1 CENTER FOR GLOBAL DEVELOPMENT PUTTING PENSION FUNDS TO WORK IN LATIN AMERICA: PROPOSALS FOR NEW FINANCIAL INSTRUMENTS TO HELP DEEPENING FINANCIAL MARKETS FEATURING THE LATIN AMERICA SHADOW FINANCIAL REGULATORY COMMITTEE (LASFRC) Thursday, July 14, 2005 10:00 a.m. - 11:30 a.m. Brookings Institution 1775 Massachusetts Avenue, N.W. Falk Auditorium Washington, D.C. [TRANSCRIPT PREPARED FROM A TAPE RECORDING] MILLER REPORTING CO., INC. 735 8th STREET, S.E. WASHINGTON, D.C. 20003-2802 (202) 546-6666 2 PARTICIPANTS: Roque Fernandez Former Minister of Finance, Argentina Pablo Guidotti Former Vice Minister of Finance, Argentina Ricardo Hausmann Professor of Economics, Harvard University Former Chief Economist, Inter-American Development Bank Former Minister of Planning, Venezuela Ruth de Krivoy Former President, Central Bank of Venezuela Liliana Rojas-Suarez President, LASFRC Senior Fellow, Center for Global Development Former Chief Economist, Latin America, Deutsche Bank Roberto Zahler Former President, Central Bank of Chile MILLER REPORTING CO., INC. 735 8th STREET, S.E. WASHINGTON, D.C. 20003-2802 (202) 546-6666 3 P R O C E E D I N G S MS. ROJAS-SUAREZ: Good morning. Thank you very much for coming today. As you know, we are the Latin American Shadow Financial Regulatory Committee. I will spend just a couple of minutes to introduce ourselves. First of all, I will start by giving you all our Web page because all the statements that we write are posted there. So it is www.claaf.org.---CLAAF. What does CLAAF have to do with the Shadow Financial Regulatory Committee? It's because in Spanish it's [SPANISH PHRASE.] This is a group of independent economists that in the past have had high-level positions either in the government or in the private sector, but now are completely independent, and its mission is to shadow the regulators both in Latin America and multilateral organizations that define or advise governments into financial policies that are going to be affecting the future of Latin America. We've been functioning for about four years now, something like that, and this is our 13th statement. That's why I gave you the reference to the Web page so that you can take a look at what are the issues we've been dealing with. The members with me right here--I don't know if you have gotten--if you have, I think--a list of the--yes, you do, okay. So in addition of the people present here, the committee also has Angel Guria [ph], who was with us until yesterday, but he had to go back to Mexico, as you know. Now, he--well, he used to be the former of Mexico, but now he's one of the top candidates for the position of the Secretary General of the OECD. So he went back. Of course, if he takes that position, he cannot become part of the committee. He will become a non-active member. Then we also have Ernesto Talbi [ph], who is the director of the think tank in Uruguay called Ceres [ph]; Miguel Mansera [ph], who is the former president of the Central Bank of Mexico. We have two Brazilians: Mr. Contador [ph] and Mr. Pedro Carballo de Melo [ph]. Pedro was here, too, and he is a director at the Security Exchange Commission in Brazil. And representing Central America we have Mr. Guillermo Chapman [ph], who is the former Minister of Finance of Panama. Okay. Now that you know who we are and what our mandate is, why don't we focus on the statement that I hope you have in your hands? You're all aware, and the reason why you have come is because I'm sure you know about Latin America being a leader of reform in the pension fund systems among developing countries. MILLER REPORTING CO., INC. 735 8th STREET, S.E. WASHINGTON, D.C. 20003-2802 (202) 546-6666 4 These reforms started in '81, in Chile, and since then progressively have been adding more and more countries and now there are ten countries in the region. What we have found as a fact is that the assets held by these pension funds are increasing continuously and at a rapid pace. On average, they are 10 percent now of GDP in most countries, but we forecast that--not only us, a number of studies--by 2015, this ratio is going to reach 30 percent of GDP. The interesting statistic is that that is basically the same ratio of financial intermediation done by banks. So by 2015, if banks don't expand more, which they're recently not doing, you're going to have a financial intermediary that basically is comparable with the size of the banking system. Now, when the pension fund was--the reform of the pension fund system took place, a large priority, as it should have been--it's very understandable--was to ensure safety, transparency and integrity. And for that, there was a number of regulatory conditions that largely limited the set of financial assets where the pension funds could invest. Pension funds were and are allowed to invest in government paper, in bank deposits. But when you ask whether they an invest in equities or bonds, there is a restriction and the restriction is that they have to be listed--the companies have be listed in the stock exchange. They have to be public offerings of the instruments that are being offered by these companies. Now, there is a number of problems that I know you would like to hear from us about the pension fund systems, and let me just tell you what we are not going to talk about. For example, pension funds have a significant problem in terms of the coverage. A large amount of the population is still not covered, and we are not going to talk about that. We are not also going to talk about the high concentration of the pension fund industry and the fiscal cost and long-term sustainability of the reform. And the reason why we are not focusing on these particular issues is because we have identified one that we believe actions can be taken in the near future and represent at the same time a major problem. And for one statement, one issue is sufficient. The problem is that we have identified an increasing gap between the supply of pension fund savings and the capacity of the markets to supply instruments meeting the regulatory requirements. In other words, the pension funds are accumulating a lot of resources, and besides government bonds and bank deposits, there are very little places to invest. Okay? And we believe that this gap is growing. This morning, we had an interview with some representatives from the press and somebody was asking us, well, how does this compare MILLER REPORTING CO., INC. 735 8th STREET, S.E. WASHINGTON, D.C. 20003-2802 (202) 546-6666 5 with the United States? And the answer is that the problem is exactly the opposite as in Latin America. In the United States, you have a huge capital market and a little part of the savings not being part of the private pension system scheme, and that little part can easily integrate into the already existing capital markets. In Latin America, you have a private pension fund that is increasing, increasing, increasing, and no capital markets. Okay? So what if, having identified this problem, we ask ourselves what is the problem? Why are we concerned about that? Well, we think that the major danger is that the pension reform is not going to deliver its full potential in terms of growth and investment; that it is a waste. That's our concern. Why is this happening? Well, we believe that, of course, a very important reason is that there has been little growth in the region, right? If there is no growth in the region, well, this reflects a depressed demand for investment. However, the regulatory framework also plays a very important role in preventing the closing of the gap between the supply and demand from funds. We think that the existing corporate structure in Latin America is very different from that in industrial countries, while at the same time the regulatory framework is just mimicking the industrial country framework. How does the corporate structure differ in Latin America from that in industrial countries? Well, very simple. In most Latin American countries, the large majority of firms are small, closed, familyowned. And if you ask them, they do not want to open. They do not want to go into being public offerings, for many reasons. And as we discussed yesterday, you cannot rule out the fact that the region is not a safe region and many firms would not feel comfortable in giving information--the small firms, in giving information about their particular situation because of fear of even criminal attacks. Now, you could tell us, well, yes, that will evolve. You know, as growth proceeds, companies will be willing--they will not have enough resources on ? and banks will not have enough capacity to lend and they will open up. Maybe, but the truth of the matter is that we don't see that in the foreseeable future, but we see the gap growing now. So when you face that, the question is what to do. And we believe that a combination of new instruments and change in regulation can make the trick while we converge toward a more developed system. Let me give you just one idea of one kind of instrument and the kind of regulatory changes that you will need to have. As I was telling you, most companies are small and medium-size enterprises, because remember the large corporations actually can finance themselves MILLER REPORTING CO., INC. 735 8th STREET, S.E. WASHINGTON, D.C. 20003-2802 (202) 546-6666 6 abroad. They don't even need the domestic capital markets. We're talking the ones that are potential sources for additional growth in the countries. How do they finance themselves besides their own savings? Well, they go to the banks, for good reasons. A bank can assess the quality of this small client, and we believe that that is what is going to continue happening, that the bank is going to be the major source of external finance for the majority of enterprises in the region. Okay? But what can we do? These bank loans could be repackaged and sold as a package, mainly little loans sold as a big pooling of loans to a fiduciary. Okay? This has one effect. First, the loans are out of the banking system, freeing resources for more loans to the small and medium-size enterprises that we think are going to go nowhere else. Okay? So we are accepting the fact that at least in the short and medium term, medium and small enterprises go to banks and nowhere else. Okay? So we're trying to free more resources for the banks. Okay, now these package of loans have been moved to a fiduciary, but this fiduciary now can issue liabilities that can be now purchased by somebody else. And we assume, or we propose that among those that can purchase these new instruments are the pension funds. What are the instruments? How does the instrument now become a source attractive to the pension fund? Well, because even though there is 1,100 loans in this big package, I basically will strip the instruments into different categories of risk. So we say, okay, you want to be safe? All right, so one tranche of this category will be very safe with little return. If you want to take more risk, then you even buy equity. So this is financial engineering. That's all it is. It's financial engineering. You are not forcing anybody to buy the instrument. The idea is that the pension funds who right now in most countries are holding only government bonds and deposits might find attractive to getting to an instrument that by pooling risk and choosing the category of risk they are willing to take--they are willing to take--will allow for the mobilization of resources from the banks to the capital market and allow for the creation of instruments available for the pension funds to absorb. To give you one example, the document presents five, but I don't want to get into each of these, but we can discuss all of them with my colleagues here. More than that, we think that regulations restricting the investment of pension funds abroad are too binding. Too restrictive is the word, too restrictive. If you want to allow pension funds to diversify for both return and safety, you need to let them invest abroad. How much? We don't have a consensus among the group, and we don't think we should MILLER REPORTING CO., INC. 735 8th STREET, S.E. WASHINGTON, D.C. 20003-2802 (202) 546-6666 7 have a consensus among the group for reasons that I will explain in a second. But clearly the change in regulations imply more flexibility to the investment of the pension funds. We should allow pension funds, with the proper procedure for disclosure, information. Not necessarily we should require the firms to go into public offerings. If we require that, there's not going to be financing to firms domestically. Now, I told you that we don't have consensus about how much to open, and we don't have consensus on many things. Why? And we're not trying to get consensus. Why? Because what we are doing through this statement--and we believe it is the role of the committee--is to identify a problem, put ideas for thoughts, for consideration of people like you and people in the region, and then let the countries design the processes. You know, when the pension reform was implemented, in most countries this was a case of crisis, right? I mean, there was no other way to go. But I'm not talking about crisis now. I'm anticipating that in the future this gap is unsustainable. We have time, but in the time is not us, is not a group of 12 people who can or should provide the solutions for the country. Instead, we think it's a question of opening up a process in which the different members and participants have a word and take a place in the decisionmaking. We actually have a name for a committee that we would suggest should be formed and it's called the Financial Market Development Commission. But we believe--and you will find that in section 4 of the report, but we believe that that is country-specific; that the amount of risk that a given system is able to take or willing and capable to take is not something that we should say; that the countries should decide that themselves. Okay, let me stop right here and ask my colleagues to add or expand on what I haven't said or what they would like to emphasize a little bit more, and then we open for discussion. MR. : I want to talk about a little bit or complement the view that Liliana has just exposed. In a certain sense, it is a problem, but at the same time it's an opportunity, okay. In a certain sense, we think that we are at a stage in the evolution of institutions starting from the initial situation in which many of these pension reforms were adopted, in which essentially it was already a revolution to actually allow individuals to have individual capitalization accounts, okay. So part of the response of congress, politicians, regulators was actually to protect a lot the future pensioners by putting a lot of capital market restrictions. And also this was based on the fact that the MILLER REPORTING CO., INC. 735 8th STREET, S.E. WASHINGTON, D.C. 20003-2802 (202) 546-6666 8 view was that the major source of finance was still the banks, okay, so that eventually the banks, which typically have a more short-term credit, would be the initiators of a process that then would cascade into other forms of finance into a private sector. And, you know, after 10 years, 15 years in some countries of this reform, what we find now today is that funds have increased so fast, but the cascading has not actually functioned. First of all, banking systems have remained small mainly because of vulnerabilities, uncertainties, macroeconomic crisis in many cases. And essentially they have remained very short-term-oriented. And on the other hand, we many times say that there is--we don't find a demand for credit in Latin America. Well, maybe we don't find demand for short-term credit, but there is certainly a lot of need for long-term investment, okay. And the fact is that when you arrive to these other forms of finance to the private sector, suddenly we find that regulations impose restrictions that really are not fully consistent with the type of preferred finance that the private sector would need in Latin America. A second issue is that up to now, in a certain sense it has been very easy for pension fund managers to have the largest portion of their returns essentially coming from interest on government bonds, which essentially reflected high-risk premia, okay. And in this you have essentially two cases, cases such as Argentina in which, in fact, risk materialized, and we have seen massive intervention of the government forcing more bonds into pension funds, okay. So in a certain sense, now we realize that that was not really maybe the best way to get high returns for pensioners. On the other hand, we have some other countries in which, in fact, the macro economy has evolved favorably and interest rates on government bonds are falling, okay. So in a certain sense, when you look into the future, it's not clear that the same high returns, easy high returns on government debt are going to be the engine in pension funds. So maybe it's the time in which we can actually try to convince different stakeholders in society that maybe there is a way to use pension funds more productively for long-term investment projects in the private sector. And it's very important to realize that the process that we sort of put forward which seems like, you know, building a commission, seems like a bureaucratic thing, in fact, reflects that these are not necessarily simple regulatory changes, okay. In most countries, this requires changes in legislation, okay, so it requires the intervention of congress. It requires, you know, making sure that these changes, although they expand the type of instruments and go beyond simply MILLER REPORTING CO., INC. 735 8th STREET, S.E. WASHINGTON, D.C. 20003-2802 (202) 546-6666 9 publicly traded securities, also do not place excessive risk on pension funds. So, you know, one has to convince workers and future pensioners that the reform actually can add value, okay. And this is why we think that the process aspect is really a crucial point. Finally, I think that it's always necessary to recognize that there is sort of a tradeoff between how much we see this as an opportunity to promote growth and investment versus clearly the fiscal transition costs that are very high especially for countries that, you know, maybe initiate the reforms now or that have initiated the reforms recently. I mean, I think that, you know, our view is that maybe the '90s view when some of the reforms were undertaken was a little bit naive in the sense that people thought simply, well, this is a reform that eventually improves intertemporal solvency of governments. So capital markets should be very willing to understand that we are simply translating bonded debt and substituting for unregistered pension obligations. And in many cases, one can even argue that the bonded debt-that that switch actually reduced total obligations, so it would be fiscally good, okay. But, you know, then we have found that sudden stops are a major part of life for emerging market finance, and liquidity considerations are important. And so the fiscal transition costs are an essential component that has to be addressed both by governments in terms of understanding what is their actual effective capability of responding with fiscal policy, and also we think multilaterals should actually consider seriously the implications on financing and borrowing requirements that reforms of long-term value and long-term span have on government finances. MS. ROJAS-SUAREZ: You want to add ? ? Anybody else? No, okay. Why don't we open to questions and from that we build up? We found out it's easier that way. MS. : [Inaudible.] MS. ROJAS-SUAREZ: Use the microphone right there. You could use it so we can hear you. MS. : I work with the Inter-American Development Bank and this is an area--this issue of investment liberalization is an issue that we have been tackling for some time in most of the countries that have undertaken the structural reforms. The problem that we have encountered is that governments are using this mechanism as a way to finance themselves and cover their fiscal deficit. So while we could propose--we have been proposing this now for some years. I think it's going to take something in addition to this to get governments to implement fiscal discipline, as well as liberalize the investment criteria. MILLER REPORTING CO., INC. 735 8th STREET, S.E. WASHINGTON, D.C. 20003-2802 (202) 546-6666 10 MS. : I guess one of the innovations that this approach brings to the table is that we are identifying mechanisms whereby specific stakeholders in the economy, such as infrastructure development, agriculture, small and medium companies, and so forth, have a tool whereby they could tap a source of long-term funding. They have until now been out of the discussion in terms of pension funds because it seemed to be irrelevant. Pension funds involved pensioners and government and banks, and banks in two ways, providing the instrument for pension fund investment, deposits, and often owning and managing the pension fund industry, as such. By opening the discussion and bringing instruments that allow for a wider sector of society to benefit from the long-term funds that are managed through pension funds, we're bringing new social stakeholders into the picture. And this financial sector development committee in each country could be a way to catalyze the process, because if you there get together government, legislators, the business community, the banks, the pension fund managers, et cetera, there is a forum to discuss these issues and to promote the kind of legislative changes that are needed to balance the need for pensioners to have a safe and profitable instrument to ensure their pensions in old age and for the economy to develop the financing instruments that are needed to promote growth and, in turn, improve investment. So perhaps this is an approach that might help open the window to solutions to your problem. MR. : Let me say just a little bit. MS. ROJAS-SUAREZ: Before that, just a question of order. Yes, thank you. A hand--would you mind going, if people go kind of-MS. : Thank you. I think it's a very interesting proposition, as well. My-MS. ROJAS-SUAREZ: Can you identify yourself, please? MS. : My name is Anita Campion [ph] from Kemonics [ph] International. I'm actually curious because the first proposal you were talking about with having the banks sell their portfolios and then being able to just have the liquidity to be able to go ahead and expand their portfolios further sounds wonderful. My concern is that many Latin American countries don't do-the banks don't do a very good job in lending especially to small enterprises, but even some to the medium enterprises. And I think that banks see them as a very different risk than the portfolio they probably lend to, primarily the larger enterprises, or they know those families very well, et cetera. So what else would you see would be necessary? To me, it seems like there would be more needed in working with those banks on MILLER REPORTING CO., INC. 735 8th STREET, S.E. WASHINGTON, D.C. 20003-2802 (202) 546-6666 11 being able to expand their portfolios in ways that they haven't had to in the past. MR. : Well, let me mix the two questions. The first question was, you know, the problem is that governments have very large deficits and they're using the pension funds to fund themselves. That is sort of like a different problem from the one we are identifying. Typically, the legislation puts a cap on how much government that the pension funds can buy. In fact, many countries are up to their cap and they cannot buy anything more. So there's more money than actually can flow into the government. But the worst thing that can happen now, for example, is for the government to start running a surplus. That may be good for the macro economy, but if the government were to run a surplus, then the pension funds will really be without anything to buy. So in some sense, the problem is one of insufficient instruments for the pension funds to buy, not one of crowding out by fiscal authorities. Now, we propose several instruments in the document. The one that Liliana mentioned is the collateralized loan obligation. So the idea is that, you know, an obligation, a bond is something that has to have a certain maturity. It has to have two ratings. It has to be traded on an exchange. It has to have liquidity. It has to have, you know, a circular offering. It has to have disclosure standards, and so on. All of this generates very large fixed costs which can only be justified if you are going to issue, say, $10, $20, $50, $100 million in a bond. That's never going to be done by a small and medium enterprise. So if you restrict pension funds to buy these traded instruments, you are restricting them to buy stuff issued by very large corporations. And if you look at corporate bonds in Latin America, they are issued by utilities. That's it, and the banks, and that's it. So essentially what we are saying is you can extend the reach of financing by taking a bunch of loans which don't have to be traded, don't have the same disclosure standards, don't have the same maturity standards, and so on, and you create--you tranche it so that you can generate as many different categories of risk as the market wants, and then you sell them as obligations. So that is the concept behind this initiative. It's something that exists in the U.S. It's something that might or might not work out in Latin America, but we will never know until we adjust the legislation to let it happen, okay. Now, banks--but that's not the only instrument we have. You know, we have--there is collateralized, you know, mortgage-backed securities. Mortgage-backed securities are being developed in Colombia. MILLER REPORTING CO., INC. 735 8th STREET, S.E. WASHINGTON, D.C. 20003-2802 (202) 546-6666 12 They have worked better in some countries than in others, but it requires a concerted effort. There are legal changes in different aspects of things, in the way market participants originate the mortgages, and so on. And that requires a certain coordination for these markets to take place, and that's why we think that we need a process whereby this coordination can happen, if it's regulatory changes, if it's legal changes, if it's market participants to agree to do things in some way. And that's why we would like to open some kind of policy process. In some ways, this policy process occurs more successfully in better-functioning political systems than in others. You could say that Chile is a place where this process more or less takes place, and there's been very active reform and transformation of the legislation to accompany the development of a capital market. In countries that have less trust, less confidence in the political system, this may become more problematic. People may not trust the pension fund administrators. They may not trust the market participants. They may not trust this or that, or they may not trust the politicians who would like to get a hand on the pot to finance some cockamamie social idea. So they would like to tie their own hands so that they are not forced to do things they don't want to do, and so on. So that's why this policy process has to be designed in a way that is compatible and consistent with the public interest. And that's why we have some ideas on how to make it transparent and accountable so that it's not diverted to other reasons. MR. : I would like to make two comments. One is that probably the bulk of possibilities of issuing these sorts of securitized bonds is from the loans from the banks. There, I think that in certain countries you may find the problem in terms of banks maybe not willing to do that, for different reasons, and I think that's not a minor comment. So the point I would like to stress is that in our statement we do a more general sort of approach regarding securitization which is not only from bank loans, but also from different sorts of activities. It could be department store receivables and it could be some, I would say, nontraditional sorts of activities. There are some experiences in the region, in Chile and in Colombia and in other countries--at least I know in Chile and Colombia-where you have been able to securitize the sort of, I would say, very nontypical sort of receivables. And I think that is something which could also--is included in our statement. And the other point I would like to mention that perhaps something which is very crucial here is that when you think in terms of CLOs especially, or CMOs, which are two of the five instruments that we MILLER REPORTING CO., INC. 735 8th STREET, S.E. WASHINGTON, D.C. 20003-2802 (202) 546-6666 13 mention in our report, clearly these types of instruments would require a change in legislation or regulation regarding investment by pension funds in Latin America in the sense that the tranche which pension funds would buy from these sorts of assets would be extremely difficult to trade in a sort of public offering in a stock exchange. Therefore, we would need some sort of change in regulations, which is not a minor component of our proposal. Thank you. MS. DE KRIVOY: I would like to add a comment to address the question posed with respect to bank lending to small and medium companies, and the uneasiness or the difficulties that banking systems in Latin America have faced when trying to expand their loans to small and medium enterprises. Why are we thinking of banks? Banks are the best-equipped institutions in our countries to assess credit risks. And although there are problems and companies may find it difficult to get a loan, there's nobody else around to do it. And, in fact, as of today banks have a portfolio of loans to large, medium and small companies that could be packaged in these structured products and partially sold to the pension funds. If we think of Basel II and of the trend that it is generating in terms of securitization and transfers of risk from the banking industry to insurance and other sectors of the financial industry, by implementing these kinds of proposals what we're doing is bringing the pension funds, which are major players in our countries, to facilitate this process to lead to a healthier lending process which should not impair the banks' health, because we need healthy banks, and at the same time bring players that may invest in that. So what these products are really helping us is strengthen the ties within the financial industry, be it banks, insurance companies which will play a role in guaranteeing some of these obligations, and the pension funds. And it needs a concerted effort to reform regulations because it's not only pension fund regulations. We have to look into banks, we have to look into insurance, capital markets and, of course, fiscal problems. So banks may have difficulties, but they are the institutions that are best equipped. And by the way, I would like to refer you to one of our previous statements which dealt with some recommendations on small and medium enterprise financing in Latin America which you may find as an interesting complement to what we're talking about today. MS. ROJAS-SUAREZ: Yes, just one point to complement what Ruth said because I think this is very important to your question. We believe that these kinds of reforms will strengthen the banking system. Why? Because remember this instrument that we just described MILLER REPORTING CO., INC. 735 8th STREET, S.E. WASHINGTON, D.C. 20003-2802 (202) 546-6666 14 where you have different tranches. Well, the different tranches have to actually be respected, right? I mean, if I tell you that you have seniority and there is a judicial problem, then that has to be enforced. So you actually--for this to work, you need better judicial institutions to actually support that this work, which will enhance the other activities that banks do such as ? and the problems related to that--so, yes, without the adequate set of institutions, clearly neither banks nor capital markets work. Heinz [ph], thank you so much for being so patient. Please introduce yourself. MR. : I'm Heinz Rugel [ph], currently with the IMF, formerly with the Ministry of Finance of Chile. I share with you your views in terms of the gap between supply and demand, and I share also the concern regarding future pensions of people in the context of low returns coming basically from bank loans and government bonds. However, you proposed four different instruments and after all the explanations you have given, actually what you are saying is countries need to improve their infrastructure, their financial infrastructure. And that's the bottom line, because you just mentioned, for example, that you need to improve the judicial system. For example, if you want to launch infrastructure bonds, what you need at the end of the day is to have very clear--that the ? rights may be very clear for everybody. If you want to launch securitized loans, you need a good rating agency. I mean, if you want to have five different tranches, who's going to rate that? Who's going to say, well, this is really first-grade? I mean, you need strong rating agencies, and that's why I get confused when I heard Ricardo saying, well, we cannot do everything at once. What do you think? In trying to lower the kind of--the requirements for offering these bonds to the market that the pension funds may increase the level of risk that they are taking? I'm not quite sure if what you are saying is, well, let us improve the infrastructure, the financial infrastructure of the countries. In that way, the pension funds will be able to buy some better products, some better instruments, or if you are saying, well, since countries have very small loans to very--I mean banks take very small loans to small companies; well, let's try to work with that and let's see where it ends up. MS. ROJAS-SUAREZ: My colleagues are going to expand a lot on this because you have raised a very, very important issue. I just want to make one comment on something very specific that you said. You asked us, are you proposing that the pension funds increase the risk of their portfolios? MILLER REPORTING CO., INC. 735 8th STREET, S.E. WASHINGTON, D.C. 20003-2802 (202) 546-6666 15 You know what? In Latin America where most of the components of the pension funds are government bonds that have actually defaulted in a number of countries, I don't think so. I don't think that pension funds right now are holding safe assets. MR. : What I think at the end of the day what should happen is that people should decide the level of risk that they want to take. And if there's people that just--old people that just want to get involved in fixed bonds, it's fine, I mean, and young people that want to get involved in more risky instruments, it's their decision. So what we should focus in the future is try to let the people to decide what kind of assets and what kind of risk/return they're willing to take. MS. ROJAS-SUAREZ: Okay. Ricardo. MR. HAUSMANN: I share your views on risk. I think what we're talking about is sort of like independent of the risk issue. It's a separate issue from the risk issue. What we are talking about is not you should take more risk or less risk. What we're talking about is essentially that we have created a huge pension fund system on a non-existent capital market and we have regulated the pension funds to buy capital market instruments. Now, why is it that the capital market is small relative to GDP in Latin America, while it is huge relative to GDP in the U.S.? Well, essentially because the guys generating the GDP are not in the capital market. Now, that is the flow of income that needs to be financed that is going to pay for the liabilities. That's the reality. Now, you have to ask yourself the question, why is it that GDP is generated by companies that are not in the capital market. Well, one reason is that capital markets have these very high fixed costs and these very high thresholds; that smaller companies find it inefficient to fund themselves by going to the capital market. Whether these costs are actual costs because you can only fund yourself with very--you know, a $20 million bond issue is a small bond issue. It's a ridiculously large amount of funding for the bulk of the enterprises, so that you find, say, in a country like El Salvador, to go to the extreme, there are no companies that now or ever-- with good judiciary systems or with bad judiciary systems, that will find it advantageous to go through costs of an initial public offering and a traded security relative to the costs and the risks of simply going to the banks and accepting shorter-term lending. So part of the problem is that we have forced an amount of savings into a set of instruments that are too small to be invested in. So that is the nature of the problem. Now, you can say, well, the solution is to wait for the corporations to grow and develop and formalize themselves, and so on, so that in the future these savings might be used. MILLER REPORTING CO., INC. 735 8th STREET, S.E. WASHINGTON, D.C. 20003-2802 (202) 546-6666 16 But we're forcing the workers now to put the money into these pension funds and we owe it to them to have that money invested productively and to have an adequate return for them, not for anybody else. So that is the nature of the problem. That is associated with the fact that we have been unable to transform the claims on the GDP that is being generated outside of the capital market into financial instruments that can be purchased by the pension funds. So what we are saying is you need to have instruments that bridge this gap between what funding is needed in the economy and the risk characteristics that are acceptable to pension funds. So I'm not saying anything about whether pension funds should be risky or less risky. I think that obviously they should want to benefit from the yield curve. They have long-term liabilities. What are they doing investing in short-term assets and foregoing the benefits of the yield curve? They could potentially invest in a lot of other stuff, but given the regulation they have, they're forced to invest in only these very large and relatively highly-regulated utilities. So there is a lot of the economy that is out of their reach. And so the argument is that in order for this to work, we have to find the instruments whereby you can get these sorts of savings to the corporate structure as it is, because the funds are coming at a fast speed and the speed of corporate transformation or institutional transformation is much slower. It's markets that have to be developed. It's not long term the development of institutions because the money is flowing much faster than the speed at which these institutions are going to take place. So market development is the challenge, and for market development you need some kind of--we would like to put the attention on the fact market development is the binding constraint; focus on relaxing the regulatory or institutional constraints that are preventing this to happen. That's the nature of the issue. MS. ROJAS-SUAREZ: Please limit your questions to a couple of minutes. I'm going to ask the panel to limit their answers to very brief statements because there's a number of you who want to talk and we're preventing you from talking. So can I please--I think Elliot [ph] was the first who--can you take the mike, please? And then, Desmond [ph], would you follow? And then I forgot--well, okay, then if you could continue in the line. MR. : Thank you, Liliana. Yes, following up a little bit on what Heinz was saying--Elliot Kalter [ph] at the IMF--one, I very much agree that these imbalances are becoming increasingly important, and I'm seeing it from the perspective of the work that I'm doing. MILLER REPORTING CO., INC. 735 8th STREET, S.E. WASHINGTON, D.C. 20003-2802 (202) 546-6666 17 And I want to raise a couple of issues that I think you already addressed, but just wanted to indicate for me the importance. One, why one would want to see capital markets become important in terms of offering finance for corporations. One reason would be that they require transparency, they require good governance. And in the end, that in itself would be a factor reducing risks. So it would be important to me that when you package these commercial loans that it be done in a way that this transparency of the individual companies that were part of this basket--it was still required. Otherwise, you're getting around one of the major positives of capital markets. A second thought is that in Chile, as Heinz knows better than I, you have now the corporate sector is taking advantage of capital markets. And I think you already do this, although I haven't read the paper yet. But in addition to coming up with new instruments that would be appetizing for the pension funds, given changes in regulations, what are other countries doing that are having success? So what can we learn from--it's true that Chile is in a different stage. It has a political system that has allowed various regulations to take hold. But what can we learn from Chile--and you mentioned Colombia--before going to new instruments? And just a third thought is while I was on a plane going somewhere recently, I sat next to a fellow who works for an investment bank here in Washington and he was going to Latin America to buy packaged commercial bank loans that sound very much like what you're talking about. So it may exist, but I now have to call him and see if this is what he was talking about. MS. ROJAS-SUAREZ: Roberto, you want to--okay, why don't I collect some questions so that everybody has a chance? Okay. MR. : I'm Desmond Glauckman [ph] from the American Enterprise Institute. I'd just like to go to a point that was raised by Mr. Zahler which I think really goes to the essence of the problem, whether the panel could discuss a little bit more about the incentives for the banks to package their loans to give it to pensions when, in fact, it would seem to me that banks have got a captive source of funds right now from the pension funds. You know, I'm not sure that I see what the incentive would be for them to do it. You know, I'd just make the observation that in the United States it seemed that the whole idea of collateralized bond offerings were developed by investment banks who were promoting a process of disintermediation out of the regular banking system. I just don't know how the panel would address that, you know, whether there's a role for MILLER REPORTING CO., INC. 735 8th STREET, S.E. WASHINGTON, D.C. 20003-2802 (202) 546-6666 18 investment banks, in general, or foreign investment banks, in particular, to actually do this packaging. MS. ROJAS-SUAREZ: Thank you. Please. MR. : Alejandro Escobar [ph] from the IDB. I'm just wondering if with regards to the small and medium enterprise financing if the solution really is around, you know, these diverse sets of financing. You mentioned El Salvador, Honduras. For some of these countries, the main source of GDP is SMEs, and I'm thinking that here in the U.S. a lot of these sized companies don't go to the capital markets. They go to venture funds and venture capital funds. And I'm not sure a bank which will have more access to a diverse set of instruments will actually lend--as you say here, they see a very high risk in these organizations--and compared to what a venture capitalist would do, get engaged more in the management, governance, financing alternatives prior to their going to the capital markets. I'm wondering if really more access to liquidity in this manner would make sense for SMEs in Latin America, where what they need more is ? venture capitalists would get engaged in the business and in the sector. MS. ROJAS-SUAREZ: There was another question. If you could just please--yes, if people could just approaching the micro-MR. : I'm Marco Brukes [ph] from the International Finance Corporation. One idea that I mean you may wish to consider is something we've been trying, not without a lot of success, but I think the comment made by Mr. Hausmann on the capital markets is key. I think, I mean, the cost of getting entities to the capital markets is very expensive. So one idea that may be worth exploring--and I'd like to get your views--is getting the pension funds to get some sort of participation on balance sheet. In other words, for example, the problem with SMEs. You cannot take SMEs to the capital markets, but if you could be able to take some risk on a portfolio basis in some banks' balance sheets and then the regulators would give some capital relief to the commercial bank, that could be a good way to bridge, I mean, the development of the capital markets until they reach a level where those funds can be deployed. MS. : Thank you. MR. : Christopher Herman [ph]. I'm with the Environmental Protection Agency. I can explain later why I'm here. [Laughter.] MR. : I was just hoping that the other panelists would take a few minutes to respond to the question that was flagged by the IMF MILLER REPORTING CO., INC. 735 8th STREET, S.E. WASHINGTON, D.C. 20003-2802 (202) 546-6666 19 earlier--and you said there would be a number of responses--with respect to the risk profile of the pension fund. Thank you. MR. : I'm Richard Jones [ph]. I'm a UK actuary currently working at IFC. Two points. First of all, I think as in every economic issue, there's a supply and demand, and you have to address the demand side. And in any pension situation, people ideally should be able to manage their risk profiles. So creating a broader range of choices for the members of the AFPs has got to be a good thing, and that in itself will create a demand. So in that sense, one would support the sort of things you are proposing. The second point is a much more general one; that is, that the privatization of pension funds around the world has generally been the case of governments trying to get rid of a problem. I think governments have to recognize that privatization doesn't completely remove them from the scene and that they have an ongoing obligation to ensure that the privatized pension industry actually functions, and functions effectively. And by that, it's not just a question of security, but also delivering the returns that will enable people to get sensible pensions, having sacrificed their income for so many years. And you made the point earlier on that this is a purely sort of Latin American or developing country issue. In some ways, it's not. There's a much broader issue that has different manifestations. For example, in the developed world the issue where pension funds are much more mature and where the balance between savers and retirees, people drawing an income, is rather different. The issue there is actually shortage of long-term secure assets. And as governments have reduced their budget deficits and have reduced particularly their stock of long-term debt, the ability to find suitable assets for annuity, to invest back in annuities, for example, has become a huge problem. That has forced down the yield on long-term government stock to almost ridiculous levels. So annuities are very unattractive. Governments have to realize they have an ongoing responsibility for the health of the pension industry. It's not just a question of getting rid of the liability. MS. : My name is Tatiana Namagan [ph] from the World Bank. MS. ROJAS-SUAREZ: A little bit-MS. : Okay. Can you hear me now? MS. ROJAS-SUAREZ: Yes. MS. : I work at the World Bank and we have just been carrying out an assessment of the Brazilian financial sector from a corporate governance point of view. And, there, we actually see that MILLER REPORTING CO., INC. 735 8th STREET, S.E. WASHINGTON, D.C. 20003-2802 (202) 546-6666 20 pension funds are starting to experiment with investing in unlisted companies, but this is where the problem comes in. For example, let's take the case of the pension funds for the telecom industry. They are trying to go into non-listed companies directly, kind of like a venture capital type involvement. And I don't need to tell you the conflict of interest that are a potential in this kind of involvement. So how confident are you--and this exactly directly speaks to my IMF colleague's questions--that a sophisticated financial intermediation industry can get developed in the either medium or short term in order to cover the gap that you're concerned with that anyway in the long term will be covered in other ways? MR. : I am Sol Hadano [ph]. I manage the retirement plans office of IDB. Apparently, everybody is trying to chase investment and chase yields. I'm sure that if these instruments are so good as you apparently are hoping, you will have a lot of competition from foreigners to go and purchase the same type of securities. My concern is that you are talking about an environment where governments have failed all over the place. The banking system has failed all over the place. So I'm very much afraid, as much as government discharge their responsibilities by forcing pension funds to buy securities in Argentina and in many other places by crowding out the rest of the system. And the banking system could be the same type--or could exercise the same type of attitude by starting to lend irresponsibly, packaging this loan into securitization, and giving it up to the pension funds. Everybody knows everybody, so the system is not so transparent. So I very much agree with the issue of governance and transparency. Definitely, those firms that do not want to make themselves transparent couldn't be a good instrument of investment. But nobody has mentioned here as much as the competition from foreigners chasing high yields in Latin America, why not the pension funds investing somehow outside, abroad. That, I was saying, should be part of the whole package. Thank you. MS. ROJAS-SUAREZ: Is there any other question? One more. MR. : Roberto Garcia [ph] from the IMF. Probably, something was relating in another question is an obvious instrument can be thinking on developing the annuity markets, but this raises the issue of how do you regulate annuities. And probably I would like to hear specifically from Mr. Zahler on how is this dealt with in Chile. MILLER REPORTING CO., INC. 735 8th STREET, S.E. WASHINGTON, D.C. 20003-2802 (202) 546-6666 21 MS. ROJAS-SUAREZ: Okay, let me start. I think all of my colleagues have something to say about the different components, and so why don't we start with Roque Fernandez and we'll take the different issues. MR. FERNANDEZ: Well, I think that we have two problems. One is to evaluate how the system has behaved after the privatization that we had in the last few decades. So part of the work that we did in our review is just to consider what has been produced in the literature in the evaluation of the performance of the pension funds. And, of course, what we have is probably the sample data going from '81 to today from Chile and a small amount of data from another country that started the reform later on. But one of the works that we reviewed emphasized what was the social impact of the binding constraint in the portfolio allocations in the case of Chile. So what would happen if you just remove a little bit the limit that you have in the prudential regulation in each of the portfolio allocations that you may have, and what would have been the impact of removing those binding constraints a little bit? And so this research paper implies that the impact would have been to increase the yield in about 10 percent, and if you consider it in terms of U.S. dollars, that means that each pensioner could have improved the situation between $500 and $1,000. That is a paper produced by--I don't remember the author, but it's a Chilean author that did that sort of analysis. So that would be one part of the analysis. So when you regulate, you can produce two types of errors, either to be too strict or to be too lax in the regulation. And that would be a sort of type one error, type two error, and then the idea of evaluating regulations would be just to try to do the right thing, trying to minimize some of these errors when you are just trying to represent the principal that will be the worker that eventually will get an annuity, okay. So that's one part of the information that we have been analyzing. And, of course, more research on those projects--I think that is going to be very useful to check out how regulation is going on in the pension funds. The second issue is the question was fortunately ? to Robert Zahler, so I just will give one brief answer that I think that regulating the annuities market is really very difficult, especially when you consider that annuities could be the sort of traded good, so in which way we regulate the market for annuities and how we restrict the citizens of different countries to participate in that world market. I think that that is a big issue that has to be analyzed. We have not analyzed that topic in this report, but the question is really very MILLER REPORTING CO., INC. 735 8th STREET, S.E. WASHINGTON, D.C. 20003-2802 (202) 546-6666 22 well taken and I think that it is a very interesting point for future research. MS. ROJAS-SUAREZ: [INAUDIBLE.] MR. : Yes. There were many issues raised. Maybe there is one that I would say maybe there is a semantic issue that because we are economists, we tend to always put things into negatives. So we talk about problems and relaxing regulations. I think that in this case, I tend to think more of an opportunity that is presented by this gap. And the relaxation of regulation is not to be implied that we want pension funds to run into higher risks, but simply adopting something that was initially set very rigid on reforms that, you know, were not really conscious about these dynamic developments and really adapt the regulations to the reality of countries. And this is certainly a long process, so I think that it should be very clear that we don't want really to increase necessarily the risk profile, but simply to provide more flexibility. And the important issue is that many times when one talks about creating markets in Latin America, many times that is a question that the regulators put themselves and they start out of the blue with some legislation or some regulation and say, well, this is the way we are going to create markets. I think that the opportunity here is that we really have funding there. So there may be a moment in which a combination of actions actually can have a real impact, okay. So I think that is sort of a philosophical sort of context of what we are trying to transmit. MS. ROJAS-SUAREZ: Ricardo. MR. HAUSMANN: I would just like to mention the issue of-I again would like to repeat that the issue of risk is really not key to what we are talking about. It's not about more risk or less risk. It's about market development, because if the market was bigger and more diversified, it would be less risky. And financial engineering can always sort of like allocate the risk and only let that portion of the risk that is adequate for pension funds to be there. We have a very different legal tradition from that of the U.S. The U.S. regulation tends to be based on what they call the prudent man principle. So you leave a lot of--sort of like it's very jurisprudence. So there is a way of doing things. You know, if somebody tries, his response--he can be sued by his customers. He adopts his own sort of like prudential principles and there's a practice that evolves over time. There are market opportunities. Practice changes and sort of like adapts. We are more of a French approach. We put everything in a code, and we put things in a code before the world exists. And then we assume that the world has to fit in our codes, and then changing the code is a headache, right? MILLER REPORTING CO., INC. 735 8th STREET, S.E. WASHINGTON, D.C. 20003-2802 (202) 546-6666 23 So in some sense what we are saying is, look, we took American institutions translated into French and read it in Spanish, okay? And the sum of those three things is that the markets are not there. So let's see if it was in the French, in the translation. You know, we may be destroying more markets than reducing risk. That is the nature of the problem that we may have, and consequently we need a policy process that recognizes those inflexibilities. MS. DE KRIVOY: I would like to address some of the issues that were raised in terms of, number one, confirming that we are aware that there are infrastructure weaknesses for the financial sector, and these have to be addressed with or without the pension fund problems. If we don't address them, our financial sectors won't develop. So that's not under discussion. Second, our question-and-answer period concentrated a lot on the collateralized loan obligations and on small and medium enterprises. Those are important, but they're not the only ones. And that's why we focus on four asset classes that could bridge the gap between supply and demand for long-term funds, and that includes mortgage securities. Mortgage lending is prevalent in all of our countries. We'll continue to have a demand for that. Infrastructure finance bonds. We have a high and growing need for infrastructure and there may be a point in finding ways in which to fund it and also collateralized loan obligations which allow us to securitize a very diverse type of future flows of income or existing loan obligations. Banks may have an incentive to get rid of part of their portfolios. If not, we wouldn't have securitization there at all. And there is an experience throughout the world when you take a very high-risk loan like a credit card loan and you package credit card receivables and you can securitize them and you can market them. Will this be so attractive that foreigners will come and buy it? Maybe, hopefully. Okay, so what? If they do come, what we're doing is adding to the flow, and we do not intend to restrict this market and make our pension funds the preferred investors in these instruments. Furthermore, this is not a one-size-fits-all for all Latin American countries, and we should bear in mind that we range from countries like Chile, which started in '81 and has gone a long way in developing its pension funds and its capital markets and its banking system and its institutions and its infrastructure, and so on, to countries that haven't even started a pension fund reform, like my country. And in between, you find countries that have done some. Countries have multi-pension funds systems. Others have single-fund pension fund systems. Some allow for foreign investment of pension MILLER REPORTING CO., INC. 735 8th STREET, S.E. WASHINGTON, D.C. 20003-2802 (202) 546-6666 24 funds, others don't. So what we're saying is this is a gap, this is a problem; it is an opportunity and here are a set of solutions. And what we're trying to launch is a thought process where each country finds its way and where we can eventually trigger also a cross-fertilization among Latin American countries where we can learn from each other. And we don't have to necessarily follow the same path, but if we have problems, maybe we can learn and do something. And there's sort of a marginal comment in one of the ending paragraphs where we say maybe at the end of the road, there's room for a Latin American harmonization of pension funds regulations. Maybe if we have these financial sector development commissions in each country and there can be an exchange of views and multilateral institutions such as the IDB or the Andean Development Fund can serve as a forum for this exchange, maybe there is a role for harmonization of pension fund regulations along the way. And maybe we could even make an allowance for pensioners in one country to invest in pension funds of another country, provided they are well-supervised, well-regulated, strong enough for a marginal portion. I mean, we want to open up the discussion and not keep it constrained to pension funds that were designed to invest in high-priority assets, I would say, socially which are government bonds and bank deposits because we have to keep the banks into the picture. So maybe this broadens the scope of our statement and allows for each of these issues to be put into perspective. MS. ROJAS-SUAREZ: Roberto. MR. ZAHLER: Yes. Regarding the issue of annuities which Roberto Garcia asked me, in practice I would say that when you in Chile talk about pension funds, we are always thinking of pension funds plus insurance companies. It's a real--you cannot talk today of one without the other. So I think that's something you have to incorporate because it's basically those are institutional investors related to the pension fund system. I would put it in that way. And in a sense, of course, annuities is one of the possibilities that people use very commonly of using the pension funds, accumulated funds, through insurance companies. So they are very, very linked. I wanted to make a couple of other comments regarding some of the questions. Today, I would say an interesting development in Chile has been the multi-fund approach, which means that although funds are managed by the pension funds, there are different--the degree of riskiness in funds are different according to the age and risk profile of people. So in a sense, you have more possibilities of choosing where do you want your money to be invested, although the administration is with the pension fund system. MILLER REPORTING CO., INC. 735 8th STREET, S.E. WASHINGTON, D.C. 20003-2802 (202) 546-6666 25 Regarding foreign investment of the pension funds, that's also something that Chile has increased a lot. We have around 30 percent of the total amount of the pension funds--the resources of the pension funds managed are invested abroad. It's a quite significant amount, although, of course, there are restrictions in which type of instrument you can invest it abroad. And I think that has been an important development. However, I think that something that one has to keep in mind is that there, regarding currency risk, is something that you need the domestic market to provide for possibilities of hedging against currency risk. And that's something that Chile has also increased the--the derivatives market has been quite active, and today the hedging is done, I will not say a hundred percent, but almost a hundred percent by pension funds. And I think that's an important component of the possibility of opening pension funds abroad because basically the basket of pensioners is mostly non-traded sort of goods. And the other thing which we discussed in the statement and which I think is important regarding pension funds and capital markets which we have not mentioned here is that we have seen a lot of experiences where, because of the type of regulation we have, which is to the prudent man's approach, whenever markets perceive or anticipate changes in the percentage--changes in the limits of the different sort of facets which pension funds have to maintain, they tend to generate very significant changes in key macro prices such as interest rates, prices of stocks, even exchange rates, which is something which the Chilean experience tells you that there is a challenge there, also; in a sense, the macro implications of changes in the regulatory limits of pension funds. And this is basically because pension funds are becoming an increasingly very, very significant component of the capital market. Finally, I would like to mention an interesting thing regarding the question of Chile. Chile has, I would say, two characteristics in the last years which make it, I would say--I think people tend to say Chile has a very developed capital market. Probably, it's true that Chile has also a very developed capital market without having pension fund reform. But Chile has a situation where Ricardo mentioned we have a fiscal surplus already for two or three years. And the government is not issuing paper, so that there is--we have a positive problem, in a sense, but a problem for the pension funds. Mortgages, which until now represent around 13 to 15 percent of the total resources managed by pension funds, practically are nonexistent anymore. Today, the competition in the banking system and the demands of consumers is such that banks are not issuing mortgages anymore and they have not become competitive, and that was one of the MILLER REPORTING CO., INC. 735 8th STREET, S.E. WASHINGTON, D.C. 20003-2802 (202) 546-6666 26 main sources of paper that was until now issued and that satisfied pension fund investments. And so when you look at the numbers, you see, for example, that no more than--Chile still has today--to give an idea, 23 percent of the pension fund resources are invested in deposits in the banking system--23 percent, which is a very significant amount which doesn't appear to be something very reasonable. And only 7 percent of the total pension fund resources are invested in bonds. So, in fact, as we mentioned here, the type of institutions, of corporations that can issue bonds in Chile, and bonds that could be bought by pension funds, are very, very small. And so we still have a problem there which I would say is very relevant. And for a country like Chile, perhaps these sorts of elements are very crucial, these sorts of instruments that we have developing here. And let me insist on one point I mentioned, but I think it is important. Let me tell you one of the reasons why, for example, in my country you find it difficult to create these instruments today. I'm saying "today" because I hope that can change. On the one hand, still banks are very, very much worried about market share. They don't want to sell an important part of their loans because they compete on market share regarding credits. You may think that that's irrational, whatever you want, but that's the practice that works that way. Banks are--it's very complicated to convince them to do that. Secondly, a fact that still occurs. Securitization is quite expensive in Chile, very, very expensive. And so banks consider--some banks consider that getting financing from deposits or from issuing their own bonds is much cheaper than securitization. So it's not so simple, you know. These sort of instruments--you require many agents to be really interested and able and find it profitable to do this sort of investment. And, finally, in the Chilean case you find that most banks have excess capital today. So given that, you really don't need it. So these sort of instruments which, of course, we think are an important component of what we think would be a further development of the capital market and the pension funds in our region, require that most all of the agents that are players in this sort of game should be interested and should be motivated and should be incentivized. Thank you. MS. ROJAS-SUAREZ: Okay. Just let me close with a final thought that summarizes what my colleagues have been saying. As a committee, something that distinguishes us from so many other committees and points of view is that the experience of the members here have made them arrive to one conclusion and it is that the production and MILLER REPORTING CO., INC. 735 8th STREET, S.E. WASHINGTON, D.C. 20003-2802 (202) 546-6666 27 financial structure in Latin America today differs significantly from that of industrial countries. And in that context, just importing regulation might not only not be effective, but even have undesirable consequences. Once we start from that recognition, our role is to say, all right, given the constraints that we face today, what kind of regulatory practices and modifications are the most suitable to actually get the same goals that we're all trying to get. That is what characterizes us and what motivates the kind of statements that we produce. With this remark, I want to thank all of you for coming here, and hopefully you will keep interchanging your views with us, as we will not disappear from the map. Thank you. [Applause.] [END OF TAPED RECORDING.] - - - MILLER REPORTING CO., INC. 735 8th STREET, S.E. WASHINGTON, D.C. 20003-2802 (202) 546-6666