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How to improve your Cash Conversion Cycle part II
| 14-09-2016 | Olivier Werlingshoff |
What you see nowadays is that the demand of goods is changing very fast. What was “in” a month ago can already have changed. The problem you will have with a large quantity of goods is that it has to be stored and because of the change in demand it will be a problem to sell them for the price your calculations where based on.
This is what happened with a few fashion retailers. A large quantity of fashion products, enormous storing cost and because the production was made in the far East it wasn’t possible to be flexible when de demand of goods changed.
Retailers who are more successful, are looking for possibilities to be very flexible with their sourcing and look for opportunities to buy smaller quantities, which are made closer to their business. By doing so they are better prepared for a demand change. They will have lower storage cost and can change their products more than two times a year.
What is the role of the treasurer in all this?
In my opinion the treasurer has to overview the total cash conversion cycle and has to show the company (sales- and procurement department) what the financial consequences are of enlarging the cycle. A second role is that the treasurer can compare the cash conversion cycle with their competitors and also discuss this information with colleagues and the CFO.
Olivier Werlingshoff
Owner of WERFIAD
Blockchain: Playing in the sandbox
| 13-09-2016 | Carlo de Meijer |
Regulators enter the stage
This is a very important signal to the regulators that they should take this technology serious and needed to enter the blockchain stage in order the give regulatory clarity. Innovations like blockchain should be primaly industry driven, and “not be unnecessarily impeded by regulatory intervention”, said the WFE. (see also my Blog: “Blockchain and regulation: do not stifle ….”, published 4 April).
Collaboration with the industry will allow regulators to understand the technology, how the future infrastructure will look like and what the impact will be on the financial markets. But above all how they could most effectively perform their regulatory tasks. With the insight and knowledge obtained, regulators will be better placed on the changes necessary to evolve the regulatory environment to not only better regulate these businesses, but also continue to ensure that the legislation does not frustrate this innovation.
Regulatory sandboxes
Regulatory sandboxes have proven to be a useful tool for the wider fintech industry in various jurisdictions. “Promising innovations may be stifled and opportunities missed as firms may be unclear on whether a new product or service complies with legal and regulatory requirements, and consequently may choose not to pursue their new product or service further”.
That is where the ‘regulatory sandbox’ comes in. They have been formed to provide a safe environment for businesses to test their innovative products. These sandbox allow firms to experiment with fintech while providing the appropriate safeguards to contain the consequences of failure for the customers.
New entrants to the financial services market, can use the sandbox to test products, services, business models and delivery without first needing to meet all of the normal regulatory requirements and incurring the considerable costs of putting in place the complex structures and processes to successfully apply for regulatory authorisation.
This should allow appropriate collaboration and exchange of information between industry and regulators.
Regulatory sandboxes: an overview
Since this year these regulatory sandboxes have been extended to distributed ledger technology in a number of countries including UK, Hong Kong, Singapore, Australia and Abu Dhabi. And now also other regulators are thinking about introducing such a testing environment.
The UK regulator FCA launched a regulatory sandbox early May this year. This is a next step for the FCA, the Financial Conduct Authority as part of Project Innovate, which aims to boost competition and growth in financial services. Goal is to help banks and other financial service providers reduce the time it takes to bring innovative ideas to the market.
The FCA’s sandbox will allow business to test disruptive technologies including distributed ledgers in a live environment “without immediately incurring all of the normal regulatory consequences”. The FCA however said that consumer protection will be a significant focus, and will be considering appropriate consumer safeguards.
Application
Fin-techs could apply to the UK’s regulatory sandbox from 9 May till 8 July. The second ‘cohort’ will have an application deadline of mid-January 2017.this year
The FCA uses an inclusive approach to defining potential users. That means anyone from a start-up to a multinational can benefit from the sandbox. For authorised users and suppliers, the FCA has identified three key tools to businesses on a case-by-case basis (individual guidance; waivers; and, no enforcement letters). Unauthorised business will use the sandbox predominantly to facilitate testing without the need for full authorisation from the FCA.
Accessing the FCA sandbox is however not straightforward. A firm must meet a number of key eligibility criteria including: be in an in-scope business; demonstrate a genuine innovation; deliver a consumer benefit; demonstrate a need for the sandbox; and, be ready for testing. It should also be noted that the sandbox will not be available for activities which fall outside of the Financial Services and Markets Act 2000. For example, payment service providers and e-money issuers already potentially benefit from the lighter touch regimes in the PSRs and the Electronic Money Regulations.
HKMA last week announced plans to create a regulatory sandbox, where start-ups and banks can test solutions and express their ideas before applying for authorisation. The sandbox allows banks to conduct tastings and trials of newly developed technology such as blockchain on a pilot basis. Within the sandbox, banks can try out their new fintech products without the need to achieve full compliance with the HKMA’s usual supervisory requirements.
In a related initiative, the HKMA has set up a ‘fintech facilitation office’ with its own dedicated e-mail account to act as a platform for the exchange of ideas between the regulatory body and banks and tech firms. Industry players, such as banks, payment service providers, fintech start-ups, the HKMA, etc. can get together at this facility to brainstorm innovative ideas, try out and evaluate new fintech solutions, conduct proof-of-concept trials, and gain an early understanding of the general applicability of creative solutions for banking and payment services.
Also Australia plans a regulatory sandbox for fin-techs technology innovations including blockchain. The Australian Securities and Investments Commission (ASIC) released a consultation paper on this issue, detailing proposals for a testing ground for innovative robo-advice providers and other similar services. It also highlighted ASIC’s views about some regulatory options already open to fin-techs under the current law.
The sandbox will allow new entrants to test a service for up to 100 retail clients for up to 6 months without holding an AFSL. The service can only relate to advice and “arranging” for dealing, catering primarily to robo-advisers. Product issuers such as payment facility providers and marketplace lenders are excluded, as is advice about general and life insurance. Start-ups will not need to apply to ASIC to be admitted to the sandbox (unlike comparable sandbox arrangements in other jurisdictions), but may need to be vetted by a “sponsor”, such as a hub, co-working space or venture capital firm.
A final regulatory position is expected by December.
Early June, the Monetary Authority of Singapore (MAS) released a consultation paper detailing guidelines for a ‘regulatory sandbox’. With this sandbox approach the MAS hopes to encourage and help firms experiment with innovative solutions to support their development, and bring fintech solutions to the mainstream.
Any interested firm can adopt a sandbox to experiment within a well-defined space and duration; the MAS will provide the appropriate regulatory support and will relax certain legal and regulatory requirements. This sandbox will however have to meet certain evaluation criteria (technologically innovative; benefit consumers and address a significant problem or issue; intention and ability to deploy the solution in Singapore on a larger scale; report to the MAS on the test progress; major foreseeable risks have to be assessed and mitigated; etc.).
In April, the country expressed its desire to become the leading hub in Asia for blockchain-technology and fin-tech start-ups. MAS aims to provide a responsive and forward-looking regulatory approach that will enable promising fin-tech solutions to develop and flourish. The sandbox will help reduce regulatory friction and provide a safer environment for fin-tech experiments.
The Financial Services Regulatory Authority (FSRA), the independent regulatory authority of Abu Dhabi’s newest financial free zone, has released a consultation paper in which it detailed its plans to create a sandbox environment for fin-tech under which start-ups would be allowed to work under a flexible regulatory framework for up to two years. The FSRA is seeking to promote the development of blockchain start-ups as part of a drive to create new efficiencies in the regional financial sector.
The FSRA’s proposal would seek to limit start-ups accepted into the program to those that “promote significant growth, efficiency or competition in the financial sector”. To give some clarity where they are focusing on the paper goes on to cite examples of technologies that fit this description.
“The advent of robo-advisers that offer lower costs, simplicity and real-time portfolio analytics and monitoring; or leveraging on the application of blockchain technology and distributed databases to facilitate price discovery, smart contracts, settlement of financial transactions, etc that may lead to safer [and] better products, and higher productivity and growth.”
Benefits for startups
The benefits of these regulatory sandbox are manifold. Both start-ups, the whole industry and regulators may profit.
There ought to be clear benefits :
Most immediately, the ability of businesses to safely test their products and also be engaged in direct dialogue with the regulator without first having to expend time and money on a speculative application for regulatory authorisation should relieve start-ups of high costs they often cannot afford.
At the same time, the businesses can adapt their offerings to better ensure regulatory compliance.
Once through the process, and assuming the road-testing has produced a successful outcome for the business, the task of attracting investors should be simpler as a major unknown will have been removed.
The regulatory sandbox may help to foster innovation in financial services and that is good for the whole industry and their customers.
With the insight and knowledge obtained from that role, the regulator will be better placed to assess the changes necessary to evolve the regulatory environment to not only better regulate these businesses, but also continue to ensure that the legislation does not frustrate the competition that the FCA wishes to promote.
Global regulatory collaboration
Given its global reach, the level of complexity and the interconnectedness of financial markets, and the level of complexity and the interconnectedness of financial markets, regulatory bodies worldwide should collaborate to ensure that no different regulatory environments are created and regulatory arbitrage is excluded. National and foreign regulators must coordinate to create a common principles-based approach for blockchain oversight A special role should be given to bodies like the IOSCO and the G-20 Financial Stability Board.
Carlo de Meijer
Economist and researcher
Financiële markt in Egypte
| 12-09-2016 | René Schilder |
Wat zijn de kenmerken van deze munt?
De EGP is een valuta die alleen gehandeld kan worden in het land zelf (onshore). De centrale bank regelt deze markt via zogenaamde auctions. Lokale handelaren (exchange companies) en banken die een vergunning hebben, kunnen hieraan deelnemen. Deze exchange companies bedienen alleen klanten die niet met banken handelen. Bij een verzoek om US dollars te kopen en EGP te verkopen moet sinds kort wel worden aangegeven wat de achtergrond van die transactie is.
De officiële koers die gehanteerd wordt is 8,78 per USD. Door de economische crisis is de vraag naar buitenlandse valuta heel groot en zien we op de parallelmarkt (exchange companies) ook een koers van 12.5 per USD. Officieel mag de maximale marge 15 piaster zijn (8.93) volgens de regels van de centrale bank. Vorige maand heeft de overheid harde maatregelen aangenomen om een betere controle te krijgen over die parallelmarkt. Een aantal vergunningen van exchange companies is ingetrokken en er zijn flinke boetes ingesteld voor degenen die zich niet aan de regels van de centrale bank houden.
Banken die buiten Egypte zijn gevestigd, zijn uitgesloten van de onshore markt, zij kunnen alleen maar NDF handelen (offshore). Handel je met een bank die buiten Egypte is gevestigd, dan kun je wel exposure afdekken maar vindt er geen fysieke levering (settlement) plaats. Op de afloopdatum wordt het verschil in koersen tussen de onderliggende contracten verrekend; er zal geen levering van onderliggende valuta’s plaatsvinden.
Gezien de ontwikkelingen op de markt voor valuta in Egypte is het heel verstandig om goed te kijken met wie je zaken doet. Naast het grote aantal regels voor exporteurs om toegang te krijgen tot de markt in Egypte, is het nu dus ook cruciaal om naar de financiële kant te kijken. Welke marktpartijen zijn toegelaten en hoe kan ik mijn valutaconversie regelen? De verwachting is dat de lening van het IMF ook tot een aanpassing zal leiden van het huidige beleid van de centrale bank met betrekking tot de lokale munt (EGP). De marktverwachtingen gaan uit van een flexibele wisselkoers na implementatie van het IMF programma.
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René Schilder – Co Owner 2FX Treasury BV
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