profile. Fitch concluded that both entities were able to receive a long-term credit rating of single A.

For investment grading criteria, Fitch applies a highest rating of AAA and a lowest rating of BBB-. A single A rating is a high credit quality. ‘A’ ratings denote expectations of low default risk. The capacity for payment of financial commitments is considered strong. This capacity may, nevertheless, be more vulnerable to adverse business or economic conditions than is the case for higher ratings.

What are the advantages of a credit rating?

Enhances access to capital markets
Facilitates risk pricing for funding
Improves bargaining power with banks and suppliers
Recognition amongst peers and in international capital markets
Rating process provides improved transparency and financial discipline for the rated entity
Annual Rating report may be used as a standalone marketing instrument

What are the implications in the Netherlands?

At present, the Dutch government has majority control in many companies including transport – NS; infrastructure – Prorail, Schiphol; energy – Gasunie, Tennet; and financial services – BNG (Fitch rated AA+, Stable, FMO (Fitch rated AAA/Stable). Furthermore local authorities also have majority control in local companies including transport – GVB, HTM, RET, energy – Eneco, and household waste – AEB, HVC. All the companies require funding, the majority of which is covered with either a national or local government guarantee, or direct participation. Fitch rates all types of government related entities, and with a rating it may be possible for these entities to further their scope for acquiring finance.

An important question that arises is: should national and local government restrict themselves to issuing guarantees and allowing the free market to determine the funding, or should they proactively engage in lending money to companies? Only if more entities were in the possession of a credit rating, could a clear decision be taken. At a time of low interest rates and a shortage of “prime” graded loans, it could possibly be advantageous if the loan market could be opened to more lenders – secure in the knowledge that the loans were guaranteed.

If you are interested in learning more, please contact us via email at [email protected]

Lionel Pavey

Cash Management and Treasury Specialist

Intercompany financing – complying with procedures

| 18-12-2017 | treasuryXL |

Many businesses (not just multinationals) finance the operations of their subsidiaries/affiliates via intercompany loans. During the financial crisis external funding became more difficult to obtain, and more businesses attempted to finance their operations internally. Whilst this can be a good procedure, consideration must be given to the fact that the loans must still be proper loans, compliant with normal market practices. Below we attempt to explain the relevant procedure.

Arm’s length principle

All terms and conditions of the intercompany loan – with special consideration for the interest rate – must be consistent with independent external loan funding. A business can not adopt a more generous approach to funding its subsidiaries than could be obtained externally. The pricing of the loan must reflect the perceived credit risk of the entity that is seeking funding.

Documentation

Just as with external financing, legal documentation needs to be drawn up and signed that clearly shows the terms and conditions of the loan. Standard covenants should be included together with a schedule showing repayment of principal and interest. If a subsidiary is granted an embedded option (early repayment without a penalty) then this must be clearly noted. Whilst the documentation does not have to be as large as that used by banks, it should always contain all relevant clauses, and both parties must adhere to the signed loan agreement. Included within the documentation should be a detailed explanation as to how the price and spread was determined, along with external data proof.

Credit modelling

As most subsidiaries are small and have no independent credit rating, an approach must be taken to attempt to define their creditworthiness. Standard metrics can be used to ascertain an internal rating. Just with a normal external loan, attention should be paid to the ability to repay. Whilst tax authorities may question the integrity of the credit modelling matrix, this can at least be negotiated if a dispute arises. If no matrix is available, then problems can occur.

Pricing

As previously stated, an internal loan should replicate the general conditions of an external loan. That means that when trying to determine the interest rate, full attention should be given to the funding costs of the main company. They need to determine what price they would pay externally to fund the loan and then apply a premium to the subsidiary. Traditionally rates can be fixed or floating with a premium.

Corporate Governance

Internal loans should always be monitored. They should not be a quick substitute for proper due diligence. Problems can easily arise if tax authorities reached the conclusion that the loan is being extended to a loss-making entity that would not receive funding externally.

Alternatives to banks – Is Fintech the answer?

| 14-12-2017 | treasuryXL |

With the steady rise of Fintech within the finance industry some people are already calling for the demise of banks as the historical financial partner of choice for corporates. Certainly, Fintech is showing itself to be very dynamic, offering many new products and solutions, and being a lot swifter than the banks. Banks seem to have grown too big and complacent, are being weighed down by new rules and regulations, are less prominent in the field of funding for corporates, and possibly have lost their focus on what used to be core businesses. But let us examine the relationship between bank and client.

The roles of a bank

Banks are, first and foremost, used so that clients can obtain and use financial services. Opening and maintaining accounts enable money to be received and paid – in this way the day-to-day financial operations of the client can be performed. Furthermore, banks offer additional services that compliment the needs of a client – business credit cards for key staff, sales services such as processing of credit card payments for goods, payroll services, online banking, loans and lines of credit.

What does a client want from a bank?

One of the main priorities is that there is an established history and a good working relationship – that the bank understands the client’s needs. A key indicator of a good relationship would be the ability and the willingness of the bank to provide funding to the client. If the bank wished the client to bank and deposit their money with them, then they should be prepared to extend credit where possible – if it meets the criteria of the bank. Running any business means there will be times when liquidity is scarce and a bank that refuses to extend credit runs the risk of losing the client. Other criteria can include the cost of banking services, support given, quality of delivery, credit rating and the overall efficiency of the services.

Fintech solutions

Fintech can provide genuine alternatives to existing banking services as they can compete with modern products – like giant ocean-going tankers, banks are large and very slow to turn around. Most bank services are still paper intensive and require many authorized signatures. By digitizing services, Fintech can reduce the transaction costs and the time taken to authorize a service. Fintech orientated lending services (like B2B) are entirely online and can be quickly approved. Through lending platforms, the risk can be spread out among many lenders.

Can the banks respond?

Banks have at their disposal very large existing customer bases and a wealth of proprietary data relating to the behaviour and patterns of their clients. This is a large untapped potential that does not need to be found or bought. If banks can utilize this data whilst offering a Fintech type of online service that is quicker and more efficient there is a possibility to fight back. The main option for banks would be to examine the Fintech companies and buy the ones that have the best products to compliment the requirements of the bank’s customers. As Fintech works in a different manner to traditional banking, this would require banks to develop internal incubators to discover new products and services that could be offered to customers. Alternatively, banks could look to design and implement their own solutions, but they appear to be behind the speed and knowledge of Fintech and might never be able to catch up.

One last word of advice

Realistically, Fintech offers attractive alternative solutions to banks. However, the power of the personal relationship should never be underestimated. We build relations slowly and by results – the cheapest offering does not get all the business. Having an account manager at a bank can be highly beneficial for a client – one point of contact, good understanding, a history. When things go wrong, you pick up the phone and call the account manager and he/she sorts out your problems. With Fintech, this could mean phoning numerous different companies to achieve the same result that can be obtained with just one account manager at a bank.

Choice is personal, but preference is normally determined by experience.

Gebrek aan voortgang in Voortgangsrapportage Rentederivaten MKB

| 13-12-2017 | Simon Knappstein |

De voortgangsrapportage van AFM die op 8 december 2017 gepubliceerd werd, bevat vooral oud nieuws. Er is verdere vertraging en zelfs de nieuwe door de banken afgegeven planningen zijn onzeker. Wat dat betreft had de AFM het passender “gebrek-aan-voortgangsrapportage” kunnen noemen. Het beeld wat blijft hangen na het lezen van deze rapportage is dat de AFM er zich bij neerlegt dat het nog wel eens erg lang kan gaan duren voordat dit dossier afgerond is.

De AFM noemt als reden voor de vertraging “Problemen met automatisering en data. De kwaliteit van de historische data van banken is niet in alle gevallen voldoende om efficiënt de compensatie op grond van het UHK te kunnen berekenen en controleren. Verder geldt dat de rentederivatendossiers van klanten zeer verschillend zijn en vaak bijzonder complex en dat heeft gevolgen gehad voor (de praktische uitwerking van) het UHK. Mede door deze knelpunten blijkt de uitvoering van het UHK in de praktijk complexer dan de banken, de externe dossierbeoordelaars en de AFM hadden voorzien. Dit betekent ook dat de door banken afgegeven planningen onzeker zijn.” Verder staat er: “Zo zijn bijvoorbeeld de derivaten- en lening-systemen veelal niet structureel gekoppeld en is een handmatig proces ingezet om de derivaten aan de juiste leningen te koppelen.” Dat die systemen niet gekoppeld zijn mag geen verrassing zijn voor de banken. Dus waarom dat op dit moment als oorzaak genoemd wordt mag eerder als verrassing gekwalificeerd worden.

De vraag die dit oproept is waarom de banken überhaupt hebben geprobeerd de oplossing te automatiseren. Mijn beste gok is dat er in een eerder stadium ingeschat is dat op de bulk van de dossiers slechts alleen stap 3 (de coulance-uitkering) van toepassing zou zijn. Het zal dan een dure misrekening zijn geweest als blijkt dat het leeuwendeel van de dossiers toch een handmatige benadering vereist. In dat geval is er een hoop geld en tijd verloren gegaan wat niet meer goed gemaakt gaat worden.
In de huidige planning, die dus onzeker is, zijn er 2 banken die verwachten eind 2017 alle aanbodbrieven te zullen hebben verstuurd, 1 bank die rekent met medio 2018 en 3 die mikken op eind 2018. Het zou nog inzichtelijker zijn als daarbij ook vermeld stond om hoeveel klanten het dan gaat per bank.
Een volgende rapportage van de AFM wordt in de zomer van 2018 verwacht. Zoals het er nu uitziet zou het al heel mooi zijn als de einddatum dan niet weer vooruitgeschoven wordt.

De AFM zegt ook in de komende periode kritisch toezicht te blijven houden op zowel de banken als de externe dossierbeoordelaars.

Simon Knappstein

Owner of FX Prospect

Lees ook: Uniform herstelkader rentederivaten mkb

Bitcoin – hype or reality?

Forward Rate Agreement (FRA)