## 1zweea2022004 - Preface

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### Mission context and purpose
- MCM conducted a virtual mission from May 3, 2022 to June 10, 2022 to assist the Reserve Bank of Zimbabwe (RBZ) in strengthening the consolidated supervision framework.
- Main focus: support RBZ in updating the RBZ consolidated supervision framework, enhancing prudential reporting on a consolidated basis, strengthening assessment of banking group risks, and intensifying cross-border and interagency cooperation.
- Mission activities included virtual meetings with RBZ Banking Supervision Division (BSD) management and supervisors, meetings with representatives of a banking group, and two days of training for supervisors.
- About 50 supervisors from the BSD participated in the training.
- The Technical Assistance (TA) was financed by the Financial Sector Stability Fund.

### Key engagements and acknowledgements
- Virtual meetings with: Mr. Philip Madamombe (Director, BSD), Mr. Ruzayi Chiviri, Ms. Norah Mukura, Ms. Rachel Mushosho, Ms. Susan Kabungaidze, Ms. Violet Ndoro (all RBZ Deputy Directors of the BSD), and supervisors responsible for consolidated supervision.
- The mission expressed gratitude to RBZ staff, particularly Mr. Philip Madamombe, Mr. Ruzayi Chiviri, and Ms. Violet Ndoro, for arrangements, openness, productive discussions, and cooperation.

### Executive summary — main findings
- The mission reviewed Zimbabwe’s consolidated supervision framework (regulation, prudential returns, and supervisory approach) and provided recommendations to enhance RBZ consolidated supervision.
- RBZ is taking steps to enhance its risk-based supervision for solo banks; these improvements will support consolidated supervision.
- RBZ has established Guidelines for consolidated supervision (Guidelines No. 92-2007/BSD: Consolidated Supervision Policy Framework) approved in 2007, which provide a good foundation but require updates and fuller implementation.
- RBZ has developed a CS-1 reporting template for consolidated supervision and collects quarterly data but is not presently utilizing this information fully.
- Recovery Plan Guidelines (Guideline No. 1-2018/BSD: Prudential Standard on Recovery Planning; Guidance on Recovery Planning, Prudential Standard no. 1-2018/BSD) were issued in 2018 and require group-wide recovery plans where applicable.
- Key supervisory challenges discussed: comprehensive understanding of banking group and scope of consolidation; onsite and offsite approaches; strategies to collect consolidated data; home-host supervisory relationships; consolidated capital calculation; intragroup transactions; related party exposures; concentration risk; large exposures; contagion/interconnectedness; and corporate governance particularities.
- Recommendations included: developing a comprehensive consolidated supervision manual; segregating internal supervisory procedures from prudential requirements in the Guidelines; reviewing BSD organization/processes/staffing; and prioritizing training and peer learning for specialist supervisors.
- The RBZ may need follow-up technical assistance to implement recommendations.

### Key statistics and sector structure (as reported)
- Banking sector composition as of March 31, 2022:
  - 13 commercial banks
  - five building societies
  - one savings bank
  - Total banking sector assets: ZW$969.24 billion (March 31, 2022).
  - Exchange rate: 1 US$ = 140.4237 ZWL$ (March 31, 2022; Reserve Bank of Zimbabwe).
  - Total banking sector assets was about 36 percent of GDP.
  - Of the 19 banks, nine banks have foreign shareholding, with a market share of over 60 percent.
  - The banking sector is concentrated in the top five banks (almost 60 percent of total assets).
  - Two of the top ten banks are members of “mixed conglomerates” (banking groups with commercial enterprise subsidiaries).

### Consolidated supervision framework — legal and regulatory foundation
- RBZ supervisory authority derives from:
  - Reserve Bank of Zimbabwe Act (RBZ Act), Section 6 (1)(e): empowers RBZ to “supervise banking institutions and to promote the smooth operation of the payment system.”
  - Banking Act [Chapter 24:20], Part 45(1)(a): RBZ responsible for “continuously monitoring and supervising banking institutions, controlling companies and associates of banking institutions to ensure that they comply with this Act.”
- The RBZ has established Guidelines for consolidated supervision (approved 2007) covering prudential standards for banking groups (including capital adequacy ratio, limits on large exposures) and supervisory approach/processes, but these Guidelines are not fully implemented.

### Recommendations summary (Table 1: Zimbabwe: Key Recommendations)
- 1. The RBZ should review and update the Guidelines on Consolidated Supervision in line with recent updates in the legislation, in order to harmonize RBZ’s powers and its supervisory approach for non-bank financial institutions and non-financial commercial subsidiaries of bank holding companies and improve prudential requirements’ methodologies for banking groups. — High ST
- 2. The RBZ should review the criteria for the identification of ‘connected counterparties’ in banking groups and ensure that they must be included in large exposures minimum requirements for banking groups. — High ST
- 3. The RBZ should develop prudential limits on intra-group exposures targeted at banking groups. — High ST
- 4. The RBZ should review the CS-1 reporting template and requirements to capture developments, which arose since the template was first developed to collect data for consolidated supervision. — High ST
- 5. The RBZ should segregate the internal supervisory procedures from the prudential requirements for banking groups set forth in the Guidelines and develop a comprehensive consolidated supervision manual. — High MT
- 6. The RBZ should develop a group-level ‘Institution Profile’ that sets forth a comprehensive description and an analysis of banking group; a deeper understanding of the banking group’s structure, corporate governance, activities, and risks should be developed. — High MT
- 7. The RBZ should review and modify as needed its current organization, processes, and staffing to support consolidated supervisory activities. — High MT
- 8. The RBZ should ensure that the specialist supervisors, responsible for consolidated supervision, should have access to training programs and peer learning attachments. — High ST
- 9. The RBZ should update the consolidated supervision guidelines and develop supervisory procedures to facilitate effective monitoring and assessment of banking groups’ compliance with prudential requirements on a consolidated basis. — High MT
- 10. The RBZ should update enforcement measures to address any weaknesses or vulnerabilities at the level of the banking group or in case of violation of prudential requirements on consolidated basis. — High MT
- Timeline notation: ST, short-term, with results less than 12 months; MT, medium term, with results from 12 to 24 months.

### Reporting, data use, and consolidated supervision readiness (CS-1)
- The RBZ has developed a report for consolidated supervision information (CS-1 template) requiring a broad range of banking groups’ financial and related information.
- The RBZ receives the financial information but does not adequately analyze CS-1 data and information.
- The RBZ is seeking to update its reporting requirements to capture developments that arose since the template was first developed, and move forward with commencing consolidated supervision activities.
- Although the Guidelines prescribe minimum prudential requirements (e.g., capital ratio, large exposures) on a consolidated basis, the consolidated ratios and exposures in the CS-1 report are not subject to analysis.
- The Guidelines define large exposures as commitments to any single person, common enterprise or corporate exceeding 10 percent of the banking group’s capital base and establishes a 25 percent limit towards the exposure of a single counterparty.
- The Guidelines’ approach to large exposures should be compared to the BCBS standards, where a single counterparty may represent a group of connected ones and the definition of ‘connected counterparties’ involves not only control relationship, but economic interdependency.
- Scope and definitions:
  - Guidelines and RBZ supervisory powers extend to banking institutions, bank subsidiaries, bank holding companies, and to subsidiaries of bank holding companies and broadly to ‘any person’ that has direct or indirect control of the banking institution.
  - The Guidelines provide a scope of application to “every banking institution, bank holding company, financial conglomerate, mixed activity group, and their associates as defined in section 2 of the Banking Act [Chapter 24:20].”
  - The Guidelines define “financial conglomerate” and “mixed activity group.”
  - Since issuance of the Guidelines, the Banking Act was amended to clarify that RBZ supervisory powers extend to ‘controlling companies’.
  - Section 15F of the Banking Act establishes control as specified in (a) and (b) with precise voting and director appointment thresholds.
- Supervisory frameworks and ratings:
  - Guidelines establish an ‘RFI/C(D)’ approach to consolidated supervisory review and rating (RFI rating system).
  - RFI assigns a composite rating based on managerial and financial condition and potential impact on subsidiary depository institutions.
  - For solo banks RBZ employs a CAMELS-based ratings approach supplemented with a Risk Assessment System (RAS).
  - RAS introduced in 2012 through an Enhanced Risk-Based Supervision Policy Framework.
  - RFI builds upon CAMELS/RAS; the D component considers standalone rating of banking entities.
- Supervisory process:
  - Supervisory Review and Evaluation Process includes annual planning cycles, interim steps for emerging risks, comprehensive institution risk profiles, on- and offsite supervision and targeted reviews.
  - Conceptual supervisory cycle: (1) understanding the institution and Institutional Profile, (2) risk assessment, (3) supervisory planning and scoping exam activities, (4) conducting on- and offsite supervision, (5) generating supervisory findings and remedial action.
- Recovery planning:
  - RBZ issued Recovery Plan Guidelines requiring recovery plans; where part of banking groups, a ‘group-wide recovery plan will be required’.
  - Guidelines establish governance, key elements, components, and RBZ supervisory assessment approach.

### Key recommendations to strengthen consolidated supervision — Laws, regulations, and guidelines
- Review and update the 2007 Guidelines on consolidated supervision to reflect recent legislative changes and clarify prudential requirements and expectations for banking groups.
- Connect the RBZ’s Guidelines firmly with Banking Act definitions; consider amendment to incorporate terms such as ‘financial conglomerate’ and ‘mixed activity group’.
- Review and update prudential requirements and supervisory procedures to clearly define scope of RBZ authority for non-bank financial institutions and non-financial commercial subsidiaries of bank holding companies, including clarifying investigatory and enforcement powers.
- Clarify the prudential standard related to the requirement that banking groups focus on ‘core’ banking activities:
  - Under the Guidelines, a mixed activity group threshold is set as a proportion of regulated financial activities to the balance sheet total of a mixed activity group of 70 percent.
  - Articulate meanings of ‘financial activities’, ‘core banking business’, ‘ancillary activities’, measurement methodology and application.
- Review the concepts of ‘connected counterparties’, ‘related parties’ and apply BCBS guidance in methodology for identification of ‘connected counterparties’ for large exposures requirements.
- Develop prudential limits on intra-group exposures targeted at banking groups; review current requirements to establish prudential limits upon intra-group transactions.
- Reinforce Guidelines and legal authority to require banking groups to make material changes to structure or operations if they hinder effective consolidated supervision.

### Key recommendations to strengthen consolidated supervision — Supervisory approach and procedures
- Separate RBZ internal supervisory procedures from the prudential requirements for banking groups set forth in the Guidelines to allow RBZ to modify and update internal procedures more regularly.
- Implement updated Guidelines and supervisory procedures to monitor and assess banking groups’ compliance with prudential standards on a consolidated basis:
  - Update Guidelines to include calculation methodologies for capital ratios, large exposures limits, LCR, NSFR, leverage ratios.
  - Review reporting templates to ensure necessary information is provided.
  - Enhance systems and monitoring tools to receive consolidated data.
  - Establish a monitoring process focused on compliance with prudential requirements on a consolidated basis.
  - Update enforcement application mechanisms for vulnerabilities or violations on a consolidated basis.

### RBZ should develop a comprehensive consolidated supervision manual
- Purpose and scope:
  - Manual would compile formalized procedures and RBZ supervisory policies for supervision of banking groups; discuss relevant laws, regulations or guidelines and interpretations; enhance staff ability to implement onsite examination, supervisory, and monitoring activities; be periodically updated; could be made publicly available consistent with RBZ policies.
- Minimum areas of coverage (selected checklist items):
  - Integrate risk-based supervision framework in consolidated supervision.
  - Incorporate consolidated supervision into annual supervisory review cycle.
  - Describe supervisory planning process for banking groups on consolidated basis.
  - Harmonize definitions and terms across laws, regulations, guidelines.
  - Define scope of consolidated supervision and cooperation with other supervisory authorities.
  - Describe roles and responsibilities vis-à-vis primary supervisors of non-bank financial subsidiaries and mixed activity groups.
  - Describe financial analysis required in the overall risk assessment; consolidated statements analysis and comparison.
  - Provide guidance to improve RFI/C(D) rating.
  - Provide guidance for analysis of quantitative and qualitative assessments: Risk Management, Financial Strength, Impact, Capital Adequacy, Earnings, Asset Quality, Liquidity, and emerging risks (fraud, AML/CFT, cyber, FinTech, Climate).
  - Guidance on shared services, critical functions, outsourcing at group level.
  - Guidance on group-level ICAAP reports and analysis.
  - Guidance on group-level liquidity risk, profile, and intra-group funding dependencies.
  - Detailed requirements for development of a banking group level Institutional Profile.
  - Cross-reference to relevant supervisory guidelines; include report preparation guidance, templates, financial analysis tools and forms.
  - Expectations for examination frequency, meetings with boards and senior management, coordination with domestic and foreign supervisors, communications around change in control, and standards for communication of supervisory findings.
  - Describe enhanced consolidated supervision reporting requirements and expectations for validation, review, and analysis.
- Institutional Profile and supervisory planning:
  - Develop a group-level Institutional Profile building on the solo bank profile to provide comprehensive description and analysis of a banking group.
  - Information sources: management, public reports, regulatory reports, third-party sources, and other primary supervisors or functional regulators.
  - Group-level reporting requirements (Guidelines para. 7.3) should include at minimum: (i) The group corporate structure; (ii) Business line organizational chart; (iii) Senior management / divisional heads; (iv) Shareholder’s profile; (v) Principal board and board committees; (vi) Strategic plans; (vii) Risk management structures; (viii) Group capitalization; (ix) Group policies and procedures; (x) Information Systems; (xi) External Auditors.
  - Institutional Profile supports supervisory planning, resource allocation, and group-level risk assessment.
- Organization, staffing, training, and specialist roles:
  - Review and modify organization, processes, staffing, and training to support consolidated supervisory activities.
  - Specialist supervisors should have access to regional and international training programs and peer learning attachments, and should provide training for BSD staff.
  - Specialists should incorporate a macroprudential perspective and enable horizontal assessments on emerging risks.
  - Consolidated supervision requires skills for evaluation of intra-group transactions, shared services, enterprise-wide risk management, and non-bank/non-financial entity operations.
- Coordination with domestic and foreign regulators:
  - Enhance coordination and leverage foreign regulators’ risk assessments.
  - Increase frequency and depth of contact with foreign and domestic supervisory counterparts; continue joint inspections and supervisory colleges.
- Reporting, templates, and data collection (CS-1 and Appendix III):
  - Develop detailed internal procedures and documentation requirements covering supervision report elements, financial analysis guidance, formulas, and reporting templates.
  - Review CS-1 to incorporate data for assessment of liquidity minimum standards (LCR and NSFR) and liquidity monitoring tools.
  - Appendix III checklist — key suggestions:
    - Reporting frequency should allow trends and behavior assessment.
    - Provide detailed template instructions and maintain communication with reporting entities.
    - Regularly review instructions to incorporate clarifications and template changes.
    - Establish a database to register and aggregate historical information of group and every entity within a banking group; capture mergers, acquisitions, incorporations, fusions.
    - Designate a ‘reporting entity’ responsible for group information on solo and consolidated basis.
    - Solo-basis information must identify the entity; consolidated information should refer to a banking group’s ID-code.
    - Balance sheet consolidated information should avoid double counting; consolidation rules should be clear and supported by regulation.
    - Exposures should be reported on consolidated and solo basis, with segregation by holder entity and aggregate banking group ID-code.
    - Counterparties should be identified preferably by existing identification numbers/codes (e.g., fiscal number); for grouped counterparties, require ‘type of counterparty’ from a pre-defined list.
    - Standardize qualitative information in lists of options (with ‘other’ as needed).
    - Data quality processes should include multiple strategies; offsite teams should plan onsite verification where necessary (e.g., detailed template instructions; communication channel with reporting entities; a senior management representative responsible for regulatory reporting; cross checking solo vs consolidated data; cross checking different sources).
- Sector structure and banking sector indicators (Appendices I & II):
  - Appendix I: Structure of the banking sector as of March 31, 2022 (Total assets, ZW$) — Top entries and market shares:
    - 1 CBZ: 175,633,885,756.09 (MARKET SHARE 18.98%) Control: Mixed; COUNTRY OF HOME SUPERVISION: Zimbabwe
    - 2 STANBIC: 150,177,972,814.49 (MARKET SHARE 16.97%) Control: Foreign; COUNTRY OF HOME SUPERVISION: South Africa
    - 3 ECOBANK: 161,139,173,563.37 (MARKET SHARE 15.80%) Control: Foreign; COUNTRY OF HOME SUPERVISION: Togo
    - 4 CABS: 75,781,308,479.11 (MARKET SHARE 7.19%) Control: Foreign; COUNTRY OF HOME SUPERVISION: Zimbabwe
    - 5 FBC: 69,170,325,958.83 (MARKET SHARE 7.09%) Control: Mixed; COUNTRY OF HOME SUPERVISION: Zimbabwe
    - 6 FIRST CAPITAL BANK: 38,083,433,967.11 (MARKET SHARE 4.22%) Control: Foreign; COUNTRY OF HOME SUPERVISION: Malawi
    - 7 ZB BANK: 46,022,463,695.02 (MARKET SHARE 4.10%) Control: Local Private; COUNTRY OF HOME SUPERVISION: Zimbabwe
    - 8 BANC ABC: 46,792,654,101.12 (MARKET SHARE 4.03%) Control: Foreign; COUNTRY OF HOME SUPERVISION: Zimbabwe
    - 9 STANDARD CHARTERED: 38,864,612,414.73 (MARKET SHARE 3.96%) Control: Foreign; COUNTRY OF HOME SUPERVISION: England
    - 10 NEDBANK: 33,231,330,204.48 (MARKET SHARE 3.72%) Control: Foreign; COUNTRY OF HOME SUPERVISION: South Africa
    - 11 NMB BANK: 32,557,280,518.34 (MARKET SHARE 3.37%) Control: Foreign; COUNTRY OF HOME SUPERVISION: Zimbabwe
    - 12 STEWARD BANK: 26,153,694,050.49 (MARKET SHARE 3.10%) Control: Local Private; COUNTRY OF HOME SUPERVISION: Zimbabwe
    - 13 METBANK: 26,549,595,381.09 (MARKET SHARE 2.73%) Control: Local Private; COUNTRY OF HOME SUPERVISION: Zimbabwe
    - 14 AFC: 20,752,183,031.58 (MARKET SHARE 1.84%) Control: State; COUNTRY OF HOME SUPERVISION: Zimbabwe
    - 15 POSB: 9,757,272,001.16 (MARKET SHARE 1.00%) Control: State; COUNTRY OF HOME SUPERVISION: Zimbabwe
    - 16 FBC BS: 9,008,959,527.03 (MARKET SHARE 1.00%) Control: Mixed; COUNTRY OF HOME SUPERVISION: Zimbabwe
    - 17 CBZ BS: 8,829,141,199.42 (MARKET SHARE 0.71%) Control: Mixed; COUNTRY OF HOME SUPERVISION: Zimbabwe
    - 18 NBS: 6,344,415,202.97 (MARKET SHARE 0.63%) Control: State; COUNTRY OF HOME SUPERVISION: Zimbabwe
    - 19 ZB BS: 3,216,926,999.62 (MARKET SHARE 0.26%) Control: Local Private; COUNTRY OF HOME SUPERVISION: Zimbabwe
    - Total assets (sector): 969,237,487,666.63 (100.00%)
  - Appendix II: Key metrics for the banking sector (benchmarks and reported values)
    - Total Assets (ZW$ Billion): Dec-20 349.59; Jun-21 482.28; Sep-21 569.03; Dec-21 763.02; March-22 969.24
    - Total Loans (ZW$ Billion): Dec-20 82.41; Jun-21 142.79; Sep-21 175.6; Dec-21 229.02; March-22 320.36
    - Net Capital Base (ZW$ Billion): Dec-20 53.8; Jun-21 72.89; Sep-21 84.58; Dec-21 123.07; March-22 169.99
    - Total Deposits (ZW$ Billion): Dec-20 208.9; Jun-21 311.5; Sep-21 374.64; Dec-21 476.35; March-22 582.26
    - Net Profit (ZW$ Billion): Dec-20 34.24; Jun-21 15.09; Sep-21 25.39; Dec-21 59.59; March-22 27.05
    - Return On Assets %: Dec-20 13.55; Jun-21 18.71; Sep-21 8.23; Dec-21 11.38; March-22 3.39
    - Return On Equity %: Dec-20 45.54; Jun-21 18.71; Sep-21 31.87; Dec-21 41.93; March-22 12.43
    - Capital Adequacy Ratio % (benchmark 12): Dec-20 34.62; Jun-21 35.32; Sep-21 35.34; Dec-21 32.89; March-22 35.16
    - Tier 1 Ratio % (benchmark 8): Dec-20 22.65; Jun-21 25.05; Sep-21 26.78; Dec-21 26.44; March-22 26.97
    - Loans To Deposits % (benchmark 70): Dec-20 39.45; Jun-21 59.1; Sep-21 46.87; Dec-21 48.08; March-22 55.02
    - Non-Performing Loans Ratio % (benchmark 5): Dec-20 0.31; Jun-21 0.55; Sep-21 0.61; Dec-21 0.94; March-22 1.57
    - Liquidity Ratio % (benchmark 30): Dec-20 73.06; Jun-21 66.89; Sep-21 62.87; Dec-21 64.41; March-22 61.38

*Source: Preface and Executive Summary of the RBZ consolidated supervision TA report (MCM mission, May 3–June 10, 2022).*

### Preface.................................................................................................................

### 1zweea2022004 - Preface

### Mission context and purpose
- MCM conducted a virtual mission from May 3, 2022 to June 10, 2022 to assist the Reserve Bank of Zimbabwe (RBZ) in strengthening the consolidated supervision framework.
- Main focus: support RBZ in updating the RBZ consolidated supervision framework, enhancing prudential reporting on a consolidated basis, strengthening assessment of banking group risks, and intensifying cross-border and interagency cooperation.
- Mission activities included virtual meetings with RBZ Banking Supervision Division (BSD) management and supervisors, meetings with representatives of a banking group, and two days of training for supervisors.
- About 50 supervisors from the BSD participated in the training.

### Key engagements and acknowledgements
- Virtual meetings with: Mr. Philip Madamombe (Director, BSD), Mr. Ruzayi Chiviri, Ms. Norah Mukura, Ms. Rachel Mushosho, Ms. Susan Kabungaidze, Ms. Violet Ndoro (all RBZ Deputy Directors of the BSD), and supervisors responsible for consolidated supervision.
- The mission expressed gratitude to RBZ staff, particularly Mr. Philip Madamombe, Mr. Ruzayi Chiviri, and Ms. Violet Ndoro, for arrangements, openness, productive discussions, and cooperation.
- The Technical Assistance (TA) was financed by the Financial Sector Stability Fund.

### Executive summary — main findings
- The mission reviewed Zimbabwe’s consolidated supervision framework (regulation, prudential returns, and supervisory approach) and provided recommendations to enhance RBZ consolidated supervision.
- RBZ is taking steps to enhance its risk-based supervision for solo banks; these improvements will support consolidated supervision.
- RBZ has established Guidelines for consolidated supervision (Guidelines No. 92-2007/BSD: Consolidated Supervision Policy Framework) approved in 2007, which provide a good foundation but require updates and fuller implementation.
- RBZ has developed a CS-1 reporting template for consolidated supervision and collects quarterly data but is not presently utilizing this information fully.
- Recovery Plan Guidelines (Guideline No. 1-2018/BSD: Prudential Standard on Recovery Planning; Guidance on Recovery Planning, Prudential Standard no. 1-2018/BSD) were issued in 2018 and require group-wide recovery plans where applicable.
- Key supervisory challenges discussed: comprehensive understanding of banking group and scope of consolidation, onsite and offsite approaches, strategies to collect consolidated data, home-host supervisory relationships, consolidated capital calculation, intragroup transactions, related party exposures, concentration risk, large exposures, contagion/interconnectedness, and corporate governance particularities.
- Recommendations included developing a comprehensive consolidated supervision manual, segregating internal supervisory procedures from prudential requirements in the Guidelines, reviewing BSD organization/processes/staffing, and prioritizing training and peer learning for specialist supervisors.
- The RBZ may need follow-up technical assistance to implement recommendations.

### Key statistics and sector structure (preserve numeric fidelity)
- Banking sector composition as of March 31, 2022:
  - 13 commercial banks
  - five building societies
  - one savings bank
  - Total banking sector assets: ZW$969.24 billion (March 31, 2022).
  - Exchange rate: 1 US$ = 140.4237 ZWL$ (March 31, 2022; Reserve Bank of Zimbabwe).
  - Total banking sector assets was about 36 percent of GDP.
  - Of the 19 banks, nine banks have foreign shareholding, with a market share of over 60 percent.
  - The banking sector is concentrated in the top five banks (almost 60 percent of total assets).
  - Two of the top ten banks are members of “mixed conglomerates” (banking groups with commercial enterprise subsidiaries).

### Consolidated supervision framework — legal and regulatory foundation
- RBZ supervisory authority derives from:
  - Reserve Bank of Zimbabwe Act (RBZ Act), Section 6 (1)(e): empowers RBZ to “supervise banking institutions and to promote the smooth operation of the payment system.”
  - Banking Act [Chapter 24:20], Part 45(1)(a): RBZ responsible for “continuously monitoring and supervising banking institutions, controlling companies and associates of banking institutions to ensure that they comply with this Act.”
- The RBZ has established Guidelines for consolidated supervision (approved 2007) covering prudential standards for banking groups (including capital adequacy ratio, limits on large exposures) and supervisory approach/processes, but these Guidelines are not fully implemented.

### Recommendations summary (Table 1: Zimbabwe: Key Recommendations)
- 1. The RBZ should review and update the Guidelines on Consolidated Supervision in line with recent updates in the legislation, in order to harmonize RBZ’s powers and its supervisory approach for non-bank financial institutions and non-financial commercial subsidiaries of bank holding companies and improve prudential requirements’ methodologies for banking groups. — High ST
- 2. The RBZ should review the criteria for the identification of ‘connected counterparties’ in banking groups and ensure that they must be included in large exposures minimum requirements for banking groups. — High ST
- 3. The RBZ should develop prudential limits on intra-group exposures targeted at banking groups. — High ST
- 4. The RBZ should review the CS-1 reporting template and requirements to capture developments, which arose since the template was first developed to collect data for consolidated supervision. — High ST
- 5. The RBZ should segregate the internal supervisory procedures from the prudential requirements for banking groups set forth in the Guidelines and develop a comprehensive consolidated supervision manual. — High MT
- 6. The RBZ should develop a group-level ‘Institution Profile’ that sets forth a comprehensive description and an analysis of banking group; a deeper understanding of the banking group’s structure, corporate governance, activities, and risks should be developed. — High MT
- 7. The RBZ should review and modify as needed its current organization, processes, and staffing to support consolidated supervisory activities. — High MT
- 8. The RBZ should ensure that the specialist supervisors, responsible for consolidated supervision, should have access to training programs and peer learning attachments. — High ST
- 9. The RBZ should update the consolidated supervision guidelines and develop supervisory procedures to facilitate effective monitoring and assessment of banking groups’ compliance with prudential requirements on a consolidated basis. — High MT
- 10. The RBZ should update enforcement measures to address any weaknesses or vulnerabilities at the level of the banking group or in case of violation of prudential requirements on consolidated basis. — High MT
- Timeline notation: ST, short-term, with results less than 12 months; MT, medium term, with results from 12 to 24 months.

### Suggested supervisory operational priorities
- Review and update consolidated supervision Guidelines in line with legislative changes.
- Enhance CS-1 reporting template and ensure collected quarterly consolidated data is analyzed and utilized.
- Develop and implement consolidated prudential limits on intragroup exposures and clarify treatment of connected counterparties in large exposures.
- Segregate procedural supervisory manuals from prudential rule text and produce a comprehensive consolidated supervision manual.
- Create group-level Institution Profiles for deeper understanding of structure, governance, activities, and risks.
- Review BSD organization, processes, staffing, and deliver prioritized training and peer learning for consolidated supervision specialists.
- Strengthen enforcement mechanisms to address group-level weaknesses and violations on a consolidated basis.

*Source: Preface and Executive Summary of the RBZ consolidated supervision TA report (MCM mission, May 3–June 10, 2022).*

### 10. The RBZ has developed a reporting requirement for banking groups subject to the

### 10. The RBZ has developed a reporting requirement for banking groups subject to the Guidelines and is moving to enhance these reporting requirements

### Reporting, data use, and consolidated supervision readiness
- The RBZ has developed a report for consolidated supervision information (CS-1 template) requiring a broad range of banking groups’ financial and related information.
- The RBZ receives the financial information but does not adequately analyze CS-1 data and information.
- The RBZ is seeking to update its reporting requirements to capture developments that arose since the template was first developed, and move forward with commencing consolidated supervision activities.

### Compliance with prudential requirements and large exposures methodology
- Although the Guidelines prescribe minimum prudential requirements (e.g., capital ratio, large exposures) on a consolidated basis, the consolidated ratios and exposures in the CS-1 report are not subject to analysis.
- The Guidelines define large exposures as commitments to any single person, common enterprise or corporate exceeding 10 percent of the banking group’s capital base and establishes a 25 percent limit towards the exposure of a single counterparty.
- The Guidelines’ approach to large exposures should be compared to the BCBS standards, where a single counterparty may represent a group of connected ones and the definition of ‘connected counterparties’ involves not only control relationship, but economic interdependency.

### Scope of application and definitions
- The Guidelines and RBZ supervisory powers extend to banking institutions, bank subsidiaries, bank holding companies, and to subsidiaries of bank holding companies and broadly to ‘any person’ that has direct or indirect control of the banking institution.
- The Guidelines provide a scope of application to “every banking institution, bank holding company, financial conglomerate, mixed activity group, and their associates as defined in section 2 of the Banking Act [Chapter 24:20].”
- The Guidelines define:
  - “financial conglomerate” as “any group of companies under common control whose exclusive or predominant activities consist of providing significant services in at least two financial services sectors.”
  - “mixed activity group’’ to mean “a group which controls at least one banking institution as well as commercial and industrial companies.”
- Since issuance of the Guidelines, the Banking Act was amended to clarify that RBZ supervisory powers extend to ‘controlling companies’, which clarifies the meaning of bank holding company.
- Section 15F of the Banking Act establishes control as: (a) where the person is a body corporate, the banking institution is its subsidiary; or (b) whether the person is an individual or a body corporate, the person together with any associates or close relatives (i) is entitled to exercise more than fifty per centum of the voting rights in respect of any class of issued shares of the banking institution; or (ii) is entitled or has the power to determine the appointment of a majority of the directors of the banking institution; or (iii) holds shares in the banking institution whose total nominal value represents more than fifty per centum of the nominal value of all the issued shares of the banking institution unless, due to limitations on the voting rights attached to the shares, the person and any associates or close relatives, voting together, cannot decisively influence the outcome of the voting at any general institution’s shareholders.

### Supervisory frameworks, ratings, and risk-based supervision
- The Guidelines establish an ‘RFI/C(D)’ approach to consolidated supervisory review and rating. The RFI/C(D) rating system (RFI rating system) assesses risk management and financial condition factors common to group parents or holding companies, and the potential impact of the parent holding company and its non-depository subsidiaries on subsidiary depository institutions.
- Under the RFI rating system, each group holding company is assigned a composite rating based on an overall evaluation of its managerial and financial condition and an assessment of future potential risk to its subsidiary depository institutions.
- The authorities indicated they might require TA to effectively apply the RFI and other rating approaches for consolidated supervision in the future.
- For solo bank supervision and oversight, RBZ employs a CAMELS-based ratings approach supplemented with a Risk Assessment System (RAS).
  - The RBZ introduced a new RAS in 2012 through the issuance of an Enhanced Risk-Based Supervision Policy Framework.
  - The RAS involves completion of a risk matrix which determines the direction of overall composite risk by each type of inherent risk across the institution, with indications of decreasing, stable, or increasing risk.
- Enhancements of ratings methodologies for solo banks are ongoing.
- The RBZ is taking steps to enhance its risk-based supervision framework to support effective consolidated supervision. The RBZ’s risk-based guidelines (RBS Guidelines) were initially issued in 2006 and updated in 2012.
- The RFI Rating system builds upon and reflects input from the CAMELS/RAS ratings and risk-based supervision approaches; the D component of the RFI system considers the overall standalone rating of the banking entities.

### Supervisory process and activities
- Both RFI rating system and CAMELS/RAS rating systems are to be employed by RBZ within an overall Supervisory Review and Evaluation Process that contains similar features: annual planning cycles, interim steps considering emerging risks, preparation of comprehensive institution risk profiles, on- and offsite supervision supplemented by targeted reviews, among other supervisory procedures and activities.
- The overall conceptual framework for solo and consolidated supervision involves a similar cycle of supervisory steps: (1) understanding the institution and developing a comprehensive institution profile, (2) risk assessment, (3) supervisory planning and scoping exam activities, (4) conducting on- and offsite supervision, and (5) generating supervisory findings and taking action to remediate identified issues.

### Recovery planning
- The RBZ has issued requirements that financial institutions develop recovery plans to support orderly and timely management of crisis situations and avoid contagion and spill-over effects.
- The Recovery Plan Guidelines extend to ‘financial institutions’ and where financial institutions are part of banking groups, a ‘group-wide recovery plan will be required’.
- The Guidelines establish requirements for the plans, including governance, key elements and components, and the RBZ supervisory assessment and approach.
- For complex banking groups, group-wide recovery plans would provide in-depth information and insight into group operations and structure.

### Key recommendations to strengthen consolidated supervision — Laws, regulations, and guidelines
- Review and update the 2007 Guidelines on consolidated supervision to reflect recent legislative changes and clarify prudential requirements and expectations for banking groups. The Guidelines should reflect recent legislative changes to the Banking Act and to recent changes to any applicable related standards or reporting requirements (e.g., corporate governance guidelines, large exposure rules, related party transaction rules).
- Connect the RBZ’s Guidelines firmly with Banking Act definitions. There is scope for further amendment to the Banking Act and/or Banking Regulations to incorporate terms such as ‘financial conglomerate’ and ‘mixed activity group’ which are currently used in the Guidelines but not employed in the Banking Act.
- Review and update prudential requirements and supervisory procedures to clearly define the scope of RBZ authority and its supervisory approach for non-bank financial institutions and non-financial commercial subsidiaries of bank holding companies.
  - Clarify the extent to which commercial enterprises operating as a subsidiary of a bank holding company are excluded from RBZ investigatory and enforcement powers, while remaining subject to RBZ’s power to monitor and supervise such commercial businesses.
  - Clarify the extent to which RBZ is empowered to gather information, conduct onsite inspections, take enforcement actions, and ‘monitor or supervise’ non-bank, non-financial and unregulated entities that operate as subsidiaries of a bank holding company or controlling company.
- Clarify the prudential standard related to the requirement that banking groups focus on ‘core’ banking activities:
  - Under the Guidelines, a mixed activity group threshold is set as a proportion of regulated financial activities to the balance sheet total of a mixed activity group of 70 percent.
  - The meaning of ‘financial activities’, ‘core banking business’, the scope of ‘ancillary activities’, the measurement methodology and its application beyond ‘mixed activity groups’ should be articulated clearly in Banking Regulations and the Guidelines.
- Review the concepts of ‘connected counterparties’, ‘related parties’ and apply BCBS guidance in the methodology for identification of ‘connected counterparties’ for large exposures requirements for banking groups.
- Develop prudential limits on intra-group exposures targeted at banking groups; review current requirements and guidelines to establish prudential limits upon intra-group transactions.
- Reinforce Guidelines and legal authority to require banking groups to make material changes to their structure or operations to ensure that effective consolidated supervision is not hindered by opaque or complex structures. The Banking Act requires RBZ to consider whether the structure or governance of a banking group ‘hinders effective supervision’ in deciding to license a banking institution.

### Key recommendations to strengthen consolidated supervision — Supervisory approach and procedures
- Separate RBZ internal supervisory procedures from the prudential requirements for banking groups set forth in the Guidelines to allow RBZ to modify and update internal procedures more regularly.
- Implement updated Guidelines and supervisory procedures to monitor and assess banking groups’ compliance with prudential standards on a consolidated basis:
  - Update the Guidelines (and other prudential regulations relevant to banking groups) to include methodologies applied in the calculation of standards e.g. capital ratios, large exposures limits, LCR, NSFR, leverage ratios.
  - Review the relevant reporting templates to ensure that the information needed will be adequately provided.
  - Enhance current systems and adapt monitoring tools to receive data on a consolidated basis.
  - Establish a monitoring process focused on the compliance of the prudential requirements on a consolidated basis.
  - Update the application mechanism of enforcement measures in case of vulnerabilities or violation of prudential requirements on consolidated basis.

*Source: IMF staff summary of RBZ Consolidated Supervision Guidelines and related framework.*

### 31. RBZ should develop a comprehensive consolidated supervision manual. The consolidated

### 31. RBZ should develop a comprehensive consolidated supervision manual.

### Purpose and scope of the consolidated supervision manual
- The manual would be a compilation of formalized procedures and RBZ supervisory policies that supervisors should follow for the supervision of banking groups.
- It would discuss the relevant laws, regulations or guidelines, and interpretations.
- It would enhance staff’s ability to implement the RBZ’s onsite examination, supervisory, and monitoring activities.
- The manual should be periodically updated to reflect the latest supervisory policy and procedures and to address changes in industry risk-management practices.
- In line with best practices, the manual could be made publicly available consistent with the RBZ policies.

### Build upon existing Guidelines and minimum areas of coverage
- The comprehensive consolidated supervision manual should build upon and enhance the current internal supervisory procedures set forth in the Guidelines and RBS Guidelines.
- The Guidelines already discuss types of organizations subject to consolidated groups and many supervisory procedures; the manual should make these more descriptive and effective.
- Recommended minimum coverage (from Table 2) — suggested as a minimum checklist:
  - Integrate risk-based supervision framework in consolidated supervision.
  - Incorporate consolidated supervision into annual supervisory review cycle.
  - Describe supervisory planning process for banking groups on a consolidated basis.
  - Harmonize definitions and terms across laws, regulations, guidelines.
  - Define the scope of consolidated supervision and cooperation with other supervisory authorities.
  - Describe how and whether Levels 1-4 identifying type of group entity structure should be employed.
  - Describe roles and responsibilities of the RBZ in relation to primary supervisors of non-bank financial subsidiaries and mixed activity groups operating within the bank holding company.
  - Describe the financial analysis required to be included in the overall risk assessment process; consolidated statements analysis and comparison.
  - Provide guidance towards the improvement of RFI/C(D) rating.
  - Provide guidance and instruction towards analysis of key major components of quantitative and qualitative assessments for banking groups: Risk Management, Financial Strength, Impact, Capital Adequacy, Earnings, Asset Quality, Liquidity. Include key elements essential to supervisory issues pertinent to the RBZ (e.g., fraud, AML/CFT, cyber, FinTech, Climate, other emerging risks).
  - Provide guidance and instruction towards evaluation of shared services, critical functions, and outsourcing at banking group level.
  - Provide guidance and instruction towards employing group-level ICAAP reports and analysis.
  - Provide guidance and instruction towards group-level analysis of liquidity risk, profile, and intra-group funding dependencies.
  - Provide detailed requirements for development of a banking group level Institutional Profile.
  - Cross-reference to all relevant supervisory guidelines or standards and include descriptions of related supervisory activities.
  - Provide report preparation guidance and templates, financial analysis tools and forms.
  - Provide expectations for examination frequency, meetings with boards and senior management, coordination, and communication with domestic and foreign supervisors.
  - Provide expectations for internal and external coordination and communication regarding change in control, ownership, mergers and acquisitions or significant events.
  - Set out standards and requirements for communication of supervisory findings.
  - Describe enhanced consolidated supervision reporting requirements and expectations for validation, review, and analysis.

### Institutional Profile and supervisory planning
- As a foundational step, RBZ should build upon the current Institutional Profile developed for solo banks and develop a group-level Institutional Profile that sets forth a comprehensive description and analysis reflecting a deep understanding of the banking group.
- Information sources for the group-level Institutional Profile may include: the organization's management, public reports, regulatory reports, third-party sources (e.g., credit rating agency and market analyst reports), and other relevant primary supervisors or functional regulators.
- Group-level reporting requirements (Guidelines at para. 7.3) should include, at a minimum: (i) The group corporate structure; (ii) Business line organizational chart; (iii) Senior management / divisional heads; (iv) Shareholder’s profile; (v) Principal board and board committees; (vi) Strategic plans; (vii) Risk management structures; (viii) Group capitalization; (ix) Group policies and procedures; (x) Information Systems; and (xi) External Auditors.
- The Institutional Profile would support RBZ supervisory planning and allocation of resources, enabling risk assessment at the group-level and allocation of RBZ resources to consolidated supervision.

### Organization, staffing, training, and specialist roles
- RBZ should review and modify as needed its current organization, processes, staffing, and training to support consolidated supervisory activities.
- Specialist supervisors responsible for consolidated supervision should have access to regional and international training programs and peer learning attachments, and should provide training for BSD staff.
- Specialists should expand responsibilities by incorporating a macroprudential perspective in addition to microprudential assessments, enabling horizontal assessments on emerging risks, relevant markets, or specific issues and improving priority setting for the BSD’s annual supervision planning.
- Consolidated supervision requires additional supervisory knowledge and skills beyond solo-bank oversight, including evaluation of intra-group transactions, critical shared services, enterprise-wide risk management, and operations of non-bank financial entities and non-financial entities.

### Coordination with domestic and foreign regulators
- RBZ should continue to enhance coordination with domestic and foreign regulators and leverage their risk assessments in conducting consolidated supervision.
- Many banking groups supervised by RBZ have foreign-ownership or participation; RBZ must understand quality of consolidated supervision by foreign regulators and assess safety and soundness of group operations in foreign jurisdictions.
- Frequency and depth of contact with foreign and domestic supervisory counterparts should increase; joint inspections and supervisory colleges should be continued.

### Reporting, templates, and data collection (CS-1 and Appendix III)
- RBZ should develop detailed internal procedures and documentation requirements in the manual, covering the key elements of a fulsome supervision report, guidance on financial analysis, related formulas, and reporting templates.
- RBZ should review the CS-1 reporting template and requirements to capture developments since the template’s creation; current CS-1 provides a good foundation but will need adjustments to incorporate data for:
  - assessment of compliance with the liquidity minimum standards (LCR and NSFR) and implementation of liquidity monitoring tools as they are implemented in Zimbabwe.
- Appendix III checklist for improvement of data quality (report templates, offsite processes, monitoring tools) — key suggestions:
  - Reporting frequency should be adequate to allow trends and behavior assessments.
  - Provide detailed and comprehensive template instructions and maintain a communication channel with reporting entities to clarify misinterpretations.
  - Regularly review instructions to incorporate clarifications and template changes.
  - Establish a database to register and aggregate historical information of group and every entity within a banking group; capture mergers, acquisitions, incorporations, fusions.
  - Designate a ‘reporting entity’ responsible for group information on a solo and consolidated basis.
  - Solo-basis information must identify the entity to which it belongs; consolidated information should refer to a banking group’s ID-code (recommend use of existing identification numbers/codes; central bank may create identification codes if not existing).
  - Balance sheet consolidated information should avoid double counting; rules for consolidation should be clear and supported by regulation.
  - Exposures should be informed on a consolidated and solo basis, with segregation by holder entity and aggregate banking group ID-code.
  - Counterparties should be identified preferably by existing identification numbers/codes (e.g., fiscal number); for grouped counterparties, require ‘type of counterparty’ from a pre-defined list.
  - Standardize qualitative information in lists of options (with ‘other’ as needed).
  - Data quality processes should include multiple strategies; offsite teams should plan onsite verification where necessary. Offsite strategies may include:
    - elaborating detailed template instructions;
    - creating a communication channel with reporting entities;
    - having a representative from senior management of the reporting entity responsible for regulatory reporting and information;
    - cross checking solo vs consolidated data;
    - cross checking information from different sources (e.g., credit register vs accounting information; LCR vs accounting information).

### Sector structure and key banking sector indicators (as reported)
- Appendix I: Structure of the banking sector as of March 31, 2022 (Total assets, ZW$):
  - 1 CBZ: 175,633,885,756.09 (MARKET SHARE 18.98%) Control: Mixed; COUNTRY OF HOME SUPERVISION: Zimbabwe
  - 2 STANBIC: 150,177,972,814.49 (MARKET SHARE 16.97%) Control: Foreign; COUNTRY OF HOME SUPERVISION: South Africa
  - 3 ECOBANK: 161,139,173,563.37 (MARKET SHARE 15.80%) Control: Foreign; COUNTRY OF HOME SUPERVISION: Togo
  - 4 CABS: 75,781,308,479.11 (MARKET SHARE 7.19%) Control: Foreign; COUNTRY OF HOME SUPERVISION: Zimbabwe
  - 5 FBC: 69,170,325,958.83 (MARKET SHARE 7.09%) Control: Mixed; COUNTRY OF HOME SUPERVISION: Zimbabwe
  - 6 FIRST CAPITAL BANK: 38,083,433,967.11 (MARKET SHARE 4.22%) Control: Foreign; COUNTRY OF HOME SUPERVISION: Malawi
  - 7 ZB BANK: 46,022,463,695.02 (MARKET SHARE 4.10%) Control: Local Private; COUNTRY OF HOME SUPERVISION: Zimbabwe
  - 8 BANC ABC: 46,792,654,101.12 (MARKET SHARE 4.03%) Control: Foreign; COUNTRY OF HOME SUPERVISION: Zimbabwe
  - 9 STANDARD CHARTERED: 38,864,612,414.73 (MARKET SHARE 3.96%) Control: Foreign; COUNTRY OF HOME SUPERVISION: England
  - 10 NEDBANK: 33,231,330,204.48 (MARKET SHARE 3.72%) Control: Foreign; COUNTRY OF HOME SUPERVISION: South Africa
  - 11 NMB BANK: 32,557,280,518.34 (MARKET SHARE 3.37%) Control: Foreign; COUNTRY OF HOME SUPERVISION: Zimbabwe
  - 12 STEWARD BANK: 26,153,694,050.49 (MARKET SHARE 3.10%) Control: Local Private; COUNTRY OF HOME SUPERVISION: Zimbabwe
  - 13 METBANK: 26,549,595,381.09 (MARKET SHARE 2.73%) Control: Local Private; COUNTRY OF HOME SUPERVISION: Zimbabwe
  - 14 AFC: 20,752,183,031.58 (MARKET SHARE 1.84%) Control: State; COUNTRY OF HOME SUPERVISION: Zimbabwe
  - 15 POSB: 9,757,272,001.16 (MARKET SHARE 1.00%) Control: State; COUNTRY OF HOME SUPERVISION: Zimbabwe
  - 16 FBC BS: 9,008,959,527.03 (MARKET SHARE 1.00%) Control: Mixed; COUNTRY OF HOME SUPERVISION: Zimbabwe
  - 17 CBZ BS: 8,829,141,199.42 (MARKET SHARE 0.71%) Control: Mixed; COUNTRY OF HOME SUPERVISION: Zimbabwe
  - 18 NBS: 6,344,415,202.97 (MARKET SHARE 0.63%) Control: State; COUNTRY OF HOME SUPERVISION: Zimbabwe
  - 19 ZB BS: 3,216,926,999.62 (MARKET SHARE 0.26%) Control: Local Private; COUNTRY OF HOME SUPERVISION: Zimbabwe
  - Total assets (sector): 969,237,487,666.63 (100.00%)

- Appendix II: Key metrics for the banking sector (benchmarks and reported values)
  - Total Assets (ZW$ Billion): Dec-20 349.59; Jun-21 482.28; Sep-21 569.03; Dec-21 763.02; March-22 969.24
  - Total Loans (ZW$ Billion): Dec-20 82.41; Jun-21 142.79; Sep-21 175.6; Dec-21 229.02; March-22 320.36
  - Net Capital Base (ZW$ Billion): Dec-20 53.8; Jun-21 72.89; Sep-21 84.58; Dec-21 123.07; March-22 169.99
  - Total Deposits (ZW$ Billion): Dec-20 208.9; Jun-21 311.5; Sep-21 374.64; Dec-21 476.35; March-22 582.26
  - Net Profit (ZW$ Billion): Dec-20 34.24; Jun-21 15.09; Sep-21 25.39; Dec-21 59.59; March-22 27.05
  - Return On Assets %: Dec-20 13.55; Jun-21 18.71; Sep-21 8.23; Dec-21 11.38; March-22 3.39
  - Return On Equity %: Dec-20 45.54; Jun-21 18.71; Sep-21 31.87; Dec-21 41.93; March-22 12.43
  - Capital Adequacy Ratio % (benchmark 12): Dec-20 34.62; Jun-21 35.32; Sep-21 35.34; Dec-21 32.89; March-22 35.16
  - Tier 1 Ratio % (benchmark 8): Dec-20 22.65; Jun-21 25.05; Sep-21 26.78; Dec-21 26.44; March-22 26.97
  - Loans To Deposits % (benchmark 70): Dec-20 39.45; Jun-21 59.1; Sep-21 46.87; Dec-21 48.08; March-22 55.02
  - Non-Performing Loans Ratio % (benchmark 5): Dec-20 0.31; Jun-21 0.55; Sep-21 0.61; Dec-21 0.94; March-22 1.57
  - Liquidity Ratio % (benchmark 30): Dec-20 73.06; Jun-21 66.89; Sep-21 62.87; Dec-21 64.41; March-22 61.38

*Source: Reserve Bank of Zimbabwe; content as presented in the provided chapter.*

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_Source: https://www.imf.org/-/media/files/publications/cr/2022/english/1zweea2022004.pdf_