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RMB internationalisation:
Perspectives on the future of RMB clearing
Executive summary
One year on from SWIFT’s 2011 white
paper1
, industry dialogue about the
internationalisation of the RMB has
continued to advance. In 2011, financial
institutions were trying to understand
what the internationalisation of the RMB
would mean for their businesses. Fast
forward to 2012, and the possibility of
“RMBification” is part of the strategy of
most global transaction banks.
Banks now have senior management
sponsored task forces looking to
identify and capitalise on developing
opportunities while protecting the
strength of their core franchises.
Transaction banks are focused on
evolving customer needs requiring
product development, system
enhancements and an understanding of
the evolving regulatory environment.
This white paper is for stakeholders
who are interested in the future of RMB
clearing and for transaction bankers
who are actively involved in the Offshore
RMB business. The opening sections will
provide a point of departure for common
understanding, while the remainder
of the paper is intended to spark
dialogue on the future of RMB clearing
and the evolution of the supporting
infrastructures.
Growing, but not quite there
The development of the RMB in trade
finance and investments has grabbed
Table of contents
	 Executive summary
	 Growing, but not quite there
	 Milestones in RMB
internationalisation
	 Offshore RMB clearing – the
current state of play
	 Developments in payment market
infrastructure and offshore markets
	 Market expectations around future
RMB clearing systems
	 How can SWIFT help?
	Acknowledgements
	 Glossary of abbreviations
White paper
Join the dialogue
about Offshore RMB
clearing for 2013 and
beyond
1	 ‘RMB Internationalisation: Implications for the global financial industry’, SWIFT, September 2011,
www.swift.com/products/renminbi?lang=en
the attention of the corporate sector and
financial community worldwide. In 2012,
the increasing use of RMB has also
been vigorously debated.
The debate mainly focuses on the
decline in Offshore RMB (CNH)
deposits in Hong Kong, describing its
change based on prediction (or not) of
appreciation. Hong Kong deposits have
not grown in 2012 due to several factors
including more approved channels to
allow for the flow of funds back to China
and increased investment options.
RMB Qualified Foreign Institutional
Investors (RQFII) and streamlining of the
process for foreign direct investment
(FDI) have helped to facilitate more
flow of funds back to China. This flow
of funds, combined with the increase
in RMB investment in dim sum bonds,
certificates of deposit and other
products, has resulted in a decrease in
customer deposits. This should be seen
as a positive sign in the development of
the RMB.
The path of RMB internationalisation
has been described in three phases
– first use for trade finance, then for
investment and in the longer term as a
reserve currency. The decline in Hong
Kong deposits shows the start of a
movement towards RMB for investment
purposes. Hong Kong is still the largest
offshore centre for customer deposits;
however, there has also been growth in
other centres like the United Kingdom
and Singapore. The development of
2
these centres is necessary in order to
lubricate RMB-based international trade.
The SWIFT business intelligence data,
from 10,118 financial institutions in 210
countries, shows tremendous growth in
the position of RMB in the list of world
payment currencies, advancing from
number 35th in October 2010 to number
14th in August 2012. So, regardless of
the market sentiment ebbs and flows,
we see during this longer time horizon
the continued increased global use of
RMB.
To provide a brief update on the RMB’s
progress to date, we looked at the
month-on-month value of payment
transactions (customer transfers and
institutional transfers). There was a
continuous increase from October 20102
until August 2011 – at which point there
was more volatility in payment value
(see Figure 1). It is clear that in May
and June 2012 we are coming close
to the peak reached in August 2011.
It is also important to realise that this
value growth in the RMB is against a
background of almost flat growth in
most other currencies.
Trade finance, the first stage of RMB
internationalisation, is still the primary
driver behind the increase in RMB-
denominated payment transactions (see
Figure 2). While the majority of trade
value will be captured in the above
payment values, we can also look at the
letter of credit values to see a measure
of growth.
In trade finance, the continued growth
can be attributed to corporations still
seeing favourable borrowing costs,
reduced foreign exchange (FX) risk
and possible improved supplier access
in paying in RMB. For corporations
that buy and sell goods in China the
use of RMB can provide a natural
hedge. It can also help to reduce costs
associated with transacting or funding
operations onshore. In the CNH market,
corporations have a greater ability to
manage their RMB exposure using FX
options and forwards. Finally, some
Chinese buyers and suppliers will prefer
to transact in local currency, which
can help foreign corporations broaden
their network of buyers and suppliers,
consequently improving their purchasing
power. This is why from a supply chain
FIGURE 1: RMB payments (MT 103 + MT 202 excluding cover) in transaction value
Source: SWIFT Value Analyser
Hong Kong China Other countries
O
ct-10
Jun-11
Feb-11
O
ct-11
M
ar-12
D
ec-10
Aug-11
Apr-11
D
ec-11
M
ay-12
N
ov-10
Jul-11
M
ar-11
N
ov-11
Apr-12
Jan-11
Sep-11
Feb-12
M
ay-11
Jan-12
Jun-12
FIGURE 2: RMB trade finance (MT 400 + MT 700) in transaction value
Source: SWIFT Value Analyser
Hong Kong China Other countries
O
ct-10
Jun-11
Feb-11
O
ct-11
M
ar-12
D
ec-10
Aug-11
Apr-11
D
ec-11
M
ay-12
N
ov-10
Jul-11
M
ar-11
N
ov-11
Apr-12
Jan-11
Sep-11
Feb-12
M
ay-11
Jan-12
Jun-12
2	 Time series showing value of transactions start in October 2010. Data on volume of transactions goes back further but is a less effective measure of growth
perspective, currency appreciation or
depreciation might be irrelevant.
This combination of factors has led
the PBOC to estimate that overseas
importers paying in RMB could save
2–3% on their invoices. While the
potential cost savings of using RMB can
help corporations, the industry still needs
to do further work to evaluate the exact
direct savings and if foreign corporations
are truly benefiting from the savings
related to RMB trade finance. Cost
advantages in addition to the relaxation
of documentary requirements and
administration procedures in China would
further help the future growth of RMB for
trade finance purposes.
All of the above SWIFT business
intelligence data supplies an absolute
value of the international use of RMB
for payment and trade finance. To
measure when a currency truly becomes
“internationalised” is a much more
challenging undertaking.
There is an in-depth project underway
to measure the relative growth in the
international use of the RMB. The
project is being sponsored by the SWIFT
Institute (established in April 2012),
which has given a research grant to
Jonathan Batten (Department of Finance,
Hong Kong University of Science
and Technology) and Peter Szilagyi
(Judge Business School, University of
Cambridge) to complete a study on RMB
internationalisation.
Their study will track the path of RMB
internationalisation to determine whether
a tipping point is approaching, or has
been reached. The resulting working
paper is expected to be issued in Q1
2013.
The SWIFT community does need an
answer to the redenomination question
to address the possible “RMBification”
of their businesses. However, for this
year’s white paper, the community was
strongly in favour of practical insights. As
3
a result, SWIFT and the industry editorial
board have decided to focus on the
future of RMB clearing. For the remainder
of this paper, we will describe the
current environment for Offshore RMB
clearing and potential developments
in payment market infrastructures. In
particular, we will highlight what the
market seeks in terms of the functionality
of infrastructures required to address
the needs of future RMB payment
transactions.
Offshore RMB developments are
dynamic. While we have made our best
efforts to ensure that this white paper
is as up to date as possible, we are
describing a fast-moving target. For
the latest news on the growth of the
RMB, we recommend you subscribe
to the SWIFT RMB Tracker by emailing
swiftforbanks@swift.com.
Milestones in RMB
internationalisation
Developments since the 2011 white
paper show the evolution of RMB
internationalisation (see Figure 3).
Chinese government policies and the
support of foreign central banks and
the private sector have been some
of the main drivers of the increasing
international use of the RMB.
While the regulatory environment has
become significantly more liberal,
cross-border payments with one leg in
mainland China still face restrictions.
Cross-border trade finance and cross-
border current account transactions
(e.g. dividends) can be done with limited
restrictions. However, cross-border
capital account transactions, RMB
outward direct investment (ODI) and
RMB FDI require governmental approval.
Interbank transfers, transfers between
corporations or individuals and transfers
between corporations and individuals
with both legs of the transaction
outside mainland China have had fewer
restrictions over the years.
Offshore RMB clearing – the
current state of play
In this section we look at the
infrastructure currently in place to
support the growing international use
of the RMB. Offshore RMB clearing
currently consists of either going through
the designated RMB Clearing Bank –
or settlement institution – or making
payments directly to an RMB Agent Bank
in China. The choice between these
two is typically based on the scope of
usage for the two accounts, the return on
investment/deposit and the complexity of
account-opening processes.
September 2011 —	Nigeria plans to invest 10% of FX reserves in RMB;
Chile, Thailand, Brazil and Venezuela to include RMB in
central bank reserves
October 2011 —	MOFCOM and PBOC issue new circulars on RMB FDI
December 2011 —	Rules published for RQFII pilot program
January 2012 —	Launch of private sector forum sponsored by HKMA and
UK treasury to cooperate on development of Offshore RMB
business
March 2012 —	Mainland Designated Enterprises list replaced; all licensed
importers and exporters can now settle in RMB with
companies outside China
—	Malaysia’s central bank extends RTGS service to include
RMB3
April 2012 —	PBOC states that China has decided to develop an
independent international payment system to facilitate cross-
border renminbi clearance, known as CIPS4
June 2012 —	HK RMB RTGS operating hours extended to 23:30; BOC HK
intraday repo service also extended to 23:30
—	HKMA, in partnership with J.P. Morgan and Euroclear,
launches a cross-border collateral management platform,
allowing the exchange of non-RMB collateral for Offshore
RMB assets
August 2012 —	Taiwan signs an MOU for cross-Strait currency clearing
arrangement with China
October 2012 —	Direct JPY/CNY quotes available
FIGURE 3: RMB internationalisation timeline
3	 Bank Negara Malaysia (BNM) press release, 21 March 2012
4	 ‘‘System to promote yuan use globally’, China Daily, 12 April 2012, www.chinadaily.com.cn/cndy/2012-04/12/content_15027521.htm
4
The RMB Agent Bank involves a
customer using a bank to settle directly
with a correspondent bank in China
(see Figure 4) and is estimated to be
between 20% and 30% of the RMB
clearing volume. One possible advantage
with this model is the option to keep
liquidity onshore and thus have access
to onshore time deposits and interest
rates, which could mean a better return
on investment/deposit. However, liquidity
is still a constraint since cash from PBOC
can only be withdrawn at 9:00 (UTC +8)
the next day.
The RMB Clearing Bank is estimated to
process 70% to 80% of Offshore RMB.
In Hong Kong, the first Clearing Bank
was established in 2003 when Bank
of China Hong Kong (BOC HK) was
appointed by the PBOC as the Clearing
Bank for Offshore RMB. In July 2010,
after consulting with the HKMA, the
PBOC signed a modified RMB clearing
agreement with BOC HK. The agreement
with the HKMA specified that Hong Kong
financial institutions should follow local
regulatory requirements and market
factors to develop the RMB business.
BOC HK acts as the central clearing
hub for Offshore RMB. The RMB real
time gross settlement (RTGS) system
provided by the HKMA and Hong Kong
Interbank Clearing Limited (HKICL)
provides the infrastructure to support
this hub. As of 27 August 2012, there
are 168 participants – 128 with a
presence in Hong Kong and 40 overseas
participants. The most up-to-date list of
RMB RTGS clearing members is available
at the HKICL website. Each bank on this
list opens a settlement account with the
RMB Clearing Bank.
The RMB Clearing Bank is an essential
part of the Offshore RMB infrastructure
(see Figure 5), as a central bank will
normally settle only in its own currency.
The Clearing Bank therefore holds the
settlement accounts and will be the
key provider of intraday liquidity for
those who have an account with it. It is
therefore critical that the RMB Clearing
Bank has appropriate access to liquidity.
It also needs to have a sufficiently high
credit rating so that participant banks are
comfortable leaving overnight balances.
The PBOC and HKMA have agreed
that BOC HK will function as the RMB
Clearing Bank in Hong Kong until 2016.
When this model was first developed,
counterparty risk was an issue.
Participating banks opened RMB nostro
accounts with BOC HK. BOC HK is
a commercial bank, which created
counterparty and concentration limit
exposures. A fiduciary account is now
used to address these limit risk concerns.
The fiduciary account arrangement
enables participating banks to transfer
liquidity from their RMB nostro accounts
with the Hong Kong RMB Clearing Bank
to the fiduciary account with PBOC
Shenzhen. This renders the exposure
and limits into sovereign risk rather
than commercial counterparty risk. As
participating banks usually have larger
sovereign exposure limits, this enables
them to grow their Offshore RMB
liquidity.
The BOC HK and RMB RTGS
infrastructure is an important one not
just for Hong Kong itself but also for
Hong Kong as a hub for the majority of
Offshore RMB transactions. Therefore,
a welcome development earlier this year
was the decision by the HKMA to extend
RMB RTGS operating hours until 23:30
local time (UTC +8). However, the Hong
Kong FX market and China National
Advanced Payment System (CNAPS)
both close at 17:00 (UTC +8), making
it impossible for European markets to
square positions overnight.
BOC HK, as the RMB Clearing Bank, has
also extended its intraday repo service
to match the extension of the HK RMB
RTGS. BOC HK is not authorised to
participate in the CNH market or buy/sell
RMB for non-trade purposes in the CNY
market. In the event of a disruption in the
Offshore RMB market, the participating
bank cannot sell non-RMB securities to
cover its collateral obligations. In 2012,
FIGURE 4: RMB agent bank model
Other banks/
customers
Other banks/
customers
Other banks/
customers
RMB agent bank
Mainland China
bank
People’s Bank of
China (CNAPS
system)
Message formats:
SWIFT MT (MT103/202)
Message formats:
MT 103/202 or
‘CMT’ or ‘CMX’
Account types:	– Individual
	 – Corporate
Message formats:
– SWIFT MT (MT 103/202)
FIGURE 5: RMB clearing bank model
Other banks/
customers
Other banks/
customers
Other banks/
customers
HK RMB RTGS
participant bank
Hong Kong clearing
bank (BOC HK)
People’s Bank of
China (CNAPS
system)
Message formats:
SWIFT MT (MT 103/202)
173 in the HK RMB RTGS
Account types:	– Individual
	 – Corporate
Message formats:
– SWIFT MT (MT 103/202)
Message formats:
‘CMT’ or ‘CMX’
5
the HKMA, J.P. Morgan and Euroclear
began offering a cross-border collateral
management service, enabling non-RMB
assets to be used to provide Offshore
RMB asset liquidity – enhancing liquidity
for the European time zones.
Other developments important for
the increasing global use of Offshore
RMB include the HKMA’s payment-
versus-payment (PvP) system, which
was developed to address Herstatt risk
through the simultaneous settlement
of two FX transactions by using the
associated payments. While PvP for
HKD/USD has been in place since
2000, the HKD/CNY facility started in
2005. As the RMB is not currently CLS-
eligible, PvP of RMB RTGS is critical as
it provides a unique channel to support
RMB FX transactions with HKD, EUR
and USD, as well as a regional link to
Indonesia for IDR and Malaysia for MYR.
Looking beyond the positive currency
and infrastructure developments to
support the increasing global use of
RMB, operational challenges still exist
for the RMB Clearing Bank, RMB Agent
Banks and banking participants globally.
One of these challenges includes banks’
internal representations of Offshore
RMB as ‘CNH’, while using the official
ISO currency code ‘CNY’ for external
communication. In 2009, the industry
began discussing the challenges of
translating the code ‘CNH’ to ‘CNY’
within their organisations. This discussion
was pressing because ‘CNH’ is not an
official ISO currency code and most
commercial bank, vendor-operated and
SWIFT systems are based only on ISO
currency codes.
In April 2011, the industry decided to
form three working groups to define
and document guidelines on the use
of SWIFT messages for Offshore RMB
transactions. The resulting work provides
a tactical solution for the immediate
needs of the industry. These guidelines
are available from SWIFT and are
an essential part in initiating bilateral
discussions between counterparties.
The latest version of the guidelines
was published on 30 June 2012 and
is available together with the working
group meeting minutes on the Offshore
CNY Best Practice community forum at
www.swiftcommunity.net. The industry
is deliberating the need for a strategic
solution to help address any need to
automate a currency with a single ISO
currency code, multiple spot rates
and yield curves together with multiple
clearing locations.
The other issue with the increase in RMB
transactions is the increased use of
financial messages containing non-Latin
characters, which can result in anti-
money laundering (AML) and sanctions
screening challenges for RMB payments.
While not an issue within China, the
use of Chinese characters is a complex
matter for foreign banks.
Currently the primary means of
transmitting non-Latin characters, for
example a beneficiary name, to China
is by using the Chinese Commercial
Codes (CCCs). The CCCs have a long
history since they were originally used
to transmit Chinese characters over
electronic telegraph. The format is the
same today with a four-digit code being
used to represent one Chinese character.
This may lead to potential gaps in
sanctions compliance – if a bank is
scanning only Latin names on regulatory
watch lists, it may inadvertently accept
payments from or make payments to a
sanctioned entity.
The need to accommodate non-Latin
characters in an international standard
continues to be widely discussed in
the community. A SWIFT advisory
group called the Payments Market
Practice Group (PMPG) has written a
paper to describe this issue in more
detail. The paper, ‘Handling of Multiple
Character Sets: Taking the Debate to the
Logical Level through Market Practice
Development’, was published in June
2010 on www.swift.com. It is necessary
that this discussion continues since this
industry challenge raises concerns for
many banks that want to control the risks
involved in transacting in RMB effectively.
In order to facilitate this, SWIFT is helping
progress the dialogue on the use of
non-Latin characters in FIN (a type of
financial message used in clearing) and
ISO 15022 messages. This is discussed
in more detail on page 8.
The current RMB clearing model
has served the industry well to date.
Commendable progress has been made
by BOC HK, HKMA, HKICL and the
industry in infrastructure developments.
SWIFT and our community are aware
that there are some significant challenges
that will need to be addressed to place
RMB on an even playing field with
other currencies from an operational
perspective.
Developments in payment
market infrastructure and
offshore markets
The primary RMB clearing centre is Hong
Kong. Hong Kong has developed to
assist in the global clearing of Offshore
RMB from different locations like the
United Kingdom, Singapore, etc. For
the purposes of this paper, a “spoke” is
defined as a location where there is a
pool of Offshore RMB liquidity outside
of mainland China, whereas a “hub” is
where Offshore RMB is cleared.5
This
paper also uses “Offshore RMB centres”
to refer to both the “hubs” and “spokes”
in their entirety.
Since 2009, many of the developing
Offshore RMB centres have been
focused on optimising the existing hub
in Hong Kong. Centres like Taiwan,
Singapore and the United Kingdom
are carefully considering aspects of
the continued use of the Hong Kong
hub. In 2012, there has started to be an
increased dialogue about the full range
of options for Offshore RMB centres. The
discussion includes:
1.	 Continuing to leverage the “hub”
(Hong Kong);
2.	 Developing a Clearing Bank with
RMB RTGS (replicating the Hong
Kong model locally);
3.	 Leveraging the development of the
China International Payment System
(CIPS)
Before discussing this on a country-
by-country basis, it is necessary to
take a view of the current status of
these centres by looking at the RMB
traffic volume from August 2012. RMB
payment (MT 103 + MT 202 excluding
5	 ‘From redback to greenback – the journey of renminbi from local circulation to reserve currency’, Joe M.K. Ng, 2012, Investing in Asian Offshore Currency Markets: The Shift
from Dollars to Renminbi, Palgrave Macmillan, forthcoming
6
MT 202 COV) volume of messages sent
and received by the top 10 countries
represents 92.7% of the worldwide
RMB traffic. Countries that are the top
10 Offshore RMB centres are shown in
Figure 6, with the associated percentage
market share of volume of payments.
Hong Kong has a first mover advantage,
which has resulted in the majority of
the liquidity, a developed RMB RTGS
infrastructure and a talent base for
continued innovation in RMB product
offering. China’s 12th Five-Year Plan
(2011–2015) includes the goal of
supporting Hong Kong’s development as
an Offshore RMB business centre. More
importantly, Hong Kong alone today has
the extended RMB cut-off processing
time that is intended to support
transactions from other regions. Hong
Kong also operates its RMB RTGS on all
global public holidays – Monday to Friday
– other than the first day of January.
Over time, Hong Kong might lose some
of this advantage to other emerging
centres like Shanghai, Taiwan, etc.
However, the previously mentioned
strengths of Offshore RMB liquidity,
support of China and a robust
infrastructure should help bring continued
benefits to Hong Kong in the future.
In London we have seen a significant
market created for Offshore RMB
deposits and FX trading. It is London’s
stated ambition to become a “western
hub” (not perhaps in the same way
this paper describes “hubs”) for the
international RMB market to complement
Hong Kong and other emerging centres.
London’s RMB clearing leverages Hong
Kong’s existing infrastructure. Clearing
RMB through Hong Kong has provided
London a fast time to market, which
in part has helped London create an
advantage in establishing itself as the
RMB gateway for the West. Since liquidity
of an Offshore RMB centre is of the
highest importance, London is expected
to focus on increasing the deposits and
to enter a swap agreement with China.
In the future, London could consider
options for its current clearing
arrangement due to the difference in
time zones. London may first evaluate
the benefits of developing its local RMB
clearing capability versus leveraging the
established infrastructure of Hong Kong.
We recognise that London has several
strengths as an Offshore RMB centre,
such as the experience of its financial
services and legal professionals, the legal
system itself, and established leadership
in international bond issuances and the
FX market. All these strengths can only
help the city grow its “western hub” in the
future.
At the time of writing, Singapore has a
smaller amount of RMB deposits than
Hong Kong and London. However, we
have seen a significant increase in FX
volumes in Singapore, which seems
a logical strength since it is generally
accepted to be the largest FX trading
centre in Asia. Singapore is also currently
using Hong Kong as a hub for Offshore
RMB settlement. While Hong Kong is
acting as a hub, Singapore might also
consider a local RMB Clearing Bank.
If successful in this endeavour, it is
expected that Singapore may look to
enhance its RTGS, creating a model
similar to Hong Kong’s.
In Malaysia, the financial community
appears focused on leveraging its
strength in CNY/MYR trading. A BNM
press release on 21 March 2012
announced that Malaysia’s Real Time
Electronic Transfer of Funds and
Securities (RENTAS) system would
extend its RTGS services to include the
RMB. Considering the infrastructural
linkage of Malaysia’s RENTAS with
HK’s RTGS and the settlement agent
relationship between Hong Kong and
Malaysia’s RMB Clearing Bank, Hong
Kong has emerged as the de facto
Offshore RMB settlement hub for
Malaysia.
For Taiwan, cross-Strait trade is
substantial and has the potential to
increase further. Taiwanese commercial
banks are currently leveraging the
Hong Kong hub. To promote financial
cooperation, the PBOC and the Central
Bank of the Republic of China (Taiwan)
have signed a cross-Strait currency
clearing MOU. The agreement was
signed at the end of August 2012 and is
scheduled to take effect in 60 days from
that date. A new spot rate is expected
FIGURE 6: Top 10 Offshore RMB centres and market share of payment volumes
China
5.2%
Hong Kong
72.8%
UK
3%
Singapore
2.6%
Malaysia
2.3%
US
1.9%
Macau
1.6%
France
1.4%
Mongolia
1.1%
Taiwan
0.9%
Offshore RMB clearing centre
Possible offshore clearing centre 2013+
Offshore RMB trading centre
7
to be created for the interbank market,
denoted by “CNT” (not an official ISO
currency code).
The MOU lays out plans for Taiwan to
select a TWD settlement institution for
China. At the same time, the PBOC will
select a RMB Clearing Bank for CNY for
Taiwan. There will still, however, be some
challenges such as how to navigate
rules and regulations, especially with two
non-convertible currencies. At the time
of writing, Bank of Taiwan has already
been selected as the TWD settlement
institution in mainland China. Based on
2012 data, Taiwan’s sent and received
CNY payments make up around 1% of
the Hong Kong volume. New regulation
has been issued in Taiwan that implies
that the overseas business unit should
use this new CNY clearing route versus
going through Hong Kong. We expect to
start seeing a shift in liquidity away from
Hong Kong by the end of 2012.
In the longer term, the key onshore
centre for renminbi business will likely
be located in Shanghai. China has
decided to construct Shanghai as an
international financial centre, but the
legal environment, financial derivatives
and regulation expertise are not fully
prepared. In the next decade, the 12th
Five-Year Plan is expected to promote
profound reform in the financial sector.
Macau is already established as an
Offshore RMB hub for local transactions
and will continue to play an important
role. The US, France and Mongolia
are all in the top 10 and are spokes
to the Hong Kong hub. They have the
potential to play a bigger role in the future
development of infrastructure although
they have no publically stated plans.
At the time of writing, the majority of
markets have leveraged Hong Kong
as a hub for Offshore RMB clearing.
The expansion of Offshore RMB hubs
such as Hong Kong will ultimately
depend on the strategy adopted by
the PBOC towards these centres. The
ability for local clearing might be viewed
by countries as a key element for the
continued evolution of their financial
centre. Other nations might want to
control trade and currency issues on
their own terms, in their own regions, and
by their own rules. Whatever the initial
motivation for these developments, their
speed of processing payment, operating
hours and other value-added services
will be possible points of differentiation.
A goal should be to level the playing field
for RMB with other currencies.
Market expectations around
future RMB clearing systems
The community view is that the existing
arrangement for Offshore RMB clearing
is appropriate in the current environment.
In the medium-to-long term, however, it
may be important to have an enhanced
platform that can address the need for
longer operating hours to cover various
time zones and lower the amount and
cost of liquidity required to support these
transactions. The following section is
intended to be a practical starting point
for dialogue related to the development
of a future cross-border RMB clearing
system.
The cross-border USD clearing and
settlement may provide an example
for what the future of RMB clearing
can resemble. Local and regional
USD systems have been developed
but the advantages have diminished
over time because of the US system’s
enhanced operating hours and efficient
use of liquidity due to the netting of the
transaction. A typical USD payment can
now be settled within seconds. This is
why some industry participants prefer the
use of centralised clearing bodies with
many participants, continual technology
and proven contingency support, and
finality based on funds placed with the
Central Bank.
While this has clearly worked for USD
we cannot assume it will be the same
for RMB because China is taking a
measured approach in opening its
economy. As a result, there is a need
for the “firewall” between the domestic
economy and the growing Offshore RMB
market. Therefore, there will be more
complexities in the payment process.
There is no public documentation
available to evaluate the functionality
of a future cross-border RMB clearing
system – however, in this paper, some
assumptions will be made. The first
is that any such system will apply the
most recent industry recommendations
for world-class critical infrastructures.
We are certain that, if this is a PBOC
initiative, as a drafting member any
new infrastructure it moves forward
with will comply with the April 2012
CPSS-IOSCO revised principles called
the new Principles for Financial Market
Infrastructures (PFMI). PFMI covers the
operation and governance of high- and
low-value payment systems, central
clearing counterparties (CCPs), central
securities depositories (CSDs) and
trade repositories. The aim of PFMI is
to set international standards and best
practice to secure robustness, efficient
operational procedures and effective
risk management within the market
infrastructure community.
The primary goal of a future RMB
clearing system is to support the need for
seamless routing of RMB payments not
only within China but for RMB payments
around the world. In order to have
seamless routing of payments, access
or reach is critical. It should be expected
that an ideal model will connect to both
domestic and overseas banks as its
direct participants.
It is also critical that the community be
able to exchange electronic payment
information in globally accepted
message standards. It is expected
that international standard messaging
formats, most likely ISO 20022, will be
selected for communication between
a future RMB clearing system and
its direct participants. The use of
international standards by the clearing
system is welcomed. However, there will
be a requirement for investment at the
commercial banks to translate between
ISO 20022 and ISO 15022, since ISO
15022 is currently the most common
standard for payments in the international
markets.
An international repository of reference
data is also critical for the seamless
routing of payments. It is requested that
any new participant code be compatible
with the Bank Identifier Code (BIC) and
published in both the local language
and in English for international use by
participating banks. Use of international
and reference data standards will
improve the quality and efficiency of the
clearing system.
If a future RMB clearing system allows
for both Chinese and Latin characters
in the message standard then this
can be a complex matter for global
8
transaction banks. Today, CCCs are used
as a workaround to address the use of
Chinese characters in the MT standard
messages and the resulting problem and
risks in this practice are described on
page 5 of this paper.
SWIFT acknowledges that for many
institutions the MT standard will continue
to play a significant role, whether
exchanged between organisations or
used as an internal data format, and the
MT standard is constrained to a limited,
Latin-only character set. SWIFT also
understands that many of the legacy
applications and platforms that are used
to process payments in the region are
incapable of supporting natively anything
but Latin characters. Both limitations
present difficulties for service providers
that wish to support name, address
and remittance information in Chinese
characters.
SWIFT is therefore discussing with the
broader community an enhancement
to certain fields in MT messages that
would enable them to convey non-Latin
characters encoded as code numbers
based on the Unicode standard. This
development should allow Chinese
characters to be passed through the
payments system via legacy standards
and applications, although it might not
fully address the sanction screening
challenge. Use of such an enhancement
would be deployed on a strictly “opt-in”
basis, protecting non-participants from
receiving messages that they are unable
to process. The discussion is still at an
early stage, and SWIFT continues to
consult with the industry on the value and
feasibility of this suggestion.
Direct participants would also want
information to monitor their payments,
accounts (settlement and liquidity),
reserves and alerts, and to make
adjustments accordingly. As several
payment systems already offer an
automated, web-based user interface
to support these functionalities, we can
expect that a future RMB clearing system
will provide similar functionality in addition
to intraday and end-of-day statements.
In terms of liquidity management, its
soundness depends not just on the
management of the liquidity position
in the bank’s settlement accounts but
also involves securing the amount of
liquidity and establishing its cost. Efficient
collateral management is required.
Some additional features, which are
not required but would be an additional
benefit, are netting, gross settlement
and PvP. PvP is important because
any future system could eventually work
towards the elimination of Herstatt risk
for RMB. This system could work with
existing multi-currency RTGS systems
with RMB capabilities by providing
access to Offshore RMB centres while
the local RTGS addresses Herstatt risk,
or work with CLS once RMB becomes
an eligible currency to work toward
mitigating this risk.
A future RMB clearing system is
expected to create efficiency; however,
there will be some challenges for the
industry related to the translation of
international standards, reference data
and the use non-Latin characters that will
require continued dialogue and industry
cooperation. This development is
expected to be a game changer for RMB
payments and the industry is enthusiastic
about being involved in the continued
dialogue.
How can SWIFT help?
Last year’s white paper identified three
key areas where SWIFT could help in the
internationalisation of the RMB.
The first was to facilitate the processing
of Offshore RMB in financial transactions
and to increase automation. SWIFT
facilitated the Offshore CNY Working
Groups to discuss the problems in
processing Offshore RMB transactions.
We produced the ‘Offshore CNY
Guidelines for SWIFT MT and ISO 15022’
in February 2012, describing the use of
structured codes in FIN messages for
customers who are converting ‘CNH’ to
‘CNY’. There is also an updated version
2.1 from 30 June 2012 that includes
payment nature codes and can be
found on www.swiftcommunity.net or
by contacting your SWIFT relationship
manager.
The second area was to help broaden the
industry’s understanding of the benefits
of the RMB. Our 2011 whitepaper was
a start and this paper is an extension of
that series. SWIFT also publishes the
RMB Monthly Tracker, which has been
very well received by the community.
The third goal was to provide detailed
business insights into RMB volumes so
as to track market share and identify
new business opportunities. SWIFT has
a comprehensive Business Intelligence
offering with supporting consulting work
allowing flow analysis, tracking market
evolution and benchmarking versus the
market.
Through our engagement with banks on
the future of RMB clearing, it has become
clear that there are other areas where
banks are looking for SWIFT’s support:
The future RMB clearing system will likely
be built using international standards
such as ISO 20022. SWIFT can provide
translation support to participants for
the translation between MT and ISO
20022. This allows faster deployment of
the solution since it allows participants to
defer, minimise or avoid upgrading legacy
systems while offering compatibility.
With the introduction of ISO 20022, non-
Latin characters can be used on the
SWIFT network. For many institutions
the MT standard will continue to play a
significant role and many of the legacy
applications and platforms that are used
to process payments around the world
are incapable of supporting anything
but Latin characters. SWIFT is therefore
discussing with the broader community
an enhancement to certain fields in
MT messages that would enable them
to convey non-Latin characters as
code numbers based on the Unicode
standard.
Lastly, the codes used in any future RMB
clearing system, and their compatibility
with BIC codes, are critical for seamless
global processing of payments. SWIFT
is working to ensure compatibility of
the codes and availability of directory
information where mapping is needed.
For more insights into recent RMB transaction
flows and which countries to focus on for your
RMB business development,please contact
swiftforbanks@swift.com for more information
about our business intelligence products and
services.
99
Acknowledgements
Many individuals and organisations have helped in the preparation of this white paper. SWIFT would particularly like to thank our
industry editorial board, which helped in setting the overall editorial direction, guiding the content and preparation.
Bank of America Merrill Lynch
Ms Catherine Li, Mr Kuresh Sarjan, Ms Chandana Thanthrige, Ms Clara Wang, Mr Alan Wong and Mr Derek Yan
Bank of China (Hong Kong) Limited
Mr Ching Kwok Leung, Mr Steve Wong, Mr Jack Yang and Mr Winston Ye
Bank of Communications
Ms Shi MeiYi
Citibank
Ms Rani Gu, Mr Amol Gupte, Mr Philippe Jaccard and Ms Carmen Ling
HSBC
Mr Stéphan Levieux and Mr Sathya Ram
J.P. Morgan
Ms Ann Lin Khoo, Mr Masayuki Tagai and Ms Lily Zou
The Royal Bank of Scotland
Ms Shirley Chan
Standard Chartered Bank
Mr Frankie Au, Mr R Madhavan, Mr Joe M.K. Ng, Ms Kaiti Pei, Ms Sonia Rossetti, Mr Stephen Street and Mr Michael Vrontamitis
Glossary of abbreviations
AML Anti-money laundering – procedures, laws or regulations in place to prevent,
detect and report money laundering activities
BIC Bank Identification Code
BOC HK Bank of China (Hong Kong)
CCC Chinese Commercial Codes
CIPS China International Payment System
CLS Continuous Linked Settlement – an industry initiative that aims to significantly
reduce foreign exchange settlement risk through simultaneous exchange of net
currency values
CNAPS China National Advanced Payment System
CNH Offshore yuan/renminbi – denotes Chinese currency traded outside mainland
China, mainly in Hong Kong. There is only one official ISO currency code for the
Chinese yuan and that is ‘CNY’ (see CNY and RMB)
CNY ISO currency code denoting the Chinese yuan, otherwise known as renminbi.
Yuan is the basic monetary unit of China, while renminbi is the system of
currency. CNY also denotes onshore RMB – Chinese currency traded within
mainland China (see RMB and CNH)
CPSS-IOSCO A joint initiative of the Committee on Payment and Settlement Systems and the
International Organization of Securities Commissions
CSD Central securities depository
EUR ISO currency code denoting the euro
FDI Foreign direct investment
FIN SWIFT’s messaging service that enables the secure and reliable exchange of MT
messages in store-and-forward mode
FX Foreign exchange
IDR ISO currency code denoting the Indonesian rupiah
ISO International Organization for Standardization
10
JPY ISO currency code denoting the Japanese yen
MOFCOM Ministry of Commerce, People’s Republic of China
MOU Memorandum of understanding
MT Message Type – denotes the data used to identify information within a standard
SWIFT format message. Standard formats are:
- MT 103: payment instruction (customer)
- MT 202: payment instruction (bank)
- MT 210: advice of funds/pre-advice (customer)
- MT 300: foreign exchange confirmation
- MT 545: receive against payment confirmation
- MT 547: deliver against payment confirmation
- MT 940: detailed bank statement information
- MT 950: summary bank statement information
MYR ISO currency code denoting the Malaysian ringgit
ODI Outbound direct investment
PBOC People’s Bank of China
PFMI Principles for Financial Market Infrastructures – a report published by the CPSS-
IOSCO committee
PMPG Payments Market Practice Group, a SWIFT advisory group
PvP Payment-versus-payment – a system wherein transfer of a payment in one
currency occurs only if the final transfer of a payment in another currency or
currencies takes place
QFII Qualified Foreign Institutional Investor; the QFII scheme allows foreign fund
managers to convert foreign currencies into RMB to invest in China
RMB Renminbi – the currency of mainland China; otherwise known as yuan. Renminbi
is China’s system of currency, while yuan is the basic monetary unit (see CNY
and CNH)
RQFII Renminbi Qualified Foreign Institutional Investor; the RQFII scheme allows
Chinese fund houses to establish RMB-denominated funds in Hong Kong for
investment in mainland China
RTGS Real-time gross settlement
SWIFT Society for Worldwide Interbank Financial Telecommunication – a cooperative
organisation created and owned by member banks to facilitate the transfer of
information and payments/advice instructions between each other via a global
data network
TWD ISO currency code denoting the new Taiwan dollar
USD ISO currency code denoting the US dollar
11
Legal Notices
Copyright
Copyright © S.W.I.F.T. SCRL (“SWIFT”), Avenue Adèle 1, B-1310 La Hulpe, Belgium, 2012. All rights reserved.
Reproduction is authorised provided the source is acknowledged.
Trademarks
SWIFT, S.W.I.F.T., the SWIFT logo, Sibos, Accord and SWIFT-derived product and service names – such as but not limited
to SWIFTNet, Alliance and SWIFT Standards – are trademarks of S.W.I.F.T. SCRL.
SWIFT is the trading name of S.W.I.F.T. SCRL.
All other product or company names that may be mentioned in this document are trademarks or registered trademarks of
their respective owners.
Disclaimer
This white paper is provided for information only. If a customer or any third party decides to take any course of action or
omission based on this report and/or any conclusion contained therein, they shall do so at their own risk and SWIFT shall
not be liable for any loss or damage, arising from their acts or omissions based on this report and/or any recommendations
contained therein.
For more information about SWIFT
visit swift.com
To join the community debate
visit swiftcommunity.net
SWIFT © 2012
56103-OCT2012

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Join the dialogue about Offshore RMB clearing for 2013 and beyond

  • 1. 1 RMB internationalisation: Perspectives on the future of RMB clearing Executive summary One year on from SWIFT’s 2011 white paper1 , industry dialogue about the internationalisation of the RMB has continued to advance. In 2011, financial institutions were trying to understand what the internationalisation of the RMB would mean for their businesses. Fast forward to 2012, and the possibility of “RMBification” is part of the strategy of most global transaction banks. Banks now have senior management sponsored task forces looking to identify and capitalise on developing opportunities while protecting the strength of their core franchises. Transaction banks are focused on evolving customer needs requiring product development, system enhancements and an understanding of the evolving regulatory environment. This white paper is for stakeholders who are interested in the future of RMB clearing and for transaction bankers who are actively involved in the Offshore RMB business. The opening sections will provide a point of departure for common understanding, while the remainder of the paper is intended to spark dialogue on the future of RMB clearing and the evolution of the supporting infrastructures. Growing, but not quite there The development of the RMB in trade finance and investments has grabbed Table of contents Executive summary Growing, but not quite there Milestones in RMB internationalisation Offshore RMB clearing – the current state of play Developments in payment market infrastructure and offshore markets Market expectations around future RMB clearing systems How can SWIFT help? Acknowledgements Glossary of abbreviations White paper Join the dialogue about Offshore RMB clearing for 2013 and beyond 1 ‘RMB Internationalisation: Implications for the global financial industry’, SWIFT, September 2011, www.swift.com/products/renminbi?lang=en the attention of the corporate sector and financial community worldwide. In 2012, the increasing use of RMB has also been vigorously debated. The debate mainly focuses on the decline in Offshore RMB (CNH) deposits in Hong Kong, describing its change based on prediction (or not) of appreciation. Hong Kong deposits have not grown in 2012 due to several factors including more approved channels to allow for the flow of funds back to China and increased investment options. RMB Qualified Foreign Institutional Investors (RQFII) and streamlining of the process for foreign direct investment (FDI) have helped to facilitate more flow of funds back to China. This flow of funds, combined with the increase in RMB investment in dim sum bonds, certificates of deposit and other products, has resulted in a decrease in customer deposits. This should be seen as a positive sign in the development of the RMB. The path of RMB internationalisation has been described in three phases – first use for trade finance, then for investment and in the longer term as a reserve currency. The decline in Hong Kong deposits shows the start of a movement towards RMB for investment purposes. Hong Kong is still the largest offshore centre for customer deposits; however, there has also been growth in other centres like the United Kingdom and Singapore. The development of
  • 2. 2 these centres is necessary in order to lubricate RMB-based international trade. The SWIFT business intelligence data, from 10,118 financial institutions in 210 countries, shows tremendous growth in the position of RMB in the list of world payment currencies, advancing from number 35th in October 2010 to number 14th in August 2012. So, regardless of the market sentiment ebbs and flows, we see during this longer time horizon the continued increased global use of RMB. To provide a brief update on the RMB’s progress to date, we looked at the month-on-month value of payment transactions (customer transfers and institutional transfers). There was a continuous increase from October 20102 until August 2011 – at which point there was more volatility in payment value (see Figure 1). It is clear that in May and June 2012 we are coming close to the peak reached in August 2011. It is also important to realise that this value growth in the RMB is against a background of almost flat growth in most other currencies. Trade finance, the first stage of RMB internationalisation, is still the primary driver behind the increase in RMB- denominated payment transactions (see Figure 2). While the majority of trade value will be captured in the above payment values, we can also look at the letter of credit values to see a measure of growth. In trade finance, the continued growth can be attributed to corporations still seeing favourable borrowing costs, reduced foreign exchange (FX) risk and possible improved supplier access in paying in RMB. For corporations that buy and sell goods in China the use of RMB can provide a natural hedge. It can also help to reduce costs associated with transacting or funding operations onshore. In the CNH market, corporations have a greater ability to manage their RMB exposure using FX options and forwards. Finally, some Chinese buyers and suppliers will prefer to transact in local currency, which can help foreign corporations broaden their network of buyers and suppliers, consequently improving their purchasing power. This is why from a supply chain FIGURE 1: RMB payments (MT 103 + MT 202 excluding cover) in transaction value Source: SWIFT Value Analyser Hong Kong China Other countries O ct-10 Jun-11 Feb-11 O ct-11 M ar-12 D ec-10 Aug-11 Apr-11 D ec-11 M ay-12 N ov-10 Jul-11 M ar-11 N ov-11 Apr-12 Jan-11 Sep-11 Feb-12 M ay-11 Jan-12 Jun-12 FIGURE 2: RMB trade finance (MT 400 + MT 700) in transaction value Source: SWIFT Value Analyser Hong Kong China Other countries O ct-10 Jun-11 Feb-11 O ct-11 M ar-12 D ec-10 Aug-11 Apr-11 D ec-11 M ay-12 N ov-10 Jul-11 M ar-11 N ov-11 Apr-12 Jan-11 Sep-11 Feb-12 M ay-11 Jan-12 Jun-12 2 Time series showing value of transactions start in October 2010. Data on volume of transactions goes back further but is a less effective measure of growth perspective, currency appreciation or depreciation might be irrelevant. This combination of factors has led the PBOC to estimate that overseas importers paying in RMB could save 2–3% on their invoices. While the potential cost savings of using RMB can help corporations, the industry still needs to do further work to evaluate the exact direct savings and if foreign corporations are truly benefiting from the savings related to RMB trade finance. Cost advantages in addition to the relaxation of documentary requirements and administration procedures in China would further help the future growth of RMB for trade finance purposes. All of the above SWIFT business intelligence data supplies an absolute value of the international use of RMB for payment and trade finance. To measure when a currency truly becomes “internationalised” is a much more challenging undertaking. There is an in-depth project underway to measure the relative growth in the international use of the RMB. The project is being sponsored by the SWIFT Institute (established in April 2012), which has given a research grant to Jonathan Batten (Department of Finance, Hong Kong University of Science and Technology) and Peter Szilagyi (Judge Business School, University of Cambridge) to complete a study on RMB internationalisation. Their study will track the path of RMB internationalisation to determine whether a tipping point is approaching, or has been reached. The resulting working paper is expected to be issued in Q1 2013. The SWIFT community does need an answer to the redenomination question to address the possible “RMBification” of their businesses. However, for this year’s white paper, the community was strongly in favour of practical insights. As
  • 3. 3 a result, SWIFT and the industry editorial board have decided to focus on the future of RMB clearing. For the remainder of this paper, we will describe the current environment for Offshore RMB clearing and potential developments in payment market infrastructures. In particular, we will highlight what the market seeks in terms of the functionality of infrastructures required to address the needs of future RMB payment transactions. Offshore RMB developments are dynamic. While we have made our best efforts to ensure that this white paper is as up to date as possible, we are describing a fast-moving target. For the latest news on the growth of the RMB, we recommend you subscribe to the SWIFT RMB Tracker by emailing swiftforbanks@swift.com. Milestones in RMB internationalisation Developments since the 2011 white paper show the evolution of RMB internationalisation (see Figure 3). Chinese government policies and the support of foreign central banks and the private sector have been some of the main drivers of the increasing international use of the RMB. While the regulatory environment has become significantly more liberal, cross-border payments with one leg in mainland China still face restrictions. Cross-border trade finance and cross- border current account transactions (e.g. dividends) can be done with limited restrictions. However, cross-border capital account transactions, RMB outward direct investment (ODI) and RMB FDI require governmental approval. Interbank transfers, transfers between corporations or individuals and transfers between corporations and individuals with both legs of the transaction outside mainland China have had fewer restrictions over the years. Offshore RMB clearing – the current state of play In this section we look at the infrastructure currently in place to support the growing international use of the RMB. Offshore RMB clearing currently consists of either going through the designated RMB Clearing Bank – or settlement institution – or making payments directly to an RMB Agent Bank in China. The choice between these two is typically based on the scope of usage for the two accounts, the return on investment/deposit and the complexity of account-opening processes. September 2011 — Nigeria plans to invest 10% of FX reserves in RMB; Chile, Thailand, Brazil and Venezuela to include RMB in central bank reserves October 2011 — MOFCOM and PBOC issue new circulars on RMB FDI December 2011 — Rules published for RQFII pilot program January 2012 — Launch of private sector forum sponsored by HKMA and UK treasury to cooperate on development of Offshore RMB business March 2012 — Mainland Designated Enterprises list replaced; all licensed importers and exporters can now settle in RMB with companies outside China — Malaysia’s central bank extends RTGS service to include RMB3 April 2012 — PBOC states that China has decided to develop an independent international payment system to facilitate cross- border renminbi clearance, known as CIPS4 June 2012 — HK RMB RTGS operating hours extended to 23:30; BOC HK intraday repo service also extended to 23:30 — HKMA, in partnership with J.P. Morgan and Euroclear, launches a cross-border collateral management platform, allowing the exchange of non-RMB collateral for Offshore RMB assets August 2012 — Taiwan signs an MOU for cross-Strait currency clearing arrangement with China October 2012 — Direct JPY/CNY quotes available FIGURE 3: RMB internationalisation timeline 3 Bank Negara Malaysia (BNM) press release, 21 March 2012 4 ‘‘System to promote yuan use globally’, China Daily, 12 April 2012, www.chinadaily.com.cn/cndy/2012-04/12/content_15027521.htm
  • 4. 4 The RMB Agent Bank involves a customer using a bank to settle directly with a correspondent bank in China (see Figure 4) and is estimated to be between 20% and 30% of the RMB clearing volume. One possible advantage with this model is the option to keep liquidity onshore and thus have access to onshore time deposits and interest rates, which could mean a better return on investment/deposit. However, liquidity is still a constraint since cash from PBOC can only be withdrawn at 9:00 (UTC +8) the next day. The RMB Clearing Bank is estimated to process 70% to 80% of Offshore RMB. In Hong Kong, the first Clearing Bank was established in 2003 when Bank of China Hong Kong (BOC HK) was appointed by the PBOC as the Clearing Bank for Offshore RMB. In July 2010, after consulting with the HKMA, the PBOC signed a modified RMB clearing agreement with BOC HK. The agreement with the HKMA specified that Hong Kong financial institutions should follow local regulatory requirements and market factors to develop the RMB business. BOC HK acts as the central clearing hub for Offshore RMB. The RMB real time gross settlement (RTGS) system provided by the HKMA and Hong Kong Interbank Clearing Limited (HKICL) provides the infrastructure to support this hub. As of 27 August 2012, there are 168 participants – 128 with a presence in Hong Kong and 40 overseas participants. The most up-to-date list of RMB RTGS clearing members is available at the HKICL website. Each bank on this list opens a settlement account with the RMB Clearing Bank. The RMB Clearing Bank is an essential part of the Offshore RMB infrastructure (see Figure 5), as a central bank will normally settle only in its own currency. The Clearing Bank therefore holds the settlement accounts and will be the key provider of intraday liquidity for those who have an account with it. It is therefore critical that the RMB Clearing Bank has appropriate access to liquidity. It also needs to have a sufficiently high credit rating so that participant banks are comfortable leaving overnight balances. The PBOC and HKMA have agreed that BOC HK will function as the RMB Clearing Bank in Hong Kong until 2016. When this model was first developed, counterparty risk was an issue. Participating banks opened RMB nostro accounts with BOC HK. BOC HK is a commercial bank, which created counterparty and concentration limit exposures. A fiduciary account is now used to address these limit risk concerns. The fiduciary account arrangement enables participating banks to transfer liquidity from their RMB nostro accounts with the Hong Kong RMB Clearing Bank to the fiduciary account with PBOC Shenzhen. This renders the exposure and limits into sovereign risk rather than commercial counterparty risk. As participating banks usually have larger sovereign exposure limits, this enables them to grow their Offshore RMB liquidity. The BOC HK and RMB RTGS infrastructure is an important one not just for Hong Kong itself but also for Hong Kong as a hub for the majority of Offshore RMB transactions. Therefore, a welcome development earlier this year was the decision by the HKMA to extend RMB RTGS operating hours until 23:30 local time (UTC +8). However, the Hong Kong FX market and China National Advanced Payment System (CNAPS) both close at 17:00 (UTC +8), making it impossible for European markets to square positions overnight. BOC HK, as the RMB Clearing Bank, has also extended its intraday repo service to match the extension of the HK RMB RTGS. BOC HK is not authorised to participate in the CNH market or buy/sell RMB for non-trade purposes in the CNY market. In the event of a disruption in the Offshore RMB market, the participating bank cannot sell non-RMB securities to cover its collateral obligations. In 2012, FIGURE 4: RMB agent bank model Other banks/ customers Other banks/ customers Other banks/ customers RMB agent bank Mainland China bank People’s Bank of China (CNAPS system) Message formats: SWIFT MT (MT103/202) Message formats: MT 103/202 or ‘CMT’ or ‘CMX’ Account types: – Individual – Corporate Message formats: – SWIFT MT (MT 103/202) FIGURE 5: RMB clearing bank model Other banks/ customers Other banks/ customers Other banks/ customers HK RMB RTGS participant bank Hong Kong clearing bank (BOC HK) People’s Bank of China (CNAPS system) Message formats: SWIFT MT (MT 103/202) 173 in the HK RMB RTGS Account types: – Individual – Corporate Message formats: – SWIFT MT (MT 103/202) Message formats: ‘CMT’ or ‘CMX’
  • 5. 5 the HKMA, J.P. Morgan and Euroclear began offering a cross-border collateral management service, enabling non-RMB assets to be used to provide Offshore RMB asset liquidity – enhancing liquidity for the European time zones. Other developments important for the increasing global use of Offshore RMB include the HKMA’s payment- versus-payment (PvP) system, which was developed to address Herstatt risk through the simultaneous settlement of two FX transactions by using the associated payments. While PvP for HKD/USD has been in place since 2000, the HKD/CNY facility started in 2005. As the RMB is not currently CLS- eligible, PvP of RMB RTGS is critical as it provides a unique channel to support RMB FX transactions with HKD, EUR and USD, as well as a regional link to Indonesia for IDR and Malaysia for MYR. Looking beyond the positive currency and infrastructure developments to support the increasing global use of RMB, operational challenges still exist for the RMB Clearing Bank, RMB Agent Banks and banking participants globally. One of these challenges includes banks’ internal representations of Offshore RMB as ‘CNH’, while using the official ISO currency code ‘CNY’ for external communication. In 2009, the industry began discussing the challenges of translating the code ‘CNH’ to ‘CNY’ within their organisations. This discussion was pressing because ‘CNH’ is not an official ISO currency code and most commercial bank, vendor-operated and SWIFT systems are based only on ISO currency codes. In April 2011, the industry decided to form three working groups to define and document guidelines on the use of SWIFT messages for Offshore RMB transactions. The resulting work provides a tactical solution for the immediate needs of the industry. These guidelines are available from SWIFT and are an essential part in initiating bilateral discussions between counterparties. The latest version of the guidelines was published on 30 June 2012 and is available together with the working group meeting minutes on the Offshore CNY Best Practice community forum at www.swiftcommunity.net. The industry is deliberating the need for a strategic solution to help address any need to automate a currency with a single ISO currency code, multiple spot rates and yield curves together with multiple clearing locations. The other issue with the increase in RMB transactions is the increased use of financial messages containing non-Latin characters, which can result in anti- money laundering (AML) and sanctions screening challenges for RMB payments. While not an issue within China, the use of Chinese characters is a complex matter for foreign banks. Currently the primary means of transmitting non-Latin characters, for example a beneficiary name, to China is by using the Chinese Commercial Codes (CCCs). The CCCs have a long history since they were originally used to transmit Chinese characters over electronic telegraph. The format is the same today with a four-digit code being used to represent one Chinese character. This may lead to potential gaps in sanctions compliance – if a bank is scanning only Latin names on regulatory watch lists, it may inadvertently accept payments from or make payments to a sanctioned entity. The need to accommodate non-Latin characters in an international standard continues to be widely discussed in the community. A SWIFT advisory group called the Payments Market Practice Group (PMPG) has written a paper to describe this issue in more detail. The paper, ‘Handling of Multiple Character Sets: Taking the Debate to the Logical Level through Market Practice Development’, was published in June 2010 on www.swift.com. It is necessary that this discussion continues since this industry challenge raises concerns for many banks that want to control the risks involved in transacting in RMB effectively. In order to facilitate this, SWIFT is helping progress the dialogue on the use of non-Latin characters in FIN (a type of financial message used in clearing) and ISO 15022 messages. This is discussed in more detail on page 8. The current RMB clearing model has served the industry well to date. Commendable progress has been made by BOC HK, HKMA, HKICL and the industry in infrastructure developments. SWIFT and our community are aware that there are some significant challenges that will need to be addressed to place RMB on an even playing field with other currencies from an operational perspective. Developments in payment market infrastructure and offshore markets The primary RMB clearing centre is Hong Kong. Hong Kong has developed to assist in the global clearing of Offshore RMB from different locations like the United Kingdom, Singapore, etc. For the purposes of this paper, a “spoke” is defined as a location where there is a pool of Offshore RMB liquidity outside of mainland China, whereas a “hub” is where Offshore RMB is cleared.5 This paper also uses “Offshore RMB centres” to refer to both the “hubs” and “spokes” in their entirety. Since 2009, many of the developing Offshore RMB centres have been focused on optimising the existing hub in Hong Kong. Centres like Taiwan, Singapore and the United Kingdom are carefully considering aspects of the continued use of the Hong Kong hub. In 2012, there has started to be an increased dialogue about the full range of options for Offshore RMB centres. The discussion includes: 1. Continuing to leverage the “hub” (Hong Kong); 2. Developing a Clearing Bank with RMB RTGS (replicating the Hong Kong model locally); 3. Leveraging the development of the China International Payment System (CIPS) Before discussing this on a country- by-country basis, it is necessary to take a view of the current status of these centres by looking at the RMB traffic volume from August 2012. RMB payment (MT 103 + MT 202 excluding 5 ‘From redback to greenback – the journey of renminbi from local circulation to reserve currency’, Joe M.K. Ng, 2012, Investing in Asian Offshore Currency Markets: The Shift from Dollars to Renminbi, Palgrave Macmillan, forthcoming
  • 6. 6 MT 202 COV) volume of messages sent and received by the top 10 countries represents 92.7% of the worldwide RMB traffic. Countries that are the top 10 Offshore RMB centres are shown in Figure 6, with the associated percentage market share of volume of payments. Hong Kong has a first mover advantage, which has resulted in the majority of the liquidity, a developed RMB RTGS infrastructure and a talent base for continued innovation in RMB product offering. China’s 12th Five-Year Plan (2011–2015) includes the goal of supporting Hong Kong’s development as an Offshore RMB business centre. More importantly, Hong Kong alone today has the extended RMB cut-off processing time that is intended to support transactions from other regions. Hong Kong also operates its RMB RTGS on all global public holidays – Monday to Friday – other than the first day of January. Over time, Hong Kong might lose some of this advantage to other emerging centres like Shanghai, Taiwan, etc. However, the previously mentioned strengths of Offshore RMB liquidity, support of China and a robust infrastructure should help bring continued benefits to Hong Kong in the future. In London we have seen a significant market created for Offshore RMB deposits and FX trading. It is London’s stated ambition to become a “western hub” (not perhaps in the same way this paper describes “hubs”) for the international RMB market to complement Hong Kong and other emerging centres. London’s RMB clearing leverages Hong Kong’s existing infrastructure. Clearing RMB through Hong Kong has provided London a fast time to market, which in part has helped London create an advantage in establishing itself as the RMB gateway for the West. Since liquidity of an Offshore RMB centre is of the highest importance, London is expected to focus on increasing the deposits and to enter a swap agreement with China. In the future, London could consider options for its current clearing arrangement due to the difference in time zones. London may first evaluate the benefits of developing its local RMB clearing capability versus leveraging the established infrastructure of Hong Kong. We recognise that London has several strengths as an Offshore RMB centre, such as the experience of its financial services and legal professionals, the legal system itself, and established leadership in international bond issuances and the FX market. All these strengths can only help the city grow its “western hub” in the future. At the time of writing, Singapore has a smaller amount of RMB deposits than Hong Kong and London. However, we have seen a significant increase in FX volumes in Singapore, which seems a logical strength since it is generally accepted to be the largest FX trading centre in Asia. Singapore is also currently using Hong Kong as a hub for Offshore RMB settlement. While Hong Kong is acting as a hub, Singapore might also consider a local RMB Clearing Bank. If successful in this endeavour, it is expected that Singapore may look to enhance its RTGS, creating a model similar to Hong Kong’s. In Malaysia, the financial community appears focused on leveraging its strength in CNY/MYR trading. A BNM press release on 21 March 2012 announced that Malaysia’s Real Time Electronic Transfer of Funds and Securities (RENTAS) system would extend its RTGS services to include the RMB. Considering the infrastructural linkage of Malaysia’s RENTAS with HK’s RTGS and the settlement agent relationship between Hong Kong and Malaysia’s RMB Clearing Bank, Hong Kong has emerged as the de facto Offshore RMB settlement hub for Malaysia. For Taiwan, cross-Strait trade is substantial and has the potential to increase further. Taiwanese commercial banks are currently leveraging the Hong Kong hub. To promote financial cooperation, the PBOC and the Central Bank of the Republic of China (Taiwan) have signed a cross-Strait currency clearing MOU. The agreement was signed at the end of August 2012 and is scheduled to take effect in 60 days from that date. A new spot rate is expected FIGURE 6: Top 10 Offshore RMB centres and market share of payment volumes China 5.2% Hong Kong 72.8% UK 3% Singapore 2.6% Malaysia 2.3% US 1.9% Macau 1.6% France 1.4% Mongolia 1.1% Taiwan 0.9% Offshore RMB clearing centre Possible offshore clearing centre 2013+ Offshore RMB trading centre
  • 7. 7 to be created for the interbank market, denoted by “CNT” (not an official ISO currency code). The MOU lays out plans for Taiwan to select a TWD settlement institution for China. At the same time, the PBOC will select a RMB Clearing Bank for CNY for Taiwan. There will still, however, be some challenges such as how to navigate rules and regulations, especially with two non-convertible currencies. At the time of writing, Bank of Taiwan has already been selected as the TWD settlement institution in mainland China. Based on 2012 data, Taiwan’s sent and received CNY payments make up around 1% of the Hong Kong volume. New regulation has been issued in Taiwan that implies that the overseas business unit should use this new CNY clearing route versus going through Hong Kong. We expect to start seeing a shift in liquidity away from Hong Kong by the end of 2012. In the longer term, the key onshore centre for renminbi business will likely be located in Shanghai. China has decided to construct Shanghai as an international financial centre, but the legal environment, financial derivatives and regulation expertise are not fully prepared. In the next decade, the 12th Five-Year Plan is expected to promote profound reform in the financial sector. Macau is already established as an Offshore RMB hub for local transactions and will continue to play an important role. The US, France and Mongolia are all in the top 10 and are spokes to the Hong Kong hub. They have the potential to play a bigger role in the future development of infrastructure although they have no publically stated plans. At the time of writing, the majority of markets have leveraged Hong Kong as a hub for Offshore RMB clearing. The expansion of Offshore RMB hubs such as Hong Kong will ultimately depend on the strategy adopted by the PBOC towards these centres. The ability for local clearing might be viewed by countries as a key element for the continued evolution of their financial centre. Other nations might want to control trade and currency issues on their own terms, in their own regions, and by their own rules. Whatever the initial motivation for these developments, their speed of processing payment, operating hours and other value-added services will be possible points of differentiation. A goal should be to level the playing field for RMB with other currencies. Market expectations around future RMB clearing systems The community view is that the existing arrangement for Offshore RMB clearing is appropriate in the current environment. In the medium-to-long term, however, it may be important to have an enhanced platform that can address the need for longer operating hours to cover various time zones and lower the amount and cost of liquidity required to support these transactions. The following section is intended to be a practical starting point for dialogue related to the development of a future cross-border RMB clearing system. The cross-border USD clearing and settlement may provide an example for what the future of RMB clearing can resemble. Local and regional USD systems have been developed but the advantages have diminished over time because of the US system’s enhanced operating hours and efficient use of liquidity due to the netting of the transaction. A typical USD payment can now be settled within seconds. This is why some industry participants prefer the use of centralised clearing bodies with many participants, continual technology and proven contingency support, and finality based on funds placed with the Central Bank. While this has clearly worked for USD we cannot assume it will be the same for RMB because China is taking a measured approach in opening its economy. As a result, there is a need for the “firewall” between the domestic economy and the growing Offshore RMB market. Therefore, there will be more complexities in the payment process. There is no public documentation available to evaluate the functionality of a future cross-border RMB clearing system – however, in this paper, some assumptions will be made. The first is that any such system will apply the most recent industry recommendations for world-class critical infrastructures. We are certain that, if this is a PBOC initiative, as a drafting member any new infrastructure it moves forward with will comply with the April 2012 CPSS-IOSCO revised principles called the new Principles for Financial Market Infrastructures (PFMI). PFMI covers the operation and governance of high- and low-value payment systems, central clearing counterparties (CCPs), central securities depositories (CSDs) and trade repositories. The aim of PFMI is to set international standards and best practice to secure robustness, efficient operational procedures and effective risk management within the market infrastructure community. The primary goal of a future RMB clearing system is to support the need for seamless routing of RMB payments not only within China but for RMB payments around the world. In order to have seamless routing of payments, access or reach is critical. It should be expected that an ideal model will connect to both domestic and overseas banks as its direct participants. It is also critical that the community be able to exchange electronic payment information in globally accepted message standards. It is expected that international standard messaging formats, most likely ISO 20022, will be selected for communication between a future RMB clearing system and its direct participants. The use of international standards by the clearing system is welcomed. However, there will be a requirement for investment at the commercial banks to translate between ISO 20022 and ISO 15022, since ISO 15022 is currently the most common standard for payments in the international markets. An international repository of reference data is also critical for the seamless routing of payments. It is requested that any new participant code be compatible with the Bank Identifier Code (BIC) and published in both the local language and in English for international use by participating banks. Use of international and reference data standards will improve the quality and efficiency of the clearing system. If a future RMB clearing system allows for both Chinese and Latin characters in the message standard then this can be a complex matter for global
  • 8. 8 transaction banks. Today, CCCs are used as a workaround to address the use of Chinese characters in the MT standard messages and the resulting problem and risks in this practice are described on page 5 of this paper. SWIFT acknowledges that for many institutions the MT standard will continue to play a significant role, whether exchanged between organisations or used as an internal data format, and the MT standard is constrained to a limited, Latin-only character set. SWIFT also understands that many of the legacy applications and platforms that are used to process payments in the region are incapable of supporting natively anything but Latin characters. Both limitations present difficulties for service providers that wish to support name, address and remittance information in Chinese characters. SWIFT is therefore discussing with the broader community an enhancement to certain fields in MT messages that would enable them to convey non-Latin characters encoded as code numbers based on the Unicode standard. This development should allow Chinese characters to be passed through the payments system via legacy standards and applications, although it might not fully address the sanction screening challenge. Use of such an enhancement would be deployed on a strictly “opt-in” basis, protecting non-participants from receiving messages that they are unable to process. The discussion is still at an early stage, and SWIFT continues to consult with the industry on the value and feasibility of this suggestion. Direct participants would also want information to monitor their payments, accounts (settlement and liquidity), reserves and alerts, and to make adjustments accordingly. As several payment systems already offer an automated, web-based user interface to support these functionalities, we can expect that a future RMB clearing system will provide similar functionality in addition to intraday and end-of-day statements. In terms of liquidity management, its soundness depends not just on the management of the liquidity position in the bank’s settlement accounts but also involves securing the amount of liquidity and establishing its cost. Efficient collateral management is required. Some additional features, which are not required but would be an additional benefit, are netting, gross settlement and PvP. PvP is important because any future system could eventually work towards the elimination of Herstatt risk for RMB. This system could work with existing multi-currency RTGS systems with RMB capabilities by providing access to Offshore RMB centres while the local RTGS addresses Herstatt risk, or work with CLS once RMB becomes an eligible currency to work toward mitigating this risk. A future RMB clearing system is expected to create efficiency; however, there will be some challenges for the industry related to the translation of international standards, reference data and the use non-Latin characters that will require continued dialogue and industry cooperation. This development is expected to be a game changer for RMB payments and the industry is enthusiastic about being involved in the continued dialogue. How can SWIFT help? Last year’s white paper identified three key areas where SWIFT could help in the internationalisation of the RMB. The first was to facilitate the processing of Offshore RMB in financial transactions and to increase automation. SWIFT facilitated the Offshore CNY Working Groups to discuss the problems in processing Offshore RMB transactions. We produced the ‘Offshore CNY Guidelines for SWIFT MT and ISO 15022’ in February 2012, describing the use of structured codes in FIN messages for customers who are converting ‘CNH’ to ‘CNY’. There is also an updated version 2.1 from 30 June 2012 that includes payment nature codes and can be found on www.swiftcommunity.net or by contacting your SWIFT relationship manager. The second area was to help broaden the industry’s understanding of the benefits of the RMB. Our 2011 whitepaper was a start and this paper is an extension of that series. SWIFT also publishes the RMB Monthly Tracker, which has been very well received by the community. The third goal was to provide detailed business insights into RMB volumes so as to track market share and identify new business opportunities. SWIFT has a comprehensive Business Intelligence offering with supporting consulting work allowing flow analysis, tracking market evolution and benchmarking versus the market. Through our engagement with banks on the future of RMB clearing, it has become clear that there are other areas where banks are looking for SWIFT’s support: The future RMB clearing system will likely be built using international standards such as ISO 20022. SWIFT can provide translation support to participants for the translation between MT and ISO 20022. This allows faster deployment of the solution since it allows participants to defer, minimise or avoid upgrading legacy systems while offering compatibility. With the introduction of ISO 20022, non- Latin characters can be used on the SWIFT network. For many institutions the MT standard will continue to play a significant role and many of the legacy applications and platforms that are used to process payments around the world are incapable of supporting anything but Latin characters. SWIFT is therefore discussing with the broader community an enhancement to certain fields in MT messages that would enable them to convey non-Latin characters as code numbers based on the Unicode standard. Lastly, the codes used in any future RMB clearing system, and their compatibility with BIC codes, are critical for seamless global processing of payments. SWIFT is working to ensure compatibility of the codes and availability of directory information where mapping is needed. For more insights into recent RMB transaction flows and which countries to focus on for your RMB business development,please contact swiftforbanks@swift.com for more information about our business intelligence products and services.
  • 9. 99 Acknowledgements Many individuals and organisations have helped in the preparation of this white paper. SWIFT would particularly like to thank our industry editorial board, which helped in setting the overall editorial direction, guiding the content and preparation. Bank of America Merrill Lynch Ms Catherine Li, Mr Kuresh Sarjan, Ms Chandana Thanthrige, Ms Clara Wang, Mr Alan Wong and Mr Derek Yan Bank of China (Hong Kong) Limited Mr Ching Kwok Leung, Mr Steve Wong, Mr Jack Yang and Mr Winston Ye Bank of Communications Ms Shi MeiYi Citibank Ms Rani Gu, Mr Amol Gupte, Mr Philippe Jaccard and Ms Carmen Ling HSBC Mr Stéphan Levieux and Mr Sathya Ram J.P. Morgan Ms Ann Lin Khoo, Mr Masayuki Tagai and Ms Lily Zou The Royal Bank of Scotland Ms Shirley Chan Standard Chartered Bank Mr Frankie Au, Mr R Madhavan, Mr Joe M.K. Ng, Ms Kaiti Pei, Ms Sonia Rossetti, Mr Stephen Street and Mr Michael Vrontamitis Glossary of abbreviations AML Anti-money laundering – procedures, laws or regulations in place to prevent, detect and report money laundering activities BIC Bank Identification Code BOC HK Bank of China (Hong Kong) CCC Chinese Commercial Codes CIPS China International Payment System CLS Continuous Linked Settlement – an industry initiative that aims to significantly reduce foreign exchange settlement risk through simultaneous exchange of net currency values CNAPS China National Advanced Payment System CNH Offshore yuan/renminbi – denotes Chinese currency traded outside mainland China, mainly in Hong Kong. There is only one official ISO currency code for the Chinese yuan and that is ‘CNY’ (see CNY and RMB) CNY ISO currency code denoting the Chinese yuan, otherwise known as renminbi. Yuan is the basic monetary unit of China, while renminbi is the system of currency. CNY also denotes onshore RMB – Chinese currency traded within mainland China (see RMB and CNH) CPSS-IOSCO A joint initiative of the Committee on Payment and Settlement Systems and the International Organization of Securities Commissions CSD Central securities depository EUR ISO currency code denoting the euro FDI Foreign direct investment FIN SWIFT’s messaging service that enables the secure and reliable exchange of MT messages in store-and-forward mode FX Foreign exchange IDR ISO currency code denoting the Indonesian rupiah ISO International Organization for Standardization
  • 10. 10 JPY ISO currency code denoting the Japanese yen MOFCOM Ministry of Commerce, People’s Republic of China MOU Memorandum of understanding MT Message Type – denotes the data used to identify information within a standard SWIFT format message. Standard formats are: - MT 103: payment instruction (customer) - MT 202: payment instruction (bank) - MT 210: advice of funds/pre-advice (customer) - MT 300: foreign exchange confirmation - MT 545: receive against payment confirmation - MT 547: deliver against payment confirmation - MT 940: detailed bank statement information - MT 950: summary bank statement information MYR ISO currency code denoting the Malaysian ringgit ODI Outbound direct investment PBOC People’s Bank of China PFMI Principles for Financial Market Infrastructures – a report published by the CPSS- IOSCO committee PMPG Payments Market Practice Group, a SWIFT advisory group PvP Payment-versus-payment – a system wherein transfer of a payment in one currency occurs only if the final transfer of a payment in another currency or currencies takes place QFII Qualified Foreign Institutional Investor; the QFII scheme allows foreign fund managers to convert foreign currencies into RMB to invest in China RMB Renminbi – the currency of mainland China; otherwise known as yuan. Renminbi is China’s system of currency, while yuan is the basic monetary unit (see CNY and CNH) RQFII Renminbi Qualified Foreign Institutional Investor; the RQFII scheme allows Chinese fund houses to establish RMB-denominated funds in Hong Kong for investment in mainland China RTGS Real-time gross settlement SWIFT Society for Worldwide Interbank Financial Telecommunication – a cooperative organisation created and owned by member banks to facilitate the transfer of information and payments/advice instructions between each other via a global data network TWD ISO currency code denoting the new Taiwan dollar USD ISO currency code denoting the US dollar
  • 11. 11 Legal Notices Copyright Copyright © S.W.I.F.T. SCRL (“SWIFT”), Avenue Adèle 1, B-1310 La Hulpe, Belgium, 2012. All rights reserved. Reproduction is authorised provided the source is acknowledged. Trademarks SWIFT, S.W.I.F.T., the SWIFT logo, Sibos, Accord and SWIFT-derived product and service names – such as but not limited to SWIFTNet, Alliance and SWIFT Standards – are trademarks of S.W.I.F.T. SCRL. SWIFT is the trading name of S.W.I.F.T. SCRL. All other product or company names that may be mentioned in this document are trademarks or registered trademarks of their respective owners. Disclaimer This white paper is provided for information only. If a customer or any third party decides to take any course of action or omission based on this report and/or any conclusion contained therein, they shall do so at their own risk and SWIFT shall not be liable for any loss or damage, arising from their acts or omissions based on this report and/or any recommendations contained therein.
  • 12. For more information about SWIFT visit swift.com To join the community debate visit swiftcommunity.net SWIFT © 2012 56103-OCT2012