Archive for the ‘Uncategorized’ Category

Cayman’s Financial Services Industry
- How (and Why) it Works

Thursday, August 12th, 2010

There is a good deal of comment these days about the role of offshore financial centres in the global economy. But what comes across loud and clear is the high level of misunderstanding not only outside of the Cayman Islands, but as importantly from within.  Capital flows, macroeconomics, cross border transactions and legal and regulatory structures are not necessarily easy concepts to understand, but just as one does not have to be a mechanical engineer to know how drive a car, you do not have to have a PhD in Finance to become conversant on the fundamentals of how the offshore financial centre model works.  A better national understanding of it is vital – for example, Cayman’s financial services industry contributes 54% of the GDP  of the Cayman Islands.

The globalisaton phenomenon has made the world a much smaller, more accessible place.  Lightening speed communications mean that investment opportunities in an emerging economy can be simultaneously considered by institutional investors sitting anywhere in the world – London, New York, Bejing or Frankfurt, for example.  The question then becomes – how are the funds pooled efficiently, so that capital can be put to work in the chosen project or investment?  How are funds from investors across the globe collected so that the investor sitting in Germany does not subject himself to additional tax or regulation for a project that will be carried out in the United States?  The Cayman Islands provides this function simply:  a tax-neutral platform for pooling the investment funds; a well-practiced process of incorporation; and compatibility with securities listing requirements on most of the world’s major stock exchanges, including those in New York, Hong Kong and Dublin.  What does all of this mean?  It means that the capital invested will be maximised by minimising the tax bite in accordance with all applicable tax laws and thereby creating more jobs and economic activity.

For those who might mistakenly believe that investors are not paying their share of tax, remember that the dollar invested was taxed when earned, and will be paid on profits made.  Further, when funds are repatriated (in the form of dividends, or other capital gains) to the investors, they will be taxed on receipt.    It should also be said that an additional layer of taxation does only one thing:  it removes wealth and productivity from an economy. The essential feature of the offshore structure is that it does not add an additional layer of taxation.

Those who support the “higher tax” argument (i.e. those Governments that are facing insurmountable deficits and no idea of how to pay for them) like to insinuate that root of the financial crisis can be found in offshore financial centres.  It is important to note – the financial crisis originated in the largest of the G-20 economies in areas that were already heavily regulated.  Mounting academic research is available to support this fact,  not least of which was the report on all the British Overseas Territories and Crown Dependencies by Michael Foot on behalf of the Chancellor of the Exchequer in October 2009.  In truth the capital flows that have already been described through jurisdictions like Cayman are now fueling the global economic recovery – the largest recipient of funds flowing out of Cayman is the United States.  Emerging markets are also beneficiaries, where the introduction of capital is the most effective tool for reducing poverty in these poorer nations, providing jobs and opportunities where none had existed before.

Cayman’s regulatory and transparency standards are amongst the very best in the world and are the benchmark by which other countries are measured.  Cayman has full income tax transparency with the United States and proactive tax reporting with the 27 European Union member states.  The US Department of Justice has had full authority to conduct a criminal investigation regarding any file in the Cayman Islands since 1990.  As a member of the International Organisation of Securities Commissions (IOSCO), Cayman has full “regulator-to-regulator” disclosure with all IOSCO regulators.  The anti-money laundering legislation of the Cayman Islands has been evaluated by the International Monetary Fund and by the Financial Action Task Force and is found to be superior to that of the United States and most EU jurisdictions.  Cayman continues to look at effective, commercially-minded regulation and the Cayman Islands Monetary Authority sits on several committees of international regulatory bodies to ensure progressive action on the issue of anti-money laundering and transparency.

So why is Cayman the target of so much negative criticism?  One answer is that politics is constantly at play.  Cayman’s success has brought attention from competitor jurisdictions which have been working very hard to increase their market share at the expense of our offshore financial industry.  But the biggest slice of the mud pie comes from G-20 politicians who are working very hard to get nods of approval from voters who want to believe that the trillions of dollars of government debt can be paid for by ‘shutting down a tax haven’.  What will be harder for politicians to explain, should more protectionist legislation be enacted, is why big business located in their jurisdictions found alternate places to domicile, with the result that highly coveted tax dollars did not increase at all but rather reduced.  How do they then explain to those voters that the only thing that increased is the length of the unemployment line?  The fact is that constant mischaracterisation cannot defy gravity forever.  The best part of the Cayman story is that eventually the truth about it must come out.


Once more, the truth about Cayman transparency

Wednesday, July 21st, 2010

I suppose the nature of this ongoing debate is that we at Cayman Finance keep restating the facts and those with alternative agendas keep ignoring them.

There are all types of unaccountable sensationalist blogs, publications and fringe socialist groups that like to appeal to the lowest common denominator in the name of ‘the common good’ and the Huffington Post is no exception.

Notwithstanding our recent advice to the editorial staff and indeed Ms. Huffington herself, the site loses all credibility when they continue to allege that the Cayman Islands are ‘secretive’.  For the record, one more time plain and simple, so everyone should  get it, in addition to the All Crimes Treaty which gives the Department of Justice full authority to obtain any Cayman Islands file, there is the Tax Treaty which extends the transparency to the IRS  for any tax matter and in addition, there is the IOSCO regulatory transparency.

Those who are able to read and understand these treaties, (not incidentally negotiated and signed by the US Government) will be trying to figure out what exactly the Huffington Post is talking about?  Perhaps what they mean is that they are upset that there are perfectly lawful provisions of US tax law which enable US corporations to avoid being taxed twice and which will allow those corporations to remain competitive in the global marketplace as against those corporations from jurisdictions that tax their corporates only once.  If that is the cause of the upset by all means change US law but the Cayman Islands has nothing to do with that discussion and making up fantastic numbers about “lost revenue” is going to lead to disappointment.

But do bear in mind also that there is an unintended consequence to rendering your global corporations less competitive (Levin/Dogget) and to rendering inward investment into the US so problematic that no one wants to bother any more (Hire Act ), particularly, one would have supposed, when you are the largest debtor nation in the world and survive only on inflows of borrowed money.

Private Sector View on Regulatory Infrastructure. Striking the Right Balance.

Thursday, July 15th, 2010

It was once said that there are lies, damn lies and statistics, but when we look at the gross mischaracterisations that are targeted at offshore financial centres, and the Cayman Islands in particular as one of the more successful of these jurisdictions, we find that a good look at some facts is an excellent starting point for the debate and at the very least extremely good for morale.

What is fascinating about an objective and non-arbitrary analysis is that despite the negative publicity which is founded in the blame deflecting endeavours of certain G-20 politicians and regulators, that is to say regulators in the jurisdictions in which the core of the financial crisis was rooted, Cayman’s financial services industry paints a robust picture.  Let’s look at the key statistics:

  • Bank deposits and interbank bookings in the banking industry remain at US$1.8 trillion, down only some 10% from the 2008 high
  • Mutual and hedge fund establishment is running at some 100 new registrations a month with an aggregate number of some 9,486 regulated funds, a drop of only 5% from the 2008 high (although it is fair to point out that gross assets under management have dropped from US$3.6 trillion to approximately $2.5 trillion, no doubt a reflection of the deleveraged marketplace in which hedge funds are currently operating
  • In the captive insurance market, we remain strong competitors for Bermuda, steadily catching them with 789 captives holding approximately US$45 billion in assets under management
  • It is only in the area of company incorporations where we see a decline of about 30%.  This is where we see the true effect on decreased transactions reflected as a consequence from the lack of available credit. That being said, the total number of companies incorporated are in the region of some 90,000.  The view from within the industry in Cayman is that the reduction of company incorporation numbers is largely due to the reduction in the number of structured finance transactions, which is directly attributable to the effects of the sub-prime crisis.

The reason I have dwelt upon these statistics at some length is not to simply cheer myself up.  The real point is that throughout the financial crisis and no doubt because of the regulatory mechanisms in effect in the Cayman Islands, no Cayman bank or financial institution failed.  No depositor in a Cayman Islands bank or financial institution lost money.  There was no Bear Stearns in the Cayman Islands, no Lehman brothers in the Cayman Islands, no Northern Rock, and no Royal Bank of Scotland.  Clearly, before we start to analyse what may be required in terms of enhanced levels of regulation we need to start with the recognition that regulation in the Cayman Islands worked effectively.  And I will go on later to discuss why this is the case.

We have been bombarded over the past 12 months with various reports from regulators and others as they look to create, appeal to and reinforce public perception about what needs to be done on the regulatory front.  We heard many of these issues discussed over the past two days at this conference.

After considering the reports and the various presentations, I wonder if I am alone in arriving at what seems to me to be the inevitable conclusion that there is a major disconnect between the suggested responses and a realistic analysis of what actually caused the financial crisis.  Various experts have differed on attribution of the crisis causes, but the debate can be boiled down to two simple points.  The first can be summarised as simply irresponsible bank lending practices driven by political motivation in the US, dressed up in the laudable objective that every American had a right to own their own home regardless of their ability to pay for it   We know that the mortgage defaults in and of themselves were not enough – the disintermediation of risk through securitisation added accelerant to what was already a wild fire and transferred an inadequately evaluated risk around the globe.  Secondly, that same disintermediation of risk could not have occurred without the repackaged assets having been branded AAA by the rating agencies.  Many investors, including some European and Asian banks, who were clearly incapable of undertaking the very basic degrees of due diligence in support of their own balance sheets, relied solely upon these ratings.

We can also say that the method of set-off of derivatives as between one major wall street investment banker and another did nothing but obfuscate the aggregate value of the derivatives in issue, which only manifested itself when major counterparties like Bear Stearns and Lehman’s were allowed to fail because set off was no longer applicable.  It is not for me today to comment on the moral issue here or the fact that AIG was not allowed to fail.  The simple fact of the matter is that had AIG and others been allowed to go under the effect on the financial system would have been cataclysmic.  If anyone doubts the foregoing analysis and many do, I will cite the very distinct practices applied by the big 5 Canadian banks and rest my case – and I am not saying that just because I am Canadian.

The point I really want to make in analysing the appropriate regulatory response is that if you accept the foregoing two reasons as the fundamental cause of the financial crisis, you will also have to accept the irony that the problems occurred in the banking industry which was already highly regulated in a jurisdiction which now leads the G20 and G8 debate on regulatory reform.

But do we find in the regulatory response a tacit recognition of this fundamental?  I think not.  What we find is Mr. Gordon Brown when addressing the US congress asking the rhetorical question “Would the world not be a safer place if jurisdictions like the Cayman Islands were outlawed?”  The universal acclaim to which this question was met belied the fact that the Cayman Islands financial services industry had remained robust throughout the crisis.   As an exercise in blame deflection this performance surely deserves some form of Oscar or at least a nomination for best fictional screenplay.

But we are of course all familiar with the pejorative descriptions of offshore financial centres.  The expression “tax haven” which cunningly suggests that tax evasion is still an issue for the offshore financial centres notwithstanding the extensive range of tax treaties and proactive reporting under the EU Savings Directive and various other tax information exchange agreements.  The expression ‘tax loophole’ is the one preferred by US politicians, which is used to cloud the fact that lawful tax avoidance rests exclusively within the tax legislation of the US and is exclusively within the purview of the onshore politicians concerned.  Cayman Finance has had occasion to write directly to President Obama and Senator Dorgan to make these blindingly obvious points directly.

No doubt a major part of the problem has been a historic failure on our part – the offshore jurisdictions unfairly targeted, to make our case and tell our story.  But we do so now.  And we do so on a regular basis.

Not only are the public misrepresentations of offshore tax transparency unfair to those jurisdictions who have entered into and continue to enter into full transparency treaties, it is equally unfair to Joe Public who is misled into believing that the solution to gross onshore government over-expenditure and climbing domestic tax revenues lies in some mythical offshore pot of gold in the possession of a leprechaun sitting at the end of a hypothetical rainbow. What we do know as fact from the tax transparency initiatives that have been in place in Cayman for the past decade is that tax evasion is an insignificant component of our financial services industry.

And now we find ourselves in the same boat when it comes to the issue of regulation.  The EU AIFM Directive (which I will call the directive) seeks to blame hedge funds for the financial crisis, although that logic is wholly flawed.  Although there are still some 1200 unreconciled amendments and therefore no final version to comment on, the Directive as it stands quite reasonably suggests that any investment manager trading in the EU on behalf of a non-EU hedge fund should be subject EU trading and risk regulation.  It quite unreasonably seeks to say that non-EU domiciled hedge funds should be precluded from being marketed in the EU.

Thus we see, in the same way that politicians vainly suggest (at least as so far as the Cayman Islands are concerned) that domestic deficits will be funded from offshore tax evasion — flawed analysis of the causes of the financial crisis and flawed political regulatory responses will lead to unintended consequences.

It has apparently not occurred to European politicians (although the rappateur M. Gauzes  has been told by Cayman Finance directly) that restricting the investment objectives, risk profile and leverage of an EU fund manager will cause the investing public and the pension funds that represent them to suffer with a less competitive rate of return.  And all this in circumstances where no one has seriously argued that hedge funds were instrumental in the financial crisis.  And therein lays the root of the problem.  Nobody and certainly not in the Cayman Islands has the slightest concern about the application of a global regulatory solution to a specific regulatory failure or to a systemic risk that ought to be properly regulated.  But, what is actually occurring is a territorial and piecemeal approach by way of regulatory response which has failed to deal adequately with the causes of the problem.  It is a staggering fact that the current financial regulatory reform bill working its way through the US senate and congress does nothing whatsoever to address the core of the financial meltdown – specifically the dangerous lending practices of Freddie and Fannie.  And now the regulatory response from Europe is to exclude institutional investors who have undertaken their due diligence and who have received perfectly satisfactory 15% or more annualised returns from Cayman hedge funds from investing in those hedge funds.

You may well ask whether we should be concerned about the directive in the Cayman Islands and the answer is not unduly since the Cayman Islands has an institutional product that was not authorised to market itself cross-border to the public in any event.  And, no institution whether in Europe or elsewhere in a global financial environment needs to invest in a Cayman hedge fund from within Europe.   The Directive in its current form may well dis-incentivise investment into Europe at a time when Europe needs all the help it can get.

The other point we may take well under consideration is that the International Monetary Fund in their report prepared for the June G20 summit in Toronto stated and I quote “it is important to ensure that the financial system regulatory reforms in advanced economies do not have unintended adverse effects on financial flows to developing countries or their financial sector management.  Vigilance is needed to avoid financial protectionism.”  The report then goes on to say “G20 leaders can boost market confidence by renewing their commitment to refrain against protectionist measures.  An even stronger signal would be a collective pledge to unwind the protectionist measures that have been put in place since the onset of the crisis.”  The IMF is calling out for more open trade and less protectionist measures because it is a fact that restricting international capital flows, and restricting tax competition hurts the poorest people in this world the most.

By all of this I do not mean to say that we are adverse to regulation in fact, rather the contrary.  I simply mean to say that there is a massive disconnect between the high sounding principles which emanate from high sounding institutions on the issue of regulation and the reality.  For example, if we look at the banking industry, we see a global regulatory framework in Basel 1 and Basel 2 that applies across the board.  And that is how it should be.  The notion that some countries can apply a Tobin tax whilst others do not shows no understanding whatsoever of a competitive marketplace.

But I will make the point again that even in the case of a global banking regulatory framework, it was US banking regulation that failed.  It could very well be argued that what is needed is not new regulation, but a proper application of existing regulation.

The same could be said for hedge funds.  Certainly the hedge fund manager with the assets under management allocated to it must be regulated in accordance with the jurisdiction where it undertakes its business activity.  But prior to the crisis, the SEC did not regulate hedge fund managers trading in the US at all. So if what is now proposed is that hedge fund managers be regulated, that seems entirely sensible and logical, provided it can be argued that there is a global system of hedge fund regulation in place (and there is not).

It can only be the case that the hedge fund must be regulated through the hedge fund manager in accordance with the laws in the jurisdiction in which it trades.  If that were not the case we would have an illogical situation if we were to have a fund with four different hedge fund managers trading in four different jurisdictions.  Thus far it is only in the area of banking where we have a global regulatory system represented by the Basel accords.  It is for the G20 and other to first establish the global systems with regards to fund management, private equity, derivatives, structured finance, insurance and indeed all areas of financial services before there can be meaningful talk about global regulation.  As matters stand, the rhetoric of the international bodies is well ahead of the substance.

In the meantime, we in the Cayman Islands would be first to say that the issue should be a focus on transparency.  The Cayman Islands has full IOSCO membership and therefore full regulator to regulator disclosure.  Is there really value then in the EU suggesting that that form of IOSCO agreement will not be acceptable for the purposes of establishing regulator to regulator disclosure under the AIFM Directive?  Clearly this is simply political posturing undertaken in the name of regulation.  Is the EU really saying that the IOSCO regulation is really inadequate and if it is, should it be allowed to do so?  Clearly if transparency is established in accordance with the requirements of an international body, that should be sufficient, otherwise we run the risk of recreating under the regulation banner the same fiasco that arose with respect to tax transparency when the OECD for political reasons refused to recognise the Cayman Islands unilateral tax transparency mechanism and then insisted on the precisely same thing introduced under a bilateral mechanism.

It is important that regulation is not used in this way as a cloak to shield the hidden agenda of onshore jurisdictions who are more interested in protecting their domestic economies from tax competition and to use the terminology of tax evasion and lack of regulation as weapons of choice.  The recurrent suggestion that there exists “dark pools of capital” that exist in some unregulated or unspecified manner in jurisdictions such as the Cayman Islands is the purest nonsense.  Transparent offshore financial centres like the Cayman Islands ensure that capital is efficiently deployed and given that tax evasion is off the table, operate by ensuring that funds are fully invested in accordance with the rules of onshore markets, whether these are in the US, Europe, Asia or South America or wherever.  It is a mistake both for tax transparency and regulatory purposes to conflate the Cayman Islands and other transparent offshore financial centres with jurisdictions like Switzerland and Liechtenstein which have until recently relied on secrecy and non-disclosure.

What we anticipate and welcome is a true level playing field and no, despite what we heard yesterday from the OECD, we have not yet arrived.  It should not be the case when regulation is required in the Cayman Islands to a more restrictive and onerous standard than is applied in G20 jurisdictions.  Think back to the anti-money laundering legislation that was required to be applied retroactively to every pre-existing Cayman client.  But that was not a standard that was required in the US, UK or continental Europe.  If those who seek to apply regulation globally are to have credibility such regulation must be part of a global standard.  And it must be applied in a non-prejudicial and non-arbitrary manner across all jurisdictions.  Regrettably what we are seeing thus far by way of regulatory response falls short on both points.

A warm welcome to Trinity

Friday, October 23rd, 2009

On behalf of CIFSA I would like to welcome Trinity Fund Administration to the Cayman Islands.   Trinity has received a full Fund Administrators licence from CIMA and has now opened an office here.

Brad Cowdroy has been appointed Head of the new Cayman office.  He has previously lived in the Cayman Islands while working for CIBC and PricewaterhouseCoopers, but is most recently from Goldman Sachs where he was a Vice President in Fund Administration Services.

Attracting new investment in Cayman is essential to the country and our industry.  The lack of physical offices and personnel is often used as an argument against the validity of corporate vehicles created here by those with little knowledge of the structure and purpose of those vehicles.  Adding to that base can only help to further marginalize those misguided comments.

CIFSA and the CIG, along with several private sector organizations like the newly formed Investment Council are working together to attract new business investment in our islands.  Funds Administration and Captive Insurance are two of the more obvious areas being targeted for expansion.

CIFSA will be contacting Trinity to promote the benefits of joining our association and the need to protect their new investment here from international threats.  The strength of our membership is what gives weight to CIFSA’s voice in the international community.  We encourage participation from all industry participants.

CIFSA Update for August

Friday, September 11th, 2009

CIFSA has been actively promoting its revamped public affairs and public relations campaigns for what has been an eventful few months. The most notable result has been the success of the CIFSA campaign to promote the inclusion of Cayman on the OECD White List.
CIFSA Chairman Anthony Travers has been heavily engaged in his role as spokesman for the association. His most recent letters and commentary have been published in The Washington Times, Hedge Fund Journal, and The Nation and he has been quoted extensively in articles by The Economist, Reuters, Dow Jones Newswire, Hedge Fund Manager Week, Global Investor magazine, Worth Magazine and other foreign press. Mr. Travers has also appeared internationally on the BBC World Radio News, Bloomberg and closer to home on Cayman 27. Over the coming weeks the Chairman will be meeting with a series of national Editors in the UK to continue his lobbying efforts in support of Cayman’s financial industry, building on his commentary on industry issues like the EU Alternative Investment Funds Directive. In September, Mr. Travers will be attending the London based FT Global forum, sponsored by CIMA.
“There exists in some quarters still an entrenched mischaracterisation of the Cayman Islands, as a place where certain individuals hide their money from foreign tax officials.”, says Mr. Travers. “The single greatest challenge in my role as Chairman of CIFSA is to expose the fallacy of these misperceptions in the light of the factual record. To that end CIFSA engaged the services of established lobbying & PR firms in Washington and London to assist us in this area. And we have already seen tremendous progress in tearing down the old stereotypes.”

In July, CIFSA hosted the much anticipated visit from Washington lobbyists Quinn Gillespie and Associates. Jack Quinn and Manuel Ortiz of QGA spoke at the CIFSA dinner event and had a series of meetings with senior members the CIG, the Cayman Islands Stock Exchange, and the Cayman Islands Monetary Authority.

In August the CIG formally signed a Tax Information Exchange Agreement with New Zealand, bringing the total bi-lateral TIEAs for the Cayman Islands to twelve. Having reached the required number of TIEAs, as set out by the OECD, the Cayman Islands was subsequently added to the OECD White List.
This is a significant accomplishment for the new government in just a few short months since taking office. CIFSA representatives sit on the government’s Financial Services Council, and regularly attend meetings with CIG on matters that concern the industry. CIFSA is also represented on the newly formed Investment Council which is focused on private sector initiatives to attract business investment to Cayman.
CIFSA fully intends to remain alert and responsive to new challenges that may present themselves and proposes to be proactive in developing relations with foreign governments and media. The truth remains our strongest ally in attempting to dispel myths and cultivate more accurate perceptions of our financial services around the world.
The inclusion of the Cayman Islands on the White List is an important step for the industry but CIFSA does not intend to rest upon that accomplishment. We recognize, and are monitoring, the initiatives that many foreign governments are considering to legislate in a way they hope will increase tax revenues and limit the use of offshore vehicles that legally minimize tax payable. CIFSA proposes to work with CIG to educate policymakers and lawmakers about the positive impact offshore vehicles have on global competitiveness, investment, and employment in developed countries.