Taking On C-Suite Communication, Hedge Accounting Changes and FX Trading Woes

April 28, 2018

FX managers discuss dashboards, headaches of trading restricted currencies, implications of new hedge accounting rules and effects of US tax reform. 

NeuGroup’s first meeting of 2018 brought together both FX peer groups, FXMPG and FXMPG2, for a summit sponsored and hosted by Chatham Financial near Boulder, Colo. Highlights included a fast-paced round of “What’s the No. 1 question you want answered?” and generous sharing on metrics and reporting style, what reports include, how they are produced and who sees them. Other standouts included two successful Solve My Problem sessions, with members unafraid of asking for the wisdom of the crowd to help move past their conundrums. These themes emerged from the FX Summit:

1) C-Suite Communication and Presenting FX to Leadership. Clarity is key when explaining FX risk strategy and success metrics to senior executives, and that’s made easier with the right tools. Those include well-designed dashboards, robust reports that may cost extra, and data visualization software that leads to more dynamic discussions. How can you improve communication with the C-suite?

2) Onshore E-trading in Restricted Currencies. Simplicity and fewer headaches are what FX managers want when attempting to trade restricted currencies on e-platforms. When that proves difficult or impossible, it’s time to rely on your ability to work the phones and check other sources to make sure you’re getting a fair price. What are your solutions to the problems encountered with e-trading these currencies?

3) A Changing Environment for FX Management. Winds of change blowing from several directions may alter the course FX managers plot for hedging and other activities in the months and years ahead. New accounting rules are one catalyst for rethinking some hedging strategies, and US tax reform presents multinationals (MNCs) with capital allocation decisions and legal entity issues that have implications for FX risk management. What changes are you contemplating to adapt to the new environment?

C-Suite Communication and Presenting FX to Leadership

One of the top-rated themes this cycle is how members explain financial risk management objectives to senior executives, how the objectives are achieved, and the metrics and reporting that keep upper management up-to-date on the program’s performance.

KEY TAKEAWAYS 

1) Illustrate the instrument choices to non-treasury stakeholders. Deciding whether to use forwards or options—and then building understanding and support for the choice, especially if it requires paying upfront premiums—is a challenge. Among the questions members asked: “If options are insurance, how do you quantify the appropriate deductible?” A treasury with a directional view of currency moves must build a case and illustrate it in the context of market conditions in a way that makes the instrument choice rational and clear. One of the presenters showed a simple matrix detailing which hedge instrument to use under different market conditions and views of where the currency will move.

2) Spend money on developing a few truly important reports. An evergreen frustration is how hard it is to get reporting out of ERPs and TMSs that is fit for treasury’s purpose and preferences without manual manipulation. But one presenter showed an impressive report with data “straight out of Reval.” His advice: “spend money” on developing a few customized, automated reports and take the time to get them right; it will be worth it. One of the results of this process was a “cash flow fact sheet” with coverage ratios, derivatives marked to market, monthly P/L impact and other items treasury wanted in one place.

3) The power of Power BI. Three members shared their reporting and how they explain FX to senior finance and business leadership. They focused on what metrics resonate with non-treasury higher-ups, and how to build reports that are on point and easy to update. More and more members are moving to dashboard-type reporting using real-time data; that creates a much more dynamic discussion with management, and less “I’ll get back to you on that,” because of the ability to drill into the data on the spot. Easy-to-use tools are available: the Microsoft suite has basic Power BI included, and anyone familiar with pivot tables can learn quickly. Certain regular processes, like “scrubbing” data according to a particular pattern, will be picked up by machine learning and automated. Power BI is also an integral part of Chatham Financial’s system, ChathamDirect. Tableau is another visualization tool.

Simplify FX Workflow While You Implement Your TMS

In a session on a TMS implementation, a member noted that a thorough review of FX processes at his company revealed that 85% of the time spent on one process was tagged as inefficient and 59% of the steps were tagged as manual. This created huge opportunities for simplification and automation of what he called “the stupid work.” That not only shortened the time required to complete certain tasks but increased controls and accuracy and freed up treasury’s time to do more value-added work.

One game changer: making the TMS the single book of record, meaning all trades need to be in it or they cannot be confirmed. Plus, all trades must go through the trading platform (exceptions for certain onshore emerging markets, but keep pushing local regulators to make more e-trading available there, too). Bonus: in the simplification of the processes, not only were big time savings realized (over 80% in some cases) but a slew of imprecise Sarbanes-Oxley (SOX) controls were reduced and made clearer. In the end, over $1.5 billion in notional derivatives were moved from manual Excel spreadsheets to a single, controlled, auditable book of record.

OUTLOOK

Real-time dashboards are making inroads toward replacing static reporting in spreadsheets and PowerPoint presentations. This allows for more focused discussion and the ability to drill down into underlying data or data sets for specific periods, counterparties and currencies. This development should enable more dynamic conversations with management and, over time, increase the understanding of FX exposures and how they are managed outside of the FX team.

Onshore E-trading in Restricted Currencies

Members continue to experience widespread challenges when trading restricted currencies. Among them: Bidding out trades remains difficult due to regulatory and documentation requirements. Members had a discussion that touched on Argentina, Brazil, Colombia, Venezuela, China, India, Korea and Malaysia—and the numerous headaches they cause.

KEY TAKEAWAYS 

1) Make it simpler! When it comes to restricted currencies, the wish list is short: Make it simple to trade them on e-platforms! Despite claims from trading platforms that e-trading is possible, central bank regulations and documentation requirements make it almost impossible to bid out some currencies due to what MNCs must provide the bank prior to and at the time of trade execution.

2) Always double-check pricing. With pre-trade documentation requirements hamstringing competitive bidding, most members check pricing via either Bloomberg or Reuters, across electronic bidding/request for quote (RFQ) channels or even local banks before placing trades by phone with one bank, using the data to push back on pricing.

3) It helps to have a guy. Execution in restricted currency zones often means picking up the phone and building relationships with onshore traders. One member’s semi-manual process involves a price check on Reuters before directly calling “his guy” onshore to execute trades by phone, then entering them into FXall for record keeping. Although he’d prefer to bid out the trades with several banks electronically, the process at least allows him to push back on price. With e-platform limitations, including the fact that some local banks are not accessible on them, one member uses the “old school way,” calling several banks to discuss his pending trades and get a sense of pricing before moving forward with documentation and the actual trade.

Solve My Problem 1:

Resist Accounting Purists Pushing for Daily FX Accounting Rates

In the first of two Solve My Problem sessions, a member sought his peers’ help to push back on demands for a switch to daily FX rates for accounting purposes. A majority of members in the pre-meeting survey say they use a monthly rate (usually the prior month-end spot), but there is a steady trickle of firms adopting daily rates. Auditors insist this is the most “theoretically pure” rate to use, and ERPs increasingly support them. But especially for balance sheet hedgers, this adds complexity, considerably more work and transaction costs for more frequent hedge adjustments.

So ask accounting to demonstrate in real dollars the benefits of daily rates vs. a monthly one (or the “cost” of sticking to a monthly), and push back with a realistic picture of increased transaction costs, forecasting demands on business units and added work for the FX team to accommodate daily rates. Also, ask the IT department to estimate the cost and time required to switch and be “pure.” Remember, once you go daily you will not be able to go back, and most who adopted daily rates now wish they had not.

OUTLOOK

Members didn’t come out of the discussion with great optimism that things will get easier anytime soon. Streamlining cumbersome trading practices doesn’t happen often, and when it does, it’s usually because of persistent communication with the relationship bank and local banking partners. A few members noted that some bank platforms have improved the documentation flow for settlement with the ability to attach documentation to trades, but this doesn’t help with limitations on competitive bidding. If the currency is non-deliverable, e-trading may work. But pricing out an NDF with a bank that isn’t available for bids on a platform still adds manual steps. The FX world appears to have a ways to go until the convenience of bidding out emerging market currencies electronically is realized.

A Changing Environment for FX Management

The year 2018 is one of potentially significant change for FX risk management: New hedge accounting rules have come out that could reshape hedging activities, and US tax reform may have widespread effects on company structure and where liquidity and other exposures are located going forward.

KEY TAKEAWAYS 

1) Early adopt or not? Adoption of the new hedge accounting rules is mandatory for public companies with fiscal years beginning after Dec. 15, 2018. About a quarter of the members in both FXMPG groups have early adopted for various reasons: collar users may have limited numbers of fair-value hedges, making the transition “easy;” those with volatile long-term forward hedges may find amortization of forward points helpful to increase predictability. Revenue hedgers may feel differently as the impact will hit the hedged item and not go below the line anymore. But get someone else to do the work, either in accounting or the treasury controllers group. Adopting at the beginning of a fiscal year makes transitioning much easier, so others may early adopt if they are on off-calendar FYs. Chatham Financial noted that Big Four firms are recommending staying with the long-haul method if doing so already, since this will reduce the need to overhaul controls on effectiveness testing relying on qualitative assessments.

2) FX management implications of US tax reform. Will tax reform and repatriation of offshore cash trigger another wave of US dollar strengthening? Not likely was the consensus of members, mainly because the proportion of offshore cash held by MNCs in non-dollar denominated assets was not substantial, and most companies shortened duration in anticipation of tax reform, so they could hold assets to maturity rather than sell to repatriate.

Solve My Problem 2:

It’s Not Impossible to Change Functional Currency

To facilitate repatriations post-tax reform and manage FX risk more efficiently, a member got advice on how to change from local currency to USD-functional subs. This brought up FASB issues and members from several USD-functional companies shared ways of meeting the six FAS 52 criteria, focusing for example on the majority of funds flows, or the dependency of subs on the parent (arguably, all are). However, accounting and systems adjustments required for a functional currency switch are big roadblocks. Also:

  • Be consistent: What are the subs’ commonalities?
  • Tax rules: Being USD functional is an easier sell in-house if the subs are in jurisdictions that accept statutory accounting in USD (e.g., UK, Hong Kong). But if management wants it, it will get it. Get help from experts like Chatham Financial or Hedge Trackers.
  • If you cannot make a solid case that an operational sub is an extension of the parent, something in the business needs to change to make the case for a functional currency change.

OUTLOOK 

USD strengthening or not, the real issue is what changes to legal entity and capital structures companies make as they adapt to tax reform. The excess capital held by overseas entities will no longer be trapped; so how much of it comes home and how do companies determine adequate cash buffers going forward? Will it just be a shift of liquidity or will broader business and entity shifts occur that totally overhaul the exposure picture of MNCs, and what will hedging look like after that? NeuGroup looks forward to connecting members in the months ahead to exchange knowledge as they seek answers to these questions.

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