Nairametrics| The Central Bank of Nigeria now allocates foreign exchange (FX) to banks based on the size of their unimpaired shareholders’ funds – the value of shareholder investment in a bank.

In a circular released by the CBN, which was not yet made public, the CBN announced a Special Wholesale Forwards Intervention not exceeding 60 days, with the following conditions (excerpts)

-US$100.00 million would be on offer
-Deposit Money Banks (DMBs) with unimpaired shareholders’ funds of N350 billion and above are limited to a maximum bid of 12.5% of the amount on offer
-DMBs with unimpaired shareholders’ funds between N200 billion and N350 billion are limited to a maximum bid of 10% of the amount on offer
-DMBs with unimpaired shareholders’ funds between N75 billion and N200 billion are limited to a maximum bid of 3.5% of the amount on offer, while DMBs with unimpaired shareholders’ funds below N75 billion are limited to a maximum bid of 1% of the amount on offer.
-Merchant banks are limited to a maximum bid of 1% of the amount on offer

The apex bank has somewhat conveniently decided not to apply Clause 2.43 of its Revised Guidelines For the Nigerian Inter-bank Forex Market, which it released in June 2016. In the rule, The CBN may, at its discretion, intervene in the FX market through the sale of FX to Authorised Dealers (wholesale) or to end-users through Authorised Dealers (retail) via a multiple-price book building process using the FMDQ-Thomson Reuters FX Auction Systems, or any other system approved by the CBN.

Crony CBN?

This move by the CBN segregate banks into 4 categories (starting from the largest) based on the size of their shareholders’ funds. It inadvertently favors the biggest banks – Zenith bank, First Bank, GTB, Access bank and UBA, as they will receive more FX allocations, while it adversely affects the smaller banks, including foreign-owned banks because they will receive less allocations.

Zenith bank, the former employer of Godwin Emefiele, has N730.4bn in shareholders’ funds; FBN holdings had 9 months unaudited shareholder funds of N622 billion; GTB, according to its 2016 audited financial statements had N496bn in shareholders’ fund; Access Bank had N449 billion and UBA N436 billion as at December 2016.

Going by this metric, as much as 50% of the total FX allocations in the system could potentially go to the top 4 banks. This could be significant for commercial bank profits considering how much Tier 1 banks have made from forex revaluation and fees in 2016 alone.

Poignant to note that the circular also emphasizes the word UNIMPAIRED. Assuming an impairment of 30% of shareholders’ funds, for mathematical rigour, Zenith, GT bank and First Bank would have been the only ones qualified for the maximum amount.

A tier 2 bank such as FCMB for example with shareholders’ funds of N170 billion as at December 2016 would qualify for just 3.5% of the offer. Same with Stanbic IBTC which had shareholder funds of N137 billion as at December 2016. Yet these banks may have several customers who need foreign exchange.

Critics of this latest move by the CBN insinuates a clear case of favoritism for Tier 1 banks, particularly Zenith Bank, the former employer of Godwin Emefiele. Recall, Nairametrics exclusively reported that Zenith bank, was considering raising additional capital of N100bn, but shelved the capital-raise plan when the MD was unable to explain to analysts and investors in its earnings call, why this extra capital was needed. Does this mean that the bank has suffered significant impairments, and was trying to shore up its capital in anticipation of this new CBN FX Intervention? Was Zenith bank forewarned of this intervention by Emefiele who was its former MD?

Wider Implications

This new FX intervention isn’t as clear as day, and it throws up some issues and implications: Will this be the norm going forward? Does it mean that the CBN will no longer disburse FX based on the needs of bank customers, as it had been doing prior to this latest intervention? Does it now emphasize banks over and above the actual number of customers that a bank has?

Finally, and more importantly’ is this intervention is meant to reduce the number of players in the FX game by channeling FX users to the few dominant banks, thereby achieving tighter control of the FX market?

This could have potential consequences. For example, it may lead to a scramble for more capital by the smaller banks, so that they can keep up their FX allotments and maintain their customers by extension. As smaller banks become unable to meet FX demands from their customers due to their reduced allotments, they will begin to lose customers to the larger banks, leading to a loss in business and revenue for them.

Nairametrics