## HOW TO DEVELOP A FRAMEWORK FOR THE INVESTMENT OF TEMPORARY GOVERNMENT CASH SURPLUSES

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### Introduction and objectives
- Primary objective: ensure government can execute the budget smoothly and meet obligations as they fall due.
- Secondary objective: achieve a return on cash balances within prudent risk limits.
- Prudence is critical during heightened uncertainty (example: the COVID-19 pandemic).
- Cash management addresses intra-year timing mismatches between revenues and expenditures via short-term borrowing for shortfalls and investing temporary surpluses in short-term assets.
- Poor cash planning leads to high cash buffers or cash rationing; effective planning reduces unremunerated idle cash and can allow a lower average cash buffer.
- COVID-19 increased unpredictability in borrowing requirements, interest rate volatility, market liquidity concerns, and cash flow volatility.

### Identifying cash surpluses: definitions, persistence, and management implications
- Definitions:
  - Cash surplus: excess of cash over what is required to meet day-to-day payment obligations.
  - Structural surplus: surplus to the needs of in-year cash management.
  - Temporary surplus: intra-year phenomenon with a short time horizon.
- Persistence guidance:
  - If managers can maintain the cash buffer and invest cash for more than three to six months, the shock is more likely permanent.
  - Analysis of underlying factors helps validate whether a shock is permanent or transitory.
- Management implications:
  - Temporary surpluses → invest in short-term instruments (investment horizon for cash managers rarely exceeds three to six months).
  - Structural surpluses → manage separately (long-term savings funds, stabilization funds, cash/near-cash reserve funds) with different criteria, personnel, and governance.

### Building and disclosing a cash buffer
- Purpose: minimum level of cash (usually in the TSA) to meet day-to-day cash requirements at all times.
- Characteristics:
  - Buffer usually held in cash at the central bank for security and liquidity and should be mostly available for immediate use.
  - Some tranche may be investable in slightly longer-term assets (e.g., term deposits breakable on penalty), but caution is advised.
  - Large buffers may need inclusion in asset-liability management analysis underlying the debt management strategy.
- Disclosure considerations:
  - Publication signals prudence but risks undermining market operations or credibility if targets are missed.
  - Markets can estimate actual cash balance from the published central bank balance sheet even if buffer not published.

### Cash reserve fund: purpose, uses, and role
- Purpose: use cash over and above the buffer but not associated with daily fluctuations or short-term market disruption risk.
- Uses:
  - Buy back debt if cost-effective and improves debt portfolio characteristics.
  - Held as a stabilization or reserve fund to be run down over the cycle or used against severe shocks (examples: banking collapse, pandemic).
- Characteristics and governance:
  - Invested in relatively short-term assets; managed under different governance from short-term cash management.
  - Cash managers typically responsible only for short-term investments used in cash flow smoothing (investment horizon rarely longer than three to six months).
- Role in money market development:
  - Reserve funds are intermediate between the buffer and longer-term funds; sensible where structural surplus likely to be run down in medium term or money market depth is uncertain.
  - Can be invested in a range of money market assets unless liquidity management or credit risk reasons require central bank term deposits.
- Example (UK DMO):
  - Proceeds from sale of third generation (3G) radio spectrum licenses were nearly £20 billion ($25 billion) more than budgeted in 2000.
  - Government held most proceeds to be run down over the following three years; managed in the money market (mostly repurchase agreements, plus certificates of deposit and commercial paper).
  - A three-month money market rate was set as a performance benchmark; fund performance monitored and internally accounted for separately from normal cash management operations.
  - Internal safety net arrangements allowed arm’s length access by cash managers if required.

### Investment options, currency choice, and instrument selection
- Currency:
  - Investments intrinsic to cash management will usually be in domestic currency.
  - Credit quality and liquidity are paramount; there should be no risk to principal.
- Investment instruments and maturities:
  - Ideal money market investment: stable value, low default risk, convertible to cash at any time without significant loss of principal.
  - Callable investments (term deposits breakable on request with some interest penalty) provide safeguards.
  - For countries with limited intervention frequency ("rough tune"), slightly longer maturities may be used.
- Typical investment horizon:
  - Typically will not exceed 30 days for cash management operations.
  - Money market instruments (maturities less than one year): T-bills, repurchase agreements (repos) and reverse repos, bank deposits (and some certificates of deposit), interbank loans, money market mutual funds.
  - For many emerging market and developing economies: repos and deposits with the central bank or commercial banks are particularly relevant.
  - For low-income countries with undeveloped money markets: options may be limited to central bank or commercial bank deposits.

### Key investment risks and priority ordering
- Principal risks to assess and manage: credit risk, liquidity risk, market risk (especially interest rate risk), legal risk, operational risk, settlement risk.
- Practical emphasis:
  - Credit and liquidity risks are of primary importance to cash managers.
  - Market risk matters less if most maturities are shorter than one month; interest rate volatility encourages shorter maturities.
- Risk tolerance and hierarchy:
  - Government risk tolerance and risk-return trade-off determine appropriate instruments.
  - General prioritization when investing cash: safety first, then liquidity, then return.
- Special circumstances:
  - During crises (global financial crisis, COVID-19) managing liquidity risk is especially important.
  - Where appropriate, investments may be made in the central bank as term deposits for liquidity or credit considerations.

### Repos, reverse repos, and collateralization practices
- Repo definition and features:
  - Repo: sale of a security by a “borrower” to a “lender” with agreement to repurchase at a specified date and pre-agreed price; treated as a collateralized loan though legally a change of ownership.
  - Typical availability: generally up to three months; in less developed markets tenors may be up to one week or overnight.
  - Collateral: most repos use government or central bank securities; other widely traded instruments may be used.
- Specific risks and mitigants:
  - Mark-to-market and remargining: collateral should be marked-to-market daily; over-collateralization (haircut) used where remargining is burdensome.
    - Example haircuts: may be small, say, 2 or 3 percent (margin rates in Australia for all repos are 2 percent); in nascent markets haircuts may be up to 25 percent.
  - Counterparty quality: restrict transactions to high-quality counterparties and require GMRA or local equivalent.
  - Legal risks: interactions with local insolvency law and tax recognition of repo may require legislative changes.
  - Custody and settlement: independent custodian, delivery versus payment (DvP), tri-party repo where available.
- Preference:
  - Where market is sufficiently liquid, reverse repo should be the preferred instrument—quick, flexible, and secure; central bank can act as agent in initial capability-building.

### Deposits (commercial banks and central bank) and market analogues
- Term deposits at commercial banks:
  - Demand deposits: extremely liquid, negotiable at par value.
  - Term deposits: usually earn higher interest but may carry penalties if terminated early.
  - Collateral: assess creditworthiness and take collateral to reduce credit risk; collateral is treated as a pledge rather than owned.
  - Pricing/allocation: use competitive processes (occasional tenders or prequalified panels with master agreement); ensure level playing field across publicly/private and foreign/domestic banks.
  - Country practices: Chile and China periodically auction deposits to a prequalified panel requiring collateral (usually government bonds); Spain organizes tenders where the variable is the spread against a money market comparator rate.
- Deposits at the central bank:
  - General guidance: surplus cash balances should not normally be invested at the central bank because that can undermine cash flow smoothing benefits.
  - Exception: where structural surplus of liquidity exists in domestic market (for example, from FX purchases), the central bank may ask the MoF to invest surplus cash with it; MoF should seek remuneration at the applicable risk-free interest rate.
  - Practical note: in many developing and some developed countries, government deposits may be unremunerated or remunerated at much lower rates.
- Remuneration principles:
  - Use a market-related rate to remunerate government deposits so MoF is appropriately compensated for foregone alternatives.
  - Possible market analogues:
    - Call deposits: link to the central bank’s policy rate or local interbank overnight rates.
    - Term deposits: relate to repo rates for similar terms, or to rates earned by the central bank in its OMOs.
- Country example (Colombia):
  - Central bank enables treasury placements in interest-bearing deposits with terms of up to 730 days; rates follow a curve linking very short-term rates to interbank rates and short- and medium-term deposits to fixed-income market rates.

### Less common instruments and cautions
- Certificate of Deposit (CD): negotiable CDs can be sold in secondary market; creditworthiness of issuer is prime concern; prior redemption carries penalties.
- Money Market Mutual Funds (MMMFs): invest up to 60 days; regulated; may become illiquid in stress; less common outside Europe and US.
- Commercial paper: unsecured promissory notes; liquidity depends on issuer’s willingness to repurchase; unattractive for government cash managers due to high monitoring needs.
- Use of surplus cash for buy-backs:
  - Benefits: can help cash flow smoothing and improve market liquidity if linked with conversion offers.
  - Disadvantages: can be expensive, reduce liquidity of remaining bond stock, and remove cash from buffer; usually better treated as a debt management tool.

### Institutional arrangements, governance, and operational setup
- Investment Policy Statement:
  - Formal written policy specifying asset allocation choices, risk tolerance, and rate of return objectives; approved by relevant minister, governing board, or committee.
  - Specify authority, decision-making responsibilities, segregation of duties, permissible investments, risk policies (permissible investments, exposure limits, diversification, collateral management), reporting, benchmarking, review process, and policy on exceptions.
  - Operating procedures: steps from identifying funds to selecting instruments and counterparties, settlement, and monitoring through maturity.
- Coordination with debt management:
  - Cash and debt management functions should be closely coordinated or integrated; institutional, governance, and decision-making requirements are similar.
  - Active cash management can protect a stable T-bond issuance program by using T-bills and other money market instruments to smooth cash flows.
- Cash Coordination Committee (CCC):
  - Bring together treasury, budget, debt, and macro-fiscal functions to make integrated borrowing and lending decisions.
  - Roles: review cash flow outturns vs forecasts; review forecasts; decide or recommend actions to ensure cash adequacy and cost-effective use of surpluses.
  - Consider a technical-level committee to support the CCC; invite central bank as observer if necessary.
- Interaction with the central bank:
  - Establish coordination mechanisms and a Memorandum of Understanding covering money market development program, respective operations (investments, T-bill issues, OMOs), operation times and announcements, and information exchanges.
  - Central bank should be informed of parameters of expected operations (e.g., target end-of-day balance).
- Internal organization (Front/Middle/Back Office):
  - Front office: monitor markets, run tenders, make investments (such as reverse repos).
  - Middle office: develop policies and strategies, create risk management framework, report on policies/operations/performance, prepare/update cash flow forecasts.
  - Back office: manage collateral/pledges, daily valuation and remargining, reconciliation, settlement, servicing.
  - Vertical separation of functions recommended to control operational risk.
- Legal and authority requirements:
  - MoF/treasury/DMO must have authority to borrow short term and to invest surplus balances in financial markets or as term deposits in the central bank.
  - Legal documents should identify and approve risk parameters rather than rigidly specify instruments to retain flexibility.

### Operational practices, staffing, systems, and continuity
- Staffing and systems:
  - Additional staff may be required for market interaction, cash flow forecasting, and transaction processing; initial set-up costs exist though continuing staff needs likely modest.
  - Training is important to embed market practices and internal controls.
  - Initial systems can use Excel for few transactions; auctions and repos ideally need electronic systems integrated with back office.
  - As transactions grow, a fully integrated transaction processing system with front, middle, and back office capabilities is preferred.
- Business continuity and financing continuity plans should address severe market disruptions.
- Contracts and documentation:
  - Prepare GMRA for repo and master agreements for term deposits; test systems with dummy transactions before live operation.

### Performance monitoring and metrics
- Performance evaluation:
  - Include performance evaluation in the investment policy; measuring investment performance is strongly recommended though difficult for cash managers.
  - Performance measures should reflect cash management objectives:
    - Measure whether cash is available to meet commitments.
    - Measure avoidance of central bank overdraft or commercial bank credit line use.
    - Assess returns against a counterfactual (e.g., return on call deposits); example: Agence France Trésor targets EONIA for short-term deposits and overnight reverse repo, and EONIA less 2 basis points for reverse repo longer than 1 day.
    - To assess smoothing, track stability of balances or deviation with respect to a range.
- Examples of indicators:
  - rolling averages of TSA balances (example: 91-day rolling average in Australia);
  - explicit upper limits on rolling averages (example: $1.5 billion in Australia historically);
  - operational objectives expressed in business days of non-debt cash requirements (example: five business days in Canada);
  - net return on balances compared to benchmark yields (Canada: return on auctioned balances minus weighted average yield on T-bills);
  - proportion of balances invested on a fully secured basis.

### Country practices and selected instrument uses (selected entries)
- Argentina: Fixed-term placements at Banco de la Nación Argentina (BNA).
- Australia: Deposits at the central bank; introduced a 91-day rolling average for the Official Public Account (OPA); $1.5 billion upper limit historically (removed February 2017).
- Canada: Bank of Canada manages the Receiver General Consolidated Revenue Fund; RG balances maintained to meet five business days of non-debt cash requirements; excess cash invested via competitive auction twice each business day; a large portion of deposits are fully secured (repos).
- Chile: Domestic term deposits, repurchase agreements via auctions with collateral usually government bonds; auctions of reverse repo investments.
- China: Periodic auctions of term deposits up to 90 days to prequalified banks; requires collateral, usually government bonds.
- Colombia: Interest-bearing deposits at central bank; central bank enables treasury placements up to 730 days; for dollars, time deposits in commercial banks through the central bank.
- Russian Federation: Treasury evolved from bank deposits toward repo (reverse repo lending surplus cash); treasury can lend surplus cash to finance budgets of subjects and municipalities in loans up to 90 days; repo collateral requirement: government securities; controls include mandatory deposit insurance participation, adequate capital base, investment grade rating of A– or higher on the national rating scale.
- United Kingdom: Reverse repos; very liquid market particularly for tenors less than 30 days; DMO objectives include ensuring daily cash supply, avoiding conflict with Bank of England monetary operations, minimizing market impact, transparent cost/risk measurement, and maintaining credible market reputation.
- United States: Historically TTL program with collateralized deposits; Term Investment Option program; overnight investments in reverse repo against treasury collateral; post-crisis changes led to excess cash left with Federal Reserve in overnight deposits (TTL temporarily closed in 2012).
- Other countries listed with typical instruments and practices include France, Hungary, Mexico, Perú, South Africa, Spain, Sweden, The Netherlands, Turkey, Vietnam.

### Practical implementation steps and operational checklist
- Identify the target cash buffer that is always available to meet residual day-to-day volatility and disrupted financing; daily cash flows above this amount are potentially available for investment.
- Research investment options; focus on reverse repo or collateralized term deposits where possible.
- Agree internal responsibilities: forecasting, decision-making, running the investment process, monitoring, maintaining, and repaying the asset; establish processes, procedures, and internal controls.
- Define investment process and timeline (example: auction with preapproved panel); prepare legislation or regulations as necessary.
- Discuss with central bank and securities regulator; agree mode of operation, operational interactions, and services; reflect in MoU or service-level agreement.
- Prepare consultation document to market participants and follow up with bilateral discussions and workshops.
- Prepare contractual documentation (e.g., GMRA) and preferred counterparties.
- Test software and systems with dummy transactions.

### Conclusions and capacity development priorities
- Investing temporary surplus cash in the banking system is intrinsic to modern cash management and can yield cost savings and wider financial policy benefits if risks are well managed.
- The global financial and COVID-19 crises highlight the importance of liquidity risk, financing continuity plans, and a developed local money market.
- Active cash management contributes to money market and government bond market development through repo and secured instruments, increasing liquidity and market infrastructure.
- Finance ministries and treasuries should address capacity development systematically through actionable steps: formalize policies, build operational capacity, establish governance (CCC), coordinate with central bank, and implement risk management and performance monitoring.

*International Monetary Fund | How to develop a framework for the investment of temporary government cash surpluses (December 2020).*

### 1. Introduction ........................................................................................................

### HOW TO DEVELOP A FRAMEWORK FOR THE INVESTMENT OF TEMPORARY GOVERNMENT CASH SURPLUSES

### Introduction
- Primary objective of cash management: ensure government can execute the budget smoothly and meet obligations as they fall due.
- Secondary objective often added: achieve a return on cash balances within prudent risk limits.
- Prudence is critical during heightened uncertainty, for example the COVID-19 pandemic.
- Cash management arises from intra-year timing mismatches between revenues and expenditures; responses include short-term borrowing for shortfalls and investing temporary surpluses in short-term assets.
- Poor cash planning leads to high cash buffers or cash rationing, both inefficient and expensive.
- Effective cash planning reduces unremunerated idle cash balances held by the ministry of finance (MoF) or other agencies and, if volatility is reduced, allows operation with a lower average cash buffer.
- COVID-19 increased unpredictability in borrowing requirements, interest rate volatility, market liquidity concerns, and cash flow volatility, making cash investment management more critical.
- Note scope and audience:
  - Discusses identifying and investing surplus government cash, options, requirements, challenges, and institutional/governance/risk/coordination issues.
  - Companion How-To-Note covers identifying the minimum cash buffer required.
  - Targeted to emerging market economies and middle- and lower-income countries with well-managed treasury functions and forecasting ability.
  - Frontier states with chronic cash shortages should prioritize reliable cash forecasting and volatility reduction; their investment options are likely limited to term deposits with the central bank or commercial banks.

### Identifying Cash Surpluses
- Definitions:
  - Cash surplus: excess of cash over what is required to meet day-to-day payment obligations.
  - Surplus types:
    - Structural: surplus to the needs of in-year cash management.
    - Temporary: intra-year phenomenon with a short time horizon.
- Distinction guidance:
  - Degree of persistence is a useful indicator: if managers can maintain the cash buffer and invest cash for more than three to six months, the shock is more likely permanent.
  - Analysis of underlying factors generating the surplus helps validate whether shock is permanent or transitory.
- Management implications:
  - Temporary surpluses → invest in short-term instruments.
  - Structural surpluses → should be identified and managed separately (e.g., long-term savings funds, stabilization funds, cash/near-cash reserve funds).
  - Investment horizon for cash managers typically rarely exceeds three to six months; structural surplus management involves different criteria, personnel, and governance.

### Building a Cash Buffer
- Purpose: minimum level of cash balances (usually in the TSA) to meet day-to-day cash requirements at all times.
- Characteristics:
  - Buffer usually held in cash at the central bank for security and liquidity.
  - Buffer should be mostly available for immediate use.
- Disclosure considerations:
  - Whether to disclose buffer to markets is a policy choice.
  - Publication signals prudence but risks undermining market operations or credibility if targets are missed.
  - Markets can estimate actual cash balance from published central bank balance sheet even if buffer not published.
- Buffer investment:
  - Some tranche of buffer may be investable in slightly longer-term assets (e.g., term deposits breakable on penalty), but should be cautious.
  - Large buffers may need inclusion within asset-liability management analysis underlying the debt management strategy.

### Cash Reserve Fund
- Purpose: use cash over and above the buffer but not associated with daily fluctuations or short-term market disruption risk.
- Uses:
  - Buy back debt if cost-effective and improves debt portfolio characteristics.
  - Held as stabilization or reserve fund to be run down over the cycle or used against severe shocks (e.g., banking collapse, pandemic).
- Characteristics:
  - Invested in relatively short-term assets.
  - Managed under different governance from short-term cash management.
  - Cash managers typically responsible only for short-term investments used in cash flow smoothing (investment horizon rarely longer than three to six months).
- Role in money market development and liquidity:
  - Reserve funds are intermediate between buffer and longer-term funds and sensible where structural surplus likely to be run down in medium term or money market depth is uncertain.
  - Funds can be invested in a range of money market assets unless liquidity management or credit risk reasons require central bank term deposits.
- Example (UK DMO):
  - In 2000 proceeds from sale of third generation (3G) radio spectrum licenses were nearly £20 billion ($25 billion) more than budgeted.
  - Government held most additional proceeds in financial assets to be run down over the following three years.
  - DMO managed assets in the money market: mostly repurchase agreements, plus certificates of deposit and commercial paper.
  - A three-month money market rate was set as a performance benchmark.
  - Fund performance was monitored and internally accounted for separately from normal cash management operations.
  - Internal safety net arrangements allowed arm’s length access by cash managers if required.

### Investment Options
- Investment of surplus cash is an intrinsic part of modern cash management and should be embedded in cash managers’ responsibilities.
- For day-to-day cash management, options are more limited; investments will usually be in domestic currency.
- Currency of investment:
  - Investments intrinsic to cash management will usually be in domestic currency.
  - Credit quality and liquidity are paramount; there should be no risk to principal.
  - Buffers should be held in highly liquid form; maturity of investments geared to cash flow profile.
  - Meeting daily target balances typically requires overnight operations and longer-term investments to build cushions for year-end surges or future bond redemptions.
  - Moving average targets or target ranges may be implemented with slightly longer maturities in some countries.
- Investment instruments and maturities:
  - Ideal money market investment: does not change much in value, low default risk, convertible to cash at any time without significant loss of principal.
  - Callable investments (e.g., term deposits breakable on request with some interest penalty) provide safeguards.
  - For countries with limited intervention frequency ("rough tune"), slightly longer maturities may be used.

### Investment Risks
- Key risks to assess and manage: credit risk, liquidity risk, market risk (especially interest rate risk), legal and operational risks.
- Practical emphasis:
  - Credit and liquidity risks are of primary importance to cash managers.
  - Market risk matters less if most maturities are shorter than one month, though interest rate volatility encourages shorter maturities.
- Risk tolerance and trade-offs:
  - Government risk tolerance and risk-return trade-off determine appropriate instruments.
  - General prioritization when investing cash: safety first, then liquidity, then return.
- Role of the cash buffer:
  - The buffer is protection against liquidity risk if adequately calculated and maintained in highly liquid form.
  - Surplus cash above the buffer should be available for short-term investment with maturities reflecting residual forecast uncertainty or financing availability.
- Special circumstances:
  - Managing liquidity risk is especially important during times of great uncertainty (examples: global financial crisis, COVID-19).
  - Where appropriate, investments may be made in the central bank as term deposits for liquidity or credit considerations.

*Source: IMF How-To Note htnea2020003 — Introduction and early sections on identifying and investing temporary government cash surpluses.*

### Box 1. The Cash Reserve Fund in the UK

### Box 1. The Cash Reserve Fund in the UK

### Key risks for investing surplus cash
- Liquidity risk: inability to convert an investment into cash prior to maturity without an unacceptable loss of principal; market breadth and depth affect the ability to buy/sell significant volumes without material price impact. The most liquid money market instruments are those that are highly marketable and have the shortest maturity.
- Credit risk (default risk): possibility that the issuer or counterparty will fail to repay principal and/or interest in full and on time. Mitigation: diversify assets and counterparties, establish permissible investments of high credit quality, and/or demand high-quality collateral.
- Market risk: devaluation of an asset from changes in market conditions, particularly interest rates; longer maturities increase market valuation variation. Mitigation: invest in short maturities; interest rate futures or options require specialized expertise.
- Legal risk: contracts not legally enforceable or misunderstanding of law/regulation; mitigation: clearly documented, legally enforceable processes (for example, the Global Master Repo Agreement (GMRA)).
- Operational risk: failures in processes, people, systems, or external events (power cuts, earthquakes, terrorist attacks); mitigation: segregation of duties (front/middle/back office), clear authorization procedures, integrated secure systems with audit trail, business continuity and disaster recovery plans, back-up systems, cyber protections.
- Settlement risk: counterparty fails to fulfill its part of the contract (e.g., delivers a bond but does not transfer funds); mitigation: effective custody arrangements, accurate timely records, dematerialization of instruments.

### Credit risk assessment approaches and limits
- Three main choices for credit risk assessment:
  - Relying on external assessment (credit rating agencies). Set exposure limits so that the product of the risk of default (specified for the rating) and the risk of loss in default is the same across banks. Note: market-implied ratings exist but data may be costly.
  - Building an internal assessment process similar to rating agencies, reflecting local conditions; requires measuring financial strength and qualitative factors but is time consuming and resource intensive.
  - Drawing on assessment methodology used by the central bank or prudential regulator; confine investment to higher-quality banks locally to ensure competition and aggregate demand. International ratings can benchmark rankings if available.
- Practical limits and guidance:
  - Avoid concentration with one counterparty; set a maximum exposure limit to any one bank.
  - Initial individual limits may be set somewhat arbitrarily for simplicity and flexibility, but the aggregate must exceed likely investment needs and be adjusted if low-risk opportunities are missed.
  - Extend credit risk analysis beyond core ratings by monitoring CDS spreads or share prices where available for quicker market signals.
  - Maintain a level playing field between private and publicly owned banks; government exposure to failure is symmetric.

### Investment objectives and horizon
- Primary objectives: preserve principal and retain liquidity; avoid altering policy to avoid or reduce negative yields by accepting greater risk or loss of liquidity.
- Typical investment horizon: will depend on market and cash flow profile, typically will not exceed 30 days.
- Money market instruments (maturities less than one year): T-bills, repurchase agreements (repos) and reverse repos, bank deposits (and some certificates of deposit), interbank loans, money market mutual funds.
- For many emerging market and developing economies: repos and deposits with the central bank or commercial banks are particularly relevant.
- For low-income countries with undeveloped money markets: options may be limited to central bank or commercial bank deposits.

### Repos and reverse repos: characteristics and safeguards
- Repo definition: sale of a security by a “borrower” to a “lender” with agreement to repurchase at a specified date and pre-agreed price; the price difference reflects the transaction interest rate. Treated as a collateralized loan though legally a change of ownership.
- Typical availability: generally up to three months, though in less developed markets may be no more than one week or only overnight. Interest may be fixed or variable.
- Collateral: most repos use government or central bank securities; other widely traded instruments may be used.
- Specific risks and mitigants:
  - Mark-to-market and remargining: collateral should be marked-to-market daily; request or return additional collateral as necessary. Where burdensome, over-collateralization (haircut) is used.
    - Example haircuts: may be small, say, 2 or 3 percent (margin rates in Australia for all repos are 2 percent); in nascent markets haircuts may be up to 25 percent.
  - Counterparty quality: restrict transactions to high-quality counterparties (recognized primary dealers and commercial banks with high credit ratings) and require GMRA or local equivalent.
  - Legal risks: interactions with local insolvency law and tax recognition of repo may require legislative changes.
  - Custody and settlement: independent custodian should hold collateral; adopt delivery versus payment (DvP); advanced systems can manage repo lifecycle and remargining (tri-party repo).
  - Market practice: use competitive processes among GMRA signatories to establish best market rate; bilateral transactions possible in developed transparent markets.
- Preference: if the market is sufficiently liquid, reverse repo should be the preferred instrument—quick, flexible, and secure; central bank can act as agent in initial capability-building.

### Term deposits at commercial banks
- Demand deposits: extremely liquid, negotiable at par value.
- Term deposits: usually earn higher interest (assuming an upward sloping yield curve) but may carry penalties if terminated early.
- Collateral: assess creditworthiness and take collateral to reduce credit risk; collateral treated as a pledge rather than owned (legal form differs from repo).
- Pricing and allocation practices:
  - Term deposits often lack transparent market prices; competitive processes help (occasional tenders or prequalified panel with master agreement).
  - Master agreement should include collateral understandings and handling for each transaction.
  - Ensure level playing field across publicly/private and foreign/domestic banks, considering regulatory status.
  - Country practices: Chile and China periodically auction deposits to a prequalified panel requiring collateral (usually government bonds); Chile also auctions reverse repo investments. Spain organizes tenders where the relevant variable is the spread against a money market comparator rate.

### Deposits at the central bank
- General guidance: surplus cash balances should not normally be invested at the central bank because that can undermine cash flow smoothing benefits.
- Exception: when there is a structural surplus of liquidity in the domestic market (for example, from FX purchases to limit exchange rate appreciation), the central bank may ask the Ministry of Finance to invest surplus government cash with it to avoid further additions to banking sector liquidity.
  - Under these circumstances, the MoF should seek remuneration at the applicable risk-free interest rate.
- Practical note: in many developing countries and some developed countries, government deposits may be unremunerated or remunerated at much lower rates.

### Operational practice example: Russian Federation
- Evolution: treasury investment role expanded since 2005 from bank deposits toward repo (reverse repo lending surplus cash); treasury can lend surplus cash to finance budgets of subjects of the Russian Federation and municipalities in loans up to 90 days.
- Credit risk controls for deposits:
  - Participation in a mandatory deposit insurance scheme with a universal license from the Bank of Russia.
  - Adequate capital base.
  - Investment grade rating of A– or higher on the national rating scale.
  - No history of delays in repayment of the treasury’s deposits.
- Repo collateral requirement: government securities.
- Additional authority: the treasury can directly debit a lending institution’s arrears.
- Outcome: large sums invested with substantial interest earnings for the treasury and the annual budget.

*Source: IMF staff.*

### Box 3. Surplus Cash Investment by the Federal Treasury in the Russian Federation

### Box 3. Surplus Cash Investment by the Federal Treasury in the Russian Federation

### Remuneration of government deposits and market analogues
- Governments and central banks should use a market-related rate to remunerate government deposits to provide appropriate economic incentives to both parties.
- A market-related rate is described as "the rate that the MoF must forego by responding to the central bank’s request and it is the rate that the central bank would have to pay if it was forced to drain cash through OMOs."
- Legal constraints (for example, a prohibition in central bank law to remunerate government deposits) sometimes prevent remuneration; the usual justification is that remuneration will increase the central bank’s costs, potentially reducing dividends to the government or adding to a central bank deficit that the government would cover.
- Possible market analogues:
  - For call deposits: link to the central bank’s policy rate or local interbank overnight rates.
  - For term deposits: relate to repo rates paid by the bank for similar terms, or to rates earned by the central bank in its OMOs.

### Less commonly used instruments, characteristics, and risks
- Certificate of Deposit (CD)
  - Time deposit documented by a certificate specifying amount, maturity date, and interest rate.
  - When issued in negotiable form, CDs can be sold in the secondary market.
  - Investors face interest rate risk but less liquidity risk than holders of nonnegotiable CDs.
  - Prior redemption of CDs carries penalties.
  - A negotiable CD cannot be collateralized to protect the investor from credit risk because ownership can change; therefore, the creditworthiness of the financial institution is a prime concern.
- Money Market Mutual Funds (MMMFs)
  - Invest in other money market instruments with slightly longer maturity (up to 60 days).
  - Yields reflect short-term interest rates.
  - Regulated by securities regulators with strict guidelines (maximum maturities, diversification requirements, liquidity tranches); these constraints have been tightened since the financial crisis.
  - While relatively safe for short-term cash, many MMMFs invest a portion in riskier securities that may turn illiquid during market stress.
  - MMMFs are less common outside of Europe and the US and are less suitable for cash managers.
- Commercial paper
  - Promissory notes (unsecured debt) issued by highly rated banks and some large nonfinancial corporations.
  - Primarily used by corporations to finance receivables; most paper is sold on a discount basis, though some issuers offer interest-bearing notes.
  - May be backed by an unused bank credit line to refund the notes if the issuer cannot roll over at maturity.
  - Liquidity depends on the issuer’s willingness to repurchase; instrument is unsecured so issuer creditworthiness is key.
  - Requires constant market monitoring because underlying credit quality can deteriorate rapidly; unattractive for government cash managers.

### Use of surplus cash for buy-backs
- Potential benefits:
  - May help cash flow smoothing if a bond close to maturity is targeted.
  - Can improve liquidity in the T-bond market if linked with a conversion offer.
- Disadvantages:
  - Can be expensive, particularly if longer-term bonds are targeted.
  - Can reduce liquidity if remaining bond volumes become insufficiently large.
  - Means the cash is no longer available for the buffer.
- Conclusion: Buy-backs are usually better considered as a debt management tool—in the context of the annual borrowing plan or debt management.

### Country practices and program examples
- United States
  - Treasury Tax and Loan (TTL) program aimed to stabilize the Treasury General Account (TGA) at the Federal Reserve by leaving excess tax-receipt cash in the banking system until needed.
  - TTL accounts were held at designated financial institutions; deposits paid a market-related interest rate and were collateralized.
  - Term Investment Option program ensured a market-related rate on longer-term deposits via collateralized deposits auctioned through a competitive process with terms of two days to several weeks.
  - The treasury could also make overnight investments in reverse repo against treasury collateral.
  - After the financial crisis, changes in cash flow volatility and the Federal Reserve’s willingness to pay interest on the TGA gave the treasury an incentive to hold more cash in the TGA, and the TTL program was closed, at least on a temporary basis (2012).
- South Africa
  - Nontax revenues flow from departmental commercial bank accounts to individual departmental accounts at the Reserve Bank; departments meet spending commitments from these accounts.
  - Daily net flow is zero-balanced with the main Exchequer account; all accounts are subaccounts of the TSA, which has a pyramidal structure.
  - Commercial banks collect and pool tax revenue in Tax and Loan Accounts and transfer revenue as required to the Exchequer account daily to clear debit balances.
  - Tax and Loan Accounts are held in high-quality banks, are not collateralized, and pay a market-related interest rate to smooth cash flows across the TSA while ensuring interest is earned on temporary surplus balances.
- Colombia
  - Conservative investment policy: domestic currency excess liquidity is invested in interest-bearing deposits at the central bank (Banco de la República) and, on occasion, in treasury bonds (TES).
  - The central bank enables treasury placements in interest-bearing deposits with terms of up to 730 days.
  - Rates offered follow a curve: very short-term rates linked to interbank rates; short- and medium-term deposits linked to rates in the fixed-income securities market.
  - For TES, the treasury invests by direct purchases on securities trading systems, acting as any other agent in the secondary market.
  - Excess liquidity in dollars is invested in interest-bearing accounts and in time deposits in commercial banks through the central bank, which is the custodian of the government’s pesos and US dollar accounts.

*Source: IMF staff.*

### Box 5. Colombia: Remuneration of Deposits with the Central Bank

### Box 5. Colombia: Remuneration of Deposits with the Central Bank

### Investment Policy Statement
- Government objectives for investing financial assets should be formalized in a written investment policy statement specifying asset allocation choices, risk tolerance, and rate of return objectives.
- The policy should be written and approved by the relevant minister, governing board, or committee.
- Operational details to specify:
  - Authority to invest excess cash, identification of decision-making responsibilities, segregation of duties, and individual authorization limits.
  - Investment policy scope: normally limited to highly liquid, high-quality securities, deposits with eligible financial institutions (preferably collateralized), and repos for treasuries building capabilities.
  - General objectives in terms of safety, liquidity, and yield, and any hierarchy among them.
  - Risk policies covering market, credit, liquidity, legal, and operational risks, including:
    - Permissible investments: types, magnitudes, and tenors.
    - Limits on exposures to credit risk, including requirements for diversification and individual and global limits on financial institution exposures.
    - Requirements for diversification of assets.
    - Collateral management frameworks and restrictions on eligible collateral.
    - Manager selection and monitoring when outsourcing operational processes or investment decision-making.
  - Reporting on performance and other issues, including audit processes, regular investment appraisal, and benchmarking against an appropriate market index with weekly or monthly reports.
  - Process for amending the policy, with review by the governing body at least annually and more frequently when warranted.
  - Formal evaluation and appraisal of the policy at least once a year by the board or investment committee or after major events.
  - Policy on exceptions: minor exceptions may be approved by the treasurer; major exceptions require board or committee approval.
- Operating procedures should specify steps from identifying funds to selecting instruments and counterparties, to settlement and monitoring through maturity.

### Money-Market Instruments: Risks and Their Management (high-level findings)
- Reverse Repos:
  - Interest-rate Risk: Low, increases with maturity
  - Credit Risk: Low
  - Liquidity Risk: Medium: repos are rarely redeemed before maturity but may be able to borrow against the repo collateral
  - Risk management: Marking-to-market collateral; Overcollateralization; Repo counterparties banks with high credit rating; Use of Master Repo Agreement
- Negotiable CDs:
  - Interest-rate Risk: Low, increases with maturity
  - Credit Risk: Medium to high
  - Liquidity Risk: Low, increases with maturity and if CDs’ secondary market is thin
  - Risk management: Invest in CDs of banks with high credit rating (prequalified); Diversification; Individual and global limits on financial institution exposures
- Nonnegotiable CDs:
  - Interest-rate Risk: Low, increases with maturity
  - Credit Risk: Medium to high
  - Liquidity Risk: High
  - Risk management: Invest in CDs of banks with high credit rating; Marking-to-market collateral; Overcollateralization
- Term-deposits (interest-bearing demand deposits):
  - Interest-rate Risk: Low, increases with maturity unless variable rate
  - Credit Risk: Low with collateral; medium to high without collateral
  - Liquidity Risk: Medium, depends if deposit can be broken early
  - Risk management: Collateralization; Invest in banks with high credit rating (prequalified); Diversification: individual and global limits on financial institution exposures
- Money market mutual funds:
  - Interest-rate Risk: Medium, depends on style of fund
  - Credit Risk: Medium to high
  - Liquidity Risk: High
  - Risk management: High-quality funds only
- Commercial paper:
  - Interest-rate Risk: Low, increases with maturity
  - Credit Risk: High
  - Liquidity Risk: High
  - Risk management: Very high-quality issues only; Diversification
- Deposits at the central bank:
  - Interest-rate Risk: Low, increases with maturity
  - Credit Risk: None
  - Liquidity Risk: Low
  - Risk management: Low risk, but a market rate of interest should be paid, and services should be remunerated

### Coordination with Debt Management
- Cash and debt management functions should be closely coordinated or integrated; institutional, governance, and decision-making requirements are similar for cash investment and debt transactions.
- Debt management strategy influences financing decisions (internal/external, short/long-term, fixed/floating-rate, retail/wholesale) and investment of financial assets.
- Active cash management can protect a stable T-bond issuance program by using T-bills and other money market instruments to smooth cash flows.
- Examples of institutional practice: historical treasury role in investing surpluses persists in some countries; Mexico and the Russian Federation cited as examples; Chile has legacy legislation leaving investment of surpluses with the budget directorate (DIPRES).

### Decision Making and Cash Coordination Committee (CCC)
- Establish a Cash Coordination Committee (CCC) to bring together treasury, budget, debt, and macro-fiscal functions to make integrated borrowing and lending decisions.
- CCC roles:
  - Review cash flow outturns and compare with forecasts.
  - Review cash flow forecasts for the period ahead.
  - Decide or recommend actions to ensure cash adequacy and cost-effective use of surpluses.
- Consider a technical-level committee to support the CCC; invite the central bank as an observer if necessary and tax authorities for forecasting perspectives.
- After CCC decisions, front office executes transactions within agreed parameters.
- Concentrate market investment and borrowing functions in a single front office unit to ensure coordination and a single point of contact with the market.

### Interaction with the Central Bank
- Establish coordination mechanisms and a Memorandum of Understanding covering:
  - Joint program for money market development.
  - Respective operations: investments, T-bill issues, or OMOs.
  - Times of day for operations and timing/forms of announcements.
  - Information exchanges.
- Central bank should be informed of parameters of expected operations, for example, the target end-of-day balance.
- Address central bank concerns about treasury competence, objectives, or complications to monetary policy; well-managed cash benefits monetary operations with smoother cash flows.

### Internal Organization (Front/Middle/Back Office)
- Vertical separation of front, middle, and back offices is important for specialization and operational risk control:
  - Front office: monitor markets, run tenders, make investments (such as reverse repos).
  - Middle office: develop policies and strategies for debt and cash; create risk management framework; report on policies, operations, and performance; lead in preparing/updating cash flow forecasts and liaise with front office.
  - Back office: manage collateral/pledges, daily valuation and remargining, reconciliation, settlement, and servicing (unless contracted out).
- Integration or close coordination of debt and cash management functions is recommended.

### Other Operational Requirements and Legal Framework
- MoF (and treasury or DMO as necessary) must have authority to borrow short term to meet cash flow requirements and to invest surplus balances in financial markets or as term deposits in the central bank.
- Authority should not preclude borrowing or lending for cash flow smoothing across the end of a financial year.
- Legal documents should identify and approve risk parameters rather than rigidly specify available instruments to retain flexibility.
- Explain government intentions for cash management to the market before policy introduction to avoid misunderstandings and solicit feedback.
- Staffing and systems:
  - Additional staff may be required for market interaction, cash flow forecasting, and transaction processing; continuing staff needs likely modest though set-up costs exist.
  - Training is important to embed market practices and internal controls.
  - Initial systems can use Excel for few transactions; auction of deposits or repo ideally needs an electronic system integrated with a database and back office processing.
  - When transactions grow, a fully integrated transaction processing system with front, middle, and back office capabilities is preferred.
- Financing continuity plans should complement business continuity plans to address severe market disruptions.

### Performance Monitoring
- Investment policy should include performance evaluation; measuring investment performance is strongly recommended but difficult.
- Assess performance of structural fund managers against chosen benchmarks; assessing cash managers is more difficult.
- Performance measures should reflect cash management objectives:
  - Measure whether cash is available to meet commitments.
  - Measure avoidance of central bank overdraft facility or commercial bank credit line use.
  - Assess returns against a counterfactual (e.g., “do nothing” option such as return on call deposits); example: Agence France Trésor target to earn interest on cash balances on average of at least EONIA for short-term deposits and overnight reverse repo, and EONIA less 2 basis points for reverse repo longer than 1 day.
  - To assess smoothing, track stability of balances or deviation with respect to a range.
- Some countries have abandoned problematic performance measures influenced by external factors not under cash managers’ control.

### Conclusions and Capacity Development Steps
- Investing temporary surplus cash in the banking system is intrinsic to modern cash management and can yield cost savings and wider financial policy benefits if risks are well managed.
- The global financial and COVID-19 crises highlight the importance of liquidity risk and the need for financing continuity plans and a developed local money market.
- Active cash management contributes to money market and government bond market development through use of repo and secured instruments, increasing liquidity and market infrastructure.
- Finance ministries and treasuries should address capacity development systematically through actionable steps focusing on the areas described above.

*Source: htnea2020003 - Box 5. Colombia: Remuneration of Deposits with the Central Bank*

### 1. Identify the target cash buffer: the cash that is

### 1. Identify the target cash buffer: the cash that is

### Key steps to establish and operationalize a cash buffer and invest excess cash
- Identify the target cash buffer: the cash that is always available to meet residual day-to-day volatility unexpected flows or disrupted financing. Daily cash flows above this amount are potentially available for investment in longer-term assets. When the surpluses are persistent or structural, consider the establishment of a separate fund—whether a cash reserve, stabilization, or wealth fund.
- Research the investment options: as necessary consult with the central bank, primary dealers, and others. Where possible, focus on reverse repo or otherwise collateralized term deposits.
- Agree on internal responsibilities:
  - forecasting and hence recommendations as to amount and maturity of investments for risk management;
  - decision-making;
  - running the investment process; and
  - monitoring, maintaining, and, in due course, repaying the asset.
  - Establish processes, procedures, and internal controls.
  - Probable new functions that will need to be specified and staffed or contracted will be credit risk assessment and collateral management.
- Define the investment process and timeline: for example, by auction with a preapproved panel of banks. Identify any internal systems needs. Prepare any legislation or other regulations, as necessary.
- Discuss with the central bank (and, as necessary, the securities regulator): agree on the mode of operation, flows of information, operational interactions, and any services supplied by the bank. Reflect these items in the memorandum of understanding or service level agreement.
- Prepare a consultation document explaining the intentions to the market, the policy objective, the benefits that flow from it, and the intended mechanisms: follow up with bilateral discussions, workshops, and other vehicles, as necessary.
- Prepare contractual documentation: for example, the GMRA for repo and come to agreement with preferred counterparties.
- Test software and other systems with dummy transactions.

### Practical operational considerations emphasized
- Favor collateralized instruments (reverse repo, secured term deposits) where possible.
- Use auctions and prequalified panels of counterparties to structure access and competition.
- Establish explicit internal risk-management roles (credit risk assessment, collateral management).
- Document operational relationships with the central bank via MoU or service-level agreement.
- Communicate intentions to market participants through a consultation document and follow-up engagement.

### Performance measurement and country practices (Annex A highlights)
- Australia:
  - introduced a 91-day rolling average for the closing balance of the Official Public Account (OPA) (the TSA at the central bank).
  - required to maintain this moving average below the approved upper limit of $1.5 billion; limit removed in February 2017 and replaced by cash management principles.
  - objectives include minimizing cost of funding and carrying cost of holding cash balances and avoiding use of the overdraft facility provided by the RBA.
  - tracks contribution of each major portfolio component to overall change in total debt service costs; term deposits are a major component contributing to reduced debt service costs.
- United Kingdom (UK DMO objectives and performance approach):
  - Objective 1: supply sufficient cash each day to enable the government to meet its payment obligations. This is fundamental and unconditional.
  - Objective 2: operations should not conflict with Bank of England operational requirements for monetary policy implementation; DMO notifies BoE in advance of weekly OMOs of the target cumulative weekly balance.
  - Objective 3: avoid undermining the efficient functioning of sterling money markets; minimize impact of individual daily flows while ensuring competitive prices.
  - Objective 4: maintain a system where costs and risks are transparent, measured, and monitored; performance assessed by comparing actual net interest paid and received with the cost of funds.
  - Objective 5: maintain a credible market reputation via openness, transparency, consistency, and active dialogue with market participants.
  - A proposed measure of value added against a passive benchmark was considered in 2004–05 but ultimately dropped.
- Canada:
  - primary objective: hold the lowest level of domestic cash balances while ensuring availability to meet daily requirements with an appropriate margin for uncertainty.
  - holds liquid financial assets sufficient to cover at least one month of net projected cash flows (including debt servicing or refinancing needs).
  - Bank of Canada manages the Receiver General Consolidated Revenue Fund (TSA); RG balances prudentially maintained to meet operational objective of five business days of non-debt cash requirements.
  - excess cash invested with private-sector counterparties through a competitive auction process typically held twice each business day; a large portion of deposits are fully secured (repos).
  - department of finance monitors:
    - the trend and level of cash balances over the course of the year, measured against previous months, quarters, and years;
    - the cost to the government of maintaining cash balances, measured as the net return on the balances (difference between return on auctioned balances and weighted average yield paid on T-bills);
    - the proportion of cash balances invested with private-sector counterparties on a fully secured basis.

### Indicators and metrics for cash management performance (examples)
- rolling averages of TSA balances (e.g., 91-day rolling average in Australia);
- explicit upper limits on rolling averages (e.g., $1.5 billion in Australia historically);
- operational objectives expressed in business days of non-debt cash requirements (e.g., five business days in Canada);
- net return on balances compared to benchmark yields (Canada: return on auctioned balances minus weighted average yield on T-bills);
- proportion of balances invested on a fully secured basis.

### Tools for reducing carrying costs and managing risk
- Use of term deposits and reverse repos to reduce debt service costs.
- Benchmarking portfolio changes against a set benchmark portfolio to measure contribution to debt service costs.
- Active cash management frameworks with explicit quantitative liquidity, interest rate, foreign exchange, and credit risk limits (UK DMO example).
- Preference for secured/ collateralized instruments to limit credit risk exposure.

### Country practices in instruments for investing excess cash (Annex B selected entries)
- Argentina: Fixed-term placements at Banco de la Nación Argentina (BNA).
- Australia: Deposits at the central bank; historically CDs; since 2012 investments in very low remuneration instruments and NCDs have ceased.
- Canada: Mostly deposits; auctions twice a day through Bank of Canada; not all collateralized.
- Chile: Domestic term deposits, repurchase agreements via auctions with collateral usually government bonds; auctions of reverse repo investments.
- China: Periodic auctions of term deposits up to 90 days to prequalified banks; requires collateral, usually government bonds.
- Colombia: Interest-bearing deposits at central bank; occasionally treasury bonds; in dollars, interest-bearing accounts and time deposits in commercial banks in the US.
- France: TSA deposits at Banque de France at contractual rates varying with amount; overnight market via unsecured loans and reverse repos.
- Hungary: Reverse repos with eligible government securities collateral; tenors one day to one week; repo by multiple price auction.
- Mexico: Wide set of instruments including government securities, deposits at Banxico, securities issued by Banxico, reverse repos denominated in DX or FX via Banxico and other institutions.
- Perú: Demand and term deposits in the Central Bank of Reserve of Peru (BCRP) and auctions of term deposits in the financial system.
- Russian Federation: deposits and currently mostly reverse repos.
- South Africa: Interest-bearing cash balances with Reserve Bank and commercial banks.
- Spain: Term deposits; has organized tenders where variable is spread against money market comparator rate.
- Sweden: Central bank certificates and deposits; may invest in covered mortgage bonds, repos in covered mortgage bonds, tri-party repos—within strong risk management.
- The Netherlands: Reverse repos; may place surplus funds at DNB with at least 5 working days’ notice; DNB reimburses at a rate equal to the deposit interest rate on the largest part of the balance.
- Turkey: Deposits; capacity to invest in reverse repos up to 30 days by auction.
- United Kingdom: Reverse repos; very liquid market particularly for tenors less than 30 days.
- United States: Collateralized deposits historically under TTL scheme; as of 2011, excess cash left with Federal Reserve in overnight deposits.
- Vietnam: Term deposits in commercial banks typically one- to three-month range; capability to invest in reverse repo being developed.

*International Monetary Fund | How to develop a framework for the investment of temporary government cash surpluses (December 2020).*

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_Source: https://www.imf.org/-/media/files/publications/howtonotes/2020/english/htnea2020003.pdf_
