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Ministry of Finance
Government of Mongolia
Ulaanbaatar, Mongolia.
January 2008
.
1
Formerly Economic Adviser, Ministry of Finance and Planning Commission of the
Government of India, and Professor (Public Policy), Institute for Integrated Learning in
Management (IILM), New Delhi. For any clarifications contact das.tarun@hotmail.com
CONTENTS
Part-1: Methodology
Selected References
Part-2: Policies
Selected References
Part-2: Policies
One of the major objectives of the ex-ante Financial Planning is to deal with
contingent liabilities of the government and risk management for unforeseen
events such as droughts, floods, earthquakes, land slides and other natural
disaster. Risk management and emergency response need to be clearly
distinguished. Risk management calls for ex-ante planning and investments to
reduce vulnerability. Emergency response involves ex-post expenditures for
reconstruction, rehabilitation and restoration of public infrastructure affected by
natural disaster, which can be greatly reduced through ex-ante planning and
investments in prevention and mitigation. While the occurrence of natural events
can not be predicted precisely and prevented fully, there is a possibility to reduce
the degree of vulnerability of populations through risk management. This can be
achieved in two ways: (i) planning with the purpose of the identification and
reduction of risk by integrating prevention and mitigation measures into national
development and financial plans and programs and (ii) financial protection
provided by transferring risk partly to the private sector or spreading it over time.
The latter can be achieved by strengthening both life and non-life insurance
institutions and allowing foreign and private investment in insurance funds.
However, this requires development of appropriate rules and regulations and
strengthening the independent regulatory authorities.
natural
hazard
engineering financial economic
engineering damage financial
vulnerability
vulnerability vulnerability
vulnerability loss
exposure mitigation ex-ante instruments
-
b) Contingent Credit Credit Payment
+
Administrative Costs Debt Repayment
-
c) Insurance
+ Insurance Payment
Premium
There is also a need to establish the necessary conditions for the use of
innovative capital market mechanisms such as catastrophe or natural calamity
bonds, commodity futures and weather-related derivatives. These instruments,
The same arguments hold good for life and non-life insurance. But, catastrophe
or natural calamity bonds are difficult to be developed by developing countries
like Mongolia which lack efficient money and capital markets. It may be easier for
Mongolia to develop other kinds of bonds such as “development funds” (viz.
municipal, social, urban, rural, roads, infrastructure development bonds etc.) to
meet critical needs. This can be helped by international development agencies.
The private sector also has the direct investment option. The community-wide
formal and informal financing instruments perform a very important role at the
local level by supplying resources, particularly in poorer areas. Regardless of the
source of financing, the implementation of these mechanisms requires close
cooperation between the public and private sectors, especially in reference to the
establishment of the appropriate legal and regulatory framework.
In some cases, existing development funds (municipal, social, urban, rural) may
also be used. Government can also impose an emergency cess or tax on the
existing tax payers. At the same time, the government would seek as much
international aid and donations as possible and resort to contingency credits.
Contingent liabilities are of two main types- explicit and implicit. Explicit
contingent liabilities are based upon legal and contractual commitment. Explicit
contingent liabilities include bonds or other liabilities contracted by the
government with put options for lenders, credit-related guarantees, performance
MOF, Govt. of Mongolia 8 Glocoms Inc. (USA)
Financial Planning Methodology and Policies – Tarun Das
Contingent liabilities are complex and not easy to quantify. There is no single and
uniform framework for their measurement. The choice of a technique depends on
the type of contingent liability being measured and the availability of requisite
data and information. It is well recognized that cash based accounting systems,
even supplemented by off-budget and off-balance sheet transactions, are not
suitable for managing contingent liabilities. Only the accrual accounting systems
can capture contingent liabilities as they are created. Within such systems,
contingent liabilities can be recorded at full face value or maximum potential loss
or expected value and expected present value of contracts.
Direct Contingent
Liabilities
Explicit • Sovereign debt • Direct guarantees for external loans
(domestic and external) by Aimags, local bodies, budgetary
• Committed Expenditures- entities and public sector enterprises
legal and non- • Guarantees on currency risks of
discretionary in the long foreign loans by commercial and
term (civil service development banks, if any
salaries and wages, • Guarantees on various types of risks
social security and (including market, currency,
insurance contributions, regulatory, political) in Built on
employment of Transfer (BOT) contracts or other
specialized staff in rural Public-Private Partnership, for the
areas, pension other development of infrastructure and
compensation to civil social sectors
servants, Social Welfare • Umbrella guarantees for various types
Fund) of loans (agriculture, agro-business,
• Benefits to children and micro-enterprises, housing etc.)
poor families • Deposit insurance of savings and
• Benefits to SMEs and commercial banks
rural areas, jobs creation • Guarantees on benefits (unfunded
and national liabilities) of the social security system
development • Future health care financing
Explicit contingent liabilities may represent a significant balance sheet risk for a
government. However, unlike most government financial obligations, contingent
liabilities have a degree of uncertainty. They are exercised only if certain events
occur, and the size of the actual fiscal outgo depends on the structure of the
contingent liabilities.
Sound public policy requires that a government needs to carefully manage and
control the risks of their contingent liabilities. The most important aspect for this
is to establish clear criteria as to when contingent liabilities will be used and to
use them sparingly. In a well-managed program, the government debt office may
be called on to assist in evaluating the government’s cost and risks under the
contingent liabilities, and to recommend policies for managing these risks.
Experiences of the industrialized countries suggest that more complete
disclosure, better risk sharing arrangements, improved governance structures for
state-owned entities and sound economic policies can lead to substantial
reductions in the government’s exposure to contingent liabilities.
An emerging country like Mongolia can adopt several public policy measures to
contain the risk of contingent liabilities. These include the following:
4. It is useful that the said centralised unit designs and issues contingent liability
instruments and monitors the associated risk exposures, and ensures that the
government is well informed of these risks.
5. Once the concepts, definitions, methodology and data problems have been
resolved and key organisational challenges addressed, a computerized
recording system for management of debt and contingent liability could be
introduced. Ministry of Finance, Mongolia is using the UNCTAD Debt
Management and Financial Analysis System (DMFAS) for recording and
monitoring external debt. The same system can be easily extended for
management of internal debt and contingent liabilities.
6. A guarantee fee must be charged for all guarantees. The fee needs to be
determined on the basis of the cost of borrowing plus the cost of provisioning.
Guarantee fees collected should not be taken as general revenues; rather be
kept in a separate contingency fund or contingent liability redemption fund.
The revenue from the guarantee fee will enable adequate reserves to be built
up over time. The government still may have to allocate some initial capital
from general revenues into the Reserve Fund in the event that the contingent
liability is called prior to the build up of sufficient reserves. The Government of
Mongolia has already established such a Contingency Fund.
10. The odds for the occurrence of a financial crisis and so the risk of implicit
contingent liabilities can be reduced by sound macro-economic policies,
complemented by appropriate legal, regulatory and institutional set-up for
effective prudential regulation, monitoring, surveillance and supervision of the
financial system and improved corporate governance. However, these entail
structural reforms with an unavoidably long-time scale.
Debt sustainability is closely related to the fiscal deficit, particularly to the primary
deficit (i.e. fiscal deficit less interest payments). Sustainability requires that there
should be a surplus on primary account. It also requires that the real economic
growth should be higher than the real interest rate. Countries with high primary
deficit, low growth and high real interest rates are likely to fall into debt trap.
Economic theory states that high fiscal deficit spills over current account deficit of
the balance of payments. Persistent and high levels of current account deficit is
an indication of the balance of payments crisis and needs to be tackled by
encouraging exports and non-debt creating financial inflows.
At present, Mongolia does not face these problems. For the past few years,
Mongolia has high economic growth, surplus on both domestic and external
current account and very low (in fact negative) real interest rate on external debt.
These positive developments should not lead to complacency on the part of the
government. The main challenge will be to ensure fiscal sustainability, low
inflation rates and stability in real exchange rates by adopting strict fiscal and
monetary discipline and sound management of mineral resources. Medium term
output is vulnerable to unfavourable weather shocks in the domestic sector and
risk of sharp fall of global prices of minerals, which may lead to fall in government
revenues and put constraints on social welfare and investment programs
financed by the windfall profits tax on minerals.
Public debt needs to be managed in such a way that the required amount of
financial resources is raised at the lowest possible medium and long-term cost
and with a prudent degree of risk. Risks include foreign exchange and financial
crisis; change in creditworthiness and insolvency (‘debt distress’); leading to
economic crisis and social instability (as in the case of East Asian crisis in 1997-
1999). Ministry of Finance should have a risk management framework that
identifies and assesses the financial and operational risks for the management of
public debt including external debt.
Public Debt Office will consist of the following independent debt offices with
associated functions:
(i)Independent Front Offices, which are responsible for negotiating new loans
with multilateral and bilateral funding organisations and other sources of
internal and external finance.
(ii)Back office, which is responsible for auditing, accounting, data consolidation
and the dealing office functions for debt servicing.
(iii)
(iv)Middle office, which is responsible for identification, assessment,
measurement and monitoring of debt and risk, dissemination of data and policy
formulation for both short and medium term, and setting benchmarks for debt
composition and currency-interest rate- maturity mix, and
(v)Head Office, which accords final approval for both internal and external debt.
(c)
Transparency in Risk Management: Debt management objectives should be
clearly defined, documented and disclosed at all levels dealing with debt
management. The measures of cost and risk that are adopted should be
explained. Objectives of debt management and preferred policies and measures
should be clearly indicated by the middle office. Equally important are the rules,
regulations, institutional and legal framework for debt management. Some may
feel that having a comprehensive debt management system as described here
will be expensive, but not having one may be more expensive.
Ministry of
Finance
Belgium Limit on the cost of borrowing The Parliament
(d) Limits on Public Debt: As regards legal framework, many countries have
enacted Fiscal Responsibility and Budget Management Acts and have set limits
on annual borrowing and total outstanding public debt as a percentage of GDP.
Parliament is the appropriate authority to set new limits of public debt (see Table-
10 and Table-11). It will be beneficial for Mongolia to legislate similar acts with
limits on fiscal deficit, annual borrowing and total outstanding public debt.
(e) Basic Principles of Risk Management: The risks in the structure and
composition of total debt should be carefully monitored and evaluated. Special
attention may be given to risks associated with foreign-currency and short-term
or floating rate debt due to exchange rate fluctuations over time. The risks should
be mitigated to the extent feasible by modifying the debt structure and taking into
account cost of doing so.
(g) Assessment of Risk: Another task of the Public Debt Office is to identify
measure and monitor risk. There are various models for risk assessment:
• To conduct stress tests of the debt portfolio based on economic and financial
shocks.
• Simple scenario models used by the World Bank and IMF.
• To project future debt services over medium and long term.
• To list key risk indicators over time.
• To summarize costs and risks for alternative strategies and debt portfolio.
External debt constitutes about 95 percent of public debt and is subject to various
risks such as liquidity risk, exchange rate risk, market risk, convertibility risk,
interest rate risk and yield risk (see Box-1).
At present, external debt service ratio at 2 percent of exports does not pose any
problem for the Mongolian economy, but in future debt sustainability may be at
risk if there is sudden fall of international prices of Mongolia’s major exports or
unexpected rise of prices of major imports. Significant falls in the global prices of
copper, coal, gold and cashmere and substantial rise of prices of petroleum
products may affect adversely the current account of the balance of payments
and may lead to the problem of external debt servicing for Mongolia.
(A1) Liquidity risk. Shortage of revenues, cash and foreign exchange to repay debt
and make interest payments. East Asian financial and foreign exchange crisis during
1997-1999 is the best example of liquidity crisis.
(A2) Interest rate risks. While fixed interest rate has the advantage of having fixed
interest payments over time, there may be a substantial loss in a regime of falling
interest rates. Solution lies to have a proper mix of variable and fixed interest rates.
(A3) Rollover risk. The risk that debt will have to be rolled over at an unusually high
cost or in extreme cases that it cannot be rolled over at all. To the extent that rollover
risk is limited to the risk that debt has to be rolled over at higher interest rates, it may be
considered a type of market risk.
(A4) Credit risk. Central government on-lends external debt to Aimags, local
governments and public sector enterprises. Losses may arise if these investments
donot have sufficient yields to repay debt and pay associated interests.
(A5) Currency risk. Currency risk arises when there is substantial depreciation of the
domestic currency in terms of the currencies in which external dent is denominated.
(A6) Settlement risk: Refers to the potential loss that the government could suffer as a
result of failure to settle, for whatever reason other than default, by the counterparty.
(A7) Convertibility risk: Easy convertibility of the domestic currency may lead to
capital flight at the slight anticipation of crisis.
(A8) Budget/ Fiscal Risk: Fiscal risk may arise from unanticipated shortfalls in
revenue or expenditure overruns. Government should consider both budget and off-
budget liabilities and try to minimize contingent liabilities.
(B1) Operational Risk is the risk that arises from improper management systems
resulting in financial loss. It is due to improper back office functions including
inadequate book keeping and maintenance of records, lack of basic internal controls,
inexperienced personnel, and computer failures. Probability of default is high with
inadequate operational and management systems.
(B2) Control system failure risks arise due to outright fraud and money laundering
because of weak control procedures, inadequate skills, and poor separation of duties.
(B3) Financial error risk. Incorrect measurement and accounting may lead to large
and unintended risks and losses.
Debt sustainability basically implies the ability of a country to service all debts –
internal and external on both public and private accounts- on a continuous basis
without affecting adversely its prospects for growth and overall economic
development. It is linked to the credit rating and the creditworthiness of a country.
Capital inflows to Mongolia had been mainly in the form of concessional loans
from multilateral and bilateral countries. There is very small reliance on non-debt
creating flows or other modes of capital due to underdeveloped capital and bond
markets. Such a system may not be sustainable for a long time and there is need
to diversify foreign capital market.
While bond lending and lending through new instruments together with
syndicated bank lending are forms of general obligation finance in the sense that
the lender provides money to be repaid on terms independent of the success of
investment made with the funds, financing by other alternatives (i.e., FDI, foreign
portfolio investment and foreign quasi-equity investment) involves risk-sharing
and responsibility sharing. For example, under FDI an investor is entitled to a
share of the distributed profits of a firm and an investor also shares in the
responsibility of managing the firm. Portfolio investment is similar, except that it
does not encompass sharing management responsibility.
Unlike other capital flows, FDI is a package that embodies capital along with
technology and managerial, marketing and technical skills. Presence of
multinationals promotes greater efficiency and dynamism in the domestic sector
and widens external trade. Training gained by local employees and their
exposure to modern organizational system and international best practices are
valuable assets for the host country.
Purpose Indicators
2. Liquidity (j) Debt service ratio: Ratio of total debt services (interest
monitoring ratios payments plus repayments of principal) to XGS
(k) Ratio of interest payments to reserves
(l) Ratio of short-term debt to XGS
(m) Ratio of total imports to foreign exchange reserves.
(n) Ratio of reserves to short-term debt
(o) Ratio of short-term debt to total debt
Although there is no unique solution to tackle various types of risk, general risk
management practices of the government aim at minimizing risk for government
bodies and public enterprises. These include development of ideal benchmarks
for public debt and monitor and manage credit risk exposures. Typical risk
management policies are summarized in Table-14.
Stress tests are closely related to the debt sustainability indicators and are useful
in identifying major liquidity risks, as well as strategies to mitigate them. Stress
tests can be used to test a variety of scenarios such as the following:
(a) Types of capital inflows (FDI, trade credit, other credits)
(b) Periods of access to capital markets
(c) Exchange rate changes/ derivative positions
(d) Risks due to price and interest rate changes
(e) Macroeconomic uncertainties (such as outlook for exports and imports)
(f) Policy uncertainties (fiscal and monetary policies)
• Shocks
– Real revenue growth
– Real depreciations
– Assets value growth
As regards legal and institutional set up, International experience suggests that
centralized debt offices in most of the countries are located under the Ministry of
Finance (MOF), only in Sweden it is located in the Central Bank, while five
countries viz. Australia, Austria, Ireland, Portugal and Sweden have independent
debt office, not a part of either the MOF or the Central Bank (see Table-16).
There is an advantage of locating the debt management office in the MOF. This is
because MOF in general is in charge of dealing with multilateral financial
institutions and bilateral donors. Within this institutional structure, in most of the
advanced countries, the debt offices are set up as an autonomous or separate
entity within a Treasury or as a statutory unit. This enables the debt office to
assume sufficient degree of operational independence.
It is observed from the legal systems in Brazil, India, Indonesia, Ireland, New
Zealand, Poland, the UK and others that, as a general rule, the Minister of
Finance is entrusted with all responsibilities relating to state finance, not only in
the context of representing the state externally, but also with respect to internal
matters such as reporting to Parliament and managing the domestic debt.
The main argument for entrusting the public debt management responsibility with
the Ministry of Finance or Treasury is the proximity of location, which enables the
senior management within the Ministry of Finance to review, assess and monitor
public debt more easily. Another factor, which prompted many governments to
locate the debt office within the Ministry of Finance, is that the public debt has
budgetary implications in terms of payments of debt services, and co-ordination
between the budget office and the debt office facilitates effective management of
debt and fiscal deficit. This arrangement, thereby, minimizes chances of any
conflict arising out of the budgetary process determining the annual borrowing
requirements and the management of such liabilities.
As regards governance of external debt, most of the countries donot allow Sub
national or provincial governments to borrow directly from the external sources
(see Table-17). Only the Central government borrows from multilateral and
bilateral sources and then on-lends money to the states and local governments.
Government of Mongolia has also the same system of locating the debt
management offices within the MOF. It is necessary to continue with the system
but to strengthen its structure, debt management policies and to adopt modern
techniques for risk management.
(2) Debt management strategy is an integral part of the wider macro economic
policies that act as the first line of defense against any external financial shocks.
(3) Nearly all of the autonomous debt management offices have adopted an
organizational structure similar to that in leading corporate treasury and
investment banks. They divide functional responsibilities for managing
transactions into different offices within the debt management organization and
established procedures to ensure internal control, accountability, checks and
balances.
(6)
At the initial stage, it is beneficia
l to encourage non-debt creating financial flows (such as direct foreign
investment and equity) followed by liberalization of long-term and medium-term
external debt.
(7)
There is need to have a cautious approach on external short-term credit. In
many developing countries, like India, government does not resort to any short
term borrowing from external sources, although the private sector is allowed to
borrow short-term credit externally subject to certain conditions.
(8) Big bullet loans are bad for small economies like Mongolia, as these can
create refinancing risk in future.
(9) It is not enough to manage the government balance sheet well, it is also
necessary to monitor and make an integrated assessment of national balance
sheet and to put more attention on surveillance of overall debt- internal and
external, private and public. In each of the major Asian crisis economies-
Indonesia, Korea and Thailand- weakness in the government balance sheet was
not the source of vulnerability, rather vulnerability stemmed from the un-hedged
sort-term foreign currency debt of commercial banks, finance companies and
corporate sector.
(11)
It is necessary to adopt suitable policies for enhancing exports and other current
account receipts that provide natural hedge and the means for financing imports
and debt services.
(12)
Detailed data recording and dissemination are pre-requisites for an effective
management and monitoring of external debt and formulation of appropriate
debt management policies.
(13) It is vital that external contingent liabilities and short-term debt are kept
within prudential limits.
(15) It is also necessary to strengthen the legal, regulatory and institutional set up
for management of both internal and external debt.
(16) A sound financial system with well developed debt, money and capital
markets is an integral part of a country’s debt management strategy.
Emerging Economies
Argentina
Brazil
China
Colombia
Hungary
India
Mexico
Mongolia
Korea
South Africa
Thailand
Turkey
Source: World Bank, IMF, OECD various documents.
Selected References
Das, Tarun (1999a) East Asian Economic Crisis and Lessons for External Debt
Management, pp.77-95, in External Debt Management, ed. by A. Vasudevan, April
1999, Reserve Bank of India (RBI), Mumbai, India.
_______ (1999b) Fiscal Policies for Management of External Capital Flows, pp. 194-
207, in Corporate External Debt Management, edited by Jawahar Mulraj, December
1999, Credit Rating and Investment Services of India Ltd. (CRISIL), Mumbai, India.
______ (2003a) Off budget risks and their management, Chapter-3, Philippines
Improving Government Performance: Discipline, Efficiency and Equity in Managing
Public Resources- A Public Expenditure, Procurement and Financial Management
Review (PEPFMR), Report No. 24256-PH, A Joint Document of The Government of
the Philippines, the World Bank and the Asian Development Bank, Poverty
Reduction and Economic Management Unit, World Bank Philippines Country Office, April
30, 2003.
______ With Raj Kumar, Anil Bisen and M.R. Nair (2003b) Contingent Liability
Management- A Study on India, pp.1-84, Commonwealth Secretariat, London.
_______ (2005) International Cooperation Behind National Borders- A Case Study for
India, pp.1-50, Office of Development Studies, UNDP, UN Plaza, New York, 2005.
_______ (2008) Accrual Accounting Rules for Government Finance Statistics, pp.1-36,
ADB Capacity Building Project on Governance Reforms, Ministry of Finance,
Govt of Mongolia, Ulaanbaatar, January 2008.
Das, Tarun and E. Sandagdorj (2007a) Strategic Business Planning- objectives and
suggested structure for Mongolia, pp.1-95, ADB Capacity Building Project on
Governance Reforms, Min of Finance, Govt of Mongolia, Ulaanbaatar, August 2007.
_______ (2007b) Output costing and output budgeting, pp.1-50, ADB Capacity
Building Project on Governance Reforms, Ministry of Finance, Govt of Mongolia,
Ulaanbaatar, October 2007.
_______ (2007c) Transition from Cash Accounting to Accrual Accounting, pp.1-35, ADB
Capacity Building Project on Governance Reforms, Ministry of Finance, Govt of
Mongolia, Ulaanbaatar, October 2007.
________ (2008) Seven-Year (2008-2014) Action Plan for the Complete Implementation
of the Provisions of Public Sector Management and Finance Act (27 June 2002), ADB
Capacity Building Project on Governance Reforms, Ministry of Finance, Govt of
Mongolia, January 2008.
_______ (2003a) The Implications of the Government Finance Statistics Manual 2001
for Country Work in the Fund, GFS Policy Development Taskforce, IMF, Washington
D.C., August 2003.
_______ (2003b) External Debt Statistics- Guide for Compilers and Users, 2003, IMF,
Washington D.C.
International Monetary Fund and the World Bank (2003) Guidelines for Public Debt
Management: Accompanying Document and Selected Case Studies, 2003,
Washington D.C.
Keipi, Kari Juhani and Justin Tyson (2002) Planning and financial protection to
survive disasters, Sustainable Development Department Tech. Studies series: ENV-139,
Inter-American Development Bank, Washington D.C., Oct. 2002.
Reserve Bank of India (RBI) (1999) External Debt Management- Issues, Lessons and
Preventive Measures, pp.1-372, edited by A. Vasudevan, RBI, Mumbai, April 1999.