–– RMB Focus MARCH 2016 I. • PBoC Circular No.2 for management of Over-The- • China Interbank Bond Market (CIBM) further opens up to offshore investors • CFETS Notice No.7 for overseas RMB Participating Banks to enter China interbank FX market usiness in CIBM • II. • PBoC announced a Reserve Requirement Ratio (RRR) cut of 0.5% • Interview on Mr.Zhou Xiaochuan regarding RMB exchange rate • PBoC emphasises on a better management of money supply • China granted RMB 50 billion quota to six banks for bad loan securitisation • SAFE caps buying of insurance products overseas at USD 5,000 • China suspended QDLP scheme to control capital outflow • • China and Georgia to push forward the comprehensive FTA in 2016 RMB Competence Centre - Page | 1 –– I. Following PBo past five months, RMB exchange rate spurred biggest rally since 2005 by 1.2% on February 15th. Clear signal has been conveyed that Chinese authorities are prioritising currency stability over RMB internationalisation in the current stage of economic transition. Onshore financial reform keeps progressing with the relaxation on management of OTC business in CIBM (PBoC Circular No. 2) . Meanwhile, burdened with heavy pressure on RMB depreciation and capital outflow, authorities have implemented a series of policies to encourage capital inflow such as the simplified rules for investment in CIBM (PBoC Notice No.3), the introduction of base quota calculation mechanism for QFII scheme (SAFE Circular No. 2) and the supplementary rules on application procedures for Overseas RMB Participating Banks to directly access CFETS for FX trading (CFETS Notice No. 7). - - PBoC issued Circular No.2 Management of OTC Business of China Interbank Bond Market ( CIBM ) on February 14th, effective immediately. – Enlarge CIBM investment scope for qualified individuals and corporates QICs are allowed to invest in OTC Products for bond spot trading, pledged repo and buyout repo, while previously only certificate treasury bonds were available. Repo provides a direct way for QICs to add leverage and finance from China Foreign Exchange Trading System ) – QFIs and related products issued by QFIs can invest in all types of Eligible OTC Products which were restricted to individuals and corporates. Under this new regulation, QFIs can access CIBM not only via direct connection of CFETS but also the Eligible OTC Products trading platform. Despite the difference in listing requirement (approval for CIBM vs registration for exchange bond market), the extension of investor eligibility can make CIBM more competitive and pave the way for the potential bond cross-market trading. – Add new quotation mechanism Request quotation initiated by Eligible Investors is allowed under this new regulation. – This Circular carries a major potential impact for BNP Paribas (China) Ltd. which can provide Eligible Investors with full agency services of OTC Products thanks to its Type A license. RMB Competence Centre - Page | 2 –– – Opening the QICs access to inferior rating bonds could mean that PBoC and NAFMII might adopt a much flexible underwriting system going forward. The ease of acquiring and placing liquidity by QICs, which never happened before, is a continuous evolution of the interest rate liberalisation effort in China. I. D Financial Institutions act as secondary agents to open bond accounts, distribute bonds, conduct custody and settlement, and pay interest and principle for Eligible Investors via sales network and electronic channel. II. FIOTC Qualifications – – Active market makers or banks with Type A license in CIBM Financial institutions with direct access to both o CFETS; o CIBM Bond Custody and Settlement Institutions e.g. China Central Depository and Clearing Corporation or Shanghai Clearing House. III. Application Documents Qualified financial institutions should submit below information to PBoC for record within 1 month after the start of OTC Business: – – – – 1 Plan for OTC Business and operation settlement; Department structure and staff organisation for OTC Business; OTC Business management system, risk prevention mechanism, investor appropriate management system1 and accounting method; System connection approvals issued by CFETS and CIBM Bond Custody and Settlement Institutions. System created by PBoC to ensure that FIOTC sell products to Eligible Investors based on their risk tolerance IV. Eligible OTC Products – – Bond spot trading, pledged repo, buyout repo and other products approved by PBoC. Bond type: Government Bond, Local Government Bond, Policy Bank Financial Bond, China Development Bank Bond and newly-issued bond targeted at Eligible Investors. V. Eligible Investors Eligible Investors include Qualified and Unqualified Investors. Qualified Investors who meet at least one of the following requirements can purchase all types of Eligible OTC Products: – Financial institutions approved by the State Council; RMB Competence Centre - Page | 3 –– – – – – Investment companies or asset management companies with net asset or AUM not lower than RMB 10 million; Wealth management products, security investment funds and other investment projects launched by above financial institutions, investment companies and asset management companies; Corporates with net asset not lower than RMB 10 million; Individual investors with more than two-year security investment experience, annual income not lower than RMB 0.5 million and financial asset not lower than RMB 3 million. Unqualified Investors can only trade bonds rated AAA or above, and conduct repo business. VI. Rules for OTC Business – – – – FIOTC can provide trading quotation service via bilateral quotation or request quotation o Bilateral quotation: FIOTC constantly and publicly quote for Eligible Investors. o Request quotation: Eligible Investors initiate request to FIOTC for quotation of certain bonds. anism for cash clearing and bond settlement. Eligible Investors can open bond accounts in different FIOTC and apply for transfer of bond custody among these bond accounts. Without approval from PBoC, institutional investors who have opened account in bond custody and settlement institutions cannot open bond accounts in FIOTC. FIOTC can open general account in CIBM Bond Custody and Settlement Institutions to settle OTC Products of Eligible Investors and strictly separate them from proprietary bonds. PBoC released Circular No.3 regarding qualified offshore institutional investors participating in CIBM on February 24th, effective immediately. − Broaden qualified offshore institutional investors definition and remove their Direct Interbank Access quota, which means they can directly participate in CIBM without license. − Simplify investment procedure. Qualified offshore institutional investors can participate in CIBM after registering with PBoC and opening relevant accounts via banks with Type A license whereas previously PBoC approval was required. − Encourage qualified offshore institutional investors to conduct medium and long term investment in CIBM. − As one of the four foreign banks with Type A license, BNP Paribas (China) Ltd. can provide full agency services to qualified offshore institutional Investors for investments in CIBM. RMB Competence Centre - Page | 4 –– − Qualified offshore institutional Investors: 1. Financial institutions e.g. banks, insurance companies, security companies, fund management companies, other asset management companies and investment products of these financial institutions. 2. Medium and long term investors e.g. pension funds, charity funds, donation funds. − Qualified offshore institutional Investors should entrust a bank with Type A license for bond custody and clearing. Bank with Type A license can provide following services: 1. File with PBoC to invest in CIBM. 2. Assist to open, modify and cancel RMB special account, bond account, capital settlement account and bond trading account. 3. Conduct bond trading and settlement as per order of qualified offshore institutional investors. 4. Arrange interest and principle payments. 5. Asset custody, report processing, accounting and valuation. − Qualified offshore institutional Investors are permitted to trade cash bonds and other products allowed by PBoC. − This circular applies to Qualified Foreign Institutional Investors and RMB Qualified Foreign Institutional Investors. − Foreign official institutions should still follow previous rules as per PBoC Circular No. 220, 2015. ement of Qualified Foreign Institutional th February 4 , effective immediately. − Remove quota limit. Investors can establish a base quota calculated according to their asset or AUM. − Simplify quota application. No SAFE approval but only registration is required if investment is within the base quota. SAFE approval is required for investment amount exceeding base quota. RMB Competence Centre - Page | 5 –– − Ease initial investment injection and repatriation process. Deadline for initial investment injection is removed. Open-end fund can be purchased and redeemed daily. − Shorten lock-up period of initial investment from 1 year to 3 months. Repatriation remains under instalment rule with monthly net outflow not exceeding 20% of total onshore asset. − QFII quota of BNP Paribas may be increased under the new base quota calculation mechanism. − The revised regulation shortens lock-up period and allows open-end funds to be subscribed and redeemed daily, which enables QFII to have a better access to liquidity. − It is a further opening-up of onshore capital market with the aim to boost inbound investment and attract more foreign institutional investors. Currently, the total size of QFII quota has reached USD 150 billion but only about USD 80 billion has been allocated by SAFE, so there is still huge potential in QFII market. − The new base quota calculation mechanism addresses concerns raised by MSCI in 2015 regarding A-share inclusion (quota limit, liquidity restriction and direct beneficial right) and will increase the probability of A-shares inclusion into MSCI. Should A-shares account for 5% in MSCI index, it would potentially represent roughly RMB 90 billion capital inflow to China. I. Investment Quota Management Accumulative amount of net capital inflow for each QFII cannot exceed the investment quota registered or approved by SAFE. Base quota − − − Maximum: no more than USD 5 billion Minimum: no less than USD 20 million For QFII with major asset or AUM registered offshore Base quota = USD 100 million + average asset or AUM in recent three years * 0.2% - RQFII quota granted − For QFII with major asset or AUM registered onshore Base quota = RMB 5 billion + total asset or AUM by the end of previous year * 80% - RQFII quota granted − Base quota for financial official institutions such as sovereign wealth funds, central banks and monetary authorities are only subject to USD 5 billion quota limit. − Base quota is denominated in USD, all the FX conversion should use the rate released by SAFE at the end of previous month. RMB Competence Centre - Page | 6 –– For QFII with existing quota, no SAFE approval but only registration is required if total quota (existing quota + newly applied quota) remains within base quota. SAFE approval is required if the existing quota or total quota exceeds base quota. Lock-up period, which starts when net inflow of initial investment reaches USD 20 million or equivalent, is shortened to 3 months. II. Application Documents For investment within base quota, QFII should submit the following documents to custodian for record: − − − − − Basic information of investment for record; Registration Form for Qualified Foreign Institutional Investors; Audited financial statements or AUM reports for the recent three years or previous year; Copy of the Certificate of QFII issued by CSRC; Filing Form for Investment Quota of Qualified Foreign Institutional Investors (Custodian should submit the Filing Form to SAFE within the first 10 days of the month). For investment exceeding base quota, QFII should submit the following documents to SAFE via custodian for approval: − Written application of QFII and its custodian with detailed explanations for increasing quota and utilisation of current investment quota; − Audited financial statements or AUM reports for the recent three years. III. Account Management − and openend funds. Afterwards, RMB special deposit accounts should be opened accordingly with custodian or banks. − Capital in both accounts cannot be used for other purposes except onshore securities investments. IV. FX Management − FX funds can be converted into RMB and transferred to the special deposit account 30 days before actual investment starts. − After the lock-up period, QFII can repatriate initial investments and profits by instalment. The cumulative monthly net outflow (including initial investments and profits) shall not exceed 20% of total onshore asset by the end of previous year. − Open-end fund can transfer in or out the net amount of the subscription or redemption on a daily basis by its custodian bank. The monthly cumulative net outflow shall not exceed 20% of fund total onshore asset by the end of previous year. RMB Competence Centre - Page | 7 –– − Repatriation of profit from other products is subject to provision of audit report and tax certificates. V. Comparison Previously − Size of quota − − Lock-up period − − − Frequency of cross-border flows (openended funds) − − Frequency of cross-border flows (other products) − − FX management − New scheme More than USD 1 billion for sovereign funds, central banks or monetary authorities From USD 50 million to USD 1 billion for others − 3-month for pension funds, insurance funds, mutual funds, charity funds, endowment funds, government and monetary authorities, and open-ended China funds 12-month for other QFII products − 3-month for QFII products Weekly on net basis Monthly net outflows cannot total onshore asset by the end of previous year For each outward remittance, its initial investment vs profit must be determined so that only initial investment amount can be reinvested − − Daily on net basis Monthly net outflows cannot exceed total onshore asset by the end of previous year Monthly net outflows cannot exceed 20% of total onshore asset by the end of previous year Repatriation of profit is subject to provision of audit report and tax certificates Repatriation of principal is subject to SAFE approval, and quota is reduced accordingly − Monthly net outflows cannot exceed 20% of total onshore asset by the end of previous year Repatriation of profit is subject to provision of audit report and tax certificates FX funds can be converted into RMB and transferred to the special deposit account 10 days before actual investment starts − − − Quota limit is removed. Investors can establish a base quota calculated according to their asset or AUM No SAFE approval but registration is required if investment is within the base quota. SAFE approval is required for investment amount exceeding base quota. FX funds can be converted into RMB and transferred to the special deposit account 30 days before actual investment starts RMB Competence Centre - Page | 8 –– According to China Foreign Exchange Trading System (CFETS) announcement on January 29th 2016, overseas RMB participating banks, with large volume of RMB purchases and sales, regional presence and international reputation can apply to become members of CFETS to trade FX spots, forwards, swaps and options directly via CFETS. All the transactions should be conducted for real business need and Participating Banks should monitor capital outflow and be able to present trade documents to PBoC for inspection. Since September 2015, PBoC and SAFE have released a number of regulations allowing offshore banks to enter China Interbank FX Market: – – – – Effective September 30th and monetary authorities, international financial institutions, sovereign wealth funds, are allowed to trade in CFETS (PBoC Circular No.31). Effective November 25th 2015, first batch of 7 FOIs are allowed to access China Interbank FX Market. Effective December 21st 2015, SAFE relaxed rules allowing Participating Banks, after being a member of CFETS, to enter China's onshore interbank FX Market, with implementation details to follow (SAFE Circular No.40). Effective January 12th 2016, second batch of 7 FOIs are permitted to enter China Interbank FX Market. This announcement supplements SAFE Circular No.40 (December 2015) with detailed rules on application procedure and technical operation for Participating Banks to have direct access to CFETS. It is an opening up of China onshore FX market with the aim to add more types of market participants and extend cross-border FX trading channels. On December 13th 2015, PBoC suspended sev CNY/CNH arbitrage. One of the reasons for suspension is the difficulty in validating the trade background of those transactions. Compared with RMB purchases and sales via onshore clearing banks, direct access to CFETS can provide a more transparent and regulated trading mechanism for PBoC and SAFE to inspect cross-border transactions. PBoC is trying to strike a balance between internationalising RMB and curbing capital outflow to stabilise RMB. PBoC still encourages outbound direct investment and cross-border trade-related transactions to support and benefit real economy. RMB Competence Centre - Page | 9 –– BNP Paribas (China) Ltd. may lose opportunity as agent bank due to competition from direct Participating Banks of CFETS, while BNP Paribas overseas entities with RMB cross-border transactions can apply to trade directly via CFETS. I. Qualification Participating Banks can apply to CFETS for China Interbank FX Market membership and conduct FX transactions including spot, forward, swap, CCS and option through CFETS trading system. II. Application Documents 1. An application report. Its content includes, but is not limited to: Basic information of the institution; purchases and sales business, including business scale and scope, product type, client information, etc. Promise to strictly abide by related rules of RMB purchases and sales business, including: o Business scope; o Product type; o Corporate clients conducting RMB purchases and sales business with Participating Banks shall complete related payments in the same bank; o Pay close attention to abnormal transactions; o Monitor the capital flow of block trades and report related information to PBC through CFETS system in a timely manner. Guarantee the authenticity of RMB purchases and sales business and report related information through CFETS system in accordance with related requirements. 2. Chinese version. 3. Internal operation procedure for trading in China Interbank FX Market. 4. The policies of risk management and RMB purchases and sales business information reporting related to trading in China Interbank FX Market. 5. CFETS RMB/FX Membership Application Form. 6. CFETS Network Connection Application Form. 7. CFETS FX Trading System Digital Certificate Application Form. 8. Copies of the Certificate of FX Trader issued by CFETS (each institution shall have at least two certified FX traders). 9. Name, resume and contact information of related managing staff and principal trading staff. 10. Other documents required by CFETS. RMB Competence Centre - Page | 10 –– All aforementioned application documents and completed forms shall be stamped with official seal or signed by authorised signatory (attached with signature authorisation). III. Application Procedure 1. Qualified Participating Banks submit application documents to CFETS. 2. CFETS sends the Member Agreement to institutions that have submitted complete application documents and met the statutory requirements. 3. The institutions complete preparation work, including signing Member Agreement, finishing network connection and attending trader training program. 4. CFETS sends formal market entry notice to the institutions approving the membership of China Interbank FX Market and publishes public announcement through www.chinamoney.com.cn. IV. Information Reporting Participating Banks acquiring the membership of China Interbank FX Market and conducting RMBFX transactions through CFETS trading system shall report related details of RMB purchases and sales through the information reporting panel in CFETS Post-trade Processing Platform at the end of each trading day (no later than 8:00 AM of the next trading day). Reported details include the name of the parties that purchase or sell RMB, their nationality and region, transaction amount and purpose, etc. The counterparties of Participating Banks are not obligated to report relevant information through the RMB Cross Border Payment & Receipt Management Information System (RCPMIS). V. Others 1. Participating Banks can connect to CFETS trading system directly via leased line or MPLS/ VPN. 2. Participating Banks can choose to use CFETS Post-trade Processing Platform to complete back-office trade confirmation with their counterparties. 3. Current China Interbank FX Market regulations and practices on network connection requirements, technical standards and fee schedule shall be applied to Participating Banks. 4. Participating Banks acquiring the membership and trading in China Interbank FX Market shall no longer trade via domestic agent banks. Source: CFETS RMB Competence Centre - Page | 11 –– II. On February 29th, PBoC announced a Reserve Requirement Ratio (RRR) cut of 0.5% for all the financial institutions, effective from March 1st. According to market estimation, the RRR cut will release around RMB 700 billion liquidity. After the adjustment, the RRR for BNPP China will be 15%. Source: PBoC, BNP Paribas On February 15th, Chinese magazine Caixin Weekly published an exclusive interview with PBoC governor Zhou Xiaochuan. Takeaways of the interview: 1. In times when forex speculation becomes the main conflict, RMB internationalisation will concede to RMB exchange rate stability in terms of importance. 2. A managed floating exchange rate regime is still necessary. PBoC will not let speculative forces dominate market sentiment, but this does not mean they must take direct action every time they face speculators. PBoC will effectively use their "ammo" to minimise cost. 3. The theme for RMB exchange rate regime is strengthening the reference against a basket of currencies, not pegging to the basket of currencies. PBoC will improve communication with the market. There will be better stability in RMB basket exchange rate and more twoway fluctuation of RMB against the USD. 4. There is no basis for continued RMB depreciation: China's current balance of payments is in good condition; global competitiveness is still strong; cross-border capital flow is within the normal range; RMB exchange rate against a basket of currencies remains basically stable. 5. PBoC will continue to reinforce control on illegal capital flows. But there is no control on normal operating forex strategy changes, liability structure adjustments, remittance of profits cross border, forex purchases for the purpose overseas M&A and setting up subsidiaries offshore. Source: Caixin Weekly, BNP Paribas PBoC started to conduct open market operation on a daily basis according to the announcement issued on February 19th; previously, the frequency of such operation is twice a week. Normally, PBoC manages liquidity in the market through repurchase agreement or reverse-repurchase agreement; the new movement will lead the central bank to a better management of short term liquidity in the banking system. Source: Ejinsight RMB Competence Centre - Page | 12 –– -high of RMB 1.27 trillion in 2015, China has granted RMB 50 billion quota for six large banks to issue asset-backed securities (ABS) with non-performing loans as underlying assets. This will provide a fresh channel for domestic commercial banks to liquidate trouble loans and better manage non-performing loan ratio. The six banks are Industrial and Commercial Bank of China (ICBC), China Construction Bank, Agricultural Bank of China (AgBank), Bank of China (BOC), Bank of Communications (BoCom) and China Merchants Bank. Source: Reuters To prevent capital outflow, China's SAFE capped the use of UnionPay bank cards to purchase insurance products offshore at USD 5,000 per transaction, effective from February 4th. Since RMB started to depreciate last year, offshore insurance policies become more and more popular. The amount of insurance policies purchased by mainland visitors achieved HKD 21.1 billion in 2015, a y/y increase of 64%. Source: Bloomberg In order to curb capital outflow and stabilize RMB exchange rate, China has suspended the quota issuance for QDLP scheme and delayed the launch of QDII2 scheme, according to Financial Times. China is experiencing a tough time due to sluggish economic growth and heavy pressure on RMB depreciation. In January, China's foreign exchange reserves declined by USD 99.5 billion from a month earlier to USD 3.23 trillion, hitting the lowest level since 2013. Qualified Domestic Limited Partners (QDLP) Programme was originally launched in 2013 with the aim to provide a new channel for foreign asset managers to raise fund onshore and invest into overseas securities markets. All together 11 foreign funded asset managers have been granted licenses and quota. But since August last year, SAFE hasn't approved any new quota for QDLP scheme, which clearly shows its intention to clamp down on outbound investment channels. Source: Financial Times, BNP Paribas On February 23rd, Christine Lagarde who is the managing director of the IMF showed her supports believed that would not face a hard landing situation and such transformation . Source: Xinhua RMB Competence Centre - Page | 13 –– On February 22nd, the first round of negotiations between China and Georgia regarding a free trade agreement was officially launched. Two countries are expected to achieve a comprehensive deal within 2016. China is now the 4th largest trading partner for Georgia; the FTA will further benefit economy of both countries. In December 2015, Chinese Mistry of Commerce and Georgian economic department signed a memorandum of understanding to start the FTA negotiations. Source: Xinhua RMB Competence Centre - Page | 14 –– This document is CONFIDENTIAL AND FOR DISCUSSION PURPOSES ONLY and does not constitute an offer or a solicitation to engage in any trading strategy, to purchase or sell any financial instruments or to enter into any transactions. 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Registered Office: 16 Boulevard des Italiens, 75009 Paris, France. www.bnpparibas.com © BNP Paribas. All rights reserved. RMB Competence Centre - Page | 15