Google, Amazon and The Shape of SME Finance

In November 2007 it seemed clear that facilitators like Google and Amazon would capitalise on their alignment with their customers' day-to-day activities to disrupt banking. Both of these giants already have e-money licences in Europe (I helped Amazon apply for its own), and the latest foray is into trade finance. Google will offer a line of credit for AdWords advertising spend, while it appears Amazon will lend to selected small businesses against their projected sales over the Christmas season. 

While these services may be offered initially in the US, where there are lots of small business funding options, bear in mind that only four UK banks control 90% of the small business finance market and are lending less and less to them. And while some UK banks enable some merchants to obtain cash advances against their card receivables, it's not exactly a core activity.

The competition alone must prove welcome, yet the critical feature of both the Google and Amazon services is that they are seamlessly intertwined with customer behaviour. Both businesses could have decided to launch free-standing, me-too banking services (like the UK supermarkets), but they have not done so. No doubt they also intend to attract new customers with the latest services, but only by showing that they support what small businesses want to do - namely, sell their own goods and services across a staggering array of markets and demographies.

And by patiently facilitating their customer's activities, neither Google nor Amazon needs to incentivise staff to sell services to people who don't need them, as banks have done.

Nude Labour and The Hung Parliament

Hung Parliament

Three Labour Party conferences after the sun set on New Labour, and it must be obvious to everyone that the party's eon in power gave it no insight at all into what might fix the root causes of this country's economic and social problems. So I must henceforth refer to the latest evolution as "Nude Labour".

Not that I'm any great fan of the other parties. As I said in May 2010, a hung Parliament means we have MPs where we want them: "They are not in control. They have little alternative but to listen and respond to our issues bottom-up."

I said "little alternative" because they are very persistent in manufacturing policies designed merely to get themselves elected rather than to actually solve the country's problems. This manufacturing process seems to consist of endless polls amongst 'swinging' voters (the confused but willing) and 'deserters' from the last election, littered with leading questions designed to persuade the victims that the party has the answer to problems created to fit pet policies. At the same time the 'party leadership' must battle the zealots and extremists to avoid appearing like complete lunatics to the rest of us. Oh, and of course they must find ways to disagree with everything the other parties say. And blame other politicians for every error, to encourage the myth that politicians make a difference. 

The recent West Coast railway fiasco is a case in point. The opposition politicians seem obsessed with blaming other politicians, rather than focusing on the deep problems in the way government departments have handled such bidding processes for many years. For instance, Daniel Kahneman refers to a "Planning Fallacy" in his book Thinking, Fast and Slow. He points to a 2005 study of worldwide rail projects between 1969 and 1998, in which it was found that 90% over-estimated passenger numbers by an average of 106%, and costs overran by an average of 45%, regardless of the publicity associated with each debacle. Gee, I wonder if it's possible that government tendering processes somehow reward bidders who over-estimate utility, and under-estimate cost?

It would be glorifying political parties to say they are themselves a root cause of problems in the UK. As I said in the context of the Red Book, their internal activities are more or less irrelevant to how any problems actually get solved by the more pragmatic amongst us. Witness the Labour Left's dogmatic approach to the reform of the NHS or social housing. And Ed Ball's astonishing rabbit-out-of-a-hat idea to blow the revenue from a 4G licence licence auction on affordable homes merely served to distract conference delegates from Labour's terrible record on actually building them. For the rest of us, his proposed magic trick eerily echoed Gordon Brown's ultimate destruction of the enormous 3G windfall. Hey, let's never forget that Balls was an economic adviser to Brown and staunch ally to the bitter end, and Ed Milliband was Brown's special advisor from 1997 to 2002. None of those people must ever be allowed anywhere  near the nation's coffers ever again.

Alas, not content with showering us with raw waste from two political non-events so far, we must now endure big media's coverage of the Conservative Party's attempt to thrill the faithful with its own recipe for clinging to power. A poor lens through which to view the world, but good fodder for the writers of vitriol. 

Meanwhile, it's down to each of us to find real solutions to the root causes of real problems, charting a pragmatic path through the party-political dogma-doo-doo.

Careful What You Incentivise

Two things seem to be choking the flow of money to people and small businesses in the UK: broken regulation and perverse incentives. Yet there's a tendency to focus more on regulation, and to only see the obvious incentives - like bankers bonuses. Some innovative self-regulation in retail finance has been welcomed by the UK government, and banking reform creeps ahead. But all this could prove futile if problems with incentives are not also addressed. To fix those, we need to look below the surface at the more fundamental incentives at play in the financial system. In particular, we need to understand the extent to which the likes of ISA schemes and pension investment rules are limiting competition and innovation in financial services and inhibiting economic growth. I've summarised some recent debate on this below, and added some comments on the government's latest defence of the ISA scheme. I'd welcome your thoughts.

Some of the perverse incentives have been outlined to government by tax colleagues previously (in Annex 3 to this document). In essence, the contention has been that certain tax relief selectively favours banks and the suppliers of regulated investments to the detriment of innovation and competition. In particular, the tax free ISA system funnels ordinary people's savings into UK bank deposits on a vast scale, which the banks then fail to lend. This effectively discourages and inhibits those same people from diversifying, one alternative being to extend finance directly to other creditworthy people and businesses through peer-to-peer platforms. As a result, it's been suggested that the ISA system should be extended to cover such direct finance. Indeed, in his response to the Red Tape Challenge, Mark Littlewood, Director-General of the Institute of Economic Affairs and a 'Sector Champion' said:

"...it is surely worth noting that the present format and definition of the ISA wrap may have raised “barrier to entry” problems for new financial products and it may be beneficial to review these to stimulate innovation in the sector."

But the impact on innovation is merely the tip of the iceberg. It's the impact on the wider economy that must be understood.

There is overwhelming evidence that the UK's small businesses are cash-starved. They represent 99.9% of all UK enterprises and are responsible for 60% of private sector employment. Their output is critical to the UK's economic growth, which has stalled. Yet they face a funding gap of £26bn - £52bn over the next 5 years. Critically, the four banks which control 90% of the small business finance market are lending less and less to them. This is a red flag. You might think from their enormous market share that these banks would consider small business lending to be very important and a retreat from that market unwise. But, as the economist Richard Werner has pointed out, the reality is that only about 10% of the overall credit issued by our banks goes to productive firms. The other 90% goes to fund deals involving financial assets which don't count towards economic growth figures. So for these banks small business lending is actually a sideshow. They clearly make their money elsewhere.

Yet the ISA scheme had lured savings and investments of £391bn from UK adults by the April 2012, half of which is in cash deposits in these same banks. And they pay nothing for it - a paltry 0.41% in interest after 'teaser rates' expire, according to a 'super complaint' by Consumer Focus in 2010. 

In other words, the government appears to be incentivising workers to plough their savings into banks which virtually ignore the sector on which most of those same workers depend for their income. 

Contrast this with the position in Germany, where 70% of the banking sector comprises hundreds of small, locally-controlled banks who provide 40% of all loans to SMEs.  In an ironic twist, the UK government now sees peer-to-peer platforms as a similar conduit for a new German-style government-directed lending programme. But it appears never to have openly considered that the limited scope of the ISA scheme is part of the problem. 

In March, the goverment defended the narrow scope of the ISA scheme for the reasons extracted here. In September, the government gave a different response (see p. 13 here). In the hope of sparking wider debate on the issues, I've set out the current defence of the status quo below (my additions/comments in square brackets). I welcome any comments.

"HM Treasury believes that there is not a strong enough case for [making bad debt relief available to P2P lenders], as creating an exception would add complexity to the tax system and is difficult to justify when other [unspecified] forms of investment do not qualify for bad debt relief. Moreover, the current tax treatment of P2P investors is not necessarily a barrier to further expansion, as witnessed by the impressive growth in the industry in recent years.

...HM Treasury does not believe that P2P loans are suitable for inclusion in ISAs. The risk profile of P2P lending is too high [compared to what? cash ISAs? stocks and shares ISAs?], and it is unlikely that the platform can satisfy some of the [unspecified] features essential to the operation of ISAs.

Consumers tend to view ISAs as a relatively safe and simple investment vehicle [this fails to distinguish between cash ISAs and stocks/shares ISAs. And are they safe?]. ISA investments are thought of as relatively low-risk, and consumers should be able to get access to their funds whenever they wish. This is less likely to be the case with P2P lending than with existing ISA Qualifying Investments [this could be cured by permitting secondary markets in P2P loans]. 

Similarly, existing Regulations require ISAs to be operated through an ISA Manager [regulations could include P2P platforms], who invests through persons or firms who are authorised by the FSA, and thus have access to the FSCS [this does not mean you can't lose the principal in your stocks/shares ISAs, or stop banks paying 0.41% interest on cash ISAs]. As far as we are aware, current P2P lending platforms are not conducive to the ISA Manager role, are not regulated by the FSA, and do not offer Financial Services Compensation Scheme (FSCS) protection [any or all of which could be changed by regulation].

Finally, in order to be included in an ISA, P2P loans will require to be listed as a Qualifying Investment. Qualifying Investments are identified generically. It would be extremely difficult to restrict a generic description such as “loan” only to loans made via P2P lending platforms [but none of the qualifying investments are so generic, being limited by reference to 'banks', 'building societies', 'recognised stock exchanges' etc., so why not by reference to 'P2P platforms'?]. Exclusion from the ISA wrapper does not make this type of lending exceptional; rather, it puts it on the same footing as investment in stocks and shares issued by unlisted companies [how are these activities equivalent?]."

UK Takes Joined-up Regulatory Approach To P2P Finance

The UK government has announced a cross-departmental working group to support the sustainable development of peer-to-peer finance (aka 'crowdfunding'), as part of its latest response to the Red Tape Challenge. 

The composition of this working group is testimony to the broad policy implications and opportunities posed by this new form of financial model for consumers and small businesses. The list of members includes the Office of Fair Trading, the Department of Business Innovation and Skills, HM Treasury, the Financial Services Authority and the Cabinet Office. However, it is known that the Department for Culture Media and Sport is also very interested in the potential for peer-to-peer finance to fund the development of the arts and entertainment industry.  

Specifically, that working group will "monitor the appropriateness of the current regulatory regime for peer-to-peer platforms" and take the lead in engaging with the peer-to-peer finance industry.  In the meantime, the government wishes to encourage continued self-regulatory efforts by the Peer-to-Peer Finance Association to address common operational risks, and to engage with policy-makers and regulators.

Other aspects of the government's response to the 'disruptive business models' Challenger Businesses Red Tape Challenge are discussed here.

Credit Drives Growth (Not Interest Rates)

Thanks to IPPR and The Finance Innovation Lab for an invigorating seminar on bank reform this morning. I've noted some of the highlights below, but in summary: Chris Hewett gave a great overview of the range of proposals; Richard Werner debunked the myth that interest rates drive economic growth and explained why the Bank of England must guide bank credit away from speculation and into productive firms; and Baroness Susan Kramer explained the work being done in Parliament.

Chris's 'policy map' in particular is worth studying in particular (zoom out of his presentation to find it). It reveals the ideas that are merely 'a glint in the eye', those that are attracting support and those that are being fought over by stakeholders in a way that is likely to produce change in the near term. 

Richard showed that interest rates do not drive economic growth. Rather, they lag changes in economic growth by as much as a year. So it's a myth that lowering interest rates will increase economic growth, or that raising them will slow growth. Instead, the evidence proves that those in charge of monetary policy merely react to a slowing economy by lowering interest rates, and react to a growing economy by raising them. In other words, economic growth drives the setting of interest rates not the other way around (so GDP growth and interest rates are positively correlated, not negatively correlated as many people suggest).

So the current low Bank of England base rate merely reflects the current economic malaise, and changing it one way or the other won't drive economic growth (GDP). Mortgage rates are already much higher, anyway, and it may be doubted whether banks would pass on any rise to savers.

In fact, Richard observed that the only driver of growth in GDP is bank credit that is used for productive investment. Credit used for consumption merely raises inflation, and credit used to buy financial assets (which don't count towards GDP) merely drives up non-GDP asset prices.

Richard explained the importance of recognising that we derive 97% of our money supply from banks extending credit. They 'create' money every time they make a loan. But here's the killer: only about 10% of credit created by UK banks actually goes to productive firms. The rest of the credit created is used by investment banks, hedge funds, private equity and so on to speculate on non-GDP assets.

In addition, the risk-weightings under bank capital rules discourage banks from lending to small firms (as I've also mentioned before), effectively encouraging lending to fund speculative property deals - even though the overall risk profile of loans to small businesses is lower than lending for speculative purposes, and in spite of the fact that small firms represent 99.9% of all enterprises and are responsible for 60% of private sector employment).

Richard explained that Project Merlin and the more recent efforts by the Treasury to shame banks into lending to productive firms all fail because the banks can afford to ignore the Treasury. But central banks have been successful in guiding credit to the right sectors previously, because the banks rely on the faith of the central bank to stay in business. The IMF has previously discouraged the use of this so-called "window guidance" because it has been abused in certain countries (e.g. to aid speculators or political cronies). But a transparent programme could work. A longer term alternative is to create new banks that never lend for speculative purposes - in Germany, for example, 70% of banks (about 2000 of them) only lend locally. Spain had a similar system, but then required its local 'cajas' to lend nationally, with devastating effects.

Finally, Richard said that the banks' could lend more to productive firms and still meet their capital requirements. But they need to lower the bar to obtaining credit (which German banks have commonly done during a downturn) and to incentivise staff for making productive loans. Currently, it's easier for bankers to earn bonuses for supporting speculative activity.

Baroness Kramer explained that Parliament is focused on four main aspects of the financial crisis: the market failure to provide bank credit to productive small firms; capital/cost barriers to launching new banks; encouraging peer-to-peer finance platforms; and ensuring that the Financial Services Bill and the up-coming Banking Bill are fit for purpose. 

Susan said that the Joint Parliamentary Committee on Banking Standards should have the membership and resources to get to the root cause of market failures and make improvements to fix them. While the evidence of market failure is clear, more evidence of the underlying problems and causes is very much welcome (even after the deadlines for submissions have expired). There is a belief amongst some in the House of Lords that the same regulator should be responsible for addressing market failure, as well as enterprise risk and market abuse, because they are all linked. The FDIC in the US provides an example of how this can work.

Proposals to reduce capital/costs that prevent the launch of new banks include reduced capital requirements for local banks that won't be systemic; and the regulation of a common banking platform that takes care of most operational risks, so that small banks could simply 'plug-in'. Susan observed that credit unions only cover about 2% of the borrowing population, so are not a replacement for new, local institutions.

Baroness Kramer has led the way in proposing amendments to the Financial Services Bill to proportionately regulate peer-to-peer finance. In the course of discussing those proposals, it appears that the Treasury has conceded that there is already a provision in the Financial Services Bill that could enable such regulation. However that still leaves the job of agreeing the detailed secondary legislation (and any further enabling legislation) required, so the industry should keep up the pressure in that regard.

Finally, Susan praised the white paper that underpins the Banking Bill as containing 'pretty good' language on enabling new entrants to the banking industry. However, it is going to be important for everyone to be vigilant in ensuring the spirit of this is captured in the provisons of the Bill.