FINANCIAL SERVICES ADVISOR a PUBLICATION of the DIALOGUE June 4-17, 2020

LATIN AMERICA ADVISOR FINANCIAL SERVICES ADVISOR A PUBLICATION OF THE DIALOGUE www.thedialogue.org June 4-17, 2020

BOARD OF ADVISORS FEATURED Q&A TOP NEWS Ernesto Armenteros Vice Chairman of the Board, BANKING Banco de Ahorro y Crédito Unión Will New Rules BBVA Argentina Pablo Barahona President & COO, Sees 36.2% Decline Global Retail Markets West, Liberty Mutual Group Improve Banking in Profit for Q1 Felipe Carvallo BBVA Argentina reported $3.1 Vice President - Analyst billion in net income for the first Latin America Banking for Brazilians? Moody’s Investors Service quarter, a 36.2 percent decline from the same quarter a year ago. Richard Child Page 2 CEO, Mattrix Group Michael Diaz Jr. PENSIONS Partner, Diaz, Reus & Targ Colombia May Ernesto Fernández Holmann Allow Partial Chairman of the Board, Ayucus Withdrawals From Rich Fogarty Pension Plans Managing Director, Alvarez and Marsal The country’s government may allow pension fund holders to Desiree Green make partial withdrawals during Vice President, Brazil’s central bank has approved new “open banking” rules that will allow banks to share International Government Affairs, consumers’ data with each other, among other measures. // File Photo: Empresa Brasil de the economic crisis caused by the Prudential Financial Comunicação. Covid-19 pandemic, said Finance Earl Jarrett Under new “open banking” rules approved by Brazil’s central Minister Alberto Carrasquilla. Chief Executive Officer, bank, Brazilian financial institutions can share, at their Page 2 The Jamaica National Group customers’ discretion, account holders’ personal and trans- Thomas Morante FINANCIAL TECHNOLOGY Chair, Insurance Regulatory & Q actional data with other financial institutions. The central Transactional Practice Group bank says the data sharing will promote competition among financial WhatsApp Kaufman, Dolowich & Voluck institutions and ease customers’ access to better products and services Manuel Orozco Launches Payment Director, at lower costs. To what extent will the new rules benefit customers? Feature in Brazil Migration, Remittances & Development, Inter-American Dialogue How much does open banking increase concerns about privacy and WhatsApp has launched a payments feature in Brazil that will Adalberto Palma-Gomez the security of customers’ information, and are consumers adequately Senior Partner, protected? How will the change affect Brazilian financial institutions and be free for individual users. Chief Proxy, Gobernanza Corporativa Operating Officer Matt Idema said their business models? Rodolfo Pittaluga Brazil is among the top countries Adjunct Professor, in which customers use WhatsApp Florida International University to communicate with businesses. Candido Botelho Bracher, president and chief executive College of Law Page 2 Fabian Saide officer of Itaú Unibanco Holding: “The new open banking Founder, CEO and President, rules have the potential to bring better products with lower Paykii costs for customers, as they facilitate the comparison among Roberto Teixeira da Costa A Founder & Board Member Emeritus competing offers and conditions. In addition, customers will be able to CEBRI use information aggregators, which will bring consolidated data about Mario Trujillo CEO, their relationship with different financial institutions, allowing for better DolEx Dollar Express planning and control of their finances. Customers will be protected both by the General Data Protection Law and by robust information security systems in the financial system. That said, in Brazil most of the financial fraud to clients is done by social engineering, that is, by groups that man- age to persuade clients to deliver information or carry out transactions that enable or characterize fraud. Open banking will bring greater ease and speed to transactions, in addition to a large flow of data between Idema // File Photo: LinkedIn. Continued on page 3

BANKING NEWS to interact with merchants, the unit’s chief NEWS BRIEFS operating officer, Matt Idema, told Bloomberg BBVA Argentina Sees News. More than five million merchants world- Remittances to Mexico wide use a business version of WhatsApp, and Drop 2.6% in April 36.2 Percent Decline the messaging application is the main, or only, online presence for many small retailers in In April, Mexicans living abroad sent $2.86 in Profit for Q1 some countries including Brazil. In Brazil, more billion back to relatives in Mexico, according than 120 million people use WhatsApp, Reuters to the country’s central bank, the Associated BBVA Argentina on June 8 reported $3.1 reported. “WhatsApp is heavily used there, Press reported June 5. The amount declined billion in net income for the first quarter, a 36.2 both by people and small businesses,” Idema 2.6 percent as compared to April of last year, percent decline from the same quarter a year told the wire service. “We think we can help but Mexico’s level of remittances did not drop earlier and 20.1 percent lower than the fourth grow digital payments, help grow the digital as sharply as transfers to some other Latin quarter of last year. “The quarter-over-quarter economy with small businesses, and help American countries, such as Guatemala and decrease is mainly explained by the fall in support financial inclusion.” WhatsApp hopes El Salvador. The average remittance amount in economic activity, and the sharp decline in the rollout in Brazil benefits customers who are April was $329, according to Mexico’s central interest rate derived from changes in the coun- quarantined at home during the coronavirus bank. In the first four months of 2020, Mexico’s try’s monetary policy and the beginning of the pandemic, Idema added. “We can’t have the remittances rose 12.6 percent, year-on-year. mandatory lockdown, due to [the] Covid-19 pan- kind of interactions with each other that we demic,” Ines Lanusse, the bank’s investor rela- normally would, if you want to lend someone tions manager, told analysts in a conference cash or if you want to buy something from a lo- Wells Fargo Reportedly call. Lanusse said the year-over-year decline cal business,” he told Reuters. Initially, holders in profit was mainly explained by the bank’s of debit and credit cards from Banco do Brasil, Pulling Payments Service one-time sale of Prisma Medios de Pago, which Nubank and Sicredi will be able to use the Zelle Out of Venezuela occurred in the first quarter of 2019. payments service, Reuters reported. In a state- Wells Fargo has reportedly told clients in Ven- ment, Visa said it is working with Facebook to ezuela that it will no longer support payments power the new payments feature on WhatsApp. service Zelle there, one of the most popular FINANCIAL TECHNOLOGY NEWS The payments on WhatsApp will use the capa- services in the Andean nation to send and bilities of Visa Direct and Visa Cloud Tokeniza- receive U.S. dollars, Decrypt reported June 8. WhatsApp Launches tion, the payment processor said. More than 60 percent of payments in Venezu- ela’s urban centers are made with dollars, and Payments Feature for about 12 percent of these payments used Zelle, PENSIONS NEWS according to Asdrúbal Oliveros, director of Ven- Users in Brazil ezuelan economic consultancy Ecoanalítica. Colombia May Allow Wells Fargo has not made a formal announce- WhatsApp, which is owned by Facebook, on ment, and it did not reply to Decrypt’s request June 15 launched a payments feature in Brazil, Partial Withdrawals for comment. Bloomberg News reported. It will be free for users to make payments using the messaging From Pension Plans platform, whether they send to other people or to businesses to pay for goods and services. Colombia may allow people to make partial Fitch Assigns Initial Rating WhatsApp will charge businesses a fee. The withdrawals from their pension funds during of BBB+ to Credicorp Facebook unit is partnering with Brazilian pay- the economic crisis brought on by the coro- Fitch Ratings on June 9 said it has assigned ments company Cielo to process the transac- navirus pandemic, Finance Minister Alberto Peru’s Credicorp an initial long-term foreign tions, Bloomberg News reported. Over the past Carrasquilla said June 10, Reuters reported. currency issuer default rating of BBB+ and a two years, WhatsApp has tested a payments As of the end of March, Colombia’s pension short-term issuer default rating of F2 with a feature in several countries, including Mexico funds held approximately 281 trillion pesos negative long-term outlook. The ratings agency and India. However, the rollout in Brazil, where ($77.13 billion) in compulsory and voluntary also assigned the Lima-based financial holding Facebook began testing the feature a month pensions, according to industry association company’s new senior unsecured notes a rating ago, marks the first location where the service Asofondos, which has opposed the withdrawal of BBB+. Credicorp’s ratings are mainly driven will be fully offered. Brazil is among the top plan, El Tiempo reported. “We have made great by the issuer default ratings of its main subsid- countries in which customers use WhatsApp strides regarding the subject of partial pension iary, Banco de Crédito del Perú, Fitch said.

withdrawals, we haven’t made a decision FEATURED Q&A / Continued from page 1 yet, but there have been meetings within the finance ministry, and we have spoken with different participants in the system. There- consumer data control, explaining principles pension and severance funds,” Carrasquilla fore, this type of fraud can be enhanced. of consumer protection and the protection said in a virtual appearance before a lower Institutions will have to compete in a more of their personal data and ensuring that the house congressional committee. He did not open market, in which competing business inclusion proposed by open banking does provide further details about the plan. Colom- proposals can be easily compared. The big not promote the increase in banking service bia is facing rising unemployment amid the question is the speed of customers’ adher- costs.” economic crisis, with unemployment reaching ence to open banking systems. In countries a historic 23.5 percent in urban areas in April, where open banking has already been im- Peter Baumgaertner and Paul representing more than four million people plemented, membership has generally been Bond, partners at Holland & without work. Additionally, the finance ministry lower than expected.” Knight: “Brazil’s central bank expects the economy to contract 5.5 percent A has issued a ‘Regulation on this year. Similar measures regarding pension Ione Amorim, economist at the Open Banking,’ supplemented by a circular withdrawals were proposed in other countries Brazilian Institute of Consumer on guidance. This regulation encourages, in the region, including Peru and Chile. In Peru, Defense (IDEC): “IDEC believes and in some cases requires, the implementa- Congress approved partial withdrawals of 25 A that the movement toward tion of open banking, defined as ‘a standard- percent, El Tiempo reported. A similar proposal opening the financial market to new entrants ized sharing of data and services through failed in Chile. is highly positive and should be considered the opening and integration of systems’ fundamental to deconcentrating this market pursuant to customer authorization. The to the benefit of the consumer. However, central bank describes a phased implemen- REMITTANCES NEWS the rules that will be implemented between tation. This will eventually include consumer November 2020 and October 2021 should better explain the rights and guarantees U.S. Sanctions Cuban of the consumer, precisely determining Brazil may ... shape Companies Including the duties of the institutions when dealing the global debate over with the consumer. For IDEC, it is worrying data portability as a Remittance Firm that the open banking rules come into workable model, or force before the approval of the General as a cautionary tale.” Data Protection Law, which was postponed The United States on June 3 added seven — Peter Baumgaertner & Paul Bond Cuban companies and hotels to its list of to May 2021. This mismatch is worrying entities under sanctions, Agence France-Press because many of the fundamentals in the reported. The list includes Fincimex, a financial open banking rules must be guided by the information relating to demand deposit or company that handles remittances to the data protection law. The complexity of the savings accounts, payment accounts or Communist-run island, as well as hotels and system, which involves technical issues, credit operations; registry and transactional other hospitality businesses controlled by the social issues and various institutions, for the information; loan proposals; and foreign Cuban military, the State Department said. “We benefit of consumers and to foster financial exchange operations, investments, insur- will continue to stop the flow of money into inclusion, would require a greater debate ance and open pension funds, among other the pockets of those who oppress the Cuban among these different actors to understand financial products. Financial institutions and people,” Secretary of State Mike Pompeo tweet- the effects and the importance of these fintech companies operating in Brazil and ed. Critics of the sanctions say remittances new mechanisms. A broader debate on the around the world will be watching closely to are a lifeline to poor families in Cuba lacking proposed regulation contributes to reducing see how this process plays out, balancing basic necessities, Reuters reported. Under the asymmetry of existing information on consumer choice and competition against Republican President Donald Trump, the United a topic that will influence the Brazilian con- privacy and data security risks. For example, States has reversed the thaw in relations with sumer. Although the open banking system it is not yet clear how the larger banks will Cuba that began under his predecessor, Barack aims to increase the well-being of Brazilian be compensated for the sharing of this Obama, although some observers say Cuba consumers among the objectives of its im- information (as the regulation only provides never robustly opened up to the United States plementation, it does not present a focus on a limited number of free accesses). Also, even then. Cuban Foreign Minister Bruno Ro- the rights of individuals directly affected by while Brazil’s plan may considerably increase dríguez tweeted it was “shameful and criminal the change. It is also necessary to focus on the volume and instances of consumer-au- to intensify the blockade” during the Covid-19 Continued on page 6

COPYRIGHT © 2020, INTER-AMERICAN DIALOGUE PAGE 3 FINANCIAL SERVICES ADVISOR June 4-17, 2020 pandemic, which has hit the country’s tourism sector hard. Cuba recently cited the economic ADVISOR Q&A fallout of the pandemic in asking the Paris Club of major bondholders for a delay in the repay- ment of its debt until 2022. The island nation Will the United States and Brazil had already missed more than $30 million in payments last year, originally committing to Reach a Free-Trade Agreement? settling those debts in May. [Editor’s note: See Nearly a year ago, U.S. commitments is neither feasible nor realistic related Q&A in the June 3 issue of the daily President Donald Trump said at this time. As such, both presidents made Latin America Advisor.] he would pursue a free-trade the practical decision to focus on what is Q agreement with Brazil, suggest- achievable with negotiations underway to ing that a warm relationship with Brazilian address non-tariff barriers. The chapters POLITICAL NEWS President Jair Bolsonaro could lead to lower under discussion—good regulatory practices, trade barriers between the Western Hemi- trade facilitation and digital trade—would Venezuela’s Supreme sphere’s two largest economies. But Demo- improve the business environment for U.S. crats in the U.S. House of Representatives investors in Brazil while reaffirming Brazil’s Court Seats New this month signaled that they would block commitment to implementing OECD stan- a trade deal, citing human rights concerns dards in these areas. Inclusion of a robust Elections Authority under the Bolsonaro administration. Are digital trade chapter is particularly important plans for a U.S.-Brazil free-trade agreement to many U.S. companies, especially with the Venezuela’s Supreme Court, which is loyal to on track, and how strong is opposition to following points: 1.) requiring intermediary li- President Nicolás Maduro, on June 12 seated the effort in Brazil and the United States? ability safeguards to ensure that Internet ser- a new elections commission, a move that What would an agreement mean for the two vices can host content and communications came ahead of this year’s planned legislative countries? What are the biggest sticking from users without automatically becoming election, the Associated Press reported. The points that could prevent a deal? liable for that content; 2.) guaranteeing opposition quickly denounced the high court’s the free flow and storage of data across action. “If we don’t recognize this farce of a Gabrielle Trebat, managing borders and prohibiting the localization of Supreme Court, we don’t recognize anything it director for Brazil and the data and computing facilities in all sectors; produces,” the opposition-controlled National Southern Cone at McLarty 3.) reaching a multilateral solution to tax Assembly’s first vice president, Juan Pablo Associates: “The U.S.-Brazil challenges arising from the digitalization of Guanipa, said in a tweet. “As Venezuelans, we A relationship is experiencing its most positive the economy and prohibiting discriminatory make our demand to the world for a free vote!” moment of the past decade with numerous digital taxation measures that contravene The National Assembly is the only branch of commitments made between Presidents international taxation principles; and 4.) al- Venezuela’s government that Maduro does not Trump and Bolsonaro to bring the two coun- lowing for modern uses of data, such as fair control, and dozens of countries recognize the tries closer together diplomatically. Notwith- use and text, and data mining rules to enable legislature’s leader, Juan Guaidó, as Venezu- standing the political approximation, money digital analysis and use of information for ela’s legitimate interim president. If Guaidó is being left on the table economically in artificial intelligence, machine learning and loses that position, it is unclear whether they the absence of a comprehensive free-trade related purposes.” would continue to do so. After the opposition agreement, with total bilateral trade just over won control of the National Assembly in late $100 billion. For U.S. industry, an FTA has 2015 and before Maduro’s allies had to give long been an objective, but political realities up control of the legislature, they stacked EDITOR’S NOTE: More commentary on this in both countries, including a complexity the Supreme Court with his supporters. The topic appears in the June 15 issue of the of viewpoints in the U.S. Congress and high court went on to sideline the National Latin America Advisor. Brazil’s commitments under Mercosur, mean Assembly by voiding its actions. In 2017, that achieving an FTA with market access Maduro’s government created a new, powerful legislature, the Constituent Assembly, made up agreement with the ruling party on minimal on time, but legislators said the country’s entirely of his supporters. The Supreme Court’s guarantees for a free and fair election, the AP constitution reserves for the National Assem- move to seat a new elections commission was reported. The previous week, the high court bly the right to select elections commission disheartening to some of Maduro’s moderate ruled that the National Assembly had failed to members. The court added two members opponents who had been seeking to reach an name members of the elections commission from outside Maduro’s party to the elections

NEWS BRIEFS commission in order to give it an appearance those wishing him a speedy recovery. “We ask of balance, Luis Vicente León, president of God for his quick recovery and good health,” Brazilian Treasury Caracas-based polling firm Datanalisis, told the President Danilo Medina said in a posting on wire service. However, the court’s action did Twitter. Medina, of the Dominican Liberation Secretary Announces not result from any political negotiation that Party, has served two consecutive terms and is Departure, Markets Roiled involved opposition leaders’ participation, he ineligible for re-election. Gonzalo Castillo, the Brazilian financial markets were turbulent June added. candidate of Medina’s party, trailed Abinader by 15 following news that the country’s treasury two percentage points in a recent poll by Mark secretary, Mansueto Almeida, is to step down, Brazil Has World’s Penn/Stagwell. In the poll, Abinader led with 39 Reuters reported. Almeida is seen as an ad- percent. The Dominican Republic’s presidential vocate for fiscal discipline. Economy Minister Second-Highest and legislative elections next month were post- Paulo Guedes told Reuters on June 15 that poned from May because of the coronavirus Bruno Funchal, currently the ministry’s director Covid-19 Death Toll pandemic. If no candidate receives a majority of programs, will succeed Almeida by the end of the votes on July 5, a runoff would be sched- of July. On June 15, Brazil’s real fell as much Brazil on June 12 became the country with uled for July 26. as 3 percent against the U.S. dollar. the second-highest death toll from Covid-19, surpassing Britain and behind only the United States, but the World Health Organization said ECONOMIC NEWS Chilean President the Latin American country’s health system was withstanding the pressure, Reuters report- Replaces Health Minister ed. As of June 16, Brazil has registered more Peru’s Economy Chilean President Sebastián Piñera on June than 888,000 confirmed cases of coronavirus, Contracts by More 13 replaced Health Minister Jaime Mañalich and 43,959 people are confirmed to have died amid controversy over the country’s figures from the disease in Brazil, according to a tally Than 40% in April for deaths from the coronavirus pandemic, by Johns Hopkins University. “The system Reuters reported. Piñera praised Mañalich, as such from the data we see is not over- Peru’s economy contracted by more than 40 saying he had spared “no effort” in carrying whelmed,” said Dr. Mike Ryan, the WHO’s top percent year-on-year in April, the government out a “difficult and noble duty.” Piñera named emergencies expert, adding that few areas in said June 15, Agence France-Presse report- Enrique Paris, an academic and medical Brazil are using more than 80 percent of their ed. The Andean nation has been among the doctor, as Mañalich’s successor. Chile’s official hospitals’ intensive care bed capacity, The New hardest hit by the coronavirus pandemic in number of deaths from Covid-19 is more than York Times reported. Latin America, despite being one of the first 3,300, but investigative website Ciper reported to implement strict quarantine measures June 13 that the health ministry told the WHO in March. Mining output in Peru, one of the that as many as 5,000 deaths in the country Leading Candidate in world’s largest producers of copper, gold and were linked to Covid-19. Dominican Republic silver, shrank by more than 42 percent in April. Overall, economic activity dropped nearly 50 Has Covid-19 percent, according to the national statistics Argentina Again Extends institute. The plunge in April “reflects the unde- Luis Abinader, who is leading the polls ahead performance of most productive sectors, with Deadline for Debt Talks of the Dominican Republic’s July 5 presidential an impact on trade, production, construction, Argentina’s government has again extended a election, has been diagnosed with Covid-19, mining, hydrocarbons, transportation, hotels deadline for international creditors to accept Reuters reported June 11. Abinader said his and business services,” the institute said. The its debt restructuring offer, Bloomberg News wife has also tested positive. “Be tranquil economy had already contracted by more than reported June 12. The government pushed because with God’s grace, we will recover 16 percent in March, after having previously back the deadline by one week, to June 19, the quickly,” Abinader, 52, said June 10 on social recorded 127 months of consecutive growth. economy ministry said in a statement. Argen- media. The presidential candidate added that President Martín Vizcarra’s government on tina defaulted last month, but investors have his doctors expect a full recovery because he is June 15 announced a public investment plan said they are not likely to pursue legal action, not a high-risk patient. Abinader, of the social dubbed “Arranca, Perú,” or “Get Off the Ground, the news service reported. Argentina and the democratic Modern Revolutionary Party, said Peru,” in a bid to create more than one million creditors are seeking to renegotiate $65 billion he and his wife are self-isolating at their home. jobs in the second half of the year, state-run in international bonds. Abinader’s political opponents were among news agency Andina reported.

FEATURED Q&A / Continued from page 3 FINANCIAL SERVICES ADVISOR is published biweekly by the Inter-American Dialogue, Copyright © 2020 thorized sharing, it does not explain how the (and low-cost) service to the client (lending, central bank will assign responsibility and li- investment products and other services). In Erik Brand ability in the event of a data security breach. parallel to open banking discussions and im- Publisher [email protected] While in many ways Brazil’s new initiative plementation, the Brazilian government has mirrors the U.S. Consumer Financial Pro- established a regulatory framework. This Gene Kuleta Editor tection Bureau’s 2017 Consumer Protection [email protected] Principles: Consumer-Authorized Financial Anastasia Chacón González Data Sharing and Aggregation, those U.S. Both banks and Reporter & Associate Editor guidelines did not constitute new law. Brazil fintechs will face the [email protected] may therefore shape the global debate over challenge of ensuring data portability as a workable model, or as a adequate treatment cautionary tale.” Michael Shifter, President of clients’ data.” Rebecca Bill Chavez, Nonresident Senior Fellow — Pedro Carvalho Leandro Vilain, director of Sergio Bitar, Nonresident Senior Fellow business policies and opera- Joan Caivano, Director, Special Projects tions at the Brazilian Federation Michael Camilleri, Director, Rule of Law Program A of Banks (Febraban): “Febraban includes Law 13.709, which protects client Kevin Casas-Zamora, Nonresident Senior Fellow believes that open banking is a positive information, to be implemented in August. Héctor Castro Vizcarra, Nonresident Senior Fellow initiative that encourages innovation and will This encompasses the responsibilities and Julia Dias Leite, Nonresident Senior Fellow bring customers greater convenience and a requirements of agents involved in clients’ Ariel Fiszbein, Director, Education Program better experience with financial services. It data sharing, which may reduce the risk of Peter Hakim, President Emeritus will also give customers greater autonomy in leaks of client information. Accordingly, both Nora Lustig, Nonresident Senior Fellow the use of their bank information, facilitating banks and fintechs will face the challenge Margaret Myers, Director, Asia and Latin America Program sharing with other institutions participating of ensuring adequate treatment of clients’ Manuel Orozco, Director, Migration, in the system and authorized to operate by data. Larger banks won’t need additional Remittances & Development Brazil’s central bank. The Brazilian bank- cybersecurity infrastructure investments to Xiaoyu Pu, Nonresident Senior Fellow ing industry is engaged and active in this operate open banking APIs. However, it may Jeffrey Puryear, Senior Fellow process and will make positive contributions be a concern for smaller participants given Mateo Samper, Nonresident Senior Fellow to the entire program, maintaining the neces- limitations of their resources vis-à-vis the Tamar Solnik, Director, Finance & Administration sary security for its customers and long-term data volume that they might deal with (which Lisa Viscidi, Director, Energy Program sustainability for the project.” could also translate into an image risk) Denisse Yanovich, Director of Development and and also a vulnerability for hackers. Fitch External Relations Pedro Carvalho, associate understands that open banking and other Financial Services Advisor is published director at Fitch Ratings: “Brazil initiatives from regulators (for example, biweekly, with the exception of major holidays, has a highly concentrated bank- instant payments) are paving the way for the by the Inter-American Dialogue at 1155 15th Street NW, Suite 800 A ing industry. Fintechs and other banking industry’s transformation. Larger Washington, DC 20005 smaller entities usually struggle to reach players are reducing the number and size of www.thedialogue.org a reasonable scale of client base, mainly branches, increasing the digital transforma- ISSN 2163-7962 due to lack of knowledge of their credit tion and user experience.” Subscription inquiries are welcomed at behavior. Open banking will allow clients to [email protected] share account information (mainly historical The Advisor welcomes comments on its Q&A lending data) with third-party entities. These section. Readers can write editor Gene Kuleta The opinions expressed by the members of the Board of Advisors and by guest commentators do not necessarily entities are expected to offer a suitable at [email protected]. represent those of the publisher. The analysis is the sole view of each commentator and does not necessarily represent the views of their respective employers or firms. The information in this report has been obtained from reliable sources, but neither its accuracy and completeness, nor the opinions based thereon, are guaranteed. If you have any questions relating to the contents of this publication, contact the editorial offices of the Inter-American Dialogue. 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