## _cr10264 — Executive Summary and Key Findings ## Source details **Canonical URL:** [_cr10264 — Executive Summary and Key Findings](https://www.imf.org/-/media/websites/imf/imported-full-text-pdf/external/pubs/ft/scr/2010/_cr10264.pdf) ## Other formats - [Markdown version](/-/media/websites/imf/imported-full-text-pdf/external/pubs/ft/scr/2010/_cr10264.pdf.md) - [Structured JSON version](/-/media/websites/imf/imported-full-text-pdf/external/pubs/ft/scr/2010/_cr10264.pdf.json) --- ### Major progress, scope, and approach - Report: reassessment of fiscal transparency practices in the Republic of Cameroon against the IMF Code of Good Practices on Fiscal Transparency. - Basis: discussions with authorities and other organizations; authorities’ response to IMF fiscal transparency questionnaire; other sources. - Includes: assessment of transparency in natural resource revenue management (detailed in annex; summary in staff commentary and recommendations). - Reference: IMF Manual on Fiscal Transparency (2007). ### Overall assessment and progress since 1999 - Cameroon was a pilot case for fiscal ROSCs in 1999. - Initiatives since 1999 include: - Preparation of a Public Expenditure and Financial Accountability (PEFA) report. - Joined the Extractive Industries Transparency Initiative (EITI) in March 2005. - Creation of a platform for dialogue on public finance (government, donors/lenders, civil society). - IMF technical assistance supported some reforms. - Overall conclusion: - Legal and regulatory framework is clear and sound. - Implementation needs acceleration to meet the Code comprehensively. - The 2007 law on the government finance system is expected to be fully in effect by 2012 and should significantly improve fiscal management and transparency. - Additional reforms required to avoid contradictions among existing arrangements. ### Clarity of roles, public sector coverage, and key counts - Government definition: general government defined consistently with GFSM 2001 principles; partly covered in budget process. - Public nonfinancial sector components (selected): - EPAs: 89 EPAs, 67 of which receive budgetary transfers as their sole source of financing or to supplement their own revenue. - Local governments: 360 communes; 10 regions (not yet operational, without individual budgets). - Public-owned corporations: 28 (including the SNH, the SNI, and Camtel). - Semi-public corporations: 40 (including the SONARA and the SIC). ### Legal and institutional framework — highlights - 2007 law on the government financial system: - Establishes budget preparation, presentation, execution, monitoring; defines payment authorizing officers (principal, secondary, delegated) and accounting/control arrangements. - A Decree of June 25, 1997, on public accounting is being amended for consistency with the 2007 law. - Tax legislation: - General Tax Code and Customs Code; self-assessment system; administrative discretion exists (Director-General of Taxes/Minister can reduce penalties; tax incentives discretionary). - Oil companies’ financial obligations defined in Oil Code, but exact terms set case-by-case in oil contracts. - Debt management: - No legislative framework for debt management; Minister of Finance responsible for public debt stock. - Communes must obtain MINFI authorization before borrowing. - Caps on central government debt set within the budget law. - Government prepared a debt strategy but it has not yet been approved. ### Accounting, budget reporting, and arrears - Accounting and treasury reporting: - Chart of accounts harmonized with budget classification. - Treasury accounts (balance du trésor) produced monthly, with a 20-day gap. - DAE prepares a monthly TOFE on a cash basis; only brief quarterly summaries on implementation; no midyear report to Parliament despite legal requirement for midterm budget execution report by September 30. - In-year reporting and final accounts: - Accounting system can produce in-year reports only for central government; such reports are not submitted to Parliament. - Final treasury accounts for December of fiscal year N generally produced in approximately June of fiscal year N+1. - Draft budget review laws (loi de règlement) required but not submitted to the Audit Office; budget review law published with a lag of two years. - Arrears and “restes à payer”: - Accounting weaknesses: system does not provide a reliable basis for preparing data on arrears. - Lack of published information on payment orders issued but not paid complicates fiscal assessment. - Recommendation: define arrears operationally and adopt the CAEMC directive 90-day criterion to consider a “reste à payer” an arrear. ### Budget process, medium-term framework, and public availability - Budget calendar and preparation: - Draft budget law must be submitted at least 15 days before start of budget session of November; Parliament has 20 days from opening of session to debate. - Budget circular published late; process seminars in April/May and conferences in July occur but are not formalized. - Draft budget law normally approved on time before start of fiscal year. - Medium-term frameworks and investment: - Forecasting Directorate prepares multiyear macroeconomic framework for PRSP; second PRSP being prepared for 2010–20. - MTEFs prepared for main social sectors; projections by sector and fiscal aggregates prepared up to 2020. - Investment project record prepared by region but multiyear investment program not shown; only payment appropriations for the year included. - Public availability and presentation: - Bulk fiscal information is available but no formal publication timetable; websites often outdated. - Budget documents cover central government and transfers but EPAs’ budgets not consolidated; annexes (lists of EPAs, debt details) are often unpublished or not distributed. - Missing from budget law: table of budgeted staff by ministry, tax expenditure, contingent liabilities; only overall balance shown (no primary or nonoil balances in budget documents). ### Coverage of extrabudgetary activities and consolidation - Coordination weaknesses: - Some appropriations bypass budget/treasury (e.g., additional centime paid to FEICOM and local governments; equalization tax collected on behalf of CSPH paid directly to CSPH). - Forecasts and actuals for extrabudgetary activities by EPAs are not consolidated; overall fiscal position is therefore incomplete. - Recommendation: conduct a complete short-term survey of extrabudgetary entities and integrate off-budget revenue/expenditure into fiscal reporting. ### Natural resource (oil and mining) revenue transparency and SNH role - Importance of oil: - In 2008 oil products accounted for more than one half (about $1.8 billion) of Cameroon’s exports and more than one third (7.5 percent of GDP) of government revenue. - Oil production expected to decline; authorities intend to promote development of mining (natural gas, bauxite, cobalt, nickel, iron). - SNH role and treatment of oil revenue: - SNH manages and markets the state’s share of production; deducts from proceeds the government’s contribution to operational costs and its mandated/miscellaneous expenses before transferring the balance to Treasury. - Signature and production bonuses are paid to SNH, not directly to government, and used to finance SNH non-mandated expenses. - SNH has participating interests (20 percent in four projects in production phase); publishes annual reports showing participation information. - Budget documents record only oil revenue passed on to government; revenue retained by SNH (bonuses, state’s production share retained to meet SNH operating expenses, dividends) are ignored in budget presentation. - SNH publishes quarterly production and revenue data on its website; EITI Committee reconciliations for 2001–04 and 2005 show only minor differences. - Oversight and audits: - SNH compiles accounts under OHADA standards and publishes certified annual financial statements; not subject to external audits by an internationally reputed audit firm (local auditors perform audit-like work). - DGI monitors taxes paid by oil companies but lacks specialized capacity to reconcile SNH-collected amounts with amounts payable to government. - Audit Office lacks means for detailed reconciliation or audit of SNH accounts. - Recommendations for natural resources: - Publish quarterly reports showing, by revenue type, all oil revenue received by government and SNH, and state allocations. - Build MINFI capacity to analyze the oil sector, possibly creating a dedicated monitoring unit. - Have an independent internationally reputable firm perform an external audit of SNH. - Ensure budget documents reflect all government oil revenue, including amounts retained by SNH to finance operating expenses; account for volatility and nonrenewability of oil revenue. ### Procurement, civil service integrity, and internal controls - Civil service ethics and enforcement: - Well-defined code of conduct; enforcement bodies exist (standing civil service disciplinary board, Budgetary and Financial Disciplinary Board, anti-corruption commission). - Key finding: these bodies are not functioning effectively and penalties for embezzlement are rare. - Public procurement: - ARMP established in 2001; Public Procurement Code published in 2004 (applies to services CFAF 5 million and above). - Ex ante controls for contracts CFAF 30 million and over; ex post audits by firms for contracts over CFAF 500 million; ARMP publishes weekly procurement record and annual report. - Key finding: procurement rules meet international standards but are not strictly followed; number and value of over-the-counter contracts increased notably in 2007. - ARMP monitoring data (selected): - Total public contracts — Number: 3,638 (2004); 4,096 (2005); 3,743 (2006); 4,164 (2007); 4,657 (2008). - Total appropriations (in billions of CFA francs): 339.7 (2004); 305.0 (2005); 313.9 (2006); 551.2 (2007); 467 (2008). - Contracts by competitive bidding — As a percentage of total: 93.3 (2004); 94.0 (2005); 93.4 (2006); 86.3 (2007); 93.6 (2008). - Over-the-counter contracts — Number: 156 (2004); 236 (2005); 238 (2006); 556 (2007); 292 (2008). Appropriations (in billions of CFA francs): 32 (2004); 61.2 (2005); 57.1 (2006); 181.5 (2007); 72 (2008). - Internal audits and tax administration: - Multiple internal controls (DGB, financial comptrollers, accountants, CONSUPE) have not guaranteed effective control; errors and embezzlement noted. - DGI had no internal audit since its creation in 2005; DGI National Inspection being reorganized. - External/independent audits are intermittent; taxpayer safeguards exist (appeals, advance tax rulings for DGI). ### External audit and oversight bodies - Audit Office (Court) (law 2003; established January 2006): - Mandate: judicial control of public accountants’ accounts across central government, EPAs, local governments, public/parapublic enterprises. - Staffing and operational constraints: - Only 25 magistrates (19 conduct audits; 6 administrative). - No assistants; received only one-third of accounts it should have; local governments produce less than 10 percent of expected accounts. - Has not received draft budget review law; reports produced for 2006 and 2007. - 2007 Audit Office report highlighted unreliability of public accounting, fragmentation to avoid procurement procedures, abuses in personnel travel, and lack of general account for administration of finances. - CONSUPE: - Internal control body attached to Office of President; 71 auditors; not independent; reports submitted to Head of State only. - Performs audits but does not assess accounts independently; effectiveness depends on presidential follow-up. - Transparency of audit reporting: - Audit reports are not submitted to Parliament and are not published (CONSUPE reports submitted only to Head of State). ### Key prioritized recommendations (condensed) - Restore integrity of the spending chain: - Eliminate or reduce use of parallel budget execution circuits; ensure budgetary regularization precedes or accompanies spending (including where SNH executes spending). - Accounting, arrears, and reporting: - Address accounting weaknesses; produce Budget review law per legal requirements; enforce complementary accounting period; define and monitor arrears (adopt 90-day CAEMC criterion); update arrears survey and formulate a clearance strategy. - Medium-term budgeting and integration: - Shift to a medium-term (three-year) budget focus with multiyear rolling program appropriations and annual payment appropriations for capital expenditure; integrate operating and investment budgets to capture recurrent costs. - Off-budget activities and consolidation: - Conduct a complete survey of extrabudgetary entities and integrate their revenue/expenditure into fiscal reporting; require SNH to prepare and update an annual plan of payments to Treasury. - Natural resources: - Publish quarterly comprehensive oil revenue reports (government and SNH); build MINFI sector monitoring capacity; commission an independent internationally reputable audit of SNH; ensure budget documents reflect all oil revenue and its characteristics. - Oversight and audit capacity: - Strengthen staffing and mandate of Audit Office (include performance audits); enforce follow-up on oversight recommendations; make audit reports public and submit them to Parliament. - Procurement and integrity: - Enforce Public Procurement Code; perform real technical and financial monitoring of public projects; impose sanctions where necessary; improve civil service file management and payroll controls. _Italic: Source: _cr10264 — IMF staff reassessment of fiscal transparency practices in the Republic of Cameroon (selected executive summary and chapters)._ ### EXECUTIVE SUMMARY ### _cr10264 - EXECUTIVE SUMMARY ### Introduction and scope - This report presents a reassessment of fiscal transparency practices in the Republic of Cameroon against the IMF Code of Good Practices on Fiscal Transparency. - The reassessment is based on: discussions with the authorities and other organizations; the authorities’ response to the IMF fiscal transparency questionnaire; and other sources of information. - The report includes an assessment of transparency in natural resource revenue management, with a detailed assessment contained in the annex and a summary in the staff commentary and recommendations. - The IMF Manual on Fiscal Transparency (2007) is referenced for further explanation of terms and concepts. ### Progress since 1999 and recent initiatives - Cameroon was a pilot case in the launch of fiscal ROSCs in 1999. - Initiatives undertaken since 1999 include: - Preparation of a Public Expenditure and Financial Accountability (PEFA) report. - Cameroon joined the Extractive Industries Transparency Initiative (EITI) in March 2005. - Creation of a platform for dialogue on public finance involving representatives of government, donors and lenders, and civil society. - Technical assistance from the IMF has supported some reforms. ### Overall assessment - Cameroon has achieved remarkable progress in recent years but additional reforms are required to meet the Code of Good Practices on Fiscal Transparency comprehensively. - The legal and regulatory framework governing public finance is described as clear and sound. - Implementation of the framework needs to be accelerated to achieve an adequate level of transparency. - The 2007 law on the government finance system is expected to be fully in effect by 2012 and should significantly improve fiscal management and transparency. - A number of other reforms need to be accelerated to avoid contradictions or inconsistencies among existing arrangements. ### Main findings on clarity of roles and responsibilities - General government is defined consistently with the Government Finance Statistics Manual 2001 (GFSM 2001) principles and is partly covered in the budget process. - The public nonfinancial sector components are listed (see Box 1 in source). Selected quantitative and descriptive points: - EPAs: 89 EPAs, 67 of which receive budgetary transfers as their sole source of financing or to supplement their own revenue. - Local governments: 360 communes; 10 regions (not yet operational, without individual budgets). - Public-owned corporations: 28 (including the SNH, the SNI, and Camtel). - Semi-public corporations: 40 (including the SONARA and the SIC). - EPAs vary in financing and operating methods: - Some EPAs are fully covered in the budget on both the revenue and expenditure sides (e.g., the Road Fund). - Some EPAs are funded primarily or solely by transfers from the government budget or by earmarked taxes (e.g., universities, National Statistics Institute). - Others have substantial revenue outside the government budget (e.g., CSPH; FEICOM). ### Specific issues identified - Fragmentation of the spending chain: - The spending chain is described as somewhat fragmented. - Parallel budget execution circuits are often used to avoid perceived cumbersome procedures. - The National Hydrocarbons Company (SNH) can be asked to execute some spending whose budgetary regularization is done after the spending has taken place. - Accounting and budget review: - Weaknesses in the accounting system should be addressed. - The Budget review law should be produced according to legal requirements. - Oversight and audits: - Internal and external oversight should be strengthened. - The Audit Office of the Supreme Court should be better staffed and its mandate enlarged to encompass performance audits in addition to its jurisdictional role. - Budget preparation and planning: - Budget preparation should focus more on multi-year budgeting, especially for public investment. - This is particularly important before the planned move to program-budgeting. - Oversight of the oil sector and SNH: - Internal and independent oversight of SNH should be strengthened. - The report recommends strengthening external audits of SNH by reputable consultancy firms. - Strengthening of the government’s oversight over the oil sector is recommended. ### Institutional and legal observations - Central bank (BEAC) and government: - Cameroon is a member of a monetary union with an independent central bank (BEAC) that plays no budgetary role. - The BEAC can grant statutory advances to the government in amounts not exceeding 20 percent of the fiscal revenue collected the previous year. - Outstanding statutory advances: currently zero (all advances previously used have been paid back). - Public financial corporations and QFAs: - Public financial corporations do not engage in quasi-fiscal activities (QFAs). - Government holdings in the financial sector are limited to three commercial banks: Banque Internationale pour le Crédit (10 percent of the capital); Société Générale de Banques au Cameroun (25.6 percent); and Société Commerciale de Banques au Cameroun (35 percent). - The market share of these three banks in terms of deposits and credits is about 40 percent. - Government holdings in nonfinancial corporations: - Extent of government holdings in the commercial sector is significant. - An annex to the budget law contains a list of all SEMs and indicates the shares held by the government and the parapublic sector; dissemination of this annex and other annexes to the budget law is limited. - The Holdings Division of the Ministry of Finance (MINFI) manages the government portfolio. - The Technical Commission for the Restructuring of Enterprises monitors economic operations of public and parapublic enterprises. - Legal frameworks and codes: - Laws and regulations governing private sector creation and functioning are presented across multiple instruments: Commercial Code, Investment Code, sectoral codes, the law on accounting, laws and regulations supporting enterprises, taxation laws, and the OHADA regional treaty. - Rules are transparent in the codes, but implementation varies. - Fiscal powers and accountability: - The 1996 Constitution describes relationships between the executive and legislative branches. - Parliament passes the government budget and laws on taxes and fees, can call the government to account, and can establish commissions of inquiry, although commissions of inquiry have rarely been formed. - The judiciary is independent; the Supreme Court includes an Audit Office charged with control and assessment of public accounts and preparation of an annual report on government accounts. ### Main recommendations (summary) - Restore the integrity of the spending chain: - Eliminate or reduce use of parallel budget execution circuits. - Ensure budgetary regularization precedes or accompanies spending, including where SNH executes spending. - Address accounting weaknesses and produce the Budget review law per legal requirements. - Strengthen internal and external oversight: - Reinforce staffing and mandate of the Audit Office of the Supreme Court to include performance audits. - Shift budget preparation toward multi-year budgeting, with emphasis on public investment, prior to moving to program-budgeting. - Strengthen internal and independent oversight and external audits of SNH, and strengthen government oversight of the oil sector. _This executive summary is drawn from the IMF staff reassessment of fiscal transparency practices in the Republic of Cameroon contained in the referenced report._ ### 11. The legal framework for the management of public finances is clear and defined by ### 11. The legal framework for the management of public finances is clear and defined by ### Legal and regulatory framework for public financial management - The 2007 law on the government financial system: - Establishes conditions for preparing, presenting, executing, and monitoring execution of the budget law. - Describes the structure and content of the budget law and defines the content and process for presenting the budget review law in Parliament. - Explains the principle of separation between the payment authorizing officer managing revenue or expenditure and the accountant. - Defines three categories of payment authorizing officers: principal (the ministers); secondary (the heads of devolved government units); and delegated (those appointed by principal or secondary payment authorizing officers). - Describes types of accounting to be maintained by the government and types of controls—parliamentary, administrative, and jurisdictional—to be established over the public accounts. - At the beginning of each fiscal year a Minister of Finance circular specifies procedures and gives detailed instructions to payment authorizing officers and accountants for execution and control of the government budget. - A Decree of June 25, 1997, establishing general regulations on public accounting, is being amended because several provisions are inconsistent with the 2007 law. ### Legislative basis for tax revenue collection - All taxes and fees are described in the General Tax Code and in the Customs Code (but not all exemptions—see paragraph 13). - Simplified manuals and information prospectuses exist. - The tax legislation framework functions under a self-assessment system. - Some provisions leave room for administrative discretion: - The Director-General of Taxes or the Minister of Finance may authorize a total or partial reduction of penalties. - Granting certain tax incentives is at the discretion of the authorities. - Financial obligations of oil companies are defined in the Oil Code, but exact terms are set on a case-by-case basis in oil contracts. ### Tax exemptions and tax expenditure - Tax exemptions and incentives are set forth in: - The Tax Code, the Customs Code, the Investment Code, sectoral codes, the law establishing the tax, financial, and accounting system applicable to partnership contracts, and international agreements. - Some exemptions are automatic (example: tax regime in the securities sector for enterprises bringing new shareholders to the Douala securities exchange). - Other exemptions require government approval and sometimes permit interpretation in eligibility (examples: regime for “structuring” projects with criterion “being a pillar of economic and social development”; customs exemptions for charitable works granted by the Minister of Finance). - The notion of tax expenditure is not officially established. - The General Customs Directorate (DGD) and, less systematically, the General Tax Directorate (DGI) prepare internal quantitative assessments. - For exemptions related to public projects financed by donors and lenders, tax expenditure is identified in annexes (unpublished) to the budget, as taxes are paid through counterpart funds. - Quantitative estimates provided in footnotes: - The DGD estimates that the total amount of customs exemptions amounted to CFAF 59.7 billion in 2008. - The DGI estimates the cost of corporate tax reduction related to reinvestment activities to amount to CFAF 6.7 billion in 2008. ### Tax administration and taxpayers’ rights - DGI administrative procedures are defined in the Book of Tax Procedures. - The administration is organized on a functional basis (legislation, disputes, audits, and collection) and by taxpayer type, with specialized units covering large enterprises, medium-sized enterprises, professional firms, real estate firms, and small taxpayers. - Note: These specializations do not exist in all regions; there are only two pilot centers for medium-sized enterprises. - There is no code of conduct for tax officers, but officers are required to maintain professional secrecy and other good practices specified in the Book of Tax Procedures. - Procedure manuals exist for some taxes, for taxation of large enterprises, and for all tax functions and production structures (Large Taxpayers Department, Center for Medium Enterprises Taxes, District Tax Centers). - Officers can request reports from third parties specified in the Book to enable audits and collection. - Customs provisions are similar; there is a joint tax/customs unit for audit missions in the field. - Taxpayers use single identification numbers for all taxes and all tax units; reforms are under way to improve protection of those identification numbers. - Taxpayers’ appeal rights and processes: - Taxpayers may request early administrative decisions (advance tax rulings) and would be informed within 30 days of tax consequences. - Appeals follow a three-phased process: regional directorate → Director-General of Taxes → Minister of Finance. - Taxpayers may be represented by third parties in relations with the tax administration. - Right to appeal to an independent court of law is limited in practice because appeals can only be made at the administrative chamber of the Supreme Court located in Yaoundé. - For customs there is no mechanism for advance administrative decisions, but implementation of the new government financial system is expected to allow significant progress. ### Public consultation - Public opinion is infrequently sought on proposed laws, regulatory changes, and broader policy changes. - The budget law is published in the official gazette and, up to 2007, on the MINFI website. - Annexes to the budget law are not confidential but are not systematically distributed or published. - Civil society is invited to share opinions on the Poverty Reduction Strategy Paper (PRSP), which determines core policies of the medium-term economic program. ### Contractual arrangements, PPPs, and privatization - Contractual arrangements between government and private entities are relatively clear, including the legal and regulatory framework for public-private partnerships (PPPs). - Model oil contracts exist, but details of signed contracts are not publicized. - Public-private partnership projects are virtually nonexistent, but a legal framework has been established. - The Ministry of Finance is called upon to play an important preparatory role in identifying eligible PPP projects but a much less important role from issuance of invitations to bid onward. - Legal framework for PPPs (Box 2 highlights): - Defined by: Law 2006/012 of December 29, 2006; Decree 2008/035 of January 23, 2008; Decree 2008/0115/PM of January 24, 2008; Law 2008/009 of July 16, 2008; Decree 2009/011 of January 13, 2009; and Order 069/CAB/PM of March 3, 2009. - Law 2006/012 defines project phases and conditions for resorting to PPPs but does not state which sectors are eligible. - Framework defines contract content and tax regime for private partners; selection, bidding, and award processes are clearly defined. - The Partnership Contract Implementation Support Council appraises and sets up partnership projects; MINFI is represented on its steering committee. - MINFI’s role is limited to giving an opinion on project eligibility and a reasoned opinion before competitive bidding; it has no formal validation authority during negotiation and award phases. - The legal framework does not contain provisions for budgetary monitoring of PPP contracts or any possible liabilities they may generate; monitoring role should be assigned to MINFI. - The legal framework does not provide for independent audits of PPP projects. - The tax regime contains generous incentives. - Privatization framework: - The legal framework for privatization is clear. - Technical preparation is entrusted to the Technical Privatization and Liquidation Commission (CTPL) under the direction of the Minister of Finance, based on a government-established privatization program. - Public is informed of various phases (invitations to bid to final award) through the media. - In cases of unsuccessful negotiations the public is insufficiently informed about reasons for negotiation failure. - Time to finalize privatizations is somewhat long due to: preparing preliminary studies; authorities validating strategic decisions; and obtaining go-ahead from development partners at key stages. - Privatization receipts are presented in the government budget as forecasts and actual performances. ### Debt management - There is no legislative framework for debt management. - The Minister of Finance is responsible for the stock of public debt. - Communes must obtain authorization of the MINFI (and the Ministry of Territorial Administration and Decentralization) before taking a loan. - Caps on central government debt are set within the framework of the budget law. - Debt management by the CAA is limited to making long-term projections that cover only confirmed commitments and do not account for possible liabilities. - The government has prepared a debt strategy, but it has not yet been approved. ### Open budget processes — calendar, medium-term framework, and sustainability - Budget calendar: - The draft budget law must be submitted to Parliament at least 15 days before the beginning of the budget session of November; Parliament has 20 days from the opening of the budget session to debate the draft budget law. - No other formally articulated provision on the budget timetable exists. - The budget circular, signed by the President of the Republic, is published late and is of formal rather than practical value. - General Budget Directorate (DGB) holds a seminar in April or May; budget conferences occur in about July, but the process is not formally established. - The draft budget law is normally approved on time, before the start of the fiscal year. - Medium-term framework and policy basis: - The Forecasting Directorate (formerly the Economic Affairs Directorate, DAE) prepares a multiyear macroeconomic framework for the PRSP, based on financial programming that includes endogenous growth, a tax module, and a debt module. - A second PRSP is being prepared for the period 2010–20. - Medium-term expenditure frameworks (MTEFs) are prepared for main social sectors (education, health, infrastructure, rural development). - Projections by economic sector and fiscal aggregates are prepared up to 2020. - The economic outlook and budget framework with macroeconomic assumptions are included in the economic report attached to the draft budget law placed before Parliament. - For investment: a record of projects is prepared with investment projects listed for each of the country’s ten regions; only payment appropriations for the year are included and implications for future years are not discussed; the multiyear investment program is not shown. - Fiscal objectives and sustainability analysis: - Fiscal objectives for the year are described in the report on the economic and social outlook attached to the budget law. - The future consequences of measures adopted during the current fiscal year are not explained. - There is no sensitivity analysis of economic assumptions or fiscal policy options. - There is no analysis of dwindling oil revenues due to depletion of oil reserves. ### Coordination of budgetary and extrabudgetary activities - Mechanisms for coordination and management of budgetary and extrabudgetary activities are generally well defined but insufficiently monitored. - The budget law places caps on appropriations and covers all transfers, but: - Some appropriations (e.g., the additional centime paid to the FEICOM and to local governments) do not go through either the budget or the treasury. - The equalization tax collected on behalf of the CSPH is paid directly to the CSPH. - This contributes to underestimation of total government revenue. - Forecasts and actual data on extrabudgetary activities by EPAs are not consolidated; overall government fiscal policy is therefore not known. - Related payments are made through special accounts rather than through the general treasury, while expenditure financed by grants and external loans is included in the budget. ### Budget execution, accounting, internal control, and arrears - Accounting and internal control procedures are not entirely effective; accounting system does not provide a basis for preparing reliable data on arrears. - Lack of published information on expenditures for which a payment order has been issued but which have not been paid makes assessment of the fiscal situation difficult. - Revenue recording: - Revenue is recorded mainly at the collections stage; receipts often occur through spontaneous deposits that do not give rise to receipt vouchers or accounting entries. - Only revenue with receipt vouchers triggers accounting entries before actual collection; full amount of accounts receivable is known only for receipts with vouchers. - Expenditure recording: - Centralized services: expenditure is computerized and recorded at commitment stage by payment authorizing officers with issuance of certificate of confirmation of availability of funds, then at the treasury at payment authorization and payment stages. - Treasury is aware of expenditure for which a payment has been authorized but not paid. - Expenditure following exceptional procedures is not systematically or completely monitored throughout the accounting process, raising settlement problems. - Comprehensive knowledge about government arrears is not easily accessible and requires constant work of recording and comparing budget and treasury data. - Internal controls are multiple and redundant (ordonnateurs, financial comptrollers, and accountants) and do not seem effective at all levels, as noted by the Audit Office and CONSUPE. - Delays produce very low implementation rates for certain investment projects; authorities sometimes resort to accelerated procedures (e.g., Road Fund expenditure). - Road Fund expenditure is recorded in budgetary accounts at time of transfer of payment credit to the treasury rather than at time of expenditure, implying treasury-reported budget expenditure may not correspond to expenditure actually executed. - The amount of expenditures for which a payment order has been issued but not paid (the “restes à payer”) is not included in published tables, though amounts are important and known by the treasury; estimated amounts only cover centralized services. - Reported cash balances reflect only part of the fiscal situation when amounts of “restes à payer” fluctuate substantially. - Accumulation of “restes à payer” during the last months of the year, if translating into payment arrears, could negatively affect budget execution and financial situation of government suppliers, potentially transmitting to companies and banks and increasing nonperforming assets. - The accumulation reflects weaknesses in government cash management and may encourage use of exceptional expenditure procedures; suppliers could face deterioration if banks tighten loan conditions or request payment of late fees. - Recommendation on arrears definition and monitoring: - It is important to clearly define the concept of arrear, including the period after which a “reste à payer” is considered an arrear, and to put in place monitoring mechanisms. - In line with the provisions of the CAEMC directive related to government financial operations (adopted by the member states in June 2008), this period should be set at 90 days. *Source: _cr10264 - 11. The legal framework for the management of public finances is clear and defined by* ### 26. The accounting system is capable of producing in-year reports on the budget ### 26. The accounting system is capable of producing in-year reports on the budget outturn only for the central government, but such reports are not submitted to Parliament. 2.2.1/2.2.2 ### Accounting, treasury reporting, and TOFE - The government’s chart of accounts is harmonized with the budget classification. - The treasury accounts (balance du trésor) are produced on a monthly basis, with a 20-day gap. - The treasury accounts cover operations to implement the budget law and cash operations. - Based on the treasury accounts, a table covering the government financial operations (TOFE) is prepared each month by the DAE, but only on a cash basis. - There is no detailed report on implementation of the budget law; the DAE prepares only very brief quarterly summaries. - The DAE also prepares a monthly economic bulletin on the economic sectors for the attention of the government and the development partners, but it is not published. - According to the 2007 law, Parliament should receive a midterm budget execution report by September 30 of the ongoing year; however, Parliament receives only the economic report that is submitted with the draft budget law at year-end and does not engage in any midyear review. ### Arrears, extrabudgetary execution, and budget adjustments - The last comprehensive survey of arrears dates back to 2005, and they are currently being paid. - Budget expenditure is occasionally executed without the observance of normal procedures (urgency, confidentiality, or cash management). - Example: the National Hydrocarbons Company (SNH) sometimes makes payments on behalf of the government and subtracts those payments from the oil revenue it transfers each month to the government. - Authorities state that such SNH payments are adjusted from a budgetary standpoint: the budget records the gross amount of the oil resources as well as the outlay (initially as expenditure for adjustment and later in the budget categories deemed to correspond to the outlay in question). - These operations do not go through the treasury; the treasury only learns of execution when the SNH informs it during monthly meetings on oil revenue. - Budgetary adjustments can be problematic because it is impossible to be sure that expenditure is recorded in the budget appropriation corresponding to its nature and recipient ministries. ### In-year revisions and supplementary budgets - The law requires revisions to revenue and expenditure during the fiscal year to be the subject of supplementary budgets. 2.2.3 - Budgets are not systematically revised; only one supplementary budget has been prepared in the past few years, for fiscal year 2008 (in September 2008), to account for oil price changes, additional revenue measures, and wage hikes. - That supplementary law was placed before Parliament and approved by ordinance of the President of the Republic. - Changes by comparison with the budget law are recorded in the budget review law. ### Final accounts, timing, and draft budget review laws - The final treasury accounts for December of fiscal year N are generally produced approximately in June of fiscal year N+1. - The complementary accounting period, legally two months, is not respected; there are delays in centralizing statements from accountants in the regions. - Revenue and expenditure accounts (comptes de gestion) should be prepared by principal accounting officers and sent to the Audit Office three months after the end of the fiscal year; these accounts are not prepared by all accountants, and quality is mixed. - Government accountants do not strictly observe the financial provisions of the 2007 law. - Draft budget review laws (loi de règlement) should close off budget execution and record changes in actual execution compared with forecasts and should be submitted to the Audit Office with supporting accounts by September 30 of the year following the fiscal year. - To date no draft budget review law has been submitted for examination by the Audit Office. - The DGB habitually prepares and submits directly to Parliament a simplified draft budget review law for fiscal year N-2, consisting merely of tables on execution of government budget revenue and expenditure; this is submitted with the draft budget law for fiscal year N (explaining why the 2009 budget law contains the 2007 budget review law). - These draft budget review laws are not based on the government annual financial statements (compte de gestion de l’administration des finances) and are accompanied by the administrative accounts from payment authorizing officers, considerably diminishing their value. ### Public availability and publication practices - The bulk of fiscal information is available to the public, but the authorities have not formally undertaken to provide the information by announcing a publication timetable. 3.3.1/3.3.2 - The budget review law, which should present budget execution details, is published with a lag of two years. - More aggregated data are published every quarter in the media, with varying lags; information on execution of the 2008 budget was published on April 29, 2009. - The presentation used in budget review laws and budget laws does not allow for easy analysis of the government’s financial operations. - The government is not bound by a publication timetable. ### Coverage and quality of budget documents - The budget documents cover central government activities and provide partial data on general government; defense expenditure is fully integrated in the budget. 3.1.1/3.1.4 - Budget documents accompanying the budget law cover central government activities and transfers to local governments and EPAs. - Principal components covered: ministries and autonomous constitutional bodies; the list of special treasury accounts is not included transparently; a list of EPAs is included in an annex, but reported budgetary transfers to them date back several years. - Budgets of EPAs are neither consolidated nor included individually in the budget law. - Missing from the budget law: table of budgeted staff by ministry and other government entities, tax expenditure, and contingent liabilities. - Defense expenditure is indicated in chapter 13 of the budget law with a level of detail comparable to other chapters. - The budget report contains a detailed table of tax and non-tax projections. - Treatment of VAT is reported on a gross basis (without subtracting VAT credit refunds, which are treated as expenditure). - Presentation of oil revenue in the budget documents varies; none of the definitions used covers all government oil revenue. - Expenditure is broken down by chapter and includes foreign-financed expenditure. ### Annexes, past data, and fiscal risks - Annexes to the draft budget law contain very little information on previous budget years and none on years beyond the ongoing year. 3.1.2 - An annex to the 2009 budget law entitled “Fiscal Revenue Forecasts” provides aggregated figures for fiscal revenue and expenditure for the year compared with forecasts and performances for the four previous fiscal years (2005–08); revenue and expenditure details are compared only with forecasts for the previous year; no information is included on subsequent years. - Fiscal risks are not analyzed in the budget context. 3.1.3 - The budget does not address sensitivity of macroeconomic assumptions nor contingent liabilities. - Budget projections of hydrocarbon prices include a precautionary margin to minimize disruptive impact of an unexpected decline in oil prices on budget execution (Appendix 1, paragraph 26). - QFAs are limited and their cost is neither systematically estimated nor presented. 3.1.3 - Subsidies to SONARA are included in the budget but explicitly listed only in annexes, which are not published. ### Debt, liabilities, and financial assets disclosure - Partial information is published on gross public debt. 3.1.5 - The budget law specifies planned new borrowings and payments in principal and interest. - An annex entitled “Public Debt,” which is not published, provides details on debt service and original amounts of financing agreements. - The stock of debt is mentioned in the annex “Report on the Nation’s Economic, Social, and Financial Position and Outlook.” The CAA publishes annual data. - Information on nondebt liabilities is not published. 3.1.5 - Main government liabilities not published: civil servants’ pensions (financed within the budget), debt and leasing contract guarantees for public enterprises, contingent liabilities related to difficulties in some important financial sector institutions, and arrears, especially to public and parapublic enterprises. - Other obligations from public-private partnership contracts are possible under the 2007 Decree; no information is published on such obligations. - Information on government financial assets is not published. 3.1.5 - Annexes (not published) contain lists of public enterprises and government equity holdings with original capital, turnover, and outturn; market value and value of assets are not estimated. ### Long-term analysis, guide to the budget, and classifications - Authorities occasionally conduct and publish long-term public finance analyses in the context of the PRSP. 3.1.7 - There is no guide to the budget; after enactment, only a summary is published in the official gazette. 3.2.1 - Budget classifications are broadly consistent with international standards. 3.2.2 - Classification harmonized with public chart of accounts and treasury accounts. - There is administrative, economic, and functional classification; no program classification. - Current appropriations are broken down by chapter, section, article, and paragraph; investment appropriations are broken down by project, article, and paragraph and made available by article in each ministry. - A separate document presents the annual investment budget as a list of projects by ministry and source of financing; this report is widely disseminated and published by the media at the beginning of the fiscal year. - Fiscal revenue is broken down by type. ### Overall balance, program budgeting, and performance information - Only the overall balance is shown in the budget documents; primary or nonoil balances are not referenced. 3.2.3 - A primary nonoil balance is presented in the TOFE, notably to monitor the IMF-supported financial program. - The budget documents do not report the general government balance and there is no consolidated balance for local governments. - Objectives and expected results of government activities are described in general terms; program performance indicators/outcome assessment have not been developed and should be before moving to program budgeting. 3.2.4 ### Integrity of forecasts, accounting policy, and reconciliation - Budget forecasts appear optimistic, but the variance between budgeted and actual cash-basis outturns of main fiscal aggregates is disclosed to the public. 4.1.1 - There is a tendency to overestimate nonoil revenue slightly (by about 5 percent in 2008), especially due to regular overestimation of nontax revenue. - Oil revenue is systematically higher than forecast owing to a margin of prudence concerning crude oil prices. - Rate of investment expenditure execution has been rising but remains low. - An annex to the budget law contains tables showing gaps between budgetary forecasts and actual performances over the past four years. - A table on budget execution is published quarterly in the media but shows expenditure on a cash basis, giving an inaccurate picture of budget execution in the ongoing fiscal year. - Information on budget execution on a payment order basis is published with a gap of two years, in the budget review law. - Statements on accounting policy are not included in the budget documentation or final accounts. 4.1.2 - There is no reference in budget documents to the accounting basis used; this is defined in the 2007 government budget law. - General government accounting follows the accounting framework established for all the CAEMC member states. - Information on revenue is recorded on a cash basis; information on expenditure is presented on commitment, payment order, and payment bases, but only for centralized services. - Accrual-basis accounting is gradually being put into use but is still incomplete; final accounts are closed off with a delay of several months. - Because administrative accounts and final treasury accounts are not produced in a timely way, reconciliation with the budget review law contents cannot be ensured. - The process of reconciling budget execution data has generally improved, but there is partial fragmentation of cash management. 4.1.3 - Bodies set up: national debt committee, payment validation committee, and cash flow plan assessment committee (the latter meets weekly). - Reconciliations between the treasury and the BEAC are continuous, reducing government cash flow management costs. - Consolidated cash management is not fully observed: several government bodies and EPAs still maintain accounts outside the treasury and the BEAC in commercial banks (e.g., CAA for debt operations and externally-financed capital expenditure, and the Road Fund), despite instructions from the Minister of Finance to the treasury to counter this development. - The treasury is seeking to make transfers to EPAs on a monthly instead of annual basis. *Source: _cr10264 - 26. The accounting system is capable of producing in-year reports on the budget* ### 49. Civil servants are subject to a well-defined code of conduct; however, penalties are ### _cr10264 - 49. Civil servants are subject to a well-defined code of conduct; however, penalties are rarely imposed. ### Ethical behavior, disciplinary bodies, and enforcement - Ethical behavior governed by: the general rules and regulations of the civil service and the bylaws of special units. - Enforcement instruments in law and decree: - Standing civil service disciplinary board (Decree of 2000). - Budgetary and financial disciplinary board (Decree of 2008). - Anti-corruption national commission; anti-corruption steering committee set up in 2005 with civil society representation. - Law of 2006: obligation for government officials at the level of director and above to declare their fortune; implementing regulations still under preparation. - Key finding: These bodies "do not seem to be functioning effectively, and it is rare for penalties to be imposed for embezzlement." ### Civil service recruitment, personnel management, and payroll issues - Entry: open competitive examination (concours) based on merit per 1994 general rules and Decree of 2000. - Specific bylaws exist for judiciary, national security, and penitentiary administration. - 1992 Labor Code governs contractual recruitment. - Promotions/upgrading: merit-based, founded on annual assessments and formal examinations (Decree of March 20, 2001). - Administrative and file-management limitations: - Personnel files centralized for about 128,000 civil servants out of a total of some 172,000. - Files for defense, police, penitentiary, higher education, and judiciary managed by respective administrations and payroll unit. - Latest physical census of civil servants dates back to 2005. - Reorganization and updating of personnel files not completed; preparations underway to institute electronic filing. - Operational weaknesses: - Errors and instances of fraud exist. - Regularizations of payments for upgrades and promotions take longer than expected, and substantial arrears have accumulated. ### Public procurement framework and practice - Institutional framework: - Public procurement regulation agency (ARMP) established in 2001 (Decree of February 23, 2001) as an EPA under the Office of the President. - Public Procurement Code published in 2004 (Decree of September 24, 2004); applicable to all services valued at CFAF 5 million and above. - ARMP mission: regulate, monitor, and assess public procurement; regional field offices being created in the country’s 10 regions. - Procedural features: - Ex ante controls by independent observers for public contracts valued at CFAF 30 million and over. - Four specialized commissions for contracts valued at CFAF 100 million to CFAF 1 billion. - Ex post audits by audit firms on contracts over CFAF 500 million and on a randomly-selected sample of 25 percent of contracts valued at between CFAF 30 million and CFAF 500 million. - ARMP working toward an electronic public procurement database; publishes a weekly procurement record and annual report to the President. - Key finding: "Procurement rules meet international standards but are not, in practice, strictly followed." Notably, the number of over-the-counter contracts increased significantly, notably in 2007. - Box 4 — ARMP monitoring results, 2004–08: - Total public contracts 1/ - Number: 3,638 (2004); 4,096 (2005); 3,743 (2006); 4,164 (2007); 4,657 (2008) - Appropriation (in billions of CFA francs): 339.7 (2004); 305.0 (2005); 313.9 (2006); 551.2 (2007); 467 (2008) - Contracts by competitive bidding - Number: 3,316 (2004); 3,744 (2005); 3,382 (2006); 3,514 (2007); 4,293 (2008) - Appropriation (in billions of CFA francs): 302.4 (2004); 235.9 (2005); 248.6 (2006); 355.4 (2007); 386 (2008) - As a percentage of the total: 93.3 (2004); 94.0 (2005); 93.4 (2006); 86.3 (2007); 93.6 (2008) - Over-the-counter contracts - Number: 156 (2004); 236 (2005); 238 (2006); 556 (2007); 292 (2008) - Appropriation (in billions of CFA francs): 32 (2004); 61.2 (2005); 57.1 (2006); 181.5 (2007); 72 (2008) - As a percentage of the total: 4.3 (2004); 5.8 (2005); 6.4 (2006); 13.4 (2007); 6.3 (2008) - Claims received: ... (2004); 64 (2005); 32 (2006); 141 (2007); 133 (2008) - Of which, claims justified: ... (2004); 19 (2005); 8 (2006); 87 (2007); 68 (2008) - Source: ARMP Annual Report. - Note 1/: "Contracts awarded, order letters (for public contracts involving amounts of at least CFAF 5 million and up to CFAF 30 million), and amendments." ### Internal audits, tax administration controls, and independence - Internal audits: - Internal verifications conducted by DGB, financial comptrollers, public accountants, Budget Operations Control Directorate, ARMP, and ministry staff supervision units. - Multiplicity of internal controls has not guaranteed efficiency; CONSUPE and the Audit Office highlighted errors and embezzlement. - Tax administration internal monitoring: - No internal audit of the DGI since its creation in 2005. - DGI has a National Inspection of Services currently being reorganized and modernized in line with a new MINFI organizational chart. - The DGD has not been subject to regular internal audits; some occasional audits performed. - External audits: CONSUPE (budget execution) and General Inspection of Financial and Budgetary Affairs of MINFI (tax operations); external/independent audits sometimes for specific taxes (forestry and road). - Taxpayer safeguards: dispute mechanisms and, for DGI, possibility of advance tax ruling (paragraph 15). - Legal protection from political interference: - "The DGI and the DGD are central administrations of the Ministry of Finance, and their senior officials are subject to the civil service codes, with no particular immunities." ### Public and independent oversight: Audit Office, CONSUPE, and reporting - Audit Office (created by law in 2003, established January 2006): - Mandate: judicial control of public accountants’ accounts across central government, EPAs, local governments, and public/parapublic enterprises. - Requirement: receive accounts three months after fiscal year closure (central government, EPAs, local governments) and three months after approval by competent body (public/parapublic enterprises). - Produce annual reports; submit to President of the Republic and President of the National Assembly and published in the official gazette. - Reports produced for 2006 and 2007; 2007 report highlighted: - Fragmentation of orders to avoid procurement procedures. - Abuses and discrepancies in personnel travels. - Public funds maintenance issues. - Unreliability of public accounting. - Lack of a general account for administration of finances and unreliable accounts for several EPAs and decentralized local governments. - Operational constraints of the Audit Office: - Staffing and resource shortfall: - Only 25 magistrates; 19 conduct audits; 6 perform administrative tasks. - No assistants for magistrates. - Receipt of accounts: has received only one-third of the accounts it should have received for control and assessment; first accounts received starting only in 2004. - Local governments produce less than 10 percent of expected accounts. - Accounts received are incomplete, lack supporting documents, and are of inadequate quality. - "To date, the Audit Office has not received any draft budget review law." - CONSUPE: - Highest institution for public finance internal control; attached to Office of the President and headed by a minister delegate. - Reorganized by Decree of 2005; comprises 71 auditors, support and administrative staff. - Program of activities proposed by minister delegate and approved by the President; reports submitted to Head of State who decides on follow-up. - Minister delegate chairs the budgetary disciplinary board for penalties on payment authorizing officers and managers. - 2006 activity: 20 audit missions across ministries, local governments, public sector enterprises, EPAs, and public projects/programs. - CONSUPE reports on discrepancies (notably procurement and EPA management); does not assess accounts and is not independent from the executive. - Effectiveness depends on presidential follow-up; reports have consequences if submitted to justice and the Budgetary and Financial Discipline Board. - Reporting and transparency issues: - "Audit reports are not submitted to Parliament and are not published." CONSUPE reports are submitted to Head of State only. - Audit Office has not formally received any draft budget review law for examination despite obligation to opine. ### National statistics and data dissemination - National Institute of Statistics: - Status: EPA; director-general and managing board members appointed by presidential decree; under technical tutelage of ministry responsible for statistics. - Uses and validates fiscal data from Ministry of Finance but does not verify their quality. - Cameroon subscribed to the General Data Dissemination System (GDDS) since 1998 and intends to transition to the Special Data Dissemination Standard (SDDS) but has not set a date. ### IMF staff commentary — progress, gaps, and reform priorities - General assessment: - Cameroon was a pilot case for the ROSC initiative in 1999 and has implemented numerous reforms with development partners and IMF technical assistance. - Examples: PEFA report (2007), joined EITI in March 2005, platform for public finance dialogue, and "Transparency in public management" cited in the September 2008 circular on 2009 budget preparation. - Remaining challenges: - Legal and regulatory framework is clear and sound, but implementation needs strengthening to meet the IMF Code of Good Practices on Fiscal Transparency. - Adoption of the 2007 law on the government financial system expected to be fully in effect by 2012 and will help improve fiscal management and transparency. - Need to avoid contradictions among existing arrangements and accelerate reforms. - Specific issues highlighted: - Clarity of roles and responsibilities: central government narrowly defined; no consolidation or monitoring of local governments or EPAs; quasi-fiscal activities and certain SNH budgetary operations remain outside the budget framework. - Open budget process: proliferation of extrabudgetary allocations (EPAs, SNH) means the budget covers only a portion of public revenue and expenditure, complicating fiscal position analysis. - Accounting weaknesses prevent preparation of final accounts and a budget review law verifiable by external audit. - Public availability of information: improved, with quarterly budget execution data and efforts by tax units, but websites often outdated and budget documents lack summaries for public understanding. - Assurances of integrity: rules and regulations often ignored; Audit Office lacks means and authority; CONSUPE audits intermittent and internal; little follow-up on reports; penalties rarely imposed; external audits not mandatory for public/parapublic enterprises. - IMF staff view: "A great deal of progress is still needed to ensure the consistency of public finance with the standards in the IMF Code of Good Practices on Fiscal Transparency." Implementation recommendations follow in the source text. *Source: _cr10264 - 49. Civil servants are subject to a well-defined code of conduct; however, penalties are rarely imposed.* ### 67. The transparency of the budget process should be increased through a medium-term ### 67. The transparency of the budget process should be increased through a medium-term ### Cash management, arrears, and budget execution - Improve cash management to reduce the amount of expenditure for which a payments order has been issued but which have not been paid yet ("restes à payer"). - Adopt, in line with the CAEMC directive, the 90-day criterion to define arrears and put in place a monitoring mechanism for "restes à payer". - Update the survey of the stock of government arrears and their valuation, and formulate an accounting method to properly monitoring them and a transparent strategy for clearing them. Take steps to prevent the accumulation of further arrears. - Bring together all of the accounts maintained at the BEAC into subaccounts of one principal treasury account, so as to improve the available picture on financial assets of the state, realign cash management, and reduce the cost of treasury financing. ### Medium-term budgeting, integration, and multiyear planning - Further instill a medium-term focus into budget preparation and initiate budget preparation in a three-year horizon by introducing notably, in line with the calendar envisaged by the 2007 law on the government financial system, the concept of multiyear rolling program appropriations with annual payment appropriations for capital expenditure. - Improve the integration of the operating budget with the investment budget so as to be able to take account systematically of the recurrent expenditure generated by future and past investment projects and enhance investment budget execution. - Avoid the gradual disintegration of the budget through the creation of totally autonomous bodies carrying out their budgetary operations outside the budget and the treasury, and limit extrabudgetary activities to the extent possible. A complete survey of such entities should be conducted in the short-term together with an assessment of their extrabudgetary activities. - Strengthen long-term analysis of the impact of the revenue losses to be generated by the exhaustion of the natural resources on the sustainability of government finance. ### Integration of off-budget revenue and extrabudgetary entities - Show the revenue and expenditure allocated to entities that are outside the scope of the budget by integrating them into revenue and transfers (e.g., the total "centime additionnel", the revenue retained by the SNH to finance its operating expenses, etc.). This would pave the way for a more accurate assessment of the fiscal stance. - Require from the SNH to prepare an annual plan of payments to the treasury to be updated monthly and submitted to the treasury. - Review the public expenditure process and assess the efficiency of ex ante controls, possibly to simplify them and avoid the use of exceptional procedures that disrupt the normal channels of public expenditure, such as the settlement of public expenditure by the SNH. ### Budget documentation, timetable, and public reporting - Improve the content and transparency of the budget documents and compare the forecasts in the budget law with the previous years’ performances rather than forecasts. Supplement the budget law with the summary tables to improve reporting to Parliament and the public about the action and the activities of the government. - Formalize the budget timetable and compile a guide on budget preparation which would ensure an effective participation of all line ministries in the preparation process. - Prepare and disseminate clear, adequate summaries on fiscal data. - Distribute monthly budget execution data from the tableau de bord of the Forecasting Directorate. - Update the Ministry of Finance website and post on it the financial regulations, the detailed budget law, and the budget review law, and establish links with the operational sites of the DGD, the DGI, and the ARMP. - Prepare and publish a report on tax expenditure and its impact on the budget. ### Public procurement, controls, and oversight - Enforce the Public Procurement Code and perform real controls for the technical and financial monitoring of public projects. - Emphasize quality and management control, and impose sanctions where necessary. - Ensure follow-up of the recommendations made by the oversight bodies and wide dissemination of their reports. ### Auditing, internal controls, and the Audit Office - Enforce observance of the complementary period cutoff date to ensure timely compilation of the December treasury accounts and enable the principal accountants to prepare their treasury final accounts. - Create an audit capacity at the Audit Office by expanding its mandate to performance auditing and by preparing a medium-term recruitment strategy. - Observe the rules and regulations for preparation and submission of the budget review law to the Audit Office within the prescribed time limits. - Internal audits are conducted at several levels, but their effectiveness needs to be increased. A proper external audit should be established. ### Roles, consolidation, and GFSM 2001 alignment - The budget documents should provide information on general government, in accordance with the GFSM 2001, that is, including, in addition to the central government, a consolidated budget for the EPAs (net of government transfers) and the local governments. The fiscal position of the general government should be submitted for information to the National Assembly and the public. - It would be appropriate to review the list of EPAs so as to clarify the status of those whose nature is unspecified. ### Transparency in natural resource management — findings - Cameroon’s oil revenue is essential to the financing of the government budget and to the balance of external trade: in 2008 oil products accounted for more than one half (about $1.8 billion) of Cameroon’s exports and more than one third (7.5 percent of GDP) of government revenue. - Oil production is expected to continue declining in the coming years; authorities intend to promote development of mining of other resources such as natural gas, bauxite, cobalt, nickel, and iron. - The legal framework governing natural resource revenue is clearly defined (Oil Code Law 99-013; Mining Code Law 2001-001; implementing decrees Decrees 2000-465 and 2002-048). - Main procedures for award of licenses are well established but leave discretion to authorities; article 9 of the Oil Code states the government "shall deal at its absolute discretion with bids for oil contracts and applications for permits. Absolute or conditional refusals shall not give rise to any right of applicants to appeal or to receive compensation of any type whatsoever." - Details of signed oil contracts are not published; contracts are the subject of press releases naming signatory enterprises and zones. - The bulk of public oil revenue is collected by the SNH; a portion of those receipts is not passed on to the government, serving to finance the operations of the SNH. - Whereas the nature of the financial obligations of oil companies to the government is defined in the Oil Code, the exact terms of those obligations are negotiated freely following call for bids or "over-the-counter" transactions and are not published. ### Transparency in natural resource management — recommendations - Publish quarterly reports showing, by revenue type, all oil revenue received by the government and the SNH, and stating how it is allocated. - Build the capacity of the MINFI to analyze the oil sector, possibly by creating a unit dedicated to monitoring the sector. - Have an independent internationally reputable firm perform an external audit of the SNH. - Ensure that budget documents reflect all government oil revenue, including revenue retained by the SNH to finance its operating expenses, and take account of the intrinsic characteristics (volatility, nonrenewability) of oil revenue. _Italic: Source: _cr10264 - 67. The transparency of the budget process should be increased through a medium-term (PDF)._ ### 16. A large share of public oil revenue is collected by the SNH. Indeed: ### _cr10264 - 16. A large share of public oil revenue is collected by the SNH. Indeed: ### SNH role in collection and use of oil revenue - The share of production to which the state is entitled is managed directly by the SNH, which is responsible for its marketing. - The SNH transfers the proceeds of those sales to Treasury after deducting from them: - the government’s contribution to the operational costs of oil operations (as stated in the oil contracts), and - its mandated expenses (inspection costs, management of security stocks, participation in international organizations, promotion of the oil sector, etc.). - Signature and production bonuses are not paid to the government but to the SNH, which uses them to finance its non-mandated expenses aimed at ensuring the development and sustainability of its operations. - As public participation in oil contracts occurs through the SNH, the latter collects the dividends paid for this participation; those dividends also help finance the company’s non-mandated expenses. (para. 16) ### SNH financing, debt, and public participation - Oil contracts do not contain financing clauses enabling the government, directly or through the SNH, to borrow from the oil companies. (para. 17) - The SNH does not incur debt, as it funds its activities from its own resources. (para. 17) - Public participating interests in the oil sector are taken through the SNH, which publishes information on them in its annual reports. 1.1.5/1.2.4 (para. 17) - The SNH has taken participating interests of 20 percent in the four projects that have entered the production phase. Information on those interests is published in the company’s annual reports. (para. 18) ### Mining participation and revenue sharing - The Mining Code states that the award of a mining permit may give rise to the award to the state of shares representing up to 10 percent of the shares of the mining company. (para. 19) - The state may subsequently increase its equity holding; an equity increase is under consideration in the main mining contract signed to date following the withdrawal of one contract licensee company. The terms of the equity increase are under negotiation. (para. 19) - Example project: The Nkamouna project (cobalt, nickel, manganese) — Geovic company holds 60 percent of the shares. (footnote 25) ### SNH mandate, organizational placement, and activities - The SNH is a public-owned public corporation, fully controlled by the state and placed under the authority of the general secretariat of the Office of the President of the Republic. (para. 20) - Initial mandate (Decree 80-086): conduct studies on hydrocarbons, collect and store related information, monitor execution of oil contracts, provide professional training, and perform commercial and financial operations related to the sector. - Broadened mandate (Decree°2008-012): include development of export projects in the sector (especially gas) and authorization to negotiate, in liaison with the ministries responsible for mines, the economy, the environment, and commerce, oil contracts on behalf of the government. - The SNH is not involved in refining activities, which are performed by the national refinery (SONARA). (para. 20) - Under its mandate, the SNH is responsible for marketing the state’s share of oil production, paying oil companies the state’s contribution to production costs, and transferring the difference to the state after deducting its other mandated expenses. (para. 21) - Oil companies are required under their oil contract to give preference, all else being equal, to Cameroonian enterprises when awarding contracts for construction and for the provision of services; they must also establish and finance programs for the training of Cameroonian personnel. (paras. 21, 24) ### Pricing, stabilization fund, and quasi-fiscal activities - SNH sales of crude oil to SONARA occur on market terms; bulk sales (factory gate) of refined products occur at controlled prices. (para. 22) - The Hydrocarbon Price Stabilization Fund is financed, off budget, from the surplus generated by the price equalization system. (para. 22) - Production-sharing contracts generally contain social expenditure clauses, but those social expenditures appear marginal. (para. 23) - The SNH sometimes finances certain budgetary expenditure, which is subsequently regularized in the Treasury accounts. (para. 23) ### Allocation of natural resource revenue between central and local government - No oil revenue is allocated to the local governments. (para. 25) - Under the Mining Code, the ad valorem tax must be shared as follows: - 50 percent to the Treasury, - 25 percent to the population groups affected by the mining activity (10 percent for local residents and 15 percent for the commune responsible for the mining area), - 25 percent to support monitoring and technical supervision of the activities by staff of the directorate responsible for mines. - It is noteworthy that neither the latter share nor the expenditure it finances is shown in the government accounts. (para. 25) ### Budget processes, definitions, and treatment of SNH revenue - The authorities do not systematically prepare medium-term budgetary frameworks that take account of oil resource projections, nor do they conduct analyses of the long-term sustainability of government finance. 2.1.2/2.1.4/3.1.7 (para. III heading and 26) - The fiscal approach is essentially annual; no analysis of the long-term sustainability of government finance is conducted (e.g., no calculation of a sustainable nonoil primary deficit). A margin of prudence is included in budget projections of selling prices for Cameroonian oil. (para. 26) - There are no extrabudgetary funds for natural resource management; the budget law takes no account of the oil revenue allocated to the SNH. Oil revenue passed on to the government follows the normal budget procedures. 2.1.2 (para. 26) - The budget law takes into account only the natural resource revenue passed on to the government; it ignores revenue collected by the SNH on behalf of the government and not passed on, such as oil bonuses or the share of state oil retained by the SNH to meet its operating expenses. It also does not directly take account of the SNH’s own oil revenue, such as dividends paid for its participation in oil contracts. (para. 27) - The SNH finances mandated expenses by subtracting an equivalent amount from the oil revenue that it passes on to the government; this net-basis treatment gives a less complete picture of the magnitude of public revenue and expenditure than a gross-basis treatment would. (para. 28) - Oil revenue collected by the government is deposited on the treasury account and is fungible with government revenue from other sources; however, when the SNH finances its mandated expenses by deduction, that component does not pass through the treasury account. (para. 29) - Government reporting: the definition of “oil revenue” in budget documents covers only: - the corporate tax paid by the oil companies, and - the share of production to which the state is entitled under oil contracts. - Other levies (fixed fees, area tax, proportional royalties, additional levy) are included in total government revenue but are not reported as “oil revenue.” (para. 30) ### Public availability of information and transparency - The report on the nation’s economic, social, and financial position and outlook discusses latest developments and prospects in the oil sector, but available oil revenue data are limited to the government-defined “oil revenue.” (para. 31) - Quasi-fiscal activities of the government are not mentioned in the budget documents; annual budget documents do not discuss budget risks, including those related to oil price fluctuations. (para. 32) - The SNH publishes on its website quarterly data on: - production of the various oilfields, - the share to which the state is entitled, - the revenue generated by the marketing of that share, - the costs of the operational activities of the SNH, and - transfers to the government. (para. 34) - The Cameroonian EITI Committee publishes annual data on payments made by companies in observance of their budget obligations under oil contracts and conducts reconciliation of oil-related financial flows between the SNH and the government. (para. 35) ### Budget balances, financial assets, and asset valuation - The budget documents mention only overall balances, on a cash basis; nonoil balances are used in IMF discussions but are not mentioned in the budget documents. 3.2.3 (para. 36) - Government financial assets generated by oil revenue cannot be distinguished from other financial assets because government revenue is deposited into the treasury account; the authorities do not establish estimates of the value of natural resource assets based on expected production flows. 3.1.5 (para. 37) ### Assurances of integrity, audits, and reconciliation - The SNH is staffed with a financial controller and auditors and is required to forward their reports and certified annual financial statements to the Ministry of Finance; the SNH publishes those financial statements and auditors’ reports on its website (latest date back to 2007). 4.2.5 (para. 38) - The DGI monitors taxes paid to the government under oil contracts but does not have the expertise to ensure that taxes paid by the SNH for marketing the state’s share match amounts payable to the government; the interministerial committee does not have the information or a specialized financial unit to reconcile the data. The Audit Office lacks the means to carry out such reconciliations or a detailed audit of SNH accounts. (para. 39; footnote 26) - The tax administration has no ex ante flexibility in interpreting tax obligations negotiated in oil contracts; the DGI does not audit non-tax revenue collected by the SNH, such as bonuses and the state’s production share. 4.2.6/1.2.1 (para. 40) - The SNH compiles accounts annually in accordance with OHADA accounting standards and publishes accounts certified by its accountants. 4.3.1/1.1.5 (para. 41) - The SNH is not subject to external audits by an internationally reputed audit firm; local auditors carry out an exercise similar to an audit and publish results in the SNH annual report and on its website. (para. 42) - The EITI Committee has reconciled payments and collections for 2001–04 and 2005, revealing only minor differences; the Committee intends to finalize reports covering 2006, 2007, and 2008 by year-end and had transmitted a preliminary conciliation report to authorities with publication scheduled. The reconciliation is purely accounting in nature. (para. 43 and Box A1) *Source: _cr10264 - 16. A large share of public oil revenue is collected by the SNH. Indeed:* ### Appendix Table 1. A Summary Assessment of Practices ### Appendix Table 1. A Summary Assessment of Practices ### Clarity of Roles and Responsibilities - Overall assessment: Largely Observed. - 1.1 The government sector should be distinguished from the rest of the public sector and from the rest of the economy. - 1.1.1: General government is defined consistently with Government Finance Statistics Manual 2001 principles and is partly covered in the budget process. - 1.1.2: The fiscal roles of the executive, legislative, and judicial branches are clearly defined in law. - 1.1.3: The constitution defines relations between the central government, regions, and communes. The regions are envisaged in the constitution, but not yet operational. - 1.1.4: Relationships between government and the public nonfinancial corporations are clear to some extent. The status of certain units should be clarified. - 1.1.5: Government holdings in corporations are extensive; their public disclosure is limited. Laws and processes governing government regulation of the nonfinancial private sector are clear but complex. - 1.2 There should be a clear and open legal, regulatory, and administrative framework for fiscal management. - Overall assessment: Largely Observed. - 1.2.1: The legal framework for the management of public finances is clear and defined by laws and regulations, some of which are being amended for consistency with the Constitution and with the law on the government financial system. The 2007 law on the government financials system is a major achievement, though not yet fully implemented. The amendment of laws and regulations needs to be accelerated to avoid contradictions or inconsistencies with the new law on the public finance system. - 1.2.2: The legislative basis for tax revenue collection is clear. The legislative and regulatory tax framework is clearly defined. Taxpayers’ rights are well defined, and appeals against decisions on tax and nontax obligations are considered in a timely way. - 1.2.3: Public opinion is infrequently sought concerning proposed laws, regulatory changes, and broader policy changes. - 1.2.4: Contractual arrangements between the government and private entities are relatively clear, including the legal and regulatory framework for public-private partnerships. - 1.2.5: There is no legislative framework for debt management. ### Open Budget Process - Overall assessment: Largely Not Observed for budget preparation; Largely Observed for budget execution, monitoring, and reporting. - 2.1 Budget preparation should follow an established timetable and be guided by well-defined macroeconomic and fiscal policy objectives. - 2.1.1: The budget calendar followed in practice is not formally articulated. Recommendation: The calendar and a guide on budget preparation should be formalized. - 2.1.2(a): Multiyear budget forecasts and underlying macroeconomic assumptions are presented summarily in the budget law, but they are disconnected from the annual budgetary process. Recommendation: Budget preparation on a three-year horizon should be initiated by introducing the concept of rolling program appropriations for capital expenditure. The integration of the operating with the investment budget should be improved to reveal recurrent expenditure resulting from planned and past investment. - 2.1.2(b): Only the overall balance is shown in the budget documents. There are no fiscal rules. - 2.1.3: Fiscal objectives for the year are described in the report on the economic and social outlook attached to the budget law. The future consequences of the measures adopted during the current fiscal year are not explained. - 2.1.4: An assessment of fiscal sustainability is not included in the budget documentation. Such assessment would be important, in particular with regard to the depletion of oil reserves. - 2.1.5: Mechanisms for the coordination and management of budgetary and extrabudgetary activities are generally well defined but are insufficiently monitored. - 2.2 There should be clear procedures for budget execution, monitoring, and reporting. - Overall assessment: Largely Observed. - 2.2.1: Accounting and internal control procedures are not entirely effective, and the accounting system does not provide a basis for preparing reliable data on arrears. The widespread existence of "restes à payer” makes it difficult to have a reliable picture of the fiscal situation at any point in time. Recommendations: An operational definition of arrears should be adopted; a survey on the stock of arrears should be urgently undertaken, combined with a strategy for their settlement and steps to avoid renewed accumulation. The public expenditure process should be improved to make the use of exceptional procedures unnecessary. - 2.2.2: The accounting system is capable of producing accurate in-year reports only on central government budget outturn, but such reports are not submitted to Parliament. Recommendation: More frequent updates, at least quarterly, should be published and submitted to the legislature. - 2.2.3: The law requires revisions to revenue and expenditure during the fiscal year to be the subject of supplementary budgets. In practice, this procedure is rarely used. - 2.2.4: The final accounts are prepared with an excessive lag. The budget review law is not consistent with legal provisions. Recommendations: The accounting complementary period cutoff date should be enforced. The budget review law should be brought in line with legal provisions. ### Public Availability of Information - Overall assessment: Largely Observed for comprehensiveness; Largely Not Observed for presentation and timeliness. - 3.1 The public should be provided with comprehensive information on past, current, and projected fiscal activity and on major fiscal risks. - 3.1.1: The budget documents cover central government fiscal activities and provide partial data on general government; defense expenditure is fully integrated in the budget. Recommendation: The revenue and expenditure allocated to entities outside the scope of the budget should be integrated. A complete survey of extrabudgetary activities should be undertaken in the short-term. The budget should be supplemented with all currently missing documents. - 3.1.2: The budget annexes contain very little information on previous budget years and none on the years beyond the ongoing year. Recommendation: Forecasts should be compared to previous years’ outcomes rather than forecasts. - 3.1.3: Fiscal risks are not analyzed in the budget context. QFAs are not very important, and their estimated cost is not included in the budget documentation. - 3.1.4: Receipts from major revenue sources are identified individually. - 3.1.5: Partial information is published on gross public debt. Information on nondebt liabilities and financial assets is not published. - 3.1.6: The budget documentation does not provide the fiscal position of subnational governments but presents the financial statements of public corporations. Recommendation: The budget documents should add information on general government accounts. - 3.1.7: The authorities occasionally conduct and publish long-term fiscal analyses. - 3.2 Fiscal information should be presented in a way that facilitates policy analysis and promotes accountability. - Overall assessment: Largely Not Observed. - 3.2.1: There is no guide to the budget; after the budget law has been enacted, only a summary of it is published in the official gazette. Recommendation: A clear and simple summary guide to the budget should be widely distributed at the time of the annual budget. - 3.2.2: The budget classifications are broadly consistent with international standards. - 3.2.3: Only the overall balance is shown in the budget documents. - 3.2.4: The objectives and expected results of government activities are described in general terms; results achieved relative to objectives of major budget programs are not systematically presented to the legislature. - 3.3 A commitment should be made to the timely publication of fiscal information. - Overall assessment: Largely Not Observed. - 3.3.1: The bulk of fiscal information is available to the public. Budget execution details are published with a lag of two years in the budget review law. - 3.3.2: The authorities have not formally undertaken to provide the information by announcing a publication timetable. ### Assurance of Integrity - 4.1 Fiscal data should meet accepted data quality standards. - Overall assessment: Largely Observed. - 4.1.1: Budget forecasts appear optimistic, but the variance between budgeted and actual cash-basis outturns of the main fiscal aggregates is disclosed to the public. - 4.1.2: Statements on accounting policy are not included in the budget documentation nor the final accounts. Recommendation: The annual budget and final accounts should indicate the accounting basis used; generally accepted accounting standards should be followed. - 4.1.3: The process of reconciling budget execution data has been generally improved, but there is some fragmentation of cash management. - 4.2 Fiscal activities should be subject to effective internal oversight and safeguards. - Overall assessment: Largely Observed. - 4.2.1: Civil servants are subject to a well-defined code of conduct; however, penalties are rarely imposed. - 4.2.2: Civil service recruitment procedures are clear. - 4.2.3: Procurement rules meet international standards but are not, in practice, strictly followed. Recommendation: The Public Procurement Code should be enforced and real controls for the technical and financial monitoring should be performed. - 4.2.4: The legal framework for privatization is clear, but privatization processes lack transparency in some cases. - 4.2.5: Internal audits take place at several levels, but their effectiveness is somewhat limited. - 4.2.6: The tax administration does not have legal protection from political interference and does not have effective internal monitoring and control mechanisms. - 4.3 Fiscal information should be externally scrutinized. - Overall assessment: Largely not Observed. - 4.3.1: The jurisdictional control of the Audit Office is independent of the executive, and, in principle, its mandate covers all public sector activities. In practice, the functioning of the Audit Office is hampered by a lack of staff and by inability to enforce the rules. An internal audit is also performed by the CONSUPE, which is not independent of the executive branch. Recommendations: Capacity at the Audit Office should be enhanced, and its mandate expanded to allow performance auditing. A proper external audit should be conducted. - 4.3.2: Audit reports are not submitted to Parliament and are not published. Recommendation: Audit reports should be widely disseminated and follow-up ensured. - 4.3.3: The National Institute of Statistics has partial independence; independent experts are not routinely invited to assess fiscal forecasts and their assumptions. - 4.3.4: The National Institute of Statistics validates and uses the fiscal data received from the Ministry of Finance but does not verify their quality. ### Appendix Table 2. Public Availability of Information — A Summary (selected entries) - Table structure: Budget and Fiscal Report Element | Included in Budget/report Documents | Available to the Public | Para. Ref. | Code Ref. - Selected entries: - 1. Central Government (CG) budget estimates — Included: Yes — Available to the Public: Yes — Para. Ref.: 32, 33 — Code Ref.: 3.1.1 - 2. CG Defense Expenditures — Included: Yes — Available to the Public: Yes — Para. Ref.: 32 — Code Ref.: 3.1.1 - 3. CG EBFs (including special development funds, social security funds, resource revenue funds) — Included: Transfers to EBF are included. A list of EPAs is included in the budget annex — Available to the Public: No — Para. Ref.: 32 — Code Ref.: 3.1.1 - 4. CG Budget outturns — Included: Yes, but in an aggregated form for the past 5 years. Details are provided for the year N-1 budget (not outturn) — Available to the Public: Yes, on request — Para. Ref.: 32 — Code Ref.: 3.1.2 - 5. CG Budget forecasts — Included: No — Available to the Public: No — Para. Ref.: 35 — Code Ref.: 3.1.2 - 6. CG Contingent liabilities — Included: No — Available to the Public: No — Para. Ref.: 36 — Code Ref.: 3.1.3 - 7. CG Tax Expenditures — Included: No, except for foreign-financed projects with domestic counterpart funds — Available to the Public: Yes, on request, for the part included in the budget — Para. Ref.: 13 — Code Ref.: 3.1.3 - 8. CG QFAs — Included: No — Available to the Public: No — Para. Ref.: 37 — Code Ref.: 3.1.3 - 9. Macroeconomic assumptions — Included: Included the budgetary document prepared by the Directory of Forecasting which has medium-term macroeconomic assumptions. — Available to the Public: Yes, on request — Para. Ref.: 22 — Code Ref.: 2.1.2 - 10. Analysis of fiscal risks/sensitivity analysis — Included: No — Available to the Public: No — Para. Ref.: 36 — Code Ref.: 3.1.3 - 11. CG Debt — Included: Yes — Available to the Public: Yes, on request — Para. Ref.: 38 — Code Ref.: 3.1.5 - 12. CG Financial Assets — Included: Partially: the Budget law annex contains a list of public participation in public and semi-public enterprises, with some figures on the equity and turnover. — Available to the Public: Yes, on request — Para. Ref.: 40 — Code Ref.: 3.1.5 - 13. Sustainability Analysis — Included: Partially in the context of the PRSP — Available to the Public: PRSP — Para. Ref.: 41 — Code Ref.: 3.1.7 - 14. General government budget estimates — Included: No — Available to the Public: No — Para. Ref.: 34 — Code Ref.: 3.1.6 - 15. CG Monthly/quarterly reports on fiscal outturn — Included: Quarterly reports are reported in the press, periodically with varying degrees of timeliness — Available to the Public: Published in the press, but information very aggregated — Para. Ref.: 26, 31 — Code Ref.: 3.3.1 - 17. CG Final Accounts — Included: The Budget review law includes final accounts for the year N-2. So far they have not been audited by the Court but the authorities indicated that this would change next year. — Available to the Public: Yes — Para. Ref.: 29 — Code Ref.: 2.2.4 - 18. Consolidated general government Final Accounts — Included: No — Available to the Public: No — Para. Ref.: NA — Code Ref.: 2.2.4/3.2.3 *Source: _cr10264 - Appendix Table 1. A Summary Assessment of Practices* --- _Source: https://www.imf.org/-/media/websites/imf/imported-full-text-pdf/external/pubs/ft/scr/2010/_cr10264.pdf_