## The Chair’s Summing Up — Independent Evaluation Office—The IMF’s Exceptional Access Policy ## Source details **Canonical URL:** [The Chair’s Summing Up — Independent Evaluation Office—The IMF’s Exceptional Access Policy](https://www.imf.org/-/media/files/publications/pp/2024/english/ppea2024062.pdf) ## Other formats - [Markdown version](/-/media/files/publications/pp/2024/english/ppea2024062.pdf.md) - [Structured JSON version](/-/media/files/publications/pp/2024/english/ppea2024062.pdf.json) --- ### Context and overall assessment - Date and meeting: December 10, 2024; Executive Board Meeting 24/112 (December 5, 2024). - Executive Directors welcomed the IEO report on the IMF’s Exceptional Access Policy (EAP), covering the policy’s objectives and design, successive reforms, and experience with implementation. - General view: the EAP struck a generally good balance between rules and flexibility, reinforced transparency and accountability, and adopted adequate safeguards while providing a structured framework for higher scrutiny through the exceptional access criteria (EAC) and enhanced decision-making procedures. - Directors saw value in the EAP as a vehicle for learning through ex-post evaluations (EPEs) and accountability, and as useful for handling exceptional access (EA) requests during large systemic shocks over the past two decades. ### Main findings and concerns - Safeguards and risk: - Most Directors shared the IEO’s concern that safeguards for IMF lending have not been as substantially enhanced as envisaged by the policy. - Directors pointed to cases of repeated use of Fund resources and continued debt vulnerabilities as evidence of gaps in the design and application of the EAC related to: - the size of balance of payments needs, - debt sustainability, - prospects for market access, - reasonably strong prospects for program success. - Perceptions and effectiveness: - Exceptional access programs have been perceived to have an optimism bias. - EA programs had relatively weak catalytic impact and were relatively rarely accompanied by debt operations. - A few Directors noted similar completion and compliance rates as in Normal Access (NA) programs despite more challenging initial conditions in EA programs, interpreting this as evidence of gains from the EAP. - Evenhandedness, transparency, and political considerations: - Directors highlighted importance of transparency, consistency, and perceptions of evenhandedness. - Some Directors raised concerns about stigma, evenhandedness, and transparency if an Exceptional Circumstances (EC) clause were reintroduced. ### Agreed actions and review processes - Recommendation 1 — Dedicated review of the EAP: - Directors agreed to conduct a dedicated review of the EAP. - Subsequent reviews should be scheduled regularly to ensure the policy remains fit for purpose in an evolving global context. - Reviews should consider strategic elements including access limits and the balance between rules and flexibility. - Scope: include PRGT exceptional access and high combined PRGT and GRA credit exposure cases. - Flexibility in timing and format emphasized given expected resource intensity of the next comprehensive review. - Most Directors were open to careful consideration of reintroducing an Exceptional Circumstances (EC) clause for rare, well-justified cases, while many expressed reservations and stressed risks (stigmatization, evenhandedness, transparency). - Managing Director and implementation: - Directors welcomed the Managing Director’s broad support for the IEO recommendations while noting qualifications. - Emphasis on evaluating resource implications of proposals and seeking synergies with existing workstreams. - Management and staff will consider today’s discussion in formulating the Management Implementation Plan (MIP) for Board-endorsed recommendations. - Some Directors called for the MIP to articulate which recommendations can be taken up immediately and which should be part of a comprehensive EAP review. ### Technical improvements and specific recommendations - Recommendation 2 — Program design and safeguards: - Directors broadly agreed to clarify the fundamental role of sound program design in providing higher safeguards in EA cases relative to NA programs. - Strong agreement on the importance of strengthening justification for policy choices and trade-offs and on consistency with reasonably strong prospects of program success (EAC4). - All EA and NA programs should remain subject to a single, common Upper Credit Tranche quality standard. - Additional rigor should not undermine practical applicability across heterogeneous institutional and political capacities. - Agreement to build on staff efforts to provide clearer guidance for assessing political assurances in the run up to elections for Fund-supported programs, leveraging the Operational Guidance Note on Program Design and Conditionality. - Importance of disclosing risks to the Board and guidance on public communications in EA cases. - Recommendation 3 — Address technical gaps in the EAC: - Directors generally agreed to address technical gaps to better align the EAC with EAP objectives and ensure evenhandedness. - Broad support to increase scrutiny of access decisions (EAC1) for cases with debt in the gray zone (debt sustainable but not with high probability). - Most Directors agreed to clarify expectations when debt is in the gray zone, revisit its terminology to strengthen signaling, and clarify distinct roles of different types of debt and creditors (EAC2). - Some Directors cautioned that tightening EAC2 might raise prospects of deeper debt restructurings, possibly diminishing prospects for fulfilling EAC3. - General concurrence on developing more consistent forward-looking guidance to support assessments of market access prospects (EAC3), balanced against concerns on usefulness, resource implications, and inherent limitations of such frameworks. - Recommendation 4 — Strengthen enhanced procedures and leverage EPEs: - Directors supported strengthening application of the EAP’s enhanced procedures, including early and regular informal consultation with Directors while preserving management and staff flexibility and respecting authorities’ prerogatives. - Agreement to strengthen EPEs by implementing procedures for more systematic follow up, enhancing transparency, and ensuring adequate independence of EPE leaders and teams, including: - having a roster of EPE leads, - formation of an interdepartmental review group. - Recommendation 5 — Coherence with Enterprise Risk Management (ERM): - Directors concurred with establishing greater coherence between the EAP and the Fund’s ERM framework, ensuring common institutional understanding of how the EAP mitigates enterprise risks consistently with the Fund’s risk tolerance in lending. - Importance of timely risk disclosures to the Board and continued progress to enhance risk analysis in program documents, including further leveraging recently introduced Enterprise Risk Assessments. - While primary responsibility remains with area departments in close consultation with review departments, a number of Directors considered that the Office of Risk Management could gradually be given greater responsibility over financial risk supplements in EA program documents. ### Next steps and implementation planning - Management Implementation Plan (MIP): - Management and staff will give careful consideration to the Board discussion in formulating the MIP for Board-endorsed recommendations, drawing on the IEO’s suggestions and ensuring synergies with existing workstreams and mindful of resource constraints. - Some Directors urged the MIP to indicate which recommendations can be implemented immediately and which require inclusion in a comprehensive EAP review. *Source: The Chair’s Summing Up — Independent Evaluation Office—The IMF’s Exceptional Access Policy (Executive Board Meeting 24/112, December 5, 2024; Chair’s note dated December 10, 2024).* --- _Source: https://www.imf.org/-/media/files/publications/pp/2024/english/ppea2024062.pdf_