Governance and Accountability
DeMPA Training
World Bank ‐ CEMLA
Mexico City, Mexico
February 28 – March 4, 2011
Why place so much focus on governance and
accountability?
•
Historically, government debt management was limited to
borrowing, recording, and debt servicing
•
There was one policy goal
– Ensure that government financing needs were met•
This narrow objective had consequences
– Multiple borrowing units (front offices) – Several debt databases – No systematic analysis of cost/risk in the debt portfolio (i.e., no middle‐office function)In the 1990s, a new perspective emerged…
“The most pressing issue confronting governments is the need to
reform the institutional arrangements governing debt policy,
reform the institutional arrangements governing debt policy,
so that the technical expertise and experience required to
manage the risks of external debt competently and
transparently can be applied. Professionalism and
accountability can best be achieved when debt management
is assigned to an agency that is separate and autonomous
from the political process.”
Cassard and Folkerts‐Landau, (1997),“Sovereign Debt: Managing the Risks,” Finance and Development, IMF 3…and a new definition
“Sovereign debt management is the process of establishing and
executing a
strategy
for managing the government’s debt in
executing a
strategy
for managing the government s debt in
order to raise the required amount of funding, achieve its risk
and cost
objectives
, and meet any other sovereign debt
management goals the government may have set, such as
developing and maintaining an efficient market for
government securities.”
Consequently, new issues moved to the center
•
Policy goals
– What are the long‐term debt management objectives/goals?•
Strategy design
– How best to achieve those goals?•
De‐politicization and decision‐making
– What is to be decided at the political level, and what is best left to professional debt managers?to professional debt managers?
•
Organizational arrangements
– Is a debt management office required, and how to set it up? 5Consequently, new issues moved to the center
•
Evaluation
– How to evaluate the performance of debt management?How to evaluate the performance of debt management?
•
Audit
– How to have a performance audit of debt management?
•
Regulatory changes
Policy goals
•
Common primary debt management objectives
– Ensure that the government’s financing needs are metEnsure that the government s financing needs are met – Minimize borrowing costs over the medium to long term, consistent with a prudent degree of risk
•
Common subsidiary objective
– Promote development of the domestic debt market 7Strategy design
•
A medium‐term debt management strategy guides borrowing
decisions
decisions
– What are the preferred cost/risk trade‐offs? – Will the government borrow short‐term to reduce cost, or long‐ term to reduce interest‐rate and rollover risks? – Will the government borrow in foreign currencies to reduce cost, or in local currency to reduce the exchange‐rate exposure? – How to promote development of the domestic debt marketHow to promote development of the domestic debt marketDe‐politicization and decision‐making
•
Some decisions are commonly taken at the political level
– Policy goals – Medium‐term strategy – Supervision and evaluation•
Other decisions are taken by the debt manager
– Preparation of the debt management strategy proposal – Annual borrowing plans based on the strategy f h l – Execution of those plans•
There is a parallel with monetary policy
– Price stability (policy goal)→ inflation targeting (strategy)→ money supply management (execution) 9Organizational arrangements
•
Increasing demands for a debt management office
– Drive strategy developmentDrive strategy development – Determine annual borrowing plans – Create one comprehensive debt database – Assume overall responsibility for debt management activities – Build up a domestic yield curve – Report on the entire government debt
•
Debt management is moved out of the central bank
Evaluation and audit
•
Before the focus was limited
– Reports limited to debt statisticsReports limited to debt statistics – Audits limited to the financial accounts
•
Now the analysis is richer, considering debt management as a
process
– Evaluation reports submitted to the legislature, covering all debt management activities assessment of outcomes against the management activities, assessment of outcomes against the stated policy goals, and compliance with the debt management strategy – Increasingly a focus on performance audits 11
Regulatory changes
•
Before it was common to have detailed regulations on
individual transactions
individual transactions
– Borrowing restricted to certain markets and through certain instruments – Legislature’s approval required for all external borrowing•
Now legislation is policy‐based
Focus on policy goals strategy development and accountability – Focus on policy goals, strategy development, and accountability
Pulling it together
Legislature Minister/Cabinet Audit Central Bank 13 Principal Debt Management EntityLegal framework (DPI 1)
•
One dimension to assess
Legal framework
• Clear authorization to borrow and undertake debt‐related transactions and issue loan guarantees • Borrowing purposes specifiedScore C
• Plus… Clear debt management objectives in primary legislation • Requirement for annual reporting to the legislature and for external auditScore B
15 • Plus… Requirement in primary legislation to develop a debt management strategy • Annual reporting includes evaluation of outcomes against stated objectivesScore A
Managerial structure (DPI 2)
•
Two dimensions to assess
– Managerial structure for central government borrowings andManagerial structure for central government borrowings and debt‐related transactions
– Managerial structure for the preparation and issuance of central government loan guarantees
Managerial structure (dimension 1)
• Borrowing and debt‐related transactions are undertaken by a g y principal debt management entity or by several entities that coordinate closelyScore C
• Plus… Borrowings and debt‐related transactions are steered by a formalized debt management strategy • No undue political influenceScore B
17 • Plus… Borrowings and debt‐related transactions are undertaken by the principal debt management entityScore A
Managerial structure (dimension 2)
• Loan guarantees prepared and issued by one or more g p p y entities that coordinate closely and with the principal debt management entity (if one exists)Score C
• Plus… Loan guarantees are prepared and issued by a principal guarantee entity, which coordinates with the principal debt management entity (if one exists)Score B
• Plus… Loan guarantees are prepared and issued by the principal debt management entityScore A
Debt management strategy (DPI 3)
•
Two dimensions to assess
– Quality of the debt management strategy documentQuality of the debt management strategy document
– Decision‐making process, updating, and publication of the debt management strategy 19
Debt management strategy (dimension 1)
• Covers the medium term and at least 90% of existing and projected debt, and is based on debt management objectives • Contains guidelines for the preferred direction of risksScore C
• Plus… Has realistic target levels for risksScore B
Score A
Debt management strategy (dimension 2)
• Strategy proposal prepared by the principal debt management entity or jointly by entities
management entity or jointly by entities • Central bank’s views are obtained • Approved by the Minister/Cabinet and made public
Score C
• Plus… If proposal is not accepted, the rationale is presented in the final document • Updated at least every third yearScore B
21 • Plus… Updated annuallyScore A
Evaluation of debt management operations
(DPI 4)
•
One dimension to assess
– Level of disclosure of government debt management activitiesLevel of disclosure of government debt management activities, central government debt, evaluation of outcomes against stated objectives, and compliance with the debt management strategy
Evaluation of debt management operations
• Legislature receives an annual report on debt management • Legislature receives an annual report on debt management activities and outstanding central government debt
Score C
• Plus… Annual report contains an evaluation of how activities have complied with the debt management strategyScore B
23 • Plus… Evaluation of outcomes against stated objectives, and the debt management strategy and the rationale behind it • Report is made publicScore A
Audit (DPI 5)
•
Two dimensions to assess
– Frequency of internal and external audit of central governmentFrequency of internal and external audit of central government debt management activities, policies, and operations, as well as publication of external audit reports
– Degree of commitment to address the outcomes from internal and external audits
Audit (dimension 1)
• External audit of debt management activities policies and • External audit of debt management activities, policies, and operations within the past 5 years
Score C
• Plus… Frequent external audits (every 3‐5 years) and annual internal auditsScore B
25 • Plus… External audits conducted every 2‐3 years and external audit reports are made public within 6 monthsScore A
Audit (dimension 2)
• Commitment to address audit outcomesScore C
• Plus… Strong commitmentScore B
• Plus… Immediate commitmentScore A
Mapping to PEFA
• PEFA indicator on recording and management of cash balances, debt, and guarantees (PI 17)g ( ) – Dimension 3: systems for contracting loans and issuing guarantees – PEFA emphasizes having a single entity responsible for approvals and the use of transparent criteria and targets. – DeMPA drills down in greater detail on the legal framework, managerial structure, strategy development, and evaluation 27Mapping to PEFA
• PEFA indicator on effectiveness of internal audit (PI 21) – Dimension 1: coverage and quality of the internal audit functiong q y – Dimension 2: frequency and distribution of reports – Dimension 3: extent of management response to audit findings – Both PEFA and DeMPA emphasize the frequency of internal audit and the degree of commitment to respond to audit findings – Both PEFA and DeMPA look beyond just financial auditMapping to PEFA
• PEFA indicator on the scope, nature, and follow‐up of external audit (PI 26) ( ) – Dimension 1: scope/nature of the audit performed – Dimension 2: timeliness of submission of audit reports – Dimension 3: evidence of follow‐up on audit recommendations – Both PEFA and DeMPA emphasize the frequency of external audit, the timeliness of submission and response, and the effectiveness and timeliness of follow‐upPEFA expects a high quality audit to include aspects of a performance – PEFA expects a high‐quality audit to include aspects of a performance audit, whereas performance audit is key to DeMPA 29