Our recent studies

  • 08.01.2017

    RAROC – A treasurer’s best tool for optimizing banking relationships and reducing financial expenses

    Banks utilize RAROC (risk adjusted return on capital), a risk-based profitability measurement, to assess the efficiency of their business relationships with corporations. Similarly, savvy treasurers utilize the tool to monitor costs and to ensure competitive pricing in their banking relationships. The range of products & services offered are evolving and their costs are increasing as treasurers’ needs broaden, regulations become more burdensome, and markets become more sophisticated.

    As a result, corporate treasurers are facing less transparency in increasingly complex relationships with their banks. The question that banks and corporations face is: what is an appropriate level of expenses paid and income earned for a mutually beneficial relationship to exist?

    Banks, in exchange for providing corporations credit lines, seek “side business” to help compensate banks for accepting credit risk. “Side business” covers a range of products and services, including cash management, market operations, coverage rates, and exchange rates. Such a system creates uncertainty surrounding the fair value of the services provided to corporations for two primary reasons.

    First, in the absence of a benchmark, companies often believe they are obtaining optimal pricing. However, without the guidance of an advisor with a database of best prices for similar companies (i.e. industry, rating, size, etc…), a company will never be certain where it stands relative to comparable organizations. Companies frequently pay fees for unnecessary services or, conversely, unwittingly expose themselves to disengagement risk if a bank believes it is not earning a sufficient overall return relative to risk.

    Secondly, because banks position “side business” as the additional compensation corporations must pay to justify the bank’s open credit risk exposure, the calculation to determine sufficient return is complex. In other words, to quantify a mutually beneficial banking relationship, the final output for return must be computed by accurately pricing the individual variables of credit exposure and products & services, among other variables. To add an additional level of complexity, each bank utilizes its own internal model with different prices for the variables. This means banks will always measure and define an acceptable rate of risk adjusted return differently than their peers!

    Superior Profitability to Weighted Average Cost of Capital (WACC)

    Since most banks measure their efficiency through a RAROC model, it is important to understand its evolution. Arising out of economic theories from the 1970s, the formula optimizes the allocation of bank capital by determining an appropriate measure of risk-adjusted return. Banks, like any other business, seek to generate a superior risk adjusted return to their WACC (weighted average cost of capital). Generally, the cost of capital is around 10% and profit targets between 10% and 15%. To achieve this goal, the banks have the ability to adapt their selling prices, lower costs or change the allocation of capital, ie their commitments to a single prime contractor.

    Source: Redbridge Debt & Treasury Advisory

    Treasurers should periodically engage an outside advisor to formally measure the corporation’s RAROC with each of its banks to ensure accurate benchmarking of services and fees to comparable organizations. Corporations with existing models must also periodically recalibrate their models. An engagement for analysis can be performed over the life of a banking relationship or for a set period. Results may take up to several months to accurately calculate, dependent upon the scope of the operation. It is also essential to note that an accurate RAROC analysis requires knowledge of each banks’ preferred range of parameters for different inputs. Such understanding is acquired only over years of working with banks across industries, credit ratings, and sizes.

    Model Parameters

    In order to determine a fair profit margin for banks, a corporation must first know the income it generates and the bank’s costs it incurs. The income corresponds to the fees and commissions paid, all of which are likely to evolve over time and establish variability in the profitability of the relationship. The costs are mainly comprised of operating expenses, which are possible to model using traditional ratios (i.e. cost income ratio, etc…) but must be calculated to accurately reflect the average cost of each type of observable transaction in the banking industry. Additionally, taxes and liquidity costs accounted for 200bps of widening during the financial crisis and had a material impact on the profitability of banking transactions. These costs have since fallen back to an historical low range of between 10-60bps, partly due to the implementation of Basel III liquidity ratios (LCR and NSFR).

    Aside from the operating costs, banks bear the cost of risk inherent to each transaction. The cost of risk is expressed through the average loss and by providing internal capital. The average loss is defined as the product between the exposure of the bank at default (EAD), the rate of loss given default (LGD), and the probability of default attributed to the borrower (PD) by the lender. These same parameters are used with the residual maturity in order to set the amount of economic capital.

    Notably, each bank takes a different approach to establish an internal rating of a company. There are two primary methodologies utilized. A bank may opt to use the LGD and other parameters provided by the IRB Foundation. Or, a bank may use the Advanced IRB method in which the bank may develop its own internal empirical model to quantify the requisite capital for credit risk. The probability of default is derived from the rating of the borrower. The rating scales used by banks and the corresponding default probabilities are typically available in the bank reports. However, a default probability, even for a “risk-free” asset, is never zero and the PD is particularly sensitive along the border between investment grade and high-yield. As a result, the latter leads to large disparities in financing terms offered by different banks to a single borrower, which create opportunities for astute treasurers to persuade lenders outside the market to meet their internal rating. To utilize this strategy, the treasurer must capitalize upon the differences between the rating criteria used by the banks and those used by rating agencies.

    Tools by which to Navigate

    The relationship between income generating bank services and the risks inherent in providing such services will affect RAROC levels. In other words, unsecured funding is often the least profitable for banks given the level of risk. In contrast, other services such as bond issuances and asset management generate minimal risk and provide high relative rates of return. By accurately tracking the rates of return generated by each banking relationships, corporations will possess a tool that will enable them to assess, control, and monitor the value of their banking relationships. Wherever RAROC can uncover sources of savings, such as in unnecessarily high credit lines, superfluous services, excessive fees, or abnormally high rates of return, treasurers will possess the tools and information to equalize the balance of power in future negotiations.

    Example of RAROC for a 5 year amortizing bank loan

    Data derived from use of RAROC


    Source : Redbridge Debt & Treasury Advisory

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  • 08.01.2017

    Redbridge at AFP Annual Conference 2017

    The Redbridge team is excited to be exhibiting and speaking at the AFP Annual Conference in San Diego, October 15 to 18, 2017. Keeping with the AFP theme of « Where the Best Get Even Better », Redbridge experts will present key insights on some of the most important developments, trends and opportunities within treasury management. Our delegation of BRM experts will be available for meetings on current topics, including treasury service utilization, bank fee optimization, merchant card costs, credit ratings, fundraising, and debt structuring.

    As you plan your schedule for maximizing your value at the AFP 2017, be sure to visit our new and expanded exhibit booth #905, schedule a meeting with one of our team, and attend our two thought-leadership sessions.

    Educational Sessions

    Do RFPs Give You the Blues?
    Speakers : Bridget Meyer, Senior Director, Redbridge Analytics / Michelle Fabela, Treasury Manager, Norstrom
    Monday, October 16, 2017, 4:00 PM-5:00 PM
    Room 11AB

    Treasurers conduct an RFP for cash management services to improve pricing, learn about service capabilities, and ultimately choose the ideal partner for their growing business. Learn how this panel of treasurers and experts get the most out of an RFP process by taking a structured approach, developing a detailed project plan, checklists, defining stakeholders and creating a cross functional internal team. Your next RFP doesn’t have to give you the blues.

    • Learn the benefits of developing an internal cross-functional project team to support the RFP process and support change internally.

    • Learn how to draft, receive, and validate your RFP responses to verify the information so there are no surprises during implementation – for either the bank or the corporate.

    Unlocking the mysteries of Bank Fees

    Speaker: Daniel Gill, CTP, Senior Director – Redbridge
    Tuesday, October 17, 2017, 8:30 AM-9:30 AM
    Room 33ABC

    How we manage our relationships with our banking partners is often clouded in mystery. We are tasked with not only knowing what services we are buying from our banks but also controlling the costs of those services. Account structures must be justified in short amounts of time. In this session, speakers discuss foolproof strategies to manage your bank fees and bank relationships in less time than ever, using such AFP Codes and pricing guides in order to put treasurers in the strongest possible position.

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  • 08.01.2017

    Why are some major banks not pricing EDI 822’s to encourage the elimination of paper?

    At some banks, paper Account Analysis Statements are still priced lower than electronic versions of the same report in PDF, CSV, or EDI 822. One bank is actually charging its corporate clients up to $175 per account monthly to receive an electronic version of the same report that comes in paper form for $25! That does not make sense! writes Bridget Meyer, senior director at Redbridge.

    Back in the 1980’s, banks began to offer new types of accounts designated to track and report balances, transaction volume and pricing for distribution to its clients for a monthly manual review. These reports known as Account Analysis Statements have become a standard business practice for all major banks doing business with large corporations. This is also considered the bill corporations receive showing all account activity and unit pricing. And since banks could no longer pay interest on checking account balances, the Earnings Credit Rate, or ECR, became a competitive feature offered to offset the fees a company might be charged for transactional services. This encouraged deposits which the banks used to lend out in the form of loans. Basic ABC’s of banking! The Account Analysis Statement helped companies understand their bank fees which had always just been deducted from their balance once a month.

    Almost 40 years later, banks are trying to reduce their costs by eliminating paper reports, which seems to be the norm with banks in the United States. It might seem that all bank statements and notices are moving to electronic and that is great! Not so fast! It might surprise you that at some banks, paper Account  Analysis Statements are still priced lower than electronic versions of the same report in PDF, CSV (Comma-Separated Value), or EDI 822 (Electronic Data Interchange). Well, at least one bank is actually charging its corporate clients up to $175 per account monthly to receive an electronic version of the same report that comes in paper form for $25! Wow, that does not make sense!

    Isn’t it a lot cheaper for the bank to produce electronic versions? Yes, it is but some questions have been raised as to the willingness of some banks to allow for the transparency and ease of reconciliation electronically of these monthly bills. These would allow clients to easily identify mis-charges, new charges, errors in services, etc. Some banks actually have 4,200 priced services for corporations and finding errors in their billing could be extremely difficult if not impossible with paper analysis statements. The most desired format for the largest customers is the EDI 822 file, received via transmission without any human intervention on a monthly basis. These can be uploaded into ERP systems or sent to third parties to reconcile.

    Not all banks are guilty of steering customers away from electronic versions, but you want to be sure your banks are not one of those charging $175 a month per account.  Some banks actually offer all electronic formats for free just to reduce cost of producing and mailing. That is great. But some electronic formats are better than others. And some offer only one electronic format for free, and that format is typically a PDF format, probably downloadable from the bank’s website.

    A PDF formatted account analysis is basically a visual photo of the paper statement, leaving any electronic review impossible. The PDF (and paper) version of a statement is legally considered the ‘statement of record’ describing accurately will actually be debited from a customer’s account.

    Receiving a CSV or PDF is not always free. One large regional bank, charges $5.00 to download a PDF and $10.00 per month for a CSV version of their invoice with no available ‘free’ option. The average account analysis statement is hundreds of pages for a large corporation. Reviewing the charges each month is not only a chore, it requires significant data entry. Most of the large banks are now offering a Comma-Separated Value (CSV) version of the analysis statement for added convenience but customers beware.  Excel will round the numbers and create slight variances from the PDF version.

    So the motives of any bank that only allows a free or very low cost PDF or CSV formatted account analysis statement might be questioned. Are they worried its customers might find errors?  Perhaps.

    Figure A shows the average monthly cost to receive an EDI 822 electronic account analysis statement from the largest 16 banks in the United States. The differentiation should surprise you. Two of the big money center banks offer free downloads of customer bills in any format (EDI, PDF, or CSV). Another money center (who the author is referencing as Bank A) charges $175.00 per month per Customer ID to send the billing information in EDI format and provides CSV’s to a very limited few. Even if a bank does charge a standard price to provide electronic statements, customers have a 44% chance of getting that fee waived from all but one bank – the one charging $175, according to Redbridge Analytics.

    EDI file cost

    Source: Redbridge Analytics

    You might be surprise that some of the major banks actually have ‘product managers’ assigned to the revenue generated from Account Analysis Statements! The revenue stream for these services at these banks is significant enough to be measuring the profitability and growth of this revenue stream. Those banks are very closely managing their services and they might be motivated to price their most efficient and lowest cost alternative at a very high price to boost profitability but they might also be enjoying the lack of transparency and low incidence of company’s third party consultants finding billing errors and unused services!

    With all this talk of about prices of a bank’s invoice to you, you may now be asking the philosophical question: why do banks actually charge their corporate customers to receive that very bill, or Account Analysis? It does seem odd from an Accounts Payable perspective, but that is another story for another time.

    Since some banks are steering cost conscious clients to download a PDF version of their 450-900 pages bill and happily auto-debiting their fees each month, the need for due diligence of bank charges is great. Billing errors are incredibly common. And bank fees could be very significant… if not one of the highest vendor costs in a corporation. It is time for all banks to become transparent and price EDI 822 electronic Account Analysis Statements so that the corporate treasurer has a reasonable electronic method of reviewing these bills at a reasonable cost.


    Author: Bridget Meyer



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  • 08.01.2017

    Thoughts for a successful and well-functioning Asian treasury operation

    Solenn Le Lay and Hélène Shen, consultants from Redbridge DTA, identify important areas that treasurers should consider to avoid the common pitfalls of doing business with banks in Asia: obtain optimal pricing and ensure top quality services for all their local cash management needs.

    Treasurers typically do not consider the banking costs of their cash management operations in Asia to be sufficiently material, particularly relative to other regions of the world. Local treasury operations in Asia pay an average of 0.003% to 0.004% of revenue for collection and disbursement services – amounts that are 10x less than those in the West.

    However, these costs deserve to be scrutinized as there could be real opportunity for these costs to be cut by 2/3rd with a well-timed and well-executed RFP. Indeed, services such as currency hedging, guarantees, trade financing, and overdrafts are costly services that can often be negotiated for more competitive terms, but many account costs are often overlooked, and often must be thoroughly and objectively challenged.

    To successfully create a highly cost effective Asian cash management operation, treasurers must focus on a few key areas. Most importantly, they must select only optimally suited banks to include in RFPs. Within companies, there is often a disconnect between the local and global treasury teams as to which banks to invite to participate. Local treasury teams typically value local banks that possess familiarity with the nuances of country-specific banking operations whereas global treasury teams often favor international banks with global capabilities. The most strategic choice is often to include both in the process so that all stakeholders can choose the most appropriate service providers.

    In the process, it is essential that management carefully scrutinize each bank’s expertise and quality of service, recognizing that banks might exaggerate their capabilities and may be engaging independent third parties to provide critical services on behalf of the bank. In cases in which major international banks have clearly invested in developing their operations in this region, treasurers must also determine whether the bank’s experience is sufficient to provide the desired level of service and efficiency. This is particularly critical for complex operations such as cross-border cash pooling in China. Few banking institutions possess this expertise and will often offer noticably low competitive pricing just to attract clients to build their experience.

    Another common challenge in assessing responses to an RFP for cash management services in Asia relates to incoming and outgoing cash flows of subsidiaries. Since the most commonly used methods of payment differ significantly from those employed in the western hemisphere, treasurers must become familiar with local business customs for each of its subsidiaries in the region. For example, promissory notes, often called bank acceptance drafts, are physically traded (hand-to-hand). Aside from being a relatively expensive means of transacting business, this alternative form of payment is difficult to trace, creating additional challenges with risk management. Treasurers must also regularly deal with the lack of bank transparency when overdraft and deposit rates are set. The deposit rate, for example, is not linked to a market reference rate but rather to non-transparent and seemingly subjective internal bank processes.

    Ultimately, selecting a cash management service provider requires a careful analysis of both a bank’s true capabilities in providing services and whether there is a long-term commercial committment to the region. In recent years, there have been some well-documented cases in which corporations were given very short notice of a bank’s decision to withdraw from the region, forcing treasurers to quickly select and establish their banking with a new cash management service provider, sometimes not benefiting from the optimal results of issuing an RFP.

    Authors: Hélène Shen / Solenn Le Lay

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  • 07.01.2017

    Case study – U.S. domestic retailer

    In 2013, a privately held retailer headquartered in the United States selected Redbridge (at the time, The Montauk Group) to conduct a bank fees and services optimization called “BRM Insight”. This ‘big-box’ retailer – with more than 200 domestic US locations – utilizes a total of seven banks for its daily cash management, cash & coin deposits, and banking needs. In addition, the client works with multiple armored car couriers to facilitate the carrying of hard cash between its stores and banks.

    Client Snapshot

    Revenues: $3 billion

    # of Stores: 230

    # of Banks: 7

    # of Bank Accounts: 324

    Gross Monthly Fees: $172,000

    Average Daily Balances: $95 million


    The engagement was initially segmented into four distinct components:

    An historical analysis of services utilized, fees paid, seasonal trends, and typical balances at each of these seven banks, during the previous 12-month period (via review of each bank’s monthly account analysis);

    An assessment of prospective opportunity, based on: a) understanding and matching the client’s daily needs to the most appropriate services available at each bank, b) price points being paid by this client compared to its peers at the same seven banks, and c) possible restructuring of bank accounts (e.g., type, funding method);

    Bilateral negotiations with each of the seven banks pertaining specifically to pricing, followed by implementation of the agreed modifications (identified in #2 above);

    Monitoring of each bank’s adherence to revised pricing and services.


    Across its seven banks, this client was paying for 510 distinct banking services. Upon completing steps 1 and 2 above (historical analysis & assessment), Redbridge identified that 65 of the 510 banking services that the client was paying for were candidates for elimination, given a review of the client’s daily operation and Redbridge’s assessment of the client’s specific needs. Additionally, Redbridge indicated that based only on its BankScore™ pricing database, the client could achieve up to a 22% reduction in fees, if it were to receive ‘best-in-class’ pricing at each of its seven banks, for all of the remaining services utilized.

    Bank Discussions

    The client was adamant about not overhauling how it used its existing banks, meaning, this optimization effort was going to be limited to direct bank discussions (instead of a structured RFP process), and not include moving business between its banks. The focus of the direct negotiation discussions would be on pricing and modifying existing banking services. Redbridge created Bank Discussion Documents (one for each bank) to facilitate discussions between the client and each bank. Meetings occurred sequentially with each bank (approximately one discussion every two weeks); for five of the seven banks, second meetings were required.

    Results of the Bank Discussions

    Following the bank discussions, the client decided to eliminate 40 of the 65 services that Redbridge identified as candidates to be eliminated; these eliminations did not adversely impact the client’s operation. This reduced the total number of utilized services to 470 (from 510). Additionally, the client’s banks agreed to reduce pricing on 90 of the remaining 470 services. The impact of the service eliminations and pricing reductions were monthly savings of about $17,000 (or $204,000 annually).

    Redbridge was then mandated to monitor each bank’s monthly account analysis to ensure adherence by the bank to the negotiated pricing and services structure. Although the client was pleased with some areas of the optimization – specifically the service eliminations – the lack of competitive pricing from the banks left a lot to be desired. Additionally, the absence of meaningful participation by some of the banks in providing competitive price reductions indicated to the client that perhaps these banks really did not want their business.

    Round Two – Customized Analyses

    With this in mind, the client was eager to achieve additional savings, and worked with Redbridge on a revised strategy: to open up the bidding for all store bank accounts by its seven banks. Redbridge created a customized cross-bank comparison template. In effect, this cross-bank comparison allows Redbridge and its clients to be able to identify a volume for a specific set of services, and then pinpoint the exact costs at each bank for the same set of services and volumes, taking into account how each bank names, segments and prices these services. In this way, Redbridge is able to quickly create and run multiple simulations, and identify theoretical outcomes.

    • A cross-bank comparison takes the various nomenclature of each bank, along with that bank’s unique pricing structure and methodology, and aligns it to all of the other banks, so that a pricing translator can be created for a specific client.

    As “depository” fees were the highest group of monthly costs for this retailer, Redbridge constructed an RFP document focused solely on activity related to store deposit activity and volumes. Each bank was instructed to provide prospective pricing for this activity, including any tiered pricing (in the case that their pricing would be different based on how many stores they would eventually be awarded), and also to provide a proximity study identifying the distance between each of the client’s store locations and the nearest bank branch.

    Results – Round Two

    21.1% in prospective monthly fees savings or $396,000 per year;

    70 stores/bank combinations changed;

    40 bank services eliminated;

    $115,000 in bank billing errors recouped;

    100% of stores depositing via vault services.

    The competitive nature of this second round proved to be significant in terms of results. Based on responses from each bank, and with the ability to use the cross-bank comparison to run multiple simulations with newly revised pricing from each bank, the client decided to move more than 70 stores amongst its existing network of seven banks. The combination of store moves and the new pricing structure across all banks led to an additional $16,000 in monthly savings. This savings combined with the savings achieved in the first round totaled $33,000 per month (or $396,000 annually). Also, this engagement helped the client achieve its initiative to ensure that armored couriers and vaults were utilized at 100% of its stores.

    In addition to the realized savings, Redbridge identified bank-billing errors by monitoring each bank following implementation of the new pricing structure. In total, $115,000 in bank billing errors were identified by Redbridge and recouped by the client. Redbridge continues to monitor bank fees each month on behalf of this client.

    • Based on the historical billing issues identified, I felt we needed monitoring as it is a best practice and has proven beneficial to our company. All of our banks continue to be understanding when I advise them of billing violations, and they have provided us with all credits requested.” – Assistant Treasurer


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  • 07.01.2017

    U.S. banks set to simplify their billing systems

    Two of America’s largest banks have recently sent notices to customers communicating the changes to their services. Multiple global banks are also in the middle of streamlining service lines as they bring additional countries into a centralized global billing system.

    The bank billing forecast for 2017 is calling for consolidation across the board.  Redbridge Debt and Treasury Advisory has noticed a consistent trend among banks looking to reduce the overall number of individual bank service IDs in their billing systems. Two of America’s largest banks have recently sent notices to customers communicating the changes to their services. Multiple global banks are also in the middle of streamlining service lines as they bring additional countries into a centralized global billing system.  These efforts are a start to better transparency in international bank billing.

    We have a long way to go, however. Upon closer look, many of the changes simply remove legacy product names or rename existing services. Others combine multiple notification options into a single service line.  Global banks that used to maintain separate service lines per country are now consolidating per region instead. While these efforts greatly improve efficiencies internally for the bank, their corporate customers will not necessarily see a reduction in service lines. The benefit for the corporate will be in the comparison, monitoring and understanding of similar services across multiple countries.

    Historically, American banks used to price treasury services based on state or region. The evidence of this practice still exists in many regional banks that have not invested in improved billing systems. While some have successfully made efforts to consolidate the remaining state-specific services, cash vault services per location still linger.

    While the forecast of consolidation is much stronger in Europe than in the US, the winds of change are blowing. It can be difficult for any corporate treasurer to keep up, even with a software in place. AFP codes and pricing grids need to be manually updated in most systems when a bank makes changes to the way they bill.  If not maintained, the value of the software quickly declines. This is one of the main reasons Hawkeye BSB is so revolutionary. The mapping and tagging is maintained by the experts at Redbridge at a master level so a client never has to worry about the ebb and flow of bank billing tides. Will your system be ready?

    Author: Bridget Meyer

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  • 06.01.2017

    The automation of bank fee monitoring becomes a reality!

    Over recent years, the banking community has made steady progress toward establishing standardized billing formats.

    HawkeyeBSB, a SaaS based platform developed by Redbridge Analytics, is the industry’s next generation of bank fee monitoring software. Since its debut in late 2016, HawkeyeBSB has analyzed over 1700 standardized invoice formats, such as EDI, Twist version 3.1 and Camt.086. The complexity of analyzing these invoices – issued by 12 global banks and for accounts in 70 different countries – provides many lessons regarding the amount of progress still required for bank billing statements to be considered as having reached a satisfactory level of data standardization.

    Over recent years, the banking community has made steady progress toward establishing standardized billing formats. Banks in the US primarily use an older standardized format, referred to as EDI (Electronic Data Interchange), for clients’ US accounts. Outside the US, the format used is dependent upon the date a bank began providing identical invoices to international clients. Early adopters, most of which are UK based banks, issue invoices in the first internationally published format – Twist BSB version 3.1. Most recently, banks in mainland Europe began embracing the Bank Services Billing (BSB) initiative with the latest published standard – ISO Camt.086.

    Redbridge Analytics highlights material differences in the quality of data in bank invoices, not only among different banks but also within the same bank, depending on the geographical area in question. For example, the leading US cash management banks do not include in their billing files the international IBAN (International Bank Account Number) or the national BBAN (Basic Bank Account Number) identifiers. Rather, the banks only provide an internal reference number for each account. Doing so deprives clients the ability to easily identify to which entity the invoice must be allocated. The exclusion of the information is even more puzzling since banks store account numbers in their systems using the international IBAN in order to facilitate international transfers!

    Making matters worse, while some banks invoice and charge for fees according to the calendar month, other banks invoice in different intervals, thereby creating reconciliation challenges. If, for example, the client is billed on a weekly basis, or perhaps on a monthly basis on the day on which the account was originally opened (i.e. the 21st of the month), treasury groups simply cannot verify the volume amount stated on the invoice.

    Lastly, global banks do not provide the same level of data quality for countries where they are located, as they are not always able to produce standardized billing files in every country. When able to do so, banks remain dependent upon the quality of the billing chain of the local entity. For example, in the 1990s, several European banks grew through acquisitions in Eastern Europe, yet those banks still have not harmonized local billing systems, thereby leading to code errors on certain transactions. The good news is that clients are complaining, and banks have been responding by advancing quickly; such errors should begin to decline gradually.

    Author: Emmanuel Léchère

    For more information about the adoption of the standardized bank invoice, we invite you to read the BSB newsletter, published by treasurers, bankers, software developers and standard setters, to which Redbridge regularly contributes. The newsletter can be viewed by clicking on the link below:


    For more information about the bank invoice analysis and verification tool, please visit www.redbridgeanalytics.com

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  • 02.01.2017

    The key to gaining and keeping corporate treasury business

    When treasurers are able to understand how they are using the bank’s services and the cost of their global cash management operations they become better customers. Accessibility to the service usage and fee information relieves many of the pressures that currently exist in the treasury banking partnership, writes Dan Gill, Senior Director, Redbridge Analytics.

    In recent years, we have witnessed unprecedented changes in the core business of banking in nearly every region of the world.  Decreasing spreads on interest rates and revenue squeezes due to regulatory changes particularly in the retail banking sector have caused many financial institutions to search for additional areas to enhance revenues.  For many, this has meant moving deeper into treasury and cash management services. While offering these services often comes at a significant cost in technology, these costs can be quickly recovered through directly or indirectly billing for treasury services back to the corporate users.  From a corporate treasury perspective, the vendor partnership that exists between a company and its banks is essential.  Unfortunately, many banks leave their corporate treasury customers underserved by not providing sufficient transparency into the services that are being purchased and the associated fees for those services.

    Successfully serving the needs of corporate treasury means more than simply providing fast and accurate transactions.  Treasury needs to have complete visibility into the volumes and costs associated with managing their cash through their banking partners, and banks that cannot provide this essential information run the risk of being replaced.  This transparency has long been available in the US through the use of the EDI 822 transaction set.  A bank looking to maintain corporate customers in the US simply must have the capability of providing their bank fee information into this format.  However, even with great technology advancements throughout the bank service offerings in the past decade, global companies are still left wondering what services are being used and what fees are being assessed with their global banks.  In the year 2017, it is unfortunate that corporates cannot know the usage or costs of the services provided by one of their most important vendors, their banks.  It is time for global banks to invest in this capability and provide to their customers, the same billing service levels that other vendors provide.

    With the sheer volume of services used combined with a large number of accounts at many corporates, reporting this information in a paper or PDF based format simply will not be cost effective for the bank, or usable by corporate treasury.  Banks need a standardized and electronic way to report the service usage and cost information to their corporate customers.  Fortunately, such a standard now exists and is becoming well established in the corporate banking market.  A relatively new Bank Service Billing file format can now be used by any bank to report service usage and fee information, as well as balance and earnings information to corporate treasury customers.  The ISO 20-022 “BSB” format (known as the camt.086) provides banks with an easy to use, XML based file format to report all of the necessary information to their corporate customers in a standardized way, in any currency or region of the world.  The BSB file format allows for the reporting of the bank fee billing information for any number of accounts in a monthly statement format that can be translated by treasury software that is built to translate these standardized monthly bills.  When treasurers are able to understand how they are using the bank’s services and the cost of their global cash management operations they become better customers.   Accessibility to the service usage and fee information relieves many of the pressures that currently exist in the treasury banking partnership.  Because treasury groups do not typically have access to information regarding the services they use and the fees they pay, the relationship with their banks can often become strained.  Removing this strain is the main reason that the camt.086 BSB format was developed and is a strong reason why all banks looking to serve the mid to large cap corporate market should invest in providing this information to their customers.

    The history of the camt.086 BSB file format is an interesting one and points to the contentious nature of the relationship between corporate treasury and their banks.   In 2006, General Electric banded together with the treasurers at more than 100 other large multinational companies and presented petitions to Europe’s largest banks demanding a new electronic bank service billing file format.  This new treasury group joined with several banks and a treasury standards organization called TWIST (www.twiststandards.org) to build the first XML based bank service billing file format.  This format became known as the TWIST BSB and is still in use by a number of banks today.   In 2010, as the ISO 20-022 financial reporting standards gained acceptance and traction in the European market, an effort was made to translate the first generation TWIST BSB into the more formal and standardized ISO-20022 schema.  This work was completed in 2012, and the new BSB format was officially given the designation of camt.086.  While both the TWIST BSB format and the camt.086 are viable alternatives for reporting bank service billing information to corporate treasury, the camt.086 format is a better alternative for banks looking to start.  Since camt.086 uses the growing ISO 20-022 schema which has already been used for many large initiatives like SEPA its adoption within a bank can be easier to accomplish since file structure and field naming are already well established.  The camt.086 will also be the only version of the BSB format that will receive future enhancements as banks look to increase their reporting capabilities.  Many banks likely already have experienced ISO 20-022 developers on their team.

    The market direction is becoming clear.  If a bank desires to remain competitive in the large treasury services space, they will need to provide access to accurate usage and fee information for their cash management customers.  This will certainly mean developing monthly electronic bank service billing information for their customers in the camt.086 format.  Still, many banks are not positioned currently to gather the information or make technical investment in developing to the industry standards.  For banks that do not already have an established ISO 20-022 team, or where the complexity of global billing within the bank makes building this reporting a significant challenge, I recommend a two phased approach.  The first step is to evaluate how service usage and fee collection is handled in each region that the bank serves.  This knowledge will help the bank’s management determine a course of action and plan to roll out bank service billing across the entire enterprise, or to focus on specific regions first.  The second decision that needs to be made is what format to report the data in.  The camt.086 is the far and away standard that should be the long term goal, in some banks this can be a significant development effort.  In these cases, I recommend that banks first take the step to build a simple csv or Excel based service reporting format that can reporting the core information for service usage and billing on an interim basis, while the bank builds towards the ultimate requirement of global bank service billing using the camt.086 bank service billing format.   If delivering bank service billing information to your cash management customers is not already under development, it needs to be added to your 2017 roadmap.

    Author: Dan Gill

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  • 02.01.2017

    Bank Services Billing standards market adoption

    Corporate case studies and presentations reflect growing adoption of the BSB. European and UK e-invoicing regulation addressing retail bank statements and could in future have an influence on wholesale providers and users. The vendor survey is completed! An initial view of the results are reported on in this issue of the newsletter. Surveys are in progress to assess corporations using BSB as well as banks providing bank billing statements in BSB format. Corporate practitioners attribute value to use of the BSB format

    In this edition

    • Introduction
    • BSB News and Events
    • Recent BSB Press Coverage
    • BSB-Adoption and Current Availability
    • In Progress – The Bank Service Billing Survey Progress in the Standardized of Bank Billing Codes
    • Will History Repeat Itself? Standardizing Bank Billing Codes
    • BSB going forward: Hindered or helped by EU Regulations?
    • Vendor Survey Results
    • BSB Q&A
    • Editorial Staff & Resources


    By Robert J. Blair, TWIST Standards, ASC x9, and Vick Consulting Group
    The BSB (Bank Services Billing statement standard) is part of the family of ISO 20022 standards. Like the EDI 822 (EAA or Electronic Account Analysis) standard in the US, and other similar standards elsewhere, BSB  responds to corporate practitioner demands for bank bill transparency. Unlike those earlier standards, BSB has been designed to address the bank fee statement requirements of domestic and cross border services globally, developed with modern technologies including business process modeling, a universal data dictionary, XML (and other) syntaxes, and is a part of the family of ISO 20022 of broadly used, open standards for financial  services.

    Billing standards covered by this newsletter include:

    • ISO 20022 BSB (camt.086, versions 1 and 2) – Developed by TWIST and ISO 20022, this is the latest version of the TWIST standard and the focal point of new industry efforts to harmonize (normalize use) across banks.
    • TWIST BSB – Still in use and supported by a number of banks, application vendors and corporations.
    • AFP Global Service Codes – Standardized billing item codes for use with BSB.
    • Legacy and domestic bank billing standards including ANSI x12 822, as well as various others.

    The creation of billing standards was driven by the interest of corporate treasury practitioners such as GE and many others. The continuing interest and advocacy of corporate practitioners is essential to the adoption and value of the BSB standard.

    Analysis of bank bills can be complex and challenging. The newsletter will continue to promote the standard and seeks to improve understanding of bank bill analysis and the value standards bring to this activity.

    ISO 20022 camt.086 is the newest version of TWIST BSB:

    • Authored by TWIST Standards with the assistance of SWIFT
    • Developed and published by ISO 20022 RMG and the Registration Authority (the RA, SWIFT)
    • Market practice is defined by CGI-MP WG5 (Common Global Implementation-Market Practice, Work Group 5 focusing on BSB).

    BSB was originally published as a statement, not an invoice. The differences are subtle and the BSB schema can effectively be used for both purposes.

    BSB News and Events

    Version 2 of the ISO 20022 BSB (camt.086) was published in the first quarter or 2016

    camt.086 is the newest version of TWIST BSB: Authored by TWIST in 2006 as a TWIST standard, re-developed by TWIST and SWIFT and published as an ISO20022 standard as camt.0086 version 1. As an ISO 20022 schema (message standard), BSB is supported with a broad family of financial services schema, and a market practice group, CGI-MP, working to harmonize and promote adoption of the standard.

    camt.086 version 1 offers minor corrections and enhancements to the original TWIST BSB standard plus the advantages of commonalities with other financial schema found in the ISO 20022 family of standards. camt.086 version 2, published early 2016, enhances BSB to include ISO 20022 bank transaction codes (BTC) in addition to or in lieu of the AFP’s Global Service Codes (or other billing code series including bank proprietary codes). Camt.086 versions 1 and 2, is the recommended version of the standard for new users and providers.

    Both code series allow industry standard identification of bill line items. The difference between the two code series:

    • AFP GSC is specifically billing codes, covering all billable events.
    • BTC are account statement transaction codes covering specifically transaction types resulting in a debit or credit to an account. Many billing items will be transactions, a few may be related to non-transaction activity.

    Version 2 also includes a (minor) update to the schema required by the 2013 edition of the foundational elements of the ISO 20022 standards.

    News from CGI-MP WG5 in 2016 (Common Global Implementation Workgroup 5-BSB) continues its work on BSB which includes:

    • A review of the Global Service Codes is now in progress to simplify the codes for improved standardization and ease of use.
    • An e-Invoicing gap analysis is in progress. Findings and recommendations will be published in 2017.
    • A case study “The Business Case for BSB for Corporates” is in development and will be shared in the next issue of the newsletter. An  excerpt from the case study appears later in this issue.

    EU and UK Regulation and Bank Billing

    The EU’s “PAD” Directive, the Payment Accounts Directive is aimed at consumers but will be relevant for small businesses who use retail banking services and with possible influence on users and providers of wholesale banking services.

    Payment service providers are required by the PAD to provide standardized fee statements to their clients. This regulation is aimed to protect retail customers of any payment services provider in the EU, delivering / facilitating:

    • transparency & comparability of fee information
    • switching of payment accounts by establishing minimum standards
    • access to basic bank accounts for everyone

    The relevant technical standards are defined by the EBA. The EBA published draft technical standards on 22 September 2016. The available documentation includes examples of fees in billing statements.


    In the UK, and irrespective of any Brexit considerations, the Government has implemented the PAD, taking effect on 18 September 2016 by means of the Payment Accounts Regulations 2015 (PARs)

    Most of the provisions on transparency and comparability of fee information come into force at a later date, potentially 2018.


    Progress in the Standardization of Bank Billing Codes

    As of January 2016 there are over 50 subscribers to the AFP’s (the Association of Financial Professionals) Global Service Codes GSC). Among them are the top 15 global banks, including the largest 5 banks, large corporates from across various industries and a variety of technology vendors and treasury consultants.

    BSB Events

    May 2016 – Germany – Verband Deutscher Treasurer Annual Meeting (The German Association of Corporate Treasurers)

    Results of a poll of German treasurers and their bank providers:

    • 83% of bank respondents think providing e-Billing will definitely (72%) or possibly (11%) improve relations with clients.
    • 95% of corporate respondents think receiving e-Billing will definitely (62%) or possibly (33%) improve relations with their banks.
    • 52% of banks provide e-Billing statements globally and/or in Europe.
    • 61% of corporate respondents receive e-Billing statements globally and/or Europe

    May 2016 – US – NYCE Conference (the New York Cash Exchange). A corporate case study (Henry Schein, Inc.) was covered in this conference discussing the results of a bank fee analysis covering banks in China, France, Germany, US and elsewhere including Asia Pacific, Eastern Europe.

    September 2016 – Global – Sibos (the annual SWIFT conference) . “The Corporate Debate: Banks should stop differentiating non-competitive services”. GE Treasury, John Marshall, and Deutsche Bank, Michael Spiegel discussed the message from corporate treasurers: more needs to be done to standardize bank administrative processes and notably bank billing.

    October 2016 – US – AFP (the annual US national corporate practitioners’ conference). Redbridge’s Bridget Meyer presented a session at the AFP National Conference entitled “Decoding Your Analysis Statements” which reviewed both US and Global bank fee statements and the challenges corporate treasurers and banks face. Redbridge DTA and Marriott Vacations Global Corporations presented “Collecting, Benchmarking and Negotiating International Bank Fees”. Discussion included the challenges of managing international bank relationships and the benefits of using the BSB.

    Recent BSB Press Coverage

    “Electronic Statements from International Banks”, Treasury & Risk (email and website), November 2016, Author: Susan Kelly


    Excerpt: “…it’s up to companies to push banks to make electronic billing happen.” And “Comprehensive monitoring of banking charges – a TIP case study of Deutsche Post DHL Group”

    “Top Flight Monitoring Bank Charges-Deutsche Post Case Study”, LinkedIn, November 2016, Hubert Rappold, TIPCO.


    Excerpts: “Despite having over 1,500 subsidiaries spread across all continents, the corporate treasury department of Deutsche Post DHL Group can easily identify incorrect banking charges.” Hubert Rappold, TIPCO

    We now have a considerably stronger negotiating position vis-a-vis banks, which have noticed that we are carefully checking statements. Besides this, we now also have an overview of products and prices. Last but not least, we have been receiving major reimbursements as a result of the checks. “

    Christine Pitzen, Senior Treasury Manager, Deutsche Post AG

    “Keeping an eye on banks – managing and monitoring bank charges”. Siemens Case Study published by TIPCO


    Synopsis: Bank fee controlling gained traction in Germany, Austria and Switzerland with 12 corporates performing bank fee controlling for a total of 22 banks in 80 countries world-wide on a monthly basis. Global technology powerhouse Siemens is explaining how they tackled this challenge and how they are benefiting from it in the following case-study:

    Excerpt: “The most important information about bank meetings and discussions is available in an appropriate format within just a few minutes. “

    Stephan Ziegler, Head of Bank Relations, Siemens Treasury GmbH

    “Take control: manage both your bank charges & payments / collections efficiency”, CTMfile, Oct 2016.


    A look at one BSB application with a focus on analytics.

    BSB – Evolution of a Standard

    The Bank Services Billing standard (BSB) is the latest development in a long history of bank billing standards developments. Unlike prior  Electronic Account Analysis standards such as the US ANSI x12 822 which focus on a single domestic market, BSB supports requirements in all payments markets including tax and value added tax, currency and multicurrency, etc.

    The initial version of the standard was developed by TWIST in TWIST syntax. The second generation of the standard was developed by TWIST and SWIFT addressing minor corrections and moving the BSB schema into the ISO 20022 family of standards. Published in 2012, the ISO 20022 BSB specification (camt.086 in ISO20022 terminology) has seen increasing support from banks and financial application providers as well as increasing use by corporate treasury practitioners.

    BSB Timeline

    2006. TWIST BSB published 2006.
    2007. The new TWIST BSB standard sees first use by a corporate and a bank (Danske Bank).
    2008. AFP publishes Global Service Codes to standardize service item identification.
    2009. A new version of the TWIST BSB is published by ISO 20022 (camt.086) including various improvements.
    2010. The new ISO 20022 version of the standard sees first use.
    2011. CGI-MP forms Work Group 5 to harmonize use of the ISO 20022 BSB standard
    2012. A new version of the BSB standard is published (ISO 20022 camt.086 version 2), enhanced to include support for ISO 20022 Bank Transaction Codes.

    BSB Current Adoption and Availability

    As previously reported, the last BSB survey reflects the following adoption of this standard:

    • 16 banks are known to be in production with BSB (either or both the newer ISO 20022 version on the original TWIST version). Other banks may be in production but have not publically declared.
    • 13 application vendors are known to support the standard: 9 for end users (bill recipients), 4 for banks.

    The survey now in progress will provide updated statistics to be published in a future issue of the newsletter. Banks, fintech companies and end users are encouraged to participate. Information about participation in the survey may be found elsewhere in this issue.

     In Progress – The Bank Service Billing Survey

    By Bridget Meyers. Redbridge

    So far, our Bank Service Billing survey, “Speak out to get satisfaction!” has attracted 18 corporate respondents. This is encouraging, but we would like to receive more responses to strengthen our results. This is why we have decided to extend the deadline to participate in the survey.
    There is still time to participate in the surveys!

    The Corporate Survey – Corporations who have not yet responded and use or are considering use of BSB are
    invited to comment on the industry standard, how they use it, where, and whether it has met their expectations.

    Completing the corporate survey should take approximately fifteen minutes. The questionnaire can be accessed at
    the following URL:


    For each complete response, Redbridge will donate $15 to the United Nations Children’s Fund to support its work in helping children across the world.

    The Survey for Banks and Technology Providers – Along with the corporate survey, Redbridge is also conducting on behalf of TWIST and other interested parties two surveys targeting major international banks and software vendors providing BSB services. Ten banks have provided the full details regarding their BSB offer (see list below) and seven vendors. The vendor survey is now closed with summary results reported in this issue of the newsletter. The results of all surveys will be published in the next issue of the BSB newsletter.

    Banks responding to the survey thus far include: Barclays, Commerzbank, Danske Bank, Deutsche Bank, Citigroup, HSBC, SEB, Standard Chartered, Unicredit, and Wells Fargo.

    Vendors who have responded to the survey: E5, Fiserv (Weiland), Hanse Orga, Infor, Redbridge Analytics, TIPCO, Vallstein.

    Bankers, please consider responding to the survey if you have not already done so.

    Global Service Codes Taskforce Launched

    A global taskforce has been launched as a sub-committee of the CGI-MP Working Group 5 to update the AFPGlobal Service Codes. The last update was published in 2013 and banks that have implemented the AFP Global
    Code have requested some changes to the descriptions some additional distinctions in the code set.

    The task force is seeking additional feedback from the newsletter community.

    Suggestions, code requests, and ideas on how the AFP Global Code set can maintain relevance in today’s global transaction banking environment can be sent to:

    Bridget Meyer: bmeyer@redbridgedta.com or Duncan Slater: Duncan.slater@citi.com.

     Will History Repeat Itself? Standardizing Bank Billing Codes

    By Bridget Meyer. Redbridge

    What will the world learn from US bank billing?

    When electronic account analysis statements (EDI 822) were first created in the US, the large corporations leading the charge approached the AFP (then known as the Treasury Management Association) for a standard unified billing code to facilitate automated reporting. To ensure adoption of the new standard code, ANSI required a “TMA code” to be assigned for each bank service included on the electronic statement.

    Flash forward 30 years. Banks are still providing EDI 822s but the “TMA Codes” (renamed to “AFP Service Codes”) have not changed much since their original mapping years ago. AFP has traditionally updated the standard every 3- 5 years but many of the banks are still using the 2004 or 2007 versions of the codes. The outdated code lists are further complicated by bank acquisitions, reduced budgets and resources, and the constant shift in a bank’s priorities due to ever evolving regulations.

    What we have left is a mess: Banks are turning to increased fee income as interest rates stay low, the number of line items and average dollar amount being billed to corporations is larger than ever, and billing transparency is even more difficult to manage. The line item descriptions confusing and the codes are inconsistently applied across banks. Where they are used, the AFP Service Codes are mapped at a 40% accuracy rate.

    The AFP attempted to solve the problem by creating the AFP Service Code Accredited Provider program in 2002. Banks who sign up to be “Accredited” have their billing systems audited and service codes mapped by a single source to the latest AFP code standard. Accredited banks are audited annually to maintain their status. Bank adoption of the program has been slow and steady but lacks the participation and support of the nation’s largest banks. Their absence in the program does not mean that the money center banks are better at mapping. In fact, at Redbridge, we spend considerable time correcting code assignments in order to launch an RFP and analyze bank offers. The inaccuracy not only frustrates the corporate end user who wants to be able to perform a comparison of fees across banks, it creates problems for the bank’s relationship managers who try in vain to use their incorrect codes to help them respond to RFP pricing schedules.

    How can we prevent history from repeating itself?

    We are at the exact point in time where the world’s global banks will either:

    1. Learn from their earlier experiences and solidify their commitment to a standard (and the accuracy of their mapping), or
    2. They will fall into the same trap.

    The BSB format does not require a standard code nor does it specify which standard should be used. The CGI-MP bank participants have mutually agreed to adopt the AFP Global Service Codes as the unified standard used in the BSB, but there are still some who are not satisfied.

    No matter which standard is adopted, banks must establish a clear process for ensuring consistency in their assignment of the AFP Global Service Codes as they implement BSB across all billing platforms.

    Just as important, however, is to ensure on an annual basis that the mapping is still relevant and that new services are mapped with the same care.

    Whether the process is outsourced or internalized through consistent training and internal efforts, the policies and procedures for the future need to be made now. A swimming pool is transparent when clean, but muddies quickly when not maintained.

     BSB Going Forward: Hindered or helped by EU Regulations?

    Tom Buschman, Founder and CEO, TWIST

    Email: tom.buschman@edgeint.net

    As can be read in this newsletter, much progress has been made with the TWIST / ISO Bank Billing standard (BSB).
    It is accepted as the de-facto standard for the electronic billing of their services by transaction banks to their larger clients.

    Counting the successes of BSB – From a corporate-led initiative the BSB has become a truly international and open ISO 20022 standard with adequate resources for its maintenance and propagation. Multiple banks have adjusted various systems in diverse countries to generate and deliver BSB compliant messages to customers. A number of these banks have started to use the wealth of data hidden in their bills to better understand the details of what services are delivered to these customers and at what price. These banks are keen for the standard to be more widely adopted by other banks and are happy to share their experiences of BSB implementation with their peers, clients and service providers.

    A growing range of large corporates on the other hand have helped the standard through improvements and relentlessly pursue their banks with contractual requests to deliver electronic bank bills. The initial set of US-based corporates has been joined in their pursuit by many multinationals based in Continental Europe and beyond.

    A diverse group of service providers has learned how to make money out of delivering tools and advisory services for the creation, receipt and / or analysis of electronic BSB messages.

    Since there clearly is demand, there is willing supply and there are budgets spent on its implementation, the accelerated adoption of the BSB should now be assured? Perhaps not.

    Industry changing regulation in the EU – The BSB has been developed to address the needs of wholesale banking services users (corporations and others) and their banks, maintained and propagated by a relatively small community. This isolation has made the BSB a great, content rich, standard but also poses risks of being overrun by other developments that have a profound impact on transaction banks and their corporate customers in the next one to two years.

    v Policy
    v Rules
    v Regulation
    v Laws
    v Compliance

    The transaction banking industry is bracing itself for the adoption of industry-changing regulations in particular in the EU. Corporates on the other hand are increasingly impacted by their own industry-changing  regulations. These regulations are still largely not known, ignored or left to others to deal with. But in combination they will have an impact for many years to come. Also, unlike most regulations, they affect client-supplier relationships and financial services at the same time. And unlike most regulations, they come with technical open-standards-based guidance that cannot be ignored.

    Three EU driven initiatives that are happening at the same time are of particular import.

    Standards-based optimization, driven by EU governments

    1. Pan European Procurement Online (PEPPOL). In order to foster the development of a Digital Single Market, the European Union has sponsored for development of Business Interoperability Specifications for
    eCatalogues, eOrdering, eInvoicing, eAttestation (VCD) and eSignature validation. Plus Network specifications for open and secure documents exchange. The EU safeguards a fair and open market with its PEPPOL Network Governance. The result is a program now adopted by many public procurement bodies in the EU. Suppliers are contractually requested to certify themselves and issue commercial documents to government agencies through the PEPPOL network, using PEPPOL standards.

    2. Revised Payment Services Directive (PSD-2). Aimed to ensure modern, efficient and cheap payment services. And promoting innovation plus improving payment security. All payment service providers (banks and non-banks) that operate in European countries (including the UK) are adopting this PSD-2 in just over one year from now – before the end of 2017. Core component is that payment service providers are obliged to allow access to their systems for non-bank service providers as long as specific data security rules are being adhered to.

    3. Payment Accounts Directive (PAD). The objective of the EU Commission with the PAD is to help people switch payment accounts, and ensure every EU resident has access to a basic bank account. All retail banks in the EU are requested to adopt before mid 2018 standardized terminology for payment accounts across the EU and structuring in detail fee information to consumers.

    Neither SWIFT nor the European Payment Council (which was responsible for the SEPA Rulebooks) appear to be driving the development and implementation of the technical standards that are needed with these regulations.

    The EU has established the OpenPEPPOL Association for the governance and maintenance of the PEPPOL specifications. The e-Invoicing standard applied by PEPPOL is UBL, which stems from the EDI-based Edifact standards of the nineties. For the classification of products and services, the PEPPOL community is relying on GS1, which has been set up by large retailers such as Walmart to structure product coding, supplier  identification and the resulting barcoding.

    When it comes to payments standards, the European Banking Authority (EBA) was tasked end of 2015 by the EU Commission to define the technical standards that are required for both PSD-2 and PAD.

    Aligned objectives? – The BSB community has identified that treasurers and cash managers wish to implement the BSB for the following reasons:

    1. Transparency – Know what you pay and what is happening.
    2. Efficiency – Get rid of manual/paper based workflows.
    3. Simplicity – Make things easy, get analysis fast
    4. Serenity – Make your auditors happy
    5. Advice – Give strategic input to management

    Source: A soon to be published CGI-MP corporate case study The Business Case for BSB for Corporates”.

    The UK’s healthcare authority has identified the following benefits to buyers and suppliers from widespread
    implementation of the PEPPOL framework in the healthcare sector:
    1. Reduction in data input errors
    2. Reduced transaction costs and cycle times
    3. Planning and forecasting
    4. Improved performance through supplier measurement information
    5. Faster payment
    6. Improved management information
    7. Vendor Managed Inventory / self-billing
    8. Improvements in Just in Time deliveries
    9. More accurate deliveries due to reduced input order errors by suppliers
    10. Reduced stock due to shared sales/forecast information

    Based on studies by McKinsey, the UK government expects to save between USD 3.5 and USD 6.0 million per average sized hospital per year with the implementation of the PEPPOL framework.

    With regards to access to banking systems, the EBA has stated that its standards “will ensure appropriate levels of security, while at the same time maintaining fair competition between all payment service providers and  allowing for the development of user-friendly, accessible and innovative means of payment.”

    And the EBA’s technical standards for billing of retail bank services are “aimed at enhancing the comparability of fees through standardized terminology and disclosure documents across the European Union. This will  allow consumers to compare offers from different payment services providers and to make informed decisions on the
    payment account that best suits their needs.”

    These objectives appear to be very much aligned. The devil however is as always in the detail of the standards that are applied.

    Push for implementation in 2017 – The PEPPOL framework is operational with hundreds of service providers. The EBA technical standards have been developed and were this summer subjected to public  consultation. The EBA is expected to formally publish them before the end of 2016.

    All banks in 27 EU countries will then have until the end of 2017 to implement the EBA’s technical rules for virtually all their payment services with regards to access to account. And all retail banks have until mid-2018 to implement the EBA’s standards for billing.

    All this has significant impact on the data management and application of security by all retail banks in the EU, including the UK. Plus opens up their market to lightly-regulated third party solution providers.

    Relevance for the BSB standard – The PEPPOL and EBA standards will be rolled out alongside the ISO 20022 standards, including BSB. It will be hard for banks that service public authorities in the EU to ignore  PEPPOL. And where the processing of bank bills is increasingly seen by corporates as part and parcel of their standard procure-topay process, corporate treasuries and their bank providers will likely have to pay notice to the PEPPOL framework as well.

    With the coding of bank services seen as complex and unstructured by corporate treasurers, the GS1 standards may be seen as a welcome alternative. The treasury community can also seek inspiration from the EBA  standards for retail payment services, which present clear and easy-to-understand templates including instructions for banks on how to fill in these templates.

    And if banks cannot deliver the bank bills in the required structure to corporates, third party service providers could offer translation services and gain access to bank systems by applying the EBA technical rules for access to account.

    The Opportunity for BSB Community – It would be a shame if the BSB standard would be overtaken by events without ensuring that new standards fulfil in detail the benefits that corporates and banks obtain from the BSB.

    There is enough time in the coming months for the BSB community to analyze these EU regulations and technical standards in detail. There is also enough time to drive the direction of their adoption.

    The BSB community could decide to engage with PEPPOL and EBA and through PEPPOL with GS1 with the objectives to:

    1. Ensure that minimal additional investments will have to be made by banks and treasurers to leverage on the standards of PEPPOL, EBA and GS1. And
    2. Further accelerate the growth of the BSB in connection of these standards and the regulations that drive them…

    The Vendor Survey Results – The results of the vendor survey are just in! Of the 15 fintech companies known to be providing bank billing related capabilities, 7 have responded. See below for an initial view of the  results. A more detailed view of the responses will be made available in future.

    BSB Q&A

    A full list of Frequently Asked Questions including those carried in the last newsletter. Additional contributions

    1. Q: What is the “Bank Services Billing standard (BSB)”?
    A: The BSB standard defines an electronic statement that can be sent by a bank to its wholesale customers
    (e.g., corporations, governments, institutions) detailing their usage of financial services and their related
    charges. A BSB statement includes volumes and associated charges for all billable services rendered during
    a billing cycle, usually one month. In addition to its use as a statement for which it was designed, BSB may
    be used as an e-invoice in most countries.

    2. Q: Why was BSB created?
    A: This standard was developed by TWIST at the request of a corporate interest group, led by General

    3. Q: What value does it offer corporations and other wholesale bank clients? And banks? /ol>
    A: BSB has been created to help corporations:

    • Enhance control over the cost of banking services
    • Automate account reconciliation and account for bank fees
    • Simplify the task of complying with market regulations such as Sarbanes Oxley
    • From the perspective of the bank, BSB represents a new information product which helps differentiate bank transaction services

    4. Q: What information is included in a TWIST BSB statement?
    A: A TWIST BSB statement is designed to report on all bank services rendered during the reporting period. A
    BSB statement includes:

    • For one or more accounts in a client/bank relationship
    • For a defined period in time, typically the most recently concluded monthly bank billing cycle
    • Identification of all chargeable services used in the period
    • The volume of those services during the period
    • The per item and total charge for those services
    • Select balance and interest information
    • Relevant tax information

    5. Q: Where can BSB be used?
    A: For reporting of periodic bank fees, any & all countries. BSB is offered in approximately 100 countries
    today. Note: A small number of countries may disallow use as an e-invoice.

    6. Q: What reporting period do the BSB statements cover?
    A: Any period as agreed between the bank and its client. A single calendar month period is most common.

    7. Q: What industry recognized codes can be used in the optional element to identify service fees? <
    A: Different code series may be used to identify service fees including bank proprietary codes as well as the
    Global Service Codes published by the AFP.

    A: They are the same thing! TWIST BSB is the first version of this standard. TWIST has worked with ISO
    20022 and SWIFT on newer versions of the standard to allow the publication of BSB as a part of the ISO
    20022 family of financial services standards. ISO 20022 camt.086 continues to be managed by TWIST as
    submitter and contains certain fixes and enhancements over earlier versions of this standard.

    9. Q: How does it relate to the US standard ANSI x12 822 Standard?
    A: Conceptually, BSB is the global equivalent to the ANSI 822. Essentially a superset of the 822, BSB
    includes virtually all of the substantive business requirements and capabilities found in the 822. BSB
    accommodates multi-currency and value added tax, features not found in 822.

    10. Q: How does BSB impact existing business bank practice regarding service fee billing?
    A: BSB is a control tool. It has been devised to complement existing activities, such as invoicing and account
    reconciliation, not to replace them.

    11. Q: If a statement contains one customer account, how can sub accounts be implemented?
    A: A BSB message supports multiple statements as well as multiple accounts. In fact a statement can be
    articulated in a hierarchy of parent and child accounts all identified by codes, to reflect most organizational

    12. Q: What does a BSB “communication exchange” looks like? Are there any other standard messages involved
    (e.g. acknowledgement, status)?
    A: In a BSB communication only the TWIST BSB message is provided as a standard document. In fact the
    purpose of a BSB communication is fulfilled when the BSB message is delivered from the originator to a
    recipient. How the message is sent and received, frequency, method of transmission (push/pull), and security
    are all out of the standard’s scope and are agreed between the sender and the receiver. Internet protocol
    based file transmission, SWIFT FileAct and other means are all currently used to send BSB files from banks
    to their wholesale clients.

    13. Q: What reporting period do the BSB statements cover?
    A: Most frequently, the reporting period is one month. The period used is bilaterally determined by the bank
    and their client.

    14. Q: What codes may be used to identify billing line items?
    A: The AFP’s Global Service Codes, bank proprietary codes, as well as other code series may be used. As
    of the latest version of camt.086, the ISO 20022 Bank Transaction Codes are also supported. The actual
    codes used are dependent on the reporting banks abilities. As a global standard, use of the AFP’s code
    series is encouraged.


    Editorial Board.

    • Robert J. Blair, Consultant, ASC x9 and TWIST Standards.
    • Andrew W. Griebenow, HSBC
    • Emmanuel Léchère, Redbridge DTA (ex bfinance)
    • Sandrine Legoff, BNP Paribas
    • Bridget Meyer, Redbridge Analytics (ex The Montauk Group)
    • Jacques Molgo, Air Liquide
    • Lisa Novick, Citi
    • Martin Postweiler, Hansa Orga
    • Hubert Rappold, TIPCO


    • AFP – The Association for Financial Professionals
      • The US national treasury practitioners association.
      • Publisher of the US and global versions of the Electronic Account Analysis (aka BSB) Service Codes–Source of the billing fees codes list as well as a whitepaper providing details on its history and use.
      • http://www.afponline.org/servicecodes/
    • CGI-MP – Common Global Implementation-Market Practice
    • ISO 20022 – International Standards Organization
      • Current version of the standard BSB (ISO 20022, camt.086) and related documentation. including:
        • Message Usage Guide describing “…the data content requirements of the Bank Services Billing (BSB) standard as defined by ISO 20022.” A useful guide for implementers.
        • A sample file as well as a field by field cross reference document: ISO 20022 to TWIST to ANSI x12
      • ISO 20022 Newsletter with periodic coverage of BSB
      • https://www.iso20022.org/display_news.page?dataitem=en/20120716_bsb_publication
    • TWIST – Transaction Workflow Innovation Standards Team
    • Wikipedia
      • A non-technical introduction to the standard.
      • https://en.wikipedia.org/wiki/Bank_Services_Billing_Standard
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  • 12.01.2016
    Press Release

    Redbridge Analytics grows sales team

    Software arm of debt & treasury advisor Redbridge enters new stage after release of bank fee monitoring solution HawkeyeBSB

    Press release – Houston, Thursday 1st December 2016

    Redbridge Analytics, the software arm of the debt & treasury advisory specialist Redbridge DTA, is pleased to announce the recruitment of two senior relationship managers, Scott Hansen and Dave Strand.

    • Scott Hansen has worked in global corporate treasury for more than two decades with a broad base of bank relationship management, bank fees, foreign exchange and treasury solutions. He joins Redbridge Analytics from Fiserv, where he worked with hundreds of Fortune 1000 companies within the Weiland Corporate division.


    • Dave Strand (CTP), joins Redbridge Analytics from Weiland Corporate Solutions at Fiserv. Dave has twenty plus years of achievement with client engagement and sales in the financial products arena focusing on corporate bank fee & account management products, FX solutions and payment platforms.


    Scott and Dave will be responsible for bringing Redbridge’s next generation of Bank Relationship Management software solutions to the treasury world. Their recruitment marks a new stage in the team’s development, following the release this fall of Redbridge’s product for bank fee analysis and account management, HawkeyeBSB, and the launch of a new website                                                     (www.redbridgeanalytics.com).

    “I am very pleased to be joining Redbridge Analytics at such an exciting time. I have always been astonished by the error prone nature of bank fee billing. Treasury teams need a system to easily monitor, manage and establishing accountability in their banking relationships”, comments Scott Hansen.

    “I am excited to be presenting HawkeyeBSB’s interactive capabilities to corporate treasurers and helping them solve the problem of bank fee management and monitoring in a modern, intuitive, time-saving way. This solution goes beyond the typical spreadsheet display of data allowing for full fee visibility across all data formats”, says Dave Strand.

    Announcing the appointments today, Dan Gill, Senior Director of Redbridge Analytics, says: “We are delighted to welcome two treasury software experts of Dave and Scott’s caliber. Their in-house experience from a pioneer vendor of bank relationship management solutions will prove extremely valuable in further supporting our clients”.


    About Redbridge Analytics

    Redbridge Analytics is the software arm of Redbridge. The team, composed of nationally recognized treasury experts, provides automated solutions dedicated to the analysis and the management of bank relationships. Its products benefit from the expertise of Redbridge DTA, its sister company which delivers advice to corporate treasuries and finance departments worldwide since 1999. For more information, please visit www.redbridgeanalytics.com.


    About HawkeyeBSB

    HawkeyeBSB is the first solution designed by Redbridge Analytics which brings to the corporates an unprecedented visibility on their bank fees. This solution is designed to scrutinize every line item on each bank account analysis statement each month, domestically and globally. To the benefit of its corporate users, it will ensure that cash management service providers are complying with contracted service terms.

    Learn more on HawkeyeBSB – Watch the video


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  • 11.01.2016

    Why AFP Codes are the global standard for bank fees

    Treasurers should be stressing the importance of discussing account analysis statements when looking at a new non-U.S. bank relationship, write Tamir Shafer and Stephan Ireland

    Historical Perspective

    When electronic Account Analysis statements (EDI 822s) were first created in the United States during the mid-1980s, the large corporations leading the charge approached the Association for Financial Professionals (AFP) – then known as the Treasury Management Association (TMA) – for a standard unified billing code to facilitate automated reporting. To ensure adoption of the new standard code, the American National Standard Institute (ANSI) required a ‘TMA code’ to be assigned for each bank service included on the electronic statement.

    Fast-forward 30 years, and EDI 822s are still the standard for electronic delivery of domestic US bank fee activity. However, the TMA codes (renamed since as AFP codes), have not drastically changed since their original mapping. To their credit, the AFP has traditionally updated their standard every 3-5 years. Despite this refreshing, many banks are still using the 2004 or 2007 versions of the AFP codes.  The outdated code lists are further complicated by bank acquisitions, reduced budgets and resources in bank back-offices, and the constant shift in banks’ priorities due to ever evolving regulations.

    Obfuscation vs. Transparency

    As interest rates hover at historic lows and lending capabilities remain constrained, banks are now turning more to alternative areas to generate fee income (e.g., cash management fees). The number of service line items and average dollar amounts being billed to corporations for cash management services is higher than ever. Billing transparency is even more difficult to manage. Not only are the service line item descriptions confusing and the nomenclature different from bank to bank, the AFP codes that are mapped and assigned (if assigned at all) by banks are mapped at only a 40% accuracy rate; the exception being the eight banks whose service codes mapping have been accredited and approved by the AFP. The inaccuracy not only frustrates the corporate end users who want to be able to perform an apples-to-apples comparison of services and fees across their banks, it also creates problems for the bank relationship managers who try in vain to use what should be correct codes to help them respond to RFP pricing schedules sent by corporate treasury departments.

    Tom Wolfe, Senior Director of Global Treasury at Marriott Vacations Worldwide chose a pragmatic middle ground to monitor cash management fees. His company, a former subsidiary of Marriott International, manages over 60 resorts globally under the brands Marriott Vacation Club, The Ritz-Carlton Destination Club and Grand Residences by Marriott. With operations in more than ten countries, Marriott Vacations’ corporate treasury department deals with about fifteen banks.

    Regarding domestic U.S. activity, as account analysis statements and the services & fees data contained within are obtained rather easily, corporate treasurers often download these files and then populate data into a spreadsheet. At a minimum, this data typically includes average collected balance, the earnings credit rate, gross fees charged and net fees paid. “The objective is to determine how each bank calculates the average collected balance, to make sure that the ECR is the one we negotiated, and to determine how much we must hold on deposit at the bank to offset our cash management fees. These days, with the ECR being as low as it is, we analyze the breakeven point very carefully,” says Tom Wolfe. “It might not be the most comprehensive approach, but it allows me to get key information quickly to my management.”  Moreover, for its three largest bank relationships, Marriott Vacations Worldwide has hired a third-party to assist in monitoring the details contained within their monthly account analyses, for its domestic U.S. cash management activity.

    Given the many imperfections, monitoring bank fees is a viable and value-add process in the U.S.  Going forward, banks must establish a clear process for ensuring consistency in their assignment of the AFP codes at the stage of adoption across all billing platforms (as several of the larger banks have more than one billing platform). Just as important, however, is to ensure that on an annual basis, the AFP code mapping is relevant and accurate, and that new services implemented by each bank are mapped with the same care.

    International Fees is the New Wild West

    Even with the imperfections that exist domestically, the situation is far less evolved at an international level. “In most cases, we do not receive account analysis statements for international activity like we do in the United States. The only way we can analyze our bank fees in a meaningful way is to look at the bank statement and filter out for a specific code. While this tells me how much we are paying in fees, it unfortunately does not necessarily indicate which bank service it relates to”, explains Tom Wolfe.

    To overcome this challenge, Marriott Vacations Worldwide relies heavily on global banks that can provide an account analysis statement on a consistent basis, and who also have domestic bank relationship managers that can easily step in and manage communication breakdowns with local bankers in other countries. “The one-off banking relationships in other countries are time consuming. They require a lot of communication. We have to get them to help us understand their central bank’s requirements, restrictions on movements of cash, etc. We also have to drive the communication to make sure they understand our needs, and that we understand what they are going to be able to provide, including the costs,” says Wolfe.

    Setting a Global Standard

    Treasurers should be stressing the importance of discussing account analysis statements when looking at a new non-U.S. bank relationship. “The formats offered and their availability is definitely something to ask banks as part of an RFP. If I could wave a magic wand, I would like to see a global standard for bank fees,” Wolfe adds.

    Thus, we are at the exact point in time where the global banks will either learn from the U.S. and solidify their commitment to setting up and implementing a standard (and the accuracy of their mapping), or they will fall into the old trap.  The Bank Service Billing (BSB) format does not require a standard code nor does it specify which standard should be used. The Common Global Implementation (CGI-MP) bank participants have mutually agreed to adopt the AFP Global Codes as the unified standard used as part of the BSB, but there are still some who are not satisfied.

    No matter which standard is adopted, global banks must establish a clear process for ensuring consistency in their assignment of the AFP Global codes at the stage of adoption, across all of their billing platforms. Similar to the US in the 1980s, Corporate Treasurers can play an important role in the adoption of a global standard. If enough Treasurers ask for it, their banks will provide it. Ask and ye shall receive…

    Tamir Shafer is a Senior Director and Stephan Ireland is a Managing Director, both with Redbridge Debt & Treasury Advisory.

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  • 10.01.2016

    Redbridge at AFP Annual Conference 2016

    The Redbridge team is excited to be returning to the AFP Annual Conference in 2016 to present our insights on the most important developments, trends and opportunities within treasury management. Our delegation of industry experts will be available for meetings on current topics, including those related to treasury service & fee optimization, merchant cards, credit ratings, fundraising and debt structuring. As you plan your attendance for AFP 2016, be sure to make time to visit us at our booth, schedule a meeting, or attend one of our five thought leadership sessions.


    Educational Sessions

    De-Coding Your Analysis Statements

    Dive into the wealth of information contained in your bank account analysis statements. Participants learn the AFP guidelines for account analysis statements, how electronic statements work, how AFP Service Codes could and should be assigned, and perform their very own cross-bank comparison. Have accounts overseas? Learn how to gain visibility into international bank fees and what the industry is doing to make things better. Participants are encouraged to bring their own account analysis statements to the session to begin building their own cross bank comparison model.


    Bridget Meyer, CTP, Senior Director – Redbridge


    Unlocking the Mysteries of Bank Fees

    How we manage our relationships with our banking partners is often clouded in mystery. We are tasked with not only knowing what services we are buying from our banks but also controlling the costs of those services. Account structures must be justified in short amounts of time. In this session, speakers discuss foolproof strategies to manage your bank fees and bank relationships in less time than ever, using such AFP Codes and pricing guides in order to put treasurers in the strongest possible position.


    Daniel Gill, CTP, Senior Director – Redbridge


    Effectively Managing Rating Agency Relationships

    This panel of two corporate practitioners and one rating agency executive will be moderated by an industry expert in a question-and-answer format to provide the attendees with personal insights and perspectives on best practices in building good working relationships between companies and rating agencies.


    Marci Lerner, CTP, Treasurer – Hologic Inc

    Catherine Stone, Assistant Treasurer – Cabot Corporation

    Michael Lenihan, Senior Advisor – Redbridge DTA

    Brian Oak, Managing Director, Corporate Finance Group – Moody’s Investor Service

    Treasury and Bank Relationship Management in Asia

    An increasingly complex and changing banking environment in Asia requires Treasurers and CFOs to be constantly up to date on local regulations and best practices. What are the challenges that make treasury management in Asia so different from the domestic US? This session uses a real corporate case study to deep dive into domestic cash and liquidity management in 8+countries in APAC in order to map out the various possibilities to build a consistent and sustainable treasury organization at regional level..


    Catherine Stone, Assistant Treasurer – Cabot Corporation

    Helene Shen, Associate – Redbridge DTA

    Collecting, Benchmarking and Negotiating International Bank Fees

    Unlike the US where nearly all commercial banks have adopted an account analysis approach to documenting services, volumes and fees, the international landscape is quite different, with fewer standards and with differentiation from country to country, region to region, and even bank to bank. In this session, the speakers will discuss the full process of collecting, benchmarking, and negotiating domestic and international bank fees. Speakers focus on the main differences between payments and collection in Europe, Asia, and the US, and ways to reconcile them.


    Tom Wolfe III, CTP, Senior Director, Global Treasury – Marriot Vacations Global Corporations

    Tamir Shafer, Senior Director – Redbridge DTA



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  • 09.01.2016

    The consumer financial protection bureau is watching out for consumers – who is watching out for corporates?

    Corporate treasurers must now become more vigilant than ever in monitoring the inventory of bank accounts, the services and volumes their banks are claiming were used, and the rates applied to these volumes, each and every month, write Daniel Gill and Tamir Shafer.

    A few days ago, we learned that the Consumer Financial Protection Bureau (CFPB) levied the single biggest fine in its history ($100 million) to Wells Fargo for fraud. In all, Wells Fargo is paying fines totaling $185 million – without admitting guilt – related to this fraud. These fines were caused by the improper opening of checking accounts and credit cards. In other words, bank personnel were opening up accounts for their clients, without their clients’ permission, in order to meet sales volume goals to trigger compensation incentives. Over 5,300 employees were fired due to their actions associated with this activity.

    Apparently, the pressure and incentives were high enough to cause more than 5,000 people – in a single company – to commit this fraud.  Without knowing all of the specifics of the incentive-based compensation structure or the required sales goals, it speaks to just how hard it must be to be a successful retail relationship manager in an environment such as this. Stories are now coming out about the intense pressure to sell more products, including the internal bank slogan of “Eight is Great!” referring to the target of having each retail client of the bank owning eight different bank products at a minimum.

    The CFPB, acting on behalf of regular consumers, is doing precisely what its mandate sets out for it do: “To make sure that banks, lenders, and other financial companies treat you fairly.”

    While this situation is an excellent example of why this type of regulated authority is needed to protect consumers, it is important to note that there is no comparable regulated authority to protect corporations in the same way, from the various revenue generation tactics employed by banks.

    While we don’t know at this point if there were any fraudulent accounts opened on behalf of corporate clients of Wells Fargo, nor do we know if any additional services were added to corporate accounts, this incident and those that are sure to follow speak volumes about the culture that we are dealing with.  While every corporate treasury department needs to be diligent in negotiating the most effective banking relationships with each of their banking partners, it cannot end there.  Corporate treasury must now become more vigilant than ever in monitoring the inventory of bank accounts, the services and volumes their banks are claiming were used, and the rates applied to these volumes, each and every month. Given the number of banks, services, accounts and data we are talking about, being vigilant without using state of the art tools or expert advisors is nearly impossible.

    Part of Redbridge’s responsibility, and incumbent as part of our Hawkeye service, is to do just that: monitor our clients’ monthly commercial bank fee invoices. Over the last several years, we have seen billing violations and errors that average $54 for every $1,000 in fees levied by commercial banks. That’s more than 5%. These billing violations and errors typically stem from:

    • Services added without approval from the client;
    • Bank accounts not closed timely;
    • Unapproved price increases on certain services; and
    • Reductions in yield.

    In some cases, these billing mistakes are explained away fairly; in many others, our clients are left to push their relationship managers to retrieve credits from their banks,  as their banks have already auto-debited the bank account for these fees owed, including these billing violations.

    Who is monitoring your commercial bank accounts and looking out for you?

    Authors: Daniel Gill & Tamir Shafer

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  • 09.01.2016
    Press Release

    Daniel Gill joins Redbridge Debt & Treasury Advisory

    Former leader of Weiland Corporate Solutions to develop the next generation of Bank Relationships Management software solutions.

    Redbridge, the leading advisory firm that provides solutions to corporate treasury & financing departments worldwide, is proud to announce the appointment of Daniel Gill as Senior Director.

    Daniel Gill, Certified Treasury Professional, is a nationally recognized treasury expert who has worked over the last two decades with hundreds of Fortune 1000 companies in developing strategies to monitor, audit, and optimize their bank relationships and bank fees. He joins from Fiserv, the provider of technology solutions to financial institutions, that acquired Weiland Corporate Solutions, which Daniel had joined in 1998.

    At Redbridge, Dan will be responsible for developing the company’s new generation of Bank Relationships Management software solutions for corporate treasurers: Hawkeye BSB. He will co-lead Redbridge’s Analytics department with bank fee expert Bridget Meyer.

    Daniel Gill, Senior Director, Redbridge DTA commented: “I have found my perfect job. I believe to my core that corporate treasury needs solid advisors and systems to manage their bank relationships and the ever increasing cost of those relationships. Redbridge has built a dream team of experts, methods and systems that grant the corporate treasurer unprecedented visibility into their bank relationships.”

    Stephan Ireland, Managing Director – North America, Redbridge DTA commented : “Daniel has developed some of the greatest bank relationship management, bank fee management and bank account management software available in the market. His joining marks a new stage for Hawkeye BSB, our solution that automates the bank fee analysis process for mid- to large-sized companies, governments and universities”.

    End –

    Contact Redbridge

    Email : news@redbridgedta.com

    About Hawkeye BSB – Automatic integration of bank reporting files

    Hawkeye BSB is an innovative solution to scrutinize every line item on bank account analysis statements each month, domestically and/or globally, and to ensure that cash management service providers are not committing billing violations.

    Price increases, price inconstancies, new services added, calculation errors, missing data points, changes in ECR/Interest rate… On average, errors identified in bank invoices represent between 2% to 5% of the invoice, irrespective of the country. That is the level recorded by Redbridge teams who have been assigned to analyze and inspect bank charges throughout the world. For treasury departments, reviewing and monitoring these costs in detail for accuracy requires time and expertise that most simply do not have.

    To efficiently manage the review and the monitoring of bank fees and services domestically & globally, Redbridge has developed Hawkeye BSB, a solution that enables corporations to precisely measure consolidated bank charges linked to cash management transactions (costs of payment methods, account-keeping, centralization, communications, reporting, etc.) for all banking partners worldwide. The solution monitors changes in prices and volumes of each transaction processed (by country/legal entity/bank, etc.) and verifies the correct application of the conditions negotiated and, more broadly, verify the amount paid by companies with respect to cash management.

    By electronically receiving, processing and analyzing billing statements, Hawkeye BSB helps corporate treasuries gain complete control over their bank relationships.

    For more information, please visit: http://www.redbridgedta.com/us/solution/bank-account-analysis/

    About Redbridge –

    Redbridge is a leading advisory firm that provides solutions to corporate treasury & finance departments worldwide. The company has been created after the merger of the US-based bank relationship management company The Montauk Group with bfinance’s debt & treasury advisory teams, operating in Paris since 1999.

    Redbridge has developed strong relationships with Fortune 1000 companies, mid- to large-sized companies, universities and governmental organizations. Given its ability to offer complex and innovative solutions on a global scale, Redbridge contributes to the development of publicly and privately held companies by supporting all of their treasury and financing projects.

    Expertise – Debt Advisory

    • Debt structure advisory
    • Corporate liquidity management
    • Identification of alternative sources of funding
    • Credit profile optimization
    • Optimization of credit terms & conditions
    • Leverage & acquisition financing
    • Corporate banking refinancing
    • Asset-backed finance
    • Project finance
    • Management of lender relationships

    Expertise – Treasury Advisory

    • Bank relationship management, including bank services review, price benchmarking, and optimization
    • Cash pooling solutions
    • Credit/Debit card payments
    • Monthly bank fees monitoring
    • Selection & implementation of treasury management systems
    • Consulting services for corporate reorganizations (carve-outs, post-mergers, acquisitions, etc.)
    • Financial risk management

    For more information, please visit www.redbridgedta.com/us

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  • 07.01.2016

    Brexit: a guide for treasurers to manage the uncertainty

    The most influential variable for optimal decision making is not based upon accurately utilizing and pricing all available information; rather, it is the inability to place any acceptable degree of confidence on the variable for uncertainty over future potential outcomes. Managing such uncertainty is precisely the challenge the corporate finance community faces after Britain’s recent referendum to withdrawal from the EU, writes Bob Callahan, Director at Redbridge DTA.

    In BREXIT: A Guide for Treasurers to Manage the Uncertainty, Redbridge DTA offers thought leadership to senior corporate finance executives on managing the challenges, risks, and opportunities in reaction to the impending changes to the landscape for global trade. Our objective is to provide the requisite tools and relevant information to enable corporate treasurers to efficiently manage the initial shocks and the impending secondary, tertiary, and quaternary disruptions.


    The Certainties – What we know

    Before outlining the challenges for the corporate finance community arising out of Brexit, it would be helpful to address the few certainties available. The three most important are:

    1.      The oft alluded to 2 year countdown clock does not actually begin until Britain’s Prime Minister goes to the European Commission (EC) to formally state the government’s desire to exit.

    2.      The period can be extended through a mutually agreed upon new time frame.

    3.      Any renegotiation requires a “qualified majority” of member states.


    The Uncertainties – Considerations for Corporate Treasurers

    Foreign Currency

    Sterling weakness was the first shock, followed by a lower Euro, and a flight to quality as stable currencies saw large inflows. The pound will continue to weaken while the Euro could strengthen as the Union may rally together. Either way, global trade is being redefined and corporate treasurers face challenges in every area of their operations.

    The overriding objective for treasurers, therefore, is to manage currency exposures and to determine the best means by which to protect profit margins from the volatility.

    Within a comprehensive analysis, treasurers must do the following:

    I. Systematically recalculate all exposures to Britain and to the EU, both currently and for their long-term growth plans.

    II. Understand that the value of protecting profit margin from volatility through hedging is relative to costs & revenues that are affected by foreign currency exposures. Generally speaking, creating a stable environment by eliminating volatility is the optimal option since it allows treasurers to more effectively plan for the future.

    III. Focus on the effects to the balance sheet by identifying new translation risks. Be mindful of translation exposures affects on credit ratios and cash flow measurements, which may be relevant to debt covenants. One option is to consider switching to local suppliers to better manage foreign currency risks by matching revenues and costs.

    IV. Evaluate the value of changing the functional currency.

    V. Determine new hedging costs and, given growth plans, where expectations for future hedging costs may be.

    VI. Explore the value of implementing currency adjustment clauses into customer and supplier contracts. Such a strategy can be a cost effective means to managing currency risk and minimizing hedging costs.



    An environment with higher funding costs in the UK is nearly certain. Why? Because markets dislike uncertainty and we are in an uncertain environment. Likely triggers are cited in I – III. Areas upon which treasurers should focus are:

    I. As sterling debt will likely be considered riskier, banks could face higher borrowing costs from the Bank of England (BoE) which, in turn, would mean higher rates for corporations.

    II. If the pound continues to fall, the BoE may have to raise rates to defend the currency.

    III. All three major rating agencies indicated that a UK exit would be credit negative. Britain is therefore facing a downgrade. If Britain were downgraded, corporations face lower credit ratings and higher funding costs.

    IV. As a UK based business, do you borrow from the European Investment Bank (EIB)? If so, do you have contingency plans? If not, do the businesses with which you transact have such exposure?

    V. To what extent will your debt financing be impacted by the exit? Scenario analysis will provide results from a variety of changes to variables and coefficients.

    VI. To implement strategic reviews for a company’s funding sources is essential to managing outcomes.


    Counterparty Risk

    Credit ratings are a common tool used to select counterparties for banking relationships, which assists in meeting internal policies for managing exposure limits. On the backdrop of recent events, a review of current and potential increases to counterparty risk is essential. Essential considerations for treasurers are:

    I. To communicate with corporate banking relationship managers to obtain early guidance for any bank withdrawing from any specific line of business OR if the counterparty will become a different entity within the organization. Doing so may change the credit rating of the counterparty.

    II. To redefine credit limits with British companies, reflective of new environment.

    III. To examine value of taking out credit insurance against suppliers/customers.

    IV. To limit not only individual credit exposures but also operational exposures to British banks.

    V. To review contracts for changes to terms and conditions that could have trigger events.


    Banking Relationship Management

    Arguably the most important consideration on which treasurers must gain control is in BRM. Banks are at the forefront of changes and will define the longer-term landscape. Communicate with your banker concerning the following issues:

    I. How will current banking relationships change and will they remain appropriate for your needs?

    II. To understand the changes in bank abilities, particularly UK-based banks which will face uncertainty surrounding their ability to offer services in the EU. Verify what you are told.

    III. Review existing facilities and the applicable currency to the RCF, paying particularly close attention to off-balance sheet funding, which is often overlooked in normal reporting.

    IV. What will be the effect on Passporting rights, particularly for UK regulated entities? Big US banks that have set up large regulative business operations in the UK and then used their right to passport into the EU are not immune, although many have EU operations to which they can transfer operations.


    Cash Management

    The most complex of a treasurer’s challenges, since it incorporates all other areas, including funding, foreign currency exposures, and overall banking relationships is cash management. Among areas to explore for potential problems are:

    I. Determine what the UK’s participation in the Single Euro Payments Area (SEPA)  means for companies. Will, for example, additional charges be implemented and passed on to companies? This is particularly bad news for companies with centralized accounts in the UK for the purpose of cash pooling to optimize liquidity.

    II. Reviewing all cash pooling arrangements, particularly as negative rates in the EU drive central banks to stop current accounts from being used to park cash. Prepare contingency plans since a change to continental Europe may be the best option, at least until laws, regulations, taxes, and trade agreements are fully known.

    III. Potential system changes need to be implemented.

    IV. Whether sufficient ST liquidity needs are met. Incoming and outgoing flows will be volatile and working capital needs must be managed forward under worst case scenarios. Explore option to extend working capital cycle.

    V. To act very early on any sterling refinancing needs.

    VI. Whether new trading companies or off-shore account structures need to be created.

    VII. To explore challenges with intercompany lending and run scenario analysis to determine optimal structure.

    VIII. Whether treasurers should review all financial contracts with different counterparties, including suppliers, banks, and clients to ensure continuity and to mitigate risks.

    IX. To determine the level of reliance on UK banks from a cash management POV. There might be a need to switch banking partners, or at least secure access to alternative banks that are based in the Eurozone.


    General Risk Management

    It is essential to review and revamp your organizations current risk management framework. To do so, it is best to develop a comprehensive scenario analysis for contingency planning. Issues to explore are:

    I. How your organization’s profile will change, particularly if your business location was specifically chosen to optimize cross-border trade.

    II. Whether creating a committee with representatives from different areas makes sense. The objective would be to ensure all company exposures are managed in sync.

    III. To consider an alternative treasury and trading model, or at least a module to adjust for changes.

    IV. How reporting may change, specifically related to risk management.

    V. How data protection, data transfer, and data sovereignty may be effected.

    VI. How to prepare for a total revamp of treasury policies to comply with new agreements.

    VII. Whether the concept of “equivalence” will remain.



    First, new trade agreements with countries and regions will take years to formalize, creating complete uncertainty for the business community for an extended period. Periods of uncertainty are always bad for business. After all, who would want to invest in new projects, expand operations & hiring, renew leases, and launch new businesses or projects without knowing the rules, taxes, and regulations that will exist in the future? Secondly, it is highly improbable that Britain will negotiate a more favorable trade agreement with the EU. In fact, the incentive for member states is to offer much less favorable terms. If more optimal terms were offered, remaining members would question the value of the Union and increase the chances of a total collapse.

    To further demonstrate Britain’s poor negotiating position, according to Britain’s Treasury Department, only 3.1% of EU GDP depends on trade with Britain whereas 12.6% of British GDP depends on trade with the EU. Moreover, according to Britain’s Office of National Statistics, over 44% of Britain’s total exports go to the EU and 53% of all goods and services imported to the UK come from the EU. One wonders what leverage Britain really has and why would remaining members agree to provide the UK significant access to the single market without requiring acceptance of EU regulations or require Britain to make contributions to Brussels to support the Union?

    Clearly, Brexit will create unanticipated dislocations due to the long period of before stability returns and, without pro-active and comprehensive management of the operational, structural, and performance related effects treasurers will face, significant risks lay ahead. The challenge to successfully manage through Brexit lies in efficiently managing uncertainties. To do so, Treasurers must confront all the potential organizational risks, systematically establish a plan of action for each detrimental effect to current operations, and continually adjust the internal strategy as the probabilities of such outcomes increase or decrease.


    Author: Bob Callahan

    Bob Callahan, Director at Redbridge Debt & Treasury Advisory North America, holds almost 20 years of global finance experience. In the 1990’s, he made equity markets for Fidelity Investments. By 2005, he had moved to a Frontier/EM debt hedge fund, focusing on performing & distressed/recovery credits. In 2010, Bob launched and later ran Banco Bradesco’s NY fixed income dealer desk. Since 2013, Bob has been a global consultant to corporate finance executives, joining Redbridge DTA in 2015. He has a B.A. from UT, Austin in Economics & English Literature, and a Master’s degree from Columbia University’s School of International and Public Affairs, with a concentration on International Finance and Business.

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  • 06.01.2016

    Bank financing within the EU: competitive, yet still lacking in efficiency

    An operational analysis of the European market for bank financing for large corporations reveals major pricing disparities among lenders, with indicative spreads that can vary by up to 100% within the same facility.

    Due to a lack of public information on existing deals, bank financing is not subjected to the competitive forces necessary for a truly efficient market. The syndicated loan market reflects the challenges borrowers face in a non-transparent environment since such conditions seriously impede a corporation’s ability to accurately benchmark the relative value of a transaction.

    To create an optimal funding strategy, corporations must understand the nuances within the bank debt market, including knowledge of the most competitive terms and conditions for similar corporations. To this end, Redbridge DTA analyzed 10 financial transactions of BB and BBB rated companies over the last 12 months. Each company initiated an RFP to establish a revolving credit facility (RCF).

    The results of the exercise revealed large pricing disparities among banks. Despite conditions generally favorable to borrowers and in an environment with tight spreads, the first round of quotes showed significantly divergent levels among the banks.

    1 ecarts de cotation US

    Credit Risk

    Why such differences? According to the sample, banks do not appear to share similar assessments of borrowers’ credit risks. The differing views can create rating disparities of up to two notches.

    Based on a proprietary model for allocating bank capital, the different assessments of a borrower’s risk can create a 50bps gap between the two notch differential of a BB+ and a BBB rated corporation. This explains half of the observed spreads between the tightest and widest levels of initial pricing.

    2 raroc US

    The perception of credit risk varies among lenders and is difficult for borrowers to understand, yet it is at the foundation of bank negotiations. It is therefore essential that a corporation obtains its internal rating from each prospective lender. And, if necessary, the corporation should conduct bilateral discussions with each credit team to ensure the perceived risks of each of the lenders in the pool are aligned.

    Negotiation levers

    Renegotiating credit terms requires a clear strategy. There are numerous variables that factor into negotiations, such as side-business allocation, quality of relationship, and competitive dynamics.  All factors, including terms within the credit documentation, must be part of the price negotiation. Borrowers should also strive to engage in bilateral dialogue with lenders to ensure the maximum level of transparency.

    In addition, the composition of the banking pool must be aligned with the group’s strategy for growth. The borrower should also identify past and future side business with each of the lenders in order to analyze the overall profitability of each bank. Doing so enables the borrower to successfully address pricing issues with empirically supported data.

    3 négociation US

    Author: Emmanuel Léchère

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  • 06.01.2016

    Predicting the future of ECR

    While rates are on the rise in a competitive environment, such as an RFP, it will take time before ECRs are increased across the board – especially at the large money center banks focused on shedding deposits rather than attracting them, says Redbridge's nationally recognized treasury expert, Bridget Meyer.

    In December 2015, the Fed hiked the overnight lending rate by 0.25%. Considering the high balances that large corporations typically leave in their commercial Demand Deposit Accounts, and the impact that the earnings credit rate and corresponding earnings credits have on offsetting transactional bank fees, two questions come to mind:

    1/ Should corporate treasurers expect a corresponding increase in the earnings credit rate that their banks are providing on average daily collected balances?
    2/ Is this the beginning of an increasing interest rate trajectory that could lead corporate treasurers to consider alternative yield-capture instruments (e.g. hybrid accounts, hard-interest accounts) that are more beneficial than analyzed checking accounts?

    In fact, taking a step back, let’s ask a more broad question: how and why did ECR even become part of the overall corporate bank fees and yield equation, and how does it fit into a global economy?

    In order to answer the first two questions, you must first know the answer to the third: The concept of an Account Analysis (and therefore, ECR and the offsetting earnings credits stemming from ECR) is not normally recognized by banks outside of the United States. There are some large US-based banks that will offer earnings credits to their US-based clients on balances in non-US bank accounts – if you ask for it. Some banks are even using it as a market differentiator and calling it ‘Global ECR’ or an equivalent term. ECR only exists in the US (instead of a traditional interest rate) as a result of Regulation Q, which prohibited banks from paying hard interest on commercial deposits being held in Demand Deposit Accounts (DDA).

    What is (or was) Regulation Q? It was a regulation that came into being during the Great Depression in the 1930s, as part of the Glass-Steagall Act of 1933. It specifically prevented corporations from earning hard interest on their demand deposit bank accounts. It is important to note that for several decades, corporate clients were not paying transaction fees for activity occurring in their DDA accounts. From a profitability perspective, the interest that banks were earning on balances that corporations were holding in their DDA accounts more than offset the costs to the bank for the transactional activity occurring in those same accounts.

    However, as the interest rate landscape changed and different investment instruments became available (specifically in the 1970s), corporations shifted balances away from DDA accounts into these alternative interest-bearing accounts; as a result DDA balances dried up. The impact of this was a reversal of fortune; the associated profitability between the interest that banks were earning on DDA balances was lower than their internal cost for processing transactions in those same accounts.

    The banks’ answer was simple: begin charging for transaction fees. Corporations though did not sit idly by and allow these new expenses to hit their income statement and reduce their own profitability. They rebelled and demanded to see how these fees were being calculated. The ‘Account Analysis Statement’ (and ECR) was first produced in 1978, when banks, in response to pressure from their large corporate clients, shared their own internal profitability analysis used to determine the target DDA balance needed to offset transaction fees at the account level. The analysis showed that the level of ‘Compensating Balances’ required to offset service fees at current market rates without technically paying hard interest on commercial deposits. Analyzed checking accounts have been a mutually beneficial win-win ever since.

    So why do we now question the future of ECR? It is because of the combination of Regulation Q being repealed in 2010 as part of Dodd-Frank regulations, and Fed rates finally moving higher. Legally, there is no corporate benefit in having ECR exist anymore. If banks are no longer prohibited from paying hard interest on corporate deposits in the US, what is preventing them from converting all commercial clients to simply earn hard interest on DDA balances? Nothing except technology and habit.

    Billing systems that were customized to produce account analysis statements would have to be reconfigured to calculate and offer hard interest instead. In fact, most major banks have already come out with what they call hybrid accounts, which calculate the amount of compensating balances needed to offset transaction fees (treated the same as ECR and earnings credits), , and then apply a hard interest to any additionalbalances after all fees have been covered. These products were first created in 2011 and have been fine tuned since; however corporate and bank adoption has been slow. Few corporations have enough balances in the current rate environment to offset all transaction fees and benefit from a Hybrid Checking account. However, as rates rise, the adoption of hybrid accounts or corporate interest checking accounts could eclipse the usage of traditional ‘analyzed checking’ account we know today.

    Finally, to address the first question: are banks finally increasing ECR? Our market intelligence and experience confirms that ECRs are in fact finally on the rise – but not for everyone. In recent RFPs, Redbridge has been pleasantly surprised to learn that the banks that have not budged on rates in the past 3 years are finally coming to the table with higher ‘exception’ ECRs that are attractive. ECR continues to be used by banks more and more to lure new clients that have significant operational balances, even as those same banks look to shed certain non-operating balances due to Basel III.

    The difference between the typical ECRs offered by regional banks compared to those offered by global banks show a stark difference. The hypothesis being that the profitability structure of smaller regional domestic banks are different, especially as these same regional banks do not have to contend with the restrictions of Basel III, allowing them to offer the higher ECRs as a considerable differential benefit. The following chart shows the progression of ECRs between these two groups of banks in the past 5 years.


    Source: Redbridge
    *Based on Redbridge’s BankScore™ of Global Rates & Fees

    While rates are on the rise in a competitive environment, such as an RFP, it will take time before ECRs are increased across the board – especially at the large money center banks focused on shedding deposits rather than attracting them. Irrespective of who is benefiting from the rate increase, it is encouraging to see that rates are demonstrably on the rise, regional banks are still providing very attractive exception rates, and the future of ECR appears to be safe… for now.

    Author: Bridget Meyer

    Bridget Meyer is a nationally recognized treasury expert in the field of bank relationship management and account analysis. Bridget actively manages and promotes the AFP Service Codes Accredited Provider Program designed to increase standardization in bank fee reporting and authored the AFP Global Service Codes. At Redbridge, she is responsible for overseeing all debt and treasury advisory projects in North America. She earned her CTP certification in 2007.

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  • 05.01.2016

    It’s time for treasury to treat banks like any other vendor

    When thinking about the typical set of cash management services that banks provide to corporations, there is no reason that a bank should be treated differently from any other corporate vendor in order to be paid for its services, writes Tamir Shafer, Senior Director at Redbridge Debt & Treasury Advisory.

    Just like other vendors that provide invoices detailing services/products rendered, each month, banks provide their own invoice-like report, clearly identifying services they provided. This report includes each service provided, associated volumes, price points and total costs due to be paid to the bank by the client for these services. This report is known in the U.S. domestic market as the account analysis.

    So why is that when we reviewed more than 100 distinct corporate-bank relationships, only six passed through a process remotely as rigorous as the typical AP process?

    There are many answers or reasons. Here are the most common explanations we have heard from treasurers and cash managers:

    • There is no simple way to validate and confirm that the volume of activity reported on each service line item listed on the account analysis is what the company actually processed at the bank.
    • The bank is paid via auto-debit each month.
    • The account analysis is system generated, so there are few, if any, mistakes or errors.
    • We believe a spot check of month-over-month totals is sufficient.
    • ECR and associated earnings credits usually offsets most of the fees anyway.
    • It’s not a priority—treasury teams do not have time/resources to do it.

    Are these valid business reasons, or excuses? Asked from a different perspective, which department should really be responsible for reviewing the accuracy and validity of charges associated with the account analysis: accounts payable or treasury?

    As you ponder that, let’s dive into one of these explanations to try and gain more insight and perspective: “There are few, if any, mistakes or errors.”

    Through our research and analysis, we have identified that on average there are 4.68 errors or billing violations per 100 services listed on each account analysis. A billing violation can be identified as any of the following:

    • Arithmetic or calculation error
    • Changes in pricing or ECR without approval
    • Multiple price points existing for the same service
    • Pricing not reflecting agreed volume-based price tier structures
    • Services added without approval

    In reviewing more than 300 account analyses in the past year, we have found that for every $1,000 in gross fees, there is $54.44 in billing violations and errors. If, for example, a company is being assessed $50,000 in gross monthly fees by its banks for cash management services in a typical month, they might expect billing violations and errors of $2,722. Over the course of a year, that amounts to $32,664 in billing violations and errors. Perhaps a “spot-check” is not as sufficient as many believe it is.

    Kristen Seduski, cash manager of Belk Inc. utilizes a third-party advisor to monitor monthly bank fees rather than saddling AP or treasury with the burden of handling it. She noted that reviewing multiple account analysis statements each month and determining if the price points, services and volumes are correct would be a very tasking role for treasury, especially given its higher priorities and typically limited resources and time.

    Seduski added that the cost of software to monitor bank fees on account analyses proved to be more expensive than utilizing a third party. “I felt we needed the monitoring, and we continue to need it to maintain this best practice as it has proved beneficial to our company,” she said. “All banks I’ve worked with have been, and continue to be, understanding when I advise them of billing violations, and they have provided us with all credits requested. The fees and time my team has saved, and will continue to save, far outweigh the cost of the third party providing this service.”

    Regardless of the tactics taken, it is clear that a review is appropriate, needed, and in order. A bank is still a bank, and a vendor too. Ensuring it is billing appropriately in no way reduces a bank’s value, and only helps to ensure that it does not circumvent the important vendor payment approval process.

    Author : Tamir Shafer

    This article was first published online by the Association for Financial Professionals: http://www.afponline.org/pub/res/news/It_s_Time_for_Treasury_to_Treat_Banks_Like_Any_Other_Vendor.html

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