IMF Executive Board Reviews the Fund’s Transparency PolicyPublic Information Notice (PIN) No. 10/04
January 8, 2010
Public Information Notices (PINs) form part of the IMF's efforts to promote transparency of the IMF's views and analysis of economic developments and policies. With the consent of the country (or countries) concerned, PINs are issued after Executive Board discussions of Article IV consultations with member countries, of its surveillance of developments at the regional level, of post-program monitoring, and of ex post assessments of member countries with longer-term program engagements. PINs are also issued after Executive Board discussions of general policy matters, unless otherwise decided by the Executive Board in a particular case.
On December 17, 2009 the Executive Board of the International Monetary Fund (IMF) concluded its latest review of the Fund’s Transparency Policy, based on a staff report entitled Review of the Fund’s Transparency Policy along with its supplements.
The review marks roughly a decade of efforts to increase the transparency of the IMF’s operations. Starting in the late 1990s, the IMF has published an increasing number of country reports, policy papers, and other documents, opened the IMF’s archives to the public, and engaged proactively with the public via the IMF’s external website, press briefings, and general outreach. Communicating and engaging with the world at large is now a normal and essential part of the IMF’s business.
The staff paper discussed by the Executive Board reflects the experience with the IMF’s initiatives to improve transparency and identifies room for improvement. The latest review also establishes an overarching principle for the IMF’s approach to transparency and puts forward proposals to increase the amount and timeliness of information that is made available to the public, protect the integrity of IMF documents, and enhance the IMF’s accountability.
Executive Board Assessment
Executive Directors welcomed the opportunity to review implementation of the Fund’s transparency policy and to consider reform proposals in their meetings on December 2 and on December 17. They expressed a range of views, reflecting in part varying degrees of concern about the trade-off between transparency and the Fund’s role as a confidential advisor. Many Directors viewed the proposed changes as fairly modest, while others saw risks that increased transparency could compromise candor. Following extensive discussions and in the spirit of compromise, Directors broadly supported the proposals outlined in the staff paper, as modified by Supplement 3, and the proposed amendments to the transparency decision and archives policy.
Commitment to an overarching principle for transparency. Most Directors supported the adoption of the proposed overarching principle for the Fund’s approach to transparency: “The Fund will strive to disclose documents and information on a timely basis unless strong and specific reasons argue against such disclosure.” They considered it important to reaffirm the Fund’s commitment to transparency through this principle. Many Directors stressed that the principle should not undermine the confidential treatment of the Fund’s views on a member’s economy and policies as provided for in Article XII, Section 8, or the need for the Fund to safeguard confidential information provided by a member. The fact that the principle will operate within the framework of voluntary publication of country documents is captured in the preamble to the amended transparency policy decision.
Procedures for consent to publication. Most Directors supported the proposed shift to publication of country documents and related policy intention documents on a nonobjection basis after the relevant Executive Board meeting or decision adopted on a lapse-of-time basis, as set out in paragraphs 5-8 of Supplement 3. They considered that this shift would encourage early consideration, both by staff and authorities, of issues related to publication, and would thus improve the timeliness of publication. A number of Directors would have preferred a member’s explanation accompanying its decision to not publish its reports. Many Directors pointed out that deciding on publication by the time of the Board meeting would be challenging for countries with more limited administrative capacity. Directors agreed that members may notify the Fund that (i) they needed additional time to decide whether to publish, or to agree with the Fund on deletions, or (ii) more generally their documents should only be published with their explicit consent.
Publication of documents relating to use of Fund resources and policy support instruments. Recognizing the importance of publication in Use of Fund Resources (UFR) and Policy Support Instrument (PSI) cases—as regards signaling and public scrutiny of program design and conditionality—most Directors supported establishing an expectation that members requesting UFR or PSI indicate that they intend to consent to publication of the related Board documents before the Board meeting, or date of adoption of a lapse-of-time decision, to which those documents relate. As in other cases, the eventual formal consent would be obtained through the non-objection procedure unless the member has indicated that its documents should only be published with its explicit consent, and publication would remain voluntary. Except as is already the case for exceptional access, access under the Flexible Credit Line (FCL), or access under the Fund’s low-income facilities, a decision by the member not to publish would not affect management’s determination whether or not to recommend approval of the member’s request for UFR or a PSI. Many Directors saw merit in the staff’s original proposal to extend the stronger publication regime currently applying to exceptional access and FCL arrangements to all staff reports on UFR and PSI and related policy intention documents. However, many other Directors were concerned that the proposal could compromise the member’s right to voluntary publication; a few considered that members’ access to Fund financial resources would be inappropriately impeded. On balance and in the spirit of compromise, Directors generally agreed that it would be best to implement the expectation of publication of UFR and PSI documents as described in paragraph 11 of Supplement 3.
Timing of requests for modifications. Directors broadly supported establishing an expectation that modification requests be submitted at the latest two days before the Board meeting. At the same time, many were of the view that short circulation periods and translation needs may make it difficult for members to observe the deadline. Directors expected that modification requests could still be made beyond this deadline if necessary; the current time limits would apply in these situations. They recognized that, while it is especially important that requests for corrections be submitted in time to inform the Board meeting, members may need additional time to consider requests for deletions. It was agreed that a member that has not yet been able to submit or agree on requests for deletions by the time of the Board meeting should be able to record its decision as consenting to publication, subject to resolving issues related to deletions in the report.
Aligning the publication regime for Financial Sector Stability Assessments (FSSA) Reports, Reports on the Observance of Standards and Codes (ROSCs), and Assessment of Financial Sector Supervision Reports with that for Article IV consultation reports. In the view of most Directors, the move to a “voluntary but presumed” regime for these reports would support—and make more visible to the public—efforts to integrate financial sector analysis into Article IV consultations. At the same time, they noted that these documents, in particular FSSA reports, often contain market-sensitive information, to which the deletions policy would continue to apply. Many Directors highlighted the voluntary nature of these initiatives; with a number of them expressing concern that demand for FSSAs and ROSCs could be reduced.
Other measures to increase publication. Directors saw merit in the proposals to align the publication regime for staff reports on Staff-Monitored Programs and related policy intention documents with that for Article IV consultation reports. Directors also supported the proposal to expand the presumed publication for policy documents and other non-country documents prepared for the Board to include those on the Fund’s income, financing and budget, those circulated for consideration on a lapse-of-time basis or for information, and those prepared for Board seminars, unless there are strong and specific reasons not to publish, such as market sensitivity. Many Directors considered that staff guidance notes should be published and welcomed management’s intention to clarify in guidance to staff that these would be expected to be published unless strong and specific reasons argued against publication.
Protecting the integrity of Fund documents. Directors noted that, while the policy for deletions and corrections remains appropriate, there was a clear need for greater consistency in its application and more evenhanded treatment. They reaffirmed that staff reports should not be negotiated, in order to protect the integrity of staff’s analysis, and stressed the need to implement the modification policy consistently and evenhandedly, appealing to staff, management, and members to all work together to ensure consistent adherence to the policy. Directors broadly welcomed the proposals set out in paragraphs 40, and 42-45 of the staff paper as modified by Supplement 3. Some Directors considered that it would be useful to restrict the current generic disclaimer on deletions to reports that actually contain deletions, but most did not view this as warranted. On balance, it was agreed to retain the current practice of applying the disclaimer to all published documents.
Enhancing accountability of the Fund. Directors broadly supported the proposals to improve procedures for declassifying documents and to allow web posting of archival material, consistent with resource constraints. Directors generally supported the proposed shortening of the time periods for public access to the archives, with a number of Directors seeing scope for reducing the lag even further for access to Board minutes and papers, and some suggesting that minutes of the International Monetary and Financial Committee should also be published. A number of Directors would have preferred to retain a longer lag for access to Board documents, and a few Directors would have preferred a longer lag for access to Board minutes, noting that early release could affect the candor of Board discussions. Directors agreed that the archives policy would be applied in a manner that would provide for the following information to be blacklined out of Board documents and minutes that are made available to the public: at the request of the authorities of any member, information that is not in the public domain and whose disclosure may be relevant for litigation that is ongoing or likely to arise in future. The authorities would specify a date after which such information could be disclosed. The authorities would be expected to use this procedure sparingly.
Other issues. In the interest of streamlining, many Directors considered that abolishing the requirement that approval of waivers of performance/assessment criteria be mentioned in the press releases containing the Chairman’s Statement for UFR and PSI staff reports would be desirable. However, many other Directors were concerned that such a change may reduce transparency. On balance, it was agreed to retain the current requirement of mentioning such waivers. It was also agreed that staff reports on Ex Post Evaluation of exceptional access arrangements be added to the list of country documents covered by the transparency decision. A few Directors suggested that there is scope to streamline key communication tools such as the Public Information Notices and Chairman’s summing up, and it was agreed that staff should consider options in this regard. A few Directors also suggested that staff explore ways to present comparisons of the Fund’s and the authorities’ forecasts against the actual outcomes. Given the importance of transparency for the effectiveness and credibility of the Fund, most Directors considered it desirable to review the transparency policy again relatively soon, although a number of Directors would have preferred the standard five-year review cycle. It is expected that the next review will take place in 2012.