## THIRD PROGRESS REPORT ON INCLUSION OF ENHANCED CONTRACTUAL PROVISIONS IN INTERNATIONAL SOVEREIGN BOND CONTRACTS

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---

### INTRODUCTION
- The IMF Executive Board endorsed in October 2014 the inclusion of:
  - a modified pari passu provision that explicitly excludes the obligation to effect ratable payments; and
  - an enhanced CAC with a menu of voting procedures, including a “single-limb” aggregated voting procedure (with a voting threshold of 75 percent of the aggregated outstanding principal of all affected bond series and a “uniformly applicable” condition), a two-limb aggregated voting procedure, and a series-by-series voting procedure.
- Directors supported an active role for the IMF in promoting inclusion of these clauses. The IMFC and the G20 called on the IMF to promote use of such clauses and report on their inclusion.
- This paper provides an update on inclusion and on the outstanding stock of international sovereign bonds as of September 30, 2017.

### ENHANCED CONTRACTUAL PROVISIONS — COLLECTIVE ACTION CLAUSES (CACs)
- Sample and coverage:
  - Approximately 350 international sovereign bond issuances since October 1, 2014, totaling approximately US$ 400 billion (information as of September 30, 2017).
  - Sample excludes: euro area sovereign issuances, China’s domestic issuances under Hong Kong law, and GDP warrants; the sample is based on the Perfect Information database.
- Uptake of enhanced CACs:
  - Approximately 87 percent of the nominal principal amount of new issuances have included the enhanced CACs (as of September 30, 2017), compared with 85 percent as of end-October last year.
  - From end-October 2016 to end-September 2017, 10 percent of issuances did not include enhanced CACs.
- Issuers not incorporating enhanced CACs (from end-October 2016 to end-September 2017):
  - Under New York law: Lebanon, Korea and the Philippines.
  - Under English law: Azerbaijan, Hungary, Malaysia (sukuk), and Poland.
  - Other non-inclusions: Hungary under Chinese law, Indonesia under Japanese law.
- Governing law breakdown of new issuances since October 2014 (in percent of total issuances):
  - English: No enhanced CACs 6.5; Enhanced CACs 41.3; Total 47.8.
  - New York: No enhanced CACs 6.1; Enhanced CACs 45.8; Total 51.9.
  - Others: No enhanced CACs 0.3; Enhanced CACs 0.0; Total 0.3.
  - Total: No enhanced CACs 12.9; Enhanced CACs 87.1; Total 100.0.
- Note: Formulation under English and New York law generally track ICMA model clauses.

### ENHANCED CONTRACTUAL PROVISIONS — PARI PASSU PROVISION
- Inclusion patterns:
  - The modified pari passu provision is largely incorporated as a package with enhanced CACs.
  - Since end-October last year, all issuances that included enhanced CACs also included modified pari passu provisions, except: Sri Lanka under New York law; and Bahrain, Indonesia (sukuk), Pakistan and Russia under English law.
- Some issuers that did not include enhanced CACs have included modified pari passu clauses (examples): Azerbaijan (under English law), Lebanon (under New York law), Hungary and Poland (under Chinese law).
- Euro area sovereigns have generally not included modified pari passu clauses.
- Issuances since October 2014 by modification status (in percent of total issuances):
  - No modified pari passu: No enhanced CACs 8.7; Enhanced CACs 6.6; Total 15.2.
  - Modified pari passu: No enhanced CACs 4.2; Enhanced CACs 80.6; Total 84.8.
  - Total: No enhanced CACs 12.9; Enhanced CACs 87.1; Total 100.0.
- All modified clauses specifically disavow the obligation to make ratable payments.

### ENHANCED CONTRACTUAL PROVISIONS — MARKET IMPACT
- Empirical observations:
  - Inclusion of enhanced CACs does not have an observable pricing effect in primary or secondary markets, consistent with prior reports.
  - For enhanced CACs, analysis is limited to country case studies due to scarcity of data points.
  - Over the last twelve months, yields at issuance of bonds with enhanced CACs are aligned with relevant points on their sovereign curves for both investment grade and noninvestment grade countries.
  - Secondary market checks for two major issuers at recent market lows and highs showed that bonds with enhanced CACs did not display noticeably higher yields, even during times of stress.
- Caveats:
  - Multiple market and fundamental factors affect pricing; more systematic analysis is necessary to draw definitive conclusions.
  - If investors expect higher recoveries on bonds without CACs, pricing divergence might be greater when the probability of default rises.

### ENHANCED CONTRACTUAL PROVISIONS — OUTSTANDING STOCK
- Change in outstanding stock composition:
  - Share of international sovereign bonds that include enhanced CACs grew from 18 percent of total outstanding stock as of end-October 2016 to 27 percent of total outstanding stock as of end-September 2017.
  - Large issuances by Saudi Arabia and Argentina incorporating enhanced CACs drove the change.
- Maturity and credit characteristics of bonds without enhanced CACs:
  - Around 30 percent of such bonds are maturing in more than 10 years.
  - 48 percent of such bonds are below investment grade.
  - Of the bonds maturing in more than 10 years, 68 percent are governed by New York law, which may pose the highest risk of holdout behavior.
- Liability management:
  - Sovereign interest in liability management operations to accelerate incorporation of enhanced CACs has been limited, largely due to transaction costs.
  - No issuer has engaged in liability management exercises solely to accelerate incorporation of enhanced CACs.
  - Mexico has pursued an active liability management strategy since 2016 that has increased the ratio of bonds with enhanced CACs in its external debt market portfolio from 18 percent at the end of 2015 to 42 percent at the end of October 2017, via four debt neutral transactions in the international markets (August 2016 to October 2017).

### BOND GOVERNANCE STRUCTURES
- Issuance structures:
  - International sovereign bonds are typically issued under either fiscal agency agreements (FAAs) or trust structures.
  - Under an FAA, the fiscal agent serves as an agent of the issuer with responsibility for making principal and interest payments to bondholders.
  - Under trust structures, a bond trustee acts on behalf of bondholders as a group and has responsibilities that provide additional protection against holdout creditors (limitations on individual creditor enforcement actions; pro rata distribution of litigation proceeds).
- Trends and data:
  - Use of trust structures continues to be monitored; no marked change observed.
  - Approximately 42 percent (in nominal principal terms) of international sovereign bonds issued between October 1, 2014 and September 30, 2017 used trust structures, compared to 45 percent reported last year.
  - The vast majority (over 80 percent) of trust-structured issuances are under New York law.

### ISSUERS, OUTREACH, AND NEXT STEPS
- Issuers' preferences and market observations:
  - Issuers under English law still appear to prefer FAAs, which may reflect lack of awareness or that many lower income countries that issue under English law may be more sensitive to the higher costs associated with trust structures.
  - The transactions had an aggregate total of approximately US $10 billion.
  - Mexico has reduced the outstanding amount of bonds with no CACs by 25 percent, from US $9.1 billion to US $6.9 billion, and bonds with series-by-series CACs by 20 percent, from US $37.1 billion to US $29.6 billion.
  - As of the third quarter of 2017, Mexico’s external debt (including market debt and bilateral credit) represents 23.3 percent of the Federal Government of Mexico’s total debt and 7.7 percent of GDP.
  - Trust structures take the form of “trust indentures” under New York law or “trust deeds” under English law.
- Outreach and next steps (staff activities and planned actions):
  - Staff continues to promote the inclusion of the enhanced clauses in international sovereign bonds using the three-pronged approach endorsed by the Board in 2014, which entails:
    - (i) collect information on the stock of existing international sovereign bonds, including the use of CACs and pari passu provisions, residual maturities, and authorities’ intentions regarding future issuances;
    - (ii) engage on related issues with the membership through various fora; and
    - (iii) inform the Board, the G20 and the public periodically on the status of sovereign issuers’ inclusion of the enhanced contractual provisions in international sovereign bonds.
  - Recent outreach and engagement:
    - Staff presented a paper on the benefits of enhanced CACs at the IMF’s Public Debt Management Forum in Mexico City, Mexico, in 2017.
    - Staff liaised regularly with the relevant debt management offices and Executive Directors’ offices on these issues.
  - Going forward, staff will:
    - continue to promote the inclusion of the enhanced provisions through the three-pronged approach, targeting those issuers who continue to resist including the enhanced clauses;
    - continue to collect information on incorporation;
    - issue periodic progress reports to the Board which will be published;
    - engage with the membership;
    - continue to reach out to the debt management offices and Executive Directors’ offices of those issuers who continue not to include the enhanced clauses in their international sovereign bonds;
    - consider additional targeted outreach at the IMF’s regional training centers;
    - continue to monitor and assess the viability of liability management operations to address the outstanding stock challenge.

### ANNEX I — INCORPORATION OF ENHANCED SOVEREIGN BOND CLAUSES (IN BILLIONS OF USD)
- Albania: Not included enhanced CACs 0.5
- Angola: Not included enhanced CACs 1.5
- Argentina: Not included enhanced CACs 31.6
- Armenia: Not included enhanced CACs 0.5
- Azerbaijan: Not included enhanced CACs 3.3
- Bahrain: Not included enhanced CACs 7.8
- Belarus: Not included enhanced CACs 1.4
- Bermuda: Not included enhanced CACs 0.7
- Bolivia: Not included enhanced CACs 1.0
- Brazil: Not included enhanced CACs 4.0
- Bulgaria: Not included enhanced CACs 6.5
- Cameroon: Not included enhanced CACs 0.8
- Chile: Not included enhanced CACs 8.6
- China: Not included enhanced CACs 0.5
- Colombia: Not included enhanced CACs 9.3
- Costa Rica: Not included enhanced CACs 1.0
- Côte d’Ivoire: Not included enhanced CACs 1.0; Included enhanced CACs 2.0
- Croatia: Not included enhanced CACs 2.9
- Dominican Rep: Not included enhanced CACs 6.7
- Ecuador: Not included enhanced CACs 6.3
- Egypt: Not included enhanced CACs 12.7
- El Salvador: Not included enhanced CACs 0.6
- Ethiopia: Not included enhanced CACs 1.0
- Fiji: Not included enhanced CACs 0.2
- Gabon: Not included enhanced CACs 0.7
- Ghana: Not included enhanced CACs 1.8
- Grenada: Not included enhanced CACs 0.2
- Guatemala: Not included enhanced CACs 1.2
- Honduras: Not included enhanced CACs 0.7
- Hong Kong: Not included enhanced CACs 1.0; Included enhanced CACs 1.0
- Hungary: Not included enhanced CACs 0.3
- Indonesia: Not included enhanced CACs 5.6; Included enhanced CACs 22.0
- Iraq: Not included enhanced CACs 1.0; Included enhanced CACs 1.0
- Israel: Included enhanced CACs 3.4
- Jamaica: Included enhanced CACs 2.9
- Jordan: Included enhanced CACs 2.0
- Kazakhstan: Included enhanced CACs 6.5
- Korea: Included enhanced CACs 1.5
- Kuwait: Included enhanced CACs 8.0
- Lebanon: Included enhanced CACs 7.8
- Macedonia: Included enhanced CACs 0.8
- Malaysia: Included enhanced CACs 3.0
- Maldives: Included enhanced CACs 0.2
- Mexico: Included enhanced CACs 25.0
- Mongolia: Included enhanced CACs 0.7; Not included enhanced CACs 0.6
- Montenegro: Included enhanced CACs 0.8
- Mozambique: Included enhanced CACs 0.7
- Namibia: Included enhanced CACs 0.8
- Nigeria: Included enhanced CACs 1.8
- Oman: Included enhanced CACs 11.0
- Pakistan: Included enhanced CACs 1.0; Not included enhanced CACs 1.5
- Panama: Included enhanced CACs 3.8
- Paraguay: Included enhanced CACs 1.1
- Peru: Included enhanced CACs 3.6
- Philippines: Included enhanced CACs 6.0
- Poland: Included enhanced CACs 12.8
- Qatar: Included enhanced CACs 9.0
- Romania: Included enhanced CACs 7.7
- Russia: Included enhanced CACs 9.9
- Saudi Arabia: Included enhanced CACs 26.5
- Senegal: Included enhanced CACs 1.1
- South Africa: Included enhanced CACs 6.8
- Sri Lanka: Included enhanced CACs 3.7; Not included enhanced CACs 1.5
- Suriname: Included enhanced CACs 0.6
- Sweden: Included enhanced CACs 2.8
- Tajikistan: Included enhanced CACs 0.5
- Trinidad and Tobago: Included enhanced CACs 1.0
- Tunisia: Included enhanced CACs 2.9
- Turkey: Not included enhanced CACs 2.0; Included enhanced CACs 12.5
- UAE: Not included enhanced CACs 0.5
- Ukraine: Included enhanced CACs 16.1
- Uruguay: Included enhanced CACs 2.6
- Vietnam: Included enhanced CACs 1.0
- Zambia: Included enhanced CACs 1.3

*Prepared by Legal Department and Monetary and Capital Markets Department led by Yan Liu (LEG); team comprised Chanda DeLong (LEG), Charles Cohen and Kay Chung (both MCM). Report prepared by IMF staff and sent to the Executive Board for information on November 30, 2017.*

### Section 1

### THIRD PROGRESS REPORT ON INCLUSION OF ENHANCED CONTRACTUAL PROVISIONS IN INTERNATIONAL SOVEREIGN BOND CONTRACTS

### INTRODUCTION
- The IMF Executive Board endorsed in October 2014 the inclusion of:
  - a modified pari passu provision that explicitly excludes the obligation to effect ratable payments; and
  - an enhanced CAC with a menu of voting procedures, including a “single-limb” aggregated voting procedure (with a voting threshold of 75 percent of the aggregated outstanding principal of all affected bond series and a “uniformly applicable” condition), a two-limb aggregated voting procedure, and a series-by-series voting procedure.
- Directors supported an active role for the IMF in promoting inclusion of these clauses. The IMFC and the G20 called on the IMF to promote use of such clauses and report on their inclusion.
- This paper provides an update on inclusion and on the outstanding stock of international sovereign bonds as of September 30, 2017.

### ENHANCED CONTRACTUAL PROVISIONS — COLLECTIVE ACTION CLAUSES (CACs)
- Sample and coverage:
  - Approximately 350 international sovereign bond issuances since October 1, 2014, totaling approximately US$ 400 billion (information as of September 30, 2017).
  - Sample excludes: euro area sovereign issuances, China’s domestic issuances under Hong Kong law, and GDP warrants; the sample is based on the Perfect Information database.
- Uptake of enhanced CACs:
  - Approximately 87 percent of the nominal principal amount of new issuances have included the enhanced CACs (as of September 30, 2017), compared with 85 percent as of end-October last year.
  - From end-October 2016 to end-September 2017, 10 percent of issuances did not include enhanced CACs.
- Issuers not incorporating enhanced CACs (from end-October 2016 to end-September 2017):
  - Under New York law: Lebanon, Korea and the Philippines.
  - Under English law: Azerbaijan, Hungary, Malaysia (sukuk), and Poland.
  - Other non-inclusions: Hungary under Chinese law, Indonesia under Japanese law.
- Governing law breakdown of new issuances since October 2014 (in percent of total issuances):
  - English: No enhanced CACs 6.5; Enhanced CACs 41.3; Total 47.8.
  - New York: No enhanced CACs 6.1; Enhanced CACs 45.8; Total 51.9.
  - Others: No enhanced CACs 0.3; Enhanced CACs 0.0; Total 0.3.
  - Total: No enhanced CACs 12.9; Enhanced CACs 87.1; Total 100.0.
- Note: Formulation under English and New York law generally track ICMA model clauses.

### ENHANCED CONTRACTUAL PROVISIONS — PARI PASSU PROVISION
- Inclusion patterns:
  - The modified pari passu provision is largely incorporated as a package with enhanced CACs.
  - Since end-October last year, all issuances that included enhanced CACs also included modified pari passu provisions, except: Sri Lanka under New York law; and Bahrain, Indonesia (sukuk), Pakistan and Russia under English law.
- Some issuers that did not include enhanced CACs have included modified pari passu clauses (examples): Azerbaijan (under English law), Lebanon (under New York law), Hungary and Poland (under Chinese law).
- Euro area sovereigns have generally not included modified pari passu clauses.
- Issuances since October 2014 by modification status (in percent of total issuances):
  - No modified pari passu: No enhanced CACs 8.7; Enhanced CACs 6.6; Total 15.2.
  - Modified pari passu: No enhanced CACs 4.2; Enhanced CACs 80.6; Total 84.8.
  - Total: No enhanced CACs 12.9; Enhanced CACs 87.1; Total 100.0.
- All modified clauses specifically disavow the obligation to make ratable payments.

### ENHANCED CONTRACTUAL PROVISIONS — MARKET IMPACT
- Empirical observations:
  - Inclusion of enhanced CACs does not have an observable pricing effect in primary or secondary markets, consistent with prior reports.
  - For enhanced CACs, analysis is limited to country case studies due to scarcity of data points.
  - Over the last twelve months, yields at issuance of bonds with enhanced CACs are aligned with relevant points on their sovereign curves for both investment grade and noninvestment grade countries.
  - Secondary market checks for two major issuers at recent market lows and highs showed that bonds with enhanced CACs did not display noticeably higher yields, even during times of stress.
- Caveats:
  - Multiple market and fundamental factors affect pricing; more systematic analysis is necessary to draw definitive conclusions.
  - If investors expect higher recoveries on bonds without CACs, pricing divergence might be greater when the probability of default rises.

### ENHANCED CONTRACTUAL PROVISIONS — OUTSTANDING STOCK
- Change in outstanding stock composition:
  - Share of international sovereign bonds that include enhanced CACs grew from 18 percent of total outstanding stock as of end-October 2016 to 27 percent of total outstanding stock as of end-September 2017.
  - Large issuances by Saudi Arabia and Argentina incorporating enhanced CACs drove the change.
- Maturity and credit characteristics of bonds without enhanced CACs:
  - Around 30 percent of such bonds are maturing in more than 10 years.
  - 48 percent of such bonds are below investment grade.
  - Of the bonds maturing in more than 10 years, 68 percent are governed by New York law, which may pose the highest risk of holdout behavior.
- Liability management:
  - Sovereign interest in liability management operations to accelerate incorporation of enhanced CACs has been limited, largely due to transaction costs.
  - No issuer has engaged in liability management exercises solely to accelerate incorporation of enhanced CACs.
  - Mexico has pursued an active liability management strategy since 2016 that has increased the ratio of bonds with enhanced CACs in its external debt market portfolio from 18 percent at the end of 2015 to 42 percent at the end of October 2017, via four debt neutral transactions in the international markets (August 2016 to October 2017).

### BOND GOVERNANCE STRUCTURES
- Issuance structures:
  - International sovereign bonds are typically issued under either fiscal agency agreements (FAAs) or trust structures.
  - Under an FAA, the fiscal agent serves as an agent of the issuer with responsibility for making principal and interest payments to bondholders.
  - Under trust structures, a bond trustee acts on behalf of bondholders as a group and has responsibilities that provide additional protection against holdout creditors (limitations on individual creditor enforcement actions; pro rata distribution of litigation proceeds).
- Trends and data:
  - Use of trust structures continues to be monitored; no marked change observed.
  - Approximately 42 percent (in nominal principal terms) of international sovereign bonds issued between October 1, 2014 and September 30, 2017 used trust structures, compared to 45 percent reported last year.
  - The vast majority (over 80 percent) of trust-structured issuances are under New York law.

*Prepared by Legal Department and Monetary and Capital Markets Department led by Yan Liu (LEG); team comprised Chanda DeLong (LEG), Charles Cohen and Kay Chung (both MCM). Report prepared by IMF staff and sent to the Executive Board for information on November 30, 2017.*

### Section 2

### Section 2 — Issuers, Outreach, and Annex I

### Issuers' preferences and market observations
- Issuers under English law still appear to prefer FAAs, which may reflect lack of awareness or that many lower income countries that issue under English law may be more sensitive to the higher costs associated with trust structures.
- The transactions had an aggregate total of approximately US $10 billion.
- Mexico has reduced the outstanding amount of bonds with no CACs by 25 percent, from US $9.1 billion to US $6.9 billion, and bonds with series-by-series CACs by 20 percent, from US $37.1 billion to US $29.6 billion.
- As of the third quarter of 2017, Mexico’s external debt (including market debt and bilateral credit) represents 23.3 percent of the Federal Government of Mexico’s total debt and 7.7 percent of GDP.
- Trust structures take the form of “trust indentures” under New York law or “trust deeds” under English law.
- See paragraphs 23-25 of the 2015 paper.

### Outreach and next steps (staff activities and planned actions)
- Staff continues to promote the inclusion of the enhanced clauses in international sovereign bonds using the three-pronged approach endorsed by the Board in 2014, which entails:
  - (i) collect information on the stock of existing international sovereign bonds, including the use of CACs and pari passu provisions, residual maturities, and authorities’ intentions regarding future issuances;
  - (ii) engage on related issues with the membership through various fora; and
  - (iii) inform the Board, the G20 and the public periodically on the status of sovereign issuers’ inclusion of the enhanced contractual provisions in international sovereign bonds.
- Recent outreach and engagement:
  - Staff presented a paper on the benefits of enhanced CACs at the IMF’s Public Debt Management Forum in Mexico City, Mexico, in 2017.
  - Staff liaised regularly with the relevant debt management offices and Executive Directors’ offices on these issues.
- Going forward, staff will:
  - continue to promote the inclusion of the enhanced provisions through the three-pronged approach, targeting those issuers who continue to resist including the enhanced clauses;
  - continue to collect information on incorporation;
  - issue periodic progress reports to the Board which will be published;
  - engage with the membership;
  - continue to reach out to the debt management offices and Executive Directors’ offices of those issuers who continue not to include the enhanced clauses in their international sovereign bonds;
  - consider additional targeted outreach at the IMF’s regional training centers;
  - continue to monitor and assess the viability of liability management operations to address the outstanding stock challenge.

### Annex I. Incorporation of Enhanced Sovereign Bond Clauses — International Sovereign Bond Issuance Since October 2014 (in billions of USD)
- Albania: Not included enhanced CACs 0.5
- Angola: Not included enhanced CACs 1.5
- Argentina: Not included enhanced CACs 31.6
- Armenia: Not included enhanced CACs 0.5
- Azerbaijan: Not included enhanced CACs 3.3
- Bahrain: Not included enhanced CACs 7.8
- Belarus: Not included enhanced CACs 1.4
- Bermuda: Not included enhanced CACs 0.7
- Bolivia: Not included enhanced CACs 1.0
- Brazil: Not included enhanced CACs 4.0
- Bulgaria: Not included enhanced CACs 6.5
- Cameroon: Not included enhanced CACs 0.8
- Chile: Not included enhanced CACs 8.6
- China: Not included enhanced CACs 0.5
- Colombia: Not included enhanced CACs 9.3
- Costa Rica: Not included enhanced CACs 1.0
- Côte d’Ivoire: Not included enhanced CACs 1.0; Included enhanced CACs 2.0
- Croatia: Not included enhanced CACs 2.9
- Dominican Rep: Not included enhanced CACs 6.7
- Ecuador: Not included enhanced CACs 6.3
- Egypt: Not included enhanced CACs 12.7
- El Salvador: Not included enhanced CACs 0.6
- Ethiopia: Not included enhanced CACs 1.0
- Fiji: Not included enhanced CACs 0.2
- Gabon: Not included enhanced CACs 0.7
- Ghana: Not included enhanced CACs 1.8
- Grenada: Not included enhanced CACs 0.2
- Guatemala: Not included enhanced CACs 1.2
- Honduras: Not included enhanced CACs 0.7
- Hong Kong: Not included enhanced CACs 1.0; Included enhanced CACs 1.0
- Hungary: Not included enhanced CACs 0.3
- Indonesia: Not included enhanced CACs 5.6; Included enhanced CACs 22.0
- Iraq: Not included enhanced CACs 1.0; Included enhanced CACs 1.0
- Israel: Included enhanced CACs 3.4
- Jamaica: Included enhanced CACs 2.9
- Jordan: Included enhanced CACs 2.0
- Kazakhstan: Included enhanced CACs 6.5
- Korea: Included enhanced CACs 1.5
- Kuwait: Included enhanced CACs 8.0
- Lebanon: Included enhanced CACs 7.8
- Macedonia: Included enhanced CACs 0.8
- Malaysia: Included enhanced CACs 3.0
- Maldives: Included enhanced CACs 0.2
- Mexico: Included enhanced CACs 25.0
- Mongolia: Included enhanced CACs 0.7; Not included enhanced CACs 0.6
- Montenegro: Included enhanced CACs 0.8
- Mozambique: Included enhanced CACs 0.7
- Namibia: Included enhanced CACs 0.8
- Nigeria: Included enhanced CACs 1.8
- Oman: Included enhanced CACs 11.0
- Pakistan: Included enhanced CACs 1.0; Not included enhanced CACs 1.5
- Panama: Included enhanced CACs 3.8
- Paraguay: Included enhanced CACs 1.1
- Peru: Included enhanced CACs 3.6
- Philippines: Included enhanced CACs 6.0
- Poland: Included enhanced CACs 12.8
- Qatar: Included enhanced CACs 9.0
- Romania: Included enhanced CACs 7.7
- Russia: Included enhanced CACs 9.9
- Saudi Arabia: Included enhanced CACs 26.5
- Senegal: Included enhanced CACs 1.1
- South Africa: Included enhanced CACs 6.8
- Sri Lanka: Included enhanced CACs 3.7; Not included enhanced CACs 1.5
- Suriname: Included enhanced CACs 0.6
- Sweden: Included enhanced CACs 2.8
- Tajikistan: Included enhanced CACs 0.5
- Trinidad and Tobago: Included enhanced CACs 1.0
- Tunisia: Included enhanced CACs 2.9
- Turkey: Not included enhanced CACs 2.0; Included enhanced CACs 12.5
- UAE: Not included enhanced CACs 0.5
- Ukraine: Included enhanced CACs 16.1
- Uruguay: Included enhanced CACs 2.6
- Vietnam: Included enhanced CACs 1.0
- Zambia: Included enhanced CACs 1.3

*Sources. Perfect Information database and staff calculations.*

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_Source: https://www.imf.org/-/media/files/publications/pp/2017/pp113017third-progress-report-on-cacs.pdf_
