## 070506

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### Importance of reliable and timely information
- Reliable and timely information is essential for all aspects of the Fund’s work; without it the Fund cannot provide sound policy advice or confidently judge the basis for providing financial support.
- Poor data can lead to inaccurate assessments, inappropriate policy advice and program design, with negative outcomes and reputational effects for the member and the Fund.

### Legal framework on information provision and misreporting
- Provision of timely and accurate information to the Fund is the responsibility of the member; the Fund’s relationship of trust with the member is fundamental.
- The Fund’s legal framework on misreporting rests primarily on:
  - Article VIII, Section 5 (applies to all members; contains general provisions on the furnishing of information with qualifications relating to capacity and confidentiality).
  - The Guidelines on Misreporting and Noncomplying Purchases in the General Resources Account and disbursements under the Poverty Reduction and Growth Facility (PRGF) or the Exogenous Shocks Facility (ESF) (collectively the “Misreporting Guidelines”), which address misreporting in the context of Fund arrangements.
- Several other Fund policies also contain provisions on misreporting (e.g., the HIPC Trust Instrument, the decision on Policy Support Instruments, and the publication policy); collectively these comprise the Fund’s “misreporting framework.”

### Historical developments, amendments, and trends
- Episodes of egregious misreporting in the late 1990s prompted a firmer stance and amendments:
  - In 2000 the Misreporting Guidelines were amended to: lengthen the limitation period from two to four years; subject reporting on specified prior actions to the Guidelines; and grant waivers only if information provided to assess the performance criterion (or other relevant performance conditions) is accurate.
  - It was decided that all cases of misreporting would be made public.
  - In 2002 a framework to address cases of data revision under the HIPC Initiative was established.
  - A framework to strengthen the effectiveness of Article VIII, Section 5 was adopted in 2004.
  - The Policy Support Instrument decision adopted in 2005 contained provisions on misreporting.
- Increase in misreporting cases:
  - Since July 2000 there has been a sharp increase in the number of misreporting cases brought to the Executive Board.
  - The 37 misreporting cases brought to the Board in July 2000–March 2006 involved 49 conditions.
  - Of those 49 conditions, the most common were:
    - performance criteria on non-accumulation of external arrears: 12
    - fiscal balances: 7
    - debt: 6
    - net international reserves, net domestic assets or reserve money: 9
    - financing: 4
  - Outcomes: in six of the 37 cases the member had to make an early repurchase or repayment; in the other cases either the Board granted a waiver for nonobservance or the member had already made an advance repurchase (repayment).
  - There has been only one case of misreporting to arise exclusively under Article VIII, Section 5 since the 2004 Decision was adopted (Paraguay in 2005).
- Factors contributing to the increase:
  - Strengthened Misreporting Guidelines (including eight incidents relating to prior actions that were not subjected to the policy before 2000).
  - More vigilant Fund approach, leading to detection of incidents that may have gone unnoticed before; some involve de minimis deviations.

### Box 1 — Key elements of the Misreporting Guidelines
- Scope:
  - Apply to performance criteria and other conditions (e.g., prior actions) applicable to an outstanding purchase in the GRA or disbursement under the PRGF or ESF, and to information provided in the context of requests for waivers.
- Procedures:
  - Whenever staff has evidence that a performance criterion or other condition applicable to an outstanding purchase/disbursement may not have been observed, the Managing Director shall promptly inform the member concerned.
  - After consultation, if the Managing Director finds the criterion or condition was not observed, the Managing Director shall promptly notify the member and submit a report to the Board with recommendations.
- Action within the limitation period:
  - If the noncomplying purchase/disbursement was made no more than four years prior to the date on which the Managing Director informed the member, the Board may decide either:
    - (a) that the member shall be expected to repay or repurchase the outstanding amount normally within 30 days from the Board decision, or
    - (b) that the nonobservance will be waived.
- Waiver criteria:
  - A waiver will normally be granted only if the deviation was minor or temporary, or if subsequent corrective policy measures were adopted to achieve the objectives supported by the relevant decision.
- Publication:
  - After the Board has determined that misreporting occurred, the Fund proceeds to make relevant information public in every case, with Board review of the text for publication.

### Objectives in modifying the misreporting framework to address de minimis cases
- Rationale:
  - Existing misreporting procedures can be taxing in de minimis cases: large staff and authority time to establish data accuracy; management and Executive Director involvement; reputational cost disproportionate to trivial deviations; potential discouragement of data revisions.
- Fundamental objectives to preserve:
  - Preserve strong incentives for timely and accurate data reporting and maintain Fund capacity to address serious misreporting.
  - Ensure consistency with the Articles of Agreement, particularly Article VIII, Section 5; do not change the fundamental nature of Fund arrangements.
  - Maintain a “bright line” test under Fund arrangements for performance criteria observance, while retaining discretion when granting waivers (taking magnitude of nonobservance into account).
  - Promote uniformity of treatment across individual cases.

### Proposed modifications to the legal framework (focus on de minimis)
- Scope and approach:
  - Proposed package aims primarily to reduce stigma and procedural burden for de minimis misreporting in cases involving the use of Fund resources or support under the PSI.
  - Focus on Misreporting Guidelines; other relevant policies to be aligned.
  - Not proposed to amend policies to address de minimis misreporting in surveillance, except for “hybrid” cases involving misreporting for UFR/PSI and surveillance.
- Identifying and defining de minimis deviations:
  - The Managing Director would make the initial judgment whether misreporting is de minimis and whether special procedures apply; all cases would continue to be submitted to the Executive Board, which may reject management’s assessment.
  - Options for definition considered:
    - Precise or quantified definition (e.g., “deviations of no more than x”) — facilitates consistency but difficult to establish for all conditions and members.
    - Define as de minimis every misreporting case involving a deviation that meets the criteria for waivers — risks making most cases qualify and could reduce incentives for good reporting.
    - Staff-favored approach: (i) define de minimis as any deviation so small as to be trivial with no impact on assessment of performance under the program; and (ii) identify examples from experience as yardsticks.
  - Practical considerations:
    - Third approach relies on judgments by staff and management, with ultimate decision by the Board.
    - Repeated occurrences, even if small, would typically not be considered de minimis.
    - Structural reform misreporting may be difficult to judge as de minimis due to nonquantifiable implications.
- Examples of de minimis misreporting (from Table 1):
  - Mexico SBA2000 — Fiscal balance: data revision resulted in deviation from the target of $57 million (0.01 percent of GDP).
  - Tajikistan PRGF2001 — External arrears: $500,000.
  - Djibouti PRGF2002 — External arrears: SDR 59,214.
  - Dominica SBA/PRGF 1/2004 — External arrears: $326,300 (claim reclassified as external in 2004).
  - Dominica PRGF2005 — External arrears: $109,000 (delayed 29 days).
  - Rwanda PRGF2005 — External arrears: $25,145.
  - Congo, Dem. Rep. PRGF2005 — Structural PC: Central Bank failed to receive prior Treasury approval for purchases totalling $1 million (0.1 percent of total budgetary expenditures).
  - Pakistan PRGF2005 — Structural PC: tax exemption but had no budgetary implications.
  - Paraguay SBA 1/2005 — External arrears: $4 million.
  - Notes: Dominica (2004) was misreporting both under the Guidelines and Article VIII, Section 5. Paraguay (2005) was misreporting under Article VIII, Section 5 only, not under the Misreporting Guidelines, because no purchase was made as the SBA was treated as precautionary. In Mexico (2000) staff considered Article VIII, Section 5 but found no breach. The other examples did not involve Article VIII, Section 5 because it does not apply to PRGF-arrangements.
- Specific proposed modifications to the Misreporting Guidelines for de minimis cases:
  - Notifications:
    - Under current Guidelines the Managing Director must promptly notify a member that a noncomplying purchase/disbursement may have been made and that an enquiry is commenced, and if concluded, that a noncomplying purchase/disbursement was made.
    - For de minimis cases these notifications could be made by the Area Department and not by the Managing Director; a written response from the authorities would not be expected.
  - Board reporting:
    - When the Managing Director concludes a noncomplying purchase/disbursement was made, he must report to the Board with recommendations (normally a separate Board document).
    - For de minimis cases the Managing Director would still report and recommend but not normally in a separate Board document; findings/recommendations would be folded into other documents (e.g., Article IV or UFR staff report) and addressed in that Board meeting.
    - If no such document can be issued promptly, management would consult Executive Directors (e.g., informal country matters session) and, if appropriate, prepare a short stand-alone document for lapse-of-time consideration.
  - Waiver and publication:
    - If the Board agrees a case is de minimis, the Board would grant a waiver for nonobservance (the Guidelines already permit waivers when nonobservance is “minor” or “temporary”).
    - Cases of noncomplying purchases/disbursements arising from de minimis misreporting would be exempted from the general publication requirement and would no longer be published; such cases would not be mentioned in PINs, Chairman’s statements, factual statements or other public statements.
    - Once determined de minimis, management and the Board would have no discretion with respect to publication; in all such cases no publication of the misreporting would be made.
    - To correct the public record, the Fund would include in a Chairman’s statement, factual statement or PIN or other press release a statement clarifying that a waiver had subsequently been granted for nonobservance of a program condition, but without stating that the relevant condition was the subject of misreporting.
  - Publication of Board documents:
    - When de minimis misreporting is addressed within a broader Board document (e.g., Article IV staff report), sections dealing with the de minimis misreporting would be deleted before publication.
    - Stand-alone Board documents discussing de minimis misreporting cases would not be published.

### Staff view on more fundamental changes
- Staff does not favor treating de minimis misreporting as not misreporting at all because:
  - It would be difficult to administer.
  - It would reduce incentives for good reporting.
  - It would change the nature of a Fund arrangement.
- Staff proposes procedural adjustments that preserve recognition of de minimis cases while retaining misreporting as a legal category subject to streamlined procedures.

### Illustrative application — Rwanda (Box 2)
- Facts from the Rwanda case considered by the Board on April 11, 2005:
  - Rwanda accumulated $25,145 in new non-reschedulable external payments arrears in 2003.
  - This led to two non-complying disbursements under the PRGF and one disbursement of interim assistance under the Enhanced HIPC Initiative.
  - The Board considered a 10-page document, including letters and the Managing Director’s report, simultaneous with the fourth review under the PRGF arrangement.
  - Press release: IMF Executive Board Completes the Fourth Review of Rwanda’s PRGF Arrangement and Addresses Misreporting of Information (No. 05/85, 4/13/05).
  - The Board granted a waiver of nonobservance because the deviation was minor, had been settled in the interim, and had not endangered achievement of the other objectives of the PRGF-supported program.
- Under the proposed de minimis procedures the following would have applied:
  - The Area Department would notify the authorities about the misreporting incident rather than a letter from the Acting Managing Director; no formal reply required.
  - No separate Board document or separate Board meeting on the misreporting incident; a brief description of facts and a proposed waiver decision would be included in the PRGF review Board documents (Rwanda—Fourth Review Under the Three-Year Arrangement Under the Poverty Reduction and Growth Facility and Requests for Waiver of Nonobservance of Performance Criteria and for Extension of the Arrangement (IMF Country Report 05/171, May 2005)).
  - Information on misreporting would be excluded from the summing up and deleted from the staff report prior to publication (assuming publication agreed).
  - The approval of the waiver would be mentioned in the PRGF review press release without direct reference to the misreporting itself; example sentence: “The Board also approved a waiver of nonobservance of the continuous performance criterion on external arrears that was breached in the fourth quarter of 2003.”

### Article VIII, Section 5 — interaction and procedural treatment
- Broad points:
  - Whenever misreporting occurs in the context of using the Fund's general resources (GRA), Article VIII, Section 5 is broadly implicated.
  - Article VIII, Section 5 does not apply to misreporting under the PRGF, the ESF, or a PSI per se, but misreporting under those arrangements can lead to a breach of Article VIII, Section 5 if:
    - (i) the information is required by the Fund for purposes other than PRGF/ESF/PSI (e.g., surveillance or as specifically listed in Article VIII, Section 5 or the January 2004 Executive Board Decision strengthening Article VIII, Section 5), and
    - (ii) understandings exist that information reported in the context of PRGF/ESF/PSI is also reported for those other purposes.
- Recommendation:
  - If a misreporting case under GRA, PRGF, ESF, or PSI would be treated as de minimis under the revised Misreporting Guidelines, any potential breach of Article VIII, Section 5 should also be treated as de minimis under the Article VIII, Section 5 procedural framework.
- Procedural implications for de minimis Article VIII, Section 5 cases:
  - Preliminary communications may be sent by the Area Department rather than the Managing Director.
  - Managing Director’s findings and recommendations should be folded into other documents where possible (e.g., an Article IV or UFR staff report) and addressed in that Board meeting.
  - For de minimis cases involving a breach of Article VIII, Section 5, the framework would make clear that:
    - (i) no further action would be expected to be taken by the Fund with respect to the member; and
    - (ii) the finding of breach would not be published.
- Key procedural elements of Article VIII, Section 5 (Box 3) preserved exactly:
  - Managing Director consults with the member to assess whether inaccuracy is due to lack of capacity.
  - If not satisfied, MD notifies member of intention to report a breach to the Board unless the member demonstrates lack of capacity within a period of not less than one month.
  - If member fails to demonstrate lack of capacity, MD reports to the Board that he believes a breach has occurred.
  - The Executive Board decides whether a breach occurred and may call on the member to take specific measures; failure can lead to graduated measures including declaration of censure and application of sanctions under Article XXVI.
  - All Board decisions arising from a breach of obligation give rise to a public announcement with prior review of the text by the Board.
- Notes on time limits:
  - Noncomplying purchases/disbursements under the Misreporting Guidelines are subject to a four-year limitation period; no such limitation applies under Article VIII, Section 5.
  - For de minimis misreporting subject to Article VIII, Section 5 and arising more than four years before the MD informed the member of a potential noncomplying purchase, the Article VIII, Section 5 de minimis procedures would apply.

### Policy Support Instrument (PSI) — alignment with de minimis approach
- Current PSI misreporting framework (Box 4) — basic procedures preserved:
  - When evidence exists that reporting was inaccurate in relation to a PSI approved or a review completed within the preceding three years, the Managing Director shall promptly inform the member concerned.
  - If MD concludes inaccurate reporting occurred, MD shall promptly notify the member.
  - Board consideration of misreporting would normally take place at the next scheduled PSI review, based on a combined staff report; the Executive Board shall decide whether misreporting occurred and reassess program performance in light of that determination.
  - In all cases where the Board has determined misreporting occurred, relevant information and impacts would be published.
- Proposed modifications to the PSI decision to follow Misreporting Guidelines approach:
  - Preliminary communications in de minimis cases to be sent by the Area Department rather than the Managing Director.
  - The PSI decision would specify that cases of de minimis misreporting would, by definition, be regarded as having no effect on the assessment of program performance.
  - The PSI decision would specify that findings of de minimis misreporting, given their irrelevance for overall program performance, would not be published.
  - To correct the public record, the non-observance itself would be mentioned in a low-key fashion in any PIN, Chairman’s statement, factual statement, or other press release issued after the Board meeting on the paper in which the misreporting was handled.
- Implementation note:
  - Amending the PSI decision will require modification of the misreporting provisions in the PSI decision; provision would also be made for lapse of time handling when warranted.

### Enhanced HIPC Initiative — adjustments and de minimis treatment
- Two types of revisions in the HIPC framework (established 2002):
  - (i) Revisions to information used to calculate the amount of debt relief to be accorded to a member.
  - (ii) Revisions to information on the member’s track record used in deciding whether to make interim assistance available.
- Existing de minimis standard for debt relief calculation:
  - Upward and downward adjustments will be made only when the change in the U.S. dollar amount of HIPC Initiative assistance exceeds one percent of the targeted net present value (NPV) of debt after HIPC Initiative relief.
  - No change to this provision is proposed.
- Track record revisions and interim assistance:
  - The current framework does not incorporate an explicit de minimis standard for track record revisions; the Fund examines the magnitude of the change and decides whether disbursements remaining in the HIPC umbrella account should be transferred back to the HIPC Trust.
  - It is unlikely that a case of de minimis misreporting under a Fund arrangement would lead to retransfer of interim assistance under the HIPC decision.
- Proposed clarifications and procedures:
  - Amend the HIPC decision to make clear that cases of de minimis misreporting of track record information would not lead to a retransfer of resources to the HIPC Trust.
  - Apply procedures similar to the Misreporting Guidelines for de minimis track record cases:
    - (i) relevant communications with the member could be sent from the Area Department; and
    - (ii) such cases would normally be addressed in the context of a Board discussion of another issue or, if not possible, sent to the Board for consideration on a lapse of time basis.
  - Publication: propose excluding cases of de minimis misreporting of track record information from the HIPC Trust Instrument’s current publication requirement that “the Fund shall issue press releases on its decisions regarding the circumstances of the misreporting and the applicable remedies.”
- Main elements of the HIPC misreporting framework (Box 5) preserved exactly:
  - Adjustments to HIPC Initiative assistance only when change in U.S. dollar amount exceeds one percent of targeted NPV after HIPC relief.
  - Revisions to exports, GDP, or fiscal revenue give rise to downward adjustments only if related to information provided by or on behalf of the authorities.
  - Interim assistance transferred into the umbrella account could be returned to the PRGF-HIPC Trust if approved on the basis of inaccurate track record information.
  - HIPC Decision requires the Fund to issue press releases on decisions regarding the circumstances of misreporting and applicable remedies (subject to proposed exclusion for de minimis track record cases).

### Transparency and publication policy
- Current policy:
  - The publication policy requires the Fund to publish all cases of misreporting, with language calibrated to circumstances.
  - The principal Fund decision governing publication is the Transparency Decision, together with misreporting provisions in the Misreporting Guidelines, Article VIII, Section 5, the PSI, and the HIPC Trust.
- Proposed adjustments for de minimis cases:
  - De minimis findings would generally be excluded from publication under:
    - Revised Misreporting Guidelines (de minimis cases would not appear in staff report summings up and could be deleted prior to publication).
    - Article VIII, Section 5 procedural framework (finding of breach would not be published).
    - PSI decision amendments (findings of de minimis misreporting would not be published).
    - HIPC Trust Instrument amendment (de minimis track record misreporting excluded from publication requirement).
  - Where necessary to correct the public record, the non-observance or waiver approval would be mentioned in low-key language in the relevant press release or PIN without direct reference to the misreporting itself (illustrated by the Rwanda example).

### Section III, Paragraph 3(d) of the HIPC Trust Instrument — amendment and implementation
- "This will require an amendment to Section III, Paragraph 3(d) of the HIPC Trust Instrument."
- "Each of these would be amended accordingly to implement the changes outlined above."

### Publication policy for de minimis misreporting (procedures)
- When a member transaction or review triggers a public statement (e.g., Chairman’s statement, or factual statement) and it is later discovered that a condition was not met by a de minimis margin, the public record should be corrected.
- For cases of de minimis misreporting, the Fund would:
  - Publicize only the fact of nonobservance and the granting of a waiver.
  - Not make reference to the misreporting associated with the nonobservance and waiver.
  - Normally include this publication in a PIN, Chairman’s statement, or factual statement issued after the Board meeting on the paper into which the misreporting case is folded.
  - Correct the public record in a "fairly low-key fashion."
- Amendments to the Transparency Decision:
  - The Transparency Decision’s rules on permissible deletions in staff reports would be amended.
  - Moving forward, the Transparency Decision would require deletion of discussions related to de minimis misreporting in Board documents that are to be published (e.g., an Article IV or UFR staff report).

### Analysis, conclusion, and next steps
- Advantages of proposed modifications:
  - May reduce the stigma and contentiousness of misreporting in de minimis cases.
  - Could reduce the amount of time spent on misreporting cases.
  - Leaves the Board discretion to decide whether a case is de minimis and whether to publish.
  - Preserves the Fund’s capacity to deal adequately with cases of misreporting.
- Drawbacks and risks:
  - Does not eliminate the time-consuming discovery process needed to protect the member and the Fund, though this should be less contentious.
  - May create incentives for members to more robustly request de minimis classification.
  - The stigma of misreporting might become worse for other ("near de minimis") cases.
- Staff view: "Overall, staff believes that the proposal outlined in this paper strikes a reasonable balance between reducing the cost of the misreporting framework in de minimis cases to members and the Fund while preserving incentives for good data reporting and the Fund’s capacity to deal with serious cases of misreporting."
- Next steps: After Executive Board discussion, draft decisions would be circulated to the Board, "possibly for consideration on a lapse-of-time basis."

### Issues for discussion (questions for Directors)
- "Should the Fund’s misreporting framework be revised to make it less onerous in cases involving de minimis deviations?"
- "Do Directors support the approach proposed in paragraph 11 to identify de minimis cases?"
- Do Directors agree that in de minimis cases:
  - "The requirement to publish information on the misreporting be abolished, and that to correct the public record, the procedures set out in paragraph 15 be followed?"
  - "A procedure would be established that notification to the member of misreporting be made by staff, and there would be no notification from the Managing Director directly. The Area Department could simply notify the authorities through a memorandum to the relevant Executive Director."
  - "The current practice of a separate Board Report from the Managing Director on the misreporting would be abolished, and that instead the misreporting discussion would normally be folded into other documents (e.g., Article IV or UFR). If these documents are published, the parts on de minimis misreporting would be deleted and they would not be mentioned in the Summing Up. Consequently, de minimis misreporting would generally be handled in the context of regular Board meetings."

### Key statistics and historical cases (selected entries from Table A1: Cases of Misreporting Discussed by the Board through end-March 2006)
- Mauritius 8/28/1985 — 1CPC1 — Debt — Yes
- Zaire 9/20/1985 — 1QPC1 — Debt — Yes
- Senegal 7/23/1986 — 1QPC1 — Debt — Yes
- Mauritania 12/19/1988 — 1CPC1 — External arrears — Yes
- Hungary 2/21/1990 — 3QPC1 — Debt — No — Yes
- Philippines 4/9/1990 — 1QPC1 — NIR — Yes
- Ukraine 12/13/1995 — 1CPC1 — External arrears — Yes
- Tajikistan 7/2/1999 — 1QPC1 — Debt — Yes
- Pakistan 9/3/1999 — 1QPC1 — Fiscal balance — Yes
- Pakistan 4/29/2000 — 1QPC1 — Debt — No — Yes
- Malawi 8/23/2000 — 1CPC1 — Domestic arrears — Yes
- Ghana 8/21/2000 — 1CPC1 — Multiple currency practices — Yes
- Ukraine 9/6/2000 — 2QPC2 — NIR, NDA — No — Yes
- Mexico 9/8/2000 — 1QPC1 — Primary balance — No — No (Voluntary Rep.)
- Bolivia 6/8/2001 — 1QPC2 — Financing, fiscal balance — Yes
- Ghana 6/28/2001 — 1PA/CPC2 — External arrears, debt — No — Yes
- Tajikistan 7/11/2001 — 1CPC1 — External arrears — Yes
- Niger 8/3/2001 — 1PA1 — Closing of budget accounts — Yes
- Bosnia & Herzegovina 11/2/2001 — 1PA1 — Pension collections — Yes
- Ghana 2/4/2002 — 2QPC4 — Reserve money, debt, financing, primary balance, NFA — Yes 3/No (Previously Rep.)
- Tajikistan 2/13/2002 — 3CPC1 — External arrears — No — Yes
- Vietnam 6/21/2002 — 1QPC1 — NIR — Yes
- Senegal 9/25/2002 — 1PA1 — Tariffs/Prices — Yes
- Bosnia & Herzegovina 12/20/2002 — 1PA1 — Transfers between the entities and the State — Yes
- Tajikistan 12/11/2002 — 2CPC1 — External arrears — No — Previously Req.
- Djibouti 12/20/2002 — 1CPC1 — External arrears — Yes
- Chad 6/23/2003 — 1CPC1 — External arrears — No — Yes
- Lao, P.D.R. 7/9/2003 — 1QPC1 — Debt — Yes
- Tajikistan 7/18/2003 — 3PA/CPC1 — External arrears — Yes — No (Previously Req.)
- Argentina 8/27/2003 — 1SPC1 — Tariffs/Prices — Yes
- Gambia, The 3/8/2004 — 2QPC4 — NIR, financing, NDA, primary balance — Yes 3/Yes
- Ghana 7/9/2004 — 1PA1 — Tariffs/Prices — Yes
- Uganda 7/30/2004 — 1QPC1 — Debt — Yes
- Dominica 8/4/2004 — 4CPC1 — External arrears — Yes
- Uruguay 8/11/2004 — 1QPC1 — Primary balance — Yes
- Argentina 9/17/2004 — 2CPC1 — External arrears — Yes
- Dominican Republic 1/31/2005 — 1QPC2 — Fiscal balance, debt — Yes
- Burkina Faso 2/2/2005 — 1CPC1 — Debt — Yes
- Dominica 3/7/2005 — 1CPC1 — External arrears — Yes
- Rwanda 4/12/2005 — 1CPC1 — External arrears — Yes
- Turkey 4/26/2005 — 1QPC1 — Primary balance — Yes
- Mauritania 5/27/2005 — 1PA1 — Creating budget reports — No — Voluntary Rep.
- Congo, Dem. Rep. 8/29/2005 — 2CPC1 — Unauthorized expenditures — Yes
- Pakistan 11/2/2005 — 7CPC1 — Introduction of new tax exemptions — Yes
- Nepal 1/18/2006 — 1CPC1 — External arrears — Yes
- Serbia & Montenegro 2/6/2006 — 1QPC1 — Wage Bill ceiling — Yes
- Mauritania 3/27/2006 — 2QPC3 — NIR, NDA, financing — No — Yes
- Notes from table:
  - "QPC=Quantitative performance criteria; CPC=Continuous performance criteria; PA=Prior action; SPC=Structural performance criteria"
  - "A blank indicates no repurchase was required. Voluntary Rep. indicates the member repurchased the amounts prior to the Board discussion of misreporting, so no waiver of a noncomplying purchase was needed. Previously Req. indicates the Board had previously required the repurchase due to a prior finding of misreporting relating to the purchase in question."
  - "Waivers were not granted for all conditions."

*Source: Excerpt from IMF staff paper on Misreporting Guidelines and related procedures (sections C–F, Boxes 2–5).*

### 1.      Reliable and timely information is essential for all aspects of the Fund’s work.

### 1.      Reliable and timely information is essential for all aspects of the Fund’s work.

### Importance of reliable and timely information
- Reliable and timely information is essential for all aspects of the Fund’s work; without it the Fund cannot provide sound policy advice or confidently judge the basis for providing financial support.
- Poor data can lead to inaccurate assessments, inappropriate policy advice and program design, with negative outcomes and reputational effects for the member and the Fund.

### Legal framework on information provision and misreporting
- Provision of timely and accurate information to the Fund is the responsibility of the member; the Fund’s relationship of trust with the member is fundamental.
- The Fund’s legal framework on misreporting rests primarily on:
  - Article VIII, Section 5 (applies to all members; contains general provisions on the furnishing of information with qualifications relating to capacity and confidentiality).
  - The Guidelines on Misreporting and Noncomplying Purchases in the General Resources Account and disbursements under the Poverty Reduction and Growth Facility (PRGF) or the Exogenous Shocks Facility (ESF) (collectively the “Misreporting Guidelines”), which address misreporting in the context of Fund arrangements.
- Several other Fund policies also contain provisions on misreporting (e.g., the HIPC Trust Instrument, the decision on Policy Support Instruments, and the publication policy); collectively these comprise the Fund’s “misreporting framework.”

### Historical developments, amendments, and trends
- Episodes of egregious misreporting in the late 1990s prompted a firmer stance and amendments:
  - In 2000 the Misreporting Guidelines were amended to: lengthen the limitation period from two to four years; subject reporting on specified prior actions to the Guidelines; and grant waivers only if information provided to assess the performance criterion (or other relevant performance conditions) is accurate.
  - It was decided that all cases of misreporting would be made public.
  - In 2002 a framework to address cases of data revision under the HIPC Initiative was established.
  - A framework to strengthen the effectiveness of Article VIII, Section 5 was adopted in 2004.
  - The Policy Support Instrument decision adopted in 2005 contained provisions on misreporting.
- Increase in misreporting cases:
  - Since July 2000 there has been a sharp increase in the number of misreporting cases brought to the Executive Board.
  - The 37 misreporting cases brought to the Board in July 2000–March 2006 involved 49 conditions.
  - Of those 49 conditions, the most common were:
    - performance criteria on non-accumulation of external arrears: 12
    - fiscal balances: 7
    - debt: 6
    - net international reserves, net domestic assets or reserve money: 9
    - financing: 4
  - Outcomes: in six of the 37 cases the member had to make an early repurchase or repayment; in the other cases either the Board granted a waiver for nonobservance or the member had already made an advance repurchase (repayment).
  - There has been only one case of misreporting to arise exclusively under Article VIII, Section 5 since the 2004 Decision was adopted (Paraguay in 2005).
- Factors contributing to the increase:
  - Strengthened Misreporting Guidelines (including eight incidents relating to prior actions that were not subjected to the policy before 2000).
  - More vigilant Fund approach, leading to detection of incidents that may have gone unnoticed before; some involve de minimis deviations.

### Box 1 summary: Key elements of the Misreporting Guidelines
- Scope:
  - Apply to performance criteria and other conditions (e.g., prior actions) applicable to an outstanding purchase in the GRA or disbursement under the PRGF or ESF, and to information provided in the context of requests for waivers.
- Procedures:
  - Whenever staff has evidence that a performance criterion or other condition applicable to an outstanding purchase/disbursement may not have been observed, the Managing Director shall promptly inform the member concerned.
  - After consultation, if the Managing Director finds the criterion or condition was not observed, the Managing Director shall promptly notify the member and submit a report to the Board with recommendations.
- Action within the limitation period:
  - If the noncomplying purchase/disbursement was made no more than four years prior to the date on which the Managing Director informed the member, the Board may decide either:
    - (a) that the member shall be expected to repay or repurchase the outstanding amount normally within 30 days from the Board decision, or
    - (b) that the nonobservance will be waived.
- Waiver criteria:
  - A waiver will normally be granted only if the deviation was minor or temporary, or if subsequent corrective policy measures were adopted to achieve the objectives supported by the relevant decision.
- Publication:
  - After the Board has determined that misreporting occurred, the Fund proceeds to make relevant information public in every case, with Board review of the text for publication.

### Objectives in modifying the misreporting framework to address de minimis cases
- Rationale:
  - Existing misreporting procedures can be taxing in de minimis cases: large staff and authority time to establish data accuracy; management and Executive Director involvement; reputational cost disproportionate to trivial deviations; potential discouragement of data revisions.
- Fundamental objectives to preserve:
  - Preserve strong incentives for timely and accurate data reporting and maintain Fund capacity to address serious misreporting.
  - Ensure consistency with the Articles of Agreement, particularly Article VIII, Section 5; do not change the fundamental nature of Fund arrangements.
  - Maintain a “bright line” test under Fund arrangements for performance criteria observance, while retaining discretion when granting waivers (taking magnitude of nonobservance into account).
  - Promote uniformity of treatment across individual cases.

### Proposed modifications to the legal framework (focus on de minimis)
- Scope and approach:
  - Proposed package aims primarily to reduce stigma and procedural burden for de minimis misreporting in cases involving the use of Fund resources or support under the PSI.
  - Focus on Misreporting Guidelines; other relevant policies to be aligned.
  - Not proposed to amend policies to address de minimis misreporting in surveillance, except for “hybrid” cases involving misreporting for UFR/PSI and surveillance.
- Identifying and defining de minimis deviations:
  - The Managing Director would make the initial judgment whether misreporting is de minimis and whether special procedures apply; all cases would continue to be submitted to the Executive Board, which may reject management’s assessment.
  - Options for definition considered:
    - Precise or quantified definition (e.g., “deviations of no more than x”) — facilitates consistency but difficult to establish for all conditions and members.
    - Define as de minimis every misreporting case involving a deviation that meets the criteria for waivers — risks making most cases qualify and could reduce incentives for good reporting.
    - Staff-favored approach: (i) define de minimis as any deviation so small as to be trivial with no impact on assessment of performance under the program; and (ii) identify examples from experience as yardsticks.
  - Practical considerations:
    - Third approach relies on judgments by staff and management, with ultimate decision by the Board.
    - Repeated occurrences, even if small, would typically not be considered de minimis.
    - Structural reform misreporting may be difficult to judge as de minimis due to nonquantifiable implications.
- Examples of de minimis misreporting (from Table 1):
  - Mexico SBA2000 — Fiscal balance: data revision resulted in deviation from the target of $57 million (0.01 percent of GDP).
  - Tajikistan PRGF2001 — External arrears: $500,000.
  - Djibouti PRGF2002 — External arrears: SDR 59,214.
  - Dominica SBA/PRGF 1/2004 — External arrears: $326,300 (claim reclassified as external in 2004).
  - Dominica PRGF2005 — External arrears: $109,000 (delayed 29 days).
  - Rwanda PRGF2005 — External arrears: $25,145.
  - Congo, Dem. Rep. PRGF2005 — Structural PC: Central Bank failed to receive prior Treasury approval for purchases totalling $1 million (0.1 percent of total budgetary expenditures).
  - Pakistan PRGF2005 — Structural PC: tax exemption but had no budgetary implications.
  - Paraguay SBA 1/2005 — External arrears: $4 million.
  - Notes: Dominica (2004) was misreporting both under the Guidelines and Article VIII, Section 5. Paraguay (2005) was misreporting under Article VIII, Section 5 only, not under the Misreporting Guidelines, because no purchase was made as the SBA was treated as precautionary. In Mexico (2000) staff considered Article VIII, Section 5 but found no breach. The other examples did not involve Article VIII, Section 5 because it does not apply to PRGF-arrangements.
- Specific proposed modifications to the Misreporting Guidelines for de minimis cases:
  - Notifications:
    - Under current Guidelines the Managing Director must promptly notify a member that a noncomplying purchase/disbursement may have been made and that an enquiry is commenced, and if concluded, that a noncomplying purchase/disbursement was made.
    - For de minimis cases these notifications could be made by the Area Department and not by the Managing Director; a written response from the authorities would not be expected.
  - Board reporting:
    - When the Managing Director concludes a noncomplying purchase/disbursement was made, he must report to the Board with recommendations (normally a separate Board document).
    - For de minimis cases the Managing Director would still report and recommend but not normally in a separate Board document; findings/recommendations would be folded into other documents (e.g., Article IV or UFR staff report) and addressed in that Board meeting.
    - If no such document can be issued promptly, management would consult Executive Directors (e.g., informal country matters session) and, if appropriate, prepare a short stand-alone document for lapse-of-time consideration.
  - Waiver and publication:
    - If the Board agrees a case is de minimis, the Board would grant a waiver for nonobservance (the Guidelines already permit waivers when nonobservance is “minor” or “temporary”).
    - Cases of noncomplying purchases/disbursements arising from de minimis misreporting would be exempted from the general publication requirement and would no longer be published; such cases would not be mentioned in PINs, Chairman’s statements, factual statements or other public statements.
    - Once determined de minimis, management and the Board would have no discretion with respect to publication; in all such cases no publication of the misreporting would be made.
    - To correct the public record, the Fund would include in a Chairman’s statement, factual statement or PIN or other press release a statement clarifying that a waiver had subsequently been granted for nonobservance of a program condition, but without stating that the relevant condition was the subject of misreporting.
  - Publication of Board documents:
    - When de minimis misreporting is addressed within a broader Board document (e.g., Article IV staff report), sections dealing with the de minimis misreporting would be deleted before publication.
    - Stand-alone Board documents discussing de minimis misreporting cases would not be published.

*Prepared by Mr. Boote, Mr. MacArthur, Mr. Erickson von Allmen, and Mr. Hilaire (PDR) and Mr. Leckow, Ms. Mouysset, and Mr. Eastman (LEG).*

### 16.      Staff does not favor a more fundamental change to the Misreporting Guidelines under

### 070506 - 16.      Staff does not favor a more fundamental change to the Misreporting Guidelines under

### De minimis approach — staff position
- Staff does not favor treating de minimis misreporting as not misreporting at all because:
  - It would be difficult to administer.
  - It would reduce incentives for good reporting.
  - It would change the nature of a Fund arrangement.
- Staff proposes procedural adjustments that preserve recognition of de minimis cases while retaining misreporting as a legal category subject to streamlined procedures.

### Illustrative application — Rwanda (Box 2)
- Facts from the Rwanda case considered by the Board on April 11, 2005:
  - Rwanda accumulated $25,145 in new non-reschedulable external payments arrears in 2003.
  - This led to two non-complying disbursements under the PRGF and one disbursement of interim assistance under the Enhanced HIPC Initiative.
  - The Board considered a 10-page document, including letters and the Managing Director’s report, simultaneous with the fourth review under the PRGF arrangement.
  - Press release: IMF Executive Board Completes the Fourth Review of Rwanda’s PRGF Arrangement and Addresses Misreporting of Information (No. 05/85, 4/13/05).
  - The Board granted a waiver of nonobservance because the deviation was minor, had been settled in the interim, and had not endangered achievement of the other objectives of the PRGF-supported program.
- Under the proposed de minimis procedures the following would have applied:
  - The Area Department would notify the authorities about the misreporting incident rather than a letter from the Acting Managing Director; no formal reply required.
  - No separate Board document or separate Board meeting on the misreporting incident; a brief description of facts and a proposed waiver decision would be included in the PRGF review Board documents (Rwanda—Fourth Review Under the Three-Year Arrangement Under the Poverty Reduction and Growth Facility and Requests for Waiver of Nonobservance of Performance Criteria and for Extension of the Arrangement (IMF Country Report 05/171, May 2005)).
  - Information on misreporting would be excluded from the summing up and deleted from the staff report prior to publication (assuming publication agreed).
  - The approval of the waiver would be mentioned in the PRGF review press release without direct reference to the misreporting itself; example sentence: “The Board also approved a waiver of nonobservance of the continuous performance criterion on external arrears that was breached in the fourth quarter of 2003.”

### Article VIII, Section 5 — interaction and procedural treatment
- Broad points:
  - Whenever misreporting occurs in the context of using the Fund's general resources (GRA), Article VIII, Section 5 is broadly implicated.
  - Article VIII, Section 5 does not apply to misreporting under the PRGF, the ESF, or a PSI per se, but misreporting under those arrangements can lead to a breach of Article VIII, Section 5 if:
    - (i) the information is required by the Fund for purposes other than PRGF/ESF/PSI (e.g., surveillance or as specifically listed in Article VIII, Section 5 or the January 2004 Executive Board Decision strengthening Article VIII, Section 5), and
    - (ii) understandings exist that information reported in the context of PRGF/ESF/PSI is also reported for those other purposes.
- Recommendation:
  - If a misreporting case under GRA, PRGF, ESF, or PSI would be treated as de minimis under the revised Misreporting Guidelines, any potential breach of Article VIII, Section 5 should also be treated as de minimis under the Article VIII, Section 5 procedural framework.
- Procedural implications for de minimis Article VIII, Section 5 cases:
  - Preliminary communications may be sent by the Area Department rather than the Managing Director.
  - Managing Director’s findings and recommendations should be folded into other documents where possible (e.g., an Article IV or UFR staff report) and addressed in that Board meeting.
  - For de minimis cases involving a breach of Article VIII, Section 5, the framework would make clear that:
    - (i) no further action would be expected to be taken by the Fund with respect to the member; and
    - (ii) the finding of breach would not be published.
- Key procedural elements of Article VIII, Section 5 (Box 3) preserved exactly:
  - Managing Director consults with the member to assess whether inaccuracy is due to lack of capacity.
  - If not satisfied, MD notifies member of intention to report a breach to the Board unless the member demonstrates lack of capacity within a period of not less than one month.
  - If member fails to demonstrate lack of capacity, MD reports to the Board that he believes a breach has occurred.
  - The Executive Board decides whether a breach occurred and may call on the member to take specific measures; failure can lead to graduated measures including declaration of censure and application of sanctions under Article XXVI.
  - All Board decisions arising from a breach of obligation give rise to a public announcement with prior review of the text by the Board.
- Notes on time limits:
  - Noncomplying purchases/disbursements under the Misreporting Guidelines are subject to a four-year limitation period; no such limitation applies under Article VIII, Section 5.
  - For de minimis misreporting subject to Article VIII, Section 5 and arising more than four years before the MD informed the member of a potential noncomplying purchase, the Article VIII, Section 5 de minimis procedures would apply.

### Policy Support Instrument (PSI) — alignment with de minimis approach
- Current PSI misreporting framework (Box 4) — basic procedures preserved:
  - When evidence exists that reporting was inaccurate in relation to a PSI approved or a review completed within the preceding three years, the Managing Director shall promptly inform the member concerned.
  - If MD concludes inaccurate reporting occurred, MD shall promptly notify the member.
  - Board consideration of misreporting would normally take place at the next scheduled PSI review, based on a combined staff report; the Executive Board shall decide whether misreporting occurred and reassess program performance in light of that determination.
  - In all cases where the Board has determined misreporting occurred, relevant information and impacts would be published.
- Proposed modifications to the PSI decision to follow Misreporting Guidelines approach:
  - Preliminary communications in de minimis cases to be sent by the Area Department rather than the Managing Director.
  - The PSI decision would specify that cases of de minimis misreporting would, by definition, be regarded as having no effect on the assessment of program performance.
  - The PSI decision would specify that findings of de minimis misreporting, given their irrelevance for overall program performance, would not be published.
  - To correct the public record, the non-observance itself would be mentioned in a low-key fashion in any PIN, Chairman’s statement, factual statement, or other press release issued after the Board meeting on the paper in which the misreporting was handled.
- Implementation note:
  - Amending the PSI decision will require modification of the misreporting provisions in the PSI decision; provision would also be made for lapse of time handling when warranted.

### Enhanced HIPC Initiative — adjustments and de minimis treatment
- Two types of revisions in the HIPC framework (established 2002):
  - (i) Revisions to information used to calculate the amount of debt relief to be accorded to a member.
  - (ii) Revisions to information on the member’s track record used in deciding whether to make interim assistance available.
- Existing de minimis standard for debt relief calculation:
  - Upward and downward adjustments will be made only when the change in the U.S. dollar amount of HIPC Initiative assistance exceeds one percent of the targeted net present value (NPV) of debt after HIPC Initiative relief.
  - No change to this provision is proposed.
- Track record revisions and interim assistance:
  - The current framework does not incorporate an explicit de minimis standard for track record revisions; the Fund examines the magnitude of the change and decides whether disbursements remaining in the HIPC umbrella account should be transferred back to the HIPC Trust.
  - It is unlikely that a case of de minimis misreporting under a Fund arrangement would lead to retransfer of interim assistance under the HIPC decision.
- Proposed clarifications and procedures:
  - Amend the HIPC decision to make clear that cases of de minimis misreporting of track record information would not lead to a retransfer of resources to the HIPC Trust.
  - Apply procedures similar to the Misreporting Guidelines for de minimis track record cases:
    - (i) relevant communications with the member could be sent from the Area Department; and
    - (ii) such cases would normally be addressed in the context of a Board discussion of another issue or, if not possible, sent to the Board for consideration on a lapse of time basis.
  - Publication: propose excluding cases of de minimis misreporting of track record information from the HIPC Trust Instrument’s current publication requirement that “the Fund shall issue press releases on its decisions regarding the circumstances of the misreporting and the applicable remedies.”

- Main elements of the HIPC misreporting framework (Box 5) preserved exactly:
  - Adjustments to HIPC Initiative assistance only when change in U.S. dollar amount exceeds one percent of targeted NPV after HIPC relief.
  - Revisions to exports, GDP, or fiscal revenue give rise to downward adjustments only if related to information provided by or on behalf of the authorities.
  - Interim assistance transferred into the umbrella account could be returned to the PRGF-HIPC Trust if approved on the basis of inaccurate track record information.
  - HIPC Decision requires the Fund to issue press releases on decisions regarding the circumstances of misreporting and applicable remedies (subject to proposed exclusion for de minimis track record cases).

### Transparency and publication policy
- Current policy:
  - The publication policy requires the Fund to publish all cases of misreporting, with language calibrated to circumstances.
  - The principal Fund decision governing publication is the Transparency Decision, together with misreporting provisions in the Misreporting Guidelines, Article VIII, Section 5, the PSI, and the HIPC Trust.
- Proposed adjustments for de minimis cases:
  - De minimis findings would generally be excluded from publication under:
    - Revised Misreporting Guidelines (de minimis cases would not appear in staff report summings up and could be deleted prior to publication).
    - Article VIII, Section 5 procedural framework (finding of breach would not be published).
    - PSI decision amendments (findings of de minimis misreporting would not be published).
    - HIPC Trust Instrument amendment (de minimis track record misreporting excluded from publication requirement).
  - Where necessary to correct the public record, the non-observance or waiver approval would be mentioned in low-key language in the relevant press release or PIN without direct reference to the misreporting itself (illustrated by the Rwanda example).

*Source: Excerpt from IMF staff paper on Misreporting Guidelines and related procedures (sections C–F, Boxes 2–5).*

### Section III, Paragraph 3(d) of the HIPC Trust Instrument.

### Section III, Paragraph 3(d) of the HIPC Trust Instrument

### Proposed amendment and implementation
- "This will require an amendment to Section III, Paragraph 3(d) of the HIPC Trust Instrument."  
- "Each of these would be amended accordingly to implement the changes outlined above."

### Publication policy for de minimis misreporting
- When a member transaction or review triggers a public statement (e.g., Chairman’s statement, or factual statement) and it is later discovered that a condition was not met by a de minimis margin, the public record should be corrected.
- For cases of de minimis misreporting, the Fund would:
  - Publicize only the fact of nonobservance and the granting of a waiver.
  - Not make reference to the misreporting associated with the nonobservance and waiver.
  - Normally include this publication in a PIN, Chairman’s statement, or factual statement issued after the Board meeting on the paper into which the misreporting case is folded.
  - Correct the public record in a "fairly low-key fashion."

### Amendments to the Transparency Decision
- The Transparency Decision’s rules on permissible deletions in staff reports would be amended.
- Moving forward, the Transparency Decision would require deletion of discussions related to de minimis misreporting in Board documents that are to be published (e.g., an Article IV or UFR staff report).

### Analysis and conclusion
- Advantages of the proposed modifications:
  - May reduce the stigma and contentiousness of misreporting in de minimis cases.
  - Could reduce the amount of time spent on misreporting cases.
  - Leaves the Board discretion to decide whether a case is de minimis and whether to publish.
  - Preserves the Fund’s capacity to deal adequately with cases of misreporting.
- Drawbacks and risks:
  - Does not eliminate the time-consuming discovery process needed to protect the member and the Fund, though this should be less contentious.
  - May create incentives for members to more robustly request de minimis classification.
  - The stigma of misreporting might become worse for other ("near de minimis") cases.
- Staff view: "Overall, staff believes that the proposal outlined in this paper strikes a reasonable balance between reducing the cost of the misreporting framework in de minimis cases to members and the Fund while preserving incentives for good data reporting and the Fund’s capacity to deal with serious cases of misreporting."
- Next steps: After Executive Board discussion, draft decisions would be circulated to the Board, "possibly for consideration on a lapse-of-time basis."

### Issues for discussion (questions for Directors)
- "Should the Fund’s misreporting framework be revised to make it less onerous in cases involving de minimis deviations?"
- "Do Directors support the approach proposed in paragraph 11 to identify de minimis cases?"
- Do Directors agree that in de minimis cases:
  - "The requirement to publish information on the misreporting be abolished, and that to correct the public record, the procedures set out in paragraph 15 be followed?"
  - "A procedure would be established that notification to the member of misreporting be made by staff, and there would be no notification from the Managing Director directly. The Area Department could simply notify the authorities through a memorandum to the relevant Executive Director."
  - "The current practice of a separate Board Report from the Managing Director on the misreporting would be abolished, and that instead the misreporting discussion would normally be folded into other documents (e.g., Article IV or UFR). If these documents are published, the parts on de minimis misreporting would be deleted and they would not be mentioned in the Summing Up. Consequently, de minimis misreporting would generally be handled in the context of regular Board meetings."

### Key statistics and historical cases (Table A1: Cases of Misreporting Discussed by the Board)
- Table covers misreporting cases "through end-March 2006."
- Columns shown include: Member, Board Date, Number of Purchases affected, Performance Criteria/Prior Actions Affected (Type/Number of conditions affected), Type of variable affected, Waivers (Yes/No), Repurchase Required (Yes/No), and Notes.
- Selected entries (preserving exact dates and descriptors):
  - Mauritius 8/28/1985 — 1CPC1 — Debt — Yes
  - Zaire 9/20/1985 — 1QPC1 — Debt — Yes
  - Senegal 7/23/1986 — 1QPC1 — Debt — Yes
  - Mauritania 12/19/1988 — 1CPC1 — External arrears — Yes
  - Hungary 2/21/1990 — 3QPC1 — Debt — No — Yes
  - Philippines 4/9/1990 — 1QPC1 — NIR — Yes
  - Ukraine 12/13/1995 — 1CPC1 — External arrears — Yes
  - Tajikistan 7/2/1999 — 1QPC1 — Debt — Yes
  - Pakistan 9/3/1999 — 1QPC1 — Fiscal balance — Yes
  - Pakistan 4/29/2000 — 1QPC1 — Debt — No — Yes
  - Malawi 8/23/2000 — 1CPC1 — Domestic arrears — Yes
  - Ghana 8/21/2000 — 1CPC1 — Multiple currency practices — Yes
  - Ukraine 9/6/2000 — 2QPC2 — NIR, NDA — No — Yes
  - Mexico 9/8/2000 — 1QPC1 — Primary balance — No — No (Voluntary Rep.)
  - Bolivia 6/8/2001 — 1QPC2 — Financing, fiscal balance — Yes
  - Ghana 6/28/2001 — 1PA/CPC2 — External arrears, debt — No — Yes
  - Tajikistan 7/11/2001 — 1CPC1 — External arrears — Yes
  - Niger 8/3/2001 — 1PA1 — Closing of budget accounts — Yes
  - Bosnia & Herzegovina 11/2/2001 — 1PA1 — Pension collections — Yes
  - Ghana 2/4/2002 — 2QPC4 — Reserve money, debt, financing, primary balance, NFA — Yes 3/No (Previously Rep.)
  - Tajikistan 2/13/2002 — 3CPC1 — External arrears — No — Yes
  - Vietnam 6/21/2002 — 1QPC1 — NIR — Yes
  - Senegal 9/25/2002 — 1PA1 — Tariffs/Prices — Yes
  - Bosnia & Herzegovina 12/20/2002 — 1PA1 — Transfers between the entities and the State — Yes
  - Tajikistan 12/11/2002 — 2CPC1 — External arrears — No — Previously Req.
  - Djibouti 12/20/2002 — 1CPC1 — External arrears — Yes
  - Chad 6/23/2003 — 1CPC1 — External arrears — No — Yes
  - Lao, P.D.R. 7/9/2003 — 1QPC1 — Debt — Yes
  - Tajikistan 7/18/2003 — 3PA/CPC1 — External arrears — Yes — No (Previously Req.)
  - Argentina 8/27/2003 — 1SPC1 — Tariffs/Prices — Yes
  - Gambia, The 3/8/2004 — 2QPC4 — NIR, financing, NDA, primary balance — Yes 3/Yes
  - Ghana 7/9/2004 — 1PA1 — Tariffs/Prices — Yes
  - Uganda 7/30/2004 — 1QPC1 — Debt — Yes
  - Dominica 8/4/2004 — 4CPC1 — External arrears — Yes
  - Uruguay 8/11/2004 — 1QPC1 — Primary balance — Yes
  - Argentina 9/17/2004 — 2CPC1 — External arrears — Yes
  - Dominican Republic 1/31/2005 — 1QPC2 — Fiscal balance, debt — Yes
  - Burkina Faso 2/2/2005 — 1CPC1 — Debt — Yes
  - Dominica 3/7/2005 — 1CPC1 — External arrears — Yes
  - Rwanda 4/12/2005 — 1CPC1 — External arrears — Yes
  - Turkey 4/26/2005 — 1QPC1 — Primary balance — Yes
  - Mauritania 5/27/2005 — 1PA1 — Creating budget reports — No — Voluntary Rep.
  - Congo, Dem. Rep. 8/29/2005 — 2CPC1 — Unauthorized expenditures — Yes
  - Pakistan 11/2/2005 — 7CPC1 — Introduction of new tax exemptions — Yes
  - Nepal 1/18/2006 — 1CPC1 — External arrears — Yes
  - Serbia & Montenegro 2/6/2006 — 1QPC1 — Wage Bill ceiling — Yes
  - Mauritania 3/27/2006 — 2QPC3 — NIR, NDA, financing — No — Yes
- Notes and footnotes in the table:
  - "QPC=Quantitative performance criteria; CPC=Continuous performance criteria; PA=Prior action; SPC=Structural performance criteria"
  - "A blank indicates no repurchase was required. Voluntary Rep. indicates the member repurchased the amounts prior to the Board discussion of misreporting, so no waiver of a noncomplying purchase was needed. Previously Req. indicates the Board had previously required the repurchase due to a prior finding of misreporting relating to the purchase in question."
  - "Waivers were not granted for all conditions."

*Source: Section III, Paragraph 3(d) of the HIPC Trust Instrument (text as provided).*

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_Source: https://www.imf.org/-/media/websites/imf/imported-full-text-pdf/external/np/pp/eng/2006/_070506.pdf_