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 "Handbook of International Credit
  Management" Second Edition
    Edited by Brian W. Clarke



         (The chapter appears on pages 316 through 327 in the Handbook - spelling is as edited in the UK)




                                                     21

         EXPORT FINANCE TECHNIQUES
                                       IN THE USA

                                        Albert A. Cannistra


With world trade now in excess of three trillion US$, it stands to reason that more companies
are looking beyond their own borders for increased market opportunities. Of the top 100 global
retailers, 55 percent have already expanded retail operations outside their base country.
Service industries, engaged in a multitude of diverse activities, now trade in excess of one
trillion US$ annually and are expected to be among the fastest growing providers of new jobs
and revenues. Clearly, the vision beyond the year 2000 is one of a global village.
                Barriers to cross border trading are coming down; protectionism, while not
entirely without visibility, is eroding as more governments realize that expanding sales abroad
increases jobs at home. Removing regulatory obstacles that give preference to local sources,
removing extra costs imposed upon consumers and eliminating government intervention in
international trade will allow entrepreneurial companies to compete effectively in a global
market-driven economy. The recent GATT agreement and the transition from embryonic to
functional institution to be known as the WTO [World Trade Organization] is a major step by
more than 100 nations in embracing the global village concept.
                As globalization takes hold, traditional methods of export finance are likely to
undergo an evolution that will result in more transactions on risky open account terms.
Prompted by competitive pressures and accompanied by more available information, increased
standardization of trading rules and improvements in technology, the change in the way
business is conducted is inevitable. This chapter will address financing techniques in use today
and will attempt p provide the American exporter with a variety of finance options and a
reference to various institutions whose purpose in some way may provide sources of capital for
international trading.
         Any apparent duplication with parts of Chapter 20 and other chapters is deliberate in
that, although US multinationals operating in Europe and elsewhere may find similar techniques
and options, they are often applied in subtly different ways.


SHORT-TERM FINANCING


There are essentially five ways to collect payment for goods and/or services sold to customers
abroad. Each, once beyond prepayment, carries its own degree of risk for the exporter.
Variations exist within the five categories, yet upon closer examination each variation can be
classified within the basic framework.
Cash in advance, letter of credit, documentary sight draft, documentary time or dated draft and
open account are the five basics. The appropriate choice is determined by the buyer's
creditworthiness, the ability of the exporter to finance, market conditions including political
conditions and hard currency availability, the competitive situation and the importance of the
market to the sellers goals. Variations may involve third parties, guarantees, government
programmes and insurance providers. In most cases, banks play an indispensable role in
conducting an international transaction.


COMMERCIAL BANKS

Commercial banks, an icon of international trade, have long been the providers of many
corporate financial services. Large European banks had an advantage over American banks in
that their American counterparts were restricted by regulations limiting their ability to expand
beyond their state borders. That changed in more recent times as banks were allowed to form
holding companies with ownership crossing state lines provided that operating headquarters
were maintained at each state office. As this book is being prepared, the Congress has
approved and the President is expected to sign, new legislation allowing the banks to operate
one headquarters office.
The current policy shift will allow banks to realize synergistic savings by consolidation of
administrative functions. The banking industry itself will no doubt concentrate into fewer, but
more powerful institutions better suited to serve an increasingly diverse customer base and
better able to compete in a global environment. As the banks increase their arsenal of financial
products, the former tendency to specialize in local industry should give way to a broadened
outreach for international opportunities.


EXIMBANK

Eximbank (Export Import Bank of the United States) is an agency of the US government. Its
function is to assist exporters of US goods or services in obtaining necessary financing. Among
the programmes available are guarantees of medium term credit sales (1 5 years, may be
longer depending on product), arranging loans to foreign buyers of goods or services originating
from US sources, arranging loans to intermediary lenders financing US exports and the granting
of guarantees to assist US businesses in obtaining working capital to support an export sales
function. The bank’s headquarters are located in Washington, DC.
                Single sale and repetitive sales to the same customer are eligible for guarantee.
The costs of the guarantee vary depending upon repayment terms, the country and the type of
customer; it is possible, when negotiating the contract to include these costs in the pricing
scheme.


LOCAL STATE GOVERNMENT

Small- and medium-sized businesses should look to their own states for export financing
assistance. Various programmes exist which can supplement the offering at the federal level.
Some programmes provide the majority of the financing with a portion supported by a
commercial bank. Other states may offer working capital loan guarantees, sometimes only in
conjunction with an export sale backed by an irrevocable letter of credit or export insurance.


COUNTERTRADE

Common forms of countertrade include barter, counterpurchase and compensation
arrangements. This methodology, in various forms, is among the most commonly employed
non conventional means of international financing. Typically, the buyer requires the seller to
accept full or partial payment in the form of specific goods or to find another buyer for those
goods. This method of financing is well suited to transactions in East West trade and with
developing countries in Asia, Africa and Latin America.
               Barter involves the exchange of goods for goods of comparable value without the
transfer of money.       Most often, these are negotiated one-time transactions that are
consummated in short time periods usually, completed in less than 24 months. The goods to
be exchanged and the quantities are always specified at the time the contract is signed.
Counterpurchase is similar in that it also typically involves a one time transaction
in the short term. The difference is that counterpurchase involves two linked contracts in which
the seller agrees to deliver goods to the buyer, accept goods in return as payment from the
buyer and, in turn, resells those goods to a second buyer for payment in the form of currency.
Compensation arrangements are usually much larger value deals, typically involving
large scale projects extending over a long period of time. This type of arrangement is best
suited to the delivery of technology or equipment for a specified project accompanied by a
reciprocal agreement to purchase specific goods or services resulting from that project.
        Countertrade is covered in detail in Chapter 17.


PROMISSORY NOTES

Provided the seller has the means, short term financing may be accomplished by having the
customer sign a promissory note and obtain the collateral signature of the principals or the
corporations which own the assets pledged to guarantee the payment of the transaction.
When using this form of financing, compliance with local requirements of negotiable
instruments, specific language, interest rates, place of payment and currency of payment are
essential. In the event that formal collection of the note is required, documents evidencing
existence, authority and legal standing of both debtor and creditor may be required.


LETTERS OF CREDIT

Modern day letters of credit can be traced back to the early 1800's; their beginnings are
traceable back to banks in the U.K. After the First World War, this activity became popular with
European and American banks and has evolved into a sophisticated, controlled process which
is described in considerable detail in Chapter 16.
A letter of credit is a commitment by a bank to pay a seller a certain sum of money at a future
date provided the seller is in compliance with the specified terms of the credit. The letter of
credit can be payable on presentation or, in the case of a time (acceptance) letter of credit,
payable forward a specified number of days. The methodology provides a compromise
between the buyer, whose interest is protected by not advancing payment until documentation
evidencing shipment or performance is delivered, and the seller, who is interested in being
guaranteed payment upon providing proof of compliance. Depending upon the needs of the
shipper, a time letter of credit may be discounted to the bank for immediate funds or the
proceeds of the letter of credit may be assigned to a third party. The rules governing letters of
credit are not codified US law (i.e. not governed by the Uniform Commercial Code), but when
cited on the letter of credit become binding on all parties.
There are several types of letters of credit. A revocable letter of credit is one that can be
revoked by the issuing bank at any time prior to presentation. This particular type of credit
cannot be relied upon for guaranteed payment. An irrevocable letter of credit is one that cannot
be canceled prior to its expiration date except with the consent of all parties involved. In this
case, the beneficiary relies upon the creditworthiness of the issuing bank and its promise to pay
in the specified currency on the date of maturity. A confirmed irrevocable letter of credit has the
guarantee of a secondary bank, usually in the supplier's own country, and it is this bank which
becomes the suppliers source of payment.
Before accepting a letter of credit, its terms and conditions should be reviewed by the
beneficiary to determine his ability to comply with all terms and conditions. If there are
conditions which cannot be met, the buyer should be requested to instruct the issuing bank to
issue an amendment making the letter of credit acceptable to all parties. Discrepancies will
cause a letter of credit to go unpaid pending the buyers subsequent approval and instructions to
the issuing bank and, without that approval, the credit may go unpaid indefinitely.


Revolving letters of credit

Revolving letters of credit may be used when business transactions are expected to be
conducted on a regular repeating basis, such as an agreed upon monthly purchase. Instead of
opening multiple credits to cover each shipment, a revolving letter of credit with multiple
drawings over a specified period of time allows the beneficiary to draw up to a designated
amount at specific intervals and self renews for the next period. Revolving letters of credit can
be cumulative or non cumulative. If cumulative, amounts not drawn in one period carry over to
the next and subsequent periods accumulating value for possible future drawings. If
non cumulative, amounts not drawn are lost.


Stand by letters of credit

A stand by letter of credit is one in which a bank guarantees payment up to a specified amount,
for a certain period of time, to a specified beneficiary, provided that the beneficiary presents
required documentation within the terms of the stand by. Documentation can be as simple as
a signed letter from the beneficiary stating that payment was not made nor performance
completed as agreed. It is a letter of credit which typically is not expected to be drawn upon.
       This type of letter of credit allows for the extension of an open account type arrangement
from the supplier to the customer with the assumption that the buyer will make good on their
promise to pay, but assures the supplier that in the event of a default by the customer, the
supplier will receive payment from the issuing bank. It is also used in a manner similar to a
surety bond or guarantee, where, the bank assures a buyer of performance by the seller with
monies available to the buyer in the event of default by the seller.

Back to back letters of credit

Back to back letters of credit may be used in circumstances where a merchant, who buys
product and then exports it, lacks sufficient means to justify open account terms and does not
want to pledge collateral to enable a letter of credit to be opened in favour of his suppliers. The
merchant’s foreign customer opens a letter of credit in his favour and that letter of credit is
deposited in the merchant's bank and used by his bank as ‘collateral’ to issue a letter of credit
in favour of the original supplier of the goods. The merchant's bank will match its letter of credit
to the foreign customer's original in terms of documentation and conditions. The differences will
be in the amount of the credit, price, shipping dates and period of validity.
Under certain circumstances it may be possible for the supplier to be paid under the merchant's
letter of credit even if the merchant is unable to comply on the original letter of credit. Banks
are, however reluctant to be placed in such a position, so caution is suggested in carefully
reviewing terms of the secondary credit. There is an additional concern in that, if possession of
the goods is given to the merchant and ultimately not conveyed in compliance with the terms of
the original letter of credit, the secondary letter of credit may be totally uncollectable.


BANK GUARANTEES

Bank guarantees are not synonymous with letters of credit. In some countries, guarantees are
a means of assuring payment to the supplier on behalf of the purchaser. The bank issuing the
guarantee will hold adequate security but will apply outstanding guarantees to the importer’s
credit ceiling thus reducing overdraft and other facilities. These guarantees are not without
internal control as banks classify the guarantees as actual liabilities rather than potential
liabilities and are restricted by reserve requirements imposed by the local Central Bank. Not all
banks may be acceptable to the exporter. U.S. banks are prohibited from issuing bank
guarantees and reference is made back to the stand-by letter of credit as an American
alternative.


PERSONAL GUARANTEE OR CORPORATE GUARANTEE

Not unlike bank guarantees, personal or corporate guarantees are the assurance of a third party
that a debt will be paid. This type of guarantee may be used when a US individual or
corporation has a vested interest in a foreign company and wishes to induce the extension of
credit facilities by a supplier based upon its own strength. The guarantee is, however, only as
sound as the individual or corporation that stands behind it.

DISCOUNTING ACCEPTED DRAFTS/BILLS OF EXCHANGE

Documentary collections (see Chapter 15) are the written confirmation of arrangements
between two international trading parties in which shipping and other documents are presented
by the exporter through a third party, usually a commercial bank, to the importer in exchange for
payment or the promise to pay. If payment is expected on presentation, this term is considered
"at sight." The promise to pay at a future specified time takes the form of a "time draft" or
"dated draft" and assumes the risk that the importer will pay as agreed at a later date. The
documents accompanying these collections are evidence of performance by the exporter and
the presentation of this evidence enables the collection of funds by the bank.
Clean collections work in the same manner except that there is no accompanying evidence of
performance. This type of collection involves the bank collecting funds from importers solely on
presentation of the exporter's bill of exchange, the shipping and other documents having gone
direct to the importer. Promissory notes, or other forms of financial receipts can be used as
clean collections. Clean collections can be used for a variety of reasons such as cash
management(allowing the exporter to know when payment should take place) or to add
payment discipline to an open account customer who should want to avoid any adverse
commercial publicity surrounding dishonored bills of exchange. They may also be a
requirement in some countries that use clean drafts as a method of controlling foreign exchange
through a central bank.
                 Documentary collections 9not to be confused with documentary letters of credit)
are not without risks. There is no question that they provide more security than strict open
account, but they do not provide the same third party guarantee given by a letter of credit.
There is the possibility that the buyer will not take possession of the goods and abandon the
transaction either because of financial or market changes. If this occurs, the shipper faces the
possibility of having to quickly find another buyer or having to pay return freight, in either case
accompanied by demurrage charges, or even the possibility of total loss of the entire shipment if
it were sold for salvage value.
                 Negotiating documentary collections with a commercial bank is a means for an
exporter to obtain immediate cash. An assumption is made that the bill of exchange is worth its
face value (self liquidating) when payment specified is due and the bank will advance funds
less certain discounting charges. It is important to recognize that this negotiation is with
recourse and, in the event of the buyer’s default, the bank will expect to be reimbursed by the
seller with interest on the funds advanced.
                 The buying discount rate is the rate at which the accepting bank discounts its
bankers' acceptances. It is the effective interest charge for funds paid in advance of
collectability. Rates will fluctuate on a daily basis and will vary according to market conditions,
creditworthiness of the buyer and other factors as determined by the accepting bank's treasury
department.

EXPORT FINANCNE AND CONFIRMING HOUSES

There are few confirming houses operating today, most of the business now having been
absorbed by commercial banks. This method of financing was popular in the UK where its
original purpose was locating exporters for overseas buyers and providing a guarantee of
payment against clean documents.
                 The financing offered by the confirming house allowed the exporter to be paid in
30 days, at a discounted rate, with the buyer paying the confirming house at some future
specified date. In its original concept, the confirming house brought unsolicited orders to the
seller; in its modern variation, sellers tend to seek out the ‘bank’ export finance house for
facilities available in a particular market.

FACTORING


Factoring is another means whereby an exporter can turn his invoices into immediate cash
funds. Funds can be obtained without recourse in approved markets and with credit approved
customers. Invoices are sold at a discount to a factoring house which will also provide
comprehensive ledger and collection service.


                This means of financing is usually attractive to smaller- and medium-sized
companies that have no credit administrative infrastructure of their own. Larger companies,
staffed with proper levels of expertise, tend to avoid this alternative as being too costly,
preferring to conduct the function internally at a fraction of the cost.


EXPORT CREDIT INSURANCE

The purpose of credit insurance is to avoid unexpected losses and to guarantee the selling
company that it will be paid for goods shipped to and/or services performed for commercial
buyers who default on payment obligations (see Chapter 10). Exporters can obtain coverage
for both political and commercial risks, and the insurance policies can be used to enhance trade
finance facilities.
                 Studies indicate that fewer losses occur on new accounts than on old established
customers. An account that may have been good for a decade or two causes the loss because
of deterioration of its business, a change in focus or a change in the controlling interest. Any of
these occurrences may go undetected especially if the account pays its bills to your company
on a timely basis right up to the end.
                 In international trade, use of credit insurance may cut costs by removing the
need for letters of credit, enabling the seller to be more competitive and, perhaps, more
aggressive in certain markets. Another reason for considering use of credit insurance is the
increase in the collateral value of your own accounts receivable to lenders. It allows the
reduction of bad debt reserve to a negotiated deductible level, allows better budgeting by
capping losses and provides an outsource credit support service.


CAPTIVE INSURANCE COMPANIES FOR EXPORT RISKS

This concept is best suited to the larger, multi divisional company that already has an
established captive for other insurance needs. The costs of operating solely for the purpose of
export insurance would usually be prohibitive.
                Self-insurance makes a company less vulnerable to the cyclical movements of
the credit insurance market, but imposes many other considerations which must be carefully
evaluated prior to this undertaking, not the least of which is re-insurance in the outside
insurance market and the consideration of whole turnover or catastrophe forms of coverage.
                Other considerations before embarking in this arena are the need for
administrative and operational management of the captive, assessment of an acceptable level
of losses that the company can endure, procedures to be followed and standards of acceptable
risks to be taken at the divisional level and a means to monitor compliance. The establishment
of terms, conditions and pricing to the divisions by the captive must also be considered.
Assistance from the outside insurance market should not be overlooked.


FORFAITING

Literally meaning ‘without recourse’, forfaiting is a form of medium-term export financing that
had its beginning in Europe in the 1950s. The technique evolved with specialists in the former
West Germany, Switzerland and Austria who were dealing with East European paper; today,
London is a leading centre for this type of transaction. Forfaiting is currently used in the USA,
albeit not being as popular as other methods of financing. An exporter has the option to seek
out sources in any major US financial centre or with a London based specialist. (See also
Chapters 9 and 20.)
         This method of financing is suggested when there is a need to go beyond 90-180 day
facilities, the exporting company is unwilling or unable to provide financing themselves and
when direct bank financing may be too cumbersome. It is a means whereby the seller may offer
extremely competitive terms to the buyer without the added risks. Forfaiting normally involves
the issuance of a bill of exchange or a promissory note which, after acceptance by the buyer,
are avalized (guaranteed) by a major bank, then discounted by a forfaiting bank for immediate
payment to the exporter and subsequently held to maturity or resold in the `a forfait market.
         The forfait market is estimated to be US$ 30 billion in terms of understandings.
The US portion is estimated to account for US$ 5-6 billion. Compared to other finance options,
forfaiting is simple and flexible, but it is also more expensive. Unlike current Eximbank
programs, there is no US content requirement for goods sold.



GOVERNMENT-RELATED SOURCES
Most export finance schemes with different degrees of government involvement cover medium-
term project financing but some short-term finance might also be available.

US GOVERNMENT AGENCIES, ETC.

OPIC [Overseas Private Investment Corporation] is a U.S. government agency whose function
is to promote US private investment in developing countries. Investors can look here for
assistance in new ventures or the expansion of existing ones; assistance may be in the form of
political risk insurance, direct loans or loan guarantees. The political coverage protects up to 90
per cent against expropriation, nationalization or confiscation by a foreign government, war or
insurrection and currency inconvertibility; the investor will be at risk for the remaining 10 per
cent.
The U.S. Department of Agriculture supervises the operations of the CCC (Commodity Credit
Corporation), another agency of the US government. The function of this organization is to
make guarantees, where necessary, in order to increase or maintain US agricultural exports to a
foreign market. Usually, this guarantee is necessary only when commercial institutions are
unable or unwilling to provide financing without the accompaniment of a guarantee, an example
being a sale to a country with a shortage of hard currency.
PEFCO (Private Export Funding Corporation) is a consortium of commercial banks, industrial
corporations and financial service institutions formed to provide supplemental export financing
through the normal channels. Working with Eximbank, loans of medium- and long-term nature
are made to finance the purchase of US goods or services by foreign buyers. Typically,
financing is available for larger projects such as ocean vessels, aircraft, power plants and
industrial projects.

THE WORLD BANK GROUP

The IBRD (International Bank for Reconstruction and Development), known as the World Bank,
is the parent to the three-member World Bank Group and a sister organization of the
International Monetary Fund (IMF). The purpose of the group is to channel money from
developed countries into developing nations for productive purposes with a goal of raising the
standard of living in those nations. Focus is on high priority economic projects which have
basic financial soundness. It is a requirement that procurement of goods and services be made
on an international competitive basis in order to accomplish maximum benefit.
        The IMF, owned and operated by more than 150 member countries, provides financial
and technical assistance to developing countries throughout the world. Working with the central
governments of member countries, the Fund seeks to promote exchange stability, economic
development and the expansion and balanced growth of world trade.
        The IDA (International Development Association) is another affiliate of the World Bank.
Its purpose is to work with less-developed countries whose resources and balance of payment
positions preclude borrowing on conventional terms from the IBRD. Operating policies are
identical to the IBRD except as related to repayment terms. Concessional terms are given to
the beneficiary countries, often with terms up to 50 years, a minimal service charge and no
interest.
        The IFC (International Finance Corporation), the third member of the World Bank,
invests in the private sector of developing countries. It is a provider of unsecured equity and
loan capital promoting projects that have economic benefit and local participation. Loan
maturities are shorter, usually in the 7-15 year range, with variable interest rates.

REGIONAL AGENCIES

The European bank for Reconstruction and Development, based in London, was established in
1991. Its purpose is to facilitate the transition toward open market economies and to promote
enterprise in Central and Eastern Europe. Its charter provides that 60 per cent of its investment
be in private loans or equity. The current focus is on rebuilding infrastructures, environmental
projects, telecommunications and the privatization of state-owned companies.
The European Investment Bank, based in Brussels, was established by the Treaty of Rome and
is the first of the regional development banks. Its purpose is to promote the growth of the
European Community, assisting in funding projects in underdeveloped regions of the EC,
modernizing existing facilities and contributing to development of the EC that has no other
means of financing available.
                The Inter American Development Bank, based in Washington, DC, was
established in 1959 for the purpose of improving economic and social development in member
countries. It is the largest source of external financing for Latin America and the Caribbean. The
bank has 44 members, including the USA and 16 other countries outside the region. The
bank's programmes lean toward the least developed countries, lending to both public and
private entities through the administration of three different funds. Interest rates and terms vary
from market to concessionary based on need.
The African Development Bank, based in Abidjan, The Ivory Coast, was established in 1964 for
the purpose of promoting economic growth and social progress of its member nations. The
bank finances both public and private projects at market rates for periods up to 20 years. It also
administers the African Development Fund, available to its least developed member nations
with terms up to 50 years and concessionary interest rates.
The Asian Development Bank, based in Manila, The Philippines, was established in 1966, for
the purpose of promoting economic development and cooperation in developing Asian
countries. It administers three funds offering both conventional and concessional loans for
periods of 20 to 40 years.


ARBITRATION IN RESOLVING INTERNATIONAL DISPUTES

No matter what financing technique may be used, occasional disputes are inevitable.
Arbitration provides a fast, efficient, fair, private and final process involving the submission of a
dispute to a neutral arbitrator who makes a decision subsequent to a hearing with
representation from both sides. Arbitration can be effected by including the proper clause in the
negotiated contract, with specific designation of the arbitration organization which will settle any
dispute, or, after the fact, provided that both disputing parties agree. (See also Chapter 24.)
                Arbitration awards are enforceable throughout the world. The Convention on the
Recognition and Enforcement of Foreign Arbitral Awards (commonly known as the New York
Convention) recognizes the enforceability of arbitration awards. Many countries have signed
the treaty and agreed to enforce awards issued by signatory countries. Other conventions have
similar enforceability and should not be overlooked. These are the Inter American Convention
on International Commercial Arbitration and the Convention on the Settlement of Investment
Disputes between States and Nationals of Others States. In fact, arbitration awards may be
more easily recognized and enforceable than judgments issued by foreign judicial courts.
                Arbitration, as opposed to litigation promotes the development and continuation
of good relations by reducing adversarial posturing of the parties involved. Usually more
economical, informal and private, it involves arbitrators with expertise, tends to reduce claimants
with unreasonable positions and eliminates unpredictable local judicial decisions. There are,
however, certain limitations of which one must be aware; the discovery process common to
American litigation is ordinarily not available; the decision is often not accompanied by a written
lengthy opinion explaining the award and the award is final there is no appeal process.
Major international arbitration organizations include The London Court of International
Arbitration, The Zurich Chamber of Commerce, Equilaw's International Arbitration Forum, The
Court of Arbitration of the International Chamber of Commerce, The Hamburg Chamber of
Commerce, The Japan Commercial Arbitration Association, The Arbitration Institute of the
Stockholm Chamber of Commerce, The Netherlands Arbitration Institute and the Korean
Commercial Arbitration Association.

SOURCES OF BUSINESS OPPORTUNITIES

The United States Department of Commerce can offer assistance on financial issues, licensing,
etc. Pretaped replies to specific licensing questions and connection to a live consultant are
available at (202)-482 2753. Trade America offers trade leads, referrals and other information
at (405) 624 3319. The Small Business Foundation of America offers referrals to trade
specialist regionally at (800) 243 7332. The Canadian government offers the Business
Opportunities Sourcing System, questions answered at (613) 954 5031. And finally, World
Trade Center databases, ‘TradeLinks’ and ‘Network’, connect 186 centers in 75 countries,
information available at (212) 435 2552.


RECOMMENDED READING

Clarke, Brian W International Trade Finance, loose-leaf handbook updated
       twice a year. Beaconsfield: Chiltern Publishing, UK.
Perry, Eugene W (1989) Practical Export Trade Finance Homewood, ILL.: Dow
       Jones – Irwin obtainable from the NACM Bookshelf.

About the Publisher - Who is Gower / Ashgate:

Ashgate is a leading independent press dedicated to publishing the finest academic research - Each year
Ashgate publishes more than 700 new books across fifteen subject areas in the Social Sciences and
Humanities, representing the best academic research from around the world.
Gower and Lund Humphries are part of the Ashgate Publishing Group One of the most trusted brands in
business and management publishing for over forty years.
Specialist publishers of research and scholarship - Books published within the Ashgate program are
subject to peer review by recognized authorities in the field.
Ashgate Publishing Group is international - Offices in the UK, North America and Australasia

Publisher: Gower / Ashgate Offices: Farnham, Surrey UK
http://ashgate.com/

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Handbookof International Credit Management Second edition

  • 1. With permission from the Publisher, we are able to share the entire text from the chapter I authored (chapter 21) in the "Handbook of International Credit Management" Second Edition Edited by Brian W. Clarke (The chapter appears on pages 316 through 327 in the Handbook - spelling is as edited in the UK) 21 EXPORT FINANCE TECHNIQUES IN THE USA Albert A. Cannistra With world trade now in excess of three trillion US$, it stands to reason that more companies are looking beyond their own borders for increased market opportunities. Of the top 100 global retailers, 55 percent have already expanded retail operations outside their base country. Service industries, engaged in a multitude of diverse activities, now trade in excess of one trillion US$ annually and are expected to be among the fastest growing providers of new jobs and revenues. Clearly, the vision beyond the year 2000 is one of a global village. Barriers to cross border trading are coming down; protectionism, while not entirely without visibility, is eroding as more governments realize that expanding sales abroad increases jobs at home. Removing regulatory obstacles that give preference to local sources, removing extra costs imposed upon consumers and eliminating government intervention in
  • 2. international trade will allow entrepreneurial companies to compete effectively in a global market-driven economy. The recent GATT agreement and the transition from embryonic to functional institution to be known as the WTO [World Trade Organization] is a major step by more than 100 nations in embracing the global village concept. As globalization takes hold, traditional methods of export finance are likely to undergo an evolution that will result in more transactions on risky open account terms. Prompted by competitive pressures and accompanied by more available information, increased standardization of trading rules and improvements in technology, the change in the way business is conducted is inevitable. This chapter will address financing techniques in use today and will attempt p provide the American exporter with a variety of finance options and a reference to various institutions whose purpose in some way may provide sources of capital for international trading. Any apparent duplication with parts of Chapter 20 and other chapters is deliberate in that, although US multinationals operating in Europe and elsewhere may find similar techniques and options, they are often applied in subtly different ways. SHORT-TERM FINANCING There are essentially five ways to collect payment for goods and/or services sold to customers abroad. Each, once beyond prepayment, carries its own degree of risk for the exporter. Variations exist within the five categories, yet upon closer examination each variation can be classified within the basic framework. Cash in advance, letter of credit, documentary sight draft, documentary time or dated draft and open account are the five basics. The appropriate choice is determined by the buyer's creditworthiness, the ability of the exporter to finance, market conditions including political conditions and hard currency availability, the competitive situation and the importance of the market to the sellers goals. Variations may involve third parties, guarantees, government programmes and insurance providers. In most cases, banks play an indispensable role in conducting an international transaction. COMMERCIAL BANKS Commercial banks, an icon of international trade, have long been the providers of many corporate financial services. Large European banks had an advantage over American banks in that their American counterparts were restricted by regulations limiting their ability to expand beyond their state borders. That changed in more recent times as banks were allowed to form holding companies with ownership crossing state lines provided that operating headquarters were maintained at each state office. As this book is being prepared, the Congress has approved and the President is expected to sign, new legislation allowing the banks to operate one headquarters office.
  • 3. The current policy shift will allow banks to realize synergistic savings by consolidation of administrative functions. The banking industry itself will no doubt concentrate into fewer, but more powerful institutions better suited to serve an increasingly diverse customer base and better able to compete in a global environment. As the banks increase their arsenal of financial products, the former tendency to specialize in local industry should give way to a broadened outreach for international opportunities. EXIMBANK Eximbank (Export Import Bank of the United States) is an agency of the US government. Its function is to assist exporters of US goods or services in obtaining necessary financing. Among the programmes available are guarantees of medium term credit sales (1 5 years, may be longer depending on product), arranging loans to foreign buyers of goods or services originating from US sources, arranging loans to intermediary lenders financing US exports and the granting of guarantees to assist US businesses in obtaining working capital to support an export sales function. The bank’s headquarters are located in Washington, DC. Single sale and repetitive sales to the same customer are eligible for guarantee. The costs of the guarantee vary depending upon repayment terms, the country and the type of customer; it is possible, when negotiating the contract to include these costs in the pricing scheme. LOCAL STATE GOVERNMENT Small- and medium-sized businesses should look to their own states for export financing assistance. Various programmes exist which can supplement the offering at the federal level. Some programmes provide the majority of the financing with a portion supported by a commercial bank. Other states may offer working capital loan guarantees, sometimes only in conjunction with an export sale backed by an irrevocable letter of credit or export insurance. COUNTERTRADE Common forms of countertrade include barter, counterpurchase and compensation arrangements. This methodology, in various forms, is among the most commonly employed non conventional means of international financing. Typically, the buyer requires the seller to accept full or partial payment in the form of specific goods or to find another buyer for those goods. This method of financing is well suited to transactions in East West trade and with developing countries in Asia, Africa and Latin America. Barter involves the exchange of goods for goods of comparable value without the transfer of money. Most often, these are negotiated one-time transactions that are consummated in short time periods usually, completed in less than 24 months. The goods to be exchanged and the quantities are always specified at the time the contract is signed.
  • 4. Counterpurchase is similar in that it also typically involves a one time transaction in the short term. The difference is that counterpurchase involves two linked contracts in which the seller agrees to deliver goods to the buyer, accept goods in return as payment from the buyer and, in turn, resells those goods to a second buyer for payment in the form of currency. Compensation arrangements are usually much larger value deals, typically involving large scale projects extending over a long period of time. This type of arrangement is best suited to the delivery of technology or equipment for a specified project accompanied by a reciprocal agreement to purchase specific goods or services resulting from that project. Countertrade is covered in detail in Chapter 17. PROMISSORY NOTES Provided the seller has the means, short term financing may be accomplished by having the customer sign a promissory note and obtain the collateral signature of the principals or the corporations which own the assets pledged to guarantee the payment of the transaction. When using this form of financing, compliance with local requirements of negotiable instruments, specific language, interest rates, place of payment and currency of payment are essential. In the event that formal collection of the note is required, documents evidencing existence, authority and legal standing of both debtor and creditor may be required. LETTERS OF CREDIT Modern day letters of credit can be traced back to the early 1800's; their beginnings are traceable back to banks in the U.K. After the First World War, this activity became popular with European and American banks and has evolved into a sophisticated, controlled process which is described in considerable detail in Chapter 16. A letter of credit is a commitment by a bank to pay a seller a certain sum of money at a future date provided the seller is in compliance with the specified terms of the credit. The letter of credit can be payable on presentation or, in the case of a time (acceptance) letter of credit, payable forward a specified number of days. The methodology provides a compromise between the buyer, whose interest is protected by not advancing payment until documentation evidencing shipment or performance is delivered, and the seller, who is interested in being guaranteed payment upon providing proof of compliance. Depending upon the needs of the shipper, a time letter of credit may be discounted to the bank for immediate funds or the proceeds of the letter of credit may be assigned to a third party. The rules governing letters of credit are not codified US law (i.e. not governed by the Uniform Commercial Code), but when cited on the letter of credit become binding on all parties. There are several types of letters of credit. A revocable letter of credit is one that can be revoked by the issuing bank at any time prior to presentation. This particular type of credit cannot be relied upon for guaranteed payment. An irrevocable letter of credit is one that cannot be canceled prior to its expiration date except with the consent of all parties involved. In this case, the beneficiary relies upon the creditworthiness of the issuing bank and its promise to pay in the specified currency on the date of maturity. A confirmed irrevocable letter of credit has the
  • 5. guarantee of a secondary bank, usually in the supplier's own country, and it is this bank which becomes the suppliers source of payment. Before accepting a letter of credit, its terms and conditions should be reviewed by the beneficiary to determine his ability to comply with all terms and conditions. If there are conditions which cannot be met, the buyer should be requested to instruct the issuing bank to issue an amendment making the letter of credit acceptable to all parties. Discrepancies will cause a letter of credit to go unpaid pending the buyers subsequent approval and instructions to the issuing bank and, without that approval, the credit may go unpaid indefinitely. Revolving letters of credit Revolving letters of credit may be used when business transactions are expected to be conducted on a regular repeating basis, such as an agreed upon monthly purchase. Instead of opening multiple credits to cover each shipment, a revolving letter of credit with multiple drawings over a specified period of time allows the beneficiary to draw up to a designated amount at specific intervals and self renews for the next period. Revolving letters of credit can be cumulative or non cumulative. If cumulative, amounts not drawn in one period carry over to the next and subsequent periods accumulating value for possible future drawings. If non cumulative, amounts not drawn are lost. Stand by letters of credit A stand by letter of credit is one in which a bank guarantees payment up to a specified amount, for a certain period of time, to a specified beneficiary, provided that the beneficiary presents required documentation within the terms of the stand by. Documentation can be as simple as a signed letter from the beneficiary stating that payment was not made nor performance completed as agreed. It is a letter of credit which typically is not expected to be drawn upon. This type of letter of credit allows for the extension of an open account type arrangement from the supplier to the customer with the assumption that the buyer will make good on their promise to pay, but assures the supplier that in the event of a default by the customer, the supplier will receive payment from the issuing bank. It is also used in a manner similar to a surety bond or guarantee, where, the bank assures a buyer of performance by the seller with monies available to the buyer in the event of default by the seller. Back to back letters of credit Back to back letters of credit may be used in circumstances where a merchant, who buys product and then exports it, lacks sufficient means to justify open account terms and does not want to pledge collateral to enable a letter of credit to be opened in favour of his suppliers. The merchant’s foreign customer opens a letter of credit in his favour and that letter of credit is deposited in the merchant's bank and used by his bank as ‘collateral’ to issue a letter of credit in favour of the original supplier of the goods. The merchant's bank will match its letter of credit
  • 6. to the foreign customer's original in terms of documentation and conditions. The differences will be in the amount of the credit, price, shipping dates and period of validity. Under certain circumstances it may be possible for the supplier to be paid under the merchant's letter of credit even if the merchant is unable to comply on the original letter of credit. Banks are, however reluctant to be placed in such a position, so caution is suggested in carefully reviewing terms of the secondary credit. There is an additional concern in that, if possession of the goods is given to the merchant and ultimately not conveyed in compliance with the terms of the original letter of credit, the secondary letter of credit may be totally uncollectable. BANK GUARANTEES Bank guarantees are not synonymous with letters of credit. In some countries, guarantees are a means of assuring payment to the supplier on behalf of the purchaser. The bank issuing the guarantee will hold adequate security but will apply outstanding guarantees to the importer’s credit ceiling thus reducing overdraft and other facilities. These guarantees are not without internal control as banks classify the guarantees as actual liabilities rather than potential liabilities and are restricted by reserve requirements imposed by the local Central Bank. Not all banks may be acceptable to the exporter. U.S. banks are prohibited from issuing bank guarantees and reference is made back to the stand-by letter of credit as an American alternative. PERSONAL GUARANTEE OR CORPORATE GUARANTEE Not unlike bank guarantees, personal or corporate guarantees are the assurance of a third party that a debt will be paid. This type of guarantee may be used when a US individual or corporation has a vested interest in a foreign company and wishes to induce the extension of credit facilities by a supplier based upon its own strength. The guarantee is, however, only as sound as the individual or corporation that stands behind it. DISCOUNTING ACCEPTED DRAFTS/BILLS OF EXCHANGE Documentary collections (see Chapter 15) are the written confirmation of arrangements between two international trading parties in which shipping and other documents are presented by the exporter through a third party, usually a commercial bank, to the importer in exchange for payment or the promise to pay. If payment is expected on presentation, this term is considered "at sight." The promise to pay at a future specified time takes the form of a "time draft" or "dated draft" and assumes the risk that the importer will pay as agreed at a later date. The documents accompanying these collections are evidence of performance by the exporter and the presentation of this evidence enables the collection of funds by the bank. Clean collections work in the same manner except that there is no accompanying evidence of performance. This type of collection involves the bank collecting funds from importers solely on presentation of the exporter's bill of exchange, the shipping and other documents having gone direct to the importer. Promissory notes, or other forms of financial receipts can be used as
  • 7. clean collections. Clean collections can be used for a variety of reasons such as cash management(allowing the exporter to know when payment should take place) or to add payment discipline to an open account customer who should want to avoid any adverse commercial publicity surrounding dishonored bills of exchange. They may also be a requirement in some countries that use clean drafts as a method of controlling foreign exchange through a central bank. Documentary collections 9not to be confused with documentary letters of credit) are not without risks. There is no question that they provide more security than strict open account, but they do not provide the same third party guarantee given by a letter of credit. There is the possibility that the buyer will not take possession of the goods and abandon the transaction either because of financial or market changes. If this occurs, the shipper faces the possibility of having to quickly find another buyer or having to pay return freight, in either case accompanied by demurrage charges, or even the possibility of total loss of the entire shipment if it were sold for salvage value. Negotiating documentary collections with a commercial bank is a means for an exporter to obtain immediate cash. An assumption is made that the bill of exchange is worth its face value (self liquidating) when payment specified is due and the bank will advance funds less certain discounting charges. It is important to recognize that this negotiation is with recourse and, in the event of the buyer’s default, the bank will expect to be reimbursed by the seller with interest on the funds advanced. The buying discount rate is the rate at which the accepting bank discounts its bankers' acceptances. It is the effective interest charge for funds paid in advance of collectability. Rates will fluctuate on a daily basis and will vary according to market conditions, creditworthiness of the buyer and other factors as determined by the accepting bank's treasury department. EXPORT FINANCNE AND CONFIRMING HOUSES There are few confirming houses operating today, most of the business now having been absorbed by commercial banks. This method of financing was popular in the UK where its original purpose was locating exporters for overseas buyers and providing a guarantee of payment against clean documents. The financing offered by the confirming house allowed the exporter to be paid in 30 days, at a discounted rate, with the buyer paying the confirming house at some future specified date. In its original concept, the confirming house brought unsolicited orders to the seller; in its modern variation, sellers tend to seek out the ‘bank’ export finance house for facilities available in a particular market. FACTORING Factoring is another means whereby an exporter can turn his invoices into immediate cash funds. Funds can be obtained without recourse in approved markets and with credit approved
  • 8. customers. Invoices are sold at a discount to a factoring house which will also provide comprehensive ledger and collection service. This means of financing is usually attractive to smaller- and medium-sized companies that have no credit administrative infrastructure of their own. Larger companies, staffed with proper levels of expertise, tend to avoid this alternative as being too costly, preferring to conduct the function internally at a fraction of the cost. EXPORT CREDIT INSURANCE The purpose of credit insurance is to avoid unexpected losses and to guarantee the selling company that it will be paid for goods shipped to and/or services performed for commercial buyers who default on payment obligations (see Chapter 10). Exporters can obtain coverage for both political and commercial risks, and the insurance policies can be used to enhance trade finance facilities. Studies indicate that fewer losses occur on new accounts than on old established customers. An account that may have been good for a decade or two causes the loss because of deterioration of its business, a change in focus or a change in the controlling interest. Any of these occurrences may go undetected especially if the account pays its bills to your company on a timely basis right up to the end. In international trade, use of credit insurance may cut costs by removing the need for letters of credit, enabling the seller to be more competitive and, perhaps, more aggressive in certain markets. Another reason for considering use of credit insurance is the increase in the collateral value of your own accounts receivable to lenders. It allows the reduction of bad debt reserve to a negotiated deductible level, allows better budgeting by capping losses and provides an outsource credit support service. CAPTIVE INSURANCE COMPANIES FOR EXPORT RISKS This concept is best suited to the larger, multi divisional company that already has an established captive for other insurance needs. The costs of operating solely for the purpose of export insurance would usually be prohibitive. Self-insurance makes a company less vulnerable to the cyclical movements of the credit insurance market, but imposes many other considerations which must be carefully evaluated prior to this undertaking, not the least of which is re-insurance in the outside insurance market and the consideration of whole turnover or catastrophe forms of coverage. Other considerations before embarking in this arena are the need for administrative and operational management of the captive, assessment of an acceptable level of losses that the company can endure, procedures to be followed and standards of acceptable risks to be taken at the divisional level and a means to monitor compliance. The establishment
  • 9. of terms, conditions and pricing to the divisions by the captive must also be considered. Assistance from the outside insurance market should not be overlooked. FORFAITING Literally meaning ‘without recourse’, forfaiting is a form of medium-term export financing that had its beginning in Europe in the 1950s. The technique evolved with specialists in the former West Germany, Switzerland and Austria who were dealing with East European paper; today, London is a leading centre for this type of transaction. Forfaiting is currently used in the USA, albeit not being as popular as other methods of financing. An exporter has the option to seek out sources in any major US financial centre or with a London based specialist. (See also Chapters 9 and 20.) This method of financing is suggested when there is a need to go beyond 90-180 day facilities, the exporting company is unwilling or unable to provide financing themselves and when direct bank financing may be too cumbersome. It is a means whereby the seller may offer extremely competitive terms to the buyer without the added risks. Forfaiting normally involves the issuance of a bill of exchange or a promissory note which, after acceptance by the buyer, are avalized (guaranteed) by a major bank, then discounted by a forfaiting bank for immediate payment to the exporter and subsequently held to maturity or resold in the `a forfait market. The forfait market is estimated to be US$ 30 billion in terms of understandings. The US portion is estimated to account for US$ 5-6 billion. Compared to other finance options, forfaiting is simple and flexible, but it is also more expensive. Unlike current Eximbank programs, there is no US content requirement for goods sold. GOVERNMENT-RELATED SOURCES Most export finance schemes with different degrees of government involvement cover medium- term project financing but some short-term finance might also be available. US GOVERNMENT AGENCIES, ETC. OPIC [Overseas Private Investment Corporation] is a U.S. government agency whose function is to promote US private investment in developing countries. Investors can look here for assistance in new ventures or the expansion of existing ones; assistance may be in the form of political risk insurance, direct loans or loan guarantees. The political coverage protects up to 90 per cent against expropriation, nationalization or confiscation by a foreign government, war or insurrection and currency inconvertibility; the investor will be at risk for the remaining 10 per cent. The U.S. Department of Agriculture supervises the operations of the CCC (Commodity Credit Corporation), another agency of the US government. The function of this organization is to make guarantees, where necessary, in order to increase or maintain US agricultural exports to a foreign market. Usually, this guarantee is necessary only when commercial institutions are
  • 10. unable or unwilling to provide financing without the accompaniment of a guarantee, an example being a sale to a country with a shortage of hard currency. PEFCO (Private Export Funding Corporation) is a consortium of commercial banks, industrial corporations and financial service institutions formed to provide supplemental export financing through the normal channels. Working with Eximbank, loans of medium- and long-term nature are made to finance the purchase of US goods or services by foreign buyers. Typically, financing is available for larger projects such as ocean vessels, aircraft, power plants and industrial projects. THE WORLD BANK GROUP The IBRD (International Bank for Reconstruction and Development), known as the World Bank, is the parent to the three-member World Bank Group and a sister organization of the International Monetary Fund (IMF). The purpose of the group is to channel money from developed countries into developing nations for productive purposes with a goal of raising the standard of living in those nations. Focus is on high priority economic projects which have basic financial soundness. It is a requirement that procurement of goods and services be made on an international competitive basis in order to accomplish maximum benefit. The IMF, owned and operated by more than 150 member countries, provides financial and technical assistance to developing countries throughout the world. Working with the central governments of member countries, the Fund seeks to promote exchange stability, economic development and the expansion and balanced growth of world trade. The IDA (International Development Association) is another affiliate of the World Bank. Its purpose is to work with less-developed countries whose resources and balance of payment positions preclude borrowing on conventional terms from the IBRD. Operating policies are identical to the IBRD except as related to repayment terms. Concessional terms are given to the beneficiary countries, often with terms up to 50 years, a minimal service charge and no interest. The IFC (International Finance Corporation), the third member of the World Bank, invests in the private sector of developing countries. It is a provider of unsecured equity and loan capital promoting projects that have economic benefit and local participation. Loan maturities are shorter, usually in the 7-15 year range, with variable interest rates. REGIONAL AGENCIES The European bank for Reconstruction and Development, based in London, was established in 1991. Its purpose is to facilitate the transition toward open market economies and to promote enterprise in Central and Eastern Europe. Its charter provides that 60 per cent of its investment be in private loans or equity. The current focus is on rebuilding infrastructures, environmental projects, telecommunications and the privatization of state-owned companies. The European Investment Bank, based in Brussels, was established by the Treaty of Rome and is the first of the regional development banks. Its purpose is to promote the growth of the European Community, assisting in funding projects in underdeveloped regions of the EC,
  • 11. modernizing existing facilities and contributing to development of the EC that has no other means of financing available. The Inter American Development Bank, based in Washington, DC, was established in 1959 for the purpose of improving economic and social development in member countries. It is the largest source of external financing for Latin America and the Caribbean. The bank has 44 members, including the USA and 16 other countries outside the region. The bank's programmes lean toward the least developed countries, lending to both public and private entities through the administration of three different funds. Interest rates and terms vary from market to concessionary based on need. The African Development Bank, based in Abidjan, The Ivory Coast, was established in 1964 for the purpose of promoting economic growth and social progress of its member nations. The bank finances both public and private projects at market rates for periods up to 20 years. It also administers the African Development Fund, available to its least developed member nations with terms up to 50 years and concessionary interest rates. The Asian Development Bank, based in Manila, The Philippines, was established in 1966, for the purpose of promoting economic development and cooperation in developing Asian countries. It administers three funds offering both conventional and concessional loans for periods of 20 to 40 years. ARBITRATION IN RESOLVING INTERNATIONAL DISPUTES No matter what financing technique may be used, occasional disputes are inevitable. Arbitration provides a fast, efficient, fair, private and final process involving the submission of a dispute to a neutral arbitrator who makes a decision subsequent to a hearing with representation from both sides. Arbitration can be effected by including the proper clause in the negotiated contract, with specific designation of the arbitration organization which will settle any dispute, or, after the fact, provided that both disputing parties agree. (See also Chapter 24.) Arbitration awards are enforceable throughout the world. The Convention on the Recognition and Enforcement of Foreign Arbitral Awards (commonly known as the New York Convention) recognizes the enforceability of arbitration awards. Many countries have signed the treaty and agreed to enforce awards issued by signatory countries. Other conventions have similar enforceability and should not be overlooked. These are the Inter American Convention on International Commercial Arbitration and the Convention on the Settlement of Investment Disputes between States and Nationals of Others States. In fact, arbitration awards may be more easily recognized and enforceable than judgments issued by foreign judicial courts. Arbitration, as opposed to litigation promotes the development and continuation of good relations by reducing adversarial posturing of the parties involved. Usually more economical, informal and private, it involves arbitrators with expertise, tends to reduce claimants with unreasonable positions and eliminates unpredictable local judicial decisions. There are, however, certain limitations of which one must be aware; the discovery process common to American litigation is ordinarily not available; the decision is often not accompanied by a written lengthy opinion explaining the award and the award is final there is no appeal process.
  • 12. Major international arbitration organizations include The London Court of International Arbitration, The Zurich Chamber of Commerce, Equilaw's International Arbitration Forum, The Court of Arbitration of the International Chamber of Commerce, The Hamburg Chamber of Commerce, The Japan Commercial Arbitration Association, The Arbitration Institute of the Stockholm Chamber of Commerce, The Netherlands Arbitration Institute and the Korean Commercial Arbitration Association. SOURCES OF BUSINESS OPPORTUNITIES The United States Department of Commerce can offer assistance on financial issues, licensing, etc. Pretaped replies to specific licensing questions and connection to a live consultant are available at (202)-482 2753. Trade America offers trade leads, referrals and other information at (405) 624 3319. The Small Business Foundation of America offers referrals to trade specialist regionally at (800) 243 7332. The Canadian government offers the Business Opportunities Sourcing System, questions answered at (613) 954 5031. And finally, World Trade Center databases, ‘TradeLinks’ and ‘Network’, connect 186 centers in 75 countries, information available at (212) 435 2552. RECOMMENDED READING Clarke, Brian W International Trade Finance, loose-leaf handbook updated twice a year. Beaconsfield: Chiltern Publishing, UK. Perry, Eugene W (1989) Practical Export Trade Finance Homewood, ILL.: Dow Jones – Irwin obtainable from the NACM Bookshelf. About the Publisher - Who is Gower / Ashgate: Ashgate is a leading independent press dedicated to publishing the finest academic research - Each year Ashgate publishes more than 700 new books across fifteen subject areas in the Social Sciences and Humanities, representing the best academic research from around the world. Gower and Lund Humphries are part of the Ashgate Publishing Group One of the most trusted brands in business and management publishing for over forty years. Specialist publishers of research and scholarship - Books published within the Ashgate program are subject to peer review by recognized authorities in the field. Ashgate Publishing Group is international - Offices in the UK, North America and Australasia Publisher: Gower / Ashgate Offices: Farnham, Surrey UK http://ashgate.com/