With growth slowing across much of the Latin America as a result of the end of the commodity supercycle and economic rebalancing in China, as well as fragmentation of the international banking system, policies to stimulate growth are needed. This book examines the financial landscapes of seven Latin American economies—Brazil, Chile, Colombia, Mexico, Panama, Peru, and Uruguay—and makes a case for them to pursue regional financial integration. Chapters set out the benefits to the region of financial integration, the barriers to cross-border activity in banks, insurance companies, pension funds, and capital markets, as well as recommendations to address these barriers. Finally, the volume makes the case that regional integration now could be a step toward global integration in the short term.
2 | Benefits of More Global and Regional Financial Integration in Latin America
Luc Eyraud, Diva Singh, and Bennett Sutton
3 | Barriers to Integration in Banking
Iulia Ruxandra Teodoru
4 | Barriers to Integration in the Insurance Sector
Alla Myrvoda and Bennett Sutton
5 | Barriers to Integration for Pension Funds
6 | Barriers to Integration in Capital Markets
Alla Myrvoda and Bennett Sutton
7 | Legal Barriers to Regional Financial Integration in Latin America
Laura Lorenzo and Wouter Bossu
8 | Regional Initiatives to Achieve Financial Integration
Charles Enoch and Iulia Ruxandra Teodoru
9 | Risks and Mitigation for Financial Integration
Mohamed Afzal Norat and Carlos Caceres
Appendix 1. Brazil
Appendix 2. Chile
Appendix 3. Colombia
Appendix 4. Mexico: Financial System Overview
Appendix 5. Panama
Appendix 6. Peru
Appendix 7. Uruguay
Regionalization of Financial Services within a Global Context
Latin American financial sectors are once again at an important crossroad. Amid economic transition and important developments in global financial markets and regulatory frameworks, there is a growing case for greater financial integration and cooperation. In this context, this book analyzes the scope for—and benefits from—further “regionalization” of domestic financial services among Latin American countries.
Following the financial crises in the 1980s and early 1990s, Latin American countries opened up their financial markets to foreign participation. This brought in North American and European banks, which were regarded as a source of capital, expertise, and know-how, as well as an opportunity for diversification from domestic shocks. Moreover, this was accompanied by a fairly cautious attitude toward risk and thus the adoption of prudent regulatory approaches. Most regional regulators opted for a model of self-standing subsidiaries, ring-fencing of domestic capital and liquidity, and in some cases limiting domestic residents’ holding of foreign currencies and binding constraints on foreign investments by local financial institutions (for instance, pension funds).
Since the global financial crisis, Latin America has been facing a rapidly changing global financial landscape. Whereas global banks were previously seen as a source of strength, policymakers need to internalize that these banks could now represent a source of weakness for domestic financial systems. Global banks are retrenching from non-core business areas and regions. The implementation of worldwide regulatory initiatives has triggered moves toward fragmentation of global financial systems, thereby heightening the risk for further withdrawals of global banks from Latin America.
Moreover, the region is currently experiencing an important economic adjustment. Rebalancing of growth in China and the end of the commodity super-cycle are putting pressure on fiscal and external sectors in several Latin American economies. Consequently, there is a need for renewed sources of long-term growth throughout the region.
This changing environment, as well as the need to alleviate long-lasting supply-side bottlenecks, calls for a sound, efficient, and forward-looking financial sector. In this regard, regional financial integration could provide an important additional boost to financial intermediation and ultimately growth.
Timeliness and Relevance of the Main Themes of the Book
This book includes comprehensive coverage of the financial sector viewed through the lens of further financial integration in the region. Latin America has been characterized by the predominant role of banks within the financial sector. However, there is also significant scope for financial integration in the region through nonbank financial sectors, as evidenced by the growing number of initiatives in those areas.
The banking sector has experienced first-hand the withdrawal—or significant downsizing—of global banks from the region, leading to increased consolidation of domestic banking systems. Other financial sectors, such as pension funds and insurance companies, have expanded rapidly in recent years. At the same time, limited availability of marketable securities at home combined with restrictions on investments elsewhere challenges the efficient allocation of resources in these sectors.
Regionalization could attenuate some of the existing and potential difficulties. Regional banks could fill part of the intermediation void left by departing global banks in domestic markets, and the possibility of investing in mutually recognized, well-regulated regional financial markets would allow for greater efficiency and diversification of pension fund portfolios.
Finally, important regional initiatives provide a platform for further integration. Broad-ranging initiatives, covering a large number of areas beyond financial integration, such as Mercosur and the Pacific Alliance, are important examples. But these can be complemented by more targeted initiatives such as the Latin American Integrated Market (MILA) initiative, which seeks to integrate the stock exchanges of Chile, Colombia, Mexico, and Peru. Political support for regional integration is ample.
Benefiting from Further Integration While Keeping Risks at Bay
In summary, regional financial integration, although not a panacea, does offer a large number of benefits for Latin America. As highlighted in this book, these benefits include increased diversification of market risks, enhanced competition, economies of scale and cost reduction, transfer of know-how and operational best practices, and convergence of regulatory practices toward higher financial standards, among others.
Undoubtedly, greater integration also brings risks. Analysis suggests that most spillover risks are currently low and there is ample scope for further integration. However, this does not mean that there is room for complacency. Financial integration needs to go hand in hand with strengthening of regulatory frameworks, adoption of best practices, and increased cooperation among supervisory entities.
To conclude, Latin America is in need of a more dynamic financial sector that fosters robust and sustained growth. Regional financial integration could prove to be a key ingredient in this new growth recipe. This book provides some useful insights on how this can be achieved in practice.
Western Hemisphere Department
International Monetary Fund
The idea of a regional financial market in Latin America is not new. Several initiatives were launched in the past with this objective. However, after the repeated crises in Latin America in the 1980s and 1990s, many countries in the region opened their financial systems to the outside world, particularly Europe and the United States, to attract capital, gain expertise, and cushion themselves against regional shocks. At the same time, they sought to protect themselves against external spillovers: foreign banks had to enter as self-standing subsidiaries, currency controls limited domestic residents’ holdings of foreign currencies, and investment regulations severely restricted the external exposure of pension funds and insurance companies.
This strategy worked well for much of the past 15 years and Latin America recovered rapidly, fueled by the commodity super-cycle and growing demand from China, with prudent domestic economic management adding potency to the mix. Indeed, even the global financial crisis did little damage to this previously crisis-prone region.
The end of the commodity super-cycle and economic rebalancing in China have seen growth slow dramatically in most of Latin America, exposing the need to identify new, alternative avenues for growth.
Latin America has also been particularly affected by the fragmentation of the international banking system in the wake of the global financial crisis. European and U.S. banks have dramatically cut their involvement in the region, either withdrawing completely or downsizing. There are various factors behind this trend, including the regulatory pressure of the post-crisis reforms that have had a negative effect on the risk-return payoffs of certain business lines, the enforcement of sanctions against tax violations, and stronger anti-money-laundering regulations. No major European or U.S. bank has entered Latin America to replace banks that have left, leading to increasing consolidation of domestic banking systems in many countries.
In the nonbank financial sector, pension funds and insurance companies have been growing rapidly, and indeed have in some cases outgrown the domestic markets in which they are—to an extent that varies across countries—constrained, potentially undermining competition and reducing the efficient financing of capital across the region. Meanwhile, stock exchanges are facing increasing challenges, with volumes declining in many cases as a result of heightened market and regulatory pressures in the post–global financial crisis environment.
Structure of this Volume
This book is a study of seven Latin American economies (LA-7): Brazil, Chile, Colombia, Mexico, Panama, Peru, and Uruguay. It looks at the financial landscapes of these economies, and sets out the case for them to pursue regional financial integration: growth has slowed across much of the region and a stimulant is needed, at a time when fiscal space for expansionary policies is very limited or nonexistent. In addition, global banks have been withdrawing from the region and, unless they are replaced from outside national boundaries, there is a risk that competition in the national markets could be undermined. Benefits from regional integration include risk diversification, in that national risks across the region would be pooled, there would be increased growth from enhanced efficiency in the placement of assets or activities, and economies of scale could be realized. Higher financial standards, through the assimilation of regulatory and operational best practices from regional leaders, as well as technical know-how, could also accrue. Global integration remains an end goal, but is hard to achieve in the short term, and regional integration now can be a step toward global integration in the long term.
Chapter 2 quantifies the benefits that could be derived from regional financial integration. It shows also that Latin America is less integrated than other regions, so there will likely be scope for increasing this integration.
Latin American financial integration is constrained by a number of barriers. A central theme of the book is that there should be a comprehensive, if gradual, reduction in these barriers, together with actions to mitigate associated risks. Chapters 3 to 6 look at barriers to cross-border regional activity in banks, insurance companies, pension funds, and capital markets, respectively, and provide recommendations to address these barriers.
Chapter 7 looks at regional financial integration from a legal perspective. The chapter looks at domestic laws and regulations that constrain cross-border financial activity.
Two important blocs covering these countries have regional integration at the core of their mandates: Mercosur,1 and particularly its financial wing (“financial Mercosur”), and the Pacific Alliance.2Chapter 8 suggests that these two groupings could make significant contributions toward financial integration, putting together, separately or in coordination, a program covering many of the recommendations here. One umbrella recommendation is that, in order to carry the other recommendations forward in a consistent and comprehensive manner, the Pacific Alliance establish a small secretariat. As regards financial Mercosur, a revitalization of the alliance, and establishment of a comprehensive financial integration agenda among interested members, would also be timely and productive.
Finally, Chapter 9 looks at measures to mitigate the risks in cross-border financial integration. The authors indicate that risks of spillovers to other countries in the region from problems in one of these countries seem limited at present and can be mitigated, particularly through enhancing consolidated supervision across countries as well as across the various entities within cross-country conglomerates. Without achieving high standards in cross-border supervision, regional financial integration could jeopardize financial stability and substantially set back growth.
This book also contains appendices that describe the financial sectors in the seven countries covered.
Leveling the Playing Field Across the Region
Ensuring a level playing field among financial institutions from across the region could have a significant impact on enhancing regional integration. The book contains an array of recommendations to establish such a level playing field.
Country authorities should, in countries where this does not yet exist, develop an explicit, open, objective, and nondiscriminatory statutory and regulatory framework for entry of cross-border financial institutions. Regional financial organizations such as the Pacific Alliance and Mercosur could play a role here to ensure that such frameworks would be consistent across their memberships. The authorities could also ensure that within their countries domestic and cross-border banks have equal access to credit bureaus and to deposit insurance,3 as well as to regulatory authorities for physical branching permits.
Convergence of tax rates and arrangements are among the key factors cited by financial institutions that could encourage more cross-border activity. This could initially be facilitated by the development of stable and transparent tax rules for domestic and cross-border financial activities across the region, buttressed where appropriate by agreements for the avoidance of double taxation. Over time, regional bodies could work toward harmonization of tax regimes and further tax convergence.
Similarly, accounting and prudential regulatory frameworks should be harmonized, through consistent and timely adoption across the region of accounting principles compliant with the International Financial Reporting Standards, as well as of the Basel III prudential framework for banks, including consistent capital, leverage, and liquidity definitions. There should also be consistency across regulatory regimes for other parts of the financial sector, including Solvency II-type regimes for insurance companies and harmonized consumer protection arrangements.
Pension funds and insurance companies in nearly all countries in the region are heavily limited in the extent to which they can invest their assets across borders. Abrupt changes in these restrictions could cause disruptions in their respective markets. The countries’ authorities should, however, announce that over time they would relax these restrictions, in those cases where the restrictions are in place, so that the maximum cross-border investment ratio for pension funds and insurance companies across the region could be raised to 50 percent or higher. They should also ensure that procurement bids for financing infrastructure projects be open to institutions from around the region, and identify routes whereby limits on sectoral concentration for pension fund and insurance company investments do not prevent cross-border bidding for infrastructure projects.
Mitigating the Risks
Past banking failures, for instance that of the Bank of Credit and Commerce International in Europe, have frequently been caused by a lack of cross-border collaboration among national regulatory authorities. Enhancements to cross-border banking therefore need to be accompanied as a matter of urgency by cross-border consolidated supervision across the region, and with formal agreement, such as through memoranda of understanding, among the respective supervisors to ensure full cooperation in the exchange of information. In some countries, this may require legislative action to ensure that banking secrecy laws contain exemptions to allow the exchange of information with supervisory agencies in other countries. For banks with a significant presence in more than one country it would be useful that supervisory colleges be set up, where these do not already exist, so that the supervisors in all the countries where the bank has a significant presence meet regularly and have a full and up-to-date picture of the soundness of the bank. Importantly, supervisory colleges could also facilitate the adoption of best-practice supervisory standards across the region, encouraging a “race to the top” and preventing the anachronistic practice of “light touch” supervision that some countries (also beyond the region) have sought in order to try to achieve a competitive advantage.
Many major Latin American banks are part of industrial conglomerates, with the banks being subsidiaries of nonbank holding companies. This generates a dangerous supervisory lacuna where supervisory authorities do not have the power to also supervise the nonbank parents of the banks. In countries where this issue exists, legislative changes will be needed to broaden the powers of the supervisor. In general, conglomerate supervision will need to be combined with the cross-border consolidated supervision discussed above. In instances where this is not possible, regulatory limits will need to be set for intergroup exposures within banking groups, and between bank and nonbank parts of conglomerates. Moreover, the supervisory authorities will need to have the power to stop any intragroup transfers if they see that the conglomerates, in whole or in part, are in difficulty.
As the international community moves on from supervisory reform to resolution reform, this too should be a focus for regional banks in the context of financial integration. Legal frameworks for resolution and restructuring should be harmonized across the region. Restructuring colleges should be established so that—unlike during the global financial crisis in North America and Europe—the failure of a cross-border bank can be handled smoothly and efficiently.
Similar arrangements are needed for cross-border activities for nonbank financial institutions. Consolidated supervision is needed for cross-border nonfinancial institutions. For conglomerates, coordination is needed between bank and nonbank supervisors; usually a lead supervisor should be identified, based on the supervisory structure in the country concerned and the relative size of the banking and nonbanking activities of the conglomerate. Colleges of supervisors are also needed, and insolvency regimes for nonbank financial institutions need to be harmonized. Pension funds and insurance companies require oversight of assets purchased across borders. And though it is recommended (see the discussion of the Pacific Alliance countries below) that licensing of market players such as broker-dealers be passported, at least across the Pacific Alliance countries, so that a dealer who is licensed in one member country can operate in all the member countries, it is an important proviso that they nevertheless be subject to supervision in both their home and host countries.
Risk mitigation is a critical concomitant to the proposed liberalization of cross-border financial activities in the region. Indeed, liberalization—such as allowing pension funds to invest a higher share of their assets across borders—should only be permitted where arrangements are fully in place for these to be properly supervised, together with remedial actions in the event of difficulties or failure.
Other Measures to Foster Regional Financial Integration
The home countries of global banks are intensifying anti-money laundering efforts, as well as efforts to combat the financing of terrorism (AML/CFT), both in Latin America and elsewhere. Failure on a national level to comply fully with these efforts, and with the Financial Action Task Force (FATF)4 standards that underpin them, could increase the process of fragmentation of a country’s financial system from that of the global economy as global banks withdraw from correspondent banking and other relations with the country. Full compliance with FATF requirements, and additional measures that may be sought by the home countries of the global banks, would foster a more thriving domestic financial sector and provide impetus for enhancing regional cross-border activity too. Harmonizing AML/CFT efforts across the region could serve to raise the standards overall, provide a stronger signal to global banks’ home countries regarding the seriousness of the region’s AML/CFT efforts, and avoid the stigma of being found to have given shelter to the sorts of activity that AML/CFT is seeking to eliminate.
Central counterparties (CCPs) are widely seen as potentially carrying systemic risk. Latin American countries should assess the compliance of the regulatory frameworks of their CCPs through peer reviews across the region using the CPSS-IOSCO Principles for Financial Market Infrastructure (PFMI) methodology.5 Integration will be fostered and financial activity more generally stimulated if, upon demonstration of compliance, countries of the region recognize each other’s CCPs and/or regulatory frameworks. Over time, there should be progressive harmonization across key characteristics, in order to embed best practices, with long-term potential for cross-border mergers.
More broadly, countries should review where they still retain exchange controls. Such controls clearly inhibit regional integration, although they likely remain in place to help the country’s authorities achieve other macroeconomic goals and financial sector prudential policies. Relaxation should therefore be progressive, eliminating remaining controls in a sequenced manner. These measures could include, for instance, permitting individuals to hold foreign exchange accounts onshore.
Regional financial integration is arguably hampered by the absence of a common currency, and the need to pay “double fees” to exchange one regional currency for another through transactions involving the U.S. dollar in New York. Mexico has already established netting arrangements under which certain Mexican banks can net their dollar assets and liabilities so as to reduce the volume of transactions that need to go through New York. Other member countries may wish to examine the possibility for extending such dollar netting arrangements to their own countries. Beyond that, in conjunction with the IMF,6 they may also wish to examine the possibility of regional currency settlements in non-dollar currencies, and ultimately cross-currency.
Brazil has by far the largest financial markets in Latin America, comprising about half of the total activity. Relaxation of some of its restrictions on cross-border financial activity could serve as a signal for greater openness, strengthen Brazil’s financial markets further, and reduce the cost of finance across the region. Although many restrictions can already be circumvented using offshore entities, use of such entities has come under increased suspicion, and is likely to come under further scrutiny. It would be useful for Brazil to stay ahead of this curve; where activities are permitted to Brazilians, it would in general be better for them to be undertaken onshore.
At the moment it is not permitted for non-Brazilian bonds to be sold onshore in Brazil. Eliminating this restriction could be a significant step toward integrating Brazil’s financial markets with those of the rest of the region. Brazil could also reduce the fragmentation of its own public bond market by eliminating the current practice of requiring separate legislation for each issuance. And although institutional investors are permitted to invest abroad, this currently must be undertaken through Brazilian asset management vehicles. This restriction is outdated. A limited liberalization in this regard would be to allow cross-border regional investment to be undertaken through regional asset management vehicles. This would also serve to encourage the development of such vehicles, possibly stimulating regional institutional development more generally.
Brazilian institutions have been expanding across the region in recent years. Bank Itaú now sees itself as a regional bank, with the region as its home market. And the Sao Paolo stock exchange has bought 8 percent of the stock exchange of Santiago, thus following a trend that is well-established elsewhere in the world, of increasing cross-border integration of stock markets. These trends are market driven; however, the Brazilian authorities could publicize that they welcome such developments. To offset possible nervousness among partner countries in the region, such clarifications should be accompanied by measures, such as reducing restrictions on cross-border activity, encouraging inward investment into Brazil, or raising financing in Brazil for other countries in the region.
Brazil was a founding member of Mercosur, an alliance that has among its objectives the financial integration of its member countries. Although Mercosur registered impressive achievements in its early years, it has been less active recently. This may be a good time to revive the financial Mercosur. On the Brazilian side, financial Mercosur may be a good vehicle for the initial stages of financial integration, taking integration measures with those fellow members of Mercosur that wish to participate. Among other countries, the new government of Argentina has expressed its support for a revitalization of the body. Active pursuit of an integration agenda by Brazil—together with Argentina and other interested countries—could achieve significant success.
Four countries of the region have together formed the Pacific Alliance, the aim of which is also to foster financial integration among its members. Although Brazil is unlikely to wish to join this alliance in the foreseeable future, the Pacific Alliance could make a good partner for Brazil’s own integration efforts elsewhere. Areas for Brazil to explore jointly with the Pacific Alliance would include increasing cross-holdings of ownerships in stock exchanges and harmonization of capital market practices.
Pacific Alliance Countries (Chile, Colombia, Mexico, Peru)
The Pacific Alliance should establish a small secretariat in one of its member countries, tasked with preparing and disseminating a comprehensive framework for integration, including timelines and sequencing; maintaining momentum; ensuring consistency; coordinating the political big-picture announcements with the technical specifics for taking the process forward; and gaining the benefits of proceeding through reciprocity. Its work would be both inward- and outward-looking: the inward-looking aspects including ensuring that all members of the Pacific Alliance are moving forward together, and providing assistance if any of the member countries is facing difficulties. Its outward-looking work would include arranging activities to encourage investment into member countries, participating with other regional groupings such as the Association of Southeast Asian Nations (ASEAN), with which the Pacific Alliance already has close links; working to achieve interregional liberalization and integration; and liaising with prospective new members. The establishment of close links with ASEAN is one of the success stories of the Pacific Alliance to date; further progress in this regard is likely to continue bringing economic benefits.
Pacific Alliance countries could foster integration by permitting a higher tranche for investment into other member countries and, beyond that, by allowing cross-border investments within the Pacific Alliance to be counted as domestic, once appropriate supervisory arrangements have been put in place. Also, remaining ratings-based country limitations for pension fund investments across member countries should be replaced by specific foreign currency and corporate limitations. Insofar as a member country (existing or prospective) has not yet signed the IOSCO Multilateral Memoranda of Understanding, it should be required to do so.
The Latin American Integrated Market (MILA) initiative, which covers the Pacific Alliance countries, has received considerable publicity, but very few trades have so far been conducted. The authorities should urgently discuss measures to help kick-start MILA with markets and other private participants in member countries. To enhance its role, MILA should be expanded beyond its present capacity, which includes primary and secondary markets for equities, to also include sovereign and corporate bonds. Operational procedures for member country capital markets should be harmonized, including all aspects of listing requirements and technical arrangements, such as opening hours. Broker-dealers registered in a member country should be passported to operate through the MILA membership area, subject to effective supervision in both home and host countries, as recommended for Pacific Alliance countries. Further cross-ownerships across the exchanges of the member countries should be considered.
Pacific Alliance countries should also examine the possibility of harmonizing their financial sector safety nets, so as to move toward best practices and to reduce the risk of intercountry arbitrage. Bank deposit insurance and capital markets investor protection programs are two areas for initial work on harmonization. In the long term, the countries may wish to consider a common fund and a single investor protection regime. These could serve to increase the visibility and credibility of financial institutions and markets in the Pacific Alliance countries, and serve to increase participation from both within the member area and outside.
Finally, Pacific Alliance countries can enhance contacts among national regulators and supervisors, including through bilateral exchanges of staff and secondments to the proposed secretariat. This would serve to increase awareness of best practices in other parts of the area, and provide a corpus of officials that would take a broader, regional perspective.
Panama and Uruguay
Panama and Uruguay are considerably smaller than the other countries in the study. They are therefore particularly affected by developments in neighboring countries, and may have a special interest in integration efforts among their neighbors.
In recent years Panama has made great strides in developing as a regional hub in a number of economic sectors, such as transportation. Its role as a regional financial center, historically relied on a model of “light touch supervision” that nowadays is obsolete. Panama can nevertheless reestablish its position as a regional hub by refocusing on the provision of high-quality services, and ensuring that capital, disclosure, and other prudential requirements are at least as strong as those of other countries in the region. As a hub, Panama should be particularly supportive of moves toward regional integration; and the authorities should continue to look closely at the Pacific Alliance, and consider the potential benefits of joining. From the point of view of the Pacific Alliance, the inclusion of Panama would also be useful, providing added linkages inside and outside the current membership, including through Panama’s use of the U.S. dollar as the national currency.
Uruguay is a founder member of Mercosur, with the headquarters in its capital. The country would have an interest in supporting the revitalization of financial Mercosur, to take forward the integration agenda on a broad front.
Uruguay still maintains tight restrictions on the extent to which it permits its pension funds and insurance companies to invest outside the country, notwithstanding the relatively small size of the domestic economy. Uruguay should consider raising the foreign asset cap on Uruguayan pension fund investments, and ending the restriction that pension funds’ foreign purchases must only include securities from multilateral institutions. Uruguay could also look into the possibility of cross-country integration more broadly, including, for instance, partnerships for the Uruguayan stock exchange that enable the exchange to maintain a critical mass of activity and continue to provide services.
This book was prepared under the general guidance of Alejandro Werner, Director of the IMF’s Western Hemisphere Department. It derives in large part from visits to Brazil, Chile, Colombia, Mexico, Panama, Peru, and Uruguay from May to July 2015 by most of the authors of the chapters in this book, as well as from analysis at IMF headquarters. We wish to thank our counterparts in each of these countries, both in the private and public sectors, who gave generously of their insights and time. We also thank Marco Piñon for his contributions during these visits. Papers from these visits were reviewed by country authorities, and by colleagues at IMF headquarters, and were presented at a seminar at the 2015 IMF Annual Meetings in Peru and to the IMF Executive Board. We thank all who participated.
We extend our appreciation also to Joanne Creary, Joe Procopio, and their colleagues in the IMF’s Communications Department, who coordinated the editing and production of this volume. Excellent assistance was provided by Modupeh Williams.