Recommendations
Multiple Exchange Rates
How do we deal with multiple exchange rates?
➀ Conduct an analysis of the regulatory environment and map access of different stakeholders to various exchange rates
Multiple exchange rates systems can be difficult to understand and navigate. It is useful to start mapping which local actors are bound to use which exchange rates. You can simply start by asking your current partners what are their practices. When you convert foreign currency into local currency, you have to use a specific, official exchange rate. However, other actors may be subject to different, more favourable exchange rate regulations. It is important to map the entire user journey for each delivery or payment mechanism to understand all the different options and possibel moments for converting foreign currency (provided by our donors) into local currency (received by the final recipient). This is likely to influence your choice of FSP and delivery mechanisms, and inform the feasibility of various programmatic choices. It will also determine whether there is scope for the aid community to advocate collectively towards authorities for preferential exchange rates for humanitarian assistance.
With additional restrictions to transactions and payments due to the current crisis, consider having a lawyer available on retainer to answer some more complex questions related to legality that may come up. For example, how do applicable exchange rates differ depending on the type of organisations in the transaction? What scope is there for advocacy to the Central Bank for a preferential rate for humanitarian organisations? Can commercial banks set their own exchange rates? Do these rates differ between banks and other FSPs? Do rates differ between transfer modalities (e.g., bank transfers, mobile money, cash notes)?
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➁ Consider that you may need to use different exchange rates for accurate financial reporting & accounting and ensure that all your documents that include price points or calculations are clearly dated
A price is not just a value in a given currency, it is a value at a given point in time. In the current context of currency depreciation, you want to restate all your financial statement in terms of their current real value. What matters for accurate financial management, when comparing planned versus actual disbursements and commitments at a given point in time, is not the ‘numbers’ that were written in past documents (for example the numbers written in budgets or BoQs). It is the current value of past or future price points across currencies. In other words, it doesn’t matter what the number value of your budget was at the time of proposal writing. What matters is always its actual current value (aka. at a given point in time what you can actually buy with what is left in it).
You want to be able to estimate what is the current value of your budget, and for that you have to ‘actualise’ your price points (the numbers that you have used at different points in time for calculations). All budgets, BoQs and payments should be actualised. To do so, it is easier to use a reference point that doesn’t vary too much from one period to another, that is to say a hard currency like the USD. But it can also be a different hard currency depending on what is practical. You want your accounting to be as much as possible in a format that is coherent with the donors reporting requirements.
In general, your programmatic decisions (for example, deciding the value of a transfer) will be mostly based on the market exchange rate, which is the value that is relevant to the participants in our programs. But you might need to also consider the point at which the currency is converted in your delivery mechanism and the exchange rates that the actor that takes on the exchange risk will have to use. This means that two different exchange rates may actually need to enter in your budget calculations at different points in time of your delivery process. Mapping your delivery mechanism helps with clarifying which rate to use for which calculation.
In NRC, we also have internal reporting systems for exchange rates and transactions. Those systems are designed among other things to average exchange rates over time to absorb currency volatility over the entire grant cycles and across countries. But they are not well adapted to contexts where exchange rates are varying significantly within a month. So you should use a slightly different approach to the reporting of exchange rates in Agresso than your general financial management. Agresso will also not allow you to report consistently the exchange rates that are applicable for each transaction according to your donors’ guidelines. Make sure you get rid of your balances at the end of the month to avoid remainders at bad exchange rates. You can also report weekly average to account for the fact that the calculation takes time to adjust. In any case, you should start engaging a discussion with NRC global finance early on around how to handle these rigidities of the system, and in particular the use of documented market rates rather than official rates as reference points in the system. (See also our recommendations about Depreciation on outstanding balances).
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➂ Advocate for coordination between agencies on implementation guidelines and joint negotiations for preferential exchange rates
The pegging of transfer values for cash transfers is a general best practice in contexts of currency depreciation. But you should also ensure that this is the practice pushed through coordination structures, such as the CWG. Even if all agencies base the value of their transfers on USD, if each agency end up distributing slightly different nominal amounts to their recipients within adjacent communities, it has the potential to cause inequities, tensions, and security issues. Therefore, it is important that there is agreement on using a single source for the value of the market exchange rate across agencies as well.
Depending on the regulatory framework, it may also be possible to successfully advocate with the government for a preferential rate for humanitarian actors and/or to negotiate preferential fees with FSPs to offset exchange losses. For example, it may be possible for transaction costs to be charged not per transaction but in bulk, for example once at the end of the month. All these negotiations are likely to be more effective if conducted jointly across organizations, i.e., through common tendering (but not necessarily contracting) processes. Otherwise different agencies will be negotiating different rates with banks e.g. UN or International NGOs might be able to negotiate a better rates as compared to National NGOs, leading to a number of issues for national organizations. Similarly, organizations with bigger portfolio would also be able to negotiate better than smaller ones, which would undermine the efforts of coordination structures to advocate for harmonized services charges for all actors.
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✚ Make sure you have also considered and adequately put in place the actions in the box below, which are meant to prepare you for high inflation contexts in the first place!
How do we prepare for multiple exchange rates?
There is not much you can do in anticipation to prepare for situations where you have to deal with multiple exchange rates.
➊ Start documenting consistently the market exchange rate
It is useful to document on a weekly basis the value of the market exchange rate to facilitate future conversations with Head Office and / or with your donors regarding which value to use as a reference in reporting systems.
In your communications, you also don’t necessarily need to talk about the 'black' market rate. You can simply distinguish between the market rate and the official rate, especially when discussing with stakeholders outside of your country of operation. In countries where exchange rates are floating, the ‘black’ market rate refers to rates used for commerce of illegal items. By contrast, in contexts of fixed and multiple exchange rate, the market rate is the 'de facto' rate in use by a majority of local actors and for a majority of transactions.
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➋ Know your donors and their regulations in terms of managing exchange gains and losses
In the context of depreciation in which there is a discrepancy between an official rate and the market rate, exchange gains and losses are likely to occur. Donors also have their own specific requirements regarding which exchange rate to apply for each transaction and at what point in time. They also often have specifications about how to proceed with exchange gains and loss. It is important to familiarise yourself with the rules of your main donors.
You can then possibly negotiate with your donors for some flexibility about what to do with possible underspent accumulated from exchange gains. Some donors for example would agree for you to be allowed to push it to programmatic budget lines if discussed in advance. Others have agreed in the past to extending a capacity for disbursement of these funds between the operational end date of a project and the budget closing end date, to be used as contingency funds. You can also try to ask for flexibility to be applicable not only by budget line, but also by budget category. This would allow for adequate budget reallocations based on the exchange situation.
It is advisable to also start negotiating in advance with donors for greater allocation flexibility, rather than at the moment that you need to use the flexibility which is often late in the implementation cycle. Donors are also more likely to be receptive to such adaptations if they are presented as 'exceptional and temporary' measures.
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