www.mandasoldiacasa.it The Italian remittance costs database

CeSPI Centro Studi di Politica Internazionale (International Policy Studies Center) www.mandasoldiacasa.it The Italian remittance costs database Data Analysis Edited by: D. Frigeri 15 November 2011

Methodology The following report on the trend in fees for sending remittances from Italy to 14 countries monitored by the website www.mandasoldiacasa.it follows the report published in June 2011 by six months. The analysis contained herein was performed over the entire reference period, from the September 1, 2009 survey to that of October 4, 2011. Overall the data refer to 15 surveys, which were conducted monthly beginning in September 2010. Compared to the previous report, the database was revised and reprocessed in order to standardize the information and make greater comparison possible among the data; for this reason some variations with respect to the data provided in the June report may occur. The overall cost of the remittance was calculated, using the World Bank methodology, as the sum of three components: the fee applied for sending the remittance, the fee applied to the recipient, and the margin on the exchange rate. The data processes refer to operators and products for which the total cost can be defined and to the three amounts that were surveyed ( 150, 300, and 1000). The 1000 amount was introduced in May 2010, and therefore the historic series of data available is shorter. Thanks to the availability of official data (published by the Banca d'italia), it was possible to analyze costs weighting by the volume of remittances relative to each corridor considered. The weighting refers to the flows reported by the Banca d'italia on December 31, 2010. Overall weighted average cost The analysis of overall average costs for sending remittances, weighted by the volume of the respective corridors, shows a reduction in the time period considered of 0.62 percentage points for the sum of 150. Graphic 1 - Average weighted cost for sending remittances in corridors surveyed for amount 150 10% 9.3 7.6 8.7 2% 0% Weighted average cost - Oct 2009 Weighted average cost - Feb 2011 Weighted average cost - Oct 2011 2

The contraction of costs compared to the February 2011 survey appears to show a slowdown characterized by an inversion of the average costs trend. This information was the subject of a specific supplementary analysis, provided in subsequent sections, and a comparison with the leading operators in the sector. In fact, on the one hand, the trend falls within a well-defined descending curve (Graphic 2), expressed graphically by the logarithmic trend line. On the other hand, the curve that combines the average weighted costs compared to the individual survey data in February 2011 shows an absolute minimum point and unexpected and significant increase (half a percentage point) in the October 2011 survey. The following analysis will show how various factors, both incidental and structural in nature, come together to explain the course of this curve. Graphic 2 - Average weighted cost for sending remittances in corridors surveyed for amount 150 and logarithmic trend line 10% 9% Sep-09 Feb-10 May-10 Sep-10 Oct-10 Nov-10 Jan-11 Feb-11 Mar-11 Apr-11 May-11 Jun-11 Jul-11 Sep-11 Oct-11 Even concentrating on the 150 amount taken as the reference amount by the World Bank to reach the 5*5 1 it can be useful to extend the comparative analysis of cost trends to the other two amounts surveyed by the mandasoldiacasa site: 300 and 1000. Graphic 3 shows the trend in average weighted costs for these three amounts. The first piece of data to emerge is a negative correlation between the average cost and the amount sent. As the average amount rises, the average cost expressed as a percentage of the amount itself decreases. However, this correlation is accompanied by a trend different from that followed by the average weighted cost curves. For the 300 amount, the logarithmic trend line shows a downward direction in the average weighted cost, but one that is far more contained than that for 150. From September 2009 to October 2011 in fact, the average cost reduces only by 0.33 percentage points. Concerning the 1000 amount, the historic series for which begins in May 2010, there is instead an upward trend which led to an increase in the average weighted cost of 0.33 percentage points. 1 The commitment to reduce the cost of remittances by in 5 years, by 2014, signed by the governments of the G8 and brought to the G20. 3

Graphic 3 trend in 300 and 1000 average weighted costs and corresponding logarithmic trend lines 3% 2% Simple overall average cost In order to provide a more complete picture of cost trends for remittances from the Italian market, along with the analysis of average weighted costs we provide the trend of simple averages of overall costs of sending remittances from Italy during the period in question. For the 150 amount (Graphic 4), average costs follow a more variable course, with an overall downward trend (logarithmic trend line). Overall, in the time interval in question, the average cost registered an overall reduction of 0.65 percentage points and a more marked increase compared to the curve of weighted average costs corresponding to the September 2011 survey, and substantial stability in the following month. Graphic 4 - Average cost for sending remittances in corridors surveyed for amount 150 and logarithmic trend line Looking instead at the simple averages corresponding to the other two amounts surveyed (Graphic 5) we see confirmation of the results of the weighted average cost analysis, with a reduction of 0.26 percentage points in the average cost for the 300 amount and an increase of 0.54 percentage points for the 1000 amount. 4

Graphic 5 Trend in 300 and 1000 average costs and corresponding logarithmic trend lines 3% 2% Regulatory changes In September with article 35-octies of the major amendment to conversion bill AS 2887 the Italian government introduced a stamp tax on remittances by immigrants of 2% of the amount sent, with a set minimum value of 3. The rule, shown in Box 1, presents a number of interpretation difficulties, introducing significant critical issues to the market, both for operators and for users. The rule came into effect before the survey on last October 4, and therefore the survey detected the initial effects of its introduction. Box 1: article 35-octies The interpretational issues, not yet resolved despite numerous meetings held between operators and the Ministry of Economy and Finance, and the mandatory requirement of a physical stamp on receipts, which forces users to visit a tax stamp reseller to purchase the stamp with which to make the remittance, are only a few of the elements that have had a direct and immediate effect on the volume of remittances moving through regulated channels. The impact on the market was especially intense, with contractions in volumes by operators of between 10% and 2 (depending on the corridors) and an effect on immigrants who, informed of the stamp tax, refused to send money of between 20% and 40%, even in those corridors exempt from the tax, due to scarce information and uncertainty 2. In summary, for macro-categories, the leading problems with the rule are: INCREASE IN DIRECT AND INDIRECT COSTS. By introducing a tax burden of 2% on the transferred amount per individual operation, with a minimum fee of 3 euro, the rule de facto implies a corresponding increase in direct costs for all users who do not qualify for the exemption. Significant indirect costs also exist, which given their size, will affect costs for transferring remittances for all clientele, yet are difficult to quantify: 2 From interviews with leading operators in the sector. 5

- new burdens for migrants who will need to display at the window simultaneously proof that they possess the requirements for the exemption (INPS number and tax code) - new burdens for operators, who will have to adapt their IT systems, contractual forms, customer information, and staff training to adapt to the requirements of the law. These new burdens appear significant (according to estimates provided by various operators in the sector, figures amount to multiple thousands of euro for each operator) - the failure to provide in advance a transition period for application of the law, which would have allowed operators to adjust, and uncertainties in interpreting the law that still exist, have given rise to temporary solutions and information problems between operators and users. THIS CREATES AN INCENTIVE TO USE INFORMAL FORMS OF TRANSFER AND MECHANISMS WITH LITTLE TRANSPARENCY THAT PENALIZE MIGRANTS. The introduction of a new cost on transferring money abroad only increases and incentivizes migrants to turn to informal forms and instruments, which lack monitoring and traceability as well as protection for the users themselves, and therefore work in opposition to the policy pursued both nationally and internationally, which aims to reduce the use of these channels. The rule will also incentivize the spread of evasion mechanisms using "name-sharing" with friends and family members who fulfill exemption requirements. These are mechanisms that can easily lead to the application of new fees, often illegal ones that penalize these individuals to the harm of migrants. MARKET CHANGES. The introduction of the direct cost element that discriminates between different instruments (compared for example to a rechargeable debit card or credit card) and a regulation that increases the fixed costs for operators, thereby raising the threshold for new entrants, constitutes an artificial change to the remittances market to the disadvantage of increased competition. What's more, the exemption enjoyed by transfers inside the European Union can generate an additional distortive effect in the market, since to get around the fee in Italy the user can make an initial transfer to another European Union country and then transfer the money from that country outside the Union. INTERNATIONAL POLICY ASPECTS. The rule is in stark contrast with the commitment undertaken by the Italian Government both during the G8 (in L Aquila in 2009) and the G20 (Seoul 2010) to reduce the cost of remittances by in five years, and with the General Principles for International Remittance Services 3 (General Principle 3), according to which remittance services must be supported by a regulatory context that is effective, reliable, nondiscriminatory, and proportionate. The rule in question demonstrates clear limitations with respect to these criteria. UNFAIR TREATMENT AND DISCRIMINATION. The distinction between European citizens and transfers directed to European countries, like the exclusion of all those who did not possess both exemption requirements (not only those working under the table, but also seasonal workers, freelance professionals, or simply tourists), creates a disparity of economic treatment and introduces a form of discrimination that does not appear to have an economic or legal foundation, in addition to striking those most vulnerable and exposed to exploitation. CRITICAL ASPECTS OF APPLYING THE RULE. As it is formulated, there are certain critical elements of the rule in its definition of the areas of applicability that amplify its negative effects. These are defects in the formulation that reduce its effectiveness and certainty, creating problems with interpretation and elements of vagueness: - Commercial transactions: the law identifies the subject of the tax as "transfers of money abroad" made by specific categories of operators, providing an exemption for European citizens and those who have both an INPS number and tax code. The rule therefore appears to link exemption from the fee for all persons, both legal and physical, to the ability to provide simultaneous proof, making INPS enrolment an exclusive criterion. This point calls for immediate clarification since, according to 3 The World Bank, Committee on Payment and Settlement Systems, General principles for international remittance services, January 2007. 6

this restrictive interpretation, all money transfers, including commercial transactions, would be subject to the fee when executed by subjects without an INPS number. - Ways of managing forms of withdrawal: the rule does not allow for unambiguous identification of the payment instruments to which the stamp tax would be applied. In particular, it is not clear if the area of application also concerns transfers abroad executed, for example, using telematic or cellular instruments, for which it is not clear how the requirement for applying a physical stamp might be fulfilled, in the absence of a receipt. Applicability of the rule was however confirmed for bank transfers. Data analysis by cost type 4 The fee required from the recipient (Graphic 6) constitutes a marginal component compared to the cost of remittance, falling at percentages of near 0 and in any event in a descending trend 5. Graphic 6 Fee required from the recipient logarithmic trend line 0.1 0.12% 0.10% 0.0 0.0 0.0 0.02% 0.00% The fee the sending operator applies however constitutes the main component of the cost of the remittance, the top revenue item, and the leading commercial instrument for operators. The trend in the fee shows the market clearly orienting toward a gradual contraction (Graphic 7). Graphic 7 Commission logarithmic trend line 4 The analysis of the individual cost components is based on an average of the data surveyed without any weighting for the volumes corresponding to the individual corridors. 5 With regard to this cost component it is important to clarify that this survey is based on the verification at the intermediary of a commission applied to the recipient anticipated by the agreement with the receiving intermediary and knowable when the remittance was sent. In the case of MTOs it is now standard procedure in Italy to declare the net sum effectively collectable by the recipient (and therefore net of all commissions), while for banks, in cases in which an interbank agreement exists, the "on our" clause is included, which does not anticipate commissions applied to the arrival of money at the corresponding bank. Because it is not possible to verify after the fact if these statements are in fact true, it is appropriate to consider the cost component with due caution. 7

The third component of the average cost, the margin on the exchange rate, instead proves to be more difficult to determine, in addition to constituting the least transparent component for the end user. This is necessarily determined on the basis of a methodology that sets certain agreements that cannot precisely capture the movements of the market. In the case of the website mandisoldiacasa.it, the margin on the exchange rate is calculated as the difference between the exchange rate declared by the operator at the time of the survey and the official daily rate published by the Banca d'italia. The trend in the exchange rate margin which is affected both by the agreements adopted methodologically and by shifts in the exchange rate, which in these recent months of financial turbulence have been significant shows a much more fragmented course with a trend toward growth. Graphic 8 - Exchange rate margin - logarithmic trend line 2. 2.0% 1. 1.0% 0. Data analysis by operator type An additional element for further analysis concerns the cost analysis by operator type. The website surveys costs at three types of distinct operators: Money Transfer Operators (MTOs), banks, and Poste Italiane [Italian Postal Service] 6. The historic series for the Poste Italiane operator, for whom we survey traditional postal products (Eurogiro, Eurogiro Cash International, and Money orders in certain corridors) beginning in October 2010, is shorter. 6 Relative to the Eurogiro, Eurogiro Cash International, and Vaglia Postale postal products, active only in certain corridors. The remittance transfer service through the MoneyGram agreement instead is surveyed as part of the MTOs category. 8

Because data from the Banca d'italia are not available on flows disaggregated by operator type, it isn't possible to conduct a weighted analysis for total volumes sent, and we will limit ourselves here to providing an analysis of the simple averages of values. Given the small number of banks for which the average cost can be determined 7 and the lower number of corridors that include postal products 8, it does not seem significant to conduct a comparative analysis for each amount surveyed. Therefore the analysis was conducted within each operator type, highlighting the trend in average costs surveyed over time for the three reference amounts. Summarized data, although with the appropriate caution required by the reasons explained above, is provided in Table 1, which shows the average cost and operator type for the 150 figure, referring to the latest available survey (October 2011). Table 1 Average sending cost by operator type ( 150 amount October 2011) Type of operator Banks MTOs Poste Italiane Average cost 6.4 7.49% 3.4 Looking at the temporal series from September 2009 - October 2011, the data show (Graphics 9, 10, 11): confirmation of the negative correlation between the cost of the remittance and the sum sent for all operator types a more pronounced cost-reduction for the MTOs, both for the 150 amount, which experienced a reduction of nearly one percentage point (-0.97 percentage points) and the 300 amount, where the reduction was half a percentage point a diverging trend for the MTOs concerning the 1000 amount, which recorded an average cost increase of 0.72 percentage points; relative stability of average costs for the banks (-0.18 percentage points for the 150 amount and no change for the 300 amount), but, if we exclude the October 2011 survey, falling within a marginal upward trend. In the case of the banks there was also an increase over time of over half a percentage point (0.58 percentage points) for the 1000 amount, which is the reference amount for this specific market segment 9 a U curve for the graph for the Poste Italiane for all reference amounts. This is due to the introduction and subsequent expiration of the series of particularly significant promotions by the operator on postal products Graphic 9 - Average remittance cost: detail of banks, by amount 7 In many of the corridors surveyed the Italian banks are unable to provide information on the exchange rate applied, since the agreements with the corresponding banks in the countries of origin call for sending the money in Euro, leaving the foreign counterparts to set the exchange rate for the customer. Lacking a cost component it is therefore impossible to include these cases in the calculation of the average cost. 8 The products offered by Poste Italiane: Eurogiro, Eurogiro Cash International, and Vaglia Postale are in fact active, not simultaneously, only on some of the corridors surveyed: Albania, Morocco, Romania, Senegal, Ivory Coast, China, and Ghana. 9 The ABI-CeSPI survey "Cittadinanza economica dei migranti e rapporto con le banche italiane [Economic citizenship of migrants and relationship with Italian banks]", Bancaria Editrice 2011, conducted on a representative sample of Italian banks showed an average amount per transaction for the banking channel of 1,600.00. 9

3% 2% 150 300 1,000 1% 0% Graphic 10 - Average remittance cost: detail of MTOs, by amount 9% 150 300 1,000 3% Graphic 11 - Average remittance cost: detail of BancoPosta, by amount 9% 3% 2% 1% 0% 150 300 1,000 10

Data analysis by continent The analysis conducted by grouping the corridors analyzed by continent, again weighting the costs for the corresponding flows, shows (Graphic 12): a contraction in costs for all four continents (again in relation to the reference countries for each continent), ranging from a maximum of 1.36 percentage points for Africa to a very low gap for Europe (less than 0.1 percentage points) Table 2 - Average weighted cost difference September 2009 - October 2011 by continent Europe Africa Latin America Asia -0.0-1.3-1.01% -0.4 the market differential found in Asia compared with the other continent s (in September 2009, Asia, for the two corridors surveyed, China and the Philippines, registered an average cost of 11%, compared with 8. in Africa, 7. in Latin America, and 6.1% in Europe) the significant cost contraction recorded in the African corridor (which in February 2011 registered an increase of 0.23 percentage points) and in the Latin American corridor, equal to one percentage point rising cost recorded in October 2011 for three of the continents: Europe, Asia, and Africa (while for Latin America the declining trend continues, supported by a series of promotions that are still in place) the analysis on the 300 amount shows a smaller contraction in the average cost, with Europe seeing an increase of more than half a point (0.66 percentage points). Graphic 12 - Average weighted total cost of remittances: breakdown by continent 150 12% 11% 10% 9% Europe Africa Latin America Asia Sep-09 Feb-10 May-10 Sep-10 Oct-10 Nov-10 Jan-11 Feb-11 Mar-11 Apr-11 May-11 Jun-11 Jul-11 Sep-11 Oct-11 Europe 6.13% 7.2 5.5 5.8 6.02% 5.91% 5.81% 5.40% 5.50% 5.52% 52% 5.53% 5.4 5.42 6.0 Africa 8.70% 8.21% 6.69% 6.9 7.31% 7.31% 7.42% 6.92% 6.9 6.9 7.1 7.0 6.7 6.90% 7.3 Latin America 7.70% 7.42% 5.7 6.8 7.13% 6.80% 6.72% 7.03% 7.7 7.42% 7.0 7.31% 6.69% 6.9 6.69% Asia 11.02% 10.42% 9.1 9.4 10.5 9.5 9.2 8.8 9.9 10.7 10.12% 10.03% 9.90% 9.90% 10.5 11

With regard to the analysis by continent it can again be helpful to provide an overview of cost trends based on simple averages (Graphic 13) which largely confirm what has already been shown by the previous analysis, with two significant features: the more marked upward trend in average costs in countries surveyed on the Asian continent, which turned in an increase of 0.34 percentage points compared to October 2009 the inversion of the average costs trend for corridors surveyed on the European continent starting in July 2011, which in the last two surveys recorded an increase of 0.5 points. Graphic 13 - Average total cost of remittances: breakdown by continent 150 9% Europe Africa Latin America Asia Sep-09 Feb-10 May-10 Sep-10 Oct-10 Nov-10 Jan-11 Feb-11 Mar-11 Apr-11 May-11 Jun-11 Jul-11 Sep-11 Oct-11 Europe 7.02% 7.6 6.3 6.6 6.6 6.5 6.4 6.0 6.1 6.21% 6.1 6.13% 6.11% 62% 6.6 Africa 8.39% 8.5 6.99% 7.33% 7.69% 7.52% 7.51% 7.2 7.5 7.69% 7.53% 7.5 6.9 7.21% 7.40% Latin America 7.60% 7.12% 5.6 6.5 6.9 6.7 6.81% 7.13% 7.8 7.39% 7.01% 7.22% 6.5 7.0 6.5 Asia 8.30% 8.3 6.51% 7.6 7.7 7.33% 7.6 7.82% 8.22% 8.60% 8.3 8.41% 8.6 8.6 8.6 Data analysis by speed of transfer The mandasoldiacasa website makes it possible to survey sending costs for remittances against another variable as well. This variable is considered an important factor by migrants when choosing the operator and the product, and also has a different impact on sending costs: how quickly the money is made available at the destination. 12

The data analysis referring to the 150 amount and to the latest survey available in the historic series (4 October 2011) shows a negative correlation between average sending times for remittances and the average costs, confirming the existence of an opportunity cost in choosing the sending schedules among products offered by the same operators 10. The graph highlights two items that, if confirmed, could be subjects for further investigation: the lowest cost for transfers available the same day (if we exclude the >6 day category) and a maximum cost corresponding to a period of 2-4 days, the most common timeline in the banking channel. Graphic 14 - Average remittance cost by transfer speed - 150 October 2011 3% 2% 1% 0% 7.3 Less than 1 hour 4.5 6.8 6.0 7.5 5.92% 2.1 Same day 1 day 2 days 2/4 days 3/5 days More than 6 days Additional information regarding market development can be provided by comparing the average cost for each category of transfer duration between February 2010 and October 2011 11. Graphic 15 - Average remittance cost by transfer speed - 150 - February 2010 vs. October 2011 10 In practice, the marketing strategies of money transfer operators are shifting toward a diversification of prices as a function of sending times. 11 We chose the February 2010 comparative survey to ensure homogeneity of the reference category that were standardized and rendered uniform only beginning on that date. 13

7. 7. 6.9% 6. 6.0% 5. 7. 7. 5.9% 3% 2. 4. 4.2% 3.0% 2.2% Feb-11 Oct-11 2% 1% 0% Less than 1 hour Same day 1 day 2 days 2/4 days 3/5 days More than 6 days Immediate transfers (less than an hour) and those within 24 hours, which typically describe the offer at MTOs, demonstrate a contraction respectively of nearly a percentage point and of over three percentage points, confirming a reduction in prices of key products and greater competition in the specific market segment. There were two increases in terms of average costs: the "next day" range (1 percentage point) and the 2-4 day range; the latter consists largely of offers from banks and appears to confirm a rising trend in average costs for this segment. Data analysis by corridor A breakdown of average costs for individual corridors for the 150 amount allows us to further investigate the data available (Table 3): a generalized reduction in average costs is found across all corridors surveyed with the exception of Nigeria, which registered an increase of 1.12 percentage points, although overall within a declining trend beginning in April 2011 the increase in costs detected in the most recent survey (October 2011) is confirmed in many corridors, excluding those in South America Peru, Bolivia, Ecuador, and Colombia and the Philippine corridor, which in October followed a downward trend the largest contraction in average cost occurred in Morocco and Peru: nearly 2 percentage points Table 3 - Average costs for corridors surveyed - 150 12 Country/date Sep-09 Feb-11 Mar-11 Apr-11 May-11 Jun-11 Jul-11 Sep-11 Oct-11 Delta 13 Albania 8.11% 6.9 7.0 7.1 7.02% 6.9 6.9 7.39% 7.5-0.5 Bolivia 7.91% 7.0 7.91% 7.53% 6.9 7.33% 6.73% 7.1 6.2-1.6 Brazil 8.51% 7.0 7.2 7.80% 7.6 8.4 8.10% 8.0 8.29% -0.23% Ivory Coast 6.7 5.6 4.90% 5.1 5.2 5.19% 5.19% 5.19% 5.40% -1.3 China 12.49% 9.81% 11.43% 12.3 11.53% 11.4 11.00% 11.00% 12.1-0.33% Colombia 8.2 8.1 7.9 7.4 7.3 7.4 6.33% 7.4 7.0-1.22% Ecuador 5.99% 6.2 7.7 6.9 6.2 6.3 5.5 5.7 5.62% -0.3 Ghana 10.70% 8.71% 9.69% 9.80% 8.9 9.50% 7.7 8.6 9.0-1.6 12 The table does not show, taking as unquestioned the values of the average costs already published in the June 2011 report. 13 Variation expressed as percentage points between the September 2009 survey and the October 2011 survey. 14

Morocco 10.0 7.7 7.7 7.7 8.0 8.0 7.79% 8.02% 8.2-1.82% Nigeria 8.5 9.52% 9.7 10.23% 10.0 9.8 8.9 9.01% 9.6 1.12% Peru 7.9 7.11% 8.1 7.3 6.99% 6.92% 6.42% 6.6 6.0-1.8 Philippines 7.40% 6.71% 6.62% 7.1 6.9 6.79% 7.4 7.42% 6.9-0.42% Romania 5.81% 5.1 5.2 5.2 5.2 5.2 5.23% 5.09% 5.79% -0.02% Senegal 7.1 5.33% 5.2 5.19% 5.3 5.13% 5.09% 5.10% 5.7-1.3 An additional study looked into the course of the cost differential compared to September 2009 in the various surveys starting from February 2011, the date to which the first data analysis report from the mandasoldiacasa website refers. Naturally the precise date, tied to a survey conducted on a predefined day, presents certain difficulties due to the fact that it can be affected by incidental factors, but the trend in the spread over the months can in any event provide an image of the costs trend in the various corridors. Table 4 - Cost differential (percentage points) among the individual surveys and 1 September 2009 Country/date Feb-11 Mar-11 Apr-11 May-11 Jun-11 Jul-11 Sep-11 Oct-11 Albania -1.1-1.0-0.9-1.09% -1.13% -1.1-0.72% -0.5 Bolivia -0.8 0.00% -0.39% -0.9-0.59% -1.1-0.7-1.6 Brazil -1.4-1.2-0.72% -0.8-0.0-0.41% -0.4-0.23% Ivory Coast -1.11% -1.8-1.59% -1.51% -1.5-1.5-1.5-1.3 China -2.6-1.0-0.12% -0.9-1.01% -1.49% -1.49% -0.33% Colombia -0.10% -0.32% -0.80% -0.90% -0.83% -1.9-0.8-1.22% Ecuador 0.2 1.7 0.9 0.2 0.3-0.43% -0.2-0.3 Ghana -1.99% -1.01% -0.90% -1.7-1.20% -2.9-2.0-1.6 Morocco -2.33% -2.30% -2.32% -1.99% -2.02% -2.2-2.0-1.82% Nigeria 0.9 1.23% 1.69% 1.53% 1.3 0.42% 0.4 1.12% Peru -0.83% 0.2-0.5-0.9-1.02% -1.52% -1.2-1.8 Philippines -0.69% -0.7-0.2-0.42% -0.61% 0.0 0.02% -0.42% Romania -0.6-0.5-0.5-0.5-0.53% -0.5-0.72% -0.02% Senegal -1.81% -1.8-1.9-1.7-2.01% -2.0-2.0-1.3 This information, while confirming the declining costs trend in the corridors of Peru, Bolivia, Colombia, and Ecuador (which has followed a declining path since July 2011), with a growing spread, also highlights a pronounced slowdown in the reduction of costs that is distributed in the various surveys on Brazil and China. A final series of indicators about the trend of remittance transfer costs concerns their variability inside the individual corridors and the historic series. An increase in the amount of competition in an economic sector should in fact lead to a reduction in price variability, eliminating or eroding yield positions. The mean square deviation is a useful indicator of data variability compared to their average value. The analysis that follows looks at the trend in mean square deviations for the individual corridors measured compared to the initial survey (September 2009) and the latest available survey (October 2011). Reading the data provided in Table 5, an actual contraction can be seen in the variability index for half of the corridors surveyed, both in the 150 amount and for 300 (closer to the average amounts sent by foreign citizens residing in Italy), some with significant shifts. Table 5 - Mean Square Deviation average costs by corridor 150 - Mean Square Deviation 300 - Mean Square Deviation Country/date 1-Sep-09 4-Oct-11 Variation Country/date 1-Sep-09 4-Oct-11 Variation Albania 4.947 4.764 (-) Albania 3.682 6.553 (+) Bolivia 6.109 4.541 (-) Bolivia 8.477 7.893 (-) Brazil 6.139 6.263 (+) Brazil 9.390 9.687 (+) Ivory Coast 0.897 3.034 (+) Ivory Coast 2.395 3.701 (+) 15

China 3.824 4.475 (+) China 5.175 5.128 (-) Colombia 7.227 3.960 (-) Colombia 8.311 5.511 (-) Ecuador 4.181 2.642 (-) Ecuador 6.581 3.352 (-) Ghana 2.420 4.397 (+) Ghana 2.613 5.971 (+) Morocco 2.402 3.478 (+) Morocco 3.171 4.921 (+) Nigeria 1.898 3.952 (+) Nigeria 2.967 6.888 (+) Peru 6.212 4.461 (-) Peru 8.481 6.303 (-) Philippines 1.450 3.098 (+) Philippines 2.403 4.928 (+) Romania 5.619 4.715 (-) Romania 7.669 6.062 (-) Senegal 2.498 1.945 (-) Senegal 3.478 1.561 (-) Promotions One of the changes introduced in the course of 2011 in the survey of remittance costs was the possibility to report any promotions occurring in the various corridors and for the various amounts, providing adequate visibility on the site using a different color for the corresponding lines. The monthly nature of the surveys in fact made it possible, in agreement with the World Bank, to include this information that was previously excluded, since it makes an effective contribution to reducing remittance costs. In order to ensure correct and adequate information for users, also given the time gap between the date of the survey and the date the data is actually published on the site, rules for including the promotions were defined: i. the promotions must be valid in both of the cities where the survey is conducted (Rome and Milan); ii. the promotions must be active the day of the survey and valid for at least 40 days thereafter; iii. the duration of the promotion and all other information helpful to users must also be provided. Table 6 shows the number of promotions active in the last three surveys and a significant contraction in the last survey, an element that can help explain the change in the costs trend recorded precisely in the October 2011 survey. Table 6 - Promotions active for the three amounts surveyed July 2011 September 2011 October 2011 35 35 12 Qualitative notes (edited by Giulio Giangaspero) Field surveys make it possible to collect a series of qualitative information that can be paired with quantitative data regarding sending costs. Between March and October 2011 certain national and international events occurred that influenced the Italian remittances market. In particular, between March and May many operators active in Italy, both MTOs and banks, suspended the transfer of remittances to the Ivory Coast because of the civil war that had broken out in that African country. In June 2011, operators resumed these transfers. From the point of view of national events, the introduction in September of the 2% tax on the amount of transfers to countries outside the European Union had inevitable effects on the sending of remittances from Italy. Nonetheless, it is still early to sketch out a balance of the effects of the tax on sending 16

remittances, even if experience in the field (even if it cannot be considered a representative picture of the immigrants' world) did demonstrate a slight increase in customers who delayed their transfers to avoid paying the tax. Other important changes concerned the behavior of the MTOs with regard to determining the exchange rate applied. In the last semester we saw operators introducing exchange rate setting mechanisms more frequently: three times over the course of the day, constantly adjusting their offer to the trends in the exchange rate on the currency markets. In terms of alliances and new products or services offered, in September Western Union and the banking operator Intesa SanPaolo reached an agreement that allows users to send money from automatic ATM tellers via the Western Union business network. The service is also active online or by phone, for customers who have access to their current accounts through these two channels. The telephone platform offers only a system to order money to be sent, but does not constitute an actual payment system by phone, with credits and debits directly on the Sim card. In addition, in April 2011 the survey group also included the operator Transfast for the Latin American corridors covered by mandasoldiacasa.it: Bolivia, Brazil, Colombia, Ecuador and Peru. Through research in the field that accompanies survey work and ongoing contacts with migrants, it has emerged that Transfast is active in all Latin American corridors and is not a marginal player. Finally, a last quality note with regard to banking operators: in collections at the teller window, the degree of accuracy of information that can be gathered is always very dependent on the degree to which the bank teller is helpful and competent. In this sense, although an effort for greater transparency can be seen in the information sheets and other sources of access to information found in the company (i.e. automated kiosks), there is still room for improvement in the quality of information that the bank is able to provide at the window, including through training courses for staff. Conclusions The trend in average costs for sending remittances from Italy to the 14 corridors surveyed by the website www.mandasoldiacasa.it is confirmed to be in a downward trend sustained by the evolution of the Italian remittances market, characterized by a plurality of operators and a real commitment to reach the 5*5 goal, also confirmed by the collaboration and dialogue within the Italian Working Group of Remittances. The descending curve appears however to have experienced a slowdown corresponding to the last available survey, in October 2011, in which a plurality of incidental factors played a part: the introduction of the stamp tax on sending of remittances, whose final impact on costs and therefore prices cannot yet be clearly detected but which surely, in this period of uncertainty and vagueness regarding its application, has generated an effective negative impact on costs the October 2011 survey coincided with the end of a significant number of promotions active on the various corridors, and in particular offers by the postal operator, creating a negative effect on average costs. It is foreseeable that the possible expected renewal of the promotions, which demonstrated stability during the year, will bring values back within a now well-established trend 17

the trend of the exchange rate margin, which has moved against the market trend compared to the other two cost components, is surely affected by the greater variability of exchange rates linked to the international context and will be further monitored in upcoming months to assess its substance Surveys in upcoming months will make it possible to gain a more precise picture of these variables and to verify the solidity of the downward trend in average costs that has emerged from an analysis of the historic series or an actual inversion of the market trend, tied also to a possible resumption of the volumes of remittances from Italy. 18