## 2028 Monetary and Financial Statistics Manual (MFSM) Proposed Recommendation 2.8 Capturing Non-Bank Financial Intermediation in the System of National Accounts and the External Sector Statistics

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**Canonical URL:** [2028 Monetary and Financial Statistics Manual (MFSM) Proposed Recommendation 2.8 Capturing Non-Bank Financial Intermediation in the System of National Accounts and the External Sector Statistics](https://www.imf.org/-/media/files/data/statistics/mfsac/recommendations/pr-mfs-update-28-capturing-non-bank-financial-intermediation.pdf)

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### Summary
- Links to related guidance cited: F.6 Capturing Non-Bank Financial Intermediation in the System of National Accounts and the External Sector Statistics; 2025 System of National Accounts (SNA) and Integrated Balance of Payments and International Investment Position Manual, Seventh Edition (BPM7).
- Global Consultations referenced:
  - SNA/BPM Consultation: May 2022
  - BPM Consultation: June 2021
- Advisory and committee discussions referenced:
  - Joint AEG/BOPCOM: March 2022
  - BOPCOM: June 2021
  - MFSAC Meeting(s): March 2026
- Summary of proposed recommendation:
  - Include further breakdowns of subsectors within the financial corporations sector to capture more detail on non-bank financial intermediation (NBFI).
  - Encourage further breakdown for some financial instruments, where relevant, on nonperforming loans and repurchase agreements, securities lending with cash collateral and margin lending as an “of which” item under Loans.
- Note on follow-up research:
  - Under 2028 MFSM update research project 1.6 “Enhancing the Coverage of Nonbank Financial Institutions” issues of classification, sectoring, and statistical treatment of NBFIs beyond GN F.6 will be further discussed and addressed.
  - Coordination with ISWGNA and BOPCOM will take place as needed.

### Background and Issues
- International macroeconomic statistics frameworks using same institutional sector classification and financial instrument breakdowns: SNA, BPM6, MFSMCG, and GFSM.
- Financial sector broken down into nine subsectors (S121–S129) in the SNA and MFSMCG.
- GN F.6 emphasized existing sectoral and instrument breakdowns in SNA and ESS were not sufficient to fully capture NBFI.
- Alignment with G20 Data Gaps Initiative II (DGI-II) Recommendation II.5 endorsing more granular breakdowns of the financial corporations sector to better capture NBFI.
- Developments and gaps:
  - As recommended in GN F.6, supplementary disaggregation introduced within some of the nine subsectors of financial corporations in the 2025 SNA (2025 SNA Table 29.1 in Annex I).
  - Breakdown of the financial corporations subsector remained unchanged in 2025 SNA and BPM7 (coding updated from S121–S129 to S1221–S1229).
  - BPM7 introduced more disaggregated institutional sector breakdowns for transactions and positions with nonresidents for OFCs (Table 4.2 of the BPM7): OFCs subsector disaggregated into six subcategories; Central clearing counterparties (CCPs) shown as an “of which” category of Other financial intermediaries (S1225); SPEs shown as an “of which” category under Captive financial institutions and money lenders, and financial auxiliaries (S1226+S1227).
  - GN emphasizes importance of further disaggregating financial instruments to provide more information on liquidity risk, leverage, and credit risk in lending activities.
  - 2025 SNA introduces two “of which” items within financial instrument ‘loans’: (i) Repurchase agreements, securities lending with cash collateral, and margin lending; and (ii) Non-performing loans.
  - MFSMCG already separately identifies repurchase agreements under loans but needs to separately report securities lending with cash collateral, margin lending, and NPLs.

### Proposed Recommendations
- Introduce further subsector breakdowns of the financial corporations’ sector in line with the updated 2025 SNA Tables 29.1 and A2.14.
- Revise the subcategory “repurchase agreements” under loans to add “securities lending with cash collateral and margin lending”.
- Along with the memorandum item on expected loan losses, introduce an additional category on nonperforming loans for relevant financial corporations subsector.

### Rationale for Proposed Recommendations
- Aim: better support analysis of financial risks and vulnerabilities of the NBFI through more detailed breakdowns of the financial corporations’ sector and additional granularity for specific financial instruments.
- Compilation guidance:
  - Further breakdowns of the financial corporations sector should be compiled in economies for which they are relevant (they should not be interpreted as breakdowns to be compiled by all countries).
  - Standardized list of subcategories should facilitate cross-country comparability in compiling NBFI statistics and undertaking subsequent analysis.
- Data-collection guidance:
  - Inclusion of these additional breakdowns in specific data requests by international organizations should depend on the aim of the specific data collection and should be the result of a careful cost-benefit analysis.

### Proposed Text and Implementation Considerations for MFSMCG Update
- Further examination: Proposed recommendations and further considerations beyond the 2025 SNA and BPM7 will be further examined in Discussion Note 1.6 on Enhancing the Coverage of Nonbank Financial Institutions.
- MFSMCG text and tables expected to be affected:
  - Paras 3.144-3.201: Encourage further breakdowns and descriptions of relevant institutional subsectors to align with the 2025 SNA.
  - Appendix II: Guidelines for completion of illustrative sectoral balance sheets/standardized report forms (if retained). In particular, para A2.65 and Tables A2.1-A2.3 would be adjusted to reflect the “of which” category “Repurchase agreements, securities lending with cash collateral, and margin lending” instead of current “Repurchase agreements”.
  - Par 7.30: Add a memorandum item on nonperforming loan.

### Annex I — 2025 SNA Table 29.1: Supplementary details for subsectors of financial corporations to capture non-bank financial intermediation (NBFI)
- Money Market Funds (MMFs)
  - Constant net asset value MMFs
  - Variable net asset value MMFs
- Non-MMF investment funds (non-MMFs)
  - Open-ended funds
    - Real estate funds
    - Equity funds
    - Bond funds
    - Mixed or balanced funds
    - Hedge funds
    - Other open-ended funds
  - Closed-ended funds
    - Real estate funds
    - Equity funds
    - Bond funds
    - Mixed or balanced funds
    - Hedge funds
    - Other closed ended funds
- Other financial intermediaries (OFIs)
  - Financial corporations engaged in securitization of assets
  - Security and derivative dealers
  - Financial corporations engaged in lending or leasing
  - Specialized financial corporations
  - Central clearing counterparties
- Captive financial institutions and money lenders
  - Estate, trusts and agency accounts (ETAs)
  - Corporate group’s captive financial institutions
    - Of which: SPEs
  - Other captive financial institutions and money lenders
- Insurance corporations
  - Non-life insurance corporations
  - Life insurance corporations
- Pension funds
  - Defined benefit pension funds
  - Defined contribution pension funds

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_Source: https://www.imf.org/-/media/files/data/statistics/mfsac/recommendations/pr-mfs-update-28-capturing-non-bank-financial-intermediation.pdf_
