In these last two months of August and September of this electoral year 2023, we see daily on all news portals that the BCRA day after day buys dollars in the exchange market.
During the month of August, the monetary entity purchased USD 1087 million and so far in September it has purchased USD 512 million, chaining together 26 consecutive operating sessions of net purchases in the single and free exchange market.
Net purchases at the MULC increased as of 14/08/2023 after the PASO elections with the 23 percent devaluation of the official exchange rate, which went from $283 to $350 and was used by exporters to liquidate foreign currency.
This, in appearance, would represent a certain bonanza in the exchange market and would also be demonstrating a stable, firm trend of the BCRA buying dollars in so many days, which would suggest that the monetary authority would be genuinely rebuilding reserves through foreign exchange earnings from exporters of goods and services.
Let us remember that the BCRA has a negative net balance of USD 1.767 million since the beginning of the year until September 2023.
But what is not known, or at least not in the headlines of all the newspapers, is the hidden obstacle to paying for imports, especially from the last week of July until now.
Let us remember that Communication A 7622 of the BCRA and General Resolution of the AFIP 5271/2022 established the system of consultation and registration of exchange operations called “Single Current Account for Foreign Trade”, in which the entities authorized to operate in the Free Exchange Market by the BCRA must consult and record the amount in pesos of the total of each of the exchange operations at the time it is carried out. For these purposes, they must access the service called “Single Current Account for Foreign Trade”, through the website of the FEDERAL ADMINISTRATION OF PUBLIC REVENUES (1).
Furthermore, said Communication A 7622 of the BCRA establishes that banks may, as of 17.10.22, provide access to the foreign exchange market to make payments for imports of goods for operations associated with a declaration in the Import System of the Argentine Republic (SIRA) to the extent that the payment is made once the term has been met in calendar days, counted from the date of the customs entry registration of the goods, which appears in the SIRA declaration.
That is to say, on the one hand we have the Single Foreign Trade Current Account, and on the other hand the SIRA (Argentine Republic import system); with these two elements there have been hidden obstacles in the payment of imports of goods and services that can be detailed below:
- The AFIP CCUCE (Single Foreign Trade Current Account) page is not working or is out of service, therefore, banks cannot record payment transactions.
Many times the aforementioned CCUCE did not work for the whole day or worked for a few hours.
- Appearance of unknown errors, such as concept code 46 (“The operation cannot be registered”) or concept 47 (“The operation cannot be registered”). In fact, it was informally learned that only those imports for which the SIRA payment term has not exceeded 30 days of expiration can be paid. That is, if the SIRA payment term is August 20 and you want to pay on 22/09/2023, the CCUCE will throw error 46 or 47. This has a very big impact, since only imports due in the last month can be paid; everything due before 30 days cannot be paid, at least until the registration in the CCUCE is in force. And the stock of unpaid overdue debt on imports will increase day by day.
- New errors due to payment in cross currencies that do not allow the recording of operations, for example, the delivery to the market is in dollars and euros are paid abroad.
- Another very common error is that the CCUCE application does not allow the registration of operations when they exceed 10 or 15% of the FOB value, therefore, operations with CIF, CPT, CIP are generally rejected because it does not validate the freight and insurance.
- Another obstacle encountered daily is that importers who have a payment date established in the SIRA when the merchandise was shipped to the market, when the time for payment arrives, magically and without any notice to the registry, the payment date is moved forward to a period of between 60 or 90 days.
- Another flaw is that in the SIRA, in the “Final Term” field, the term does not appear in numbers, but instead there is a dash, and therefore it cannot be paid.
Based on the above, the fact that the Single Foreign Trade Current Account did not work or worked for only a few hours a day, the appearance of errors in the records with codes 46 and 47 for debts greater than 30 days, payment in crossed currencies, payment up to 10 or 15% of the FOB value and the shifting of the SIRA payment dates, the dash on the SIRA payment date, means that the validations of the banks of the entire financial system are effective in 30 or 35%; the rest, 70 or 65%, are rejected.
Payments for services are a separate item, since the concepts of professional services, legal services, advertising services, research and development services, and architectural services cannot be paid as of 20.04.2023/7746/XNUMX under COM A XNUMX BCRA.
Therefore, with all these hidden obstacles to import payments, it is reasonable for the BCRA to buy foreign currency in the exchange market on a daily basis since the flow of import payments has been considerably reduced in the last 60 days or so.
Thus, the total unpaid overdue debt on imported goods, estimated at more than USD 16.000 billion to date, is increasing day by day and is estimated to accumulate at a rate of USD 1.000 per month from now until 10/12/2023, the date of the inauguration of the newly elected government.
The debt left for the next government, including unpaid overdue debt for imports of goods and services plus import financing granted by suppliers or banks abroad, dividends and loans between related companies, makes it very difficult to lift foreign exchange restrictions immediately as of 11/12/2023 without establishing clear and reasonable regulations that allow debts to be paid off according to a payment schedule that must be established by the next administration, for which it is necessary to simplify this entire tangled system of import payments and for exporters to be able to collect foreign currency at the real price and without being subject to withholdings.
He is a certified public accountant from the University of Buenos Aires (UBA). He has a postgraduate degree in Finance from the Universidad Argentina de Empresas (UADE). Currently, he is Head of the Comex Technical Area at Banco Santander Argentina, since 1987. He also serves as Secretary of the Comex Commission at the Association of Argentine Banks (ABA), since 2011. He has been married for 34 years to Adriana Barsanti, and has three children aged 33, 31 and 26, all professionals.