## Summary of Consultation Responses: Proposed Recommendations - Group 3

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### Overview
- The consultation on thirteen Proposed Recommendations for Updating the Government Finance Statistics Manual 2014 (GFSM 2014) ran from July 4 – August 1, 2025.
- The thirteen Proposed Recommendations were based on changes agreed for the System of National Accounts 2025 (2025 SNA) and the Balance of Payments Manual 7 (BPM7).
- All thirteen Proposed Recommendations were agreed for inclusion in the update of the GFS manual by the majority of respondents who expressed an opinion.

### Respondents
- Number of responses: 27.
- Responses from country authorities: 25 responses from authorities in 23 different countries; plus 2 independent GFS experts (Individuals) for a total of 27.
- Regional distribution:
  - Africa (AFR): 2
  - Asia & Pacific (APD): 5
  - Europe (EUR): 5
  - Middle East & Central Asia (MCD): 4
  - Western Hemisphere (WHD): 9
  - Individuals (Experts): 2
- By organization:
  - Ministry of Finance (MoF): 10
  - National Central Bank (NCB): 6
  - National Statistics Institute (NSI): 9
  - Independent Expert (Expert): 2
- By main interest/relationship with GFS:
  - GFS compilation: 18
  - Compilation of other macroeconomic statistics (e.g., national accounts, balance of payments): 2
  - GFS analysis and use (e.g., analyst, academic): 2
  - Other (4 compilers, 1 user): 5
- Around half of respondents (13 respondents) also provided responses to the second global consultation on proposed recommendations (Group 2).
- Most respondents (89 percent) indicated they were engaged in macroeconomic statistical compilation (predominantly of GFS); the remaining 11 percent reported they were users of GFS data.

### Aggregate agreement on Proposed Recommendations
- Two Proposed Recommendations were agreed unanimously by all respondents who expressed an opinion, without caveats:
  - PR 1.32 Recording of Share buybacks
  - PR 1.35 Recording of Central Bank swap arrangements in macroeconomic statistics
- One Proposed Recommendation had a single respondent selecting “No”:
  - PR 1.1 Valuation Principles and Methodologies (no comment provided to explain the “No”)
- One Proposed Recommendation had a single respondent voting “No” with substantive comment:
  - PR 1.14 Capturing Non-Bank Financial Intermediation — respondent noted that the high level of detail in the 2025 editions addresses analytical needs beyond usual government finance analysis and cautioned about keeping the manual lean.
- One respondent voted against PR 1.26 Treatment of Trusts and Other Types of Funds as Separate Institutional Units and requested flexibility and public-sector-specific decision trees; other respondents who voted “Yes” for PR 1.26 also requested decision trees to guide implementation.
- For eleven Proposed Recommendations, there were a few respondents who agreed “Partially”; comments from those respondents are summarized in Annex 2 of the consultation document.

### Detailed counts by Proposed Recommendation (responses who expressed an opinion unless “No Comment” shown)
- PR 1.1 Valuation Principles and Methodologies
  - Yes: 25
  - No: 1
  - Partially: 1
  - No Comment: 0
  - Total: 27
- PR 1.3 Treatment of Centralized Currency Unions in Macroeconomic Statistics
  - Yes: 19
  - No: 0
  - Partially: 1
  - No Comment: 7
  - Total: 27
- PR 1.12 Reverse Transactions
  - Yes: 23
  - No: 0
  - Partially: 1
  - No Comment: 3
  - Total: 27
- PR 1.13 Financial Derivatives by Type
  - Yes: 23
  - No: 0
  - Partially: 3
  - No Comment: 1
  - Total: 27
- PR 1.14 Capturing Non-Bank Financial Intermediation
  - Yes: 20
  - No: 1
  - Partially: 5
  - No Comment: 1
  - Total: 27
- PR 1.15 Treatment of Cash Collateral
  - Yes: 19
  - No: 0
  - Partially: 1
  - No Comment: 7
  - Total: 27
- PR 1.16 Treatment of Factoring Transactions
  - Yes: 18
  - No: 0
  - Partially: 3
  - No Comment: 6
  - Total: 27
- PR 1.18 The Recording of Crypto Assets in Macroeconomic Statistics
  - Yes: 19
  - No: 0
  - Partially: 3
  - No Comment: 5
  - Total: 27
- PR 1.26 Treatment of Trusts and Other Types of Funds as Separate Institutional Units
  - Yes: 20
  - No: 1
  - Partially: 1
  - No Comment: 5
  - Total: 27
- PR 1.32 Recording of Share Buybacks
  - Yes: 23
  - No: 0
  - Partially: 0
  - No Comment: 4
  - Total: 27
- PR 1.33 The Statistical Treatment of Negative Interest Rates
  - Yes: 21
  - No: 0
  - Partially: 1
  - No Comment: 5
  - Total: 27
- PR 1.34 Clarification on Reserve Position in the IMF
  - Yes: 19
  - No: 0
  - Partially: 1
  - No Comment: 7
  - Total: 27
- PR 1.35 Recording of Central Bank Swap Arrangements in Macroeconomic Statistics
  - Yes: 17
  - No: 0
  - Partially: 0
  - No Comment: 10
  - Total: 27

### Summary of rationales for partial agreement (Annex 2 highlights)
- PR 1.1 Valuation Principles and Methodologies
  - 1 respondent partially agreed; the respondent did not provide consent for publication of comments.
- PR 1.3 Treatment of Centralized Currency Unions in Macroeconomic Statistics
  - 1 respondent partially agreed: in Mexico the central bank does not have agencies, so the recommendation has no impact on compilation or presentation for that country.
- PR 1.12 Reverse Transactions
  - 1 respondent partially agreed; the respondent did not provide consent for publication of comments.
- PR 1.13 Financial Derivatives by Type
  - 3 respondents partially agreed; concerns include:
    - The recommended disaggregation by market risk categories and type of instrument is too extensive for government statistics given data availability limits.
    - Need for guidance on practical application and alignment with hedge accounting principles in IFRS; implementation costs to split asset codes at 4-digit level and to accommodate up to 6 new subtypes.
- PR 1.14 Capturing Non-Bank Financial Intermediation
  - 5 respondents partially agreed; concerns include:
    - Major implications for IT applications from changing institutional sector codes (e.g., from S123 to S1223) with high costs and limited benefits.
    - Recommendation that new breakdowns be reported as memo items rather than core accounts.
    - Significant alterations to GFS data sources, collection and production systems and long implementation timelines.
    - Recognition that standardized categories enhance comparability for some countries.
    - Need for clarification to support implementation and concerns about consolidation complexity.
- PR 1.15 Treatment of Cash Collateral
  - 1 respondent partially agreed; recommended a simplified, more practical approach and retention of flexibility given national data system constraints.
- PR 1.16 Treatment of Factoring Transactions
  - 3 respondents partially agreed; issues raised include:
    - Agreement with treating commercial credit transferred in non-recourse factoring as a loan but concerns about registration for non-recourse factoring where risk transfer is unclear.
    - Debate over recording factoring as contingent liability instead of financial liability; expectation that factoring is not prevalent in General Government Sector.
- PR 1.18 The Recording of Crypto Assets in Macroeconomic Statistics
  - 3 respondents partially agreed; issues raised include:
    - Lack of established policies/methodologies and ongoing updates anticipated to SNA and BPM.
    - Preference not to deviate from 2025 SNA / BPM7 guidance for most crypto-asset classes; national processes (e.g., UK NSCASE) may reserve judgement on classification of crypto assets without corresponding liability.
    - Support for harmonization with 2025 SNA and BPM7, interest in a decision tree for classifying fungible digital assets, research on taxes and seizure of crypto assets, and awareness of potential divergence between IFRS/AAS and GFS recognition criteria as crypto usage evolves.
- PR 1.26 Treatment of Trusts and Other Types of Funds as Separate Institutional Units
  - 1 respondent partially agreed: recommended clearer separation between major special-purpose government funds (e.g., national wealth funds) and standard commercial investment vehicles used by public financial institutions.
- PR 1.33 The Statistical Treatment of Negative Interest Rates
  - 1 respondent partially agreed; the respondent did not provide consent for publication of comments.
- PR 1.34 Clarification on Reserve Position in the IMF
  - 1 respondent partially agreed and commented that the clarification brings clarity on IMF-related assets, ensures alignment with BPM7, and enhances consistency in recording international reserve positions.

### Next steps stated by the institution
- All feedback from the consultation, including comments from those who agreed with the Proposed Recommendations, will be carefully considered when advancing each of the research projects and drafting Notices of Decision.

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_Source: https://www.imf.org/-/media/files/data/statistics/gfsm/global-consultations/group3/summary-of-responses-to-third-consultation-on-gfsm-update-prs.pdf_