Naira exchange rate stability and the Irrelevancy theory of the Bureau de Change By JONA N. EZIKPE

1. Introduction.
There has been clamor by the Bureau De Change (BDC) operators for their readmission into the Investors and Exporters (I&E) window, now known, as the Nigerian Autonomous Foreign Exchange Market (NAFEM).
With the re-listing by the new CBN Governor Mr. Cardoso of the 43 items hitherto, banned from the list of eligible items that can access the NAFEM, there maybe renewed pressure on the CBN to readmit BDCs into the NAFEM under the current regime of single floating rate of the Naira.

2. The Structure Of The Nigerian Foreign Exchange Market
The Nigerian foreign exchange market is structured along the line of participants in the market. The major market participants are the following institutions which include the CBN, licensed dealers namely: the DMBs and the BDCs. Others are the traders mostly individuals operating in the informal sector of the foreign exchange market namely: the Abokis or Mallams you see at the International Airport, Balogun Market in Lagos Island, Bristole Hotel Lagos, Ikeja and other parts of Nigeria, Nigerians in Diaspora who send money to relatives in Nigeria. Those remittances end up in the foreign exchange market.

CBN: CBN is the major supplier of foreign exchange in the market. It is the recipient of the foreign exchange flows from oil and non-oil exports of Nigeria, including foreign exchange flows from invisible transactions. These foreign exchange flows are accounted for as foreign reserves of Nigeria.

DMBs act as whole sellers of foreign exchange in the market by the CBN classification. They attend mostly to major consumers of foreign exchange which include, importers of goods and services and investors in Nigeria that want to repatriate their capital plus dividend. They also service individual users of foreign exchange for Business and Personal Travel Allowances. Those that require medical attention abroad, can equally obtain Medical Travel Allowance. Guardians of Nigerians studying abroad pay for their wards’ school fees. They source their foreign exchange mostly from the CBN.

Bureaux De Change (BDCs). BDCs are by CBN classification the retailers in the foreign exchange market. They are supposed to serve the small users of foreign exchange for travel purposes and other small uses of foreign exchange. They are designed to reach those users of foreign exchange who may not have easy access to banks or major financial centers. Ordinarily, BDCs are mostly located at the entry ports of a country. They are usually patronized by travelers coming from abroad who may want to exchange their foreign currencies to local currency to enable them, pay for hotel, taxi, bills etc. In Nigeria, BDCs are allowed to buy foreign exchange from the CBN. However, their participation in the foreign exchange market has been suspended.

d. Black Market or Informal Market
Black market participants are those that are not licensed by the CBN. They consist of individual traders who buy and sell foreign currencies. They do not render monthly returns on their operations to the CBN. This segment of the foreign exchange market is dominated by the Abokis or Mallams, an expression used in common parlance. The Black Market traders or money changers have been in existence since time immemorial. They and Money lenders were found at the gate of Babylon during the Babylonian Empire. These traders are usually at the fringe of society. Trading in foreign currencies becomes almost the only source of livelihood, hence it is usually difficult to exclude them from the foreign exchange market by executive fiat. Attempts, have been made by various administrations of Nigeria to close the Black Market but to no avail. Due to lack of documentation requirements in this market segment, a lot of people tend to patronize the Black market dealers. This market has come to stay and nobody can wish them away in the scheme of things.

3. Exchange Rate Determination
Exchange rate is the unit of a country’s currency that will exchange for a given unit of a foreign currency. For example, the Naira/Dollar exchange rate is the amount of Naira you need to exchange or obtain one dollar. Currently, the exchange rate of Naira to Dollar is above N1000/1$ in the Black market. Exchange rates are relevant because of International trade in goods and services where transactions and obligations are settled in currencies other than the local currency. The United States of America dollar serves as the reserve currency. Reserve Currency means that the currency in question, is sufficiently or widely held by many central banks or monetary authorities of various nations. Payments or International Settlements between countries in international trade are made mostly in dollars and those dollars are held as foreign exchange reserves for that particular country. If Nigeria sells oil to say a USA buyer, Nigeria will be paid in dollars, because dollar is not a legal tender in Nigeria and cannot be legally used in domestic settlement or payment for goods and services. Those dollars earned as proceeds of oil sale are held in American banks and constitute the foreign reserves of Nigeria. Hence, changes in the exchange rate of the Naira vis-à-vis the dollar and other convertible currencies will depend on the ability of Nigeria to export more goods and services than it imports. The Naira will strengthen or appreciate when Nigeria generates more foreign exchange than it consumes and the reverse is the case when Nigeria uses more foreign exchange than it generates and that results in the weakening or depreciation of the Naira. The CBN has practiced different exchange rate regimes in an attempt to stabilize the value of the Naira. They include among others, Fixed Exchange rate where the Naira value relative to the Dollar is fixed or constant. You have the Managed Float were the Naira exchange rate is allowed to fluctuate within a given band. There is the Multiple exchange rates were the CBN divides the foreign exchange market into various segments, like the Official market, the I&E market, the BDC market etc. and determine the rate for each market segment. The Black market rate which is assumed to reflect the true value of the Naira exchange rate is not under the CBN control. The rate in that market is said to depend on the supply and demand conditions in the market for foreign exchange. The exchange rate of the Naira vis-a-vis other convertible currencies has been depreciating since the Structural Adjustment Program (SAP) of General Ibrahim Babangida when the foreign exchange rate regime moved from fixed to managed float. That was the first attempt to deregulate the foreign exchange market. Every CBN Governor, has tinkered with the admission or otherwise of BDCs into the CBN official foreign exchange window with no avail. Between the introduction of SAP and now, the Naira has lost substantial value as reflected in the exchange rate depreciation, which has macro-economic effects in terms of inflation, interest rate, debt service obligation, prices, employment, poverty alleviation and standard of living of Nigerians.
The merging of the various segments of the foreign exchange market into the I&E window or NAFEM has resulted in a single floating rate. The participants in the NAFEM are CBN, DMBs, Willing buyers and Willing sellers and End users. BDCs are excluded from participation. The rate in the I&E window is suppose to be market determined in the sense that Willing buyers and Willing sellers will agree on a rate. The resultant rate becomes the prevailing exchange rate of the Naira in that particular trading day. Currently, the I&E rate is about N791/1$. However, it is important to note that this rate is still far apart from the Black market rate of about N1000/1$ which was suppose to reflect the true value of the Naira. See Hasan Mohammed (Understanding Monetary Policy Series-CBN Monetary and Exchange Rate Policies) for a detail discussion on foreign exchange management in Nigeria.

4. Argument Against Admitting BDCs Into The I&E Foreign Exchange Window Or NAFEM
Different CBN Governors have allowed the BDCs into the CBN official foreign exchange window, while other have banned them as it is presently the case. The reasons for allowing or banning the BDCs have ranged from various infractions in the foreign exchange rules to lack of meaningful contributions to the economy. An economic unit is said to contribute positively towards growth and development with the resultant wealth creation and prosperity if that unit, is able to reduce the cost of allocating scarce resources in a price coordinated economy. Presently, the Emefiele CBN banned the BDCs from the official foreign exchange window. President Tinubu Administration has deregulated the foreign exchange market and allowed the rate to float under a single floating rate regime. The question to be answered next in this paper, is whether the CBN should readmit the BDCs into the NAFEM within the framework of the on-going economic deregulation policy of the Tinubu government.

4a. The Irrelevancy Theory Of Bureau De Change

Allowing BDCs to source foreign exchange from the I&E window or NAFEM under the single floating exchange rate regime, will defeat the objective of deregulating the market as it will, introduce distortions by fueling speculation in the market and the resultant multiple exchange rates.
That BDCs have not been able to either appreciate or stabilize the Naira exchange rate under whatever regime because, the issue of exchange rate stability, has to do with the supply side of the market. That Nigeria has a foreign sector that is highly import dependent, thus, the supply of foreign exchange has not been able to meet the demand.

Furthermore, the Irrelevancy school argued that by splitting the foreign exchange market into various segments with the attendant rates does not increase the value of the Naira as Naira value, depends on the ability of the CBN to fund the excess demand in the market. That BDCs have nothing to offer or bring to the market place.
That the ability of CBN to fund the foreign exchange market is in question due to the dwindling inflow of foreign exchange arising from crude oil theft, low non oil sector exports, high foreign debt servicing amount and gross leakages and lack of accountability of foreign exchange earnings associated with corruption in the system.
The Irrelevancy school went further to argue that BDCs have been the major conduit for money laundering and corruption. That it is easy to give and accept bribes in dollars rather than carrying the equivalent of such amounts in Naira. That public officials, find it easy to receive bribes in dollars and transport them across international boundaries than open Naira accounts in local banks which can be easily detected and garnered should there be probe on such officials.
BDCs the Irrelevancy school argued, are likely to demand for a separate rate from the I&E rate as they will argue that they were allowed a margin under the multiple exchange rates regime to cover their operating cost plus profit.
That when such is not feasible under the deregulated foreign exchange market, that BDCs being profit making organizations will encourage patronage of money launderers and take their requests as willing buyers to the l&E window or NAFEM. That they will collude with some authorized dealers as willing sellers to purchase foreign exchange at prices that can cause greater volatility to the exchange rate. Hence, BDCs should not be allowed to participate in the NAFEM.
The Irrelevancy school argued that BDCs will not increase market liquidity because they have not been able to mobilize foreign exchange from the autonomous sources other than depend on the CBN window.

That local banks with foreign branches do open off-shore accounts for BDCs and use such accounts to launder money. These facts were disclosed when former President Buhari on assumption of office, attempted to probe the administration of former President Goodluck Jonathan. We were told the huge dollar sums that BDCs traded with their customers which were far above the limit authorized by the CBN.

The Irrelevancy school argued that BDCs will not increase market liquidity because they will not be able to get a Willing buyer and Willing seller. Ordinarily, they have not been able to mobilize foreign exchange from the autonomous sources other than depend on the CBN window.

That the number of licensed BDCs which at last count is more than 5000{five thousand) is so unwieldy that it will be difficult to properly supervise their activities, given the amount of paperwork associated with returns they render to the CBN. Moreover, they argued that the CBN does not have the necessary manpower to sufficiently and effectively regulate and supervise the BDCs.

The Irrelevancy school said that if BDCs are allowed to participate in NAFEM that it will increase market speculation as they would artificially cause the Black Market rate to rise so that arbitrage profit will exist for those that move across market segments.

The Irrelevancy school further argued that even if the BDCs are allowed to participate in the Order-based two-way quote system of NAFEM, that their number will be so cumbersome to allow CBN officials or Central Counter Party(CCP) to clear the transactions in a timely fashion. That even with the computerized CBN operations, that returns or bids from some of these BDCs are bound to be fraught with errors as the staff of the BDCs are not well trained and equipped to make accurate returns or bids.

That the activities of the BDC owners are more of rent seeking than contributing meaningfully to the growth of the economy in terms of real output. That some of the owners of the BDCs include Senators, Bureaucrats, Judges, Military, Traditional rulers. That these owners do not have any idea on how an efficient foreign exchange market should operate, hence, they cannot give or recommend ways of improving the market to the policy makers. That those owners see the BDCs as means of making quick income or profit that does not reflect the attendant market risk as there is no risk to mitigate in the first place. Hence, in an economy were profit is made without the commensurate risk, that scarce resources in this case foreign exchange, is not optimally allocated. That the activities of the BDCs have neither reduced risk nor lowered the cost of allocating scarce resources which is foreign exchange such that the economy or the society will be better off.

That the economy will be more productive if the labor employed in the BDCs are deployed to the real sector of the economy where they can produce some of the goods that the nation imports from abroad which have been the source of weakening the exchange rate of the Naira.

The Irrelevancy school went on to say that the existence of BDCs is a source of corruption even in the CBN itself. That most of the BDCs are owned by some of the CBN officials. That the unwidely number of BDCs is not necessary given the size of the foreign exchange market as measured by the volume of foreign exchange that is brought to the market on a given trading day. That CBN officials demand gratification in licensing those BDCs which is a source of corruption. That CBN officials approve BDC licenses for government officials as a means of curring favors.
The Irrelevancy school therefore, concluded that admitting BDCs into the foreign exchange window of the CBN now, in the light of the deregulation of the market and the emergence of the single floating rate, will be counter productive and will defeat the whole concept of economic liberation policy of President Tinubu Administration. They said that foreign exchange rate is a key macro-economic variable whose changes, affect other critical variables in the system such as the general price level. That any disturbance emanating from the foreign exchange market by allowing BDCs to access the CBN window, will be transmitted to other sectors or markets in the economy such as the commodity, labor, loanable funds etc markets.

4b. The Relevancy Theory Of Bureau De Change

The Relevancy theory school of thought, argued that BDCs are relevant in the smooth functioning of foreign exchange market. The reason being that, they serve foreign exchange users who may not have access to DMBs because, they do not maintain account relationship with them or they are not near financial centers. They argued that BDCs are at the retail end of the foreign exchange market spectrum
The Relevancy school believes that BDCs, contribute to the stability of the foreign exchange market whether under the multiple exchange rates regime or the newly introduced single floating rate if they are allowed to participate in NAFEM. They said that under the multiple exchange rates regime, CBN determines the rate and margin within which they can sell. That usually, the BDC rates are lower than the Black market rates and both the BDCs and Black market dealers serve the same end users. That customers tend to switch and patronize BDCs because of the lower rate thus, making the exchange rate to be relatively stable and approximate the rate obtainable at the Black market. That Black market rate is assumed to serve as the barometer of the true Naira value as it is considered, to be determined by the forces of demand and supply in the foreign exchange market.

The Relevancy school went further to argue that both BDCs and Black market dealers serve the same end user market and the product of trade which is the dollar, is known to differ only in terms of price. That if BDCs are allowed to participate in the NAFEM, that BDC rate will still be lower than the Black market rate and end users being utility maximizers, will tend to abandon the Black market where the rate is higher and move to BDCs where the rate is lower. That these rates adjustments will continue until rates in both segments will approach equilibrium which is the necessary condition for stability in the exchange of rate of the Naira and a reduction in Naira volatility. That this exchange rate stability is due to the participation of BDCs in the foreign exchange market, hence BDCs are relevant.

The Relevancy School argued that BDCs employ many people in the economy and thus, help reduce the level of unemployment and the attendant crime rate. That the income generated in the BDC subsector of the foreign exchange market is distributed to a larger segment of the society who are dependents of the employees of BDCs. Thus, existence of BDCs results in greater income redistribution.

The Relevancy school argued further that the number of BDC operators is not unwieldy as to deny them participation in NAFEM. That if BDCs are allowed to participate in the single floating exchange rate regime under the willing buyer, willing seller system, that Naira will experience greater stability. They try to buttress their argument by saying that all that CBN needs to do, is to acquire an algorithm that is capable of handling bids or quotes from the BDCs and the time required to process bids will be so small given the advancement in financial technology (FINTECH). That the algorithm should be such as to detect, disqualify and throw away any incomplete bid. Thus, the argument that BDCs staff lack the skill to prepare error free returns or bids does not hold water.

That if the BDCs with their numerical strength are allowed to participate in the NAFEM under the single floating exchange rate regime , that Naira value will appreciate because in price coordinated market, the more the market participants, the more price will approximate individual preferences and values. That the present system where DMBs are allowed to participate in the NAFEM while BDCs are excluded, may lead to collusion in rate fixing or rate gouging. Thus, the exchange rate may not reflect the real value of the Naira. That where a market exhibits oligopolistic tendency because of limited number of participants, that it is easy to fix price and in this case the exchange rate. The Relevancy school went on to cite an example of collusion in fixing of LIBOR(LONDON INTERBANK OFFERED RATE) by the major London banks because they were few in number. They concluded that the more the better.

The Relevancy school said that currently, the rate at NAFEM is about N787/1$ and that of the Black market is about N1,175/1$ which is an indication of existence of premium in NAFEM. That the existence of this risk-free premium is an indication that Naira is overvalued. That if BDCs are allowed to participate in NAFEM that they will force the Naira to attend its real value. In addition, they will serve as a check on the activities of the DMBs in the foreign exchange market as it would be difficult for them to engage in rate gouging due to law of large number.
The Relevancy school said if BDCs are allowed to participate in the NAFEM under the single floating rate regime, that they will mount intensive training programs for their members using highly qualified and experienced consultants to train them in the methods of preparing and submitting bids. That they will invest in computer infrastructure and open up time-sharing processing centers to help members, meet datelines for bid submission.

The Relevancy school said that the argument that BDCs are major source of money laundering in the Nigerian foreign exchange market in particular and financial market in general, is far from the truth. That although some of their members must have been involved in unscrupulous activities, that under the Association of Bureau De Change of Nigeria (ABSCON) there is internal self regulating mechanism that is employed to ensure that member BDCs comply with relevant rules and regulations as announced by the CBN. That erring members are immediately reported to the monetary authorities for necessary action including revocation of licenses.

The Relevancy school further argued that the real culprits when it comes to money laundering are the DMBs. That BDCs are not banks and cannot provide other foreign exchange products like opening of letters of credit, receiving inflow of foreign capital from investors and repatriation of capital and dividend by multi national companies. That some of the DMBs use their foreign branches to launder money in collaboration with customers. That they do that by funding customers who over invoice their goods and subsequently, allowed them to buy or obtain foreign exchange more than is needed. The excess, they channel back to the Black market or BDCs and share the premium
That some of the owners and directors of the DMBs have cozy relationship with some of the public officials. That they use their banks to channel illegal money from corruption outside the country. That monetary authorities in other countries are aware of this practice as some of the banks and individuals have been sanctioned. That these money laundering activities which fuel corruption, have contributed in low inflow of foreign direct investment as most foreign investors see Nigerians as dishonest. That a country cannot develop rapidly, if you have bunch of dishonest and corrupt officials.

That bank officials use their cronies to either allocate or sell foreign exchange to themselves. That the expected end user, rarely gets the Basic Travel Allowance. That this foreign exchange is channeled back to the BDC and Black market segments of the foreign exchange market. They went on to say that as long as the DMBs continue to dominate the foreign market even under the current NAFEM, that the Naira will remain overvalued and continue to depreciate. That opportunity for arbitrage and speculation will cause the Naira to be volatile which is not good for business planning. That the BDCs should be admitted to broaden the market breadth.

The Relevancy school further said that a critical review of the Income Matrix of DMBs, will reveal that the huge profits reported by the DMBs come primarily from foreign exchange related transactions. However, these earnings are hidden under non foreign exchange related income headings in the financial statement in order, to cover their track and avoid sanction by the CBN.

That DMBs are highly averse to lending to the real sector of the economy because of the perceived risk. That the real sector should ordinarily, receive the highest amount of credit because, their outputs are capable of altering the consumption pattern from foreign to locally made goods thereby, reducing the nation’s import bills. That it is the DMBs that do not really contribute meaningfully to economic growth because their wealth is concentrated in the hands of few thus, resulting in greater income inequality in the society.

That the argument that BDCs are owned by every Dick and Tom in the society, especially those who do not have knowledge of the operations of the financial markets or systems thus, they cannot make any meaningful contribution towards the advancement of financial knowledge for the overall growth of the economy is not true. The Relevancy school fired back saying BDCs are companies registered with the Corporate Affairs Commission (CAC) like any other financial institution including banks. That in a BDC like any other company, there is separation of board and management. That the owners of BDCs which may include Judges, Military personnel. Traditional Rulers etc are just investors like you have similar people as investors in banks. That BDCs have their own management teams that carry out day to day operations of the companies. That the experiences of some of these owners/investors serving on the boards of those BDCs improve the quality of corporate governance.
That the argument that the BDCs are rent seekers and do not contribute anything meaningfully except to exchange financial claims is erroneous. The Relevancy school argued that BDCs employ a large number of people in the economy and they help in income redistribution. That some of the BDC owners and personnel have other economic activities such as owning farms, manufacturing outfits and as importers and exporters of goods and services.

That the impression that DMBs increase liquidity in the foreign exchange market is wrong. That the rules of engagement in the foreign exchange market as set by the monetary authorities, allow DMBs to receive inflows of foreign exchange from Diaspora remittances and other invisible transactions thus, making it appear as if they are generating autonomous foreign exchange outside the CBN window. That the percentage of export proceeds in their portfolio, which is the true measure of autonomous funds, is insignificant. That DMBs shy away from lending to exporters in the real sector because of the risk of default, hence, export proceeds in their portfolio is very small. The Relevancy school concluded by saying that in terms of contributing to market liquidity, that both DMBs and BDCs will be identical if the playing field is the same or level.
The Relevancy school argued that when it comes to speculation in the foreign exchange market, that the DMBs are the real speculators. That they either reduce or withhold the flow of foreign exchange to the various economic units in the system to allow a rise in exchange rate and subsequent depreciation in the value of the Naira. That as the exchange rate rises, that they use their cronies or customers who are in collaboration with them, to channel foreign exchange to the Black market to take advantage of the arbitrage profit/premium arising from the speculation and manipulation of the market.

That we have seen cases where a single customer, who is suppose to be in the manufacturing sector, is allocated a disproportionate share of foreign exchange.

16. The Relevancy school therefore, concluded by saying that, allowing BDCs to participate in the NAFEM under the single floating exchange rate regime, will help stabilize the exchange rate and reduce volatility in Naira value and that the society will be better off.

5. SUMMARY.

At this juncture, I will like to summarize this paper by highlighting the key takeaways.
The objective of this paper is to discuss the merits or demerits of admitting Bureau De Change operators into the NAFEM in the light of the deregulation of the foreign exchange market and adoption of a single floating exchange rate of the Naira by the President Tinubu Administration.
The structure of the Nigerian foreign exchange market was reviewed. The major institutions in the market are the following: 1) Central Bank of Nigeria (CBN). 2) Deposit Money Banks(DMBs). 3)Bureaux De Change(BDCs) and 4)Black Market Dealers(BMDs). CBN is the major supplier of foreign exchange in the market and they license, regulate and supervise the activities of the authorized dealers namely: 1)DMBs. 2)BDCs. The Black market dealers operate in the informal sector of the foreign exchange market and they are not under the purview of the CBN.
The exchange rate which is the price of one currency relative to the other was discussed. It was mentioned that exchange rate became necessary because of international trade in goods and services where various national currencies are used in settlement. However, it was stated in the paper that Dollar is more or less the Reserve Currency which other currencies derive their values from. Thus, Naira/Dollar exchange rate which is about N1,175/1$ in the Black market now is expressed in terms of Dollar. The paper further showed that the volatility of the exchange rate, depends on the ability of a country to generate foreign exchange by exporting more goods and services than it imports. The paper further stated, that Naira has been depreciating in value since the Structural Adjustment Program (SAP), when the foreign exchange market was first deregulated.

The paper discussed the various exchange rate regimes from fixed rate, multiple rates, managed float to the present single floating rate. The paper highlighted the fact that, other than the Black market rate which is assumed to be market determined, that other rates do not reflect the true value of the Naira.

The arguments by the various schools of thought as to the relevance or irrelevance of the BDCs in the determination or stability of the Naira exchange rate were discussed.
The Irrelevance Theory argued that BDCs, neither do they determine nor stabilize the Naira exchange rate. That the services they provide in the market segment they serve, can be adequately covered by the Black market dealers. That BDCs are a source of instability and corruption in the market. That BDCs do not add anything to the economy as they have not been able to reduce the price of dollar. That the owners of BDCs are rent seekers. They concluded by saying that BDCs should not be allowed to participate in NAFEM. The Relevancy Theory on the other hand, argued that the existence of BDCs is necessary for the health and stability of the Naira exchange rate. They went further, to say that BDCs are the link between the official foreign exchange window of the CBN or now rebranded as NAFEM and the Black market. That because BDCs serve the same end users like the Black market dealers, that BDC rate tends to adjust to approximate the Black market rate or vice versa. They went further to say that because the BDC rate is usually lower and determined by the CBN under the previously discontinued multiple exchange rates regime and will still be influenced by the CBN if BDCs are allowed to participate in NAFEM, that market participants will move across market segment boundaries to take advantage of any rate differential between market segments. That speculators, who are driven by profit expectations will buy dollars from the BDCs where it is lower to sell in the Black market where it is higher. Simultaneously, end users who are cost sensitive, will prefer to buy foreign exchange from the BDCs where the rate is lower and abandon the Black market where the rate is higher. That the adjustment in rates will continue until there is a convergence of rates. That the convergence of rates, is the necessary and sufficient condition for equilibrium in the foreign exchange market and stability of the Naira exchange rate and a reduction in Naira volatility. The Relevancy school concluded by saying that such convergence of rates in both the BDCs and Black market have been observed in the foreign exchange market. Hence, BDCs contribute to the stability of the Naira exchange rate and they should be allowed to participate in NAFEM under the current single floating rate regime.

6. CONCLUSION.
In conclusion, the paper highlighted the following:
That BDCs should not be allowed to participate in NAFEM under the newly introduced single floating Naira exchange rate regime because they do not have any foreign exchange to bring to the bargaining table. That they are only good at playing at the demand side of the market. That by their unscrupulous business practices, they introduce impurities into the foreign exchange market that are transmitted to other markets such commodities, labor, capital, thus, putting those markets in possible state of disequilibrium and the likelihood of market failure.
Finally, I take responsibility of the content of this paper and I humbly welcome comments.

*Dr. Jona N. Ezikpe is former MD/CEO of Manny Bank PLC.