Financial Information Note Fin 2004/4 Accounting for Foreign Currency Transactions 1. The great bulk of the College s business is conducted within the UK and in sterling. However, with an increasingly international profile, we have devised following policies for handling overseas financial engagements. Broad strategies: 2. (i) We should seek to avoid contracts denoted in overseas currencies where practicable. By doing so, the risk associated with currency fluctuation becomes the responsibility of the other party, rather than us. (ii) Where this cannot be achieved:- (a) try to limit the length of the contract to two years, or, if longer, break the projects into sub-projects with the budgets for later stages being renegotiable on an agreed timetable, according to the changing currency situation as the work proceeds; or (b) agree with the sponsor at the outset to set aside a contingency margin of say 10% per annum of the contract price to deal with potential adverse currency variances during the contract period. This should be an earmarked budget, not to be used for scientific purposes. If the currency moves favourably, it can be returned to the sponsor or, with the College s agreement, transferred into research budget headings. (iii) The College will not normally accept contracts in foreign currencies other than US dollars or Euros. Any proposals where the sponsors or customer seeks to denote a contract in another currency should always be referred to the Finance Division for advice at the earliest opportunity.
(iv) The College operates bank accounts in sterling, US dollars and Euros. In the short term, receipts are matched with payments in each currency, in order to minimise exchange risk and banking costs. Where overseas receipts are unlikely to be required for some time, they are converted to sterling until needed. (v) Where substantial future foreign expenditure is anticipated, it is possible to limit our exposure by taking out forward exchange contracts or currency options. There are costs associated with such hedges, however. Treatment in ICIS: the general position 3. A standard corporate exchange rate is set for each of the major currencies at the end of each month, to apply for the whole of the following month. All transactions effected during the month are translated into sterling using this rate. Research contracts in foreign currencies 4. If a proposal or application is made in a foreign currency, the rate used should be the College's corporate rate for that month, unless the sponsor specifies their own rate of exchange. Corporate rates are obtainable from the cashier s office at South Kensington (020 7594 8728). For research proposals for the European Commission, the Research Contracting Office should always be consulted at an early stage. (See also paragraph 7, below.) 5. If the award is successful, the sterling budget should be set up at the same exchange rate used on the original application. This sterling budget is fixed for the duration of the project, and any differences due to currency fluctuation will be borne by the College centrally. 6. To avoid ambiguity, all research contracts should include a brief clause concerning treatment of foreign currencies. Specimen wording is obtainable from the Research Contracting Office. 7. The European Commission contracts have their own rules, which are non-negotiable, viz: Costs incurred in currencies other than the Euro shall be reported in Euro on the basis of the conversion rate that would have applied on the date that the actual costs were incurred or the rate applicable on the first day of the month following the end of the reporting period. The exchange rates used must be those published by the Commission at <http://europa.eu.int/comm/budget/infoeuro/en/index.htm>.
8. In a few cases, overseas contracts require expense-type payments to be made in the contracted currency, or, if paid in sterling, to be adjusted to ensure the full-value payment is received. A prime example is the Marie Curie travelling fellowships awarded by the EU, which denote a stipend in Euros, although the fellow, based in the UK, invariably wants to receive sterling. The only practical way to deal with these is to disburse the available cash prudently in the early months of the grant period, and then adjust as necessary, towards the end of the project, when actual currencyequivalent costs are known. Substantial sub-contracts and partner payments 9. In such cases, the College s own costs arise predominantly in sterling, but partners and subcontractors costs arise in a foreign currency. EU partnership contracts are the commonest example. 10. The process for preparing any proposal for such grants or contracts, and subsequently accounting for the funds received, is as follows:- (i) etc.). Initially estimate the College s own costs in sterling (salaries, material (ii) Use the corporate month applying at the time the proposal is submitted to convert this to the currency of the proposal (eg Euros). (iii) Add the partners proposed budget costs directly in overseas currency. For memorandum purposes, convert the partners budgets to sterling using the same rate as above. (iv) If the bid is successful, enter the sterling budget calculated as above in ICIS, for both the College s and the partners components of the project. (v) As each tranche of funding is received from the sponsor, it should be split between the College s and the partners shares. The College portion should be converted immediately to sterling and posted in ICIS using the corporate rate for that month. Any profits/losses arising should be written off immediately to the central P/L exchange account. The principal investigator should ignore the actual receipts, and control spending against the sterling budget (for the College s portion of the project), for the entire duration of the contract. [A detailed note on the accounting treatment will be distributed to Research Services Managers and Accounts Receivable staff]. (vi) The partners share of each tranche of funding received should be retained in the applicable currency and paid away as soon as possible. This will ensure that postings in ICIS use the same (or almost the same) exchange rate as was used for the receipt, so that little or no exchange profits or losses arise in the College s books on the partners share of the funding.
Foreign currency donations 11. These will normally be converted to sterling at the rate prevailing immediately upon receipt. If you are expecting a substantial overseas donation for which expenditure will be incurred in the same currency, please contact Malcolm Aldridge beforehand, who can arrange to retain the funds in currency for a short period (as for partner payments, above) or make hedging arrangements in the longer term. Where it has been agreed that the donation is lodged in an interest-bearing account, interest will be calculated on the sterling balances recorded in ICIS, using sterling interest rates. [For these purposes, a donation account is one beginning Ennnnn or Lnnnnn. Accounts beginning Pnnnnn or Rnnnnn never carry interest.] Purchase contracts 12. Where a purchase contract is expressed in foreign currency it will be translated into sterling in ICIS at the corporate rate applying on the date the order is placed. 1 The sterling figure will appear as an encumbrance. 13. When the supplier s invoice is received, the payment will be translated using the corporate rate applying at the time of payment. The sterling encumbrance will be cancelled (or matched if currency-matching is available). 14. If a buyer is aware of a purchase denoted in foreign currency whose value is greater than 100,000, where a substantial delay between ordering and delivery is likely, he/she should contact Malcolm Aldridge to consider the possibility of buying currency forward to eliminate exchange risks. Overseas contract approval procedures 15. Except where measures along the lines described in paragraph 2 (ii) have been incorporated within the contractual terms, any proposed award whose value exceeds the currency equivalent of 250,000 and whose duration exceeds 3 years must be referred to the Director of Finance for authorisation, prior to signature on behalf of the College. Transitional arrangements 16. The arrangements described above will come into immediate effect, in respect of all new contracts. For existing research contracts, principal investigators should manage their project on the basis of the sterling budget currently entered in ICIS. Any overspends resulting purely from exchange fluctuations will be written off to a central account at the end of the project. 1 A project to allow direct entry of overseas currencies into ICIS via I-Procurement has been specified but is awaiting resources to deliver it. In the meantime, please take great care to check any fax or paper output from ICIS before issuing to the supplier, to ensure that any monetary values shown are correctly expressed.
Where application of this policy would have an adverse effect upon a particular project for example where significant favourable currency variances have already occurred prior to the publication of this policy - Principal Investigators may apply no later than 1 January 2005 for an increase to the sterling budget. Applications should be submitted via their Faculty Research Services Manager to the Head of Financial Management. Losses crystallised at the end of a research project 17. Where the accounting procedures described at paragraph 10(v) are followed, losses should have been identified and written off during the lifetime of the project. However, in cases where a loss materialises only at the project s conclusion the following procedure should be adopted: (a) Where sterling expenditure is less than or equal to the sterling budget recorded in ICIS, but the total amount received from the sponsor, when converted to sterling, is insufficient to meet the expenditure, the shortfall may be written off to central funds. The relevant Research Services Manager should prepare a journal and submit it to Ewa Szynkowska. Where the loss exceeds 2,500 the journal should be supported by a brief note or e-mail, detailing the circumstances which have given rise to the loss. (b) Where sterling expenditure exceeds the sterling budget but the overspend can be traced directly and exclusively to a contractual requirement to pay a fixed amount in an overseas currency (eg to a sub-contractor or research fellow), the overspend should be isolated and may be written off, as described above. Enquiries 18. Please address any enquiries about: the currency aspects of overseas research contracts to Research Services Managers; overseas purchase contracts to John Whitlow (ext. 48651); and hedging contracts, forward purchase or sale of currency, treasury management and foreign currency policy in general to Malcolm Aldridge (ext. 48683). Malcolm Aldridge 23 September 2004