## _040714 ## Source details **Canonical URL:** [_040714](https://www.imf.org/-/media/websites/imf/imported-full-text-pdf/external/np/pp/eng/2014/_040714.pdf) ## Other formats - [Markdown version](/-/media/websites/imf/imported-full-text-pdf/external/np/pp/eng/2014/_040714.pdf.md) - [Structured JSON version](/-/media/websites/imf/imported-full-text-pdf/external/np/pp/eng/2014/_040714.pdf.json) --- ### Main Changes to the Transparency Policy (Box 1) - Extend the stronger publication regime to all UFR and PSI staff reports; publication of country documents remains subject to the members’ consent. - Define “prompt publication” as being no later than 14 days: publication within 14 days of the Board date or 28 days of issuance to the Board, whichever is later; staff will strive to publish policy documents within seven days if the Board agrees to publication. - Introduce lower-profile publications for reports published more than 90 days after Board consideration. - Issue Factual Statements at 28 days if certain country documents or related press releases have not been published. - Use only the term “press release” for external communications; discontinue “Public Information Notice” (PIN). - Create a new category of multi-country documents. - Provide further guidance on treatment of members’ confidential information and encourage staff to explain confidentiality rules at mission start. - Replace the previous exhaustive list of documents covered by the policy with an “indicative list.” ### Prompt publication and timing rules - “Prompt publication” target: publication within 14 calendar days after the Board date, or 28 calendar days after issuance to the Board, whichever is later. - For multi-country documents the 14-day guidance applies even if one or more countries have not yet consented to publication. - Staff should encourage authorities to publish within 14 days but this is not a strict deadline. - Policy papers: staff should strive for publication within seven days of the Board date. - Country documents normally published within 14 days after the Board date; if not published within 28 days, a factual statement will be issued immediately. - Documents published after 90 days: publish in a lower-profile manner and exclude from the Fund’s “what’s new” website section. ### Publication regime and consent - Publication regime for country documents: “voluntary but presumed” (publication subject to member consent; Fund encourages consent). - Exception: certain factual statements (e.g., on waivers) are country documents covered by the Decision but can be published without member consent. - Stronger presumption of publication applies to all staff reports relating to the use of Fund resources (UFR) and policy support instruments (PSIs); publication remains voluntary. - Members requesting UFR or PSI are expected to indicate consent to publication before circulation to the Board. - Managing Director’s guidance when member withholds consent: - Generally will not recommend Board approval of requests for (i) access to resources in the General Resources Account or the PRGT, (ii) access under the HIPC Trust, or (iii) assistance through a PSI, unless the member explicitly consents to publication of the associated staff report. - Will not recommend approval of (i) an arrangement under the PRGT or completion of a review under such arrangement, (ii) a HIPC decision point or completion point decision, or (iii) a member’s request for a PSI or completion of a review under a PSI, if the member does not explicitly consent to publication of its I-PRSP, PRSP, PRSP preparation status report, or PRSP annual progress report. - If a member consents then later withdraws consent after Board consideration, staff will inform management and the relevant ED immediately; the Board will be informed no later than the next review. ### Consent mechanics and timelines - Typical consent obtained on a “non-objection” basis: standing consent to publish promptly after the Board date unless the member informs the Fund otherwise in advance. - If by the Board date the member objects, requires more time, or consents subject to modifications, staff should act accordingly. - Members requiring additional time expected to inform the Fund of a final decision within 28 calendar days of the Board date. - Members may “opt out” of the non-objection system by written notification; this will be recorded by SEC and on the cover memorandum of every report about the member when issued to the Board. - Papers circulated to the Board for information: explicit consent from the member required to publish. ### Drafting guidelines (Box 2) — key rules for staff reports - No negotiated documents: staff reports must not be negotiated with country authorities. - No sharing of draft country documents, except for specified items (drafts of press releases; Selected Issues Papers; ROSC modules, EPA/EPE reports, FSAP aide-mémoires and FTNs, aide-mémoires, DARs, TA reports; wording describing authorities’ views). - No surprises: ensure major issues have been discussed with authorities before publication. - Authorities’ right of reply: authorities may issue a statement (ED’s BUFF or separate “authorities’” statement) to be published alongside the staff report. - Provide candid and comprehensive assessments; publication intentions should not affect candor. - Accurately characterize counterparts’ views and identify third-party sources where permitted. - Avoid politically divisive or gratuitous language. - Do not include information provided to staff on the understanding it will remain confidential (unless required under the Articles or critical for Board decision); clarify confidentiality when in doubt. ### Staff communication with authorities on publication (Section 14) - Staff must discuss the publication process with authorities during missions and at latest by the Board date. - Ensure authorities are aware of key elements of the Transparency Policy (including publication regime and modification policies). - Record publication intentions on the cover memorandum when the paper is issued to the Board. - For UFR/PSI: management will generally not recommend approval unless the member consents to publication of the related staff report before the Board date; consent should be obtained before circulation to the Board. - Remind members about non-objection implications and request confirmation from those who opted out before conclusion of Board consideration. - Reminders are not a reason to delay publication once document is ready; authoring department should inform SEC and COM and communicate publication date to the relevant ED. - Deadlines for modification requests and logistics: - Requests expected no later than two business days before the relevant Board meeting or date of adoption of LOT decision. - Requests shall normally be submitted no later than seven calendar days after the Board date or 21 calendar days after issuance to the Board, whichever is later. - Requests to SEC at the latest by noon the day before the required circulation date. - SPR requires 24 hours to clear requests. ### Modifications to country documents — corrections and deletions - Modifications are tightly controlled; except for bona fide administrative errors, all modifications are guided by Transparency Policy rules. - Corrections: - Modify the original document; may be made by staff initiative or at authority/ED request. - Requests expected no later than two business days before the Board date. - Limited to: typographical errors; factual errors; mischaracterization of authorities’ views; evident ambiguity. - Corrections after the Board date must meet criteria (brought to Board attention before conclusion; or failure to correct would undermine publication value). - Corrections should retain original text where possible; should not be used to facilitate publication, improve presentation, extend arguments, or add/update data post-issuance. - For corrections with significant implications, staff must provide rationale and discuss implications in the corrections memorandum; the original document is corrected for publication but corrections memorandum is not published. - Primary responsibility: authoring department; SPR sign-off required for corrections with significant implications or where judgment is needed. - Deletions: - Made to the published version only; typically requested by the primary country or, rarely, by a third party member under conditions. - Deletions expected in writing no later than two business days before the Executive Board date; normally no later than seven calendar days after Board consideration or 21 calendar days after issuance, whichever is later. - Deletions limited to information not already public that is either: - Highly market-sensitive material (all criteria must apply: not public; market-relevant in near term; sufficiently specific to risk triggering a disruptive market reaction), or - Premature disclosure of policy intentions (rare; all listed criteria must apply). - Politically sensitive information that does not meet the above grounds shall not be deleted. - Information on performance/assessment/quantitative/structural benchmarks related to UFR/PSI/SMP may not be deleted unless such information would have been eligible for communication in a side letter. - Deletions can include minor rephrasing to retain candor but must not add substance or mislead; not normally used to remove large portions. - Primary responsibility: authoring department; SPR sign-off required when judgment is needed or criteria not clearly met. ### Resolving disagreements on deletion requests - Management approval of deletions delegated to department Directors; explicit management approval needed only if disagreement between Directors or between staff and authorities. - If staff and authorities disagree: - Authorities or their ED can present concerns to management. - Serious disagreements can be referred to the Executive Board by the ED or Managing Director. - For Article IV/regional surveillance staff reports, if Managing Director approves third-party deletions and primary member disagrees, the matter may be referred to the Executive Board by the Managing Director or the ED of the primary member. - If the Managing Director believes deletions would undermine the Fund’s overall assessment and credibility, the Managing Director shall recommend to the Board that the document not be published. ### Removal of references and preparatory steps before publication - Prior to publication remove: - Internal documents not in the public domain; do not reference internal reference numbers for published internal documents. - Internal processes that should not be disclosed (inquiries on misreporting, breaches of obligations). - Legal texts of arrangements and decisions (Fund does not publish legal texts of members’ arrangements or related decisions). - To implement corrections/deletions authoring department should: - Prepare separate memoranda to SEC for corrections and deletions (templates in Appendices VII–VIII). - Provide brief justification for each substantive modification that is not self-explanatory. - For deletions, attach authorities’ written requests for record-keeping (e-mails acceptable) but do not circulate them to the Board. - Strengthened recordkeeping: teams must copy SPR when corrections/deletions memoranda are sent to SEC. - Obtain SPR sign-off when required and indicate it in the memorandum. ### Handling confidential information - Staff/management must disclose to the Executive Board any information required under the Articles or necessary for Board decisions; staff should not agree with authorities to withhold such information from the Board. - Members are not obliged to provide information revealing individuals or specific financial institutions/corporations; safeguards preserve confidentiality. - Confidential information that is highly market sensitive or premature policy intentions can be deleted from staff reports under deletion criteria. - Even when information must be provided to the Board, confidentiality vis-à-vis the public remains: neither the Executive Board nor EDs can publish information provided on the understanding it remains confidential, unless the member consents. - During missions staff should: - Provide authorities with detailed information on safeguards for confidential information. - Ensure common understanding of what should remain confidential and whether it can be shared with the Board and/or the public. - Reviewers should watch for inadvertent inclusion of confidential information and ensure confidential information relating to individual financial institutions in FSAPs is not included in FSSAs. ### Press releases — scope, timing, factual statements and bundles - Press releases issued following certain Board meetings or LOT decisions; term PIN discontinued. - Cases warranting press releases include: Article IV, regional surveillance, stand-alone FSSAs, PPM, EPA, EPE, and combined permutations; content comprises introductory section and Board’s summing up and/or chairman’s statement as applicable. - Timing and responsibility: - Authoring department must ensure press releases are issued as soon as possible after Board consideration, provided authorities consent. - UFR/PSI and combined cases: press releases normally released immediately after Board consideration on the same day. - Article IV/regional surveillance/FSSA: press releases published along with staff report when member consents to publication. - If staff report not expected within seven days of the Board date, a press release should be issued immediately and not delayed. - Press releases will be translated into other languages when feasible. - Factual statements when documents not published within 28 days: - If after 28 calendar days a member has not consented to publication of a press release covering the Board assessment, a brief factual statement will be issued immediately in press-release form stating Board consideration took place. - If after 28 calendar days the staff report or staff report and related press release have not been published, the area department will arrange for a brief factual statement to be added to the country page on the Fund’s external website (not as a press release) clarifying authorities’ publication intentions; factual statements can be updated. - Area departments must submit a draft factual statement to COM one day before the 28-day period elapses; Fund does not seek consent of country authorities for factual statements using standard language. - Following Board consideration of a UFR or PSI: if member does not consent to a Chairman’s statement press release, a brief factual statement will be issued immediately as a press release describing the Board’s decision on use of resources or PSI approval/review. - Publication bundles and preparation: - Country staff reports published in a bundle with supplements or staff statements circulated to the Board and the press release. - Bundle will reference other relevant documents published separately (e.g., Selected Issues Paper, FSSA, ROSC modules, LOI/MEFP, PRSP documents). - Authoring department responsibilities in preparing the bundle include: ensure corrections/deletions incorporated; remove draft press releases/draft arrangement texts; remove internal reference numbers; check ED consent for publishing ED’s statement; prepare an electronic single-file bundle; coordinate publication with COM and inform relevant ED of publication date; consult COM and SEC if publication requested within 48 hours after finalizing bundle. ### Policy documents, timing, modification rules and press releases - Presumption that all policy papers, with few exceptions, will be published; exceptions include administrative matters (except those on Fund income/financing/budget not involving market-sensitive information). - Authoring departments should consult COM where policy documents or documents related to Fund’s financial position are not proposed for publication. - The Board decides on publication of policy papers and related press releases based on staff recommendations; Board consent deemed given if no Director objects in meeting or by SEC cover memo date; objection allows Board to decide by simple majority of votes cast. - Timing: - Staff will strive to publish policy papers within seven days of the Board date. - Policy papers sent to the Board for information only normally published no later than 14 days after issuance to the Board. - If multiple staff papers on repeated policy issue, normally publish each within seven days of relevant Board date. - Modifications prior to publication: - Staff may make factual corrections, deletions, and rephrasing guided by Transparency Policy rules. - Modifications without management approval: editing for publication; factual corrections limited to information available at time of issuance; deletions of country-specific references containing unpublished Fund views/confidential information; removal of references to internal processes; clarifying differences between Board and staff recommendations (with staff positions not endorsed by the Board indicated). - All other modifications require management approval; authoring department should request approval in a memorandum copied to SPR, LEG, and COM explaining rationale. - Board must be informed of all modifications to the Board version of any paper; authoring department sends memorandum to SEC (cc SPR) listing changes with redline; SEC circulates changes to the Board for information. - Staff may revise a policy paper where staff has modified its views in light of Board discussion or significant new developments; a staff report cannot be modified to reflect Board’s views unless staff and management share those views; once a Board decision adopted, staff report cannot be revised to reflect staff view changes if decision was adopted on basis of original paper. - Press releases for policy documents: - Can be stand-alone or with the underlying policy document; should be based on Board decision and/or summing up with a short factual background. - Draft introductory section should be attached when paper circulated to the Board and sent to COM for comments before circulation. - If policy document not expected to be published within seven days of Board date, a press release will be issued shortly after the Board date. - Press releases will be translated into other languages when feasible. ### Multi-country documents: definitions, sub-categories and special rules - Multi-country documents apply where analysis covers more than one country or is not focused exclusively on Fund policy issues; procedures can be applied to whole documents or material sections. - Three sub-categories: - Multilateral Policy Issues Documents (e.g., WEO, GFSR, FM). - Country Background Pages: country-specific sections that can be issued alongside a multilateral policy issues paper or policy paper; consent of a concerned member required to publish that section. - Cluster Documents: cross-cutting issues affecting a discrete group of countries with integrated country discussions. - Publication rules: - Country Background Pages: Fund will strive to publish within 14 days of Board date or 28 days from issuance to the Board, whichever is later. If one or more members need more time, staff will wait 14 days before publishing (document may be published without those pages); updated versions posted when members decide to publish or agree deletions; country background pages always include full list of all countries involved. - Cluster Documents: publication requires consent of all concerned members (non-objection basis); if one or more members object, document shall not be published; document is published along with a press release. - Each concerned member may request deletions/corrections in accordance with country document procedures. - Timing/press-release rules for Cluster Documents: if not expected to be published within seven days of Board date, authoring department will arrange a press release shortly after the Board if members consent; press release should not be issued before the summing up is circulated as a final Fund document. ### Appendices — selected numeric timing and publication expectations - Publication may not occur before the Board date unless indicated otherwise. - “Prompt publication” defined as within 14 calendar days from the Board date or 28 calendar days from issuance to the Board, whichever is later. - Key timeline milestones (post-Board): - 7 calendar days after BD - 28 calendar days after BD - 14 calendar days after BD or 28 calendar days after issuance to the Board, whichever is later (notification of expected date of publication to ED) - 7 calendar days after BD, or 21 calendar days after issuance to the Board, whichever is later (deadline for requests for deletions) - 90 days after BD (documents published after this will not be included in the “what’s new” section) - Modification deadlines: - Requests expected as soon as possible, no later than two business days prior to the Board date. - Requests for deletions normally no later than seven calendar days after Board consideration or 21 calendar days after issuance to the Board, whichever is later. - Administrative errors (Appendix VI): bona fide administrative errors are rectified through reissuance with certification by authoring department head(s); reissuance procedures include notifying management and ED(s), submitting corrected documents to SEC within one business day, and SEC replacing the wrong document in its repository. - Templates and procedural guidance provided for memoranda to SEC on corrections and deletions; SPR sign-off required in specified cases. ### Legal foundations and rules protecting confidential information (Appendix IX introduction; Legal Department) - Legal bases: - Article IX, Section 5: archives inviolable; non-public documents protected and cannot be published/produced without Fund approval. - Article XII, Section 8: Fund should not publish the Executive Board’s views regarding a member without the member’s consent except in specified circumstances (70 percent majority provision has not been used). - Internal rules and conduct: - Rules N-6 and N-11, Staff Code of Conduct, and General Administrative Order No. 35 prohibit unauthorized disclosures. - Principle: Executive Board, management and staff may not disclose information provided in confidence unless the party consents and disclosure is consistent with Fund rules; where doubt exists, give benefit of doubt to member. - Circumstances requiring disclosure to the Executive Board despite claims of confidentiality: - Information required to be reported under the Articles. - Where Board-established policy requires disclosure of certain information. - Where information is critical for the Board to exercise responsibilities meaningfully. - Continued confidentiality vis-à-vis the public: even when information is provided to the Board, it remains confidential to the public unless the member consents to publication. ### Roles, responsibilities and language/translation rules (selected operational points) - Authoring department must send COM drafts of press releases on policy matters and multilateral policy issues documents (introductory paragraphs and draft summing up) for COM advice. - Final press release released as soon as final text received by COM from SEC; goal: release press releases and policy documents within 7 calendar days of the Board discussion. - LOT cases press release format: normally 3–4 pages with (i) factual introductory section including a table of economic indicators and (ii) Executive Board Assessment (staff appraisal verbatim except for permitted corrections/deletions). - UFR and PSI LOT and non-LOT: factual statements required immediately in specific non-consent situations and press releases may include program facts. - Publication in Languages Other than English (LOE): English versions presumed cleared in substance; one LOE posting per document generally permitted; translations must accurately reflect published English versions and note English versions prevail where applicable. - Templates provided for factual statements and for memoranda to management requesting approval of modifications. *Guidance Note on the Fund’s Transparency Policy, April 7, 2014.* ### 1. Main Changes to the Transparency Policy in the 2013 Review ________________________ 5 ### _040714 - 1. Main Changes to the Transparency Policy in the 2013 Review ________________________ 5 ### Main Changes (Box 1) - Extend the stronger publication regime to all UFR and PSI staff reports. The stronger presumption of publication previously applicable only to FCLs and exceptional access UFR has been extended to apply to all UFR and PSI cases. The publication of country documents remains subject to the members’ consent. - Define “prompt publication” as being no later than 14 days. To help speed up publication, “prompt publication” is defined as being publication within 14 days of the Board date or 28 days of issuance of a document to the Board, whichever is later. Country authorities and staff are encouraged to publish country documents within the timeframe, although it is not a deadline. Staff will strive to publish policy documents within seven days, if the Board agrees to publication. - Introduce lower-profile publications for reports published more than 90 days after Board consideration. - Issue Factual Statements at 28 days. If certain country documents or related press releases have not been published within 28 days of the Board date, the Fund will immediately issue a Factual Statement confirming that Board consideration took place and indicate the authorities’ publication intentions. - Use only press releases for external communication, discontinue PINs. Only one term—press release—will be used for external communications products; the term “Public Information Notice” (PIN) is discontinued. Press Releases will be issued shortly after Board consideration of Article IV consultations, regional surveillance discussions and standalone FSSAs. If the staff report is expected to be published later than seven calendar days after the Board date, the press release should be issued immediately. - Create a new category of multi-country documents. - Provide further assurances regarding the Fund’s treatment of members’ confidential information, through guidance to staff on the kinds of information that need to be included in staff reports, and what constitutes confidential information. Staff teams are encouraged to explain the Fund’s rules on confidentiality at the start of each mission, while departmental reviewers are expected to watch for inadvertent inclusion of confidential information in staff reports. - Clarify the coverage of the policy. To reflect the flexibility of coverage, the previous exhaustive list of documents covered by the policy has been replaced by an “indicative list.” ### Prompt publication and timing rules - The Decision states the Fund will aim to publish documents subject to the Decision no later than 14 calendar days after the Executive Board meeting, informal Board session, or adoption of an LOT decision (the “Board date”), or 28 days after the document has been issued to the Executive Board, whichever is later. - For multi-country documents the 14-day guidance applies, even if one or more countries have not yet consented to publication. - Staff should encourage country authorities to publish within the 14-day timeframe, though it is not a deadline. - In the case of policy papers, staff should strive for publication within seven days of the Board date. - Country documents will normally be published within 14 days after the Board date. If they are not published within 28 days, a factual statement will be issued immediately. - Some documents circulated to the Board for information only (e.g., I-PRSPs, PRSPs, ROSCs, and AFSSRs) may be published immediately after their circulation to the Executive Board. - Documents published after 90 days will be published in a lower-profile manner and shall not be included under the “what’s new” section of the Fund’s external website. ### Publication regime and consent - The publication regime for all country documents covered by the Decision is “voluntary but presumed.” “Voluntary” means publication is subject to the consent of the member concerned. “Presumed” means the Fund encourages each member to consent to publication in line with the Fund’s Transparency Principle. - Exception: factual statements issued to the Board on Fund decisions on waivers of applicability or for nonobservance of performance criteria and waivers for nonobservance of assessment criteria are country documents covered by the Decision but can be published without the member’s consent, as they are factual statements. - Stronger presumption of publication applies to all staff reports relating to the use of Fund resources (UFR) and policy support instruments (PSIs), though their publication is voluntary. Members requesting access to Fund resources or support under the PSI are expected to indicate, before circulation to the Board, that they consent to publication of the related staff reports. - A member’s decision not to consent to publication of the staff report may affect management’s recommendation to the Board regarding approval of its request for access to Fund resources or support under the PSI: - The Managing Director will generally not recommend Board approval of a request for (i) access to resources in the General Resources Account or the PRGT, or (ii) access to Fund resources under the HIPC Trust, or (iii) assistance through a PSI, unless the member explicitly consents to publication of the associated staff report. - The Managing Director will not recommend Board approval of (i) an arrangement under the PRGT or completion of a review under such arrangement, or (ii) a HIPC decision point or completion point decision, or (iii) a member’s request for a PSI or the completion of a review under a PSI, if the member concerned does not explicitly consent to publication of its I-PRSP, PRSP, PRSP preparation status report, or PRSP annual progress report. - If a member initially consents to publication but then changes its mind after the Board’s consideration, staff would immediately inform management and the relevant ED. The Board would be informed at the earliest opportunity and no later than the time of the next review. ### Consent mechanics and timelines - A member’s consent to publish is typically obtained on a “non-objection” basis: the member provides standing consent for all its country documents to be published promptly after the Board date unless it informs the Fund otherwise in advance. - If, by the Board date, the member notifies the Fund that it objects to publication, requires additional time, or consents subject to agreement on modifications, staff should act accordingly. - Members that require additional time are expected to inform the Fund of their final decision within 28 calendar days of the Board date. Members that request additional time may still decide to publish after 28 days; in such cases publication proceeds only upon explicit consent. - A member may “opt out” of the “non-objection” system by notifying the Fund in writing that its country documents should be published only with its explicit consent. This notification may be transmitted via the member’s Executive Director (ED) and will be recorded by SEC and on the cover memorandum of every report about the member when it is issued to the Board. - For papers circulated to the Board for information, explicit consent from the member to publish is required. ### Drafting guidelines (Box 2) - No negotiated documents. Staff reports must not be negotiated with country authorities. - No sharing of draft country documents, except for a few listed below. Staff may not share draft country documents with country authorities or EDs. This rule extends to AFSSRs, FSSAs, JSANs, and HIPC Decision and Completion Point Documents. The following can be shared: - Drafts of press releases; - Selected Issues Papers; - ROSC modules, EPA and EPE reports, FSAP aide-mémoires and FTNs, aide-mémoires, detailed assessment reports (DARs), and TA reports; and - Wording describing the authorities’ views. - No surprises. Staff should ensure major issues in the staff report have been discussed with the authorities so there are no surprises when they see the document. - Authorities’ right of reply: When there are major differences of views, staff may remind the authorities they can issue a statement (in the form of an ED’s BUFF statement or a separate “authorities’” statement) to be published alongside the staff report as part of the document bundle. The “right of reply” statement can be the original ED’s BUFF statement or a revised version of the original. - Provide candid and comprehensive assessments. Authorities’ publication intentions should not affect candor and comprehensiveness of staff reports. Staff should discuss publication intentions with authorities during missions, but generally not refer to them in staff reports. - Accurately characterize counterparts’ views. Counterparts’ views should be properly characterized as official views of authorities, views of institutions, or personal views. When reporting third-party views, staff should identify their source (to the extent permitted by confidentiality needs) and clarify whether these views are shared by staff. - Avoid politically divisive or gratuitous language. Staff should avoid formulations that may be considered insulting or divisive in the member country while providing candid assessments. - Do not include information provided by the member on the understanding it will remain confidential to staff (unless required to be reported to the Fund under the Articles or staff believes it is critical for the Board to make a decision). In case of doubt, staff should clarify with the authorities whether information is meant to remain confidential within staff/management, or whether it can be shared with the Board and/or the public. *Guidance Note on the Fund’s Transparency Policy, April 7, 2014.* ### 14. Staff should discuss the publication process with the authorities during the mission ### 14. Staff should discuss the publication process with the authorities during the mission ### Publication process communication and timing - Staff should discuss the publication process with the authorities during the mission and at the latest by the Board date to ensure understanding and expedite publication after the Board date. - Staff should ensure authorities are aware of the key elements of the Transparency Policy (see Appendix V), including: - A summary of the publication regime for relevant documents. - The modification policies. - Staff should seek to ascertain the authorities’ publication intentions well before the Board date. Publication intentions will be recorded on the cover memorandum when the paper is issued to the Board. - For UFR/PSI, management will generally not recommend approval of a member’s request or completion of a review unless the member consents to publication of the related staff report before the Board date. Consent should be obtained before the UFR/PSI staff report is circulated to the Board. - Staff should remind members of the implications of the non-objection procedure for publication (paragraphs 9-10). For countries that have consented on a non-objection basis, staff are encouraged to remind country authorities immediately after the country paper has been issued to the Board that the document will be published promptly after Board consideration unless an objection is received prior to the Board conclusion. - Staff should request that countries that have opted out of the non-objection procedure confirm their publication intentions before the conclusion of Board consideration. - Reminders should not be viewed as a reason to delay publication pending consent. Once the document is ready for publication, the authoring department should inform SEC and COM, and communicate the date of publication to the relevant ED. The Executive Board will be informed of these intentions in the cover memorandum prepared by SEC. ### Deadlines and logistics for publication and modification requests - Staff should remind authorities of modification request deadlines and SEC’s circulation deadlines: - Requests are expected to be submitted to the area department no later than two business days before the relevant Board meeting or date of adoption of LOT decision. - Requests shall normally be submitted no later than seven calendar days after the Board date or 21 calendar days after the issuance of document to the Board, whichever is later. - Requests should be submitted to SEC at the latest by noon the day before the required circulation date. - SPR requires 24 hours to clear requests. ### Modifications to country documents — overview - Modifications are tightly controlled to protect the integrity of Fund documents. Except for bona fide administrative errors certified by head(s) of authoring department(s), all modifications are guided by the rules under the Transparency Policy. - Modifications are limited to: - corrections (to the original, and thus also to the document to be published); and - deletions (to the document to be published, but not affecting the original). - Modifications should be parsimonious and adhere to the specified rules. ### Rules for corrections - Corrections modify the original version of the document and can be made by staff on its own initiative, or at the request of country authorities or an ED. - Requests for corrections are expected to be submitted to the area department no later than two business days before the Board date. - Corrections are only to ensure factual accuracy and are limited to correcting: - typographical errors; - factual errors; - mischaracterization of the authorities’ views; or - evident ambiguity, i.e. the possibility of a plausible, specific misinterpretation. - Corrections after the Board date must fall into one of the four permissible categories and are limited to cases where: - the correction is brought to the attention of the Board before the conclusion of the Board’s consideration of the document; or - the failure to make the correction would undermine the overall value of the publication. - Staff should aim to retain as much of the original text as possible while rectifying the error or removing ambiguity; the underlying meaning should not be altered. - Corrections should not be used to: - facilitate publication; - improve the presentation; - extend the staff’s or the authorities’ arguments; or - add information or update data based on new information received after the report has been issued to the Board. - For corrections with significant implications for the substance of the document, staff must present an explanation of their rationale and a discussion of their implications. A brief justification should be included in the memorandum circulated to the Board unless the corrections are completely self-evident. - All corrections and the discussion of their rationale and implications should be included in a designated section of the corrections memorandum. For publication and for the Fund Archives, the original document is corrected, but the corrections document issued by SEC to the Board is not published. - Primary responsibility for handling corrections lies with the authoring department. SPR sign-off is required for corrections with significant implications (as described above) and for corrections where there is room for debate as to whether they satisfy the correction criteria. Area departments determine whether SPR sign-off is needed; in case of doubt, SPR sign-off should be sought. ### Rules for deletions - Deletions are made to the version of the staff report that will be published. Deletions are generally considered at the request of the primary country and, more rarely, at the request of a third-party member if: - the text to be deleted relates to that other member; - the member to whom the document relates consents to the deletion; and - the deletions criteria are met. - Criterion (ii) does not apply to staff reports for Article IV consultations and regional surveillance discussions. The primary country should be informed of third-party deletion requests. - Deletions shall be requested in writing and are expected to be communicated to the Fund no later than two business days before the Executive Board date. Requests after this time will still be considered in certain cases. In any case, requests for deletions shall normally be made no later than seven calendar days after the Executive Board has considered the document, or twenty-one calendar days after the document was issued to the Executive Board, whichever is later. - Deletions should be limited to information that is not already in the public domain that constitutes either: - Highly market-sensitive material, mainly the Fund’s views on the outlook for exchange rates, interest rates, the financial sector, and assessments of sovereign liquidity and solvency. Material is considered highly market-sensitive when all of the following criteria apply: - The material is not already in the public domain; - The material is market-relevant within the near term; - The material is sufficiently specific to create a clear risk of triggering a disruptive market reaction if disclosed; or - Premature disclosure of policy intentions. This deletion ground applies only in rare cases when all of the following criteria apply: - The material is not already in the public domain; - The information consists of operational details of a policy the authorities intend to implement; - Premature disclosure of the operational details would, in itself, seriously undermine the ability of the authorities to implement it. - Politically sensitive information that does not fall under the above two grounds shall not be deleted. - Information relating to any performance criterion, assessment criterion, quantitative benchmark, or structural benchmark relating to a UFR, PSI, or SMP may not be deleted unless the information is such that it would have been eligible for communication to the Fund in a side letter. - Deletions can be accompanied by minor rephrasing to retain candor or minimize misinterpretation, but rephrasing should not add substance not in the original text or mislead the reader. Deletions should not normally be used to eliminate large portions of text, such as boxes and appendices. - Primary responsibility for handling deletion requests lies with the authoring department. SPR sign-off is required for all deletions that do not clearly and unambiguously meet the criteria for high market sensitivity or premature disclosure of policy intentions, or that require redrafting (except when limited to grammatical correctness). Area departments decide whether SPR sign-off is needed; in case of doubt, SPR sign-off should be sought. ### Resolving disagreements on deletion requests - Management approval of deletions is delegated to department Directors. Explicit management approval is needed only if there is disagreement between department Directors or between staff and country authorities. - If there is disagreement between staff and the country authorities: - The authorities (or their ED) can present their concerns to management. - In the case of serious disagreement between management and the member, the matter can be referred to the Executive Board by the ED representing that member, or by the Managing Director. - For staff reports for Article IV consultation and regional surveillance discussions, if the Managing Director approves deletions requested by a third party, and the primary member disagrees with the assessment of the Managing Director, the Managing Director, or the ED representing the primary member may refer the matter to the Executive Board. - If the Managing Director believes proposed deletions would result in a document that would undermine the overall assessment and credibility of the Fund, the Managing Director shall recommend to the Board that the document not be published. ### Removal of references and preparatory steps before publication - Prior to publication, references to the following should be removed from staff reports: - Internal documents that are not in the public domain; published internal documents should not be referenced under their internal reference number. - Internal processes that should not be disclosed to the public under existing policies, including inquiries regarding possible misreporting and breaches of member’s obligations. - Legal texts of arrangements and decisions; the Fund does not publish legal texts of members’ arrangements with the Fund and decisions related to these arrangements. - To implement accepted corrections and deletions, the authoring department should: - Prepare a memorandum to SEC. Separate memoranda should be prepared covering corrections and covering deletions (templates in Appendix VII and Appendix VIII). - Provide a brief justification for each substantive modification that is not self explanatory. - For deletions, attach authorities’ written requests (e-mails are acceptable) for record keeping and information, but they should not be circulated to the Board. - Internal control of evenhanded application of corrections and deletions will be exercised through periodic ex-post review, requiring strengthened recordkeeping. Teams are required to copy SPR when corrections and deletions memoranda are sent to SEC, even when SPR sign-off is not required. - When required, staff should obtain sign-off from the SPR review officer and indicate it in the memorandum. Formal signature of a joint memorandum is not required as long as a written record is available (e.g., e-mail). ### Handling confidential information - Staff (and management) should disclose to the Executive Board any information required to be reported under the Articles or necessary for the Board to make decisions, including for conducting surveillance or in the context of Fund-supported programs. Staff should not reach understandings with the authorities to withhold such information from the Board. - Members are under no obligation to provide the Fund with information that reveals information on individuals or specific financial institutions or corporations, though authorities often do voluntarily provide such information. Safeguards are in place to preserve confidentiality. Confidential information that is highly market sensitive or constitutes premature disclosure of policy intentions can be deleted from staff reports under paragraph 28. - Even when information must be provided to the Board, confidentiality vis-à-vis the public remains: neither the Executive Board nor EDs can publish information provided by a member on the understanding that it remains confidential vis-à-vis the public, unless the member consents. - During missions staff should: - Provide country authorities with detailed information on how the Fund safeguards confidential information. - Ensure a common understanding of what should remain confidential, including whether the information is meant to remain confidential within staff/management, or whether it can be shared with the Board and/or with the public. - Reviewers in authoring departments should watch for the inadvertent inclusion of confidential information into staff reports, and ensure confidential information relating to individual financial institutions in FSAPs are not included in FSSAs. *Source: _040714 - 14. Staff should discuss the publication process with the authorities during the mission* ### 45. Press releases will be issued following certain Board meetings or adoption of ### _040714 - 45. Press releases will be issued following certain Board meetings or adoption of ### Press releases: scope and content - Press releases will be issued following certain Board meetings or adoption of decisions on an LOT basis after the summing up has been circulated as a Fund document (paragraph 45). - Cases where press releases are issued: - Article IV consultation, discussion of regional surveillance (e.g., with members of currency unions), stand-alone consideration of FSSA, PPM, EPA, and EPE or combinations of these. In these cases, the press release comprises an introductory section (circulated together with the staff report) and the Board’s summing up. The draft press release should be sent to COM for comments before circulation to the Board (paragraph 45, footnote 22 and 23). - Adoption by the Board of a decision regarding a member’s UFR or a PSI, a discussion on a member’s participation in the HIPC Initiative, or a discussion of a PRSP-related document in the context of a UFR or PSI. In these cases, it comprises an introductory section and the chairman’s statement (paragraph 45). - Combined cases (Article IV/UFR, Article IV/PSI, EPA/UFR, EPA/PSI and EPE/UFR). In these cases, it comprises an introductory section, the Board’s summing up and the chairman’s statement (paragraph 45, footnote 24). ### Timing and responsibility for press releases - The authoring department is responsible for ensuring press releases are issued as soon as possible following Board consideration, provided the authorities have consented to publication (paragraph 46). - Timing rules: - In cases of UFR or PSI, or combined cases (Article IV/UFR and Article IV/PSI), press releases will normally be released immediately after Board consideration, on the same day (paragraph 46). - Press releases for Article IV consultations, regional surveillance discussions or stand-alone Board consideration of FSSA reports will be published along with the underlying staff report when the member has consented to publication of the staff report (paragraph 46). - If the staff report is not expected to be published within seven days of the Board date, a press release should be published, following its approval, and should not be delayed if the staff report will not be published promptly (paragraph 46). - Press releases will be translated into languages other than English when feasible (paragraphs 48 and 61, footnote 25). ### Specific procedures and LOT cases - Specific procedures apply for discussions concluded on an LOT basis (Appendix XI) (paragraph 47). - If the summing up will not be available soon after Board consideration, two separate press releases can be issued: one covering UFR issues immediately, and one on the Article IV issued immediately after the SU has been approved (footnote 24). ### Factual statements when documents are not published within 28 days - Authoring departments must prepare a factual statement if the underlying staff report and/or related press release have not been published within 28 days of the Board date for an Article IV consultation, a regional surveillance discussion, an FSSA report, a PPM, an EPA an EPE or any combination of these (paragraph 49). - Procedures after 28 calendar days: - If 28 calendar days after the relevant Board date a member has not consented to the publication of a press release covering the Board assessment, a brief factual statement will be issued immediately in the form of a press release stating that Board consideration has taken place (paragraph 49). - If, 28 calendar days after the relevant Board date, the staff report or the staff report and the related press release has (have) not been published, the area department will arrange for a brief factual statement to be issued immediately stating that the Board consideration has taken place, and clarifying the authorities’ publication intention. The factual statement should not be issued as a press release, but added to the information at the top of the country page on the Fund’s external web-site. The factual statement can be updated as needed. The area department is responsible for tracking the 28-day period (paragraph 49). - Area departments must submit to COM a draft factual statement using standard language one day before the 28-day period elapses (paragraph 49). - As factual statements, the Fund does not seek consent of country authorities nor consult with them on the standard language (paragraph 49). - Following Board consideration of a UFR or a PSI: - If a member does not consent to publication of a press release containing a Chairman’s statement, or if no Chairman’s statement has been issued because a decision was taken on a LOT basis, a brief factual statement will be issued immediately after the Board date. The factual statement will be issued in the form of a press release and describe the Board’s decision relating to (a) the member’s use of Fund resources (including HIPC initiative decisions, PRSP documents and waivers granted) or (b) a PSI approval or review (including waivers granted) and consideration of PRSP documents, when relevant (paragraph 50). - If 28 days after the relevant Board date the staff report has not been published, a brief factual statement will be issued immediately, using the guidelines in paragraph 49 above (paragraph 50). ### Steps after the Board: publication bundles and preparation - Country staff reports are published in a bundle, together with any related supplements or staff statement circulated to the Board, and the press release (paragraph 51). - The bundle will reference other relevant documents published separately (e.g., Selected Issues Paper, FSSA, ROSC modules, concluding statements, LOI/MEFP or PRSP documents) (paragraph 51). - In the case of FSSAs, the authorities may choose not to publish the FSSA but still publish as ROSC modules any or all of the summaries of standards assessments (paragraph 51). - The authoring department is responsible for preparing the bundle for prompt publication, including: - Ensuring approved corrections and deletions have been incorporated; - Removing draft press releases and/or draft texts of arrangements from the file; - Removing internal reference numbers (SMs/EBSs/EBMs, etc.) and, if available, replacing them with references to the published versions, and removing references to certain internal processes (see paragraph 36); - Checking whether the ED consents to publish the ED’s statement, and if so, inserting it into the bundle; - Preparing an electronic file with the bundle for publication, including in a single file all documents that are part of the bundle; - Coordinating publication with COM and communicating the date of publication to the relevant ED; - If publication is to be requested within 48 hours after the authoring department has finalized the bundle, staff should consult with COM and SEC on the timing of the publication (paragraph 52). ### Policy documents: presumption of publication and Board role - It is presumed that all policy papers, with few exceptions, will be published. The presumption does not apply to papers dealing with administrative matters of the Fund, except with respect to matters pertaining to the Fund’s income, financing or budget matters that do not involve market sensitive information (paragraph 53). - Authoring departments should consult with COM in cases where policy documents or documents related to the Fund’s financial position are not proposed for publication (paragraph 53). - The Board decides on publication of policy papers and related press releases based on staff recommendations. The Executive Board is understood to consent if no Director objects (i) during the Board meeting or before the relevant LOT decision, or (ii) for a paper prepared for an Executive Board informal session or for information, by the date in the SEC cover memorandum. If there is an objection, the Board can decide on publication by a simple majority of votes cast (paragraph 54). - Staff should explain in the SEC cover memorandum if it does not recommend publication (paragraph 54). ### Timing and modification rules for policy documents - Timing: - Staff will strive to publish policy papers within seven days of the Board date (paragraph 55). - Policy papers sent to the Board for information only will normally be published no later than 14 days after issuance to the Board (paragraph 55). - If multiple staff papers are issued on a repeated policy issue, the Fund will normally publish each paper within seven days of the relevant Board date for that paper (paragraph 55). - Modifications prior to publication: - Staff may make necessary factual corrections, deletions, and rephrasing guided by the rules under Transparency Policy (paragraph 56). - Modifications staff may make without management approval include: - Editing for publication (formatting and technical clarifications); - Factual corrections limited to information available at time paper was issued, including typographical errors, factual errors, mischaracterization of views, and evident ambiguity; - Deletions of country-specific references containing unpublished views of the Fund and/or other confidential information (including premature disclosure of policy intentions); - Removal of references to internal processes and documents; - Modifications clarifying differences between Board and staff recommendations, with staff positions not endorsed by the Board indicated, potentially via a standard footnote (paragraph 56). - All other modifications require management approval on a case-by-case basis, including deletions of highly market-sensitive information and information on authorities’ policy intentions, and deletion of country-specific references that could unduly single out a member country or group of countries (paragraph 57). - The authoring department should request management approval of such modifications in a memorandum (copied to SPR, LEG, and COM) explaining the rationale (paragraph 58). - The Board should be informed of all modifications to the Board version of any paper. The authoring department will send a memorandum to SEC (copied to SPR) listing all changes (excluding removal of references to internal documents and procedures) with a redlined version attached. SEC will circulate changes to the Board for information. Whenever possible, factual corrections should be circulated before the Board date (paragraph 59). - Staff may revise a policy paper where staff has modified its views in light of a Board discussion or significant new developments. A staff report cannot be modified to take into account the Board’s views unless staff and management share those views. Once a decision has been adopted by the Executive Board the staff report cannot be revised to reflect a change in the staff’s views if the decision was adopted on the basis of the views expressed in the original paper (paragraph 60). ### Press releases for policy documents - A press release can be issued on a stand-alone basis or together with the underlying policy document. It should be based on the Board decision and/or the summing up or concluding remarks, preceded by a short, purely factual background section (paragraph 61). - Where staff recommends a press release, the authoring department should attach a draft introductory section when the paper is circulated to the Board. The draft press release should be sent to COM for comments before circulation to the Board (paragraph 61). - If a policy document is not expected to be published within seven calendar days of the Board date, a press release will be issued shortly after the Board date (paragraph 61). - Press releases will be translated into languages other than English when feasible (paragraph 61, cross-referenced to paragraph 48 and footnote 25). ### Multi-country documents: definitions and sub-categories - Multi-country documents cover more than one country or are not focused exclusively on Fund policy issues; procedures can be applied to whole documents or material sections, or to treat part of a report as a policy document and another as country background pages if each is a self-standing material section (paragraph 62). - Three sub-categories of multi-country documents (paragraph 63): - Multilateral Policy Issues Documents: cover multilateral global economic issues (examples listed in source). - Country Background Pages: contain information and data on individual countries presented separately; normally issued alongside a multilateral policy issues paper or a policy paper. - Cluster Documents: analyze cross-cutting issues affecting a discrete group of countries, with discussion of individual countries fully integrated into overall analysis. *Guidance Note on the Fund’s Transparency Policy — content excerpt as provided.* ### 64. The guidelines for the publication of policy papers and press releases (Sections IIIA ### _040714 - 64. The guidelines for the publication of policy papers and press releases (Sections IIIA ### Multilateral Policy Issues Documents and WEO/GFSR/FM - The guidelines for the publication of policy papers and press releases (Sections IIIA and IIIE) apply to Multilateral Policy Issues Documents and the related press releases. - The modification rules for policy documents also apply (Section IIID). - Different modification rules apply to the World Economic Outlook (WEO), the Global Financial Stability Report (GFSR) and the Fiscal Monitor (FM). - Staff may modify the WEO, GFSR and FM prior to publication in order to, inter alia, take into account views expressed at the relevant Executive Board meeting. ### Country Background Pages - Consent of a member referred to in Country Background Pages (the “concerned member”) is required to publish a section that relates to the member. - Consent is normally obtained on a non-objection basis (see paragraphs 9-10). - If any concerned member objects to publication of information pertaining to it, the Managing Director may: - (i) decide to publish the Country Background Pages without that information, or - (ii) recommend to the Executive Board not to publish the Country Background Pages and/or, as the case may be, the associated Multilateral Policy Issues Document or Cluster Document, if the non-publication of the information would substantially undermine the overall analysis and substance of the document. ### Treatment of Multi-Country Documents (Box 3) - Any of the concerned members can request deletions or corrections of information pertaining to it in accordance with the procedures for Country Documents in Section IID. - All modifications except those certified by the head(s) of the authoring department(s) as bona fide administrative errors are guided by the rules under Transparency Policy. - The Fund will strive to publish Country Background Pages within 14 days of the Board date or 28 days from the issuance of document to the Board, whichever is later: - If one or more members notify the Fund that they need more time to decide on publication and/or to consult on deletions, staff will wait 14 days before publishing the paper, in the interest of trying to publish a complete document. As soon as such a notification is received, staff will advise the member that the document—with or without their pages—will be published following the 14-day period. - If the paper is published without some of the country pages, an updated version will be posted once the relevant members decide to publish, or agreements are reached on deletions. If the member decides not to publish, no further action is required. - Country background pages will always include a full list of all countries involved in relevant analytical exercises, even if not all of their country pages are published. ### Cluster Documents - Publication of a Cluster Document or the associated press release requires the consents of all the members to which the document relates (the “concerned members”). - Consent is obtained on a “non-objection” basis (see Section IIB). If one or more members object to publication, the document shall not be published. - The document is published along with a press release. - Each concerned member has the right to request deletions or corrections in accordance with the criteria and procedures applicable to Country Documents (see Section IID). - All modifications except bona fide administrative errors are guided by the rules under Transparency Policy. - If there are serious disagreements among the members concerned regarding requests for deletions, the Managing Director shall propose a solution; if no commonly acceptable solution can be found, the Managing Director or the EDs elected, appointed, or designated by the members concerned may refer the matter to the Executive Board. - Timing and press releases: - If a Cluster Document is not expected to be published within seven calendar days of the Board date, the authoring department will arrange for a press release to be issued shortly after the Board, if the members concerned have consented to issuance of the press release. - The press release on a Cluster Document should not be issued before the summing up is circulated as a final Fund document; otherwise, the press release, the Cluster Document, and the relevant buff(s) should be published together with any other documents included in the bundle. - If, 28 calendar days after the relevant Board date, a member has not consented to the publication of a press release covering the Board assessment, a brief factual statement will be issued immediately, in the form of a press release, stating that Board consideration has taken place. - If, 28 calendar days after the relevant Board date, the staff report or the staff report and the related press release has (have) not been published, a brief factual statement will also be issued immediately stating that Board consideration has taken place, but also clarifying the authorities’ publication intentions with respect to the staff report and/or the press release. This statement will not be issued in the form of a press release. ### Appendix I — Indicative List of Board Documents Subject to the Transparency Policy (selected items) - Multilateral Policy Issues Documents such as, the World Economic Outlook, the Global Financial Stability Report, the Fiscal Monitor, and Spillover Reports. - Press Releases following Executive Board consideration of Multilateral Policy Issues. - Country Background Pages and associated press releases. - Cluster Documents and associated press releases. ### Appendix II — Publication Expectations and Timing (selected rules and numeric timing) - Publication may not occur before the Board date of the document unless otherwise indicated. - “Prompt publication” is defined as being within 14 calendar days from the Board date or 28 calendar days from issuance of document to the Board, whichever is later. - Publication regimes summarized: - Documents related to country matters: Publication is voluntary but presumed. Consent normally obtained on non-objection basis. - Press releases on Article IV consultations and related Chairman’s Statements: Publication is voluntary but presumed. The Fund will aim to issue press releases as soon as possible after the Board date. Press releases containing the Chairman’s Statement are normally released within one day. - Multilateral Policy Issues Documents: Publication is presumed but subject to Board authorization. - Country background pages: Publication is voluntary but presumed. The consent of a member referred to in the Country Background Pages is required to publish a document or section to which the member pertains. - Cluster Documents: Publication is presumed but subject to the consent of all the countries involved. ### Appendix III — Special Publication Policies - Papers issued to the Board but for which the Board is not the primary intended audience are not subject to Board approval for publication purposes; staff should indicate publication intentions in SEC’s cover memo. - Specific regimes and rules: - TA reports: publication is encouraged under their own publication regime. - Safeguard assessments: considered confidential and not published; full reports made available to the central bank and the ED representing the country; the Executive Board receives only a summary, which appears in the next staff report. - Assessment letters: Fund does not generally publish assessment letters, although it may do so with the consent of the member and the authoring department; staff must seek authorities’ consent before publication. - Overdue financial obligations, misreporting, and breaches of Article VIII, Section 5: have specific publication policies; relevant information concerning Board findings of misreporting and breach of obligation under Article VIII, Section 5 is generally required to be made public, except when proposed to be treated as de minimis. - Management decision to delay completion of Article IV consultation discussions and issuance of a staff report because of lack of adequate data should be made public in the form of a press release, with prior Board review of the text for publication. *Guidance Note on the Fund’s Transparency Policy — Excerpts from the specified sections and appendices* ### Appendix IV. Timeline for Publication of Country Documents ### Appendix IV. Timeline for Publication of Country Documents ### Timeline milestones and deadlines - Mission End → Board Date (BD) → subsequent deadlines follow relative to BD. - Key post-Board deadlines: - 7 calendar days after BD - 28 calendar days after BD - 14 calendar days after the Board date or 28 calendar days after issuance of document to the Board, whichever is later (notification of expected date of publication to ED) - 7 calendar days after the Board date, or 21 calendar days after issuance of the staff report to the Board, whichever is later (deadline for requests for deletions) - 90 days after the Board date (documents published after this will not be included in the “what’s new” section of the Fund’s external website) - Process timing requirements: - Submit draft Summing up to Management & SEC, at the latest 4 days before BD - Obtain deletions and corrections request (or request own corrections), at the latest 2 business days before BD - Requests for modifications are expected no later than two business days prior to the relevant Board date - Transmission to SEC for reissuance after administrative error: within one business day of notifying management ### Publication intentions and non-objection procedure - Core principle: publication is voluntary but presumed; publication of country documents is subject to the concerned member’s consent, and the Fund encourages consent by members. - Publication modes: - Most members consent to publication on a non-objection basis (unless the authorities object or require more time). - Members may opt out of the non-objection procedure; expected to indicate publication intentions within 28 days of the relevant Board meeting or LOT decision (but may provide final decision later). - Stronger presumption of publication for cases involving all use of Fund resources and PSI: members requesting access are expected to indicate consent prior to circulation of the staff report to the Board. - Managing Director will generally not recommend Board approval for requests for (i) access to resources in the General Resources Account or the PRGT, or (ii) access to Fund resources under the HIPC Trust, or (iii) assistance through a PSI, unless the member explicitly consents to publication of the associated staff report. ### Press releases, factual statements, and timing policy - Press releases: - Will be published unless the member objects by the conclusion of the relevant Board meeting or prior to the adoption of a LOT decision. - For use of Fund resources, a press release containing a Chairman’s Statement will be published. - Factual statement: - If a country paper or press release has not been published within 28 days of the Board date, the Fund shall immediately issue a short factual statement confirming the Board consideration date and indicating the authorities’ publication intentions. - For UFR and PSI cases, a short factual statement is issued immediately after the Board date when a member has not consented to issuance of press release. - Prompt publication goal: - The Fund strives to publish staff reports promptly, meaning within 14 days of the Board date (or 28 days after issuance, whichever is later). ### Modifications: corrections and deletions - Timing and deadlines: - Modification requests should be submitted as soon as possible after issuance of the report, expected no later than two business days prior to the Board date. - Requests for deletions shall normally be made no later than: - 7 calendar days after the Executive Board has considered the document, or - 21 calendar days after the document was issued to the Executive Board, whichever is later. - Criteria: - Deletions allowed only if the deleted text is “highly market sensitive” or constitutes premature release of policy intentions. - Corrections limited to factual errors, typos, mischaracterization of the authorities’ views, or evident ambiguity. - Both deletions and corrections should be parsimonious. - Dispute resolution: - In a serious disagreement between the Managing Director and the member regarding deletion requests, the authorities or ED elected/appointed/designated by that member may refer the matter to the Executive Board. - If management believes a deletion would undermine the overall assessment and credibility of the Fund, it shall recommend to the Board that the document not be published. ### Administrative errors (Appendix VI) - Scope: - Rectification of bona fide administrative errors falls outside of the Transparency Policy; all other modifications follow Transparency Policy rules. - Administrative errors occur when a wrong document and/or attachment or wrong version is inadvertently circulated to the Executive Board, provided the correct version existed at the time of initial circulation. - Examples of administrative errors: - Circulation of an earlier version of a document or attachment instead of the finalized version that already existed. - Circulation of a document with an entirely wrong attachment (e.g., net international reserves table instead of balance of payments table). - Circulation of an entirely wrong document (e.g., last year’s Article IV report circulated instead of current year’s; staff report for Country A circulated for Board consideration of Country B). - Rectification process: - Reissue the relevant document to the Executive Board and inform the Board that the wrong document/version was inadvertently submitted. - Authoring department responsibilities: - Obtain approval of the head(s) of the authoring department(s) to reissue the document certifying a bona fide administrative error. - Notify management and, where relevant, the ED(s) concerned by memorandum (copying LEG, SEC, and SPR) certifying the administrative error. - Notify ED(s) in writing after informing management but prior to reissuance. - Submit the correct document to SEC, redlined relative to the wrongly-circulated document and clean copies, together with a cover memorandum explaining the error and certification by department head(s), within one business day of notifying management. - SEC actions: - Replace the wrong document with the right one in SEC's Document Management Facility (central repository). - Ensure the wrong document includes a reference to the right one in the repository and block further retrieval of the wrong document (including in the ED extranet, intranet websites, and the Institutional Repository). ### Templates and procedural guidance (Appendices VII–VIII) - Template for Memorandum to SEC on Corrections: - Use for corrections to SM/13/xx scheduled for Board discussion (example in template). - SPR sign-off is required for corrections with significant implications for substance; SPR should be copied on all corrections whether their approval is required or not. - Categories in template: Mischaracterizations of the Views of the Authorities; Evident Ambiguity; Factual Errors Affecting the Presentation of Staff’s Analysis or Views; Factual Errors Not Affecting the Presentation of Staff’s Analysis or Views; Typographical Errors. - Include corrected and redlined pages as attachments; cc SPR. - Template for Memorandum to SEC on Deletions: - Use for deletions to country documents, cluster documents, and country background pages. - Deletions must concern information not in the public domain and be requested under stated grounds. - Sections in template: - A. Highly Market-Sensitive Material (criteria: (i) market relevant in the near term; (ii) release would create a clear risk of triggering a disruptive market reaction) - A.2 Other deletions on highly market sensitive grounds (use if criteria not unambiguously met) - B. Operational Details of Policy Intentions (criteria: (i) material concerns operational details of authorities’ policy intentions; (ii) release would seriously undermine ability to implement) - SPR sign-off required for deletions listed under Section A.2 and where judgment is required; deletions on grounds other than A or B may only be approved by management or by the Board on an exceptional basis. - Attach redlined pages; cc SPR. ### Guidelines on the treatment of confidential information (Appendix IX introduction) - Purpose: - Presents the Fund’s legal framework for the treatment of confidential information and the application of this framework in surveillance, use of Fund resources, and technical assistance. - Section heading: - I. Rules of Confidentiality vis-à-vis the Public *Source: Appendix IV. Timeline for Publication of Country Documents.* ### 1. Three broad sets of rules protect the disclosure of confidential information to the ### 1. Three broad sets of rules protect the disclosure of confidential information to the public. ### Legal foundations protecting confidentiality - Article IX, Section 5 of the Fund’s Articles of Agreements: - Provides that the archives of the Fund shall be inviolable. - “Inviolability” has been applied to mean that all non-public documents produced by the Fund—whether in the Fund’s custody or held by members or third parties—are protected by the Fund’s immunities and cannot be published, or otherwise produced (including in response to a subpoena) without the Fund’s approval. - Approval to publish can be granted in a general context (for example, pursuant to the Fund’s Open Archives Policy, Transparency Policy, or Transmittal Policy) or on a case-by-case basis for situations not covered by a decision of general applicability. - Nonpublic documents received by the Fund from members or other parties are also covered by the inviolability of the Archives, and would only be published or released by the Fund in accordance with its policies and with the approval of the author of the document. - Article XII, Section 8 of the Articles: - Has been applied to require the Fund not to publish its views (meaning the Executive Board’s views) with regard to a member without the member’s consent, except under certain specific circumstances. - The Fund’s publication of a document on a member containing Fund views pertaining to a member’s “conditions and developments which directly tend to produce a serious disequilibrium” would not require the consent of the member concerned, if the Fund were able to muster 70 percent majority of the total voting power to approve publication. However, there has never been a case in which the Fund has sought to exercise the 70 percent majority provision. ### Internal rules, staff conduct, and governance instruments - Rules N-6 and N-11 of the Fund’s Rules and Regulations, the Staff Code of Conduct, and General Administrative Order No. 35: - Prohibit Fund staff from making unauthorized disclosures to third parties of confidential information obtained in the course of their service to the Fund. - The Code of Conduct for Members of the Executive Board adopts by reference the same regime governing the Fund’s staff with respect to the protection of confidential information. - Relevant administrative references cited in source text: - Decision No. 14498-(09/126), December 17, 2009, as amended, on the Open Archives Policy at Paragraph 5. - General Administrative Order No. 35, Rev. 2 of November 1, 2007 on “Information Security—Policies Regarding Classified Documents”, at Paragraph 3.01. ### General principle on confidential information provided by members or others - Core principle: - The Executive Board, management and the staff may not disclose information that a member or other person has provided in confidence, unless that party consents to disclosure and such disclosure is consistent with Fund rules. - Determination of whether information was provided in confidence: - Based on examination of all surrounding circumstances, including the nature of the information provided. - Central issue: whether there was an understanding between staff and the other party that such information would not be disclosed without that other party’s consent. - This understanding can be expressed or implied. - Where doubts exist as to whether certain information was provided on a confidential basis, the Fund’s approach has been to give the benefit of the doubt to the member or other party. ### Rules of confidentiality within the Fund: circumstances requiring disclosure to the Executive Board - Management and staff may not indiscriminately withhold information from the Executive Board even if authorities provided it as confidential. Three broad circumstances where management/staff cannot agree to withhold information from the Board: - First: The member should not purport to withhold from the Board any information required to be reported to the Fund as a result of members’ obligations under the Articles of Agreement. - Second: Where the Board has established a policy requiring that certain information received from members must be disclosed to the Board, members are understood to be on notice of the existence of such a policy and are considered to have consented to such disclosure. - Third: In the absence of policies mandating disclosure to the Board, disclosure is required if such information is judged to be of a nature that is critical for the Board to be able to exercise its responsibility in a meaningful way. - Illustrative applications in the Fund’s main activities: - Surveillance: - Members, management, and staff may not on grounds of confidentiality withhold from the Board any information that is required to be reported under Article VIII, Section 5 or that is otherwise judged to be necessary for the conduct of surveillance. - Use of Fund resources: - The Board has a policy requiring Fund management and staff to disclose to the Board confidential information provided by a member in the form of a side letter. - Technical assistance (TA): - TA reports are treated as confidential vis-à-vis the Board. - Fund policy requires management to share with the Board certain types of reports arising from Fund TA for the purposes of informing the Board’s work on surveillance: Reports on Standards and Codes and Assessment of Financial Sector Supervision and Regulations. - Where no policy mandates disclosure but management considers disclosure necessary for Board decision-making (e.g., program review or effective surveillance), management should not recommend Board action unless the member consents to disclosure. ### Continued confidentiality vis-à-vis the public after disclosure to the Board - Even when information is required to be provided to the Executive Board, confidentiality issues remain: - Neither the Executive Board nor Executive Directors can publish information provided by a member or other person on the understanding that it remains confidential vis-à-vis the public, unless the member or other person consents. --- *Prepared by the Legal Department (text as presented in the source).* ### 1. The authoring department is responsible for sending COM drafts of press releases on policy ### 1. The authoring department is responsible for sending COM drafts of press releases on policy matters and multilateral policy issues documents, comprising introductory paragraphs and the draft summing up in order for COM to advise upon consistency and accessibility of the language. If the policy document is to be posted, the electronic files of the version to be published should be sent to COM as soon as possible. ### Responsibilities and timing for press releases and policy documents - The authoring department must send COM drafts of press releases on policy matters and multilateral policy issues documents, including introductory paragraphs and the draft summing up, so COM can advise on consistency and accessibility of language. - If the policy document is to be posted, the electronic files of the version to be published should be sent to COM as soon as possible. - After Board consideration: - The authoring department should obtain the final summing up from SEC and put together the final press release. - The final version of the press release should be sent to COM (subject line reads [subject:] Press Release—Final version), with mention of a special release time, if appropriate. - The press release will be released as soon as the final text is received by COM from SEC, and in conjunction with the release of the policy paper if the Board has agreed to release both. - Goal: release press releases and policy documents within 7 calendar days of the Board discussion. ### Lapse-of-Time (LOT) cases: Article IV consultations, regional surveillance, or stand-alone FSSAs - Press release format for LOT cases (and all Article IV consultations) when the member consents to publication: - Normally 3-4 pages. - Consist of two sections: - (i) an introductory section with factual information on the economy of the member, including a table of economic indicators; and - (ii) the Executive Board Assessment of the member's prospects and policies. - In LOT cases, the Executive Board‘s Assessment should follow the staff appraisal verbatim, with the exception of changes to accommodate corrections or deletions permitted by the Fund‘s transparency policy. - Required chapeau sentence for the Executive Board assessment section (followed by the staff appraisal): - “In concluding the [year] Article IV consultation with [country], Executive Directors endorsed staff’s appraisal, as follows:” - Press release must indicate LOT conclusion as follows: - (i) The first sentence of the press release should read: “On [end of lapse of time date], the Executive Board of the International Monetary Fund (IMF) concluded the Article IV consultation with [country], and considered and endorsed the staff appraisal without a meeting.” - (ii) Footnote 2 to press releases explaining the Article IV process, i.e., the sentence concerning the explanation of qualifiers, should be dropped, since references to Directors are not expected to be used in LOT press releases. - Drafting and circulation timing: - The draft press release (both background section and Executive Board Assessment), prepared by the area department, should be sent to SEC so it can be circulated to the Board at least three business days before the expiration of the LOT period. - The area department will give the ED concerned the opportunity to review the draft press release prior to its release, to propose changes, if any, consistent with the rules on modifications. - It can be published as soon as the LOT period has expired. - If the member does not consent to publication of a press release: - For LOT cases, as for all Article IV consultations, a brief factual statement is issued noting the LOT. ### UFR and PSI Cases (LOT and non-LOT) - For all LOT UFR reviews (regardless of member’s consent for publication), a factual statement in a press release is issued. - The factual statement must include all relevant factual information on the Board decision regarding the country’s use of Fund resources or PSI, including: - the nature of the facility, - stage in the program (original request, review, etc.), - amount disbursed, - any granted waivers. - Where relevant, it should also include information such as a summary of HIPC Initiative decisions pertaining to the member. - The Transparency Policy does not require LOT UFR factual statements to indicate their LOT basis, but staff is encouraged to do so. - The Transparency Policy does not rule out that LOT UFR press releases could contain some additional factual information on the program; staff can and is encouraged to include a few paragraphs drawing on the Executive Summary or the Staff Appraisal section of the staff report to provide a succinct, factual overview of economic developments, the program, and performance under it. - The area department should send a draft of the press release to COM for review three days before the expiration of the LOT period. - For longer factual statements, area departments are encouraged to give the ED representing the country the opportunity to review the draft press release. - If the authorities consent, the press release should be published once the LOT period has expired. - Footnote 1: For regular (non-LOT) cases, when the member consents to publication, a press release is issued that contains a Chairman’s Statement. When the member does not consent to publication, the press release contains only a short factual statement. ### Publication in Languages Other than English (LOE) - Rules apply only to publication of English-language versions; materials cleared in English are presumed cleared in substance for LOE. - Non-English versions of press releases, staff reports, and mission concluding statements can be posted on the Fund’s website in one language other than English per document (press releases for policy papers can be posted in more than one language) if the English text has been cleared for publication and the non-English version is available. - Translations should be accurate versions of the published English documents, and modifications must be correctly reflected in translations; where applicable, it should be noted explicitly that English versions prevail. - Area departments are expected to make necessary arrangements for accurate translation. - Specific procedures for web posting: - Authoring departments are responsible for ensuring web-posting of LOE versions, where available, and should keep ED offices informed. - For PRSPs originally in LOE, when the area department receives a finalized PRSP (or an update) in LOE, they should send COM a link to the authorities’ website where the PRSP is uploaded. - Once the English version is circulated to the Board and the clearance sheets are signed, both the English and the LOE electronic files should be promptly posted on the PRSP site and the link to the authorities’ site deactivated. - For further information, see Guidance Note on Translation of Documents for Publication in Languages other than English. ### Sample factual statements and templates for non-publication cases - Factual statement structure: (a) description of purpose of the Board meeting and (b) statement on publication intentions. - Sample opening templates (to be used with substitutions indicated by brackets): - Article IV and regional surveillance: “On [date], the Executive Board of the International Monetary Fund concluded the consideration of the [discussion type] of [country name].” - Standalone FSSA: “On [date], the Executive Board of the International Monetary Fund concluded the consideration of the Financial Sector Stability Assessment for [Country].” - Standalone UFR/PSI: “On [date], the Executive Board of the International Monetary Fund (IMF) [approved a [XX]-month [name of arrangement] or PSI for an amount equivalent to SDR xx million for [Country]] OR [completed the [xth] review of [Country]’s economic performance under a program supported by a [XX]-month [name of arrangement] or PSI].” - Standalone EPA / EPE / Combined permutations: sample templates describing the Board’s consideration and the purpose of ex-post assessments/evaluations (including that ex-post assessments were established by the IMF's Executive Board in 2003 and that EPE ex-post evaluations follow the 2002 Board decision). - Publication intentions templates: - [Non-publication of staff report] The authorities [have consented to publication and it is expected that the staff report will be posted on this website shortly] or [have not consented to publication of the staff report] or [need more time to consider the publication of the staff report]. - [Non-publication of staff report and press release] The authorities [have consented to publication of the staff report and the related press release and it is expected that these will be posted on this website shortly] or [have not consented to publication of the staff report and the related press release] or [need more time to consider the publication of the staff report and the related press release]. *Guidance Note on the Fund’s Transparency Policy — Appendix XI–XIII (selected excerpts).* ### Appendix XIV. Template for Memorandum to Management ### Appendix XIV. Template for Memorandum to Management ### Template for requesting approval - To: The Managing Director; The Deputy Managing Directors - Date: [blank in template] - From: [blank in template] - Subject: Proposed Modifications to [Title of Document] - Core request: - "Staff request Management approval of the following modifications to the policy paper [Title of paper and document number]." - "[Each deletion and/or added footnote should be noted and the rationale underpinning each modification should be provided]" - "Redlined pages with the proposed modifications are attached." - "Management approval of the above modifications to the policy paper will be considered as granted if no communication is received by [specify deadline]." - Copy to: "cc: SPR; SEC" ### Contextual placement - Appears under "GUIDANCE NOTE ON THE FUND’S TRANSPARENCY POLICY" (page header context in source). --- ### Appendix XV. Publication of PRGT, PRSP, JSAN and HIPC Documents ### Publication timing for PRSPs and APRs - "PRSPs and PRSP Annual Progress Reports (APRs) should be published immediately after circulation to the Executive Board, provided that the authorities have not objected to their publication (either ad hoc or on a standing basis)." - "Interim PRSPs and PRSP Preparation Status Reports are normally issued (to both Boards) only when either` the Bank or the Fund or both needs such a document to support a financial operation." - "If an interim PRSP is prepared in the absence of any lending by either Board, it may be posted on the Fund website after it has been circulated to both Boards for information by the relevant ED." ### JSAN publication rules - "JSANs that are scheduled for discussion by one or both Boards may be published only after consideration by the relevant Boards." - "JSANs circulated to the Board for information may be published only after the stated period within which an ED may request that the document be placed on the agenda of the Board." - "In cases where modifications are being introduced to the JSAN before publication, the JSAN cannot be posted on the Fund’s website until both the Fund’s and Bank’s Board have been formally informed of these changes." ### HIPC documents and press release timing - "HIPC documents may be published after each Board has had the opportunity to discuss them." - If Fund Board meets before Bank Board: - A press release including a Chairman’s Statement may be issued following the Fund Board consideration, except in the case of stand-alone HIPC meetings, where a joint Bank-Fund press release will be issued after the Bank Board has met. - "Where relevant, the Chairman’s Statement should indicate that some of the Board decisions are contingent on action by the Bank." - "The timing of issuance of Chairman’s Statements and press releases on stand-alone HIPC discussions and joint HIPC/PRSP or HIPC/PRGT discussions must take into account the timing of the corresponding discussions by the Bank’s Board (see below)." ### Specific procedures for combined and stand-alone cases - Stand-alone PRGT, stand-alone PRSP (or APR), and joint PRGT/PRSP (or APR): - "the Chairman’s Statement may be released immediately after the Board consideration." - Stand-alone HIPC cases: - "the Chairman’s Statement would be embargoed until after the Bank Board has met (although that statement would be transmitted to the Bank within two hours of the Fund Board discussion)." - After the Bank Board meets: "a joint Bank-Fund press release and the Fund Chairman’s Statement would be issued, cross-referenced through hyperlinks." - Combined HIPC/PRGT or HIPC/PRSP (or APR) where the Bank has not yet considered the HIPC decision: - "a press release containing the Chairman’s Statement would still be released immediately, but it would include only the PRSP-related and PRGT-related aspects of the Executive Board discussion, and the following reference to HIPC: 'A final decision on [Country X’s] debt relief under the enhanced HIPC initiative is still pending action [this]/[next] week by the World Bank’s Executive Board. A press release will be issued jointly with the Bank following those deliberations.'" - "In such cases, the HIPC language from the Chairman’s Statement should be included in the Fund version of the joint Bank-Fund press release." - "Publication of PRSP-related documents may occur immediately after their circulation to the Fund and Bank Boards, whichever is later." --- ### Appendix XVI. Transparency Guidelines for Non-Board Documents ### Drafting guidelines - "The drafting guidelines outlined in Section II generally also apply to non-Board documents." ### Publication expectations and timing (key rules) - "Non-Board documents are not subject to the Transparency Policy. Fund documents, including non-Board documents, are the intellectual property of the Fund." - Non-Board documents may be published following the Managing Director’s approval (or as delegated to department heads), except when either of these criteria are met, in which case the member’s consent is also required: - "They contain information provided by the member on the understanding that it will remain confidential; or" - "They contain Fund (i.e., Board) views about the member governed by Article XII, Section 8 of the Articles of Agreement." - "Non-Board documents may be published as soon as the necessary consents have been received." - "Assessment letters or statements, FSAP technical notes, and TA reports have separate publication and/or dissemination policies (see Appendix III)." ### Staff Discussion Notes (SDNs) - Purpose: "showcase new policy-related analysis and research by Fund departments, and are aimed at a broad international audience interested in economic policy issues." - Characteristics: "SDNs are brief (10–20 pages), with only limited technical content." - Clearance and review: - "The publication of SDNs requires management clearance." - "SDNs must also be submitted to the COM and other relevant departments for review before publication." - "The ED(s) concerned should be informed by the authoring department of any intention to issue an SDN dealing with a specific country or group of countries (including cross-country analysis referring to a group of countries)." - "After incorporating comments from COM, other reviewing departments, and EDs (if any), the authoring department and COM will send the prospective SDN and the draft communications plan to Management for clearance on a three-day LOT basis." - "Once cleared, the SDN is posted on the Fund’s website." ### Working Papers (WPs) - Purpose: "feature original and ongoing theoretical or empirical research undertaken by Fund staff, consultants, and guest scholars." - Distribution: "These papers are widely disseminated outside the Fund to the academic and professional economist communities, and their full texts are posted on www.imf.org and other sites." - Technical content: "Unlike Staff Discussion Notes, WPs usually contain complex technical analysis." - Clearance and ED involvement: - "The publication of WPs requires clearance by COM." - "If the WP relates to a specific country or group of countries the relevant ED(s) should have the opportunity to comment on it prior to its issuance, but their consent is not legally required, unless at least one of the two criteria above are met." ### Publication process for non-Board (country) documents - Mission chief responsibilities: - "For country documents, the mission chief should ascertain the authorities’ publication intentions and Management’s decision." - "The authorities’ view should be communicated to the mission chief directly or through the ED’s office of the concerned member." - Area department responsibilities: - "The area department is responsible for preparing the documents for publication." - "The authoring department should send COM the authorities’ consent (if necessary) and management’s approval." - "If the document is going to be distributed to the Board for information, then the authoring department should also send the document and clearance sheets to SEC, in accordance with SEC’s procedures and guidelines." - "Some documents circulated to the Board for information only may be published immediately after their circulation to the Executive." - Footnote: "However, SEC usually indicates on the cover that these documents will be posted five working days after their circulation to the Board." - Working Paper and SDN issuance steps: - For a WP: "after the originating department (division chief or above) has authorized a WP for issuance by signing a memorandum addressed to the Chief of the Editorial and Publications Division, COM reviews the draft WP for confidentiality and sensitivity and to ensure that it meets minimum editorial quality standards." - "Publication of SDNs follows a similar procedure." *Appendix XIV, Appendix XV, and Appendix XVI excerpts — Guidance Note on the Fund’s Transparency Policy* --- _Source: https://www.imf.org/-/media/websites/imf/imported-full-text-pdf/external/np/pp/eng/2014/_040714.pdf_