## Preface and Executive Summary — Mongolia Central Bank Communications (1mngea2023001)

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---

### Mission and team; Purpose
- Mission timeframe: in-person in August 2022.
- IMF MCM mission team: Udaibir Das (mission chief); Vassili Prokopenko (both—MCM); Florian Gimbel (COM); Altynai Aidarova (CCAMTAC); Marianne Nessén (Riksbank); John Power (Bank of England).
- Local support: IMF Resident Representative office (SeokHyun Yoon, Selenge Sandagsuren, and Ardak Bazarbai).
- Stakeholder meetings: Governor of BOM Lkhagvasuren; BOM management and staff; current and former members of Parliament; Financial Regulatory Commission; commercial banks; Bankers’ Association; think tanks.
- Purpose:
  - Assist the Bank of Mongolia (BOM) to enhance its communication framework and propose a roadmap for follow-up technical assistance (TA).
  - Specifically requested: understand global trends in central bank communications, established international practices, and provide input on BOM’s policy communications organizational design.

### Recent developments and scope of the review
- Trend: Over the last decade, BOM has significantly intensified the use of communications.
- New flagship products and platforms: Inflation Report; Financial Stability Report; BOM’s pages on financial literacy; social media engagement.
- Scope: review focuses on monetary and financial policy communications, internal organization of BOM’s communication function (structure, resources, procedures), and preconditions for effective communications including legal and normative frameworks related to mandate and independence.
- Key areas for enhancement: coverage, clarity, consistency, and effectiveness of communications.
- Principal recommendations (overview):
  - Monetary policy communications: make the Inflation Report more forward-looking; streamline Monetary Policy Guidelines by moving non-core material into a separate publication.
  - Financial policy communications: sharpen focus of the Financial Stability Report; enhance inter-departmental and inter-agency communications/collaboration.
  - Organizational: create a dedicated, well-staffed Communications Department integrated into major policy actions and flagship reports.
  - Evaluation: develop and adopt a framework to conduct regular impact assessments of communications.

### Table 1 — Key Recommendations (as presented)
- Organization of Communications at BOM
  - 1 Create a Communications Department — Priority: High — Timeframe: Immediate
  - 2 Integrate communications into major policy actions and flagship reports — Priority: Medium — Timeframe: Short term
  - 3 Upgrade communication tools and guidelines — Priority: Low — Timeframe: Medium term
- Monetary Policy Communications
  - 4 Enhance consistency on communicating MPC decisions — Priority: High — Timeframe: Immediate
  - 5 Upgrade Inflation Report into Monetary Policy Report — Priority: Medium — Timeframe: Short term
  - 6 Streamline Monetary Policy Guidelines — Priority: Low — Timeframe: Medium term
  - 7 Introduce External Sector Report — Priority: Low — Timeframe: Medium term
- Financial Sector Policy
  - 8 Upgrade and revitalize the Financial Stability Report and its communication plan — Priority: Medium — Timeframe: Immediate
  - 9 Revitalize the Financial Stability Council and the arrangements between BOM and FRC — Priority: High — Timeframe: Short term
  - 10 Reshape the BOM set up on financial policy analysis and communications — Priority: High — Timeframe: Medium term
- Evaluating Outcomes of Communications
  - 11 Start conducting impact assessments of communications — Priority: Medium — Timeframe: Short term

Note: Short term: < 12 months; Medium term: 12 to 24 months.

---

### Context, trends, and challenges
- Trends: central banks in emerging and frontier markets align communication functions to local realities; public roles expand into macroprudential and crisis management issues.
- Benefits of clear communication: builds credibility, improves public confidence, and makes the central bank’s reaction function more transparent.
- Specific challenges:
  - Knowledge and data rigidities complicate effective communication across audiences.
  - Many communication approaches assume higher public literacy, complicating adaptation.
  - Building policy credibility takes time; internal models cannot fully capture behavioral aspects of all agents.
  - Communicating under stressed conditions is particularly difficult.
  - Mandate-related uncertainty: unclear medium- and long-term objectives hinder stakeholder responses and can cause conflicting messages from BOM, parliament, and media.

---

### Organization of Communications at BOM — Diagnosis and Recommendations

### Summary diagnosis
- Two major operational challenges:
  - Organizational fragmentation, increasing risk of inconsistent messages.
  - Limited capacity for strategic communications, reducing effectiveness of external engagements.
- Core recommendation: create a new Communications Department.

### Current weaknesses and operational effects
- Communications function: weak internal standing and fragmented; not empowered to ensure message consistency and generally not involved in final review of major communications products.
- Operational effects:
  - Delayed responses to media requests due to bureaucratic internal processes.
  - Delayed external communications have in some cases allowed misinformation to spread fast and unchecked.
- Strategic communications shortfall:
  - Communications are mostly reactive rather than proactive/strategic.
  - Shortage of highly qualified communications staff with time and capacity for strategic planning.
  - Difficulty attracting and retaining economists, journalists, public relations experts, and digital content creators.
  - Communications staff are largely excluded from policy development and decision making.
  - BOM lacks an overarching communications strategy and does not use fully-fledged communication plans for specific policy decisions and products.
  - Cultural implication: many BOM staff implicitly treat communications as “not my job!”

### Stakeholders
- Domestic: Parliament & other public authorities; media (press, broadcast, social media); financial sector (banks, non-bank financial institutions, investors); corporates (SMEs to big mining groups); students (high-schools, universities); think tanks, academics, researchers, influencers; general public (urban-rural divide).
- External: global financial sector (banks, non-bank financial institutions, investors); rating agencies; international media; multinational corporations; trade partners; international organizations.

### Recommendations — strategic reorganization and integration
- Priority reforms:
  - Turn the fragmented communications function into a fully-fledged Communications Department.
  - Integrate communications into all major products and decisions.
  - Upgrade communications tools and guidelines.

Recommendation 1: Create a Communications Department
- Implementation: Immediate start feasible; some elements may require medium-term implementation (e.g., increased staffing).
- Rationale: centralization and elevation will improve consistency, clarity, and traction of BOM messages; empower the Department to ensure message consistency and flag inconsistencies across layered communications.
- Operational synergies: streamline internal processes, optimize coordination through clear reporting lines and procedures.
- Proposed composition and responsibilities:
  - Revamped Press & Information Division (PID).
  - Foreign Relations & Ceremony Unit (relations with rating agencies, central banks, international organizations).
  - Newly created Parliament Outreach Unit.
  - Public Financial Education Center (consumer protection & financial education).
- Governance: direct reporting line to the Governor recommended; COM Director should act as a counselor to BOM’s management and oversee qualitative and quantitative assessments (including frequent stakeholder surveys and refined impact assessment).
- Press & Information Unit transformation:
  - Current PIU: 5 staff focused on social media, traditional media relations, and supporting Governor speeches/articles.
  - Additional PID responsibilities: full control over BOM’s website content/management; enhanced capacity to assess impact across platforms; oversight of translator team for better English translations; increased internal communications role including townhall facilitation.
- Parliament Outreach Unit:
  - Medium-term establishment to lead engagement with Parliament; brief parliamentarians and advise management (inspired by the Bank of England Parliamentary Affairs Group).
- Staffing: new Department will need more highly skilled staff; elevated internal standing facilitates competing for talent.

Recommendation 2: Integrate communications into major policy actions and flagship reports
- COM Director should be involved in policy formulation and decision-making (short-term implementable).
- Roles for senior communications staff:
  - Anticipate stakeholder reactions to policy actions.
  - Communicate difficult financial stability messages.
  - Simplify language without changing meaning.
- Communications plans for major policy actions and flagship reports (short-term priority, e.g., banks’ asset quality review (AQR) and initial public offerings (IPOs)):
  - Message formation: early interdepartmental collaboration on flagship chapters and likely public reception.
  - Message determination: finalization and nuancing by BOM management; communications staff empowered to support.
  - Message dissemination: interdepartmental collaboration to prepare layered outreach products; communications staff to lead outreach.
- Medium-term supports:
  - Dedicated staff to support “Flagship Departments”; moderator roles for events (MPC press conferences); hire more economists and financial sector experts (senior advisors, secondments); create an institutional communications strategy led by the new Communications Department.

Recommendation 3: Upgrade communications tools and guidelines (short-term)
- Upgrade English-language website: build in-house capacity in new PID for high-quality English translations to reach nonresident investors.
- Modernize website design: more visual information, mobile-friendly, no-jargon infographics and basic-concepts videos (e.g., “What is inflation?”).
- Create formal guidelines:
  - Interaction guidelines for staff-media interviews.
  - Clear social media guidelines for staff, including private account use.

Box 1 — Key attributes of an effective central bank website (high-level checklist)
- Ease of finding key information (monetary policy objectives, policy decisions, calendar, core analysis).
- Focus on most relevant information at initial entry.
- Clarity, conciseness, timeliness, readability for professionals and the broader public.
- Layering of information: high-level messages up front with links to detailed technical information.
- Attribution of information: clearly identify official status and source for each item.
- Accessibility of historical information: organized past policy decisions and reports.
- Use of graphics, videos, and podcasts.
- Public education section for teachers, students, and general public.
- Mobile-friendliness.

---

### Monetary Policy Communications — Current Practice and Recommendations

### Current situation
- Key elements of an effective monetary policy communication framework are in place.
- BOM publishes an Inflation Report (IR), regarded as an excellent analytical source.
- Regular stakeholder engagement and active promotion of transparency are evident.

### Monetary policy framework and governance (Annex I)
- MPG frame policy; operational decisions taken by the Monetary Policy Committee (MPC).
- MPG: approved by Parliament and published annually.
- Legal basis: constitutional clause whereby Parliament can “determine monetary and fiscal policy”.
- MPC structure: headed by the Governor with 3 internal and 4 external members.
- MPC meetings: four pre-scheduled meetings per year; may hold unscheduled meetings; sets policy rate and reserve requirements; can decide on foreign exchange interventions.
- Inflation target: currently set at 6 percent, with a tolerance range of +/- 2 percentage points.
- Channels and timing:
  - Immediately after MPC meeting: short Monetary Policy Statement and press conference.
  - Inflation Report: published four times per year, typically a few weeks after pre-scheduled MPC meeting.
- Content:
  - Monetary Policy Statement: summarizes economic assessment, action taken, and reasoning.
  - Press conference: prepared (and published) remarks from the Governor plus Q&A.
  - IR: more in-depth motivations and fuller account of policy deliberations.

### Key challenges identified
- Ambiguity in mandate:
  - Law on the Central Bank: “main objective of Bank of Mongolia is to sustain stability of national currency – togrog”.
  - Interpretation divergence: BOM interprets as price stability (CPI-based); other stakeholders interpret as stability of the nominal exchange rate of the togrog.
  - Lack of clarity undermines coherence of public communication and public confidence; any future Law review should resolve mandate clarity.
- Limited English translations:
  - Timely English channel: Monetary Policy Statement only.
  - IR translated into English but with long delay (as of August 2022, latest available English IR was as of March 2021).
- Quasi-fiscal activities: Parliament-assigned fiscal tasks (e.g., subsidized mortgage program) complicate monetary decision-making and communications.
- Inconsistent messaging across channels:
  - Example: June 2022 policy rate increase produced differing wordings across IR, Monetary Policy Statement, and Governor’s remarks.
  - Current two-day MPC meeting period may be insufficient for in-depth discussion of communication aspects; other central banks take several weeks for this process.

### Recommendations to enhance monetary policy communications
- Recommendation 4: Enhance consistency on communicating MPC decisions
  - Put the inflation target at the center of communications and explain how policy actions will lead to the target being fulfilled.
  - Ensure multiple communication channels present a consistent public message.
  - Organize more pre-MPC meetings focused on communications and involve all MPC members to distill main message and build consensus.
  - Assign responsibility for all communications to the new department.
- Recommendation 5: Upgrade Inflation Report into Monetary Policy Report (MPR)
  - Upgrade IR into an MPR with more forward-looking material and discussion on policy decisions.
  - Current IR is mainly backward-looking; forecasts lack clear assumptions on stance of monetary policy, making BOM’s reaction function difficult to discern.
  - Monetary Policy Department has required analytical skills; internal alternative scenarios are presented to MPC but are not published.
  - Publishing the MPR together with the monetary policy statement would reinforce focus on stable inflation and clarify BOM’s reaction function.
- Recommendation 6: Streamline the Monetary Policy Guidelines (MPG)
  - Short term: streamline MPG by moving long sections about non-core central banking issues to other publications prepared by other authorities.
  - Longer term: consider merging MPG with the new MPR to serve as an accountability mechanism and better delineate fiscal and monetary responsibilities.
- Recommendation 7: Introduce External Sector Report
  - Launch an External Sector Report to improve communications on exchange rate and balance of payments issues, clarify exchange rate regime, provide granular capital account monitoring, and foster dialogue with international stakeholders. Examples cited: Thailand, Korea, and India.

Box 2 — Considerations for a Future BOM Monetary Policy Report (MPR)
- Role and typical structure: flagship publication, typically quarterly, synchronized with MPC meetings, containing Monetary Policy Decision; Executive Summary; Economic Conditions (External and Domestic); Macroeconomic Forecasts (Baseline and Alternative); Monetary Policy and Operations; Annexes/Boxes.
- Proposed MPR features:
  - Introductory section summarizing deliberations, alternative scenarios, trade-offs, and MPC discussion nature.
  - Forward guidance more informative than current statements; be explicit about direction and possibly size of next policy move in main scenario.
  - Expand coverage of inflation expectations: include BOM’s 4-5 pages report on inflation expectations and extend scope to longer-term expectations.
  - Include short topical articles (2-3 pages) on issues affecting Mongolian monetary policy (e.g., higher oil/energy prices, depreciating currency effects).

---

### Financial Stability Communications and the Financial Stability Report (FSR)

### Current strengths and weaknesses
- Strengths:
  - FSR reflects cross-authority effort, covers important sectors, includes policy-relevant information (e.g., cybercrime risks in September 2021 FSR), and uses professional visual aides.
- Weaknesses:
  - FSR too long and overly skewed towards macroeconomic developments with little reference back to the financial system.
  - Chapters differ in style, tone, and disclosure extent; links between analyses and policy recommendations are inadequate.
  - Stress test messaging is not managed; readers left to draw conclusions about magnitude and implications.
  - FSC periodic statements are thin and cryptic.
  - Uncoordinated messages post-IPO due to dual regulation concerns.

### Communications in stressed circumstances
- BOM has experience communicating during elevated stress (COVID-19; Governor interview on banking sector reform praised).
- Tendency: reactive rather than proactive; staff anxiety about negative media reporting contributes to reactivity.
- Cross-authority communications for stress situations underdeveloped; FSC has not issued public statements on AQR/IPO despite relevant mandate elements.

### Organizational capacity and coordination
- Financial stability communications have lower prominence than monetary policy.
- Data confidentiality limits supervisory information sharing for macroprudential analysis.
- MPC and Supervisory Council make financial policy decisions in isolation.
- FSC perceived as bureaucratic and ineffective; technical staff risk averse in escalating matters to FSC.
- FSR-producing staff not empowered to challenge or change contributor narratives.

### Recommendations for financial policy communications
- Recommendation 8: Upgrade and revitalize the FSR and its communication plan
  - Shorten the FSR and make it more financial sector focused.
  - Refresh the executive summary to focus on key risks, assessed resilience, and policy actions.
  - Shorten outlook and scene-setting chapters; link each aspect of the outlook to implications for banking system health.
  - Cross-refer to the MPR for supporting analysis.
  - Empower a skilled editor to work with Communications and stakeholders across BOM and FRC; editor should be able to make editorial decisions.
  - Medium-term goal: redesign FSR as the authoritative FSC/BOM view and the “golden source” with layered communications tailored to audiences (households and firms; journalists; regulated firms; Parliament; researchers; international community).
  - Support FSR publication with outreach: press release, senior management interviews, and possibly a conference.
- Recommendation 9: Revitalize the FSC and BOM-FRC arrangements
  - Short term: FSC should recommit to mandate to coordinate systemic risk monitoring/mitigation, sponsor the FSR, and act as a nimble cross-authority clearing house (e.g., for IPO and AQR issues).
  - Medium term: empower joint BOM-FRC working on shared financial sector issues (post IPO coordination; consider risk arbitrage between banks and non-banks). A more authoritative FSC would enable quicker and more credible crisis communications.
- Recommendation 10: Reshape BOM arrangements for supporting financial policy analysis and communications
  - Short term: convene joint sessions of MPC/Supervisory Council on common issues; coordinate or endorse prioritized joint work program between MPPD and BPRD (leverage in real sector balance sheets; shared stress-test scenarios).
  - Medium term: consider creating an analytical hub by combining MPPD and BPRD to support macroprudential, supervisory, and resolution policy analysis; ensure hub is forward-looking and develops a controlled data system for secure access to sensitive supervisory information. In the interim, make data sharing between departments more seamless.

---

### Evaluating Outcomes of Communications — Framework and Recommendations

### Current gaps
- BOM lacks a framework to regularly assess communications effectiveness; readership and traction of flagship publications (IR and FSR) are unknown.
- No formalized channel to gather public feedback; feedback limited to ad hoc surveys (commercial bank survey on deposit interest rates; an ad hoc public opinion survey rated BOM among top-5 most trusted state institutions).

### Recommendation 11: Start conducting impact assessments of communications
- Develop and adopt a framework to conduct regular impact assessments; specify communications subject to evaluation and methodology; feed results into decision-making.
- Impact assessment components:
  - (i) Outcome evaluation: quantify media exposure using qualitative and quantitative indicators such as audience outreach, number of articles / mentions in the media, number of reposts / tweets, website users, with breakdowns by topic.
  - (ii) Audience reaction assessment: survey stakeholders’ understanding of content and tone, confidence in the central bank, and expectations on monetary or financial developments.
- Best-practice tools: targeted communications assessments; central bank confidence surveys; expectations assessments; web surveys; ad hoc operational assessments.
- Forward guidance: aim for a virtuous cycle where policy and market reactions become more predictable; communications impact on market reactions and expectations should be cornerstone of future strategy.
- Transparency emphasis: communicate primary and secondary mandates and related balance sheet costs; greater transparency on BOM’s accounts and balance sheet is vital.
- IMF availability: IMF remains available for follow-up TA to help implement recommendations (develop communications strategy, upgrade IR, assess communications impact) via in-field missions or desk review.

---

### Appendix I — Indexes and Key Numeric Facts (IAPOC, Cuikerman, Dincer-Eichengreen)

### Index definitions and methodology highlights
- Cuikerman Index:
  - Quantifies legal independence using 16 criteria grouped into four clusters: (i) legal procedures related to appointment/dismissal of governor; (ii) legislative procedures of monetary policy formulation; (iii) mandate and objectives of the central bank; (iv) independence of the central bank.
  - Legal independence scale: highest score = 1, lowest score = 0.
  - Cuikerman Index cited values:
    - 2010: 0.58
    - 2022 (mission calculation): 0.63
- Dincer-Eichengreen Index:
  - Quantifies monetary policy transparency (de jure and de facto); minimal level is 0 and most transparent maximum level is 15.
  - BOM historical values:
    - 2000: 2
    - 2020: more than 8
- IAPOC Index (IMF):
  - Holistic index characterizing three pillars: Independence and Accountability; Policy and Operational Strategy; Communications.
  - Constructed from quantifying 225 criteria.
  - IAPOC country coverage in IMF working paper: 50 countries, 11 of which are LIC.
  - IAPOC for BOM (2022, mission calculated): 0.63.
  - Interpretation: BOM IAPOC 0.63 is above the mean for low-income countries; IAPOC advises strengthening Communications and Policy and Operational Strategy as BOM transitions to inflation targeting.

Key statistics and numeric facts (preserved exactly)
- Cuikerman Index criteria: 16 criteria in four clusters.
- Cuikerman Index scores cited: 2010: 0.58; 2022 (mission calculation): 0.63.
- Dincer-Eichengreen Index range: minimal level is 0 and most transparent maximum level is 15.
- Dincer-Eichengreen historical BOM values: 2000: 2; 2020: more than 8.
- IAPOC construction: based on quantifying 225 criteria.
- IAPOC country coverage in IMF working paper: 50 countries, 11 of which are LIC.
- IAPOC for BOM (2022): 0.63.

_Excerpted from IMF Technical Assistance Report – Mongolia Central Bank Communications (content unit 1mngea2023001)._

### Preface ____________________________________________________________________ 4

### Preface

### Mission and team
- The mission took place in-person in August 2022.
- The mission team from the IMF’s Monetary and Capital Markets Department (MCM) comprised:
  - Udaibir Das (mission chief)
  - Vassili Prokopenko (both—MCM)
  - Florian Gimbel (COM)
  - Altynai Aidarova (CCAMTAC)
  - Marianne Nessén (Riksbank)
  - John Power (Bank of England)
- The mission met Governor of BOM Lkhagvasuren, management and staff of BOM, several current and former members of Parliament, representatives from Financial Regulatory Commission, commercial banks, Bankers’ Association, and think tanks.
- The IMF Resident Representative office (SeokHyun Yoon, Selenge Sandagsuren, and Ardak Bazarbai) provided support.

### Purpose
- Assist the Bank of Mongolia (BOM) in enhancing its communication framework and suggest a roadmap for follow-up technical assistance (TA).
- Specifically requested: better understand global trends in central bank communications, established international practices, and provide input on BOM’s policy communications organizational design.

---

### Executive Summary

### Recent developments and current use of communications
- Over the last decade, BOM has significantly intensified the use of communications.
- New flagship reports and platforms introduced include:
  - Inflation Report
  - Financial Stability Report
  - BOM’s pages on financial literacy
  - Social media engagement
- Communications now include numerous reports, articles, statements, speeches, financial education activities, and regular/ad-hoc meetings with stakeholders (Parliament, banks, journalists, think tanks).

### Scope of the review
- The report reviews BOM’s communication framework focusing on:
  - Monetary and financial policy communications
  - Internal organization of BOM’s communication function (structure, resources, procedures)
  - Preconditions for effective communications, including legal and normative frameworks related to mandate and independence

### Key areas for enhancement
- The report identifies areas to improve coverage, clarity, consistency, and effectiveness of communications.

### Principal recommendations (overview)
- Monetary policy communications:
  - Make the BOM’s Inflation Report more forward-looking and provide more information supporting BOM’s decision-making.
  - Streamline BOM’s Monetary Policy Guidelines by moving all non-core central bank material into a separate publication.
- Financial policy communications:
  - Sharpen focus of the Financial Stability Report.
  - Enhance internal (inter-departmental) and external (inter-agency) communications/collaboration.
- Organizational:
  - Create a dedicated, well-staffed Communications Department integrated into major policy actions and flagship reports.
- Evaluation:
  - Develop and adopt a framework to conduct regular impact assessments of communications.

---

### Table 1: Key Recommendations (as presented)

- Organization of Communications at BOM
  - 1 Create a Communications Department — Priority: High — Timeframe: Immediate
  - 2 Integrate communications into major policy actions and flagship reports — Priority: Medium — Timeframe: Short term
  - 3 Upgrade communication tools and guidelines — Priority: Low — Timeframe: Medium term
- Monetary Policy Communications
  - 4 Enhance consistency on communicating MPC decisions — Priority: High — Timeframe: Immediate
  - 5 Upgrade Inflation Report into Monetary Policy Report — Priority: Medium — Timeframe: Short term
  - 6 Streamline Monetary Policy Guidelines — Priority: Low — Timeframe: Medium term
  - 7 Introduce External Sector Report — Priority: Low — Timeframe: Medium term
- Financial Sector Policy
  - 8 Upgrade and revitalize the Financial Stability Report and its communication plan — Priority: Medium — Timeframe: Immediate
  - 9 Revitalize the Financial Stability Council and the arrangements between BOM and FRC — Priority: High — Timeframe: Short term
  - 10 Reshape the BOM set up on financial policy analysis and communications — Priority: High — Timeframe: Medium term
- Evaluating Outcomes of Communications
  - 11 Start conducting impact assessments of communications — Priority: Medium — Timeframe: Short term

Note: Short term: < 12 months; Medium term: 12 to 24 months.

---

### Context

### Trends and challenges
- Central banks in emerging and frontier markets are aligning communication functions to local realities.
- Traditional definition of central bank communications: information about current and future policy objectives, current economic outlook, and likely path for future policy decisions.
- Roles and public expectations are expanding into macroprudential and crisis management issues.
- Clear and consistent communication builds credibility, improves public confidence, and makes the central bank’s reaction function more transparent.

### Specific challenges highlighted
- Knowledge and data rigidities and frictions complicate effective communication across audiences.
- Most policy communication approaches are developed in markets with higher public literacy, raising adaptation challenges.
- Building policy credibility takes time; internal models cannot fully capture behavioral aspects of all agents.
- Communicating under stressed conditions is particularly difficult.
- Market views and BOM views will not always align; the goal is understanding, not alignment.
- Mandate-related uncertainty complicates effective communications; unclear medium- and long-term objectives hinder stakeholders’ responses and can lead to conflicting messages from BOM, parliament, and media.

---

### Organization of Communications at BOM

### Summary diagnosis
- Two major operational challenges:
  - Organizational fragmentation, increasing the risk of inconsistent messages.
  - Limited capacity for strategic communications, reducing effectiveness of external engagements.
- Recommendation: creation of a new Communications Department.

### A. Multiple challenges require broader-based communications
- BOM has moved beyond press statements and conferences to broader communications including:
  - Financial literacy programs for students
  - Economic education courses for journalists
  - Regular/ad-hoc management meetings with stakeholders
- Communications amplified via website and social media (infographics, short videos, interviews, flagship reports).

### Examples of creative, low-cost engagement
- Continuous stakeholder engagement through Twitter and Facebook (dominant platforms in Mongolia).
- Publicizing initiatives with significant media impact (e.g., commemorative coin featuring The Hu; amplifying Governor’s interview on crypto coins).
- Regular interview slot on Bloomberg TV Mongolia, and Twitter Space/Clubhouse talks aimed at younger audiences.

### B. A fragmented communications function
- About 23 BOM staff are focused on communications but spread across the institution, mostly in Units that do not report directly to the Governor.
- Distribution of communications staff:
  - Press & Information Unit: 5 staff
  - Foreign Relations and Protocol Units: 7 staff
  - Public Financial Education Center: 8 staff
  - Money Museum guides: 2 (in the Market Operations Department)
  - Website expert: 1 (in the Information Technology Department)
- Policy departments also craft economic and financial messages through various publications.
- Organizational fragmentation has significantly increased the risk of inconsistent messages and communications mishaps, with recent instances of inconsistent monetary policy communications cited.

*IMF | Technical Assistance Report – Mongolia Central Bank Communications — Preface and Executive Summary.*

### 10.      Because of its fragmented organization, the BOM’s communications function has a

### 10.      Because of its fragmented organization, the BOM’s communications function has a

### A. Current weaknesses and operational effects
- The communications function has a relatively weak internal standing and is fragmented.
- It is not empowered to ensure message consistency across the institution and is generally not involved in the final review of major communications products.
- Other Departments can easily decline its requests.
- Effects on effectiveness:
  - Delayed responses to media requests; communications staff often must gather information through an overly bureaucratic internal process.
  - Delayed external communications have in some cases allowed misinformation to spread fast and unchecked.

### B. Importance of strategic communications
- BOM communications are mostly reactive rather than proactive and strategic, reducing effectiveness of internal interactions and external engagements.
- Key capacity constraints:
  - Shortage of highly qualified communications staff with time and capacity for strategic planning.
  - Difficulty attracting and retaining economists, journalists, public relations experts, and digital content creators due to more lucrative private sector opportunities and preference by economists for more prestigious BOM Departments.
  - Communications staff are largely excluded from policy development and decision making.
- Integration shortfall:
  - Many BOM Departments have yet to fully integrate communications into daily operations and longer-term strategies.
  - BOM lacks an overarching communications strategy and does not use fully-fledged communication plans for specific policy decisions and products.
  - Example: The Financial Stability Report is published on the BOM’s website without bespoke advertising or outreach.
  - Cultural implication: For many BOM staff, the implicit message in the past has been: “Communications is not my job!”

### C. Stakeholders
- Domestic stakeholders:
  - Parliament & other public authorities
  - Media: press, broadcast, social media
  - Financial Sector: banks, non-bank financial institutions, investors
  - Corporates: from small and medium-sized enterprises to big mining groups
  - Students: high-schools, universities
  - Think tanks, academics, researchers, other influencers
  - General Public (urban-rural divide)
- External stakeholders:
  - Global financial sector: banks, non-bank financial institutions, investors
  - Rating agencies
  - International media
  - Multinational corporations
  - Trade partners
  - International organizations

### D. Recommendations — strategic reorganization and integration
- Fundamental reforms recommended to improve clarity, consistency, and effectiveness of communications. Three priorities:
  - Turn the fragmented communications function into a fully-fledged Communications Department.
  - Integrate communications into all major products and decisions.
  - Upgrade communications tools and guidelines.

Recommendation 1: Create a Communications Department
- Immediate start feasible; some elements may require medium-term implementation (e.g., increased staffing).
- Rationale:
  - Centralization and elevation would improve consistency, clarity, and traction of BOM messages.
  - Empower the Department to ensure message consistency, break internal “silos,” improve flow of information and ideas, and flag inconsistencies across layered communications (flagship report, Governor’s speech, press statement, Tweets, Facebook posts).
  - Reduce risk of misunderstandings, misinformation, and mishaps.
- Operational synergies:
  - Streamline internal processes and optimize coordination through clear reporting lines and procedures.
- Proposed composition and responsibilities:
  - Revamped Press & Information Division (PID).
  - Foreign Relations & Ceremony Unit (managing relations with rating agencies, central banks, international organizations).
  - Newly created Parliament Outreach Unit.
  - Public Financial Education Center (focused on consumer protection & financial education activities).
- Governance:
  - The new Communications Department should have a direct reporting line to the Governor (short-term implementable).
  - The new COM Director should act as a counselor to BOM’s management on communications effectiveness, requiring qualitative and quantitative assessments, including more frequent surveys of key stakeholders and more refined impact assessment.
- Press & Information Unit (PIU) transformation:
  - Current responsibilities: the five-strong PIU is focused on managing and monitoring social media, managing traditional media relations (via press statements, press conferences), and supporting the BOM Governor in drafting speeches and articles.
  - Additional responsibilities for the new PID: full control over the content and management of the BOM’s website; enhanced capacity to assess impact across multiple tools and platforms; oversight of a new team of translators to improve quality of English translations.
  - Increased internal communications role: regular internal communications and facilitation of townhall meetings for staff to give direct feedback to management.
- Parliament Outreach Unit:
  - Medium-term establishment to lead BOM engagement with Parliament, advising management and briefing parliamentarians; inspiration cited from the Parliamentary Affairs Group at the Bank of England.
- Staffing:
  - The new Department will need a greater number of highly skilled staff; enhanced internal standing would facilitate competing for internal and external talent.

Recommendation 2: Integrate communications into major policy actions and flagship reports
- Communications should be “at the table” at all levels; the COM Director should be fully involved in policy formulation and decision-making (short-term implementable).
- Roles for senior communications staff:
  - Anticipate stakeholder reactions to policy actions (e.g., larger-than-expected interest rate increase).
  - Help communicate difficult financial stability messages.
  - Simplify language without changing meaning to improve understanding across audiences.
- Communications plans for major policy actions and flagship reports (short-term priority, especially on banks’ asset quality review (AQR) and initial public offerings (IPOs)):
  - Message formation: early interdepartmental collaboration and brainstorming on flagship chapters and reception by the public.
  - Message determination: finalization, nuancing, and clearing by BOM management of key messages prepared by staff; communications staff should be empowered to support management, especially in nuancing messages.
  - Message dissemination: interdepartmental collaboration to prepare layered outreach products; communications staff should lead outreach efforts.
- Medium-term staffing and structural supports:
  - Dedicated staff to support “Flagship Departments” to engage continuously with policy experts, build knowledge and trust, moderate MPC press conferences and similar events, and improve communication quality and timeliness.
  - Hire more economists and financial sector experts to strengthen credibility and ability to work across Departments; options include senior advisors and secondments from other BOM departments.
  - Create an institutional communications strategy in the medium term, owned and internalized by BOM’s management and staff, led by the new Communications Department.

### E. Recommendation 3: Upgrade communications tools and guidelines (short-term measures)
- Upgrade the BOM’s English-language website: build in-house capacity in the new PID to ensure high-quality English translations to reach a wider audience, including nonresident investors in domestic financial markets.
- Modernize website design with more visual information: make the site more mobile-friendly and significantly enhance visual impact; feature more (no-jargon) infographics and basic-concepts videos (e.g., “What is inflation?”).
- Create formal guidelines:
  - Draft and implement guidelines for interactions between staff and media, especially interviews.
  - Establish clear social media guidelines for staff, including on use of private accounts.
  - These measures are critical to improve BOM communications and reduce reputational risk.

### F. Box 1 — Key attributes of an effective central bank website
- Ease of finding key information: easy to find monetary policy objectives, monetary policy decisions (on policy rate, calendar of future policy meetings), and core economic analysis (inflation report).
- Focus of information: present only the most relevant information at the initial point of entry, with no extraneous information.
- Clarity of information and readability: presentation should be clear, concise, timely, and easily understandable for both professionals and a broader public.
- Layering of information: present high-level messages up front with links to more in-depth information; segregate detailed technical information from high-level information while keeping it easy to locate.
- Attribution of information: clearly identify official status and source for each piece of information; show whether it is endorsed by the government or based on law, whether it reflects a decision by the BOM Board, or whether it is a staff or unofficial view; provide sources for all statistical tables and figures.
- Accessibility of historical information: organize past monetary policy decisions, past inflation reports, past press releases so they are easy and quick to locate.
- Use of graphics, videos, and podcasts: use these media effectively.
- Public education: include a section to help teachers, students, and other members of the general public learn about BOM functions and activities.
- Mobile-friendliness: ensure usability on mobile devices as well as larger screens.

### G. Monetary policy communications — current situation (start)
- Key elements of an effective monetary policy communication framework are in place in Mongolia.
- As part of the forecasting and policy analysis system used for the inflation targeting regime, policy decisions are communicated to the public.
- BOM publishes an Inflation Report (IR), which is widely regarded as an excellent source of analytical information on monetary policy and overall economic developments in Mongolia.
- There is regular engagement of BOM with different stakeholders, and BOM is actively promoting transparency.

*IMF | Technical Assistance Report – Mongolia Central Bank Communications | excerpts from content unit 10–30*

### Annex I.

### Annex I.

### Monetary policy framework and governance
- The Monetary Policy Guidelines (MPG) frame monetary policy; operational decisions are taken by the Monetary Policy Committee (MPC).
- MPG are approved by the Parliament and published on an annual basis.
- Legal basis: constitutional clause whereby Parliament can “determine monetary and fiscal policy”.
- MPC structure and meetings:
  - MPC is headed by the Governor and has 3 internal and 4 external members.
  - There are four pre-scheduled MPC meetings per year, and there may also be unscheduled meetings.
  - The MPC sets the Bank of Mongolia’s (BOM) policy rate and reserve requirements and can decide on foreign exchange interventions.
  - The regulation guiding the work of MPC is published on the BOM’s web site and is broadly consistent with conventional practices in peer central banks.
- Inflation targeting detail:
  - The inflation target is currently set at 6 percent, with a tolerance range of +/- 2 percentage points.
  - The inflation target is set by the Parliament, based on the suggestion from BOM.

### Communication practices and instruments
- Channels and timing:
  - Immediately after the MPC meeting, a short Monetary Policy Statement is published, and a press conference is organized.
  - The comprehensive Inflation Report (IR) is published four times per year, typically a few weeks after the pre-scheduled MPC meeting.
  - MPC members hold periodic speeches communicating policy decisions.
- Content of communications:
  - The Monetary Policy Statement typically summarizes the economic assessment, the action taken, and the reasoning behind it.
  - The press conference is held with prepared (and published) remarks from the Governor, with time for questions from attending media.
  - The IR contains more in-depth motivations for economic assessments and a fuller account of policy deliberations.
- Internal coordination:
  - An analytical unit within BOM’s Monetary Operations Department supports internal information flow between management and the monetary operation and policy departments.
  - Key information on foreign exchange operations is communicated to banks in advance as BOM serves as the price-maker on the market.

### Key challenges identified
- Ambiguity in mandate:
  - The Law on the Central Bank states the “main objective of Bank of Mongolia is to sustain stability of national currency – togrog”.
  - This is interpreted differently: BOM interprets it as price stability (CPI-based), while other stakeholders (members of Parliament, business leaders, parts of the public) interpret it as stability of the nominal exchange rate of the togrog.
  - The lack of clarity affects coherence of public communication and can undermine public confidence; any future review of the Law should strive to resolve this lack of clarity in the mandate.
- Limited English translations:
  - The only communication channel available in English in a timely manner is the Monetary Policy Statement.
  - The IR is translated into English but with a long delay (as of August 2022, the latest available English version of the IR was as of March 2021).
  - Lack of official translations complicates evaluation of BOM monetary policy communication and makes it conditional on the accuracy of unofficial translations.
- Quasi-fiscal activities:
  - Parliament has traditionally assigned BOM tasks that are fiscal in nature (for example, the subsidized mortgage program), complicating BOM’s monetary policy decision-making and communications.
- Inconsistent messaging across channels:
  - Example: June 2022 policy rate increase
    - IR summarized the decision as “necessary to stabilize inflation in the medium term”.
    - Monetary Policy Statement noted the policy rate was raised “with the aim to stabilize inflation expectations in the medium term, ensure external and domestic balance at an appropriate level and maintain relative yield on togrog in an environment of rising external benchmark rate”.
    - Remarks by the Governor noted that monetary policy was tightened “in order to maintain external and internal balance of the economy at an appropriate level”.
  - The period of two days currently devoted to the MPC meeting may be insufficient for in-depth discussion of communication aspects; experience from other central banks indicates this process can take several weeks.

### Recommendations to enhance monetary policy communications
- Recommendation 4: Enhance consistency on communicating MPC decisions
  - Put the inflation target at the center of communications and explain how policy actions will lead to the target being fulfilled.
  - Ensure multiple communication channels present a consistent public message.
  - Organize more pre-MPC meetings focused on communications and involving all MPC members to distill the main message and build consensus.
  - Assign responsibility for all communications to the new department (as discussed elsewhere in the Annex).
- Recommendation 5: Upgrade Inflation Report into Monetary Policy Report (MPR)
  - Upgrade the IR into an MPR with more forward-looking material and discussions on policy decisions.
  - Current IR is mainly backward-looking; forecasts in the IR lack clear assumptions on the stance of monetary policy, making the BOM’s reaction function difficult to discern.
  - With editorial changes and analytical additions, BOM can produce an MPR similar to those published by most central banks.
  - The Monetary Policy Department already has the required analytical skills; internal alternative scenarios are presented to the MPC but are not published.
  - Publishing the MPR together with the monetary policy statement would reinforce focus on stable inflation and clarify the BOM’s reaction function.
- Recommendation 6: Streamline the Monetary Policy Guidelines (MPG)
  - Short term: MPG should be streamlined by moving long sections about non-core central banking issues to other publications prepared by other authorities.
  - Longer term: MPG could be merged with the new MPR to serve as an accountability mechanism for monetary policy, better delineating fiscal and monetary responsibilities and making BOM a more modern, strong, and credible central bank.
- Recommendation 7: Introduce External Sector Report
  - Launching an External Sector Report would improve communications on the exchange rate and balance of payments issues.
  - Benefits include:
    - Clearer communications on the exchange rate regime and rate, foreign currency markets, auctions, and interventions.
    - More granular monitoring and analysis of capital account issues.
    - Deeper proactive dialogue with international stakeholders.
  - Examples of central banks proactively communicating on external sector risks: Thailand, Korea, and India.

*Source: Annex I.*

### Box 2. Considerations for a Future BOM’s Monetary Policy Report

### Box 2. Considerations for a Future BOM’s Monetary Policy Report

### Role and typical structure of a Monetary Policy Report (MPR)
- An MPR is the flagship publication of most central banks and fully reflects the core function: the conduct of monetary policy.
- Typically published quarterly and synchronized with MPC meetings; MPC decisions on the key policy rate are supported by data and analysis in the MPR.
- MPR content mix:
  - Monetary Policy Decision
  - Executive Summary
  - Economic Conditions: External and Domestic
  - Macroeconomic Forecasts: Baseline Forecast and Alternative Forecasts
  - Monetary Policy and Operations
  - Annexes / Boxes on Topical Issues
- MPRs are often technical documents for professional audiences but typically include introductory non-technical summaries for a broader audience.
- Common recurring sections include: (i) the central bank mandate, (ii) numerical inflation target, and (iii) the strategy that guides central bank decisions.

### Proposed features for a future BOM MPR
- Begin with an introductory section summarizing monetary policy deliberations, including qualitative summaries of alternative scenarios and other relevant analyses to convey trade-offs, main concerns, and the nature of the MPC discussion.
- Include forward guidance:
  - Make forward guidance more informative than current monetary policy statements.
  - Be more explicit about the direction and possibly size of the next policy move envisaged in the main scenario.
- Expand coverage of inflation expectations:
  - Include the BOM’s existing 4-5 pages report on a survey of inflation expectations in the MPR, together with analysis of the results.
  - Extend the scope of the survey to include longer-term expectations to help measure the credibility of the inflation target.
- Include short topical articles (2-3 pages) on issues affecting Mongolian monetary policy (examples: effect of higher oil and energy prices, impact of a depreciating currency on domestic inflation).

### Findings on financial policy communications and FSRs
- Financial policy communications is a young area; BOM has started using it as a policy instrument in peacetime and crisis times.
- BOM can use financial policy communications to warn market participants, set out expectations, incentivize action, and provide calming influence under stress—requiring closer collaboration with other financial sector authorities.
- Institutional roles:
  - BOM must ensure “stability of financial markets and the banking system” and shares financial stability responsibility with the Financial Regulatory Commission (FRC) and Financial Stability Council (FSC).
  - Macroprudential Policy Department (MPPD) leads macroprudential analysis and the flagship Financial Stability Report (FSR); Banking Resolution and Policy Department (BRPD) conducts microprudential risk assessment.
- Strengths of the FSR:
  - Reflects cross-authority effort, covers important sectors, includes policy-relevant information (e.g., cybercrime risks in September 2021 FSR), and uses professional visual aides.
- Weaknesses of the FSR and other communications:
  - FSR is too long and overly skewed towards macroeconomic developments with little reference back to the financial system; insufficient in-depth assessment of macro-financial linkages.
  - Chapters differ in style, tone, and extent of disclosure, reducing clarity and consistency.
  - Inadequate links between analyses and policy recommendations; stress test messaging is not managed (readers left to draw their own conclusions about magnitude and implications).
  - FSC periodic statements are thin and cryptic, missing opportunities to influence financial sector discourse.
  - Business-as-usual regulatory communications with banks work well, but concerns exist about uncoordinated messages post-IPO due to dual regulation.

### Communications in stressed circumstances
- BOM has experience communicating during elevated financial stress; communications during COVID-19 and the Governor’s interview on banking sector reform were praised.
- BOM tends to be reactive rather than proactive in stressed circumstances. Staff anxiety about negative media reporting contributes to reactivity.
- Cross-authority communications for stress situations are underdeveloped; FSC has not issued public statements on the AQR/IPO despite mandate elements relevant to crisis prevention and mitigation, hindering confident communications.

### Organizational capacity and coordination issues
- BOM staff recognize communication importance and the need for complementary expertise in policy areas, but financial stability communications have lower prominence than monetary policy.
- Data confidentiality blocks sharing supervisory information for macroprudential analysis; MPC and the Supervisory Council make financial policy decisions in isolation.
- FSC perceived as bureaucratic and ineffective; technical staff appear risk averse in escalating matters to FSC, inhibiting a credible shared narrative on risks, resilience, and required actions.
- Staff producing the FSR do not appear empowered to question or change narratives submitted by contributors.

### Recommendations (numbered as in source)
- Recommendation 8: Upgrade and revitalize the FSR and its communication plan
  - Shorten the FSR and make it more financial sector focused.
  - Refresh the executive summary to focus on key risks to the financial system, assessed resilience, and policy actions the authorities are or should be pursuing.
  - Shorten outlook and scene-setting chapters; challenge inclusion by asking how each aspect of the outlook affects the health of the banking system.
  - Cross-refer to the MPR for supporting analysis/reporting.
  - Empower a skilled editor to work with the Communications department and stakeholders across BOM and FRC; editor should ensure clarity and consistency and be empowered to make editorial decisions.
  - Medium-term aspirational goal: re-design FSR to be the authoritative FSC/BOM view and the “golden source” of information for stakeholders with a layered communication approach tailored to audiences:
    - Households and firms: simple messages reassuring that money is safe and BOM actions.
    - Journalists and media: need context and education to deliver simple messages to the public.
    - Regulated firms and financial market participants: analytical heft and credible analysis to influence behavior and set expectations.
    - Parliament and politicians: sufficient information for scrutiny, requiring credible supporting analysis.
    - Researchers and academics: inspire further research on issues under review.
    - International community: confidence that local authorities understand and are on top of risks.
  - Support FSR publication with outreach: press release, senior management interviews, and possibly a conference with media, academia, and financial sector.

- Recommendation 9: Revitalize the FSC and the arrangements between BOM and FRC
  - Short term: FSC should recommit to its mandate to coordinate monitoring and mitigation of systemic financial risks, provide real oversight, actively sponsor the FSR, and act as a nimble cross-authority clearing house (e.g., for IPO and AQR issues).
  - Medium term: FSC should empower joint BOM-FRC working on shared financial sector issues (post IPO coordination on supervision, consider risk arbitrage between banks and non-banks). A more authoritative FSC should enable quicker and more effective crisis communications.

- Recommendation 10: Reshape BOM arrangements for supporting financial policy analysis and communications
  - Short term: Convene joint sessions of the MPC/Supervisory Council on common financial sector issues; coordinate or endorse a prioritized joint work program between MPPD and BPRD to exploit synergies (e.g., leverage in real sector balance sheets; shared scenarios for stress testing).
  - Medium term: Consider creating an analytical hub by combining MPPD and BPRD to support macroprudential, supervisory, and resolution policy analysis; ensure the hub remains forward-looking and develop a controlled data system for secure access to sensitive supervisory information. In the interim, make data sharing between departments more seamless.

- Recommendation 11: Start conducting impact assessments of communications
  - Develop and adopt a framework to conduct regular impact assessments of communications; specify communications subject to evaluation and the methodology; feed results into decision-making.
  - Impact assessment components:
    - (i) Outcome evaluation: quantify media exposure using qualitative and quantitative indicators such as audience outreach, number of articles / mentions in the media, number of reposts / tweets, website users, with breakdowns by topic.
    - (ii) Audience reaction assessment: survey stakeholders’ understanding of content and tone, confidence in the central bank, and expectations on monetary or financial developments.

### Evaluation and forward-looking guidance
- Current situation:
  - BOM lacks a framework to regularly assess communications effectiveness; readership and traction of flagship publications (Inflation Report and Financial Stability Report) are unknown.
  - No formalized channel to gather public feedback; feedback limited to ad hoc surveys (examples: commercial bank survey on deposit interest rates; ad hoc public opinion survey rated BOM among top-5 most trusted state institutions).
- Best practice highlights:
  - Evaluation improves communications effectiveness; central banks should both speak and listen.
  - Use systematic tools (targeted communications assessments, central bank confidence surveys, expectations assessments, web surveys) and ad hoc operational assessments.
  - Collect data from various sources at highest feasible frequency, balancing benefits against collection and maintenance costs.
  - Compare internal projected policy paths with external forecasters as a measure of communications effectiveness.
- Looking forward:
  - No single report can cover all aspects; aim for a virtuous cycle where policy becomes more predictable and market reactions more predictable (Blinder (1998) concept).
  - Communications impact on market reactions and expectations should be the cornerstone of future strategy.
  - BOM should develop a culture and practice to communicate primary and secondary mandates and related balance sheet costs; greater transparency on BOM’s accounts and balance sheets is vital.
  - IMF remains available for follow-up technical assistance (TA) to help implement recommendations, especially on developing a communications strategy, upgrading the Inflation Report, and assessing the impact of communications; TA may be provided by MCM via in-field missions or desk review.

*IMF | Technical Assistance Report – Mongolia Central Bank Communications*

### Appendix I. IAPOC

### Appendix I. IAPOC

### Indexes and definitions
- Three indexes summarized:
  - Cuikerman Index: quantifies legal independence of the central bank using 16 criteria grouped into four clusters: (i) legal procedures related to the appointment, dismissal, etc. of the governor of the central bank, (ii) legislative procedures of monetary policy formulation, (iii) mandate and objectives of the central bank, (iv) independence of the central bank.
  - Dincer-Eichengreen Index: quantifies monetary policy transparency (de jure and de facto); minimal level is 0 and most transparent maximum level is 15. It considers: Political transparency; Economic transparency (information and forecasts used in decision-making); Procedural transparency; Policy transparency (disclosure and communication of policy decisions); Operational transparency (implementation of policy).
  - IAPOC Index (IMF): a holistic index characterizing three pillars of the monetary policy framework—Independence and Accountability, Policy and Operational Strategy, and Communications—encompassing transparency, consistency, and coherence. The IAPOC is constructed based on quantifying 225 criteria.

### Cuikerman Index — Bank of Mongolia (BOM) findings
- Legal independence scale: highest score = 1, lowest score = 0.
- Historical and mission calculations:
  - Cuikerman Index in 2010 (per Dincer and Eichengreen (2019) calculations): 0.58
  - Mission-calculated Cuikerman Index for 2022 (reflecting de jure improvements after 2018 law amendments): 0.63
- Interpretation:
  - 2018 amendments modernized BOM legal framework and improved legal independence and transparency.
  - Room for improvement remains in mandate/objective setting and government lending practices at the BOM.

### Dincer-Eichengreen Index — BOM findings
- Global and regional context:
  - Recent recalculation (N. Dincer and B. Eichengreen “Central Bank Transparency and Independence: Updates and New Measures”, 2021) shows global improvement in transparency (de jure and de facto).
  - Countries from the region demonstrated persistent and stronger growth than observed at the BOM.
- BOM trajectory:
  - Index increased from 2 in 2000 up to more than 8 in 2020.
  - BOM has been consistently improving transparency over the last two decades, but there is still room for further improvement.

### IAPOC Index — methodology and BOM results
- Methodology highlights:
  - IAPOC characterizes three pillars: Independence and Accountability; Policy and Operational Strategy; Communications.
  - The index captures transparency (availability of information), consistency (alignment of policy/operations with communication), and coherence (logical features of monetary policy).
  - Constructed from 225 criteria.
- Coverage:
  - The IAPOC estimated in the IMF working paper covers 50 countries, 11 of which are LIC; Mongolia was not in that original list.
- BOM-specific calculation and interpretation:
  - The mission calculated the IAPOC Index for the BOM for 2022: 0.63.
  - The BOM IAPOC Index of 0.63 is above the mean for low-income countries, though the range for LIC is broad.
  - Across the three pillars, the IAPOC advises strengthening:
    - Communications
    - Policy and Operational Strategy
  - Relevance:
    - As BOM plans to switch to inflation targeting, which implies clear, consistent, and transparent legal foundations, monetary policy design and implementation and communication, the IAPOC index could be a useful tool to monitor development and compare to peer countries.

### Key statistics and numeric facts (preserved exactly)
- Cuikerman Index criteria: 16 criteria in four clusters.
- Cuikerman Index scores cited:
  - 2010: 0.58
  - 2022 (mission calculation): 0.63
- Dincer-Eichengreen Index range: minimal level is 0 and most transparent maximum level is 15.
- Dincer-Eichengreen historical BOM values:
  - 2000: 2
  - 2020: more than 8
- IAPOC construction: based on quantifying 225 criteria.
- IAPOC country coverage in IMF working paper: 50 countries, 11 of which are LIC.
- IAPOC for BOM (2022): 0.63.

_Excerpted from Appendix I. IAPOC (IMF Technical Assistance Report – Mongolia Central Bank Communications)._/

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_Source: https://www.imf.org/-/media/files/publications/cr/2023/english/1mngea2023001.pdf_