In the graph below we show that the Brazilian swap market (DI curve) is roughly in line with analysts’ expectations. The swap curve estimates are slightly higher in the beginning because they are being anchored by the current DI rate/SELIC rate at 11.87% and 11.90%, respectively. The swap market currently expects the COPOM to gradually reduce SELIC to about 10.00 in April 2012. Economists on average are looking for 10.25% in June 2012.

The next graph shows that the markets were far more pessimistic in the first week of October. The October 3rd DI curve implied that the COPOM would lower rates to 9.67% in June 2012. Since then, the market has backed off this pessimistic view and now sees a low of 10.12% in April 2012. It then sees rates raising again at the end of 2012 as the Brazilian economy responds to the stimulus and the European crisis is resolved.

Economists take a slightly different view. The graph below shows the evolution of the economist survey for SELIC forecasts put together by the BCB. Each point on the x axis represents the date that the forecast was made for SELIC in June 2012. Economists, on average, have been steadily lowering their SELIC forecasts since the end of August 2011.

The Brazilian journal Valor published an excellent survey on Friday, October 14th, that shows that economists’ estimates for SELIC vary wildly. The table below was published in an article written by Angela Bittencourt and Lucinda Pinto which was titled Markets See a Gradualist Copom and Already Project a One Digit SELIC.

Analyzing the table further, most banks see a 50 basis point cut from this meeting and rates eventually drifting to 10.5% or 10.0%. Nomura is forecasting a 100 basis point cut from this October meeting and higher rates in 2012. Banco Itaú Unibanco is expecting a 75 basis point cut from this meeting and rates falling to 9% in 2012.

The article goes on to point out that an one digit SELIC forecast was unthinkable before the COPOM’s August 31st meeting. These forecasts demonstrate a dramatic change in the economic outlook in Brazil over the last month and a half. In reality, the economic scenario is deteriorating rapidly in Brazil. Part of the deterioration is due to the international economic scene. However, Brazil has its own demons to deal with.

This past Sunday, October 16th, Fernando Nakagawa wrote an article in the journal O Estado de São Paulo (see link below, we will discuss further in another blog) that observed that the private banks in Brazil set aside more than R$1 billion in provisions for bad loans during August alone. Clearly the private banks continue to see their credit portfolios deteriorate as a result of the bubble in consumer lending in Brazil and the contagion effects from high levels of problem loans in the non-bank finance sectors.

http://www.estadao.com.br/noticias/impresso,bancos-publicos-ignoram-efeitos-da–crise-e-reduzem-reservas-contra-calote-,785997,0.htm

LatAm Structured Finance is pessimistic about the short-term economic outlook in Brazil. We are alarmed at the continuing deterioration in consumer credit portfolios and a domino-effect scenario for the business and real estate credit markets. The BCB has openly stated that it believes that consumer spending will carry the Brazilian economy through the current global economic difficulties.

LatAm Structured Finance believes that the BCB’s expectations for consumer spending are naïve and that the economy will continue to slow more than expected as a result. We currently project almost a no growth scenario for GDP in Brazil in the final quarter of 2011 and into 2012. Finally we continue to see higher losses on credit portfolios through the end of the year with some improvement coming in spring 2012.

• Central Bank of Brazil surprises markets and lowers SELIC 50 basis points.
• Banks increase reserves and provisions for bad debt to record levels.
• FGC Helps to Sanitize the Financial System

What are the implications for investors?  New-issue investors need to evaluate carefully the issuing entity’s portfolio for the quality of debt underwriting and the entity’s ability to service the loans.  Investors that currently hold FIDCs need to monitor the credit portfolio’s performance carefully.

We see weakness in consumer loans issued by banks and finance companies and we have no doubt that this is the single thread that unites some of the otherwise contradictory economic news in the Brazilian press. 
Both the Central Bank of Brazil (BCB) and the Fundo Garantidor de Crédito (Credit Guarantee Fund, FGC) have been working behind the scenes to contain the growing problems from NPLs and to prevent a full blown credit crisis in Brazil.

FIDCs do not have this government protection.  FIDC credit quality has deteriorated since the beginning of the year according to data we pulled from Orbis, a structured finance database and news service from Uqbar.  Of the 250 FIDCs in the Orbis system with data for the last seven months, 77% have seen increases in provisions for bad debt (PDD – Provisões Devedores Duvidosos).   PDD increased more than 100% since the beginning of the year in 29 FIDCs.  Fifteen of those deals were either multiple market or multiple segment deals.  Due to lack of transparency in the Brazilian ABS market, it is better to look directly at the credit markets themselves to understand these trends.

Putting Together Pieces to Understand Brazil’s Credit Markets

The August 30 meeting of the COPOM, the monetary committee for Brazil’s central bank (BCB), dramatically altered the general perception of the economic picture in Brazil when they cut SELIC by 50 basis points.  Most analysts were caught by surprise; however, our calculations show that the market had been forecasting approximately an 80% chance of a 25 basis point interest rate cut on August 29.   The COPOM has since been criticized from many corners for lowering the rate even though Brazilian inflation has not yet retreated.

The market now expects the COPOM to cut SELIC to about 10.25% by June 2012, while analysts polled by the BCB survey are divided between 10.50% and 10.75% as the low, as you can see in the first graph below.  Both the market and economists now view the BCB as very accommodative.  The BCB conveniently cites the growing problems in Europe as the motive for cutting rates.  We don’t believe that’s their main motivation.  In our view, the BCB and the Brazilian Government are more worried about the growing problems with consumer credit at home and about protecting the banking system.   This explains why the BCB cut rates at the risk of losing control of inflation and some credibility with the international financial community.

We have been warning that the Brazilian financial system is showing signs of strain due to the extraordinarily high growth in consumer credit balances and the high level of consumer NPLs since May 2011.  Government’s efforts to rein in the growth this market have failed.  We also pointed to the evidence that payments on consumer loans are not sufficiently large enough to amortize the principal. As a result loan balances continue to grow in spite of declining issuance (See our Second Quarter Review).

The Brazilian press continues to point to the overall low levels of non-performing loans and occasional reductions in the levels of non-performing loans.  We put these reports in the basket labeled “misleading statistics.” As with FIDCs, the overall numbers in the financial system are obscuring some important developments in the sub-sectors.  Most importantly, there is a growing number of NPLs on the consumer portfolios of both banks and non-bank finance companies.

Smaller Brazilian banks have encountered difficulties in managing their balance sheets since the 2008 global credit crisis.  These banks find it difficult to sell parts of their credit portfolios to the larger banks because the large banks have tightened up their credit underwriting standards, especially after the Banco PanAmericano scandal.  The graph below indicates two dangerous trends.  First, NPLs continue to run much higher than 2008/2009.  Second, the lagged but sudden increase in NPLs in bank portfolios indicates that the problems in consumer credit portfolios for non-bank finance operations seem to be affecting or “contaminating” the bank consumer credit portfolios.

Estado de São Paulo announced in a September 15 edition that the Fundo Garantidor de Créditos (FGC) had realized “sanitation operations” of around R$7.5 billion this year to clean up problems with some medium and small sized banks.    The most recent operation transferred Banco Matone to Grupo JBS, thanks to support of R$850 million from the FGC.  The other big “sanitizing operation” for 2011 was a R$1.5 billion package help BMG absorb Banco Shahin.  That leaves roughly R$5 billion more in other operations that have been used to shore up other banks.  FGC currently has resources of a little more than R$26.8 billion.  This means that the fund has spent about 25% to 33% of its resources to prop up the financial system this year.

It is clear that the BCB and the Brazilian government are trying to avoid a panic.  An editorial in Estado de São Paulo points out that the FGV’s operations have two advantages promoted by Brazil’s Central Bank:  they don’t involve public money and they are discreet.  The operation’s discretion prevents depositors from panicking about the financial health of other banks.    The editorial points out that this helps reduce systemic risk in the Brazilian financial system.

At the end of August we produced a report that analyzed the recent actions taken by Brazilian banks to shore up reserves and increase provisions for non-performing loans.  (See “At What Height Does A Bank Seawall Protect From a Credit Tsunami?”)  The biggest Brazilian private and government banks have been increasing loan loss provisions and reserves to almost unheard of levels.  Caixa Econômica Federal is provisioning 300% of NPLs.   Given that banks recover on average 30% to 40% of bad debt, with the range spanning from 5% to 60% of the value of loan, a provision of 300% of NPLs seems like overkill unless the bank knows something that the public doesn’t.  Brazilian banks execute “renegotiation operations” that banks in other countries would normally consider bridge loans for defaults.  The BCB would know if banks are entering into these types of agreements frequently.

Summarizing the condition of the FIDC Market

This brings us to the FIDC market in Brazil.  The statistics are deceptively reassuring.  As the graph below demonstrates, the overall PDD level has been fairly stable.  It appears that the problems in the consumer credit market have not yet affected FIDCs in general.  As with the banking system, we believe the overall statistics are hiding the problems.  Statisticians often quote the paradox of a person drowning in a river that is on average 5 inches deep.   We believe that the distributions are skewed and that the averages are hiding problems.

We used data from Orbis to calculate the percent change PDD from January to July 2011 and plotted the data in the histogram in the fourth graph below.  We took out all of the deals with extraordinary changes over 500% to error on the side of caution in our calculations.  PDD increased by more than 25% in more than 47.6% of the FIDCs over this period, even with our conservative approach.

Part of this artificial stability stems from the issuer’s ability (and common practice) to buy back loans that are more than 90 days past due.  However, the CVM has passed new rules (Instruction 489) that will severely limit the balance sheet options for issuers who repurchase substantial amounts bad loans from FIDC credit portfolios.  In addition, the banks will not have the balance sheets to continue this practice if the credit markets continue to deteriorate.   We believe this picture will worsen as the economy slows down more.

As stated in the opening, new issue investors need to evaluate carefully the issuing entity’s portfolio for the quality of debt underwriting and the entity’s ability to service the loans.  Investors that currently hold FIDCs need to monitor the credit portfolio’s performance carefully for the near future.

As bank portfolios deteriorate in quality and larger banks rein in issues, smaller banks will have more incentive to sell loans into FIDCs. Investors in FIDCs backed by short term credit, such as factoring receivables, need to be especially vigilant.  These revolving FIDCs experience large turnover and the credit quality can drop dramatically in one month. Any sudden jumps in PDD or sharp increases in late payments (Créditos Vencidos e Não Pagos – CVNP) should be investigated quickly.   This information can be found on the Informe Mensal on the CVM website.

According to the CVM website, 23 FIIs with a total value of R$561 million where registered in 2008. In 2010, 39 FIIs were registered with a total value of R$9.7 billion. As of August 2011, 26 FIIs have been registered with a value of R$4.8 billion versus 16 FIIs in the same period of 2010 with a value of R$2 billion. In 2008 there were R$4.7 billion CRIs issued, R$3.8 billion in 2009, and R$8.53 billion in 2010, almost twice as high as the previous record in 2008. (CVM data)

The Comissão de Valores Mobiliários (CVM – the Brazilian equivalent of the SEC) had restricted FII to investments in pure real estate. The rules were relaxed in 2009 to allow FIIs to buy other types of real estate securities, such as CRIs, as well as the pure real estate. The new regulations also allowed CRI-backed FIIs to pass-through the tax advantages embedded in CRIs. This was one of the main factors in the growth in the market for FIIs.

However, there are recent signs that the market is cooling off. The performance of the FII market has fallen in the last four months according to Uqbar (a Brazilian firm that tracks the FII market and provides data through its Orbis service). In 2010 the 22 most actively traded FIIs returned a capitalization weighted average of 21.2% (Data from Uqbar, LatAm Structured Finance calculation). Just the price appreciation of FIIs was 13.2% in 2010. In April 2011 the average 12 month price return was 16.5%, in May and June 14.6%, and dropped to 12.2% in July.

Like the market for FIIs, real estate in Brazil is experiencing some hiccups after increasing steadily over the last few years. On August 31, 2011, Estado de São Paulo reported that the unit sales in the city of São Paulo fell 31% in the first half of 2011 and fell 28% in the São Paulo metropolitan area. While the level of activity is cooling off some, the São Paulo real estate market is still seeing lots of activity with 80% of the listed property being sold in 6 months or less. However, the market makers warn that this level of activity can only be maintained with continued economic growth and the availability of credit.

http://www.estadao.com.br/noticias/impresso,sinais-de-acomodacao-no-segmento-imobiliario,766321,0.htm

In a side article in the same edition, Ana Maria Castelo, an economist with Fundação Getúlio Vargas (FGV), writes that Porto Alegre and Belo Horizonte also experienced weaker real estate sales. She notes that this slow down started before the growing global credit problems and arises from domestic factors. Demand in 2010 was overheated and credit expanded very rapidly. This increased building activity also drove up prices and construction costs increased 7.71% in the last twelve months. Castelo argues that this is still not a bubble because the growth is sustainable and that Brazilian real estate will continue to perform well despite these recent setbacks. “Prices may not increase as dramatically, but they will not fall. Buyers will become more cautious as the prices continue to increase and financing will be limited by the level of income.”

http://www.estadao.com.br/noticias/impresso,nao-temos-bolha-o-mercado-vai-continuar-aquecido,766325,0.htm

The market for FIIs and CRIs in Brazil should be followed closely if the investor is planning on entering at these levels. The Brazilian economy is still growing but the growth is slowing dramatically. While delinquencies on real estate for business and residential purposes are at multi-years lows, Brazil is experiencing a bubble in the consumer credit markets and non-performing loans in this sector are rising rapidly. Banks are cutting back on credit and tightening their underwriting criteria. It is time to use some caution and look at the possibility of muted price gains for the foreseeable future in the Brazilian real estate market and the market for securities backed by real estate and real estate debt.

Foreign newspapers, especially the Financial Times, have been calling attention to the growing imbalances in the Brazilian economy and raising the possibility of an economic crisis. The growth of consumer credit in Brazil is one of the indicators that they cite frequently. The response from the Brazilian press has been to deflect or diminish these arguments by pointing out that the Central Bank of Brazil demands that Brazilian Banks hold a minimum of 11% in reserves versus 8% for the rest of the world.

On August 17th, the Brazilian Federation of Banks (Febraban) reported that banks, on average, are provisioning for 170% of late the paying credits on their books. These provisions are higher than in 2008. The Brazilian newspapers focused on the extreme level of provisions held by the largest banks; Banco Santander provisioned 143%, Bradesco 189%, Banco do Brasil 226% and Caixa Econômica Federal 310%.

In addition, banks are maintaining Basil Indices well above the mandatory targets. Of the large Brazilian banks, Santander is maintaining the highest Basil Index, 21.4%. Itaú Unibanco upped its index to 16.1%, Bradesco to 14.7%, Caixa Econômica Federal to 14.6%, and Banco do Brasil to 14.4%.

Building bank reserves is a little like building sea walls to protect from tsunamis. They are expensive because they reduce profitable lending opportunities in Brazil’s high interest rate markets and generally need to be built higher than expected to protect against credit tsunamis that come every 100 years.

Taking such extraordinary precautions is admirable, but people build high walls when they expect big waves. Outstanding balances for consumer credit in Brazil have grown at very high rates over the past year. Analysts estimate that the average Brazilian is now paying 25% of income to service his debt compared to 16% in the United States (Financial Times).

The percentage of non-performing consumer loans is growing quickly. The current statistics cited in the press for Non-Performing Loans (NPLs) is low because they use averages calculated by the Central Bank of Brazil. However, the Central Bank’s data shows that NPLs for Credit Cards and Debt for Acquisition of Goods are near their highs for past ten years when measured as a percentage of the bank’s portfolio. The most recent reports from Serasa/Experian, the Brazilian credit bureau, show that the index of late paying loans at non-bank finance companies continues to worsen and is 50% higher than its worst number ever in 2008. The Serasa/Experian index for NPLs in bank portfolios is not too pretty either; it is 27% above the highs seen in 2008/2009.

If the wall holds, then the land stays dry with maybe some minor damage. However, if the tsunami breaches the wall, the wave destroys everything. If the public has confidence in the banking system then high levels of reserves will protect the banking system from a “normal” credit crisis. If the crisis deteriorates to the point that the public loses confidence, then no realistic reserve level protects a fractional banking system from a crisis and the economy comes apart at the seams.

As we have written before in the other blogs and papers, the key is confidence. Can a small segment of the finance sector experience levels of default so high that it erodes confidence in the entire banking system? The 2008 credit crisis in the United States provides grounds for responding with a resounding YES to this question. We hope not.

Nagi Hamiyeh, managing director of investment at Temasek, said: “With a growing population of more than a billion, the African domestic economies are growing with the emergence of a middle class with an increasing disposable income. James Teeger, group managing director at E Oppenheimer & Son appears to be the representative of the Oppenheimer Family in this venture.

In the GCC region, investors who allocate to fund managers tend to prefer allocating to funds with larger assets under management, longer track records and higher levels of liquidity. Unfortunately, these requirements are common among investors in markets where the fund industry is relatively young, such as the GCC. Funds that do not meet these criteria from the offset must work harder to identify the correct investors, build an internal investor database and implement a professional marketing strategy in order to win allocations.

Identifying which group of investors you wish to target is the first step on a long process of relationship building. In the investor pyramid below, sovereign wealth funds top the chain and are usually seen as the largest allocators to funds globally, followed by pension and endowment funds. Beneath them, high net worth individuals tend to engage private banks, independent wealth advisors or family offices to manage their investment portfolio, who in turn may then allocate to funds of funds that are more industry/sector focused when looking to diversify their clients’ portfolios.

Allocations are not necessarily made in this order. However, having this picture in mind helps managers focus on their target market, since it is impossible to have a one-size-fits-all fund product. It also helps managers in developing their branding, sales and marketing strategy.

When building a marketing strategy, fund managers should identify where their target investors are domiciled and start gathering contact data on them from the websites of their respective regulators. For example, when looking for information on private banks in the DIFC, fund managers should go through the DIFC register as well as the DFSA register.

Another tool to help build an initial investor database is to purchase one from a reputable source. Although investor databases on sale on the internet are often out of date and occasionally contain inaccurate information, it is a good first step in building an internal marketing database for your firm.  Many of these investor databases contain contact details and descriptions of potential investors, which is useful when you wish to filter your target investor market. It is important to keep your internal database clean and updated, either by your internal marketing team or with the help of an external professional consultant.

Picking the correct customer relationship management (CRM) software is also important. Remember, finding an investor is less than half the work done. The ultimate goal is to convince them that your fund is a suitable investment candidate by building a relationship, and by being transparent with your product.

Make sure that a professional marketing strategy is put in place to send your funds’ details and performance data to the potential investor on a regular basis. Have your investor relation team visit the offices of the potential investor at least once a month, and make sure that every note relating to these investor visits are put on the central CRM system, so everyone in the team who might deal with the potential investor is kept updated on historical communications. The trick is to be consistent in your communication and in your follow-ups.

Finding investors and getting them to invest in your fund is no easy task, and there is no silver bullet. It involves time, resources and a little creativity in building your marketing strategy. The funds industry in the GCC is growing, and it is the fund manager who gets off on the right foot earliest wins the investments.

Contact me if you are looking to build investor relationships in the Middle East.

I recently was contacted by the founder of a risk management software company based in the United States, who was looking for an investor for his company pre-money.

Quoting from his email,

Our software is intended for the financial adviser as cutting-edge analytic support for better wealth planning decisions – pairing the adviser’s capabilities and client relationships with a toolset that helps to assess the client’s current risk and return profile, examine new investment and cash planning decisions not just in the content of risk and reward but in light of probability of goal success, and finally to optimize investment plans and cash plans using our patent-pending methodology. Our software is able to measure risk and optimize the full suite of investment products and insurance products, including complex variable annuities. This is why the current commercial interest in our solution is the following:

- insurers see our tool as useful in helping to sell their products (particularly variable annuities) to skeptical clients. Without a toolset like ours (which does not exist in the market) they cannot easily show how, for example, a complex variable annuity can help a client raise their probability of successfully meeting their overall goals. All clients (and many advisers) see is a highly structured insurance contract with an even more complex fee schedule; we can help quantify the benefits during various scenarios and stress environments.

- we are in partnership discussions with a US-based wealth advisory service to distribute a SAAS-driven wealth planning service to independent financial advisers, using our web services interface which integrates our analytics with any in-house or commercial full service wealth planning software application

- we are in discussions with a world-class wealth manager, who would use the software in their private planning desks to help with more complex, structured analysis for high net worth clients

Moving all of these forward is the key reason we, as a pre-revenue start-up, are seeking a strategic acquisition / stake at this point in time – particularly if the acquirer has interest in entering these commercial segments to leverage and expand their existing business lines.

I have looked at the presentation relating to this company and their software/services, and it certainly looks promising. If you’re reading this and have some interest in acquiring a majority stake in this company, drop me an email (felix@felixsim.com). This definitely looks like a company to watch.

 The UAE  may not be seen as such an attractive place for the investment community at the moment, but it certainly still presents a lot of hidden investment opportunities (and investor pools). Real estate prices is at its lowest points in history, banks are beginning to provide credit, private equity funds are allocating investments to businesses with growth potential, and private investors are starting to flock into the UAE (primarily Dubai) from neighbouring countries including the sub-continent.

Like all emerging markets, the only way to be able to tap into these opportunities is to physically spend time in the country. Not surprisingly, the Dubai International Financial Centre (DIFC) is enjoying the inward flow of financial institutions and investors into the Middle East. The DIFC arguably provides the best (and probably the only) legal and regulatory infrastructure to run a financial institution or family office in the Middle East. It is the only financial free zone in the Middle East with its own legal system and courts, and a regulator – the Dubai Financial Services Authority (DSFA) – which has become more mature and experienced in the last 6 years.

All financial services firms such as Hedge Fund managers, financial advisors and investment banks who wish to conduct business in the Dubai International Financial Centre MUST be authorised by the Dubai Financial Services Authority (DFSA). Before the DFSA can authorise a firm as an Authorised Firm, they need to be satisfied that the firm meets their Fit and Proper test, and is likely to do so on an ongoing basis. Generally, Fit and Proper means the ability to carry out a financial service competently, with honesty and integrity. Before 2010, firms that are looking to be authorised by the DFSA in order to provide financials services from within the DIFC have huge hurdles to cross, whether they were a regulated entity in another jurisdiction or not. The DFSA, being a forward-looking regulator, introduced a “Representative Office” license in the second quarter of 2010, and this changed the landscape of the DIFC significantly. Firms that are now regulated in what the DFSA calls “Recognised Jurisdictions” such as Singapore, Hong Kong, the UK, etc. are now able to apply for a Representative Office license, which effectively is a branch of the regulated parent.

This is a perfect license for firms regulated in other jurisdictions and are looking to expand their client base in the Middle East from the DIFC. Whilst a representative office is restricted to only market the products and services of its parent, and not allowed to take on clients, it is a valuable first step for most firms to start building their client base without too much regulatory (and economic) burden. The authorisation timeline for a Representative Office is also significantly shorter than that of a fully licensed firm, and there is also no requirement to hire any “Mandatory Functions” such as a full time Compliance Officer and a full time Finance Officer.

To know more about getting licensed in the DIFC and setting up your financial institution, please feel free to contact me.
Email: felix@felixsim.com
UAE: +971 56789 1863
Singapore/International: +65 9838 4560