FX orders: Rules of Engagement 6 March 2017 · 2 Treasury Broadsheet | Quarterly newsletter of snippets and stories from the world of treasury management 6 March 2017 The rules of

1 Treasury Broadsheet | Quarterly newsletter of snippets and stories from the world of treasury management 6 March 2017

FX orders: Rules of Engagement

Using foreign exchange orders placed with a bank to enter currency hedging

contracts is no different to many other aspects of professional corporate treasury

management, it pays to know what the rules of engagement are in advance so that

there are no surprises.

In instructing a bank to buy or sell one currency against another at a

predetermined market exchange rate level (a firm FX order) the importing or

exporting company is requesting the bank to monitor the FX market movements

24/7 and execute the transaction if and when the order level is reached.

The first aspect to understand with FX orders is that there is no specific or single

market convention, global standard or protocols that a corporate user of FX

dealing services can look to. Banks have different parameters, policies and

treatment for FX orders. However, most banks' terms and conditions (in the fine

print) on customer services will clearly state that FX orders are taken and handled

on a "best endeavours basis and at the bank's discretion on the bank's pricing".

FX rates quoted on a Reuters screen are not necessarily actually traded in the

market by the bank holding the order. Therefore, there is no guarantee that

orders will be struck even though a Reuter’s intra-day chart of the rate movement

shows that the market traded through the order level.

It will always be in the company's best interest and the bank's best interest if the

rules of engagement and parameters with FX orders are communicated and

agreed between the parties in advance. Some banks place the order at the

stipulated exchange rate and trigger the transaction for their customer if the bank

trades at that interbank wholesale rate. Any additional margin points for the bank

under agreed banking arrangements are subsequently added/deducted to the

forward points when the FX order is rolled out to a forward exchange contract.

Other banks adjust the customer's FX order level to ensure they receive their

margin points. There are some instances where this is done without the

customer's prior knowledge and disputes arise as to whether the order was struck

or not.

6 March 2017

(Click to view)

FX orders: Rules of Engagement

Alleviate the pain of low foreign currency deposit rates

A small nation with a large problem. How will New Zealand companies respond to the rising anti-globalisation sentiment?

Developments within the New Interest Rate Paradigm; implications for Corporate Treasurers

XVA – Application to corporate borrowers

Time to consider retail bonds?

The ISDA Standard Initial Margin Model

Dairy Future Updates


The rules of engagement with FX orders is that the bank must deal in the market at the first opportunity they

have once the market trades through the FX order rate. Slippage of 10 to 30 points may occur from the FX order

rate in volatile market conditions. Questions and disputes can occur when the bank holding the order cannot

transact in the interbank market for the full amount of their combined customer orders. Some banks will allocate

these "partial fills" in equal proportions across their customers. Other banks may have a rule that none of the

order is struck unless the full amount can be dealt by the bank and allocated. It pays to check the policy and

practice of your Bank!

Banks can tag an order with specific instructions i.e. if the order is struck the contract is to be rolled out into a

collar option at a specified cap or floor rate. If the overnight markets are volatile it is very difficult for the bank to

convert the triggered order into a collar option unless they know that requirement in advance.

A well organised bank should inform the customer in advance what their minimum FX order amounts for

particular currencies. The bank is well within its rights to refuse a FX order, in which case the company's

representative might have to sit up all night and deal spot when the market reaches the desired level. Generally

banks will accept FX orders for smaller amounts if they can piggy-back the order onto other larger customer

orders which may be at slightly different exchange rate levels.

Banks who value their customers' FX business and thus relationship over a medium term horizon will ensure that

the terms of engagement for FX orders are well understood and agreed on both sides. If an importer and exporter

has evidence that their order should have been struck, however their bank advises that it was not struck, the

customer has every right to query and question the bank for an explanation.

Currency market events like the recent GBP/USD flash crash is pushing banking regulators to require banks to

disclose their margins on FX order transactions. Automated FX trading systems can compound issues of market

prices gapping, leading to disputes of whether FX orders were filled or not.

Many local importers and exporters use a series of FX orders of different amounts staggered upwards or

downwards from the desired first order level. Another common practice is to use "either/or" FX orders that have

two rates, one higher and one lower than the current spot rate e.g. A USD exporter may have an "either/or" order

at 0.7050 and 0.7300 to ensure they enter the hedging at the more favourable 0.7050 if the NZD depreciates over

subsequent days, however they are automatically hedged at 0.7300 should the exchange rate appreciate. If the

decision is made to increase export hedging, then the tactical execution of that decision is to accept the fact the

hedge may be entered at 0.7050 on the best case, or at 0.7300 worst case. Either way, the hedge is transacted and

there is no risk of not getting the hedge completed. By just having a single FX order at 0.7050 with the market

spot rate never falling to that level and appreciating to say 0.7500, the company has failed to execute/transact

their hedging decision.


Alleviate the pain of low foreign currency deposit rates

It's 2017, seven years after the global financial crisis and major central banks continue their massive stimulatory

monetary policies through very low and negative interest rates. Overnight central bank rates in Japan are -0.1%

and Europe -0.4%. The response is that commercial banks are not actively seeking EUR and JPY deposits and are

offering zero or negative interest rates for call and term deposits. In some cases banks have said they have no

interest in receiving deposit funds.

For those corporates or wholesale investors that hold operating surpluses for terms of greater than one month or

have core foreign currency denominated term deposit investments, the use of foreign currency swaps may

provide the enhanced NZD investment interest yield that offsets the current low global interest rate

environment.

The foreign currency swap strategy is used in conjunction with the NZD term deposit market and allows the

investor to benefit from the current credit spread benefit between term deposit rates and New Zealand short term

wholesale rates. The positive credit spread benefit is shown in the following chart:

The term of the strategy is primarily driven by the underlying liquidity and matched expenditure requirements of

the business. Importantly, the future foreign exchange rate risk of selling NZDs back to the foreign currency

amount is protected through the forward exchange contract entered into at the time of transacting the foreign

exchange rate swap. With all foreign exchange and interest rate risks locked in, the NZD net income amount is

known from the commencement of the strategy.

An example could be, a corporate has EUR5million on call deposit which is expected to remain for a six month

term. The bank has offered a zero EUR interest rate. A foreign currency swap is transacted whereby EUR is

converted to NZD at today's NZD/EUR 0.6797 spot exchange rate. At the same time a forward exchange contract

is transacted that sells NZD for EUR in six months’ time at 0.6704. The NZD amount is put on term deposit for

six months at 3.4%. The net NZD income gained after considering the forward point cost is for this example

around NZD21,000.

The savvy treasurer that builds a calculator and inputs the known variables before transacting, will ensure any

opportunity to enhance income returns is identified and captured.

Source: RBNZ


A small nation with a large problem. How will New Zealand companies respond to the rising anti-globalisation sentiment?

March 2017 marks the date that New Zealand steps into the era of Brexit and Trump with wide eyes and cautious

steps. The necessity of trade that underpins the New Zealand economy is facing what looks to be an anti-

globalisation political movement threating its wellbeing. The global economic environment appears to be growing

in hostility via proposed reductions in movement of goods, people and in essence ideas.

Highlighting this change are Britain (UK) and the United States (US). Both nations are rallying on the ambitions

of their respective citizens to provide localised jobs, tightened migration clauses, greater focus on local resources

and a reduction of imports, which in their eyes is the solution to reclaiming their economic wealth. With this

mandate, the question then has to be asked, will 2017 will be the year of anti-globalisation?

Since the inauguration of President Trump, his rhetoric has suggested this ideal of anti-globalisation (Trade on

American terms) wasn’t just campaign propaganda, rather, is reflective of his future economic policy direction.

The executive order to step away from the Trans Pacific Partnership signalled to the markets that anti-

globalisation is his overall agenda. These proposed actions create a volatile economic environment for both

exporters and importers alike. This not only influences global trade growth but impacts currencies and interest

rate yield curves.

Worst Case Scenario – “super-power trade war”

Commander-in-Chief Trump vows to “make America great again” by implementing isolationist and protectionist

policies to reduce the reliance of the United States on overseas trade. In particular these policies are targeted

towards China. This includes imposing restrictions such as tariffs (possibly up to 45%) and quotas on imported

goods from China with the idea of weakening their export revenue and encouraging consumers to buy from local

manufacturers rather than overseas competitors. Westpac New Zealand’s Head of Market Strategy, Robert

Rennie, believes that Trump will use the exchange rate of 7.00 RMB/USD as the trigger point for enforcing these

policies. Currently the exchange rate is fluctuating between 6.70 - 6.90.

The retaliation from China against these policies will essentially confirm the “super-power trade war”. The

retaliations could come in multiple forms, however, one of the most concerning is that China is the top holder of

U.S government bonds with $1.3 trillion on their books. By buying US Treasuries China helped keep US interest

rates low. If China stopped buying or even sold US Treasuries, interest rates would likely increase sharply,

throwing a still fragile US economic recovery into chaos. As the world’s largest economy, this decision will also

result in New Zealand interest rates increasing, a significant risk to borrowers. A short term consequence of any

trade restrictions will likely be an increase in inflation, adding to an already steepening yield curve.

China’s response could take a more strategic line where they counter with an agricultural trade tariff impacting

$20 billion of Chinese imports from US farmers. We know what a strong lobby group they are!

Any form of trade war and restrictive trade policies will likely be negative for global confidence and global growth.

This could result in other central banks from major economies facing inflation on one hand but flat to negative

growth prospects on the other. They may have to cope with awkward yield curve volatility as a result.

Will this result in markets re-evaluating key currency values, especially amongst the commodity group such as

CAD, AUD and NZD?


How will this affect New Zealand?

China’s economic power is driven by its exports to The United States. If a trade-war begins, China may attempt to

“balance the books” by importing less themselves, including importing less from New Zealand’s lucrative dairy

market, an industry that underpins the New Zealand economy. A chain reaction of such an effect is essentially

fewer jobs, increased interest rates in New Zealand, increased household debt and significantly less disposable

income and money to buy the goods and services provided by New Zealand companies. Further hampering New

Zealand corporates would be confirmation from world powers to move away from large multi-country trade deals

and a focus on bi-lateral deals, which will immediately impact New Zealand exporters looking to sell into overseas

markets. It is unfortunate that our small size and agricultural focus will put New Zealand significantly down the

pecking order, as agriculture is usually at the top of protectionist country’s list.

This economic uncertainty will also go hand in hand with currency and interest rate uncertainty making it even more important that New Zealand companies proactively manage their exposure to material foreign exchange and interest rate risk. Staying on top of accurate business forecasting will be the No.1 priority for New Zealand Treasurers and Chief Financial Officers.

New Zealand has benefited greatly via globalisation over the past 20 years. It has been the vehicle driving our

economic growth, advocating our agriculture sector to the world in particular. If a trade war and anti-

globalisation sentiment were to come to fruition, New Zealand will be small a nation with a large problem.


Developments within the New Interest Rate Paradigm; implications for Corporate Treasurers

Nine months ago in our comprehensive Interest Rate Thought Leadership piece we posed the question whether a

paradigm shift lower had occurred in New Zealand (and global) long-term interest rates. At that time the New

Zealand 10 year swap rate was trading well below 3.00% and the US 10 year government bond yield was trading

towards 1.50%. We concluded that over the two to five year future period, US 10 year government bond yields

were most likely to move back to 2.50% and New Zealand 10 year swap rates to 4.00%, i.e. below historical

averages but above then prevailing rates. The conclusion was based on:

Oil/petrol price decreases ultimately giving way to increases (hence higher headline CPI inflation)

A gradual tightening in capacity utilisation (influencing higher underlying/core inflation), and

The economics of banking, long-term liability managers (e.g. pension funds, life insurers) and interest

rate yield curve dynamics not being sustainable as interest rates continued to rally lower (i.e. there

remains a need to get a sufficient return for lending and investing ‘long’).

What has since happened?

The Bank of Japan was the first major Central Bank out of the blocks August last year, targeting a level

and shape across the entire yield curve, helping reverse the prior trend of negative bond yields.

Oil has reversed its previous falls, strengthening to USD55/barrel and with it pushing headline CPI

inflation rates higher.

-1.00

0.00

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10-Y

ear

Govt

Bond Y

ield

(%

)

10-Y

ear

Govt

Bond Y

ield

(%

)

NZ, Germany, Japan, Australia and US 10-Year Govt Bond Yields

United States Australia Japan Germany New Zealand

Source: Bloomberg


US wage rates and core CPI trends (i.e. excluding energy and food) have also moved somewhat higher.

Of greater surprise to most has been the global ‘reflation’ trade under the Trump Presidency where

stronger fiscal expansion, growth and inflation expectations have also seen higher market interest rates.

The combination of these events has seen the US 10 year government bond yield move to 2.50% and the New

Zealand 10 year swap rate to 3.50%.

Implications for corporate borrowers and treasurers

With the prior ‘flat’ yield curve of recent years there was an easier decision for treasurers to fix interest rate risk

longer-term, even if a reluctance to continue to fix into a market that had continued to fall. Now, the decision is

less clear cut; whilst our long-term interest rates (primarily driven by US/global factors) have increased and the

yield curve has steepened, there remains little urgency for OCR / 90 day bank bills to shift significantly higher.

Whilst headline CPI has increased primarily on oil prices, and will continue to do so for the immediate future,

outside of the US there has been little sign of wage inflation and underlying (core) CPI inflation increases. The

Reserve Bank of New Zealand remains non-committal on the scope for short-term interest rate increases awaiting

evidence on the persistence of higher inflation (or not).

The interest rate risk management trade-offs for corporate borrowers and treasurers may currently be seen as

follows:

New borrower swaps where fixed rates being paid will initially be well above 90 day bank bill rates

Forward starting swaps, where one can enjoy the lower 90 day bank bill rates initially, but a higher

forward starting swap rate thereafter

Purchased borrower caps, where a premium/insurance cost is paid, to enjoy lower 90 day bank bill rates

initially and remain protected from any spike higher in 90 day bank bill rates

Purchased borrower swaption (where a premium cost is paid), allowing initial maintenance of low

floating rates, and where the swaption would subsequently have value if term swap rates increase.

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1991 1993 1995 1997 1999 2001 2003 2005 2007 2009 2011 2013 2015 2017

US

10 Y

ear

Tre

asury

Month

ly A

vera

ge (

%)

US

Headlin

e C

PI Y

oY

(%

)US 10-Year Treasury Bond Yields and US Headline CPI

US Headline CPI US 10-Year Treasury Yield

Correl: 57%Pre GFC: 53%Post GFC: -2%

Source: Bloomberg


In practice, the existing hedge portfolio (including the level/percentage of fixing, the term, existing fixing rates, and range of instrument use) and the organisation’s tolerance/sensitivity to market interest rate risks will help determine the optimal approach for new fixing. Please let us know if you’d like to know more.


XVA – previous application to corporate borrowers

Following our XVA article on why it matters, we outline how credit, funding and capital/liquidity value

adjustments (collectively known as XVA) will impact the pricing of borrower swaps and interest rate risk

management practices of corporate borrowers.

CVA (credit valuation adjustment) from a corporate perspective means the additional credit adjustment to

transacting an interest rate swap. It is the perceived credit risk of that corporate. CVA adjustments are well

known with regards to financial statement reporting. However, in any swap transaction the cost of credit will be

added as a basis point cost above the wholesale market mid-rate.

FVA (funding valuation adjustment) is the cost for funding out-of-the-money restructures of borrower swaps.

Such might occur when there is a timing mismatch between a live swap and delayed timing of drawn debt

(requiring the start date of the swap to be pushed out). Or the blending and maturity extending of an existing

swap (for Policy compliance, or changing shape in the yield curve). In restructuring the swap the counterparty

bank is effectively funding the corporate borrower the “out-of-the-money” market position. The funding cost

incurred by the bank is added as a basis point cost to any restructured swap coupon rate.

KVA (regulatory capital valuation adjustment) is the regulatory capital cost that a counterparty bank is required

to apply for holding capital for the swap. Longer dated out-of-the-money swaps require significantly more capital

allocation. KVA represents a higher proportion of the cost of transacting swaps relative to CVA and FVA as

regulations, and the cost/bank return on capital may potentially fluctuate over the life of the borrower swap.

Recent experience has shown us that as a proportional cost of out-of-the-money restructures, KVA has

represented circa 70-80% of the overall additional cost above the restructured swap coupon rate.

Given the above, corporate borrowers should not hesitate in asking their swap counterparty bank to provide the

breakdown of XVA costs when restructuring swaps. This can allow greater transparency to be applied when

determining the effectiveness of a restructured swap or transacting a new forward start swap at prevailing market

rates without effectively being ‘underwater’ due to valuation adjustments.


Time to consider retail bonds?

Treasurers have been forced to consider their funding options in recent months as bank funding costs continue to

increase. As part of this assessment, they would be wise to consider the retail bond market. For medium and large

scale corporates with core debt greater than $200 million, this market is becoming an attractive alternative to

standard bank loans. For those unfamiliar with certain aspects of the market, an overview is provided below:

Diversification – Investors in this market range from private wealth clients to “Mums and Dads” with

differing investor objectives and constraints to the banks. The funding diversity of the retail market

reduces reliance on bank loans which can prove problematic during times of banking stress.

Pricing – Retail investors are traditionally focused on a fixed coupon or yield. Typically coupon rates

need to yield more than bank term deposit rates which can often lead to competitive borrowing rates for

corporates. Within the market, well-known ‘household’ names also tend to procure competitive pricing

as their investors are often their customers. In this regard, having a strong brand presence is

advantageous as retail investors typically associate these entities as being good investments.

Credit ratings – For unrated borrowers (borrowers without a formal rating from a credit rating

agency) volume is more readily available in the retail market when compared to the wholesale bond

market. The reason for this is due to wholesale investor mandates which restrict investments in unrated

issuers. The retail market does not contain such restrictions with investors typically increasing the

coupon rate to reflect any implied additional credit risk associated with being unrated.

Disclosure – Dependent upon the amount of financial information you wish to share, the disclosure

requirements may be viewed favourably or unfavourably. At a minimum, issuers will be required to

submit yearly audited financial statements and a business disclosure statement at the time of issuance. If

the bonds are listed (which can procure favourable pricing) on the NZDX, issuers will also have to

comply with the exchange’s continuous disclosure requirements. For those considering an IPO in the

future or looking to impress greater financial discipline upon the business such requirements could

present an opportunity to do so.

Tenor – Unrated issuers can typically get funding out to 7 years which is longer than the bank loan

market that gets to 5 years for strong credits. Longer dated bonds can more easily be issued by formally

credit rated entities who can get funding for up to 10 years.

Timing - All up it takes about 12 weeks to issue a retail bond with the majority of this time spent on

documentation such as drafting of the product disclosure statement. However, once this is in place

future issuances can be completed in less time. For lesser known names and first time issuers, it may

also be preferable to complete an investor roadshow. By doing so, investors are likely to be more

comfortable with your credit and therefore may not require as high a coupon payment as compensation

for any unfamiliarity.


The ISDA Standard Initial Margin Model

The ISDA Standard Initial Margin Model (SIMM) affects every aspect of the non-cleared derivatives space:

pricing, funding, legal, IT, custody arrangement and margin calculation. It has been proposed or adopted in,

Canada, the European Union, Japan, Switzerland, United States, Australia, Singapore and Hong Kong.

Initially it is a requirement for banks only, where they must start exchanging initial and variation margin on their

non-cleared derivatives trades (i.e. intra-bank). This requirement will expand to include a wider universe of

derivatives users over time (i.e. corporates). It is expected that the requirement on banks will be phased in

through to 2020 and swap dealers will be the earliest and most significantly impacted.

The implementation of the new rules is presenting swap dealers and financial end-user counterparties with

various issues. Globally, banks will be required to hold more capital as operational and financial costs of

transactions will rise. There are other issues regarding stricter transfer timing, how minimum transfer amounts

will apply across multiple accounts and how existing positions will be affected. There are also cross border issues

to consider regarding which jurisdiction rules will apply, to whom they apply and what type of derivatives are

covered. As an alternative to the variation margin, some swap dealers and financial end-user counterparties are

finding it less cumbersome to negotiate their own variation margin changes to their Credit Support Annex’s

(CSAs).

Although corporates are initially excluded from capital and margin requirements, they will be impacted by the

rise in end-user prices reflecting the cost increases introduced by this new regulation (i.e. banks to pass on

additional costs). End-user corporates will find it hard to plan for the future when the regulatory environment is

unclear. With transaction costs for derivatives looking to increase, clients should be beginning to reserve an

adequate amount of cash or credit and start the process to alter their hedging strategies to adapt to this new

regulatory environment. Liquidity is also an important issue, clients may need to obtain and deploy additional

liquidity resources that exceed current practices to meet the new margin requirements. In the coming years it’s

looking like collateral management will become costly and complex to put into operation. Although this is a

challenge, it also presents an opportunity to capitalise on the disruption by strategically evolving processes to be

in line with the new regulations.


Dairy Future Updates

In May 2016 the NZX commenced a NZ Milk Futures contract to provide the opportunity for large and small

dairy farmers to proactively risk manage milk price movements and volatility. Whenever a new futures contract is

opened, its success depends upon active market participation.

Approaching one year on from the launch of the milk price futures and options contracts, we have seen promising

signs for growth in volume and participation. Trading volumes have remained above 200 contracts per month

since the seasonal peak of 960 executed contracts reached in August. As a result, futures pricing is becoming

more reflective of industry expectations for ‘fair value’.

There is still some way to go before a milk price forward curve is developed to provide a robust price discovery

mechanism. However, these advancements do not happen overnight. International and local experience is that it

can take up to two or three years for a new futures contract to gain traction, volume and liquidity.

It is up to all those with a vested interest in an active forward price market for the largest commodity our

economy produces, to continue supporting the new futures contract. As financial risk and volatility is reduced,

investment and borrowing decisions in the dairy industry should be easier to make and thus all participants in the

industry benefit.

0

200

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600

800

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1200

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May-16 Aug-16 Nov-16 Feb-17

Milk

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Milk Payout Futures Pricing and Volume Traded

Volume Traded (RHS) Farmgate Payout September 17 Future September 18 Future

Source NZX (2017)


DISCLAIMER: This publication is subject to the following restrictions. This publication should not be reproduced or supplied to any other

party without first obtaining our (PwC New Zealand) written consent. We accept no responsibility for any reliance that may be placed on

its content should it be used for any purpose other than that set out below and in any event we will accept no liability to any party other

than you in respect of its contents.

The purpose of the publication is to provide our current financial market views and opinions. The statements and opinions contained in

this report are based on data obtained from the financial markets and are so contained in good faith and in the belief that such statements,

opinions and data are not false or misleading. In preparing this publication, we have relied upon information which we believe to be reliable

and accurate.

We reserve the right (but will be under no obligation) to review our assessment and if we consider it necessary, to revise our opinion in

the light of any information existing at the date of this publication which becomes known to us after that date.

pwc.co.nz /corporate-treasury-advisory-services/

Get in touch

Stuart Henderson Partner T: +64 9 425 0158 M:+64 21 343 423 E: [email protected]

Roger Kerr Consultant T: +64 9 355 8181 M:+64 21 935 288 E: [email protected]

Brett Johanson Partner T: +64 4 462 7234 M:+64 21 771 574 E: [email protected]

Chris Hedley Director T: +64 9 355 8183 M: +64 21 479 680 E: [email protected]

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FX orders: Rules of Engagement 6 March 2017 · 2 Treasury Broadsheet | Quarterly newsletter of snippets and stories from the world of treasury management 6 March 2017 The rules of