Memorandum submitted by Chequepoint Money
Transfer
Some suggestions for possible changes in
legislation and regulation over the UK money transfer market which
may have a positive impact in improving and increasing the flow
of remittances to the developing world:
INTRODUCTION
Chequepoint is pleased to have an opportunity
to contribute to the deliberations of the committee in relation
to its work on migration and development.
Chequepoint recognises that as part of your
enquiry, the committee has already received a presentation from
Dahabshiil money transfer, which, like ourselves, is an independent
money transfer provider. We have read their evidence with interest;
however, we feel the committee needs much more information if
it is to have a fuller picture of the influences which are shaping
the UK money transfer market today.
As a money transfer company which provides a
service to more than 70 developing countries worldwide, including
the following African countries (Sierra Leone, Ghana, Nigeria,
Gambia, Zimbabwe, South Africa, Morocco, with more starting soon),
Chequepoint has long recognised that remittances are enabling
people resident in the destination country to improve their standard
of living (eg through access to health care) and to take advantage
of new opportunities (eg through access to education).
Chequepoint feels that the impact of remittances
has for too long gone unnoticed by policy-makers in the UK and
elsewhere in Europe; we believe that remittances will play a crucial
and expanding role in the future as source of much needed funds
in the developing world. Remittances must be factored in as a
key element in the formulation of longer term European aid policy
for developing countries.
According to World Bank figures, the total volume
of remittances sent worldwide in 2002 was USD$80 billion. Sending
money home dwarfs the $USD16 billion of net government and bank
lending. In the western hemisphere alone, foreign earnings from
expatriate remittances now provide capital flows that have nearly
quadrupled in the last ten years.
Because remittances have been neglected as a
source of investment in developing countries, there are no figures
which give an indication of the annual outflows of remittance
funds from the UK and other Western European countries to Africa
and Eastern Europe. In the context of this information vacuum,
we refer the committee to what has happened in the United States,
where remittances flow extensively to South and Central America
and the Caribbean. We believe that what has happened here is analogous
to what is presently happening in terms of remittances flowing
from Western Europe to Africa and Eastern Europe.
According to the Washington Inter-American Bank,
remittance payments from the US to Latin America and the Caribbean
topped £32 billion in 2002. Remittance payments from South
Americans working abroad matched the total amount of direct foreign
investment made by trans-nationals working in the region. In several
countries (Mexico, Jamaica, El Salvador, Nicaragua, etc) 10% of
the country's GDP is generated by foreign worker remittances.
It is estimated that in the coming decade Latin
America and the Caribbean may receive as much as $300 billion
dollars. Such flows would exceed by far the aid donated through
international organisations and government initiated programmes.
And it seems certain that the impact of remittances on the livelihood
of those who receive them is much more significant that the impact
of government directed aid, which may be lost or mis-applied by
the governments which administer them.
In short, remittances are already having a major
impact in allowing the individuals who receive them better access
to education and health care.
For many people in Western Europe, the key issue
of our times is the increasing numbers of migrants who are arriving
here from less developed countries in Africa and Eastern Europe.
Governments are all too aware of the social policy implications
and are trying to manage migration flows. In this context, it
clearly makes sense for European governments to re-double their
efforts to put in place policies which help to reduce the push
factors in less developed countries and regions. A clear policy
which harnesses the remittance outflows from migrants already
arrived must be central to maximising financial investment in
the developing world.
For these reasons, the mechanisms by which migrant
workers send money back to their countries of origin are crucial
to the debate. Based on a lack of objective information, UK policy
makers such as the International Development Committee may have
assumed that the UK banks are going a large part of the way to
meeting the needs of this market.
Chequepoint believes this is not the case. We
are certain the UK banks do not want to meet the needs of ethnic
minorities and newly arrived migrants, the very group which most
urgently needs to send money remittances back to their countries
of origin. The UK banks make it difficult to open a bank account
without ID and proof of address, and these proofs of identity
are not always readily available to workers who may be regularly
changing both jobs and accommodation. Many ethnic minority and
newly arrived workers have been permanently relegated to the status
of `unbanked'.
Even if this kind of worker does manage to open
a bank account, the banks do not offer a money transfer service
which meets their needs. Transfers are expensive (£20 minimum
fee is normal and rates of foreign currency exchange are poor),
slow (the transfer may take three weeks to arrive) and the network
of payout locations in the receiving country may be limited (for
example, cash payout may be unavailable or available only at extra
cost). Contrast this with the independent money transfer sector,
which can deliver a cash payment in the destination country cheaply
and quickly (often within a few hours).
In an environment where the UK banks are uninterested,
at best, in transfer business, consumers are turning to bespoke
money transfer companies. Here they have a choice between oligopolistic
suppliers such as Western Union and Moneygram and the independent
money transmitters such as Chequepoint.
As the committee has already discovered, there
are some major differences between the oligopolistic suppliers
and the independents. Price is a crucial one but not the only
one; for a money transfer of £100, WU will typically charge
£14. Independent money transfer companies will charge £5
for a transfer of this amount. Workers on the minimum wage will,
for understandable reasons, wish to seek the most cost effective
means of getting their money home. On the basis of price, the
choice of most ethnic minority and migrant workers is to turn
to the independent money transfer operators (of whom there are
about 2,000 outlets in the UK). Newly migrants may also prefer
to use a service which is run by members of the same ethnic group
as themselves, as for example Dahabshiil money transfer and Somalia.
Yet for companies in the independent money transfer
sector to operate, they are entirely reliant on the UK banking
system. Each money transfer operator is obliged to open a bank
accountthey are trapped, they have no other choice. The
entire independent money transfer market therefore operates at
the behest of the banks.
So, whilst the UK banks may not be too concerned
to cater to the money remittance market directly, they do have
an interest in scrutinising those money transfer companies which
they allow to operate. They may seek to close down those companies
which they consider to be too successful, and they can use entirely
arbitrary and often spurious grounds to do so (for example, supposed
failure to maintain a proper AML policy, although there is no
evidence that the money transfer industry is deficient here).
Independent money transfer companies have no right of appeal and
even no right to know why they have been denied a service.
The situation is made even worse by the relatively
small number of UK clearing banks which are willing to provide
services to money transmitters. If a bank such as HSBC decides
that it will no longer provide a service, the viability of the
UK money transmitters sector as a whole is placed at serious risk.
This is not a hypothetical situation. Specific instances of such
conduct can be provided.
Bearing this in mind, Chequepoint is trying
to co-ordinate the development of an Association of independent
money transfer companies which will represent the interests of
this group, disparate by reason of the wide range of ethnic minorities
it serves. Working with the UK government, we would like to make
representations to the banks to establish a code of conduct in
their dealings with the independent money transfer companies.
We want to highlight to government in the strongest
terms, that, for the on-going viability of the UK money transfer
market, it is essential that independent money transmitters are
seen as a special category; Chequepoint believes the banks should
be obliged to answer to an independent authority if they intend
to remove banking facilities from an independent money transfer
company.
In the event that the UK banks are not able
to provide the assurances which the independent money transfer
needs, we ask the UK government to use its influence to assist
in the setting up of alternative financial structures (examples
of which we would be happy to provide) to guarantee the future
of the independent UK money transfer industry. Chequepoint believe
that the relationship with the banks is one vital regulatory change
which the UK government should endorse now if it is to realise
the full potential of remittances to deliver much needed impact
in the developing world.
There are a number of other areas where additional
government scrutiny and action is required if the efficiency of
the money transfer sector is to encouraged and the potential of
remittances as a development aid is to be maximised. The key areas
for action include efforts to increase competition within the
discrete money transfer segment of the market by removing obstacles,
costs and difficulties. Among other things, this might include
looking at the monopoly which Moneygram presently has in relation
to money transfer at major UK post offices (3,000 branches). If
post offices are intended to provide services to the broader community,
tolerance of a monopoly money transfer provider cannot be acceptable.
In relation to regulation of the money transfer
industry, we recognise and welcome the principles of light touch
regulation employed by HM government in relation to anti-money
laundering compliance. We would support the extension of such
an approach to other countries in the EU (which perhaps the UK
government could lead). We further believe that for the purposes
of monitoring money transfer transactions, the government should
encourage money transfer companies to pool information on those
who are sending money transfers. This would enable for enhanced
scrutiny of transactions sent by the same sender through more
than one money transfer company. This may include setting a common
industry standard for software compatibility.
We also wish the committee to maximise its engagement
to make the most in development terms of remittances being sent
from the UK to Africa/Eastern Europe. For example, what about
a co-ordinated initiative across government to develop private-public
partnerships whereby the government could offer tax reliefs on
person to person remittances? Government could also match-fund
charitable donations made from remittances to education and health
projects in developing countries. Chequepoint believes that such
a UK government initiative will enhance the possibility of meeting
Millennium Development Goal targets. A summary of our suggestions
to the committee is included.
Suggestion 1: The International Development
Committee has already acknowledged the substantial size of the
world remittance market (World Bank estimate: USD$80 billion).
The UK government should take a lead in assembling information
on the size of outflows of remittances from the UK and should
encourage other European governments to do the same. Chequepoint
believes this data is a vital tool to enhance knowledge and understanding
of the substantial sums under discussion and their importance
in development terms.
Suggestion 2: Chequepoint asks that the
International Development Committee use its influence to ensure
an open, accessible, transparent and competitive UK banking sector.
At present, the attitude of the banks to ethnic minorities/recent
migrants (the unbanked) is ambivalent at best and hostile at worst.
If the true potential of money remittances as a development tool
is to be realized, the UK government (in partnership with independent
money transfer companies) must take an initiative with the banks
to agree a code of practice that provides an assurance the UK
banks will continue to work with the independent money transfer
sector and will not withhold services unreasonably. In the event
that the UK banks are not able to provide the assurances to the
independent money transfer sector which are required, we would
ask the UK government to use its influence to assist in the setting
up of alternative financial structures (examples of which we would
be happy to provide) to guarantee the future of the UK independent
money transfer industry.
Suggestion 3: We hope the International
Development Committee will recognise the contribution of the UK's
independent money transmitters to meeting the needs of money transfer
consumers. We hope the Committee will use its influence to help
us to set up an Association of independent money transfer transmitters
to represent this important, but (for reasons of ethnic diversity),
still disparate, group.
Suggestion 4: The International Development
Committee should give consideration as to how it can encourage
more competition in the UK money transfer market place, particularly
by breaking down the unnecessary monopolies that exist. All the
evidence is that more remittances will flow to developing countries
as a result.
Suggestion 5: We welcome the principles
of light touch regulation which is employed by the UK government
and feel it should be extended to other EU countries. We further
believe that for the purposes of monitoring money transfer transactions,
the government should encourage money transfer companies to pool
information, where possible. This would enable for enhanced scrutiny
of transactions sent by the same sender through more than one
money transfer company. To this end, we encourage the UK government
to set a common industry standard for software compatibility.
Suggestion 6: We hope that the International
Development Committee/UK government will work with the money transfer
industry to devise a private-public partnership to maximize the
potential of remittances and so help the government meet its Millennium
Development Goal targets. We hope the Committee will be advocates
of the benefits of this approach to HM Treasury.
CHEQUEPOINTA
LEADING FINANCIAL
SERVICES PROVIDER
First, some information about our company.
Chequepoint has been a leading international
financial services brand for 30 years. Chequepoint was founded
by Felix Grovit in England in 1974 where it pioneered the stand-alone
bureau de change business. This initial success in London enabled
the concept to be expanded into other key tourist destinations.
Chequepoint and its associates now operate in
over 70 countries and offer a wide range of financial and tourist
services including foreign currency, money transfer and travel
tours. The company has more than 100 wholly owned branches worldwide
and access to many other branch networks through correspondent
banking relationships.
In today's travel and remittance related market-place,
the Chequepoint brand has achieved significant global recognition.
This success has been built on the company's commitment to providing
customers with value, consistency of service and reliability.
Chequepoint has been offering a money transfer
service for ten years and (either through directly managed branches
or agents) now has a presence in a number of European countries:
UK, Ireland, Netherlands, Spain, Czech Republic and Sweden. In
the UK, Chequepoint offers the money transfer service through
25 directly managed branches in London and a network of 100 agents,
also mainly in London.
Over the last two years, the volume of money
transfers process by Chequepoint worldwide has risen by 250% and
Chequepoint expects to handle 1.25 billion Euros in volume of
transfers by the end of 2004. We pay out through 40,000 outlets
around the world. Chequepoint offers a service which meets the
needs of the majority migrant groups in the UK.
The countries to which we offer a service include:
Africa (Nigeria, Ghana, Sierra Leone, Zimbabwe, South Africa,
Morocco), Eastern Europe and the former Soviet Union (Poland,
Czech Republic, Romania, Bulgaria, Albania, Russia, Lithuania,
Latvia, Ukraine, Armenia, Georgia, Kyrgystan), South America (Colombia,
Ecuador, etc), the Southern Hemisphere (Australia, New Zealand).
In appendix a), we provide a summary of the distinct groups which
use Chequepoint money transfer.
Chequepoint is the third largest provider within
the discrete UK money transfer market. Our competitors include
Western Union and Moneygram as well as smaller, country specific
operators such as Dahabshiil Transfer Services. UK banks also
provide money transfer services. Chequepoint is aiming to play
a leading role within the independent money transfer sector, which
caters particularly to the ethnic minority/migrant worker (most
of whom are unbanked) segment of the UK remittance market. According
to HM Customs and Excise figures, there are 2,000 outlets operated
by independent money transfer companies in the UK.
1. RemittancesA vital tool for international
development
Chequepoint is certain that the impact of remittances
has for too long gone unnoticed by the UK and other European governments;
we believe also that remittances will play a crucial and expanding
role in the future as source of much needed funds in the developing
world. Remittances must be factored in as a key element in the
formulation of longer term European aid policy for developing
countries.
According to World Bank figures, the total volume
of remittances sent worldwide in 2002 was USD$80 billion. Sending
money home dwarfs the $USD16 billion of net government and bank
lending. In the western hemisphere alone, foreign earnings from
expatriate remittances now provide capital flows that have nearly
quadrupled in the last ten years.
Because remittances have been neglected as a
source of investment in developing countries, there are no figures
which give an indication of the annual outflows of remittance
funds from the UK and other European countries. In the context
of this information vacuum, we refer the committee to the experience
of remittance sent from the United States to South and Central
America and the Caribbean.
We believe that what has happened here is analogous
to what is presently happening in terms of remittances flowing
from Western Europe to Africa and Eastern Europe.
According to the Washington Inter-American Bank,
remittance payments from the US to Latin America and the Caribbean
topped £32 billion in 2002. Remittance payments from South
Americans working abroad matched the total amount of direct foreign
investment made by trans-nationals working in the region. In several
countries (Mexico, Jamaica, El Salvador, Nicaragua, etc) 10% of
the country's GDP is generated by foreign worker remittances.
It is estimated that in the coming decade Latin
America and the Caribbean may receive as much as $300 billion
dollars. Such flows would exceed by far the aid donated through
international organisations and government initiated programmes.
And it seems certain that the impact of remittances on the livelihood
of those who receive them is much more significant that the impact
of government directed aid, which may be lost or mis-applied by
the governments which administer them.
For many people in Western Europe, the key issue
of our times is the increasing numbers of migrants who are arriving
here from less developed countries in Africa and Eastern Europe.
Governments are all too aware of the social policy implications
and are trying to manage migration flows. In this context, it
clearly makes sense for European governments to re-double their
efforts to put in place policies which help to reduce the push
factors in less developed areas. A clear policy which harnesses
the remittance outflows from migrants already arrived must be
central to maximising financial investment in the developing world.
Although the US remains the biggest buyer of
Latin American labour, Europe is fast becoming a preferred destination
for workers seeking jobs abroad. According to the IADB, remittances
from the EU to Latin America topped $2 billion in 2002, more than
double their level in 2000.
At least 500,000 Latin Americansmainly
from Ecuador, Peru, Colombia and the Dominican Republicare
currently working in Spain, the source of almost half of Europe's
worker remittances to the Americas. Smaller, but fast-growing
communities of Peruvian and Argentine workers remitted nearly
$300 million from Italy.
Chequepoint notes that a comprehensive picture
of remittance outflows from the UK and European market to Africa
and Eastern Europe is not yet available. Chequepoint has already
had contact with HM Treasury, which is carrying out some much
needed work on the UK money remittance market. We believe it would
excellent news if the International Development Committee could
use its influence to highlight the importance of this initiative
from a development perspective.
Suggestion 1: The International Development
Committee has already acknowledged the substantial size of the
world remittance market (World Bank estimate: USD$80 billion).
The UK government should take a lead in assembling information
on the size of outflows of remittances from the UK and should
encourage other European governments to do the same. Chequepoint
believes this data is a vital tool to enhance knowledge and understanding
of the substantial sums under discussion and their importance
in development terms.
2. UK clearing banksA vital player
Chequepoint money transfer recognises the fundamental
importance of the UK clearing banks in the future development
of the UK money transfer industry. Based on a lack of objective
information, UK policy makers such as the International Development
Committee may have assumed that the UK banks are going a large
part of the way to meeting the needs of the ethnic minority and
migrant market which needs to send remittances home. Chequepoint
knows that this is not the case.
We are certain that the UK banks do not want
to meet the needs of ethnic minorities and newly arrived migrants,
the very group which most urgently needs to send money remittances
back to their countries of origin. From the start, the UK banks
make it difficult to open a bank account without ID and proof
of address, and these proofs of identity are not always readily
available to workers who may be regularly changing both jobs and
accommodation. Many ethnic minority and newly arrived workers
have been permanently relegated to the status of `unbanked'.
Even if this kind of worker does manage to open
a bank account, the banks do not offer a money transfer service
which meets their needs. Transfers are expensive (£20 minimum
fee is normal and rates of foreign currency exchange are poor),
slow (the transfer may take three weeks to arrive) and the network
of payout locations in the receiving country may be limited (for
example, cash payout may be unavailable or available only at extra
cost).
In an environment where the UK banks are, at
best, uninterested in transfer business, consumers are inevitable
going to turn to bespoke money transfer companies. Here they have
a choice between oligopolistic suppliers such as Western Union
and Moneygram and the independent money transmitters such as Chequepoint.
As the committee has already discovered, there
are some major differences between the oligopolistic suppliers
and the independents. Price is the crucial one; for a money transfer
of £100, WU will typically charge £14. Independent money
transfer companies will charge £5 for a transfer of this
amount. Workers on the minimum wage will, for understandable reasons,
wish to seek the most cost effective means of getting their money
home.
However, on the basis of price, the choice of
most ethnic minority and migrant workers is to turn to the independent
money transfer operators (of whom there are about 2,000 outlets
in the UK). Yet for companies in the independent money transfer
sector to operate, they are entirely reliant on the UK banking
system. Each money transfer operator is obliged to open a bank
accountthey are trapped, they have no other choice. The
entire independent money transfer market therefore operates at
the behest of the banks.
So, whilst the UK banks may not be too concerned
to cater to the money remittance market directly, they do have
an interest in scrutinising those money transfer companies which
they allow to operate. They may seek to close down those companies
which they consider to be too successful, and they can use entirely
arbitrary and often spurious grounds to do so. Independent money
transfer companies have no right of appeal and no right to know
why they have been denied a service.
The situation is made even worse by the relatively
small number of UK clearing banks which are willing to provide
services to money transmitters. If a bank such as HSBC decides
that it will no longer provide a service, the viability of the
UK money transmitters sector as a whole is placed at serious risk.
This is not a hypothetical situation. Specific instances of such
conduct can be provided.
Bearing this in mind, Chequepoint is trying
to co-ordinate the development of an Association of independent
money transfer companies which will represent the interests of
this disparate group. Working with the UK government, we would
like to make representations to the banks to establish a code
of conduct in their dealings with the independent money transfer
companies.
We want to highlight to government in the strongest
terms, that, for the on going viability of the UK money transfer
market, it is essential that independent money transmitters are
seen as a special category; Chequepoint believes the banks should
be obliged to answer to an independent authority if they intend
to remove banking facilities from an independent money transfer
company.
In the event that the UK banks are not able
to provide the assurances to the independent money transfer sector
which are required, we would ask the UK government to use its
influence to assist in the setting up of alternative financial
structures (examples of which we would be happy to provide) to
guarantee the future of the UK money transfer industry.
Suggestion 2: Chequepoint asks that the
International Development Committee use its influence to ensure
an open, accessible, transparent and competitive UK banking sector.
At present, the attitude of the banks to ethnic minorities/recent
migrants (the unbanked), is ambivalent at best and hostile at
worst. If the true potential of money remittances as a development
tool is to be realized, the UK government (in partnership with
independent money transfer companies) must take an initiative
with the banks to agree a code of practice that provides an assurance
the UK banks will continue to work with the independent money
transfer sector and will not withhold services unreasonably. In
the event that the UK banks are not able to provide the assurances
to the independent money transfer sector which are required, we
would ask the UK government to use its influence to assist in
the setting up of alternative financial structures (examples of
which we would be happy to provide) to guarantee the future of
the UK independent money transfer industry.
3. UK Independent Money Transmittersrecognising
and valuing their role
Chequepoint is an independent money transmitter
and, as such, is a member of a group of money transmitters which
is largely run by, and run for, the benefit of the many minority
ethnic and migrant workers in the UK. The independent money transfer
industry would like to work with the UK government and industry
regulators on a number of levels.
Some examples of possible shared objectives
might be:
to establish a code of practice with
the UK banks to ensure that they do not close down the accounts
of independent money transmitters in an arbitrary way and to ensure
they are fair and transparent in their relationship with our sector;
to increase awareness of the importance
of effective competition within the industry and its impact on
commission charges and the level of funds sent to developing countries;
to define a system for reporting
transaction volumes (perhaps on a quarterly basis?) to increase
data on the volume of transactions flowing through the UK money
transfer market;
to get feedback on suspicious money
transfer transactions which have been reported ;
to widen recognition among the general
public of the steps which money transfer companies have taken
to improve standards of anti-money laundering compliance;
to develop a wider awareness of the
positive role which money transmitters play in the global economy
in transferring financial resources from richer to poorer countries.
To maximise the potential of the independent
money transmitters segment, Chequepoint would like to take the
lead in setting up an independent money transmitters association,
to represent shared concerns. We have already spoken to HM Customs
and Excise to see their assistance and, as a member of the Money
Service Business Forum, we know that they are committed in principle
to seeing such an organisation come into being.
However, for reasons which we do not entirely
understand, their involvement has been stalled for a number of
months. We would welcome any assistance which the International
Development Committee could provide to move this process forward.
Suggestion 3: We hope the International
Development Committee will recognise the contribution of the UK's
independent money transmitters to meeting the needs of money transfer
consumers. We hope the Committee will use its influence to help
us to set up an Association of independent money transfer transmitters
to represent this important, but (for reasons of ethnic diversity)
still disparate, group.
4. Increasing competition in the money
transfer marketHow UK government can help. Chequepoint
believes that the remittance system will work better if obstacles,
costs and difficulties are removed.
Multiple factors affect the cost of money remittances.
To gain a clear understanding of these costs, it is first necessary
to understand the remittance process and the participants in the
remittance chain. The remittance participants include:
the sending customerin the
UK;
the money transfer companyprovides
the service for sending the money remittance (may include a directly
managed network of branches to take remittance orders over the
counter from customers);
the agent receives the remittance
order over the counter from the customer;
the correspondentdistributes
or pays the remittance to the intended beneficiary;
the beneficiaryusually a recipient
in another country.
The money transfer company must factor in the
costs of establishing and maintaining an infrastructure sufficient
to process remittances in a manner that complies with customer
expectations and regulatory requirements. There are several salient
infra-structural expenses that account for a substantial portion
of recurring expenses for money transfer companies. These include:
1. the cost of developing and updating technologies,
2. the cost of internal accounting for the
transaction (booking an Account Receivable from the Agent, and
Account Payable to the correspondent),
3. the cost of a collection platform to collect
the sterling amount of transfers and commissions paid in by the
customer to the Agent,
4. the cost of maintaining a viable Compliance
program,
5. the cost of maintaining a directly managed
branch network.
From the agent's perspective, the agent must
recoup operational costs, including overhead expenses such as
rent, payroll and others. In fact, rent and payroll contribute
a great deal to the Agent expense structure.
The money transfer company also carries a Point
of Sale cost (POS) that includes commission payments to agents
where senders pay in the transfer amount and to overseas correspondents
who deliver the money to the beneficiary. This cost also includes
up to four days in interest finance charges covering the interval
between the time the sender pays in the transfer amount and the
time the money transfer company collects it at his or her bank
account.
Also, the agent and the correspondent relationship
affect the actual costs paid by consumers. In turn, these costs
are affected by circumstances surrounding the private party negotiations
with both correspondents and agents, and the level of competition
present in each of the respective markets.
Lastly, the foreign exchange rates applicable
to each market greatly impact the costs paid by consumers. Those
rates are generally set by the foreign correspondent operating
in the countries where remittances are paid out and are generally
passed through to the consumer, after handling costs are deducted
by the money transfer company, the correspondent, or both.
As in any business or industry, the most effective
means to achieve costs reduction is to foster competition. Greater
competition would improve the service to the consumer with respect
to all three of the performance standards which the consumer cares
about: price, speed and security.
Chequepoint believes that one of the major weaknesses
of the UK money remittance arena is that the market is dominated
by two international companies which have to date created a quasi
cartel which, some would argue, has reduced competition and therefore
prevented commission charges finding their true level. Based on
HM Customs and Excise registrations for money service businesses,
Chequepoint estimates that there are 5,000 Western Union agents
and 3,500 Moneygram agents. By comparison, there are 2,000 outlets
operated by independent money transfer companies in the UK.
Customers therefore have the choice of using
Western Union, Moneygram, a number of smaller independent money
transfer operators or, perhaps, the UK clearing banks.
On small send amounts, for example, the effects
of market domination by the two oligopolistic players is particularly
marked. For sums up to £100, a charge of 14% is not uncommon.
By contrast, smaller independent operators, charge 5%. The foreign
exchange rates of independent money transfer companies are generally
10 to 20% more favourable to the consumer than those of the oligopolistic
large company. Some price comparisons are set out in appendices
b and c).
We believe that the UK government has scope,
relatively easy, to recognize and take action to reduce the monopoly
in one area where it has a controlling interest, the Post Office,
which, at present, has an exclusive agreement with Moneygram for
the purposes of money transfer. We hope the UK government will
investigate whether this exclusive agreement is in the interests
of the money transfer consumer.
Separately, we believe that attention should
be paid to paid to the way in which Western Union is exercising
a monopoly in requiring that it's high street agents should sign
an exclusivity agreement. We believe this is against the interests
of true competition.
We believe that an attempt to increase competition
is important, because evidence suggests that increasing competition
will have a great impact on the total volume of remittances received
in the developing country. As previously, there are no statistics
available from the European market place but, as evidence, we
can refer to research carried out by the Inter-American Development
Bank, which shows that reducing commission charges on a money
transfer transaction by 50% would increase the flow of remittances
from 7% to 10% of GDP in the receiving country.
Suggestion 4: The International Development
Committee should give consideration as to how it can encourage
more competition in the UK remittance market place, particularly
by breaking down the unnecessary monopolies that exist. All the
evidence is that more remittances will flow to developing countries
as a result.
5. Regulationsetting an industry standard
for money transfer software
Worldwide, the level of regulation has steadily
increased for this industry during the past 10 years, particularly
post 9/11. We understand that the UK government aims to maintain
a regulatory light touch, and we believe that this is in the best
interests of consumers and the long term development of the money
transfer sector. We would be pleased if the UK government would
take the lead in the EU in sponsoring a unifying law for the regulation
of the money transfer business, because there is a huge spectrum
of regulation at present.
We further believe that for the purposes of
monitoring money transfer transactions, the UK government should
encourage money transfer companies to pool information on those
who are sending money transfers. This would enable for enhanced
scrutiny of transactions sent by the same sender through more
than one money transfer company. This may include setting a common
industry standard for software compatibility.
In terms of a specified software package which
delivers a high level of compliance with regulatory requirements,
we would draw the attention of the committee to the Worldcash
software(patent application pending). Developed by Chequepoint
in house, the software achieves unprecedented advances in technology
while offering, for example, tracking and reporting of single
or multiple transactions to comply with regulatory needs. The
efficiency of the software has been independently audited by international
law firm Clifford Chance.
Chequepoint feels that the Worldcash software
sets a benchmark in terms of the technology which should be in
place to allow the processing of money transfer transactions.
We would welcome the chance to demonstrate the Worldcash software
to legislators, regulators and those involved in crime prevention.
Suggestion 5: We welcome the principles
of light touch regulation which is employed by the UK government
and feel it should be extended to other EU countries. We further
believe that for the purposes of monitoring money transfer transactions,
the government should encourage money transfer companies to pool
information, where possible. This would enable for enhanced scrutiny
of transactions sent by the same sender through more than one
money transfer company. To this end, we encourage the UK government
to set a common industry standard for software compatibility.
6. Money remittancesworking with Department
For International Development to maximise potential at the grassroots
in developing countries
We are pleased that the committee has recognized
the significant importance of remittances in terms of development.
The money which migrant workers send back to their families has
a great potential to enhance opportunities and improve quality
of life.
Chequepoint believes remittances have further
significant benefit which should be of interest to those concerned
with International Development. We believe that remittances have
within them the means to assist expatriate workers who feel a
commitment to the future of their homeland and who wish to make
a direct financial investment toward small infra-structural or
charitable projects.
As a company, Chequepoint has already taken
the lead in supporting charitable projects in the countries where
we work. For example, we are providing funds to an orphanage at
Manso Agoroyesum in the Ashanti region of Ghana. It is home to
33 orphans aged between 12 and 17 years under the care of Miss
Paulina Opei, a matron at St Martin Hospital. Additionally, we
are financially supporting Kwaku, a mentally disabled teenager
who lives in the village of Hwenampori near Bibiani in the Wiaso
district of Western Region. Kwaku's aged parents are crippled
and beg for alms at a local market. None of his four siblings
has ever set foot in a classroom.
As the next stage, we will allow migrant workers
sending money with Chequepoint to earmark a portion of an individual
transaction to a specially designated country fund (eg Sierre
Leone, Ghana) and even to a specific project in a particular geographic
location. The projects will be small enough for the migrant to
identify with the benefits generated for the local community and
might include schools, irrigation systems, health clinics, etc.
One of the key fundamentals for the success
of this initiative will be to identify suitable projects in the
target countries and also to ensure that these were promoted to
migrant workers in the contributing countries. We are certain
that DFID and its voluntary sector partners could help us to identify
suitable projects in developing countries.
And, of course, this initiative has the potential
to go much further. It would be excellent if DFID would be willing
to match-fund, in some way, the contributions made by expatriates.
It would be even more advantageous if HM Treasury could be persuaded
to see person to person money remittances as some sort of donation
and could be encouraged to make them tax-deductible. A full range
of options would arise from more detailed discussions with HM
Treasury.
Suggestion 6: We hope that the International
Development Committee/UK government will work with the money transfer
industry to devise a private-public partnership to maximize the
potential of remittances and so help the government meet its Millennium
Development Goal targets. We hope the Committee will be advocates
of the benefits of this approach to HM Treasury.
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