What would Teddy (Roosevelt) do?

I have long been concerned by the rise and rise of the global mega-bank, first due to my conviction of the impossibility of managing such complex behemoths (with the dangers as we all now know having repercussions far beyond any individual bank’s shareholders or creditors) and also due to the increasing rents such a de facto oligopoly could (and so logically does) extract from the rest of the global economy. I’ve started and then stopped writing this post at least half a dozen times in the past year; partly due to a sense of ‘what’s the point’, partly due to the problem being covered by many with much (much) more influence than I, and partly (I’m somewhat ashamed to admit) due to a small underlying element of self-censorship. As some of you know, we have ambitions to raise capital to allow us to catalyze the re-invention of financial services by investing in companies with disruptive new business models in this sector, and well the big banks are not only potential sources of capital in their own right, but also have significant influence with many of the people and institutions who are potential sources of capital for us. As regular readers know, I try always to tell it like I see it but if I’m objective, I probably have had a tendency to pull my punches a bit when discussing the banking industry. But as the debate on reforming global banking takes centre stage, and at the risk of annoying some of our potential future investors with a dissident opinion, I thought it would be worthwhile to lay out my key thoughts on the subject.

Commenting on an interview with Christine Lagarde (French Finance Minister), the FT editorial page identified the issue clearly:

Weak competition is obvious to customers: financial companies demand high fees that are often calculated according to illogical tariffs. Fund managers’ charges, for example, are usually large and are often not linked to the quality, or the real costs of their services.

The lack of competition shows up to economists in the sector’s staggering profitability. In the second quarter of 2009, 29 per cent of US domestic profits came from finance. The profit-generating power of financial companies across the developed world has stubbornly remained higher than that of other companies.

There is, in addition, good reason to suppose that competitive pressures will weaken further. The recent wave of bank failures and mergers, born of the crisis, have left the sector more concentrated. With fewer players on the field – many enjoying implicit state guarantees – competition will be further enfeebled.

The followed on from a great column earlier this month by one of my favorite economists, John Kay:

But in more advanced economies, rent-seeking takes more sophisticated forms. Instead of 10 per cent on arms sales, we have 7 per cent on new issues. Rents are often extracted indirectly from consumers rather than directly from government: as in protection from competition from foreign goods and new entrants, and the clamour for the extension of intellectual property rights. Rents can also be secured through overpaid employment in overmanned government activities.

Rent-seeking is found whenever economic power is concentrated – in the state, in large private business, in groups of co-operating and colluding firms. Private concentrations of economic power tend to be self-reinforcing. This problem was widely recognised in America’s gilded age. The well-founded fear was that the new mega-rich – the Rockefellers, Carnegies, Vanderbilts – would use their wealth to enhance their political influence and grow their economic power, subverting both the market and democracy. Today it is Russia that exemplifies this problem.

But America has a new generation of rent-seekers. The modern equivalents of castles on the Rhine are first-class lounges and corporate jets. Their occupants are investment bankers and corporate executives.

So much of the conversation seems to revolve around this question of how do we deal with financial institutions which are “too big to fail”, with the turkeys running the world’s mega-banks almost unanimously (and somewhat breathlessly) insisting that breaking banks up would achieve nothing except to hurt customers.

Back in June, I set down my thoughts on what the key issues were in terms of (fixing) banking regulation, highlighting that size (of assets or business) was not the only variable to consider when assessing systemic risk, but that ‘connectedness’ was probably even more important. Certainly the combination of both is something that should ring alarm bells.

Wouldn’t it make much more sense to build a set of rules that explicitly addresses the vulnerabilities of a scale free network and as such focuses disproportion attention and resources on protecting the hubs from attack or failure. The beauty is that the digital global financial system of the 21st century and advances in the science of networks actually now allows us to do this: we can empirically and quantitatively observe, measure and manage the ‘connectedness’ of institutions. Forget the rating agencies, companies like Bonabeau’s IcoSystems and others could help the regulators create, maintain and monitor network ‘maps’ and score each market participant in terms of their connectivity. This should be the defining core metric of financial regulation and mirroring the power law distribution of the underlying network, financial regulation should focus its attention and resources in geometrically increasing fashion.

However it’s pretty frustrating to continue to read much of the ‘financial establishment’ – people who have the luxury and the privilege of being able to speak from the pages of the FT – continue to miss the point entirely and cling to a (slighty) new and improved version of the regulatory status quo. I have enormous respect for Jamie Dimon, and while I agree with him that the system must be re-engineered so as to allow any bank of any size to fail without jeopardizing the system, I disagree that breaking up the biggest banks would be damaging and serve no purpose. The rules need to be reset (to build-in automatic and steeply increasing impediments to growth in size and connectedness), but at the same time the biggest global and domestic mega-banks need to be pruned back to a size that is commensurate with this new paradigm.

The parallels between the rise and rise of Standard Oil in the late 19th and early 20th centuries, and its subsequent government mandated break-up and the rise and rise of giant global banks in the late 20th and early 21st centuries are real. John D. Rockefeller sounded every bit as sincere and paternalistic in calling for an ever bigger, ever more dominant Standard Oil – a company that would bring ‘order’ and ‘stability’ to the market making customers’ lives and choices ‘easier.’ Well of course we know that the market for oil products didn’t suffer as a result of the break-up of Standard Oil, nor did anarchy descend on the US telecommunications markets following the break-up of AT&T. I think you’ll actually find that there is a decent case to be made that things got better in both cases, with more robust and innovative markets and better value for customers. (I highly recommend that legislators everywhere take a moment to read Chernow’s great Titan: The Life of John D. Rockefeller, Sr. before reaching their conclusions as to the merits (or not) of breaking up the biggest banks.)

But the most important long-term reason to consider government intervention in the size and power of the world’s largest financial institutions is that failing to do so will inevitably starve one of the key sectors of the economy of innovation and progress with increasingly damaging results. Indeed, in the conclusion to his column Mr. Kay hits the nail on the head:

Because innovation is dependent on new entry it is essential to resist concentration of economic power. A stance which is pro-business must be distinguished from a stance which is pro-market. In the two decades since the fall of the Berlin Wall, that distinction has not been appreciated well enough.

It’s time for a change. It’s time to shake things up a bit. No?

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Anyone who has ever used an Apple product understands that a key part of the value flows from the design aesthetic that covets simplicity, intuition and beauty; harnessing these attributes to provide solutions and services that users find a joy to use right out of the box. The complexity of their products is hidden from view, Steve Jobs having understood that the extra effort needed to transform complexity into simplicity was something that created tremendous value both for his customers and his shareholders.

Creating simplicity is hard. Much harder than creating complexity. Entropy and all that. But it is very often worth the effort. Helpfully, John Maeda wrote a great guidebook “The Laws of Simplicity” where he articulates 10 basic laws:

1. Reduce: The simplest way to achieve simplicity is through thoughtful reduction.
2. Organize: Organization makes a system of many appear fewer.
3. Time: Savings in time feel like simplicity.
4. Learn: Knowledge makes everything simpler.
5. Differences: Simplicity and complexity need each other.
6. Context: What lies in the periphery of simplicity is definitely not peripheral.
7. Emotions: More emotions are better than less.
8. Trust: In simplicity we trust.
9. Failure: Some things can never be made simple.
10. The One: Simplicity is about substracting the obvious, and adding the meaningful

Finance and financial markets are often complex. This complexity can arise within products (exotic derivatives), infrastructure (clearing, settlements and payment platforms) or regulation. And most financial services firms (and professionals) revel in this complexity. Not only do they not seek to hide it away, but they often compete vigorously to show it off in all its glory (and of course by association they seek to validate their virility and cleverness by navigating all this complexity on behalf of their hapless customers.) Of course – sticking with the computing metaphor – this ‘look how clever I am’ approach is very Microsoft-ian (and no, that isn’t a compliment) and very rarely does it provide the most utility or best value for the customer. So one of our key investment themes is to find and nurture companies who are to finance as Apple is to computing (and media!) The complexity of modern finance and markets is the ideal substrate for simple products and services, to quote John:

Simplicity and complexity need each other. The more complexity there is in the market, the more that something simpler stands out. And because technology will only continue to grow in complexity, there is a clear economic benefit to adopting a strategy of simplicity that will help set your product apart. That said, establishing a feeling of simplicity in design requires making complexity consciously available in some explicit form. This relationship can be manifest in either the same object or experience, or in contrast with other offerings in the same category—like the simplicity of the iPod in comparison to its more complex competitors in the MP3 player market.

One of our portfolio companies does exactly this. They take a simple service, using technology and their market knowledge to engineer a solution that keeps the complexity away from the customer and behind the scenes. (Where it should be.) A solution that embraces simplicity and transparency in a market heretofor characterized by complexity and obfuscation. It’s not a new music site or social network. It’s probably not something anyone would get too excited about. It’s boring. But it’s big. Billions big. And important. And for many individuals and corporates, unavoidable.

The service is foreign exchange (aka FX) and international payments. And the company, as you might now have guessed, is FX Capital Group. (See also my FX 2.0 post from this spring.) And the reason I am writing about them today is that they have just launched their new website and online trading platform and it is by far the best FX user experience I have seen. Simple. Transparent. Complete. Easy-to-use. From the initial client take-on, all the way through to the onward payment to the account of your choosing, every last detail of the process has been engineered to make the customer’s life simple. The “iTunes of foreign exchange”. After all selling one currency to buy another should not be that hard.

And now, it isn’t.

FX Capital Group’s vision is to combine technology and traditional phone base services with competitive and transparent pricing to deliver on the promise of simple, cost effective, and customer friendly foreign exchange and international payments services for clients.

Leveraging experienced individuals, the best technology and a deep understanding of both international foreign exchange and payments markets, FX Capital Group brings transparency, simplicity and automation to meet the foreign exchange needs of clients in a robust, easy and effective manner.

With FX Capital Group, clients can:

• Buy, Sell and Hedge Currencies: A full range of phone based and online services to buy/sell currencies and hedge currency risk. Competitive, consistent and transparent pricing for all customers.
• Manage Currency Risks: Guidance on strategies to hedge currency risk within your business. A great service for firms who contract in multiple currencies or import / export goods and services.
• Sell on Your Website in Multiple Currencies: Expand your online customer base by selling to customers in multiple currencies using our real-time FX API’s at rates that are better than those “bundled” with merchant service providers.
• Invoice in Multiple Currencies: Invoice your international clients in local currency. Embedded hedging of any currency movements and no need to maintain bank accounts in multiple currencies.
• Make International Payments: Our international payments service (online and phone) will save you money over you bank for making international payments and may be free if you transact your FX with us.

And other brokers and financial intermediaries are also welcome to partner with FX Capital Group, either via API or white label agreements. Indeed, first and foremost this is very much a platform company, FXaaS really. The customer facing website is in fact just an implementation of the underlying platform, and shortly the company will be launching the second implementation – RabbitFX – which will be tailored specifically to private and retail clients. Going forward we hope that many other partners choose to build innovative and customized services on top of the core FXCG platform. We also are excited by the ability for partners to integrate FX into their products and workflows simply and powerfully. Imagine for example an ERP provider, or online accounting services, or an ad network, etc. etc. …the list of potential partners is almost endless.

One area that is particularly close to my heart is the ability to allow even the smallest start-up to offer their customers payment in any currency – easily, cost effectively and transparently. Or helping start-ups with geographically dispersed operations pay employees, contractors and suppliers in any currency without having their eyes ripped out by their bank or payments provider. I’m sure most of the seedcamp finalists from the last few years have foreign exchange payments to make from time to time, many on a regular basis. In the spirit of helping to get the ball rolling on this front, I’ve convinced them to sweeten the bargain for all the companies that have applied to seedcamp (or mini-seedcamp) over the past three years.

If you have been a seedcamp applicant, finalist or winner, if you open a corporate account and do a trade before December 25th, FX Capital Group will send you a £25 iTunes or Amazon gift card and also contribute £25 to the charity of your choosing. Just let them know when you register for which seedcamp event you applied or attended. They’ll do the rest. And then sit back and save time, money and energy and never worry about managing FX payments again.

Like all good start-ups a big part of the excitement and frustration is knowing what is ‘in the pipeline’ and wanting it all to be released to users ‘yesterday’. However we also know that the best ideas and certainly the best prioritization algorithms emerge from getting a product into the wild and so after 9 months of development and private alpha, I can’t wait to hear ways in which customers and developers will want to use the platform. So for all you early adopters out there, know that the platform is probably not perfect (although we’ve stress-tested it up to 250,000 trades a day without any problems, which gives us a bit of headroom to grow into! lol) but (we think) it’s damn good and would rather challenge you to help us make it even better than pretend we’ve got it all figured out.

In case you were wondering, the team is indeed working on putting a screencast/video demo of the trading platform online and but in the mean time they are more to happy to walk you through a short online demo if you are interested. Alternatively you can go yourself to https://demo.fxcapitalgroup.co.uk/ and use the following credentials:

• username: demo@splashypants
• password: demosplash
• pet’s name: splashy
• favorite animal: whale
• favorite city: atlantis

Have a go and be sure to let the team know what you think. Best channel is probably twitter where you can find them at @FXCapitalGroup or on Facebook.

Finally it’s important to make clear that I’m not just writing this post as an investor, commentator or director but first and foremost as a customer. My entire adult life I have had to deal with managing FX risk and struggle with the pain and cost of doing international transfers. When the founder Nigel Verdon came to me with his vision, I thought ‘Hallelujah!’ – at last. It may not be the sexiest business in the world but there is real pain and real profits to be made in using technology to disrupt the old way of doing business and give customers a better deal. And so I did a ‘Victor Kiam’. So next time you have to make a foreign payment, whether its for yourself or your company, give FXCG/RabbitFX a chance, I’m sure you won’t be disappointed.