Developing Issues: Dodd-Frank’s Impact on IHBs; SSC Evolution; DFA Update

April 17, 2013

A snapshot of what’s on International Treasurer’s radar screen this week.

Issues on Horizon - BinocsSeveral topics came out of this week’s International Treasurer editorial meeting that we will pursue in the coming weeks. This included a further examination of how Dodd-Frank will impact in-house banking structures. Also we will take a look at the evolution of shared service centers. And with deadlines looming for Dodd-Frank implementation, we’ll take a look at where the law stands and what companies should be doing.

Dodd-Frank and IHBs.

Do you have an in-house bank or planning to develop one? Check the legal structure. As many treasurers know, one of the benefits of using an IHB is that it can centralize the management of critical functions. For instance, an IHB can allow headquarters to keep control while also engaging regional centers around the world. Treasury activities can then be strategically aligned, allowing operating companies to focus on their business. Additionally, an IHB can sweep cash (where legally allowed) to HQ from the operating companies daily, and from there operations can be funded from HQ as needed, in accordance with legal restraints.

But Dodd-Frank could put the kibosh on such activities. If the legal structure of an IHB is as a separate entity, it could put the IHB under the purview of banking regulators such as the Fed. It could also be subject to central clearing and margin requirements.

Shared service centers.

The evolution of shared service centers continues. Some companies are following a BP SSC model uses a refined and thus, more efficient reporting structure – an elevated position whose leader reports to the CIO – and also taking on more than just finance. We’ll take a look at what some member companies are doing in this regard.

DFA Update.
It’s a daunting task getting prepped for Dodd-Frank. Determining how your company will be classified, selecting the appropriate board committee to approve of the end-user exception and keeping ahead of all of the mammoth rulemaking that is Title VII of Dodd-Frank is not for the faint of heart. And what about your inter-affiliate trades and the recent no-action relief language put out by the CFTC? Dodd-Frank updates are part of virtually every US-based NeuGroup meeting lately (but our European group is also affected and will discuss it at its May 15 meeting in Geneva), and IT will dig into a few things we have learned from our meetings and other experts.

Also on the radar.

  • A look at what’s happening in supply chain finance
  • SAP Financial Services Network
  • Hedge programs revisited

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