Download what should a financial market dealer licence

A STRUCTURAL REVIEW OF
CAPITAL MARKET OPERATORS
INTRODUCTION
Let me first start by commending the Securities & Exchange
Commission and the Central Bank of Nigeria under the vision 2020 work
done in time passed under the Money & Capital Markets Committee in
its bold accomplishment of ending the concept of universal banking and
hence, the final separation of commercial and merchant/investment
banking.
However, this major accomplishment has led to a major financial
exclusion of the key players in this very important intermediation sector
of the economy
FMD DISCUSSION PAPER
2
We are not investment banks – we call ourselves that
but, we are not.
1.
There are two types of intermediation;
•
Bank based intermediation and
•
Capital market based intermediation –
•
In Nigeria, only bank based intermediation works - Our inability to
provide a full platter of services to our clients and fulfill our role as
intermediaries is a testimony…
2. Why? capital market based intermediation is cut out of the wholesale
funding markets hence, no ability to fund any part of the capital market
business, it has no repo markets for liquidity, and therefore (except for
commercial bank treasuries) generally has inefficient sales & trading
operations or maturity transformation activities.
3. There is therefore no real added value from a liquidity stand point, as the
equity trading business is generally also mainly brokerage hence, market
making which is meant to significantly increase liquidity is highly inefficient.
FMD DISCUSSION PAPER
3
We are not investment banks – we call ourselves
that but, we are not….cont’d
Even from the corporate finance origination stand point;
• Underwriting financing (if you can get it) is
extremely high,
• No ability to execute bought deals for sell down,
• No real leverage at the client’s table - lack of
balance sheet generally (application to stand-alone
institutions).
FMD DISCUSSION PAPER
4
We are not investment banks – we call ourselves
that but, we are not…..cont’d
The question is:
• How long can these businesses continue to mal-function
due to their inability to operate as intermediaries across
the financial markets with No wholesale funding access?
• As is, capital market operators currently operate in “silos”
with no access to the money markets and therefore totally
cut off from the life blood or base liquidity of all financial
markets.
FMD DISCUSSION PAPER
5
NIGERIA AND MALAYSIA COMPARISON
FMD DISCUSSION PAPER
6
Malaysia and Nigeria – A factual Comparison of capital requirements - 1
RM
Current GDP/Capital
2012
Investment Bank
500,000,000.00
USD 10,432.06
0.31
Universal Broker
100,000,000.00
USD 10,432.06
Stockbroker (Broker/Market Maker )
20,000,000.00
Issuing House
Malaysian Bank Capital Requirements
RM
NGN
$155,000,000.00
74,529,862.75
3,741,458,973.39
0.31
$31,000,000.00
14,905,972.55
748,291,794.68
USD 10,432.06
0.31
$6,200,000.00
2,981,194.51
149,658,358.94
2,000,000.00
USD 10,432.06
0.31
$620,000.00
298,119.45
14,965,835.89
NGN
Current GDP/Capital
2012
NGN
Investment Bank
15,000,000,000.00
$1,555.00
3,741,458,973.39
4.01x
Universal Broker
1,300,000,000.00
$1,555.00
748,291,794.68
1.74x
FMD DISCUSSION PAPER
7
Malaysia and Nigeria – A factual Comparison of capital requirements - 2
Malaysian Bank Capital Requirements
Domestic Bank
Current GDP/Capital
2012
RM
2,000,000,000.00
0.31
$620,000,000.00
$10,432.06
Investment Bank
500,000,000.00
0.31
$155,000,000.00
$10,432.06
Universal Broker (Marker Maker)
100,000,000.00
0.31
$31,000,000.00
$10,432.06
20,000,000.00
0.31
$6,200,000.00
$10,432.06
Issuing House
2,000,000.00
0.31
$620,000.00
$10,432.06
Nigerian Banks Capital Requirments
NGN
Stockbroker (Broker/Dealer)
Current GDP/Capital
2012
GDP/ Capital required
for current capital
Capital required at
current GDP levels
In Local currency
Domestic Bank National
25,000,000,000.00
165
$151,515,151.52
$1,555.36
$2,549.38
$92,438,425.39
15,252,340,189.76
1.64x
Investment Bank
15,000,000,000.00
165
$90,909,090.91
$1,555.36
$6,118.51
$23,109,606.35
3,813,085,047.44
3.93x
Domestic Islamic Bank (National)
10,000,000,000.00
165
$60,606,060.61
$1,555.36
$1,019.75
$92,438,425.39
15,252,340,189.76
0.66x
1,300,000,000.00
165
$7,878,787.88
$1,555.36
$2,651.35
$4,621,921.27
762,617,009.49
1.70x
Market Maker (Fixed Income & Equities)+Broker Dealer
FMD DISCUSSION PAPER
8
Malaysia and Nigeria – A factual Comparison of capital requirements - 3
Malaysian Bank Capital Requirements
RM
Current GDP/Capital
2005
RM
NGN
Investment Bank
500,000,000.00
$5,553.94
0.38
$190,000,000.00
139,990,709.30
7,027,646,049.11
Universal Broker
100,000,000.00
$5,553.94
0.38
$38,000,000.00
27,998,141.86
1,405,529,209.82
20,000,000.00
$5,553.94
0.38
$7,600,000.00
5,599,628.37
281,105,841.96
2,000,000.00
$5,553.94
0.38
$760,000.00
559,962.84
28,110,584.20
Stockbroker (Broker/Market Maker )
Issuing House
Current GDP/Capital
2012
NGN
Investment Bank
Market Maker (Fixed Income & Equities)+Broker Dealer
NGN
15,000,000,000.00
$1,555.00
7,027,646,049.11
2.13x
1,300,000,000.00
$1,555.00
1,405,529,209.82
0.92x
FMD DISCUSSION PAPER
9
Malaysia and Nigeria – A Comparison –Key Takeaways
• The new SEC capital requirements are adequate
for the current size of the economy
`
BUT
• The capital requirements for a Merchant Bank by
CBN is clearly in excess for the size of our
economy
FMD DISCUSSION PAPER
10
Malaysia and Nigeria – A Comparison – Key take aways..cont’d
• Best case example, Commercial Banks in 2004 where asked to increase
capital from N2bn to N25bn to become universal banks – this was
severely frowned upon by the market as it was a 12.5x increase in
capital
• An issuing House/Financial Adviser, Underwriter, Asset Management
License from SEC was until recently N270m – (their combined work
however constitutes c50% of the current Merchant Banking License
issued by CBN)
• Hence on September 7th 2010 when the Merchant Banking regulations
were signed by the CBN, capital market operators wising to convert
(who were not officially made aware of this licence that constitute c50%
of the allowable business) were expected to increase from N270m to
N15bn - a Whooping 55.6x INCREASE IN CAPITAL.
FMD DISCUSSION PAPER
11
Approach to our Operations and Regulations
• This has not been possible. As to date (26th of March, 2014) there remains
only one fully owned Nigerian merchant bank after c4years!!
• This means we require a new way or approach to our operations and
markets – not in regulatory and operational silos but across the full curve
from the shortest end to the longest (permanent capital or equities)…see
fig 2
• We therefore require a new paradigm shift in thinking and make some
major changes to the way we operate and regulate our markets
• The first being - like other liquid markets (Malaysia included)……..
….THE CENTRAL BANK MUST JOINTLY WORK WITH THE
SECURITIES EXCHANGE TO GROW AND REQULATE THE
INDUSTRY - WHY?
FMD DISCUSSION PAPER
12
Addressing the NEED for a WHOLESALE FUNDING
MARKET
• ALL IMPORTANT LIQUIDITY
• “The tri-party repo market is the most important source of funding for
investment banks and securities broker-dealers as they can obtain shortterm liquidity to finance their securities portfolios. Liquidity providers
are usually money markets, investment funds, asset managers or public
authorities with surplus liquidity” - Deutsche Bundesbank Monthly
Report Dec 2013.
• TODAY in Nigeria 2014 – this resides ONLY at the short end of the
curve (Money and Interbank Markets plus the discount window – Lender
of last resort – comfort to all investors)
• No Broker/Dealer/Market Maker has access to this and therefore the
business is severely illiquid, fragile, small, viewed as high risk and can
NEVER grow into real institutions
FMD DISCUSSION PAPER
13
Possible Suggestions
• We therefore suggest one or a combination of the following options :1.
2.
3.
Adopt the Malaysian model of a Universal Broker
A Financial Market Dealer licence that will support financial market
intermediation to act as a stop-gap measure to operators becoming a full
fledged Merchant Bank (jointly regulated by SEC and CBN)
A two-tier Merchant Bank Licence
• International Merchant Bank License
• National Merchant Bank License
• Each position is discussed in-turn in exposition to follow...
FMD DISCUSSION PAPER
14
BACKGROUND TO OUR MARKET
The Nigerian capital market operates in silos of its own, cut
off from the rest of the financial markets. We currently have
a market that looks as follows:Fig 1
Money Markets
DMB
Short Term Capital
D.H
D.M.B
Bond Markets
D.H
Medium Term Capital
NBFI* brokers I.H
NBFI
Equity Markets
Broker/Dealer
Permanent Capital
Issuing houses
FMD DISCUSSION PAPER
15
BACKGROUND
If we plot these markets in risk/return/duration space, we
should get:Fig 2
Risk Premium
Risk Premium
Risk Premium
Money Markets
Bond Markets
Equity Markets
FMD DISCUSSION PAPER
16
BACKGROUND
In effect, for the same credit risk, the cost of shorter term money
should by all definition be cheaper than longer term capital or
permanent capital. “A normal yield curve”
So, whose responsibility is it to price the entire financial markets
as depicted in fig 2 appropriately?
Different parts of the market are concentrated in silos and there is
no one institution that can design/create, price and trade across
instruments across the curve
Our competitive ability should be to fully serve our clients, and
market across the curve and hence have a real impact on our
economy
FMD DISCUSSION PAPER
17
BACKGROUND
How do you promote innovation across markets where each
participant is confined to only one part of the market? More
importantly, how do you efficiently price across all asset
classes in one continuous price curve, intermediating across
all markets?
We believe we require a major shift in our thinking to allow
an institution intermediate the short, medium and long term
securities across the entire financial markets.
This is the only way the deficient issues mentioned above
can be addressed and the market begin to see real growth
FMD DISCUSSION PAPER
18
THE IMPORTANCE OF INTERMEDIATION
 Users of financial intermediation will include governments, large
institutions, medium sized corporations, institutions, high net
worth individuals; in addition to short, medium and long
term investors
 Financial intermediation firms will generally advise
companies on buying and selling businesses and assist
them in managing risks
 They will generally work with businesses, local, state and
national governments to finance their operations through
debt and equity offerings
FMD DISCUSSION PAPER
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THE IMPORTANCE OF INTERMEDIATION
 They will buy and sell equities, bonds, currencies,
commodities primarily to facilitate transactions by their
clients in all of the key sectors of the financial markets
 They will manage assets for institutions, including mutual
funds, pensions and foundations as well as for individuals
 They may also invest capital together with their clients in
growing businesses which help to create jobs
 Finally and importantly, they will create and manage
liquidity across the financial markets by acting as dealers
/ market makers of traded securities
FMD DISCUSSION PAPER
20
OPTION 1 – UNIVERSAL SECURITIES BROKER
FMD DISCUSSION PAPER
21
THE CASE FOR A UNIVERSAL SECURITIES DEALER
This is defined herein as a firm that is SEC and NSE
approved and regulated:Capital
1. Fixed Income Market Maker –
N500m
2. Equities Market Maker –
N500m
3. Broker /Dealer –
N300m
N1,300m
This level of capital for our market size MUST give access to
the wholesale funding market
FMD DISCUSSION PAPER
22
THE CASE FOR A ADOPTING THE MALAYSIAN UNIVERSAL
BROKER MODEL
In Malaysia, the Universal Broker - means a brokerage firm
that has merged or acquired at least 3 other brokerage firms (To
meet Capital requirements) and has satisfied all conditions and
requirements stipulated by the Securities Commission under the
Policy frame work for the brokerage industry consolidation
Minimum Paid-up capital of RM100m ($31m).
Minimum shareholders funds of RM100m ($31m) to be maintained at all
times
Minimum Capital Adequacy ratio of 1.2x
NOTE:
these parameters operate in economies c4.5x the size of the Nigerian economy and we can be
clever by scaling the requirements to suite our market size – this was previously depicted
FMD DISCUSSION PAPER
23
THE CASE FOR A ADOPTING THE MALAYSIAN UNIVERSAL
BROKER MODEL
The Universal Broker - Why is this important?
As part of measures to strengthen capacity &
competitiveness of universal brokers, brokers that meet the
eligibility criteria were allowed to access the interbank
market to undertake borrowing or lending
•
•
•
•
•
Minimum shareholders funds of RM100m
Strong capital position as measured by capital adequacy ratio (CAR) imposed
by the Malaysian bursa (stock exchange)
Satisfactory conduct of current credit facilities obtained from banking
institutions
Compliance with prudential and financial regulators imposed by the
securities exchange and stock exchange
Limit on aggregate interbank borrowings not to exceed 2x shareholder funds
unimpaired by losses
FMD DISCUSSION PAPER
24
THE CASE FOR A ADOPTING THE MALAYSIAN UNIVERSAL
BROKER MODEL
•
•
A robust and effective risk management framework to identidy, measure and
monitor risks and
A sound liquidity management framework that encompass strategies to
manage funds, ability to match near and short term liquidity requirements
and maintain sufficient credit lines, liquefiable assets in managing potential
liquidity shortfalls
Universal brokers are allowed to borrow securities from the central bank via repo
arrangements to enhance their securities broking activity and will be subject to
examination by the central bank and the securities commission where
appropriate.
FMD DISCUSSION PAPER
25
THE CASE FOR A UNIVERSAL SECURITIES DEALER
Graphical depiction of how a Universal Broker/Dealer –
Market Maker with say N1.5bn in capital (regulated by SEC
and CBN) can now provide liquidity due to its ability to fund
Fig 3
Purchase Securities
INTERMEDIATION
BUYERS
FMD DISCUSSION PAPER
Sell Securities
SELLERS
26
OPTION 2 – A FINANCIAL DEALER LICENCE
FMD DISCUSSION PAPER
27
THE CASE FOR A FINANCIAL MARKET DEALER LICENCE
A Financial Market Dealer (FMD) licence will provide a very
essential intermediation function by ensuring that our
financial markets across the curve (see fig 2) remain liquid.
This will be achieved where such licence and skills give the
holder the ability to fund and trade securities across the
financial markets from say a 7day note issued under a
commercial paper program or medium term note program to
permanent capital (equities).
FMD DISCUSSION PAPER
28
THE CASE FOR A FINANCIAL MARKET DEALER LICENCE
Going forward, with such a licence, we would expect
financial market dealers to provide liquidity and begin to
create new products for companies, institutions and
governments like interest rate swaps, currency swaps etc. for
improved risk management for the institutions and the
financial markets
FMD DISCUSSION PAPER
29
THE CASE FOR A FINANCIAL MARKET DEALER LICENCE
Graphical depiction of how a combined Issuing House and
Broker Dealer (regulated by SEC) and a FMD (regulated by
CBN) can now perform
Fig 3
Distribute Securities
Originate Securities
BORROWERS
FMD DISCUSSION PAPER
Trade Securities
INVESTORS
30
THE CASE FOR A FINANCIAL MARKET DEALER LICENCE
The additional licence should encourage a new paradigm
shift to allow for the combined entity to have an evenly
spread business model as depicted above.
The financial market dealer/Issuing house/Broker/Dealer
will therefore be able to function across the entire sphere of
the market as shown in fig 2
FMD DISCUSSION PAPER
31
ADVANTAGES OF THE PROPOSED MODEL TO REGULATORS
FMD Regulated by CBN
Issuing Houses
1Jointly
Underwriting
Financial
Advisory
Fixed Income
Broker/Dealer
PDMM/MM
Fund Portfolio
Management
Equity/MM1
Commodity
Dealers
Regulated By SEC
Fig 4
In – Time
regulated by SEC/NSE with oversight from the CBN
FMD DISCUSSION PAPER
32
ADVANTAGES OF THE PROPOSED MODEL TO REGULATORS
 Allows for each regulator to still focus on their core areas
of competence whilst being able to have an oversight on
the other areas of this important financial market
intermediary
 This leads to greater scrutiny and therefore less
probability of systemic risk to the system
 Allows for sharing of information, stricter regulation as
these firms will be jointly regulated with formalised
shared information for all procedures
 It also allows for the regulators to grow with these
institutions learning from lessons where capital is still
relatively small and risks are very manageable.
FMD DISCUSSION PAPER
33
ADVANTAGES TO MARKET
 Wider product coverage
 Origination, distribution and trading of securities should
become seamless
 Product development, increased knowledge on pricing
across the financial markets leading to deeper liquidity in
all markets
 Deeper liquidity reduces costs to the end user
 Creation of new jobs as sales and trading operations
become much bigger, more sophisticated and less risky to
manage due to significantly improved information
technology infrastructure and risk management systems.
FMD DISCUSSION PAPER
34
ADVANTAGES TO MARKET
 The users of financial intermediaries will strongly benefit
from lower costs across all markets, efficient pricing, and
an ability for firms to now create products for their clients
across the entire sphere of the financial markets
 To build resilience in the domestic financial markets to
withstand shocks by increased participants in the
financial intermediation market
FMD DISCUSSION PAPER
35
WHAT SHOULD A FINANCIAL MARKET DEALER
LICENCE HOLDER BE ALLOWED TO DO?
SOURCE OF FUNDS  Equity - paid up capital plus reserves
Liabilities
 Call Money and short term borrowings
 A FMD that is short of funds must be able to:
•
•
•
Obtain from the CBN an overnight advance against acceptable
collateral
Sell short term AAA rated assets to the CBN for the CBN to provide
rediscounting facilities for treasury and other eligible securities
Enter into repurchase transactions with CBN using eligible securities
 Have a CBN account
 Access to the interbank market (as discount houses have for
alternative short-term funding purposes)
FMD DISCUSSION PAPER
36
WHAT SHOULD A FINANCIAL MARKET DEALER LICENCE HOLDER BE ALLOWED TO DO?
SOURCE OF FUNDS -
Types of Assets
The short to medium term nature of its funding sources and
liabilities should require that the assets it funds are generally
also short – medium term assets. (Asset/liability matching)
The aim of such combined entities is to create and sell down
good assets to real money managers – pension funds and
other asset managers.
FMD DISCUSSION PAPER
37
WHAT SHOULD A FINANCIAL MARKET DEALER LICENCE HOLDER BE ALLOWED TO DO?
SOURCE OF FUNDS -
Therefore the assets it can hold should be as follows:











Treasury Bills
Treasury Certificates
Negotiable certificates of deposits
Bankers Acceptance
Commercial Paper
Asset Backed Commercial Paper
Asset Backed and Mortgage Backed Securities
Corporate Bonds and Notes
Federal Government Bonds
State and Municipal Bonds
Equities for NOT more than 5 days (Trading Purposes ONLY)
Any other securities that may be from time to time approved by the
CBN/SEC/NSE.
FMD DISCUSSION PAPER
38
PROPOSED CAPITAL COMPUTATION
Beginning in 2008, many observers remarked that the 2004 change to the
United States SEC's net capital rule permitted investment banks to increase
their leverage and this played a central role in the financial crisis of 2007-2009.
This position appears to have been first described by Lee A. Pickard, Director
of the SEC's Division of Market Regulation (the former name of the current
Division of Trading and Markets) at the time the SEC's uniform net capital
rule was adopted in 1975. In an August 8, 2008, commentary, Mr. Pickard
wrote that before the 2004 rule change, broker-dealers were limited in the
amount of debt they could incur, to a ratio of about 12 times their net capital,
but that they operated at significantly lower ratios.
FMD DISCUSSION PAPER
39
PROPOSED CAPITAL COMPUTATION
He concluded that, if they had been subject to the net capital rule as it existed
before the 2004 rule change, broker-dealers would not have been able to incur
their high debt levels without first having increased their capital bases.[10]
In what became a widely cited September 18, 2008, New York Sun article (the
"2008 NY Sun Article"), Mr. Pickard was quoted as stating the SEC's 2004
rule change was the primary reason large losses were incurred at investment
banks.
FMD DISCUSSION PAPER
40
PROPOSED CAPITAL COMPUTATION
In late 2008 and early 2009, prominent scholars such as Alan Blinder, John
Coffee, Niall Ferguson, and Joseph Stiglitz explained (1) the old net capital rule
limited investment bank leverage (defined as the ratio of debt to equity) to 12 (or
15) to 1 and (2) following the 2004 rule change, which relaxed or eliminated
this restriction, investment bank leverage increased dramatically to 30 and even
40 to 1 or more.
The investment bank leverage cited by these scholars was the leverage reported by
the Consolidated Supervised Entity Holding Companies in their financial
repoPrts filed with the SEC.[13]
FMD DISCUSSION PAPER
41
PROPOSED CAPITAL COMPUTATION

As noted from the last financial crisis, having excessive capital
does not make an institution immune to an insolvency,
bankruptcy or liquidity crisis

We therefore advocate for a rather medium level of capital
requirement as a head start but with a very strict and much
improved monitoring/reporting/regulation on the amount of
leverage currently applied by the firm, the assets, tenors, funding,
governance structure, market values, asset concentrations etc

Firms should be mandated to have very robust risk management
systems and high level risk management personnel.
FMD DISCUSSION PAPER
42
PROPOSED CAPITAL COMPUTATION
 We propose that the FMD licence gave a capital of
N2.0bn but, with a maximum leverage of 1:15x.
We propose a strict capital / leverage / asset /
funding monitoring by both the CBN and SEC
FMD DISCUSSION PAPER
43
Credit rating
Maximum
Leverage
Maximum Assets
30,000,000,000.00
Est. Returns
AAA
12,000,000,000.00
12.75%
40.00%
AA
7,200,000,000.00
13.50%
24.00%
A
6,000,000,000.00
14.50%
20.00%
BBB
3,000,000,000.00
16.00%
10.00%
N/R
1,800,000,000.00
20.00%
6.00%
2,000,000,000.00
14.01%
100.00%
Capital
Credit protection
<BBB
Credit protection
=>BBB
Credit rating
Mainly Equities
Maximum buckets
4,212,000,000.00
Funding Costs
10.00%
3,000,000,000.00
Net Spread( turnover not included
4.04%
1,212,000,000.00
MD
CEO:
Loss % of
capital
MD CEO:
Number of
Days held
111.10%
7.09%
Single Obligor
Limit
Single Obligator Amount
Capital protection
Coverage
AAA
25.00%
3,000,000,000.00
2,000,000,000.00
67%
AA
20.00%
1,440,000,000.00
2,000,000,000.00
139%
A
15.00%
900,000,000.00
2,000,000,000.00
222%
BBB
12.50%
375,000,000.00
2,000,000,000.00
533%
N/R
2.50%
45,000,000.00
2,000,000,000.00
4444%
FMD DISCUSSION PAPER
MD CEO:
Maximum
Loss per
day
10%
5 18,427,950.00
0.92%
44
OTHER REASONS FOR A LOWER CAPITAL THRESHOLD





Non deposit taking institution
Does not trade currencies
Cannot advance loans as risk assets (illiquidity)
No trade finance business
Purely institutional funding.
FMD DISCUSSION PAPER
45
OTHER REASONS FOR A LOWER CAPITAL THRESHOLD
FINALLY,

The financial market dealer licence is intended to serve as a
stepping stone for issuing houses, underwriters, broker/dealers,
market makers etc to one day become fully fledged Merchant
Bank

This also allows for financial inclusion from the institutional level

It also allows for the regulators to grow with these institutions
learning from lessons where capital is still relatively small and
risks are very manageable.
FMD DISCUSSION PAPER
46
OPTION 3 – A TWO TIER MERCHANT BANKING LICENSE
FMD DISCUSSION PAPER
47
THE CASE FOR A CREATING A TWO TIER MERCHANT BANK STRUCTURE
A two tier structure is proposed as follows:
1. International Merchant Banking License
• Can bid for international issues
government
• Can have operations offshore
for
the
2. National Merchant Banking License
• Can only operate within Nigeria
• Cannot bid for international issues
FMD DISCUSSION PAPER
48
OTHER REASONS FOR A LOWER CAPITAL THRESHOLD
FINALLY,

Financial intermediation remains a very crucial part of the
workings of any financial market. Moreso, where the
development of infrastructure in the economy is weak and
requires a multitude of funding propositions or its middle class
requires a viable primary and secondary mortgage markets to
function relying on liquid financial markets
FMD DISCUSSION PAPER
49
OTHER REASONS FOR A LOWER CAPITAL THRESHOLD
FINALLY,

We believe the case to have new institutions that are jointly
regulated by SEC and CBN that can originate, distribute and
trade all asset classes across the financial market spectrum is long
over-due.

The process for achieving this has little or no hitch to current
regulatory practices and will be seen by domestic and foreign
observers of the Nigerian financial markets as a major step in
the right direction
FMD DISCUSSION PAPER
50
OTHER REASONS FOR A LOWER CAPITAL THRESHOLD
FINALLY,

We have shown the model to be sustainably profitable and that
the risks associated can be strictly contained and managed

We therefore believe that the newly created Universal Brokers or
originators (Issuing Houses), distributors and traders (Financial
Market Dealers) or National Merchant Banks will become major
engines of growth for the development of our financial markets
going forward
FMD DISCUSSION PAPER
51
THANK YOU
AND
GOD BLESS THE FEDERAL
REPUBLIC OF NIGERIA.