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Showing posts with label international financial centre. Show all posts
Showing posts with label international financial centre. Show all posts

Friday, February 09, 2018

Hollowing out of India's financial markets: Banning trading abroad is not a choice

by Ajay Shah.

For a long time, there has been a realisation that India's policy mistakes on capital controls, financial regulation and taxation will induce a hollowing out of Indian financial markets. Here is an example from May 2012. The two most important products are Nifty and the rupee, and these are increasingly dominated by overseas activity. Non-residents have a clear choice about where they wish to send their order flow and locals also are known to evade capital controls and take their custom to more competitive venues. In this week, there is an amplified concern about these problems e.g. see Mobis Philipose in the Mint and my article in the Business Standard.

These developments are good for the real economy, as superior mechanisms of financial intermediation are displacing the inefficiencies of the onshore financial system. This reduces the cost of doing business for foreign investors.

But at the same time, we in India are losing massive financial service exports as the business is shifting out of India. On the rupee, the estimated loss of revenue for India is around Rs.60,000 crore per year. Similar values are likely to prevail for Nifty.

In many developing countries, the lack of macro/finance policy capabilities gave a comprehensive hollowing out of domestic financial markets. This is the scenario that is being posed before India. 

The correct solution to this problem lies in going to the root cause, and solving our mistakes of financial regulation, capital controls and taxation. This  painstaking work has been analysed in by the Standing Council on the International Competitiveness of the Indian financial sector, which was setup by the Department of Economic Affairs in June 2013 in recognition of this problem.

Men and nations will do the right thing after trying every reasonable alternative. What are these `reasonable' alternatives?

Ban the product


I remember a time when RBI requested the UAE central bank to force DGCX to not trade INR futures. Such a ban is not in the interests of either DGCX or the UAE, and this request was not accepted.

Block the participants


RBI has tried to say to international firms operating in India: do not trade in India-related financial markets overseas. But the jurisdiction of RBI is limited. There are concerns about non-rule-of-law methods of harming firms who do not obey.  RBI and SEBI periodically try to ban PN trading.

These bans are futile as India's regulators have no ability to enforce these bans. In any case, even if the ban is effective, all that will happen is that the business will move from firms that comply with India's grab for extra-territorial jurisdiction to firms that do not care about  India's regulators.

Block the information products


Nifty is made by IISL, which is  an India-domiciled information company.

IISL is not a financial firm and is not exposed  to RBI or SEBI regulation. But perhaps non-rule-of-law techniques of coercion can be applied. Suppose  this succeeds, and IISL does not license Nifty to SGX.

SGX has numerous alternatives. SGX can go to a mom-and-pop index provider who makes a Nifty-like index: an index where 49 of  the 50 stocks are the same as those in Nifty. SGX can shift to the MSCI India index, and MSCI can gently move closer  to the Nifty composition.

If, somehow, SGX is prevented from having an effective exchange-traded Nifty product, the business will just go OTC.

Conclusion


Let's not lose sight of what is going on. There is a trading venue that offers lower costs in investing/trading on Indian assets. We are discussing tools for protectionism through which the cost of participating in the Indian economy is driven up. This is not in India's interests.

Our course of action should lie in solving the Indian policy mistakes of capital controls, financial regulation and taxation.

Monday, September 28, 2015

Is India a hospitable environment for India-related finance

by Anjali Sharma, Kanwalpreet Singh, Rajat Tayal, Rohini Grover, Susan Thomas.

Competition in finance


There is an assumption in India that financial services and products connected with India can only exist through the aegis of financial firms and markets in India. As a consequence, there tends to be little discussion on international competition for India-related finance.

There are, indeed, elements of finance which are not amenable to international competition. For example, setting up bank branches in Nagpur is something which can only take place in Nagpur. However, for a growing class of situations, Indian customers of finance, or non-resident customers of India-related finance, now have choices:

  • Indian firms can choose between raising equity or debt capital within India or abroad.
  • Non-residents have a choice of buying the equity of Indian companies by coming to Indian exchanges (NSE or BSE), or by sending orders go to overseas venues (e.g. London Stock Exchange or the New York Stock Exchange) when Indian companies list abroad.
  • Derivatives settled in cash can trade anywhere. Outside India, exchanges and the OTC market  trade derivatives on the rupee, on Nifty, on Indian interest rates, on India-related credit risk, etc. This gives non-residents a choice about whether orders go to India or to overseas rivals.

These developments have taken place over the last decade, changing the dynamics of what is possible for domestic and foreign investors. This has brought international competition to confront Indian financial institutions and systems.

This competition is good for the Indian economy. When an Indian firm is able to access debt overseas, it overcomes the limitations of the Indian credit market. This is good for India. Similarly, when an Indian firm is able to obtain equity capital overseas, overcoming the problems of the Indian primary market for equity, access to capital for India goes up. This is good for India.

When non-resident investors take exposure in Indian assets, they face financial risks such as the rupee risk, Nifty and single stock price risk. To the extent that they are able to reduce risk, this is good for India. For example, a non-resident investor who has given a dollar-denominated loan to an Indian firm, or a foreign firm who has FDI in India, should be able to reduce their risk by trading in derivatives. These include sovereign Indian credit default swaps (CDS), single stock CDS, rupee derivatives, Nifty derivatives, Indian interest rate derivatives, etc. Whether these are available in domestic markets or in competing markets off-shore, the presence of these markets encourages higher foreign participation in Indian assets.

Hence, the emergence of greater competition against Indian financial producers, which gives reduced prices and higher quality, is good for India.

Expected and actual outcomes


India has a natural edge in global competition for India-related finance. As an example, consider trading in Nifty derivatives. The information is formed in India. The most liquid market is in India, created by the trading of hundreds of thousands of thinkers, and decision makers in India. Once India is the most liquid market, this would suck in all order flow, which would help further increase the liquidity. The most reasonable outcome is one where India owns one hundred percent of the market share. However, the outcome that has come about over the last decade is starkly different.

Precise estimates of turnover are difficult to obtain. But most estimates suggest that it is reasonable to think that roughly half of the global trading in the rupee and in Nifty is now taking place outside India. In 2008, the share of the overseas market was roughly 0%. Since then, this share has gone up to roughly 50%. There is a possibility that the share of the overseas market could further increase in the days to come.

Implications: Loss of revenues in India


An order that comes to the Indian financial system induces export of financial services. A basket of revenues comes with the basic order. This includes securities broking, legal services, research, accounting and travel. All these revenues are lost when the order goes to an off-shore market such as Dubai or Singapore.

We believe that a conservative estimate of the total services revenues associated with each order is approximately 0.25%. As there is a buyer and a seller for each unit of turnover, this implies a total revenue stream associated with turnover of 0.5%. Given the extent of international competition that Indian finance faces, what is the size of the revenue at stake?

If turnover is \$1 billion per day, or \$250 billion per year, this would imply a revenue stream of \$1.25 billion per year. This is Rs.83.75 billion per year. In other words, each \$1 billion per day of overseas activity is a loss of financial services exports revenue for India of Rs.83.75 billion per year.

But how much turnover is taking place outside India? This is hard to estimate and there is no unambiguous answer. We believe the answer lies between \$10 billion to \$50 billion per day. If all this business came to India, it would yield additional financial services export revenues of between Rs.83.75 billion per year to Rs.4.18 trillion per year.

Implications: Loss of domestic market liquidity


If an order flow of between \$10 billion/day and \$50 billion/day were added to domestic financial markets, this would yield a quantum leap in market liquidity and market efficiency. The reduced capabilities of domestic financial markets is the second consequence of the loss of market share. This may have an adverse impact for India that is even greater than the headline grabbing figure for the loss of export revenues.

Tackling the problem of the loss of market share


In June 2013, in recognition of the importance of the problem as one requiring research analysis and policy responses, the Ministry of Finance setup a `Standing Council of International Competitiveness of the Indian Financial Sector'. The Standing Council is chaired by the Secretary of the Department of Economic Affairs. IGIDR FRG has been the technical team for the Standing Council.

On 7 September 2015, the Standing Council released Volume 1 of its Report. There is likely to be a Volume 2 that follows shortly after. The Standing Council is likely to establish a rhythm of work where it is continuously watching the space of international competitiveness of the Indian financial system, and making recommendations with remedial actions to the Ministry of Finance.

The Standing Council has diagnosed four classes of problems which have generated this loss of market share of the onshore market.

  1. Problems in domestic financial regulation. In many situations, there are flaws in domestic financial regulation which are harming the onshore financial system.

  2. Taxation. The global financial system sends orders to financial centres which have `residence-based taxation', where non-residents are not part of the tax base as seen by the local authorities. Apart from the Mauritius treaty, this is not how India works.

  3. Capital controls. The global financial system sends orders to financial centres where the frictions are minimal. India's capital controls actively introduce friction which deters financial services exports.

  4. Unpredictability of policy changes. In a mature market economy, there is a consistent economic policy philosophy shaping policy pathways. In a mature market economy, rule of law procedures are used when changing laws or regulations. These two features create predictability about changes in policy. India suffers from flaws in both respects. As a consequence, market participants are frequently suprised by unexpected changes in policy. This enhanced political/regulatory risk deters investments in building organisational capital. It is safer for a global financial firm to build an INR derivatives business in a place like Singapore or London, rather than committing resources to build that same organisational capital in Bombay.

Looking forward


The ongoing process adopted by the Standing Council is to render policy advice to the Ministry of Finance, through which these four classes of problems can be addressed. This line of thinking constitutes one more impulse to undertake deeper reform of Indian finance.

Sunday, March 15, 2015

Concerns about Finance SEZs

by Anjali Sharma.

For more than a decade, Indian policy makers have aspired for a globally competitive financial sector in India. In 2007, a High Powered Expert Committee headed by Percy Mistry (MIFC) proposed that Mumbai be developed as a full fledged International Financial Center (IFC). At the time, this was `an offensive strategy', in the sense that India was aspiring to export into the world market. In 2013, a Standing Council of Experts on the International Competitiveness of the Indian Financial Sector, was setup to evaluate the cost of doing business in the Indian market, and find ways to improve international competitiveness. This was a `defensive strategy', as there had been a sea change in Indian finance between 2007 and 2013: the collapse of market share in Nifty and the rupee.

A third initiative is now visible: a white paper Policy framework for Finance SEZs (referred to as FSEZs going forward). This was followed by a budget announcement regarding issuance of regulations for GIFT city, a FSEZ, by March, 2015. Finance SEZs are viewed as a tool to expedite the globalisation of Indian finance.

Competing in international finance requires four things: (a) No capital controls; (b) Residence-based taxation; (c) Sound financial law and regulations; (d) Good urban infrastructure. At present, India fails on all four counts. There has been some progress on implementing "c", with the draft Indian Financial Code proposed by the Financial Sector Legislative Reforms Commission (FSLRC) in March 2013. There is little sign of progress on the other three fronts. India's capital controls deter foreign customers of Indian finance, and are not onerous enough to prevent the flight of domestic customers.

The white paper points out to loss of market share in INR and Nifty futures trading. The decline of Indian finance goes beyond just Nifty and the rupee, though these can be visible symbols of the decline of the ecosystem akin to the tiger in the Indian jungle. Indian non-financial firms borrowed Rs.4.5 trillion from foreign shores in 2012-13, almost double their foreign borrowings in 2009-10. Indian firms, and even the Indian government, use offshore rather than domestic commodity derivatives markets to hedge commodity risk. Indian firms are increasingly interested in offshore listings. In India-related CDS, 100% of the market share is overseas.

London, Dubai and Singapore are obtaining a strong share of the increased financial services revenues associated with Indian GDP growth. These cities score over India with stable legal and regulatory frameworks, competitive tax regime and efforts to improve market liquidity and depth. The policy establishment of these countries is free of the reflexive socialism which bedevils economic policy thinking in India.

Are FSEZs the right solution to these problems?


An SEZ follows an enclave approach. Manufacturing units located within the SEZ, are given fiscal, regulatory and trade exemptions so as to enhance exports. The white paper proposes three objectives for an Indian FSEZ: create high value financial sector jobs on Indian soil; create an avenue into financial globalisation (like Hong Kong is to China); and be a laboratory of new ideas for financial policy making for the development of the overall Indian financial system. This is small thinking compared with MIFC, where the aspiration was: to capture a share of the global finance business by delivering a wide variety of services to a wide variety of global participants with minimum friction.
The areas of concern are:

  • Financial reform in India has fared poorly. The implementation of MIFC from 2007 onwards, or the implementation of the Indian Financial Code, from 2013 onwards, has been an uphill struggle. These same difficulties will hamper the enclave approach.
  • There is a chicken-and-egg problem in market liquidity. Bombay has a certain market. It has a full ecosystem of financial firms and their customers. That market can suck in additional orders, if the mistakes of financial regulation, capital controls and taxation are fixed. A Finance SEZ would start from scratch, with no ecosystem. It is hard to build from scratch. The natural jumping off point for obtaining foreign customers is Bombay, not an SEZ.
  • The white paper proposes that a subset of the draft Indian Financial Code will be enacted as the Finance SEZ Act. It will be more complicated than this. The regulatory machinery required in a Finance SEZ differs from that required for India. E.g. there will be no fiat money in a Finance SEZ, hence there will be no requirement for monetary policy. It may make sense to have a single unified regulator in a Finance SEZ. The work required, in going from the Indian Financial Code to the Finance SEZ Act, may be significant.
  • After the Finance SEZ Act is passed, new regulatory institutions will need to be created. It will be important to avoid importing the institutional culture, and pessimism, of existing regulatory agencies. Getting away from the `inspector raj' (as described in the MIFC report) will be quite a challenge. Exporting from an Indian platform can only come about when world class regulatory agencies are found there. This may take many years. If enough new age project management is not put into this, the institutional culture of existing financial agencies might recur, in which case the Finance SEZ will fail.
  • The removal of capital controls in the FSEZ will have an immediate benefit for foreign clients who might shift order flow away from the mainland. This may adversely impact upon liquidity and market efficiency in the mainland. While the FSEZ is intended to compete with London, Dubai and Singapore, the first victim of its success could be Bombay.
  • While the white paper envisages that FSEZs should be India's Hong Kong, this requires today's regulatory agencies to respect and value a Hong Kong. At present, this may not be the case; today's regulatory agencies may work systematically to ensure that FSEZs do not become India's Hong Kong. RBI has regulation-making power under FEMA. This could easily yield draconian restrictions that hamper onshore participants, cutting off the FSEZ from the mainland. If FSEZs on Indian soil are cutoff from India, they cannot succeed.
  • FSEZs require improved working from the Indian tax bureaucracy as much as they require improved working from the Indian financial regulatory bureaucracy.
  • FSEZs will need not just good laws but sound enforcement agencies and sound courts. While important new work is underway in building courts, there is little certainty as yet that this will work out well. Three things are required: a Tribunal to hear appeals against the regulator, a court where disputes between private parties are heard, and an arbitration mechanism. All these are extremely important for the mainland, and have not been done for decades; why will they now be done for FSEZs?

These are onerous challenges. It will take remarkable project management to overcome them, of a kind that we have not seen in Indian finance in the past. Given enormous political capital and implementation capabilities, Finance SEZs in India can work. But would that effort not be better used in combating the low quality of financial law and financial agencies of the mainland?

There is a very scarce resource in Indian economic policy: the time and energy of the persons who actually do reform. Man-hours allocated to Finance SEZs come at the cost of man-hours which could be spent on fixing the mainland. It could get worse. A dangerous scenario that can be envisioned is as follows. Suppose domestic financial reform is stranded in bureaucratic politics. Suppose FSEZs make progress and cannibalise activity away from the mainland. Suppose this creates feedback loops where the intelligent end of the economic policy establishment gets increasingly focused on successful work on FSEZs and despairs of the difficulties of the mainland. It would be very costly for India if, in this fashion, FSEZs damage the future of Indian finance.

How to approach Finance SEZs


As the white paper says, a useful role for Finance SEZs is:

"...to be a laboratory where controlled experiments with new ideas in policy take place, and feedback can then be used by the Ministry of Finance to alter course for the future."

If this vision is emphasised, FSEZ development would complement domestic reform and globalisation, rather than become a substitute. New ideas should be tried out in an FSEZ, and once proven, be immediately implemented in the mainland. Finance in the mainland should not stagnate in the present mode.

If this is done, FSEZs can facilitate the process of achieving the scale of ambition of the MIFC report. There may be useful lessons from China, in the development of the China (Shanghai) Pilot Free, Trade Zone (SPFTZ). The main objective of the SPFTZ is to develop institutional capacity while opening up the Chinese financial system and liberalising capital controls and currency convertibility. For example, the Shanghai-HongKong Stock Connect is an experimental system through which Chinese investors can trade their share holdings with foreign participants in the Hong Kong market.

This initiative involves setting new capital controls for the traded shares, regulations on the trade and settlement of shares, operations of connecting trading, common clearing and settlement across the Hong Kong Stock Exchange and The Shanghai Stock Exchange. The intention is to develop the equity market liquidity for both domestic and global participants. The intention is backed by consistency of implementation: the experiment was tried once before, failed and tried again.

Many markets and products that are not permitted today in the Indian market, due to legal or regulatory constraints, reinforced by low knowledge in financial agencies. Such missing markets and products can be tested and understood in a controlled environment by policy makers and regulators in the FSEZ, before they are introduced into the Indian financial system. Some examples where there is global interest include Indian OTC commodity derivatives, Credit Default Swaps on Indian credit, Rupee denominated foreign currency settled government bonds, and a Eurodollar market for Masala bonds. This will require changing the easy life of existing Indian financial regulators.

While the effort to take back market share on the INR and Nifty futures may yield some results in an FSEZ, these new markets and products have the potential to yield large benefits for India. The FSEZ could also be a testing ground for introducing global standards into market processes such as marginning for financial portfolios spanning equity, commodity, currency and interest assets rather than each one individually as is done in the Indian market today.

In this approach, the stagnation of financial law and agencies on the mainland must be tackled. Policy makers should not make the choice of permitting the mainland to stagnate, while building high quality structures in Finance SEZs.

The way forward


In conclusion, the FSEZ white paper is the latest policy proposal to improve the international competitiveness of India's financial system. It proposes an enclave approach to overcome the failures of implementation which have held India back ever since the MIFC report and the drafting of the Indian Financial Code. However, the enclave approach appears to face as many challenges. Remarkable inputs of State capacity are required to make it work. That human capital, project management and political capital would surely have better uses in fixing Indian finance.

The key insight in salvaging the situation is to not lose sight of the main objective: the mainland. We should build an enclave because it will help us solve the problems of the mainland. Every decision about building the enclave should be made keeping this larger objective in mind.

Wednesday, February 18, 2015

Policy framework for Finance SEZs

There is a lot of interest in India today, on setting up an international financial services centre (IFSC) in an enclave, i.e. a Special Economic Zone. Possibilities include GIFT City near Ahmedabad and a MIFC in Bombay.

A concept note of ours on this subject has been released for public comment by the Ministry of Finance.

Many decades ago, free trade zones like Kandla or SEEPZ, played a role in improving India's engagement with globalisation at a time when there were many restrictions on the current account. There is a possibility that Finance SEZs could play a similar role in improving India's engagement with globalisation.

In 2007, the Percy Mistry Committee on Mumbai as an International Financial Centre (MIFC) had rejected the strategy of building an enclave, and had emphasised the importance of solving the problems of the mainland. From 2007 till 2015, the main work process of financial sector policy has been to fix the mainland. It is only in the context of that larger strategy that it makes sense, today, to additionally explore an enclave strategy. The raw materials available at hand today, owing to that larger strategy, are what make now the enclave strategy feasible. The enclave strategy is now only a small detour and is now advisable.

The Percy Mistry Committee used the acronym `IFC' for `International Financial Centre'. This has become confusing as the acronym also stands for `Indian Financial Code'. The folks at GIFT shifted to the phrase `International Financial Services Centre' (IFSC) which is unambiguous and we should all just switch.

Sunday, January 19, 2014

The biggest exchanges in the world

There are two ways to measure turnover: dollar value and number of trades. By dollar value, advanced economies dominate the rankings. But the number of trades is more important than meets the eye. The number of trades is a measure of what's going on : 1000 trades/s is a lot more than 100 trades/s. And, as far as the IT complexity of an exchange is concerned, number of trades is all that matters. For the folks building and running exchanges, or consuming a feed from an exchange, the IT complexity is determined only by the number of trades.

Here's data from the World Federation of Exchanges for the top 10 exchanges by the number of transactions (measured in millions):

Exchange2012 transactions2012 rank2013 transactions2013 rankChange (%)
NSE India 14071144913.04
NYSE Euronext 1375211883-13.59
NASDAQ OMX 1268311515-9.17
Korea Exchange 1219410326-15.38
Shenzen SE 93651289237.82
Shanghai SE 92661153424.61
BSE India 35673458-3.07
Tokyo 3508599771.39
London 222921110-4.87
TMX Group 2161023599.15

This shows that NSE was #1 in the world in both 2012 and 2013. With 1449 million transactions spread over roughly 250 days of roughly 20,000 seconds each, this is an average intensity of 290 trades per second. There is no other part of Indian finance where a win of this scale has come about. I used to be nervous about the vulnerability of these achievements, but now the danger has subsided. We have a good equity market and it's now unlikely to get messed up. As the Indian Financial Code gradually falls into place, the equity market will become much better.

The listing underlines the well known fact that the electronic limit order book won. There are no market maker exchanges of note any more. This is a serious problem for academic finance as a lot of our intuition is still rooted in the old world of market makers. I see a striking contrast between the importance of market makers in the finance literature and their irrelevance in the real world. The only game in town is the anonymous limit order book market, and academic finance is weak on it.

If you add up the two Chinese exchanges, there is more activity than the two Indian exchanges. In 2012, the two Chinese exchanges added up to 1861 million transactions, which went up sharply (by 31.25%) to 2442 million transactions in 2013. The two Indian exchanges, in contrast, added up to 1762 million transactions in 2012 but grew by only 1.81% to 1793 million transactions in 2013. In 2013, the two Chinese exchanges added up to a trading intensity that was 36% greater than India. If Shenzen and Shanghai keep up their blistering growth, and NSE stays at low growth, then by 2015 or so, NSE will be displaced from the #1 slot. The question mark for China lies in establishing something like the Indian Financial Code and the rule of law.

This ranking implies that NSE is a great lab for doing research. It is now a bigger exchange than the NYSE and NASDAQ by number of transactions. In addition, liquidity in the US is fragmented across numerous trading venues, which makes is much harder to understand what is going on. In contrast, the order flow for spot and derivatives is largely consolidated. If one can marshal data for NSE and BSE there is 100% coverage. There is no OTC trading and no dark pools. In fact, if a stock is not on the stock derivatives list, it is essentially impossible to take a leveraged position on it. This makes India a clean laboratory where the working of an equity market can be understood.

The US is the ideal lab for understanding what happens when liquidity is fragmented; research projects focusing on fragmentation of liquidity should be done using US data.

The heart of the action in modern exchanges is algorithmic trading. I see one world for the really big exchanges where on average there are over 200 trades/s with peaks of over 10,000 trades/s, and another world for all other exchanges. There is one cadre of finance and IT folks, spread all over the world, who are building these hairy systems around the top exchanges. If you setup a conversation on algorithmic trading between the folks in Bombay, New York, Korea and China, they'd have a lot to say to each other. A new world of financial firms is going to emerge, where a common set of finance & IT skills are deployed across the four locations.

A very large number of transactions yields economies of scale. It is not surprising that the charges in India are low by world standards. This is a competitive advantage in the production of transaction services. If India makes the right moves on the policy bottlenecks, a greater fraction of India-related activity will come to India, and India can be a platform for trading global products. The competitive advantage of NSE and the algorithmic firms surrounding NSE comes from a combination of world class transaction intensity but low revenues/trade. This forces exchanges and algorithmic firms in India to be more intelligent.

Wednesday, January 02, 2013

The rise of high-end finance work in India

by Shashank Bansal.

Until recently, outsourcing by global financial firms to India conjured up an image of commoditised low end services outsourcing: call centres, peripheral systems programming, and testing and maintenance. However, in recent years, there is a new rise of more sophisticated work. This reflects supply and demand factors. Global financial firms are keen to cut costs. Capabilities of operations in India -- both captives and independant firms -- have grown for many reasons:

  • The individuals involved in this field in India have gained experience ("learning-by-doing") and credibility.
  • New management practices and improved telecommunications technologies have improved the extent to which teams and projects are handled in a more non-local way.
  • The Indian diaspora has been rising to senior management levels in global firms, and is better able to envision what can be done in India and to obtain execution.

A European investment bank was among the first to experiment by bringing in teams in India into critical projects. This was a landmark change as a lot of inertia about confidentiality was overcome. Other banks followed suit. New management practices, higher pay, greater meritocracy came in, which helped Indian teams make the transition from low-end work where the HR and management techniques used are quite different. Demand for high skill labour has helped induce greater supply, with a lag, as individuals were more inclined to tool up with advanced degrees and high-end knowledge.

Alongside the developments in finance, parallel developments were taking place in the field of offshoring which have driven up skill levels, and helped create a high skill ecosystem in India. Top tier consulting firms launched `centres of excellence' in India, hiring grads from IITs, IIMs, IISc, statisticians, economists. While education in India has huge problems, the raw talent available in India was of good quality, particularly when we focus on individuals who were able to read on their own and reinvent themselves ("never let your school come in the way of your education"). This process has been helped by globally recognised certification exams such as the FRM and the PRM.

IT firms have have been evolving from core development and maintenance to an entire gamut of IT strategy and consulting for financial firms. Many smaller KPO firms with specialised domain knowledge in finance have emerged, who cater to smaller hedge funds, trading houses, not just outsourcing increasingly complex pieces of work, but also advising them on the entire outsourcing strategy. All this has helped create a pool of high skill labour which is moving between multiple employers in India and able to build knowledge through diverse kinds of experience.

The most impressive development of recent years has been the growth of offshore trading units of global brokerages and trading houses, where people sitting in India take independent trading decisions in international financial markets based on their own skills and judgement. In some ways, this is the highest level of transfer of decision functions to India, albeit at relatively low monetary stakes.

In this fashion, within a period of 15 years, India had graduated from doing repetitive low value tasks to Knowledge Process Outsourcing (KPO) for the global financial system. While these activities are primarily in Bombay, they are also taking place in Gurgaon and Bangalore. The number of high-end finance workers in Bombay has never been greater than it is today. It is estimated that there are now 50 individuals working in Bombay doing work for global financial firms who have Ph.D. degrees in quantitative fields. This is starting to become a big enough number for them to talk with each other and get network effects going. From an employer's point of view, it is now possible to shop in the labour market in Bombay and recruit a 10-man team all with Ph.D. degrees so as to get a new group going. This is a sea change when compared with conditions just a few years ago.

To appreciate this change a little further, it was interesting to take a look at some of the capabilities of finance focussed KPOs, divided mainly into 4 broad categories, catering to Sales and Trading, Middle office and Back office:

  1. Quantitative Research and Analytics Support:
    1. Equity and FICC Analytics: Model Validation, Price Verification jointly with clients: these are pretty quant heavy functions which require in-depth understanding of products.
    2. Technical and Fundamental Analytics.
    3. Index and Portfolio Analytics: Index maintenance, design, construction, operations and after sales, Portfolio tracking, decomposition and correlation analysis, performance measurement and attribution support.
    4. Derivatives and Risk Analytics: Measurement of derivatives Greeks, Value at Risk, Tolerance checks.
  2. Research:
    1. Equity and FICC Research: Company research, Credit Research, Economics research etc. to augment senior analysts in money centres.
    2. Trade idea generation and back testing: Sales pitches for clients and internal trading desks.
    3. Country, Sector, Company profiling, trends, news and projections: Pitch book generation and support.
    4. 24x7 weather patterns tracking for global energy trading outfits
    5. Overnight trade and market tracking to feed in summary reports, Market Dashboards, news letters, morning meetings and agendas
    6. Market Research: Pre-entry market research and positioning survey for bank's clients.
  3. Data Analysis and Modelling:
    1. Data sourcing from multiple heterogeneous sources, refining and maintenance: Static data, Live and Historical market data maintenance. Data research and statistical studies feeding into trading strategies.
    2. Data Mining solutions.
    3. Data modelling, smoothing: Providing data solutions for Algo trading desks.
  4. Operations and Control
    1. Derivatives trade processing and documentation: Trade review of structured trades and complex documentation. End to end life cycle management of trades e.g., matching, broker confirmations and fee calculations.
    2. P&L and balance sheet control: Generation and reporting of P&L for vanilla products. Some banks have started moving exotics P&L functions to India. This is quite a significant milestone as such activities require high degree of confidentiality and direct user (e.g., traders) interaction who have zero tolerance for mistakes.
    3. Risk Stress testing, VaR back testing, Risk reporting to senior management.
    4. Auditing: external auditing of valuation marks of trading desks and control processes around it.
    5. It should be noted here that since the funding crisis of 2008, these jobs have become quite complex as most banks have built more sophistication into their analytics. For example, most yield curves would now have multiple basis spreads (like tenor basis, xccy basis) and not just rates desks but even credit and equities desk have been using such advanced discounting curves.)

What's next

The biggest push probably has been in quantitative middle-office functions with an ever increasing emphasis on valuations and counterparty risk management. Given the way markets have adopted collateral based pricing of derivatives, and the regulatory push on managing counterparty default risk, some captives have started building quantitative teams who will develop and manage CVA, DVA, etc. processes for all trading desks.

The new regulatory climate (Dodd Frank, Basel III etc) has lead to a substantial increase in costs due to additional checks and reporting requirements e.g., centrally cleared OTC trades, real time trade reporting to regulators, exhaustive risk reporting - all of which can are leading to fresh volumes of activity in offshoring.

All high quality banks have a team of techno-quants who work closely with the sales/trading desk, risk managers etc, on their day to day needs as well as on strategic projects. It is now feasible to move such high impact roles to India. It would be possible to have "extended front office teams" where dedicated staff support traders in money centres, doing real time risk analysis and client profiling, while the trade is being dealt overseas.

For a back-of-envelope calculation, if we think of internal billing rates of $100,000 per person per year, and if there are 10,000 persons at this average price, then this is services export of $1 billion a year, which is a sizeable amount. It appears that the early beach-head is in place, and this area will grow dramatically now.

This blog post reflects my experience, which is in investment banking and money management. A similar escalation of complexity of work in India is taking place in retail banking, insurance, etc., reflecting similar compulsions and opportunities.

Constraints

There is a certain tension between the push towards offshoring to India, and the activities that regulators consider `key in-house activities' that cannot be outsourced.

There are serious constraints with education in India. The top institutions are producing some quantitative skills (e.g. fluency with matrix algebra, fluency in numerical computation). On one hand, there are weaknesses of broad intellectualisation that shapes cognition, creativity and malleability. On the other hand, there is essentially nothing in place by way of a finance education in India. A small amount of high-end finance research is taking place (example) but for the rest, there isn't much capacity in the existing academic campuses. New approaches to learning and training need to be devised through which high quality individuals, with strong quantitative skills, can be converted into full fledged participation in high-end global finance work. A mix of public and private initiatives are required in order to jump to the next level.

There are strong synergies between the sophistication of the Indian financial system and the work that is done for global financial firms. There is a two-way feedback loop here: Better domestic capabilities will help do sophisticated offshore work, and the brainpower built for offshore work will strengthen domestic capabilities. The best example of this is found in the equity derivatives market, where India has a world-class market. The individuals with a domestic background here are ready for offshore jobs in fields like algorithmic trading, and individuals with capabilities built in offshore work are useful in the domestic setting. This is where India can set itself apart from Malaysia and the Philippines. To the extent that Indian financial reform makes progress, this will fuel the rise of high-end outsourcing to India.

Acknowledgements

I am grateful to Anand Pai, Paul Alapat and Gangadhar Darbha for useful discussions.

Friday, December 21, 2012

Next big development in the global market for the rupee

The next interesting development after ICE trading of rupee futures: CME will launch rupee futures soon also. See CME follows ICE into rupee futures by Tom Osborn on Financial News.

ICE and CME are the world's top exchanges and they are serious rivals for the global rupee market. These recent developments add up to a substantial change in the outlook for the rupee as an internationally traded currency. The rupee will become more prominent as a globally traded and liquid market. And, ICE and CME are likely to do well, thus accelerating the decline of the onshore market.

Thursday, December 06, 2012

Thursday, November 29, 2012

Rupee and Real futures at ICE

Intercontinental Exchange has announced cash-settled futures on the Indian Rupee and the Brazilian Real [press release] [Saabira Chaudhuri in the Wall Street Journal]. With this, ICE is the first serious global exchange to start trading in the rupee.

Vimal Balasubramaniam and I have pointed out that the global market for the Indian rupee is adding up to some fairly big numbers. I recently noticed that in 2010, even though China is a much bigger economy than India, rupee trading was 0.9 per cent of global currency trading while RMB trading was at 0.7 per cent. Similarly, it appears that the INR NDF is bigger than the RMB NDF, even though China is a much bigger economy. Something is going right in the growth of the rupee as a big currency by world standards. Rupee trading at ICE would strengthen that process.

The ICE announcement also connects to the issues of global competition for Indian underlyings. The two biggest financial markets in India are Nifty and the rupee. So far, NSE faced serious competition with Nifty futures trading at SGX and CME, but there was no significant rival with the rupee. With the arrival of ICE, the competitive dynamics for the rupee changes, which is a welcome development. NSE now faces genuinely difficult competition from three first-tier rivals: CME, ICE, SGX. At the same time, the outlook for rupee trading in India is hobbled by an array of constraints:

  • ICE can pitch for business from non-residents, while NSE cannot, since foreign participation in currency futures is banned. We seem to think that OTC trading of currency forwards requires encouragement from industrial policy operated by RBI.
  • ICE is able to start contracts any time it likes on (say) the Brazilian Real while NSE is forbidden from starting any new contracts.
  • India has mistakes on tax treatment, lacking residence based taxation, while the world has all this well sorted out.
  • India has an array of other policy and regulatory mistakes that hobble local players. The ICE transaction charge is zero. I wonder if litigation will now start at CCI to try to block this.
A process is afoot, at present, through which the Indian financial system is being hollowed out. If this process runs unchecked, RBI and SEBI will be left lording over nothing. There is a need to reverse this  policy framework of reverse protectionism.

Sunday, July 22, 2012

The two escape routes away from domestic formal-sector finance

Three problems afflict formal-sector finance in India today: capital controls, taxation, and financial policy. The most important financial products traded in the formal sector in India -- the stock market index (Nifty) and the exchange rate (the rupee) -- are under enormous pressure as a consequence.

One dimension, that has been emphasised in the existing discussions, is the flight to offshore markets. There is another: the trade goes off into underground markets. These come in two kinds. In the field of commodity futures, it appears that important price discovery and liquidity is found on unregulated markets. As an example, in Gujarat, the town of Bhabhar is famous for having a huge oilseeds and edible oil futures market. Babhar is a true market: it has liquidity and discovers the price.

A second mechanism is a class of market mechanisms which leech off the price discovery of a main market, do not really offer liquidity of their own, and let people achieve trades. In Indian parlance, these are called the `dabba market'. Here is how it works:

  1. The main market where Nifty trades is NSE. But if a customer goes there, he has to suffer the full burden of the securities transaction tax, the charge by the NSE member firm, etc.
  2. The dabba operator (`DO') sets himself up in business offering trading services in Nifty futures.
  3. Many individuals place buy/sell trades with him. These are meticulously tracked; their profits and losses are calculated and money is exchanged w.r.t. each customer.
  4. Through this, the DO is effectively accepting orders -- like an exchange -- and doing daily mark-to-market w.r.t. the customers.
  5. On average, the sum total of trades by many customers adds up to zero. So the net exposure of the DO is roughly 0. If an exposure builds up, he might choose to lay off his risk on NSE.
  6. The DO charges much less than the NSE member since he does not pay STT and his establishment costs are lower.
  7. He is a big man in the community. He can break your bones. So you will not default on him. So he charges less margin. This is another attraction - but it means that some fraction of customers endup entangling with the underworld.
  8. The DO will work with black money (i.e. cash). This is another attraction, compared with the all-cheques-and-PAN-numbers world of NSE. The short-term capital gains tax (or worse, ordinary business income treatment of winnings) is then avoided.
Bhavesh Shah, reporting from Ahmedabad in DNA, tells us that dabba trading has gotten bigger of late. He also points out that the DOs have been doing some system-building to make their business more efficient. Dabba trading is one response of economic agents to the problems of taxation and improper financial policy. It also happens to a varying degree with trading in India of international underlyings (e.g. crude oil or gold), where capital controls prevent locals from accessing the world market.

In summary, when India makes mistakes on three things -- capital controls, taxation and financial policy -- there are two kinds of responses on the part of onshore and offshore users of India-related financial markets. On one hand, users go off to overseas venues. On the other hand, users shift towards informality. In the limit, large scale mistakes on the three fronts will drive the bulk of customers away from the formal sector onshore market venues. RBI, the tax authorities and SEBI will then lord over an insignificant part of the market.

Sunday, July 01, 2012

A tale of two economies and two currencies

by Percy S. Mistry, in the Financial Express.

A fortnight's visit to China in April, to understand better the progress it has made with public and corporate governance, was startling in its revelations. Having been to China years earlier, to advise the State Commission on Reform of the Economic System (Ti-Gai-Wei) in 1988-1994, it was amazing to realise in retrospect that, over the last two decades, much of the advice given then, had actually been taken and applied.

That was in sharp contrast to experience in India. The advice provided there -- e.g. through the Mistry Report and innumerable interactions with MoF and RBI over the years - was applauded by the private financial system for which it was intended (less so by public financial institutions which need to be privatised). But such advice was taken and implemented by MoF and RBI only grudgingly and at the margins of insignificance in terms of impact.

What was most strikingly apparent during the visit was the resolution and purposefulness with which China and its institutions are governed. That applies to public institutions and agencies at various levels of central, provincial and municipal governance, state-owned enterprises (SOEs), and the rapidly growing number of private Chinese companies; whether domestically owned or joint ventures with multinationals involving both public and private partners. It was no surprise to confirm that China is much better governed at central, state and municipal levels than India; where public governance is deteriorating by the day. But, that Chinese companies now seem better and more responsibly governed than their Indian counterparts came as a rude shock!

The impression of corporate and public governance in China now being well ahead of India (and a lot of what now mistakenly passes for the 'developed world' as well) emerges despite the occurrence of the Bo Xi Lai/Gu Kai Lai affairs that were unfolding at the time. One almost got the sense of careful orchestration and stage management of these 'affairs' by two competing factions for influence within the ruling Politburo and its supporting Standing Committee as the future leadership/management team that takes over in October was being put in place.

To be sure the case is invariably made that such resolution and purpose is usually (or can only be) exemplified by a totalitarian state like China, rather than a democratic state like India. After all, China is unhindered by the cumbersome processes of democracy. It has yet to provide many of the personal and human freedoms/rights provided in much of the world and in large emerging countries like India. Yet, despite the correctness of this perception, one cannot help but feel that blaming the Opposition, parliamentary process and democracy, as GoI invariably does routinely (to explain its incompetence and loss of nerve for losing the plot on macroeconomic management), stretches the excuse a bit too far.

One wondered after the China visit whether India is the world's largest democracy as it always claims, or whether it is the world's largest abuse of democracy. Abuse: because of the make-up and mind-set of its parliamentarians and political class, and because of the characteristics of the poor and destitute electorate that engenders, propagates and perpetuates at each election such a dysfunctional polity with such destructively counterproductive tendencies, habits and behaviors.

China still has to cross the Rubicon of political democratisation and full extension of human rights taken for granted elsewhere. Until it does so, the world is right to be sceptical (if not perturbed) about its inexorable ascendancy into a position of global hegemonic power. But one gets the sense (almost with certainty) that China -- in its own imitable way and in its own time unhurried and unbowed by external pressures -- will develop a 'democratic' or 'quasi-democratic' model that suits its purpose and characteristics.

Learning hard lessons from Russia, where it is clear in retrospect that economic and political liberalisation were carried out in the wrong sequence and in the wrong manner, China will do so without destabilising itself in the way that Russia did. The Chinese leadership has no desire to repeat what happened in Russia - i.e. the emergence, after a period of total confusion during the Yeltsin era, of a KGB-controlled/inspired kleptocracy under Putin's leadership. That kleptocracy has now replaced the econo-political apparatus (and power) of the former communist state. Russia's situation has evolved in a manner that, if one thinks about carefully, has some disturbing indirect parallels with 'liberalization' in the Indian case.

The Indian public-private kleptocracy (a peculiarly Indian type of PPP) that has emerged in India post-1991 reforms, has not involved the membership of a repressive state intelligence apparatus, as in Russia. India has never had an intelligence apparatus worthy of the name or of any note. The only threat it poses (hopefully but not assuredly) is to Pakistan. That too is an ineffectual, minuscule threat given how poorly Indian intelligence (if that is not an oxymoron) is organised, funded and conducted. But, the Indian kleptocracy that has emerged after 1991 has certainly involved core relationships between established Indian political dynasties and large corporate houses (especially newer ones) that emerged after the Emergency.

Those corrosive relationships have become deep-rooted and taken hold in various avatars at central and state levels. At each of these levels they involve different business houses and different political dynasties; some of which have become organised medium-scale businesses in their own right, specialising in unique forms of rent extraction.

Taken together, they have resulted in Indian corruption becoming an organised mega-industry post-1972, from the localised handloom cottage industry that it was in the 1952-72 era. That mega-industry has its own codes, institutions, intermediaries, processes and lexicon (peti and khokha). It has resulted in a unique form of crony capitalism, favouring those business houses in India that originated mahacorruption and have since become its principal beneficiaries.

Indeed, such corruption has become embedded in the Indian economic system. It is so essential to the 'functioning' of its post-1991 quasi-market, improperly liberalised economy -- where the grant of licenses and inexplicable asymmetries in regulation play such a key role in introducing anti-market distortions and subsequent market failures -- that one now sees the visible damage being done to the functioning of the economy as ham-handed attempts are made to root it out.

One could make a good case that, in part, the slowing down of the Indian economy, and the rapid decline in corporate investment following the 2G-scam, is the result not only of macro-economic mismanagement and poor judgement by the FM/MoF, but also because corruption can no longer be relied upon by corporate houses to get things done in the way they once were. If the people (politicians, bureaucrats, regulators and police) a corporate house 'buys' -- through corruption in the political and bureaucratic systems, to retain its strategic and tactical advantages over its competitors in its main markets - can no longer be relied upon to deliver the goods, then what is the point of taking risks that simply cannot be managed?

Corruption is not only an Indian phenomenon. It occurs in China; possibly to a greater extent. Its totalitarian regime has not expunged it, although it pretends to have. Petty corruption at lower levels of officialdom is neither as pervasive nor as predatory as it is in India. But at the upper reaches it certainly seems omnipresent. Indeed most Chinese (in the public and private sectors) suspect that members of the Politburo and Standing Committee are engaged in concealed corruption on a scale that might make Indian corruption seem amateurish.

Corruption in China arises (and is fuelled) from pervasive state ownership of large public manufacturing, exporting, service and transport enterprises, of public construction companies that have benefitted from massive public spending on infrastructure (of which 10-15% of all contracts is allegedly accounted for by kick-backs), from public ownership of the banking system, and over $3 trillion in reserves that are increasing by 10% annually. On that amount of reserves, over $1-2 billion a day can easily be salted away via accounting errors and omissions and through improperly accounted-for effects of supposed daily exchange rate fluctuations or mark-to-market losses on sovereign bond purchases.

Rumored public estimates of proceeds transferred abroad by the top leadership in China invariably range from $100-150 billion over the last five years. If one extrapolates from that figure the proceeds of corruption at lower levels of governance (especially at municipal levels where the granting of land leases is the major source of leakage), figures of around $1 trillion over the last 5-10 years do not appear as outlandish as they might.

Certainly the ostentatious wealth displayed by Chinese political and business families abroad lends substance and credence to these estimates, in the same way that the lavish life-styles and expenditures of expatriate Russians in London give credence to its own kleptocratic state.

Yet, despite the functioning of both the Chinese and Indian economies being profoundly affected by corruption (of different sorts) the growth and resilience of the Chinese economy does not appear to have been as adversely affected by it as has been the case in India. Instead, quite the reverse! The Chinese economy is displaying extraordinary resilience in the face of externally generated headwinds that are slowing down its dynamic export machine. All the talk about hard and soft landings for the Chinese economy seem moot after the April visit. China has managed to orchestrate a reasonably soft landing with growth slowing to < 8% levels with China switching gradually to a domestic-consumption led rather than export-led growth strategy.

But it takes time for a super-tanker the size of China with its $6-7 trillion economy to change course and reverse gears. The single most effective instrument to induce and accelerate such a change - i.e. opening its capital account and floating its currency to result in more rapid market-driven appreciation of the Chinese Yuan (CNY) or Renminbi - has been eschewed as a policy tool to bring about more rapid switching.

Over the last two years the strength and resilience of the Chinese economy, in the face of the worst global economic and financial crises the world has experienced in nearly a century, have been remarkable, as reflected in its continued build-up of reserves. These now amount to over $3.2 trillion -- despite the impact of the post-Lehman financial crash of 2008 and the rapid deterioration in the economic circumstances of its two largest export markets: i.e. the US and EU. This massive build-up of surplus capital, which it seems unable to use for its own needs, has led China to open its currency market through administrative measures.

The April visit suggested that China is deeply concerned about using exchange rate adjustment as a policy tool, fearing that doing so would destabilise its labour and wage markets. After all the key Chinese imperative to ensure its success as an exporting power has been to manage (manipulate?) its exchange and wage rates so as to import jobs from, and export goods to, the rest of the world for as long as the rest of the world permitted China to get away with it.

And, so far, the rest of the world has done that. In the process, China has built up gargantuan reserves which are likely to grow at 10-20% annually even if its trade account comes into balance. Such unprecedented, large global reserves and the way in which they are managed -- perversely reflecting the limitations and dysfunctionality of China's state-owned financial system -- now pose an economic and political threat to the rest of the world. A continued build up reserves at the same rate as before would be intolerable.

Consequently, China has arrived at the stage where it has no option but to liberalise its currency market and export capital a little more easily in one way or another. It is choosing to do so through administrative measures such as bilateral CNY swaps rather than via traditional open market measures. These measures lead to a number of interesting interim possibilities before full and traditional capital and currency market liberalisation is undertaken.

Until this month, China had focused CNY swaps in local currencies of major emerging market trading partners, and not with developed market partners such as the US and EU. But, a couple of weeks ago, China announced that it would do CNY:JPY swaps with Japan, a developed and large trading partner. Partial capital account liberalisation is also being attempted through gradual opening of the CNY (dim-sum) bond-market in Hong Kong. That market has taken off faster than the Chinese authorities seem comfortable with.

What are the implications of the latest Chinese measure to introduce CNY:JPY swaps? They are not likely to be significant immediately as few internationally traded contracts are denominated in either CNY or JPY.The same arrangement for CNY:USD or CNY:EUR would have been more globally significant and led to CNY internationalisation more quickly.

However, the question raises some interesting possibilities where China-Japan, China-Asean and Japan-Asean trade is concerned. Triangulation on trade and trade-related long term investment among these three large trading blocs/players (more if one includes Korea and Taiwan) holds out interesting possibilities for the growth of Asian markets in regional currency trades and derivative hedges.

Also, Japanese multinationals are major investors in Chinese export production, which is linked to their own export production for global markets, in innumerable and intricate ways. If the CNY:JPY arrangements stabilise the influence of currency fluctuations on such bilateral and pass-through trade then the CNY will benefit and internationalise faster.

How rapidly the CNY becomes an international currency like the USD depends initially on how the Asian/Asean markets perceive movements in the CNY and JPY in the short, medium and long term. As a long-term hold, the CNY seems more attractive than the JPY. The Japanese yen is intrinsically a weak currency issued by a very heavily indebted country that is dying slowly demographically, and is a waning global economic power in relative terms. The opposite is the case for China and the CNY. But long-term currency holds are for investors not traders. And China is denying the world full market access to probably the most significant currency numeraire for long-term investment over the next 30 years.

In the short and medium term, it is difficult to predict what will happen to the value of the CNY relative to other currencies (especially USD, EUR and JPY) because of administrative intervention. If currency markets were left alone the CNY would appreciate significantly against all three; despite the arguments being made that the CNY has found its real effective equilibrium rate and does not need appreciation.

Anyone who believes that does not understand currency markets. Right now the JPY is an international currency that seems to be overvalued, taking Japan's underlying fundamentals and economic prospects into account. Yet it is widely held in global central bank reserves though used to a more limited extent than should be the case for Japan's trade contracts with its various trading partners which, unfortunately, are still denominated more in USD than in JPY.

The Chinese authorities could of course internationalise the CNY faster and more efficiently by opening up their capital markets in a phased fashion; making the CNY at first (up to 2016) a partially and then (2017 and beyond) a fully convertible currency. They are doing it instead in a clumsy, administratively burdensome fashion in the belief that going that route will result in more 'control' over the pace of internationalization.

A key concern is that this administrative approach (akin to the route that Indian bureaucrats invariably prefer in the bizarre belief that their control results in better outcomes, despite evidence to the contrary) will lead to a series of significant anomalies. They will create distortions of the kind that usually arise with administrative intervention and an aversion to letting markets do what they do best -- i.e. price discovery. Those anomalies and distortions could damage the world at a time when the global economy is still quite fragile.

Yet the CNY is heading towards becoming a global currency, perhaps second in importance to the USD over the next 20 years and even more important than the USD thereafter. That process is as inexorable as it is inevitable. Indeed that outcome has been delayed too long. For the world's second largest economy, and its second largest trading economy, to continue having a closed capital account, and a non-convertible currency with a fiat-determined price, is an intolerable eccentricity that has damaged the world and provides an unfair structural advantage to China. Oddly, China has been permitted by the world trading community to play by its own rules to its own advantage (and to the detriment of the rest of the world) for too long by asserting the right to control the most significant price affecting its trade with the rest of the world i.e. the price of its own currency.

In an open economy global trading model, world trading patterns, and consequently global investment patterns, as well as global production location and market share, are all supposed to be determined/equilibrated (i.e. with trade, current and capital account surpluses and deficits -- or imbalances -- being sorted out) by markets and not by administrative interventions; with market forces being left to adjust all prices, including currency prices, that affect global trade.

When China respects the notion that market prices should determine the prices of all inputs and outputs that make up the cost of its production, but then asserts the right to control a key price (i.e. the price of its currency), which in turn affects the price of imports from China by other countries, it violates a fundamental precept of the open economy global trading model. The sustained violation of that principle for two decades has in large part been responsible for bringing the global economy to its knees, while allowing China to accumulate extreme reserve surpluses that now pose a fundamental political and economic threat to the rest of the world.

In the post-Bretton Woods world, China is the most egregiously anomalous case of a country (misusing the developing country argument) becoming as significant as it is in the world economy without being obliged to open its capital account and make its currency convertible. All the other rising economies in the 1960s and 1970s (Germany, Japan and several smaller European economies), 1980s and 1990s (Korea, Singapore, Taiwan, some Asean and most Latin American economies) made their currencies convertible and opened their capital accounts.

They did not suffer any of the kind of damage that China claims it would suffer if it did the same. Essentially what China seems to be asserting through its currency management policy is the divine, inalienable right to import jobs from, and export manufactures to, the rest of the world indefinitely by manipulating the price of its currency. That cannot be permitted to continue given the devastating impact such a policy has had on the rest of the world. The CNY must be internationalised sooner rather than later in a market-oriented manner.

If that is so for the CNY then what is the future of the INR? As the next largest emerging global economy after China shouldn't the INR follow a similar trajectory? Until last year many astute commentators envisaged the INR taking its own place in the world, following the CNY as an increasingly significant trading currency. They thought at first that the INR would become a littoral/regional (2015-2020) trading currency and later (2020 onwards) a globally significant trading and reserve currency.

But the dreadful mess that the UPA-2 coalition and central government have made of the Indian economy over the last 24 months, and the shattering of confidence in India on the part of both domestic and foreign investors, has been an object lesson in confirming that India seems incapable of coping with success for any length of time. India seems instead to be more inured at coping with prolonged failure. It seems to know how to cope with that better attitudinally.

Therefore the INR is unlikely to emulate the CNY as a global trading or reserve currency for quite some time yet. Instead the INR is now seen as a temporally if not structurally weak currency that can barely hold its own value, leave alone become a serious trading or reserve currency in the foreseeable future.

Contrary to assertions by the FM, PM, RBI and UPA-2 leaders, none of the wounds that India is suffering from, and have inflicted on the INR, have much to do with negative global influences or Europe. At most those factors may have had only a marginal impact on growth and inward investment. The damage done has been mostly self-inflicted.

The really devastating impact of MoF/FM misjudgement and malfeasance has been on overall investment and in not relieving mounting supply-side constraints sooner. The FM in particular has played a leading role in convincing investors in India and around the world that India is no longer worth investing in. That impression has been reinforced by aggressive but injudicious posturing by the FM/MoF, goaded by their tax hawks, about the 'losses' India suffers from its DTAs with supposed tax-havens (such as Mauritius) and its contradictory if not absurd positions on applying GAAR retrospectively; and attracting the derision of the world at large.

Immense damage has been caused by this failure of judgement, obtuseness and obstinacy in the vindictive vendetta that has been conducted against Vodafone in particular, and foreign firms in general, on the capital gains tax issue. No mention is made at all about the tax gains (direct and indirect) as well as employment gains that have been derived from inward FDI and about the losses that would be incurred if such FDI flows ceased - as they now seem to be doing.

If GoI/MoF were so concerned about revenue losses to the exchequer, from FDI that escapes capital gains taxation, the PM and FM would have done better to look more closely at their neighbours in parliament and state legislatures. They could apply more vigorously and impartially laws on assets disproportionate to income. That approach would provide them with a triple-whammy. It would deal holistically with the phenomena of black money, corruption and tax evasion/avoidance, all at the same time. The revenue raising possibilities from that source would make Vodafone look trivial by comparison.

Had GoI/MoF done that they would have drawn more effective public attention to the generation of black money which official India is exerting every sinew to evade doing in the most clumsy fashion, knowing that to take serious action on that issue would be to indict virtually the entire political class in the country and bring in to the black money net most corporate leaders as well.

The egregious and severely damaging misjudgements on the tax issue, and the mismanagement of the Indian macro- economy since the change of leadership of the Finance Ministry in 2009, have introduced the kind of uncertainty into investment decisions that now make banana-republics and places like Rwanda and Congo seem almost sagacious in comparison with India.

How could this have happened? The answers seem obvious in retrospect. The political and bureaucratic leadership of the post-2009 Finance Ministry appears to have been childishly naive and clueless about how finance or economics actually work. All of India, and corporate sycophants dependent on the state-owned banking system for liquidity and long-term loan largesse, have been worshipping a false god -- as we seem to do relentlessly. Look at how we worship supposed corporate titans with feet of clay. It would be funny if it were not so tragic that one needs to screw up a country before one becomes an eligible candidate for that country's Presidency!!

Compounding the problem of gross malfeasance in short-selling India as an attractive long-term investment destination, GoI's top leadership appears to have as little clue about what leadership or good governance is all about. The other big beasts in the Cabinet (i.e. the Ministers of Home, Defence and External Affairs) all seem to be in the wrong jobs that play to their weaknesses rather than their strengths. As a consequence, GoI and India have lost all credibility at home and abroad. The impression they convey is of gross incompetence and surprising insouciance.

Being clueless seems widespread and endemic. It goes beyond characterising what now seems to be a sorry excuse for a crippled government that needs to be put out of its misery. At the top political leadership level in the UPA, Madam Sonia and Master Rahul Gandhi also appear to have no clue about anything, if the results of recent state elections are to be judged dispassionately.

They and their sycophants in the leadership of the Congress Party (simply a monarchy in drag) still believe in an India that should be managed politically by hand-outs, subsidies and populist sops that break the Union and state budgets. They do not yet believe in sustainable long-term development generating growth of >8% for the next few decades based on productive public and private investment of between 30-35% of GDP. Nor do they believe in reducing poverty through productive and meaningful private employment generation rather than on NREGA type income subsidies and hand-outs. They would rather that, at election time, the poor voted for them out of gratitude for hand-outs, than because employment was generated by private companies investing in the economy that could not be visibly attributed directly to them.

Their attitudes and supposed 'leadership' make proper macro-economic management by anyone almost impossible. They still do not believe in continuing with structural reforms that widen the distance between the polity and the economy, thus limiting the amount of damage the former can do to the latter through negligence, false ideologies about how the poor can be helped, populism and plain economic ignorance.

They do not believe that significant reforms are needed, along with an urgent programme of ambitious privatisation, beginning with Air India, extending to state-owned companies in telecoms, transport, minerals, natural resources, manufacturing, services (such as transport and tourism) and most of all privatising the state-owned financial system. It is through the SOBs that many of the weaknesses of the Indian economy are aggravated and exacerbated. The SOBs are also the conduit for exercising the kind of political influence that results in the kleptocratic quasi-market economy that has emerged in India post-1991; through an inimical but pervasive public-private partnership (PPP) between political dynasties and large business houses.

Taken together, the top leaderships in MoF, GoI and UPA -- individually and collectively -- are the PROBLEM, not the solution. Once that diagnosis is accepted, a cure can be found. Until then one can but hope that the next election brings more succour to India than is the case now.

What needs to be done urgently is to revive domestic and foreign investment and growth in the Indian economy. Given the rapidly deteriorating state of public finances, a widening current account deficit, a collapsing Indian rupee, and the entrenchment of structural inflation, which it will take prolonged tightness of monetary policy to control, GoI's room for manoeuvre is limited. But there are options to be exercised. The first is to revive confidence in government on the part of domestic and foreign investors. For that to happen, the MoF's obsession with imaginary tax losses has to be dropped in favour of more investor-friendly policies that attract inward foreign investment in large amounts. If that happens, it will spur domestic investment concomitantly.

A start can be made by putting the Insurance and Pensions Bills immediately before parliament with GoI doing whatever it must with its allies and opposition parties to get these passed. If the cap on FDI in insurance were lifted from 26% to 49% in the next few months it would result in a significant inflow of FDI. That would spill over through linkages into private corporate capital investment as well as investment in infrastructure. Both are needed urgently to relieve the supply-side bottlenecks that have been built up in the economy over the years and which are now responsible for structural inflation becoming embedded.

Similarly, the counterproductive debates and hold-ups on limiting FDI in retail (single and multi-brand) and on moving more urgently with privatising Air-India need to be ended. No national interest is served by imposing constraints and limits in any of these areas.

As far as Air India is concerned, it is now obvious to every Indian that continued public investment in that hopeless airline is a waste of public money. It benefits no one, least of all the poor, to run a state-owned airline simply for the personal convenience of the political class.

The same could be said for BSNL, MTNL, Coal India and all the SOBs. GoI ought to commit itself to privatising all SOEs by no later than 2025 in a phased manner. State governments need to follow suit rapidly in privatising the plethora of inefficient state-level public enterprises they own as well.

Those steps might indicate to the world that GoI/MoF is serious about undoing the immense damage it has done to India and its image as an investment destination since 2009. Unless that is done, with an ambitious far-reaching reform and privatisation agenda which convinces domestic and global investors that GoI really does mean business, then the Indian economy will continue to languish with prolonged sub-par performance. If that happens fiscal performance will worsen, inflation will remain too high, and growth will remain too low.

A financial crisis will ensue. The INR will continue to decline in value internally through high inflation, and externally against other currencies, putting at risk and perhaps even reversing all the achievements of the 1991 reforms.

It would be a sad legacy for a beleaguered and exhausted PM to leave, with the best of intentions but the worst of performance (and corruption) records, as he exits a stage he has played a lead role on for nearly a decade.

Saturday, June 16, 2012

Trading in the rupee: Starting to look like serious numbers

by Vimal Balasubramaniam and Ajay Shah.

The rupee-dollar is the most important price of the Indian economy. It is discovered on the currency market. What are the contours of this market? Specifically:
  1. How big is the daily trading in the rupee?
  2. Where does the rupee stand, in global rankings of currencies?
  3. Where does trading take place?
  4. Where are we on the onshore versus offshore distinction?

How big is the daily trading in the rupee?


Trading in the rupee is composed of the following elements of the market:

Exchange-tradedOTC
Onshore Options, futures Spot, forwards, swaps, options
Offshore Futures Forwards, swaps, options

We attempt an estimate of turnover across all components, on 25 May 2012:[1]


Location Billion USD

OTC Spot (onshore) 19.82
OTC Forwards (onshore) 4.40
OTC Swaps (onshore) 11.34
Exchange Futures (onshore) 7.02
Exchange Options (onshore) 1.45
Exchange Futures (offshore) 1.17 [a]
OTC (offshore) 20.03 [b]

Total 65.23

Source:- RBI Weekly Statistical Supplement, NSE, USE, MCX-SX, DGCX, and BIS Survey (Tables D.1.1 and D.1.2)
[a] DGCX data as on June 6, 2012 for May 2012.
[b] This is the April 2010 BIS survey valuation of the offshore market, adjusted for the DGCX daily average value (estimated from overall value of futures contracts) for April 2010.


This is an under estimate for two reasons. Data for one important element (offshore OTC) pertains to April 2010; the market must have grown since then. Data from the BIS is likely to not capture activities of non-bank players.

Three interesting facts come out of this. First, that the overall market for the rupee is roughly $70 billion a day. Second, that roughly one-third of it is spot, and the rest is derivatives. Third, that rougly one-third of it is offshore.

Growth in recent years has been tremendous. In May 2000, the onshore market did only $2.7 billion a day. That is, we've got 24x growth over 12 years.

Where does the rupee stand, in global rankings of currencies?


BIS surveys global banks and reveals interesting data about the currency market. However, it is likely that the BIS misses out on a great deal of non-bank activity. If a hedge fund sends an order to an exchange, this is likely to elude the measurement of the BIS.

According to the BIS, in April 2010, the daily average turnover for the INR against the USD was a total of U$41.7 billion. [2] INR then ranked 15th (spot), 10th (forwards) and 22nd (swaps) in a pool of 28 currencies covered in this BIS survey. Summing up, the rupee stood at rank 16 in their group of 28 currencies. In the class of emerging markets, the rupee ranked fourth, third and ninth in the spot, forwards and swap markets respectively:


Ranking among EMs

Currency Spot Forwards Swaps
Korean Won 1 1 3
Mexican Peso 2 6 1
Russian Ruble 3 12 5
Indian Rupee 4 3 9
South African Rand 5 9 4
Brazilan Real 6 4 14
Chinese Renminbi 7 2 8
Turkish Lira 8 8 6
Polish Zloty 9 7 2
Taiwan Dollar 10 5 11

Source:- BIS Survey, Tables D.1.1 and D.1.2


The BIS triennial survey included the INR since 1998. The three-yearly snapshot of Rupee's position marks its rise over time. Measuring only the spot market, the rupee ranked 13 (tied with Hungary, Indonesia and Chile) in 1998 and moved to the third position in 2010. In terms of change, the rupee has moved dramatically, perhaps, with no other currency witnessing such rapid change.


Emerging market currencies rank: spot market

Economy 1998 2001 2004 2007 2010
Russia 2 1 1 1 1
Korea 6 2 3 2 2
India 13 10 6 3 3
Brazil 3 4 6 7 5
China 16 18 17 5 5
Chinese Taipei 6 6 4 4 6
Mexico 2 4 2 7 8
Turkey 18 17 17 18 8
Malaysia 16 17 17 13 10
South Africa 4 10 9 8 10

Source:- BIS Survey, Table D.19


The most surprising feature of these results is the extent to which the rupee is a bigger market than the CNY, even though Chinese GDP and internationalisation exceed that of India. It seems to suggest that you'd have to do bigger trades to obtain a 1% change in the INR/USD rate, when compared with the trade size required to obtain the same change with the CNY/USD rate. This helps us see why India has moved into greater exchange rate flexibility when compared with China: there was really no choice.

Where does trading take place?


For the first time, Table D.6 of the triennial survey provides information about where currency trading takes place. A surprisingly diverse set of locations light up:


Location of the currency market (% of turnover)

Location BRL CNY INR KRW ZAR
India -- -- 50.02 0.00 0.04
Australia 0.51 0.44 0.31 0.50 1.20
Brazil 29.68 0.01 0.00 0.01 0.07
Canada 4.66 1.36 0.15 0.18 0.39
China -- 24.87 -- 0.00 0.06
Hong Kong SAR -- 27.29 10.91 10.33 --
Japan 0.05 0.28 0.21 0.19 4.65
Korea 0.05 0.03 0.02 52.13 0.02
Singapore 1.07 19.01 16.12 21.01 1.18
United Kingdom 19.18 17.29 12.32 10.98 36.43
United States 37.53 7.72 9.26 3.95 8.36

Source:- BIS Survey, Table D.6


Where are we on the onshore versus offshore distinction?


As the table above suggests, roughly half of rupee trading takes place in India. The issues which shape this onshore versus offshore market share are likely to be similar to those seen with Nifty. Recent events are likely to have driven the share of the onshore market to below 50%.

The onshore OTC market consists of forex spot transactions, forwards and swaps. The RBI publishes information on turnover in the onshore spot and forward market and the forward and spot legs of the swap transaction are captured in this data as well. An RBI report on OTC derivatives in 2011 highlights that OTC derivative turnover was 3.53 trillion USD in FY2009-10. Out of this, forex swaps account for over 60% of the total turnover in the same period. Here is the time series for the onshore OTC market:

Source: RBI, Weekly Statistical Supplement (1996 - 2012)


Exchange-trading of the rupee, in India, started in 2010. At a point in time, turnover in exchange-traded currency futures did seem to have overtaken the OTC forward market. The USD-INR futures contract on MCX-SX, NSE, and USE with a contract size of USD 1000 occupied the first three ranks for volume in the world in 2010 and 2011. The USD-INR options contract on the NSE ranked fourth while the EUR-INR futures on the NSE also featured in the top 20 forex futures contracts in the world. The collapse in the following graph, which shows exchange traded onshore turnover, is associated with the CCI order:

Source: NSE, MCX-SX, and USE


Putting together the information from the onshore exchange-traded market (options, and futures) and the onshore OTC market (spot, forward, swaps data from the RBI), one gets a complete picture about the onshore INR market:

Source: RBI, NSE, MCX-SX, and USE


The most recent BIS triennial survey (April 2010) had placed the onshore market (USD-INR) at about U$20 billion. As the graph above shows, current values are more like U$30 billion a day. The offshore market is likely to have grown more, giving total INR turnover of well above U$70 billion a day. This puts the Indian rupee today above the Korean Won as of April 2010.

Conclusions


The Indian rupee has grown rapidly to becoming the sixteenth most traded currency in the world. From less than 0.2% of the world forex turnover in 1998, it has grown rapidly to constitute about 0.9% of the world forex turnover in April 2010. It is one of the biggest emerging market currencies with the Korean Won, Russian Ruble, Chinese Renminbi and the Mexican Peso being its close competitors. The offshore market today is as big as the onshore market, as is seen by other EMs. Today, the rupee does roughly $70 billion a day, roughly where the biggest EM currency (the KRW) was in 2010.

These developments have many ramifications:
  1. The rise of a large currency market is consistent with India's rapid integration into the world economy of recent decades.
  2. When a market does turnover of $70 billion a day, market manipulation is difficult. Manipulating the rupee is now as hard as manipulating Nifty: both are large globally traded products with highly liquid markets. This is the essence of India's evolution away from an INR/USD pegged exchange rate to a mostly-floating exchange rate: the monetary policy distortions required to support manipulation became too large.
  3. As with Nifty, mistakes of domestic policy are giving a substantial shift in India-related finance to overseas locations. The two most important pillars of the Indian financial system are trading in the rupee and in the Nifty, and with both these, India is rapidly losing ground. If present policy mistakes continue, the role of the onshore market will continue to decline, for both the rupee and Nifty.
  4. In the last 12 years, there was 24x growth. Suppose there is only 10x growth in the next 10 years. That would take us to $700 billion a day, which would be quite something.
  5. Looking into the future, if India is able to continue on the course of high GDP growth and integration into the world economy, the rupee will become a big currency by world standards. The big four currencies today are the USD, EUR, JPY, GBP. It is not inconceivable to think of CNY and INR joining that club. This could connect nicely with a role for India in global finance. But for all these good things to happen, we have to put our house in order.

Notes

[1] Forward market turnover is estimated as purchase + sale - cancellation.
[2] The BIS survey also does cross-border netting - something that we cannot adjust for from the RBI data. However, as Jayanth Varma points out, this may not be a very large number that the overall calculations dramatically change.