## Judgment No. 2025-3 — Administrative Tribunal of the International Monetary Fund ## Source details **Canonical URL:** [Judgment No. 2025-3 — Administrative Tribunal of the International Monetary Fund](https://www.imf.org/-/media/files/imfat/j2025-3.pdf) ## Other formats - [Markdown version](/-/media/files/imfat/j2025-3.pdf.md) - [Structured JSON version](/-/media/files/imfat/j2025-3.pdf.json) --- ### Tribunal composition, parties, and procedural timeline - Tribunal composed of Judge Nassib G. Ziadé (President), Judges Andrew K.C. Nyirenda and Kieran Bradley. - Applicants: Mr. Anil Ari; Ms. Vybhavi Balasundharam; Mr. Nicholas End; Mr. Mark E.L. Griffiths; Ms. Kelly MacKinnon; Mr. Liam O’Sullivan; Ms. Priscilla Toffano; Mr. Felix Vardy—most were current or former principals of the Staff Association Committee (“SAC”). - Applicants’ counsel: Mr. Ryan Griffin, James & Hoffman, P.C. - Respondent: International Monetary Fund; counsel included Mr. Brian Patterson, Assistant General Counsel, Administrative Law Unit, IMF Legal Department, Mr. James R. Newland, Jr., Ms. Stephanie Magnell, and Ms. Anna Isernia. - Key procedural dates: - April 20, 2023: Board adopted FY2024 staff compensation decision, effective May 1, 2023. - July 28, 2023: Applicants filed Application. - November 1, 2023: Applicants filed Reply. - December 1, 2023: Respondent filed Rejoinder. - August 12, 2024: Tribunal disposition on document-production and oral-proceedings requests. - June 6, 2025: Tribunal decision rendered. ### Subject of the dispute and relief sought - Core dispute: - Applicants contended the FY2024 staff compensation decision failed to adhere to rules in the 2019 Comprehensive Compensation and Benefits Review (“CCBR”), particularly the multi-step payline adjustment processes for Grades A1-A8 and Grades A9-B2, producing payline midpoints “inexplicably below market” at specified grades. - Applicants alleged Management’s analysis deprived the Board of necessary facts and led to an inadequate salary-increase decision. - Relief sought (summary): - Revision of the 2023 Review to: (i) state the overall percentage increase to fully align payline with U.S. comparators and (ii) specify the single salary increase percentage needed to restore a comparatio of 100; clarity on the “market pitch” and adherence to the 75th percentile methodology; presumptive supplemental adjustments retroactive to May 1, 2023. - Alternatively, rerun compensation analyses to adhere to the CCBR and present revised information to the Board. - Legal fees and costs under Article XIV(4) of the Tribunal’s Statute if Application sustained. ### CCBR framework and key quantitative parameters - CCBR structural features: - Decoupling: structural payline adjustments (midpoints) separated from salary increases; triennial comparator-based assessment in Year 1. - Market pitch: level at which Fund relates salary-structure midpoints set at the 75th percentile of total cash. - Safeguard mechanism: links structure adjustments and salary increases by monitoring the comparatio and specified thresholds. - CCBR multi-step processes: - Grades A1-A8: two-step process — Step 1 provisional payline via local (Washington-Baltimore) comparators; Step 2 grade-by-grade adjustments giving weight to hiring grades (A4/A5). - Grades A9-B2: three-step process — Step 1 level-to-level comparison with U.S./international markets to derive provisional payline; Step 2 grade-by-grade adjustments within Step 1 average increase; Step 3 international competitiveness assessment against France, Germany, Japan, using arithmetic average of percentage differences weighted by staff as of January 1 of review year. - International competitiveness testing range: Fund payline targeted at 10-20 percent above the composite international market payline. - Safeguard comparatio constraints: - Downward adjustment permitted only if it does not raise the comparatio above 102 percent. - If comparatio exceeds 102 percent before downward adjustment, management may propose a lower salary increase. - If upward adjustment would lower comparatio below 98 percent, the proposed salary increase may be supplemented. ### Management’s FY2024 proposals and quantitative findings - Grades A1-A8: - Step 1 finding: Fund payline 7.2 percent below the local market on a staff-weighted average basis. - Noted midpoint differentials between Grades A1-A8 of about 12 percent. - Recruitment: Grades A5 and A6 accounted for approximately 56 percent of CY2022 hires within A1-A8. - Result: proposed grade-by-grade midpoint adjustments yielding a proposed staff-weighted average increase of 4.8 percent for Grades A1-A8. - Grades A9-B2: - Step 1/Step 2 findings: - Table comparisons produced a staff-weighted average of 12.5 percent difference between 2020 and 2023 U.S. market data (Step 1 reported in overview). - Management presented that a 9.4 percent increase in the Fund’s salary structure is needed to fully align to the 2023 U.S. comparator market on a staff-weighted basis. - Step 3 international competitiveness assessment: - Full alignment to the U.S. market would place the payline 44.3 percent above the composite international market (France, Germany, Japan) — more than 20 percentage points above the 10-20 percent target range. - Management observed U.S. wage growth “continues to outpace” France/Germany/Japan; U.S. gross pay yields higher net-of-income salaries after tax adjustments; strong appreciation of the US dollar in 2023 reference period. - Management recommended a weighted-average structure increase of 5.2 percent for Grades A9-B2 with grade-by-grade adjustments, aiming to: - Accommodate full alignment at key grades A11-A14; - Improve salary progression within those grades; - Maintain international competitiveness at 38.8 percent (vs. 44.3 percent under full U.S. alignment). - Overall Management proposal: - Staff-weighted average salary structure adjustment: 5.0 percent overall composed of: - 4.8 percent at Grades A1-A8; - 5.2 percent at Grades A9-B2; - 3.0 percent at Grades B3-B5. - Proposed average salary increase: 6.9 percent, effective May 1, 2023. - Application of safeguard: proposed 5.0 percent structure adjustment caused the comparatio to fall below the 98-102 percent range; 6.9 percent proposed salary increase intended to bring comparatio to 98.5 percent. ### Applicants’ key empirical points cited - Recruitment/retention indicators (Draft 2023 Review quoted): - Rejection rate for staff offers rose to 7 percent; for contractual offers rose to 13 percent in CY2022. - Research Assistants comprised 40 percent of all contractual offer rejections. - SAC proposed a 10.2 percent payline increase to align on average with the U.S. market. - Applicants’ quantitative contention: payline was “approximately 4 percent below the CCBR-defined primary comparator market in the U.S.” and the salary increase raised average salaries to only 98.5 percent of an already below-market payline. ### Tribunal’s legal framework and standard of review - Nature of review: - High deference for Board regulatory policy decisions but close scrutiny where the Fund’s regime is “rules-based” and “comparator-based.” - Discretion permitted within limits defined by CCBR rules; changes must be based on relevant facts, reasonably related to objectives, made in good faith, not unjustifiably discriminatory, and avoid excessive harm to staff. - Precedent: - Earlier Tribunal decisions (including Elkjaer et al. matters) guide scrutiny where rules prescribe specific calculations or dates. ### Tribunal findings on contested points (summary of analysis) - Provisional payline: - Management compared current Fund midpoints with relevant market paylines and therefore considered a provisional payline as required for both grade cohorts. Tribunal concluded Management did not fail to consider a provisional payline. - Commingling of steps and account of competing factors: - Steps in CCBR are not strictly mechanical; Management may balance comparator alignment, career progression, payline stability, and recruitment/retention. - Tribunal found Applicants did not show Management improperly “commingled” elements or failed to account for required factors; Management’s prioritizations fell within permitted discretion. - Grades A1-A8 midpoints (A5/A6): - Management intentionally positioned A5 and A6 slightly below U.S. market reference points to preserve a smooth grade-by-grade progression and a historical midpoint differential near 12 percent. - Tribunal concluded these are permissible discretionary choices and did not amount to abuse of discretion. - Grades A9-B2 downward adjustment and international competitiveness: - Step 3 assessment showed full U.S. alignment would produce a 44.3 percent margin over composite international market — outside the 10-20 percent target. - Management adopted a targeted approach yielding a 5.2 percent average structure increase and an international competitiveness margin of 38.8 percent. - Tribunal concluded Management’s Step 3 choices were reasoned and not arbitrary. - Adequacy of explanation to the Board: - Tribunal found Management provided numerical grade-by-grade adjustments and narrative, tables, charts, and boxes sufficient for the Board to have “all relevant and available facts” under the CCBR. - Market pitch (75th percentile) challenge: - The CCBR and 2023 Review use “75th percentile” as shorthand for more elaborate, sector-weighted calculations; Tribunal found Applicants’ challenge to the 75th percentile representation without merit. ### Tribunal conclusions and disposition - Legal and factual conclusions: - Management did not fail to adhere to CCBR rules nor abuse its discretion in proposing the FY2024 triennial payline adjustment. - Management provided sufficient explanations to the Board. - The Board did not abuse its discretion in adopting the FY2024 staff compensation decision based on Management’s proposal. - Specific rejections of Applicants’ allegations: - Tribunal rejected claims that Management (i) failed to consider a provisional payline; (ii) improperly commingled steps; (iii) arbitrarily adjusted A9-B2 downward; (iv) failed to explain its proposal adequately; or (v) otherwise misdirected the Board. - Final order: - Application of Mr. A. Ari, Ms. V. Balasundharam, Mr. N. End, Mr. M. Griffiths, Ms. K. MacKinnon, Mr. L. O’Sullivan, Ms. P. Toffano, and Mr. F. Vardy denied unanimously. - Decision authenticated by Nassib G. Ziadé (President), Andrew K.C. Nyirenda (Judge), Kieran Bradley (Judge), and Paul Jean Le Cannu (Registrar). *Administrative Tribunal of the International Monetary Fund, Decision, Washington, D.C., June 6, 2025.* ### INTRODUCTION ........................................................................................................... ### INTRODUCTION ### Tribunal composition and parties - The Administrative Tribunal of the International Monetary Fund (“Tribunal”) composed, pursuant to Article VII(4) of the Tribunal’s Statute, of Judge Nassib G. Ziadé, President, and Judges Andrew K.C. Nyirenda and Kieran Bradley, decided the Application. - Applicants: Mr. Anil Ari, Ms. Vybhavi Balasundharam, Mr. Nicholas End, Mr. Mark E.L. Griffiths, Ms. Kelly MacKinnon, Mr. Liam O’Sullivan, Ms. Priscilla Toffano, and Mr. Felix Vardy—staff members of the Fund, most of whom were current or former principals of the Staff Association Committee (“SAC”). - Applicants were represented by Mr. Ryan Griffin, James & Hoffman, P.C. - Respondent: International Monetary Fund (“Respondent” or “Fund”); represented by Mr. Brian Patterson, Assistant General Counsel, Administrative Law Unit, IMF Legal Department; Mr. James R. Newland, Jr.; Ms. Stephanie Magnell; and Ms. Anna Isernia. ### Subject of the dispute - Applicants challenge elements of the FY2024 staff compensation decision, which was proposed by Management and adopted by the Executive Board (“Board”) on April 20, 2023, with effect from May 1, 2023. - The Application was brought pursuant to Article VI(2) of the Tribunal’s Statute, permitting direct challenges to regulatory decisions within three months of the later of the announcement or effective date of the decision. - Applicants’ chief contention: the FY2024 staff compensation decision failed to adhere to rules established by the Comprehensive Compensation and Benefits Review (“CCBR”) decision adopted by the Board in 2019; in particular, alleged noncompliance in the multi-step payline adjustment process produced a payline that was “inexplicably below market” at some grades (Applicants identify Grades A5-A6 within the A1-A8 payline, and Grades A9-A10 and A15-B2 within the A9-B2 payline). - Applicants assert that Management’s allegedly flawed analysis deprived the Board of necessary facts to make an informed decision concerning the payline, and that this failure affected the salary increase decision. - Respondent’s position: the FY2024 staff compensation decision was taken consistently with the rules prescribed by the CCBR and reflected the reasonable exercise of discretionary authority within that framework; Management had “broad discretion” to balance comparator markets, career progression, payline stability, and staff recruitment and retention, and the decisions were deliberate and taken after extended consideration with stakeholder input including the SAC. ### Factual background — CCBR role and key change - The controversy arises from implementation, in the FY2024 staff compensation decision, of provisions of the 2019 Comprehensive Compensation and Benefits Review (“CCBR”) decision. - The CCBR: - Represented the first major revision to the Fund’s employment compensation and benefits system since 2006. - Provides the framework for annual compensation decisions going forward. - Key change: decoupling of adjustments to the Fund’s salary structure (“payline”) from increases to staff salaries. - Under the CCBR framework: - One set of comparator-based calculations establishes midpoints of pay grades (structural payline adjustment). - A separate analysis of salary increase budgets at comparable institutions sets the average salary increase. - The “safeguard mechanism” links the two processes by ensuring “average salaries continue to track the midpoints well and maintain the current international competitiveness test.” - The triennial comparator-based assessment of the salary structure takes place during “Year 1” of the three-year compensation cycle. ### CCBR rules governing the triennial payline adjustment (overview) - The triennial comparator-based review is undertaken separately for Grades A1-A8 and Grades A9-B2 because the Fund competes for talent in different markets for those grade ranges. - The level at which the Fund compares its salary structure midpoints to the market is set at the 75th percentile; this is known as “market pitch.” ### CCBR: Grades A1-A8 payline (two-step process) - Primary comparator market: Washington-Baltimore region; comparator institutions drawn from that region. - Year 1 two-step process prescribed by the CCBR: - Step 1: - The midpoints at grades A1-A8 will be compared to those of the comparator market to develop a provisional payline. - A grade-by-grade assessment determines what is needed to maintain consistent and adequate progression between grades and to more closely align the Fund’s midpoints to the market payline. - Step 2: - After the provisional payline is developed, final grade-by-grade adjustments will be made giving consideration to those grades where the Fund recruits most staff at these levels (grade A4/A5) and any challenges experienced in bringing in and retaining talent at grades A1-A8. ### CCBR: Grades A9-B2 payline (three-step process) - Primary comparator market: the United States; comparator institutions drawn from that market with sector weights supporting recruitment and retention needs. - Year 1 three-step process prescribed by the CCBR: - Step 1: - Midpoints at grades A9-B2 compared on a level-to-level basis with U.S. and international comparator markets to take stock of the relationship of the overall payline (including its slope) with the comparator market paylines. - The Fund midpoints will be assessed to determine the overall percentage increase required to maintain market alignment, on a staff weighted average basis, resulting in a provisional payline. - Step 2: - Staying within the average structure increase percentage determined in Step 1, grade-by-grade adjustments will be applied to individual midpoints, taking into account different recruitment challenges. - Where the market reflects a lower reference point than the Fund’s current midpoint, the midpoint would remain unchanged. - In making grade-by-grade adjustments, internal considerations of career progression and payline stability will also be taken into account. - Step 3: - An assessment of the competitiveness of the revised payline vis-à-vis the international comparator markets (France, Germany, and Japan) using the arithmetic average of percentage differences at each grade level, weighted by the number of staff in each grade as of January 1 of the review year. - The test for international competitiveness: a Fund payline that is a range of 10-20 percent above the international market payline. ### CCBR: international competitiveness assessment and constraints - The CCBR permits, but does not require, a further adjustment of the Fund’s salary structure midpoints after grade-by-grade adjustments based on evaluation of international competitiveness. - Factors to consider in the international competitiveness evaluation include: - Recent recruitment and retention experience. - The margin by which the testing range has been eroded or surpassed. - Effects of tax and exchange rate developments on the level of the composite international market payline. - Conditions and constraints specified by the CCBR: - The targeted margin (testing range) is 10-20 percent above the composite payline for France, Germany, and Japan. - If alignment with the U.S. market would produce a Fund payline that, on a staff-weighted average, falls below the 10 percent floor, the provisional payline could be adjusted upward; such an upward adjustment could raise the A9-B2 payline to a level either below or above the threshold. - Any discretionary downward adjustment from a position within the 10-20 percent testing range would be subject to the safeguard mechanism and could not result in a staff-weighted average increase to the payline that is less than the higher of: (i) the 10 percent floor; or (ii) the percentage increase in the Washington, D.C. Consumer Price Index for the 12 months ending in January, whichever is greater. - A downward adjustment from a position above the 20 percent ceiling would be subject to the safeguard mechanism, and if that adjustment would put the payline below that ceiling then constraints (i) and (ii) also apply. - If warranted, an upward adjustment from within the range may be permitted. *Judgment No. 2025-3, Administrative Tribunal of the International Monetary Fund* ### 13. The CCBR further relates the international competitiveness assessment to the safeguard ### j2025-3 - 13. The CCBR further relates the international competitiveness assessment to the safeguard ### CCBR linkage to the safeguard mechanism - In year 1 of the review cycle, when there is a full review of the salary structure midpoints, the international competitiveness test works in tandem with the safeguard mechanism. - Any downward adjustment to the payline based on the international competitiveness test raises the average salaries relative to the adjusted payline (the comparatio), and any upward adjustment to the payline lowers the comparatio. - A downward adjustment to the payline based on international competitiveness is permitted only to the extent it does not raise the comparatio above 102 percent. - If the comparatio exceeds 102 percent before a downward adjustment to the payline, management may propose a lower salary increase. - If an upward adjustment to the payline would lower the comparatio below 98 percent, then the proposed salary increase may be supplemented. ### FY2024 staff compensation decision — Management’s 2023 Review of Staff Compensation (overview) - The staff compensation system is described as both “comparator-based” (to support attraction and retention) and “rules-based” (reviews conducted within an agreed framework providing transparency). - The rules-based system provides scope for management and the Executive Board to exercise judgement within defined parameters. - The Board’s 2019 CCBR decision allowed more flexible management of the Fund’s payline to reflect market developments in different grades, to “ensure continued competitiveness where it matters most (at the hiring stage), and temper wage growth where it is less needed to remain competitive (among senior managers).” ### Development of the proposed Grades A1-A8 payline for FY2024 - Step 1 (aggregate alignment): - Midpoints at grades A1-A8 compared level-to-level with the local comparator market to determine the overall percentage increase required to maintain market alignment on a staff-weighted average basis. - The analysis determined that for Grades A1-A8, the Fund’s payline was 7.2 percent below the market on a staff-weighted average basis. - Step 2 (grade-by-grade within staff-weighted constraint): - Considered: (i) external market rate relative to the corresponding grade midpoint; (ii) internal considerations regarding career progression and stability of the payline; (iii) recruitment and retention trends and challenges within each grade. - Noted that midpoint differentials between Grades A1-A8 were about 12 percent. - Recruitment assessment: Grades A5 and A6 accounted for approximately 56 percent of CY2022 hires within the A1-A8 cohort. - Result: Proposed grade-by-grade midpoint adjustments yielding a proposed staff-weighted average increase of 4.8 percent for Grades A1-A8. ### Development of the proposed Grades A9-B2 payline for FY2024 - Step 1: - Purpose: take stock of relationship of Fund midpoints and payline with the market to determine overall percentage increase required to maintain market alignment (implying a comparatio of 100 at each grade). - Table 1 showed the difference between the 2020 and 2023 U.S. market data at each grade level, resulting in a staff-weighted average of 12.5 percent. - Step 2: - Staff-weighted average increase to align the salary structure at Grades A9-B2 fully with the U.S. market was calculated at 9.4 percent. - The 2019 CCBR introduced flexibility and determined full alignment at every grade is not the goal; full-aligned payline is presented for transparency to inform potential downward adjustments based on international competitiveness. - External-market observations: - At Grade A9 and Grades A11-A14 the implied increase to fully align with the U.S. market is about 5-7.5 percent. - The implied increase to fully align for grades above A15 is more than 20 percent. - Career-progression observation: full alignment to current U.S. market would disrupt smooth salary progression and internal equity. - Recruitment/retention observation: Grades A11-A14 identified as most relevant for recruitment and retention; high rejections at Grades A9 (Research Officer), A11 (EPs), and in A13-14 specialist-skills areas. - Table 3 showed grade-by-grade staff hires and separations in CY2022 for Grades A9-B2. - Step 3 (international competitiveness assessment): - Evaluated payline against international comparator market accounting for: (i) wage growth; (ii) income tax policy; (iii) exchange rate developments. - Findings: - U.S. wage growth “continues to outpace” that of France, Germany, and Japan. - Adjusted for income tax, U.S. gross pay levels “continue to produce higher net-of-income salaries relative to international comparators.” - Exchange rate developments showed “strong appreciation of the US dollar in the current 2023 reference period.” - Conclusion: - Proposing a payline fully aligned with the U.S. market would place the payline 44.3 percent above the composite international market — more than 20 percentage points above the CCBR’s 10-20 target range for international competitiveness. - The system permits, but does not require, management to propose and the Executive Board to approve a downward adjustment, uniformly or by individual grades to the A9-B2 midpoints. - Factors to consider before a downward adjustment include: (i) recent recruitment and retention experience; (ii) extent to which the margin over the test range has been surpassed; (iii) effects of tax and exchange rate developments on the international market level. - Observed that the U.S. labor market is tight, there is a substantial wage gap relative to Fund and international comparators, inflation remains high, and the Fund faces competitiveness challenges at key grades. - Noted that income tax policies and exchange rate developments continued to support a favorable environment for the U.S. labor market vis-à-vis the composite international comparator, but the strength of the U.S. dollar could be transitory and could quickly lead to an erosion of international competitiveness. - Step 3 assessment outcome: - Full alignment to the U.S. market across A9-B2 and resultant increased competitiveness margin is not warranted at this time. - Recommended a more targeted and moderate increase in the Fund’s payline to maintain competitiveness at key recruitment levels, satisfy internal equity, and uphold the rules-based system. - Emphasized full alignment to the U.S. market at grades A11-A14 as essential to recruit and retain staff at these levels. - Management’s recommended Grades A9-B2 outcome: - Recommended a weighted-average increase in the salary structure for Grades A9-B2 of 5.2 percent, with grade-by-grade adjustments. - Expected effects of a 5.2 percent structure adjustment for A9-B2: - Accommodate full alignment to the U.S. comparator market at key grades A11-A14; - Allow a more desirable salary progression within and across these key grades; - Maintain the Fund’s international competitiveness but at a lower level: 38.8 percent, compared with 44.3 percent under full U.S. comparator market alignment. ### Overall proposed payline and salary adjustments for FY2024 - Management’s staff-weighted average salary structure adjustment proposal: 5.0 percent overall, reflecting: - 4.8 percent at Grades A1-A8; - 5.2 percent at Grades A9-B2; - 3.0 percent at Grades B3-B5. - Management’s overall proposal to the Board: - (a) an increase in the payline that resulted in a staff-weighted average of 5.0 percent; and - (b) an average increase in salary of 6.9 percent, effective May 1, 2023. - Application of the safeguard mechanism: - Based on the proposed 5.0 percent payline adjustment, the comparatio fell below the safeguard range of 98-102 percent, triggering application of the four-factor supplementary analysis. - The 6.9 percent proposed salary increase was to bring the comparatio to 98.5 percent. - Management’s rationale: - The adjustment in the salary structure is less than needed for full alignment with U.S. comparators at all grades, justified by the large divergence between U.S. and international comparators. - To retain competitiveness in a challenging recruitment environment, the adjustment retains full alignment at the key recruitment and retention grades A11-A14. ### Draft 2023 Review versus final 2023 Review — international competitiveness language - A Draft 2023 Review circulated to the Staff Advisory Committee (SAC) contained a paragraph on international competitiveness not included in the final 2023 Review. - Key content of the omitted Draft paragraph: - “Considering the factors above, there is no compelling evidence that the Fund is over-competitive.” - Recruitment/retention evidence cited in the Draft: - Rejection rate for non-EP offers more than tripled in CY2022 due to competitiveness pressures: the rejection rate for staff offers rose to 7 percent while that for contractual offers rose to 13 percent. - Research Assistants made up 40 percent of all contractual offer rejections. - The Draft stated there was little evidence of a surge in applications from international comparator markets that would be expected if the Fund was perceived as over-competitive. - The Draft concluded: “A downward adjustment of the payline from the level of the U.S. market would place even greater competitive pressures on the Fund’s payline,” and recommended no downward adjustments from the proposed midpoints established in step 2 above, given the persistent trend since 2018 of the Fund payline being positioned above the 10-20 [percent] target range and no indication that the divergence between the U.S. and international comparators will correct in the near-term. - The SAC highlighted this difference between the Draft and final 2023 Review in its communication to the Board. ### SAC Statement to the Board - SAC proposed: - An increase in the payline of 10.2 percent to align it on average with the U.S. market as “our main comparator and where Fund staff work and live”; - An average salary increase that would raise Fund salaries “so that they are in line with the midpoints of the Fund’s salary structure rather than on average being below it.” *Source: 2023 Review of Staff Compensation and related Management and SAC submissions contained in the FY2024 staff compensation decision materials.* ### 38. As to the Grades A1-A8 payline adjustment, the SAC Statement asserted: “[W]e believe ### j2025-3 - 38. As to the Grades A1-A8 payline adjustment, the SAC Statement asserted: “[W]e believe ### SAC Statement and staff association criticisms - SAC asserted that for Grades A1-A8 the second step was followed but implemented incorrectly because the proposed increase “falls short of the salary increase needed to align with the market.” - For Grades A9-B2, SAC asserted that the 2023 Review “fails to implement the correct three-step process outlined in the 2019 CCBR.” SAC encouraged Management to revise the 2023 Review to ensure that the steps required by the 2019 CCBR, paras. 10 and 15, were followed and to present that information to the Board. - SAC viewed international competitiveness considerations as “neither relevant nor sufficient” to argue against full alignment with the U.S. market, noting the Draft 2023 Review had stated there was “no compelling evidence that the Fund is overcompetitive” and that recruitment and retention experience underscored the need to maintain alignment with the U.S. market. ### Management’s Supplement to the 2023 Review — three-step process and quantitative findings - Management issued a Supplement to the 2023 Review of Staff Compensation (“2023 Supplement”) providing additional information on the three-step process for Grades A9-B2. - Step 1: A table showed, at each grade, the percent difference between the 2022 Fund midpoints and the 2023 U.S. market, resulting in a staff-weighted average of 8.2 percent below the U.S. market. - Step 2: Management stated Step 2 calls for grade-by-grade adjustments considering recruitment challenges, career progression, and payline stability. Management noted grade-by-grade adjustments are also permitted at Step 3 and presented changes to the payline shape in Step 3 for transparency. A corresponding table showed that “on average, a 9.4 percent increase in the Fund’s salary structure is needed to fully align to the 2023 U.S. comparator market.” - Step 3: A further table compared proposed 2023 Fund midpoints to 2022 Fund midpoints, reflecting adjustments for international competitiveness, showing a staff-weighted average increase of 5.2 percent. ### Board decisions and implementation - On April 20, 2023, the Board approved, effective May 1, 2023: - Management’s proposed salary structure adjustment resulting in a staff weighted average of 5.0 percent. - The proposed average salary increase of 6.9 percent, as set out in the 2023 Review. - On April 20, 2023, the HRD Director notified Fund staff of the Board’s decisions. ### Tribunal procedures, filings, and timeline - Article VI(2) of the Statute of the Administrative Tribunal allows an application challenging a “regulatory decision” within three months of its announcement or effective date. - Key filings and procedural dates: - July 28, 2023: Applicants filed a consolidated Application with the Tribunal. - July 31, 2023: Application transmitted to Respondent. - August 4, 2023: Registrar circulated a notice summarizing issues raised in the Application. - September 14, 2023: Respondent filed its Answer (transmitted to Applicants on September 18, 2023). - October 10–11, 2023: Applicants requested and were granted extension to file the Reply until November 1, 2023. - November 1, 2023: Applicants filed their Reply. - December 1, 2023: Respondent filed its Rejoinder. - August 12, 2024: Parties notified of the Tribunal’s disposition of Applicants’ requests for production of documents and their provisional request for oral proceedings. - August 13, 2024: Applicants submitted final supporting documentation regarding legal fees and costs; August 26, 2024: Respondent filed a responsive Comment. ### Document production requests and Tribunal ruling - Applicants made four Document Requests under Rule XVII relating to: 1. Calculation of “market pitch” and evidence supporting the statement that the Fund relates salary structure midpoints at the 75th percentile of total cash. 2. Basis for positioning of Grades A5–A6 midpoints (within A1–A8 payline). 3. Basis for positioning of Grades A9–A10 and A15–B2 midpoints (within A9–B2 payline). 4. Documentation explaining exclusion from the 2023 Review of preliminary draft conclusions (listed in full by Applicants, including statements such as “there is no compelling evidence that the Fund is over-competitive” and related points). - Respondent opposed the requests, asserting the relevant documents were already in Applicants’ possession and in the record, objecting that requests sought documents “sufficient to” meet Applicants’ own standards and that some requests aimed to elicit explanations in Applicants’ chosen manner. - Applicants pursued adverse inferences from Respondent’s assertion of no further responsive documents; Respondent contended the requests attempted to shift burdens and make legal arguments. - Tribunal decision: Where the Fund asserts it has no documents responsive to a Rule XVII request and the applicant has not proffered evidence suggesting such documents exist, the Tribunal denies the request as the applicant has not shown denial of access (Rule XVII(1)). Respondent asserted it had no documents beyond the record; Applicants did not counter. Tribunal denied Applicants’ Document Requests and did not reach whether requests were an inappropriate attempt to make legal arguments. Parties were notified on August 12, 2024. ### Oral proceedings decision - Article XII of the Tribunal’s Statute and Rule XIII(1) govern whether oral proceedings are warranted. - The Tribunal has convened oral proceedings in prior compensation challenges, sometimes on its own initiative. - In this case, Applicants made a “provisional” request and Respondent opposed oral proceedings. Applicants did not advance particular reasons; Respondent argued written submissions sufficed. - The Tribunal concluded it would determine the Application on the basis of comprehensive written submissions and extensive annexes and decided not to hold oral proceedings. Parties were notified on August 12, 2024. ### Applicants’ principal contentions and requested relief (summary) - Applicants’ substantive contentions include: - Respondent “failed to adhere to governing CCBR rules and practice and abused its discretion” in setting the payline in the 2023 Review. - Procedural deficiencies produced substantively unjustified results. - The CCBR’s multi-step process is meant to provide “analytical clarity and transparency.” - For Grades A1–A8, non-adherence produced below-market midpoints at Grades A5–A6 lacking reasonable basis; Management failed to provide a provisional payline or explain why an evenly spaced payline around non-hiring grades was preferable to full market alignment at Grades A5–A6. - The two-step process for A1–A8 should have distinguished adjustments for career progression from recruitment/retention; Management deprived the Board of that information. - Management did not give meaningful consideration to recruitment and retention when aligning non-hiring grades while leaving hiring grades below market. - For Grades A9–B2, Management’s purported three-step process differed materially from the CCBR; non-adherence produced a below-market increase lacking reasonable basis; Management failed to provide a provisional payline and clear grade-by-grade adjustments. - Management improperly relied on international competitiveness to propose an arbitrary downward adjustment to the A9–B2 payline despite prior acknowledgements of “no compelling evidence” of over-competitiveness and evidence of under-competitiveness for certain positions; the downward adjustment amount was arbitrary. - Management misdirected the Board on the “market pitch.” - Alleged defects deprived the Board of the proper benchmark, resulting in a payline “approximately 4 percent below the CCBR-defined primary comparator market in the U.S.” and a salary increase decision that brought average salaries up to only 98.5 percent of the already below-market payline. - Relief sought by Applicants: 1. Orders requiring Fund Management to revise the 2023 Review in accordance with the 2019 CCBR, past practice, and fair treatment, including: - Clear statements of (i) the overall percentage increase needed to fully align the payline with the U.S. comparator markets, and (ii) the single salary increase percentage needed to restore a comparatio of 100 and fully align average salaries to the payline. - Inclusion of a full and accurate explanation of the “market pitch” for each U.S. comparator market segment used for Grades A9–B2 or adoption of a methodology fully consistent with the 75th percentile representation. - Directing the Board to presumptively consider, absent articulated countervailing considerations, (i) a supplemental adjustment to fully align the payline with U.S. comparator markets, and (ii) a supplemental single salary increase sufficient to restore a comparatio of 100 and fully align average salaries to the payline, retroactive to May 1, 2023. - Granting additional relief the Tribunal deems just and proper. 2. Alternatively, a remedy short of annulment entailing rerunning compensation analyses to adhere to the CCBR, presenting revised information to the Board for payline and salary adjustments, and notifying staff. 3. Legal fees and costs under Article XIV(4) of the Tribunal’s Statute if the Application is well-founded in whole or in part. *Source: International Monetary Fund* ### 63. The principal arguments presented by Respondent in its Answer and Rejoinder may be ### j2025-3 - 63. The principal arguments presented by Respondent in its Answer and Rejoinder may be ### Respondent’s principal arguments (points 1–12) - 1. The establishment of the payline and salary increase in the FY2024 staff compensation decision reflects the proper exercise of discretionary authority. The Fund followed the CCBR and did not violate any condition of Applicants’ employment. - 2. The CCBR grants “broad discretion” to balance competing factors in developing the proposed payline. In proposing the grade-by-grade adjustments to the midpoints as part of the 2023 Review, Management properly took into consideration the comparator market, career progression, payline stability, and staff recruitment and retention. - 3. The CCBR’s steps are not mechanical. They prescribe the information that must be considered in setting the paylines but leave the outcome to the exercise of discretion. - 4. With respect to the Grades A1-A8 payline, the payline adjustment decision was reasonable and consistent with the CCBR. Management used as the provisional payline the comparator market, that is, the complete alignment with the U.S. market. However, alignment of the payline with the U.S. market would have meant abandonment of a consistent salary progression between grades. - 5. “The CCBR provides for the Fund’s consideration of the competing goals of ‘consistent and adequate progression between grades’ while ‘more closely align[ing] the Fund’s midpoints to the market payline,’ and in the end grants the Fund clear discretion to position some final grade midpoints below the comparator, and others above.” Considerable weight was given to a regular progression between grades, as well as to the historical payline differential of 12 percent. The Grades A1-A8 payline adjustment decision was informed, reasonable, and broadly consistent with prior practice. - 6. With respect to the Grades A9-B2 payline, Management used the U.S. market as the “provisional payline” and, in Step 3, compared that payline to international comparators. This decision was reasonable and consistent with the CCBR. - 7. Applicants contest only those midpoints that are not aligned with the U.S. comparator market. That their challenge is selective rather than comprehensive “shows that Applicants do not have a foundation to challenge the Fund’s compliance with the CCBR, and instead only disagree with the result of the Fund’s exercise of its discretion.” - 8. The record demonstrates that the decisions Applicants seek to impugn were “deliberate,” and were taken “after extended consideration” of a range of views and data, with input from multiple stakeholders including the SAC. - 9. While the Fund is obligated to make a reasonable decision after thoughtful consideration of adequate information, the CCBR does not require that a written explanation be provided for the choice of one reasonable option over another: “[W]here there exist reasonable options, the Board’s discretionary and informed selection of one of these options should not be overturned, even if Applicants or the Tribunal think a different choice would have been better.” - 10. In taking the FY2024 staff compensation decision, the Board had all of the information required by the CCBR. Management showed the Board the grade-by-grade adjustments numerically and in the narrative of the 2023 Review. The 2023 Review contains information that supports its recommendations and also offers transparency so that a reader may review the information (including tables, charts, and boxes, showing data and calculations) to determine whether the payline recommendation is reasonable. - 11. Management did not misdirect the Board in any material respects, including with regard to “market pitch.” - 12. None of the remedies that Applicants seek is warranted. ### Consideration of the issues presented to the Tribunal (paras. 64–66) - Principal questions for decision: - Whether, in proposing the triennial payline adjustment in connection with the FY2024 staff compensation decision, Management failed to adhere to the rules prescribed by the CCBR and abused its discretion. - Specific sub-questions: did Management (1) fail to consider a “provisional payline”? (2) improperly “commingle” elements of a multi-step process and fail to take proper account of career progression, payline stability, and staff recruitment and retention? (3) arbitrarily adjust downward the Grades A9-B2 payline based on its assessment of “international competitiveness”? (4) fail to explain adequately to the Board the FY2024 payline adjustment proposal? and (5) otherwise misdirect the Board in developing the proposed payline adjustment? - Second principal question: given Management’s proposal, did the Board abuse its discretion in taking the FY2024 staff compensation decision? ### Tribunal framework for analysis (paras. 65–71) - Context: - This is the third challenge before the Tribunal arising from annual implementation of the CCBR (the revised system adopted by the Board in 2019). Earlier challenges concerned the “safeguard mechanism” rule and salary increase decisions for FY2022 and FY2023; the present Application raises challenges to the triennial payline adjustment rules and the FY2024 salary decision. - Legal principles: - The Fund’s staff compensation system rests on two “fundamental and essential” principles: that it is “rules-based” and “comparator-based.”60 - Beyond these principles, the compensation system may be unilaterally amended, including by amending rules implementing these principles, subject to review for abuse of discretion.61 - Annual application of the CCBR results in amendments to terms and conditions of staff employment and are “regulatory decision[s]” under Article II(2)(b) of the Tribunal’s Statute.62 - Standard of review: - The Tribunal’s “degree of deference—or depth of scrutiny—may vary according to the nature of the decision under review, the grounds contested, and the authority or expertise vested in the original decision maker.”63 - Deference is highest for regulatory and policy decisions by the Executive Board, but lawful amendments of non-fundamental terms remain constrained: changes must be based on proper consideration of relevant facts; reasonably related to stated objectives; made in good faith; not prompted by improper motives; not unjustifiably discriminatory; and made reasonably to avoid excessive and unnecessary harm to staff.65 - The Fund’s adoption of rules can constrain discretionary authority; because the compensation system is “rules-based” and “comparator-based,” the Tribunal will “scrutinize closely the Fund’s adherence to the governing rules.”66–68 - Comparative precedent: - Elkjaer et al. (No. 2) involved a rule specifically drawn and led the Tribunal to find Management exceeded discretion when it departed from prescribed calculation dates.70–71 - By contrast, the CCBR triennial payline adjustment rules provide some room for discretion within an established framework; the key question is whether Respondent failed to adhere to those rules or exceeded the breadth of discretion they afford. ### Analysis of contested procedural and substantive points - (1) Did Management fail to consider a “provisional payline”? (paras. 72–78) - Relevant rule framing: - For both Grades A1-A8 and Grades A9-B2, Step 1 calls for development of a “provisional payline” by comparing midpoints to those of relevant comparator markets.72–73 - For Grades A1-A8, Step 1: “The midpoints at grades A1-A8 will be compared to those of the comparator market to develop a provisional payline. In this step, a grade-by-grade assessment will be made to determine what is needed to maintain consistent and adequate progression between grades, and more closely align the Fund’s midpoints to the market payline.” (CCBR, para. 10.) - For Grades A9-B2, Step 1: “The midpoints at grades A9-B2 will be compared on a level-to-level basis with the U.S. and international comparator markets... This will result in a provisional payline.” (CCBR, para. 15.) - Parties’ positions: - Applicants: Management skipped development of a “provisional payline” and improperly “commingled” elements, producing substantively unjustified results. - Respondent: Management “used the comparator market itself as the provisional payline” for both Grades A1-A8 and Grades A9-B2. - Tribunal findings: - The purpose of a provisional payline is to ensure the system is “comparator-based,” but comparator alignment does not require congruence with market payline because other factors (career progression, payline stability, recruitment and retention) must also be accounted for. - The Steps are not strictly mechanical or sequential; they are a means to ensure comparator-based review and do not confine Management to a rigid process. - Conclusion: Having reviewed the record (notably the 2023 Review and the 2023 Supplement), the Tribunal concludes that because Management compared the Fund’s then-current paylines with the relevant market paylines, it did not fail to adhere to the CCBR’s requirement to consider a “provisional payline” for Grades A1-A8 and Grades A9-B2 in developing the FY2024 proposal. - (2) Did Management improperly “commingle” steps or fail to account for career progression, payline stability, and recruitment/retention? (paras. 79–82) - Applicants’ contention: - Management “largely rolled its proposed adjustments to the payline into a single step,” making it difficult or impossible to determine whether deviations from full market alignment addressed recruiting challenges, maintained consistent progression between grades, or adjusted positioning relative to international comparators; Applicants allege failure to take proper account of recruitment and retention as required by the CCBR. - Respondent’s contention: - The CCBR grants “broad discretion” and the Steps are not “mechanical.” The rules prescribe information to be considered but leave the outcome to discretion. Management properly considered comparator market, career progression, payline stability, and staff recruitment and retention. - Tribunal framing of the issue: - The interrelationship of the factors is acknowledged by both parties (e.g., equally spaced payline vs. market alignment). The question is whether Respondent exceeded the discretionary authority afforded by the rules. - Noted positions: - Applicants: midpoints are established with reference to one another and to market comparators; flaws in establishing certain midpoints can affect others. - Respondent: the “consistent and adequate progression” and “more closely align” criteria are competing priorities, making it impossible to align each pay grade midpoint to the market while maintaining steady progression. *Excerpt from the IMF Administrative Tribunal judgment (paragraphs 63–82).* ### 83. Applicants assert that these “realities,” however, should not “. . . leave the Fund with carte ### Tribunal analysis of the FY2024 payline adjustment and CCBR compliance ### Discretion under the triennial payline adjustment rules - The triennial payline adjustment rules constrain Management’s discretionary authority but allow the exercise of discretion “within the limits defined by those rules.” - The rules require Management to make various “assessments,” “taking into consideration” various factors, as well as “tak[ing] into account” other considerations, and to “tak[e] stock of” still others, without specifying how competing factors shall be balanced. - The Tribunal notes that “provision for the exercise of discretion within a system does not invalidate the system,” and that exercises of discretion within governing parameters yield legally valid solutions. - The Tribunal concludes Applicants have not shown Management improperly “commingled” elements of the governing rules in preparing the payline adjustment proposal for FY2024. ### Grades A1–A8 payline: recruitment, progression, and midpoints - The 2023 Review stated the Step 2 analysis “calibrated” midpoints at A1-A8 to “approximate the market rate at each grade while adhering to about a 12 percent midpoint differential from grade to grade.” - Table 14 in the 2023 Review showed proposed grade-by-grade midpoint adjustments, resulting in a proposed staff-weighted average increase of 4.8 percent. - For Grades A5, A6 and A7, the proposed midpoints represented a 4.9 percent increase over the current year. - Applicants alleged Management failed to give “meaningful consideration” to staff recruitment and retention and set Grades A5 and A6 midpoints “inexplicably below market.” - Respondent explained the decision to set A5 and A6 “slightly below the U.S. market reference points, while maintaining a smooth and stable grade-by-grade progression,” was a reasonable exercise of discretionary authority, giving considerable weight to a regular progression and a historical payline differential of 12 percent. - The Tribunal finds these differing outcomes reflect permissible prioritization among competing factors and does not find that Management abused the discretion conferred by the CCBR rules. ### Grades A9–B2 payline: international competitiveness assessment and downward adjustment - Step 3 permits further adjustment of A9-B2 midpoints “based on an evaluation of international competitiveness.” The CCBR factors specified include “recent recruitment and retention experience, the margin by which the testing range has been eroded or surpassed, and effects of tax and exchange rate developments on the level of the composite international market payline.” - The 2023 Review determined (at Step 3) that aligning Grades A9-B2 fully with the U.S. market would place it 44.3 percent above the composite international market, i.e., more than 20 percentage points above the CCBR’s 10-20 percent target range for international competitiveness. - Management concluded “full alignment to the U.S. market at every grade across the A9-B2 grade range and resultant increase in the competitiveness margin over the international comparators is not warranted at this time,” and proposed a “more targeted and moderate increase in the Fund’s payline.” - The proposed average structure adjustment for Grades A9-B2 was 5.2 percent, described as accommodating full alignment at key grades A11-A14 while maintaining international competitiveness “at a lower level (38.8 percent, compared with 44.3 percent under full U.S. comparator market alignment, and broadly aligned to 2023).” - Applicants challenged Management’s departure from language in the Draft 2023 Review that stated there was “no compelling evidence” of over-competitiveness and alleged the downward adjustment and its magnitude were arbitrary. - SAC highlighted the divergence between the Draft and final 2023 Review and characterized international competitiveness considerations as “neither relevant nor sufficient” to argue against full alignment; SAC also referred to recent recruitment and retention experience. - Respondent maintained the Draft’s statements proved inconsistent with the data and were properly revised; Respondent noted the 38.8 percent margin was nearly 19 percent above the ceiling of the CCBR testing range. - The Tribunal concludes Management made a considered choice at Step 3 within the parameters of the CCBR rules and did not arbitrarily adjust the Grades A9-B2 payline downward on the basis of international competitiveness. ### Adequacy of Management’s explanation to the Board - Applicants contend Management failed to explain adequately to the Board why one option was recommended over another and thus “deprived the Board of the full information required for it to make an informed payline adjustment decision.” - Respondent responds the CCBR does not require a written explanation of the choice of one reasonable option over another and asserts the Board had the information required by the CCBR, including numerical grade-by-grade adjustments and supporting narrative, tables, charts, and boxes in the 2023 Review. - The Tribunal recalls that the Board’s lawful exercise of discretionary authority is predicated on Management’s full compliance with the rules the Board adopted in the 2019 CCBR decision and that the Board must have “all relevant and available facts” when taking its decision. - Having reviewed the record, the Tribunal concludes Management provided information and made considered choices in line with the CCBR process; Applicants have not shown Management failed to explain adequately its FY2024 payline adjustment proposal to the Board. *The Tribunal Judgment on the FY2024 payline adjustment (based on the 2023 Review).* ### 106. The Tribunal has already held that Management did not fail to adhere to the rules prescribed ### The Tribunal has already held that Management did not fail to adhere to the rules prescribed by the CCBR or abuse its discretion in developing the FY2024 triennial payline adjustment proposal ### Tribunal's legal and factual conclusions - The Tribunal concluded that Management did not fail to adhere to the rules prescribed by the CCBR in proposing the FY2024 payline adjustment and did not abuse its discretion in developing that proposal. - The Tribunal concluded that Management provided sufficient explanations to the Board about its FY2024 payline adjustment proposal. - The Tribunal found that reasoned decision-making is required to avoid arbitrariness and that the Fund’s staff compensation system is to be “rules-based,” meaning not arbitrary, transparent, and predictable. ### Treatment of the “market pitch” (75th percentile) and Applicants’ challenge - The 2023 Review states that “[t]he level at which the Fund relates its salary structure midpoints in its comparator markets, on average, is the 75th percentile of total cash.” - The CCBR states that the level at which the Fund compares its salary structure midpoints to the market will continue to be set at the 75th percentile of total cash. - The CCBR specifies the reference level as: - “(i) the 75th percentile of the U.S. general industry sector and each sector in the international comparator market (France, Germany, Japan); (ii) a level 10 percent above the mean of the U.S public sector; and (iii) on a sliding scale between the 75th percentile and the mean of the U.S. financial sector . . . .” - Applicants alleged Management misled the Board by not fully spelling out the market pitch and that the “75th percentile market pitch claim simply portrays the Fund’s payline as more competitive than it actually is.” - Respondent and the SAC explained that the “75th percentile” is a shorthand reference to more elaborate calculations fully disclosed and explained in the CCBR and related documents. - The Tribunal found that the 2023 Review and the CCBR make clear that the Fund’s market pitch “targets” or “approximate[s]” the 75th percentile and that the Applicants’ challenge to the reference to the “75th percentile” is without merit. ### Additional Applicants’ contentions and Tribunal responses - Applicants contended that the CCBR requires Fund salaries to “remain aligned” with the comparator market. The Tribunal held that being “comparator-based” does not require congruence with a comparator-constructed payline because additional factors—career progression, payline stability, and staff recruitment and retention—must be taken into account. - Applicants attempted to incorporate by reference an argument resolved in Elkjaer et al. (No. 3); the Tribunal considered that issue moot in this context. - The Tribunal concluded Applicants’ additional arguments that Management misdirected the Board in developing the FY2024 payline adjustment proposal were without merit. ### Specific alleged failures that the Tribunal rejected - Applicants did not show that Management: - failed to consider a “provisional payline”; - improperly “commingled” elements of a multi-step process or failed to take proper account of career progression, payline stability, or staff recruitment and retention; - arbitrarily adjusted downward the Grades A9-B2 payline based on its assessment of “international competitiveness”; - failed to explain adequately to the Board the FY2024 payline adjustment proposal; - otherwise misdirected the Board in developing the proposed payline adjustment. - Accordingly, the Tribunal concluded Management did not fail to adhere to the rules prescribed by the CCBR, nor did it abuse its discretion in proposing the triennial payline adjustment in connection with the FY2024 staff compensation decision. ### Board’s exercise of discretion - The Tribunal emphasized that the Board’s lawful exercise of its discretionary authority in taking the annual staff compensation decision depends on Management’s full compliance with rules established when the Board adopted the 2019 CCBR decision. - Having concluded Management complied with the CCBR in proposing the FY2024 payline adjustment, the Tribunal also concluded the Board did not abuse its discretion in taking the FY2024 staff compensation decision based on that proposal. - Applicants raised no independent challenge to the Board’s FY2024 staff compensation decision separate from their challenge to Management’s proposal. ### Final disposition - The Tribunal unanimously decided to deny the Application of Mr. A. Ari, Ms. V. Balasundharam, Mr. N. End, Mr. M. Griffiths, Ms. K. MacKinnon, Mr. L. O’Sullivan, Ms. P. Toffano, and Mr. F. Vardy. - Decision authenticated by: - Nassib G. Ziadé, President - Andrew K.C. Nyirenda, Judge - Kieran Bradley, Judge - Paul Jean Le Cannu, Registrar - Washington, D.C., June 6, 2025 --- _Source: https://www.imf.org/-/media/files/imfat/j2025-3.pdf_