If there was a turning point for Mongolia’s economy, it happened on the last day of May 2017.
The frontier market, battered by low commodity prices, was locked into a state of crisis. Public debt had tripled in the six years to the end of 2016, to $8.5 billion, or 85% of GDP. Per-capita income was down for the third year in a row, the deficit had spiked to 17% of output and foreign reserves had dipped below $1 billion for the first time since the global financial crisis.
Lawmakers in the capital Ulaan Bataar had been nervously eyeing a date with destiny. The Development Bank of Mongolia (DBM), a cash-strapped policy lender, faced repayment on a $580 million bond, due in March. Equating non-payment to a sovereign default, Moody’s placed Mongolia on review for a downgrade.
John Bell, Khan Bank
“At the time, the market wasn’t sure where that payment would come from,” says John Bell, chief executive of Khan Bank, Mongolia’s largest retail lender.In the end, salvation came, as it so often has in the past, from Washington.
In May, the IMF signed off on a three-year, $434 million loan, part of a $5.5 billion economic stabilization package that included soft loans from Japan and Korea, fiscal and project support from the World Bank and the Asian Development Bank, and a Rmb15 billion ($2.3 billion) swap line with the People’s Bank of China. It also allowed DBM to swap its debt for new sovereign bonds worth $600 million, due 2024.
This was no ordinary bailout. Just eight years before, the IMF agreed to a $242 million package that briefly sparked the economy back to life – the fifth IMF-led facility since Mongolia’s transition to market-economy status in 1990. But collapsing commodity prices and doubts over the future of the Oyu Tolgoi mine left the state’s finances more imperilled.
In hindsight, the 2009 bailout had been a wasted opportunity. Paid up-front in a lump sum, it allowed the state to repay the loan as soon as the economy improved, and thus to “soft-pedal on vital reforms”, says a person with direct knowledge of the package. The net result: “It didn’t broaden or deepen the financial economy, create better banks, or instil the need to be more fiscally responsible.”
IMF leaders in Washington, aware that earlier bailouts were poorly implemented, were not going to make the same mistake a sixth time. The 2017 bailout is designed to succeed. If it doesn’t, neither the Fund, nor the government, can have any excuses.
To that end, it’s worth combing through the extended fund facility, to give it its full name, to reveal the realities and the limits of its ambitions. The first thing that strikes you about the 2017 bailout is its size. In relative terms, it is the fourth-largest in the IMF’s history: a $5.5 billion loan package to prop up an $11.2 billion economy.
The second is how high the bar has been set. Take the asset-quality review (AQR), the most demanding and important feature of the bailout, which was still in process when Asiamoney went to press.
Heart of the matter
At first glance, it is a typical stress test designed to weed out poorer-quality lenders from the herd. But at heart, it’s so much more. Executed by PwC’s Czech Republic unit, it precisely replicates stressor scenarios used by Europe’s central bank when evaluating the strength of EU-based lenders.
That has not gone down well in Ulaan Bataar. “It’s OK to use ECB methodology in a place like Europe, with its mature and advanced banking sector,” says Orkhon Onon, chief executive of Trade and Development Bank of Mongolia (TDB) and president of the Mongolian Bankers Association.
“But our modern banking system is just 27 years old. We don’t have deep capital markets, derivatives or project finance. Our banks are highly conservative, taking deposits and using old-fashioned collateral like mining licences and real estate to make loans.”
Another bank chief executive weighs in, warning that ECB rules are “not compatible to our situation. European stress tests are carried out in developed economies with advanced tax collection systems. Mongolia is a frontier market at best, landlocked and small, politically unstable and over-reliant on commodities.”
The IMF’s response to these perfectly reasonable claims is a simple one. Yes, its officials say in private, ECB-style stress tests may seem like a merciless form of tough love. But they are available and they have been tested and appear to work – so why not use them?
In Ulaan Bataar’s financial circles, the fear is that the AQR will shine a harsh light on several banks, including one or more top-tier institutions, and ask some intrusive and awkward questions. These could include if a bank is underfunded, who owns and runs it, what its real stock of impaired loans is, and how it gets and carries out its business.
But would that really be so wrong? Many of these questions have never been asked before. Dominated by domestic players (because foreign banks are all but shut out), the banking sector has largely been left to its own devices. This will be the first time that Mongolia’s banks have been subjected, in the IMF’s words, to a “comprehensive diagnosis”: properly dissected and tested using international-quality stress testing.
When a lending institution fails here, it tends to be quietly merged with a state-run bank. That happened in 2013, when the fifth largest lender, Savings Bank, was taken over by State Bank, itself the result of the 2009 union of two other failed outfits, Zoos Bank and Anod Bank. “We need the IMF,” sighs the deputy chief executive of a local lender. “We’ve had years to sort out our problems. These laws may look tough, but the ambition is good.”
What penalties banks are likely to face if they fail some or all aspects of the stress tests remain to be seen. Central bank rules were changed recently, doubling the minimum amount of paid-in regulatory capital banks must hold on their books, to Tug100 billion ($40 million), with lenders given until 2021 to locate fresh sources of funding.
Most big banks are “already well in excess of that number”, says Randolph Koppa, executive vice-chairman of TDB, the country’s leading corporate lender. The rule change was explicitly designed “to shake some of the smaller lenders out of the system, forcing them to shut down or consolidate”, he adds.
Around 85% of all domestic banking assets are controlled by five lenders, including TDB, Khan Bank, XacBank and Golomt Bank. The remainder feed off the scraps or are reliant on their parent for new business.
The AQR is designed to pinpoint any lender that is likely to require additional provisioning. Banks were slated to complete the review by the end of 2017, with the central bank then set to carry out stress tests in early 2018, before publishing a list of which banks require additional injections of capital, by July.
If any lending institution is deemed to lack the requisite strength and resilience, the IMF says it will be recapitalized and restructured as needed. The Fund is clearly preparing for the worst.
It tips the banking system’s capital shortfall to be as much as $784 million, or 7% of GDP. In that event, Ulaan Bataar will set up its own version of the Troubled Asset Relief Programme, which purchased toxic assets and equity from US lenders at the height of the global financial crisis.
Key differenceQuite apart from its relative size, a Mongolian Tarp, to be set up in early 2018 and overseen by the central bank, will differ from the original version in one key way. Rather than buying assets directly, it will officially give banks until the end of June 2018 to meet all their recapitalization needs – though bank chief executives widely expect this deadline to be extended to the end of the third quarter.
If they can’t, the central bank will dip into Tarp and “invest in each capital-constrained bank on an interim basis until it hits certain benchmarks”, says TDB’s Koppa. “The government will effectively buy stakes in banks in order to improve them.
"If they succeed, the bank’s shareholders will be able later to buy back their original stakes. If they fail, the government will auction off its stakes.” Any lender that does not pose a systemic risk and that fails to raise enough capital from private sources faces being wound up.
While the AQR has largely focused on identifying which banks need capital and which do not, the stress tests will also tackle a series of deeply ingrained defects that have long undermined the financial system.
Five in particular stand out, starting with loan resolution. Non-performing loans as a share of total lending hit 8.7% at the end of September 2017, the highest level in eight years, according to central bank data, with deteriorating asset quality blamed on a weak economy and inadequate provisioning.
Bankers have long complained about the lack of a viable resolution programme. “We’ve been waiting for years for a commercial law that solves NPLs promptly,” says a senior bank official.
“It can take up to 12 years to resolve a failed loan in a satisfactory way. The judicial system is slow, appeals take for ever and too many restructured loans are of dubious quality.”
This problem will be tackled in two ways, the IMF said in its May 2017 report. First, by identifying “legal and regulatory obstacles to NPL sales”, and developing a resolution strategy that removes impediments. The London-based Financial Stability Board is expected to approve the strategy by the end of January 2018.
And second, to demand that all banks have in place, by July 2018, the right “strategies, policies, and internal capacity” to quickly and effectively be able to resolve failed loans – though how the IMF intends to enforce the new rules once they are up and running remains to be seen.
On November 27, the IFC, the private-sector arm of the World Bank, signed a memorandum of understanding with the justice ministry, to reform the bankruptcy framework by strengthening insolvency and debt collection systems. The second challenge involves the central bank itself.
For years, people have questioned its reliability and efficacy, not to mention the integrity of some senior officials. Previous Bank of Mongolia chiefs have been accused of overlooking rule-breakers and even channelling state capital to favoured lenders.
Moreover, notes one senior bank executive, the governor “is appointed by the prevailing ruling political party, so his independence is not always as strong as it should be”. That problem seems set to change. Senior bankers in Ulaan Bataar nod their heads and cluck with approval when the name of the current BOM governor, Nadmid Bayartsaikhan, is mentioned.
“He’s good, especially compared to the previous guys,” says one chief executive. “He’s implementing the stress tests and working with the IMF – and doing it well and willingly.” A new central bank law, which is due to be adopted in the first half of 2018, will, the IMF says, “clarify the BOM’s mandate and strengthen its governance and autonomy”.
All members of the Monetary Policy Committee will vote on policy decisions – preventing too much power being concentrated in the hands of one person – while the central bank will also be subject to an annual external audit. Then there’s the thorny issue of governance.
As of December 2017, a new banking law linked to the IMF reforms was working its way through parliament. Its myriad aims include improving asset provisioning, strengthening bank resolution and bringing the Deposit Insurance Corporation in line with international best practice.
But the big shake-up relates to governance and ownership. Specifically, the new law is designed to expand the investor base, making it harder for banks to be owned and controlled by a single, dominant shareholder, as is the case with Golomt Bank and TDB.
Related-party lending is another remnant of a bygone era that the new law aims to eradicate. Successive governments and central bank chiefs have sought, often not too vigorously, to tackle a problem viewed as most pervasive at poorly run lenders dominated by a single shareholder, and which only emerges into the public realm when a bank suffers a financial seizure.
That happened when Savings Bank collapsed in 2013. Sifting through the wreckage, the central bank observed that the lender had been in financial peril for at least two years and linked its failure to loans made to “related interests of the bank’s only shareholder”, a conglomerate called Just Group. When it failed, Fitch Ratings found that related-party loans and non-performing loans exceeded capital by more than two times.
Can the IMF and the central bank resolve this problem? Related-party lending is second nature to many lenders: it is why so many non-banks decided to get into the business. The IMF is certainly trying.
It aims to ensure that by September 2018, no transaction with a related party is “undertaken, restructured or resolved on more favourable terms than [equivalent] transactions with non-related counterparties”. It’s a fancy way of saying: “Don’t try anything because we are watching.”
Two final and interconnected factors stand out. Foreign banks remain shut out of the lending industry. Those that are here – notably ING Group, Bank of China (BOC), Industrial and Commercial Bank of China, and the Japanese pair of Bank of Tokyo-Mitsubishi and Sumitomo Mitsui Banking Corporation – run limited advisory services via representative offices.
Most bankers in Ulaan Bataar say this reticence about doling out full operating licences is rooted in the fear that China’s big state banks will rush in and gobble up the lending market. “We don’t want China to dominate,” admits the chief executive of a leading private bank. “Their companies are already strong enough here as it is.”
But how much longer can regulators keep foreign capital out of the banking sector?
“They always cite national security when asked about allowing foreign banks in,” notes one industry insider. “But they can’t fob them off for ever. I speak to the guys at BOC. They have Chinese customers who want to put their money to work here, lending to big corporates and to big infrastructure deals related to [Beijing’s] Belt and Road project. But they are stymied at every turn.”
Read between the lines of the IMF’s May 2017 report and you sense it would love to see the banking industry attract more foreign capital, as it would probably lead to better corporate governance. Many local operators certainly think so. Khan Bank’s Bell spent nearly 20 years working in central and eastern Europe for Citi and RBS before moving to Ulaan Bataar in 2015.
He says: “The difference between Mongolia and other emerging markets I’ve worked in is there are no global lenders here, no HSBC or Citi. They are mini universities that make every market in which they operate better. You don’t have that here.”
Adds Tumurkhuu Davaakhuu, chief support officer at Arig Bank, the country’s second-oldest lender: “I’d love to see a global bank here with retail operations. It would force everyone to do better.”
Leaving aside the issue of how welcome they are, a bigger question is how many foreign lenders actually want to put their capital to work. Viewed from any angle, Mongolia is a risky bet for global players.
Economically speaking it’s tiny, generating less annual output than Brunei or Burkina Faso. It ranked 62nd in the World Bank’s Doing Business rankings, a middling performance at best. But Mongolia is hazardous in other ways.
In October 2016, the Financial Action Task Force on money laundering (FATF) gave the country 18 months to clamp down on organised crime, drug smuggling and money laundering.
A report published in September 2017 by the 41-nation Asia Pacific Group on Money Laundering warned of growing trade with the Democratic People’s Republic of Korea (DPRK). Around 1,500 North Koreans live and work in Mongolia, the report said, adding: “A number of known legal entities operate in Mongolia with direct links to the DPRK, and Mongolian companies own shares in DPRK state-owned enterprises.”
The lingering fear in Mongolia is that it will be added to the FATF’s ‘grey list’ of countries regarded as lacking the will or ability to combat money laundering. “When the FATF guys came through Mongolia in 2016, they told us to get our act together,” one local banker says. “China’s banks would care a bit if we are added to the grey list. US banks would care a lot.”
Khan Bank’s Bell believes being included on that list of errant states would be a disaster for Mongolia – not least because it would be harder for lenders to form correspondent relationships with US-based banks. “We are a risky market,” he says. “We cannot afford not to be squeaky clean.”
In December 2017, the European Union published its first-ever blacklist of tax havens that included Mongolia, as well as the likes of South Korea and Guam. President Battulga Khaltmaa, in office since July 2017, is keen to make Mongolia more receptive to foreign capital. In the first half of 2018, the government is set to amend and expand the legal code, making corruption and money laundering criminal offences, including for politicians.
So a year that started out badly for Mongolia, and threatened to get progressively worse, actually turned out surprisingly well. Foreign exchange reserves rose throughout 2017, hitting $1.63 billion in December.
Growth is back, as is foreign investment, while a trade surplus helped narrow the current account deficit. In October, global investors seemed to reward the sovereign by placing $5.5 billion worth of orders on an $800 million bond priced at 5.625%. That constituted a big confidence boost for a sovereign that the agencies rate as speculative grade or junk at Caa1/B-/B-.
Then there’s the IMF bailout, which appears to presage a new chapter in the short and often turbulent modern history of this frontier state. If every facet of the bailout is met or exceeded, the country will in five or 10 years’ time have a thriving banking sector, dominated by well-run lenders and overseen by an active and fiscally responsible central bank.
Much of course remains to be done, but the events of the last year offer hope. After years of missed opportunities and wrong turns, Mongolia is finally headed in the right direction.