Today, the Fund has published the report of the 2013 Review of its Transparency Policy. This paper discusses the IMF’s progress on transparency and issues that have emerged since the last review in 2009. It indicates that, despite some progress, the Fund still lags behind in terms of the timeliness of publication, and notes various concerns expressed by civil society organizations (CSOs). SeveralCSOs participated in the online consultation and conference calls the IMF arranged to discuss this review at the beginning of the year. Below is a summary of CSOs views and comments submitted for the Review of the IMF’s Transparency Policy:
Civil Society Organization (CSO) Views on the IMF’s Transparency Policy
To ensure that a wide range of views are reflected in the 2013 Board paper, Civil Society Organizations (CSOs) were invited to express their views on the Fund’s transparency policy. The consultation comprised two approaches. First, CSOs were invited to respond to an online consultation page. Second, representatives from selected CSOs participated in a conference call to exchange views on the Fund’s Transparency Policy.  While CSOs conceded that some improvements have occurred since the 2009 review, they saw the need for further reforms to catch up with current international standards. The discussions centered around five key themes summarized below:
Overarching Principles: Follow the lead of other IFIs
- Despite recent reforms, the Fund’s transparency policy continues to be seen as more restrictive than that of other IFIs, including the World Bank. The CSOs urged the Fund to follow the lead of other IFIs in the following areas:
- Presumption of disclosure. The World Bank moved in 2010 to a policy of full disclosure except for a limited set of documents on a “negative list”, an approach that was seen as superior to the Fund’s practice of seeking consent from country authorities or Board approval prior to publication.
- Board meetings. Some institutions provide live streaming of Board meetings and the World Bank issues summary minutes immediately after the meeting. In contrast, the Fund’s summing ups are issued later, without attribution, and verbatim minutes are made available to the public with a five-year lag. More generally, information about the Fund Board’s calendar and activities was seen as limited and often unreliable.
- Governance of information releases. A number of IFIs have clear procedures for handling information requests from the public and have established independent bodies to adjudicate complaints in this area, including appeals when information requests are turned down. The IMF has not established such developed procedures.
- The Fund should strike a balance between its duty to advise country authorities and its wider responsibility to countries as a whole. In response to worldwide moves towards participatory democracy, the Fund should step up its interaction with other stakeholders, e.g. parliaments, opposition groups, CSOs and trade unions.
- The Fund’s handling of consultations with CSOs on policy papers is seen as suboptimal, including the current review of the transparency policy, as CSOs were allowed only to provide general comments ahead of time, limiting their scope to influence decisions. Instead, CSOs should be given an opportunity to review and comment on draft policy papers before issuance to the Executive Board.
- The Fund should increase its interactions with CSOs and representation on public forums, including through IMF’s resident representatives (res. rep.) offices.
- The Fund should publish CSOs’ full comments on its website.
- Greater candor and timely disclosure of information would enhance the Fund’s accountability, and reduce the risk of it being used as a scapegoat by governments.
- The emphasis on market sensitivity in the Fund’s transparency policy was seen as overblown. The Fund should define more clearly the concept of “market sensitivity”. The Fund should put the emphasis on keeping the public informed rather than on maintaining market stability in cases when these two objectives come into conflict. In general, the Fund should realize the difference between secrecy and responsibility.
- Fund documents should clearly highlight differences of views between the various parties concerned: the Board, staff, management and the authorities. This would strengthen staff independence and avoid the suppression of views, as flagged by the IEO. More attribution of views was also seen as needed in Board summing ups.
- The Fund should disclose the list of unpublished and modified documents, as well as modification requests with justifications as to why they have been permitted. If documents are modified, they should be published with black line redactions to clarify the nature of the change.
- While the Fund was seen as having made progress at releasing information on “outcomes”, but information on “processes” that lead up to decisions is more limited. There is a need for more systematic disclosure on how decisions are made, including on technical assistance funding and program conditionality.
Consultations with stakeholders: Gather broader perspectives
Candor and timely disclosure: Increase transparency on decision-making processes
Evenhandedness: a new approach to information sharing
- The Fund should be more willing to respond to information requests from outside stakeholders. This would improve evenhandedness as information would be “pushed out” in addition to voluntary publication.
- The Fund should systematically include a section on stakeholders’ views in staff reports.
- The Fund should cut back on jargon and in general use language that makes documents more accessible to the general public. More documents—including policy papers—should be translated, including into languages beyond the five official UN languages. Country papers should be translated into at least the language of the country concerned.
- The Fund should make a clearer distinction between papers with policy content cleared by the Fund, and those that do not represent the Fund’s official position. Doing so would help clarify the Fund’s position on key issues and the Fund’s message to stakeholders.
- The Fund should create a web page for all resident representative offices, and those offices should maintain a mailing list of key CSOs and distribute news releases to them electronically.
- Information related to a country should be housed in a single location to facilitate searching. In addition, country pages on the IMF website should include a factsheet on IMF involvement with the country, and a list of forthcoming and recently completed interactions with authorities (staff visits, technical assistance, meetings with CSOs, etc.). Information on ways to engage with the visiting teams should also be disclosed.
Communication: Cut back on jargon and improve ease of access
 CSOs were also invited to provide comments via the online CSO Consultation Page for 2013 Transparency Review). Two institutions provided written comments: Global Research Priorities in Global Governance (UK) and New Rules for Global Finance (US).
 Eight organizations participated in the conference call, which was held on March 8th: Save the Children (Norway), European Network on Debt and Development (Belgium), Human Rights Watch (US), ITUC (US), Oxfam (US), ONE Campaign (US), Center for Law and Democracy (Canada), The Bretton Woods Project (UK).
New Rules' Comments and Recommendations on 2013 IMF Transparency Policy
- First, we recommend that all public consultation submissions for this Transparency Policy review and future reviews be published on the IMF website. This will demonstrate a genuine commitment to greater transparency and establish a mechanism of accountability for the Transparency Policy review process. This mechanism being that the public will be able to compare submitted recommendations with the updated IMF Transparency Policy.
- Accessible language:
- Published documents should be written in accessible and non-technical language when possible.
[Background Paper, External Stakeholder’s Views, paragraph 11, pg. 8]
[Background Paper, APPENDIX I. SUMMARY OF COMMENTS FROM CIVIL SOCIETY ORGANIZATIONS, paragraph 67, pg. 35]
- Market sensitive information should be more clearly defined [Authorization and Consent, Paragraph 6, pg. 17]. An independent and external body should be designated to define “market sensitive” or other terms for deletions.
- Member country requests for deletions that are rejected by the IMF should be made public – and be used to formulate a comprehensive definition of market sensitive information [Authorization and Consent, Paragraph 7, pg. 18]
- Transparency policy indicates that the Managing Director approves member requests for deletions. Who is responsible for approving deletions when the MD is unavailable?
- Executive Board
- All Executive Board Meetings should have “minutes” available to the public [Supplementary Information and Proposed Decision, Decision II: Archives Policy, Paragraph 2, pg. 32]
- Once the 2010 reforms package becomes effective, the process and outcomes of the all-elected Board of Executive Directors should be fully transparent, including: ??
- Ex-Ante Impact Assessment
- We presume that the IMF conducts ex-ante impact assessments of all policy recommendations, including Article IV policy recommendations. This information, the process and findings should be available to the public. This measure is essential for meaningful transparency and accountability.
[Background Paper, APPENDIX I. SUMMARY OF COMMENTS FROM CIVIL SOCIETY ORGANIZATIONS, paragraph 67, pg. 35]
- Advanced announcement of IMF Country Missions
- The IMF should release far in-advance the schedule of its Missions – Article IV consultations, loan negotiations, interim reviews, etc.
- In addition, this must be complemented by information on how civil society can engage with the IMF Mission team. This should include: the process for consultations, how to participate, how CSOs are vetted/selected to participate, prompt and clear correspondence, times and locations of consultations. [Background Paper, APPENDIX I. SUMMARY OF COMMENTS FROM CIVIL SOCIETY ORGANIZATIONS, paragraph 67, pg. 35]
- Any document published that is related to a member country should be available in the national language of the country.
[I cannot find anything about that. The document called Supplementary Information and Proposed Decisions only says the documents written in non-English tend to have lags for public access, and the IMF is trying to reduce such lags]
- Technical Assistance:
- IMF Technical Assistance Reviews need to be more transparent and should include:
- The specific work of the Technical Assistance Teams, Country Missions and Technical Assistance Centers
- How the technical assistance programs are decided
- How the Technical Assistance Reviews are evaluated
- Staff of Executive Director Offices
- The staff and advisors that represent their country in the office of the Executive Directors should be available to the citizens from that country. [I cannot find anything relevant at all]
New Rules will compare the input from CSOs and the final IMF Transparency Policy. We will post our findings soon.
You are cordially invited to participate in an important pilot effort to improve IMF Consultation with CSOs through a review of Fiscal Transparency:
IMF member-states have agreed to regular reports on their fiscal status, both the income side and the expenditure or budget side. The IMF is inviting us to review/add input their draft of Core Pillars and Core Principles. Governments use these Pillars and Principles in their reports to national legislatures, publics, and the IMF.
I would like to describe two things:
1) Content and process of the consultation
2) Improving IMF-CSO consultation.
The IMF Fiscal Affairs Department (FAD), in reviewing the lead-up to the global financial collapse that surfaced in 2008, realized it had not been receiving comprehensive, timely, and accurate information from member-states. They have therefore embarked on an ambitious overhaul of what information and the quality of the information governments collect, make public, and report.
Some of you have already participated in an initial conversation (first phase) with the Fund on this topic which concluded February 10, 2013. This conversation focused on reviewing the Fund’s code of best practices for Report on the Observation of Standards and Codes (ROSC). External comments from that portion of the consultation can be found here.
In this second phase, the FAD has prepared a revision for comment on the core pillars, principles and criteria for evaluating how governments go about implementing those best practices.
A third phase is planned to review the Manual for countries on how to implement the principles; and a fourth phase is planned to focus on Fiscal Transparency and Resource Extraction.
In the first phase ending February 12, 2013, FAD regarded the CSO input as demonstration of genuine interest, and they have agreed with the External Affairs unit to replicate this experience with fiscal transparency initiatives, while hoping to expand, deepen and diversify CSO participation. New Rules has agreed to assist in this effort.
This consultation (Phase II) on Fiscal Transparency uses a web portal on the IMF website:
At this website you will be invited to email or fax your comments to IMF staff. You will not be able to report anonymously, but your information will be confidential. New Rules will receive copies of all comments. The deadline for input is August 30, 2013.
2) IMPROVING CSO CONSULTATION
New Rules’ responsibilities are primarily to reach out to CSOs especially in the Global South, in an effort to decentralize and diversify input.
- Our first suggestion was to expand the time allotted to the consultation by 2 weeks. This has happened. We are working with a 6 week time frame: July 15 – August 30.
- To increase participation from organizations in diverse regions in the Global South who may be interested in this and future consultations, we are using our own networks of people and organizations built up over the years, plus active solicitation and research to identify additional CSOs likely to be interested. We are also combining our lists with the names provided by the IMF CSO unit.
- Please forgive us if there are duplications.
- Please share this invitation with your own colleagues and networks.
- We have asked the IMF to encourage Resident Representatives in countries throughout the world, but especially in the Global South, to reach out to local CSOs to encourage participation. Ideally, this could involve face to face conversations in the region, especially if there are language difficulties (because of the technical level of the language, or the absence of translation to local languages).
- So far, the consultation document has been translated into Spanish and French; concern about precise language is an obstacle for FAD providing additional translations
- We hope to organize 2 or 3 real time telephone conferences with regional CSOs and the IMF staff working on this paper.
There may also be opportunities for video conference calls. With Video and Audio conversations, transcripts will be posted on the same website.
New Rules will synthesize all CSO input, share that synthesis on our website (www.new-rules.org) and share with all respondents. We will then incorporate your feedback into a second edited version. We plan to use this synthesized document to measure how the IMF incorporated CSO input into its final policy paper.
In addition to the work plan we agreed to with the IMF External Affairs and Fiscal Affairs Departments, we are also working to ensure:
1) Feedback to CSO recommendations;
2) A schedule of the Fund’s planned consultations so we can plan ahead; and
3) The option for CSOs to initiate topics for consultation.
As I said above, this is a pilot, an experiment. It is not likely to be perfect—but it can begin a process that gets increasingly better. It is also a test of the IMF’s commitment to a genuine dialogue.
Jo Marie Griesgraber
PLEASE NOTE: this process is independent of the online survey many of us have been asked to respond to by Professor Bessma Momani of the University of Waterloo in Canada. It is, however, another indicator of the IMF’s apparent seriousness in speaking with and listening to CSOs.
 Since we regard this work as fundamentally the responsibility of the IMF, we are therefore being paid to organize and stimulate this consultation. These were the same terms under which we coordinated the collection of CSO recommendations for the IMF governance debates in 2008; regrettably the Financial Crisis provided a major distraction from providing feedback to CSOs. We have been promised feedback for this consultation.
AFDB Side Event on Domestic Resource Mobilization
In the afternoon of May 30, a side event of the African Development Bank Annual Meetings titled “South-South Technical Cooperation on Domestic Resource Mobilization to halt illicit financial flows from Africa” was held as a follow up to last year’s Annual Meetings side event that initiated work to increase domestic resource mobilization through capacity building efforts. Co-organized by New Rules for Global Finance and African Development Bank Institute, this side event focused on:
- the strain of illicit financial flows on revenue collection and the need to build capacity;
- the importance of domestic resource mobilization for national development and the need for capacity building;
- the importance of exchanging good governance experience in domestic resource mobilization though South-South Cooperation.
For the first topic, Dev Kar, Chief Economist from Global Financial Integrity provided perspectives from his organization research in illicit financial flows from Africa. For the second topic, Frannie Leautier, Executive secretary from African Capacity Building Foundation, and Victor Murinde, Head of the African Development Bank Institute highlighted the advantages of domestic resource, including strengthening the public voice in governance and the expansion of policy space for national development priorities; and plans for capacity strengthening in the area of domestic resource mobilization. On the last topic, Horacio Simao, Director General Strategic Planning in Mozambique Revenue Authority, and Logan Wort, Executive Secretary of ATAF shed some lights on the need for capacity development in domestic revenue collection, especially in light of the strain of illicit financial flows; and the examples of South-South cooperation that have resulted in capacity building for increased domestic resource mobilization.
Chair: Matthew Martin, Director, Debt Relief International;
(1) Dev Kar, Chief Economist, Global Financial Integrity
(2) Frannie Leautier, Executive secretary, African Capacity Building Foundation
(3) Victor Murinde, Head of the African Development Bank Institute
(4) Horacio Simao, Director General Strategic Planning, Mozambique Revenue Authority
(5) Logan Wort, Executive Secretary, ATAF
The Global Legal Entity Identifier System (GLEIS)
Currently, there is no unified global identification system for legal entities across markets and jurisdictions that is designed to provide for greater transparency in the global financial system; or to allow better insights into relationships among legal entities and their affiliates conducting financial transactions. GLEIS, under the supervision of the Financial Stability Board (FSB), was designed to help global regulators to monitor and analyze threats to global financial stability and to effectively measure systemic risk across financial entities. This system is intended to prevent events, such as the collapse of Lehman Brothers in 2008, from becoming systemic threats to the global financial system and to hold financial institutions accountable for their subsidiaries. The governance framework of the GLEIS is to comprise the Regulatory Oversight Committee (ROC), the Central Operating Unit (COU), and the Local Operating Unit (LOU). A detailed briefing of the GLEIS and its governance structure can be found below (prepared by Navin Beekary).
What is GLEIS? Download GLEIS Concept Note
In September 2012 Navin Beekarry (Private Sector Participants Group) was nominated to coordinate the Relationships Working Group and to assist the FSB in the implementation of the G20’s decision to create a GLEIS. Based on recommendations prepared and finalized for submission to the Committee on Evaluations and Standards (CES) and the ROC, the second phase of the Relationships work is projected to be completed by the end of 2014. Publicly available documents and Progress Reports on the LEI can be found at the following: http://www.financialstabilityboard.org
What is the Global Legal Entity Identifier System (GLEIS)?
Concept Note on the Global Legal Entity Identifier System (GLEIS) - Transparency in Global Finance
1. The Legal Entity Identifier (LEI)
The LEI is a reference code to uniquely identify a legally distinct entity that engages in a financial transaction. Currently there is no unified global identification system for legal entities (LEs) across markets and jurisdictions. The LEI is designed to be the first global and unique entity identifier offering free and open access to regulators, industry, NGOs and the public, to the LEI and to shared reference information for any entity across the globe. Each entity will be registered and assigned a unique code that would be associated with a set of reference data (e.g. basic elements such as name and address, or more complex data such as corporate hierarchical relationships).
The LEI is expected to provide for greater transparency in the financial world, as it will allow better insights into relationships among LEs and their affiliates conducting financial transactions across multiple jurisdictions based on publicly available data about those LEs within the Global Legal Entity Identifier System (GLEIS). The GLEIS will provide significant benefits to multiple parties including regulators, the industry, NGOs, and academic and policy research. It will enable financial entities to better manage risk and allow regulators to identify parties to financial transactions precisely by having access to reliable data about their counterparts.
The 2007-2008 financial crisis increased awareness of the need for financial transaction transparency in order to accurately assess exposure to counterparty risk. The crisis provided renewed interest in the development of a global LEI system and its importance as a key component of necessary improvements in financial data systems. The LEI initiative dates back to the collapse of Lehman Brothers in 2008 and the inability to track down counterparty interconnectedness and risk built-up in the global financial system. The risks already faced by banks that lack a clear understanding of the legal structures of their counterparties was cast into focus by the Lehman bankruptcy, when financial regulators and private sector managers were unable to assess quickly the extent of market participants’ exposure to Lehman or to explore quickly and fully how the vast network of market participants were connected to one another. The challenge was for regulators to conduct systemic risk analysis in order to understand the aggregate risks of entities and their counterparties across asset classes and markets. Precise and accurate identification of legal entities engaged in financial transactions became critically important to both financial institutions and regulators. As such, a global LEI standard with core attributes and a supporting system became an essential component to enable regulators to conduct risk analysis.
3. The G-20 Decision, Implementation of the global LEI Governance Structure and Recent Developments
a) The G20 Decision
The G20’s decision of November 4, 2011 provides the basis for work on the establishment of the GLEIS. The mandate given to the FSB by the G-20 was “to lead the co-ordination of international regulatory work and to deliver concrete recommendations on the LEI system by June 2012”:
‘We support the creation of a global legal entity identifier (LEI) which uniquely identifies parties to financial transactions. We call on the FSB to take the lead in helping coordinate work among the regulatory community to prepare recommendations for the appropriate governance framework, representing the public interest, for such a global LEI by our next Summit.’ (Cannes Summit Declaration, November 4, 2011)
More specifically, the implementation mandate includes defining and setting up the Governance framework for a global LEI (legal and governance; its Operational model (operations); and the Scope of LEI reference data (relationship data).
b) The Global LEI Governance Structure
The governance framework of the Global Legal Entity Identifier System (GLEIS) comprises the Regulatory Oversight Committee (ROC)- the central policy-making organ, the Central Operating Unit (COU), and the Local Operating Unit (LOU).
The ROC has been established and is already operational and has the ultimate responsibility for the governance of the global LEI system. It would comprise authorities from different countries that support the core principles and purposes of the system (as set out in the High Level Principles) and that are committed to support the governance in the public interest.
The COU has responsibility for ensuring the application of uniform global operational standards and protocols that deliver global uniqueness of the LEI; and open access to the global LEI and to high quality reference data for users; as well as protocols and methods for how local systems can connect to the COU, including the necessary support of the local systems. The COU will support the maintenance of a ‘logically’ centralized database of identifiers and corresponding reference data. LOUs will provide the primary interface for entities wishing to register for a LEI. They will be the local implementers of the global system.
LOUs will offer facilities such as local registration, validation, and maintenance of reference data; protection of information that must be stored locally; and will facilitate the use of local languages and organization types.
The Private Sector Preparatory Group (PSPG) represents the platform for industry, NGOs and academic sector’s participation and contribution to the GLEIS implementation work and has been in operation since 2012. The PSPG comprises around 300 entities and groups and operates through three Working Groups (WGs) - Legal & Governance WG; Operational WG; and Relationship WG. The PSPG supports the CES and the ROC in its legal, operational and relationship work.
The GLEIS Relationship work focuses on the identification and definition of relationship reference data that in the long term will provide the comprehensive set of data-types that will allow for the definition of relationship among entities. The GLEIS will start operations on the basis of a set of core data (first phase data) (based on the ISO standard 17442: 2012) that includes basic information about an entity’s official name, the address of its headquarters, address of its legal formation, the date of the first LEI assignment, the date of last update of the LEI, the date of expiry, business registry information, alongside the 20 digit alphanumeric code. The second phase data which build on the first phase and identify relationship data based on accounting / consolidation principles; whereas in the longer term (3rd phase), relationship data will include risk-type information.
c) Recent Developments / Progress
Recent developments include the establishment and operations of both the ROC and the Committee on Evaluation and Standards (CES) that acts as the technical arm of the ROC and provides recommendations on the technical aspects of the GLEIS work. The ROC is presently engaged in finalizing the establishment of the COU and the formation of the COU’s foundation- that is, its Board of Directors. This step should be completed by the end of August and the entire GLEIS governance structure should be in place and operational by the end of 2013. The ROC and the CES have had a number of meetings so far and have taken a number of decisions that include the allocation of pre-LOU prefixes to a number of institutions that include Japan, EU, Dutch, France, German, US. The pre-LOUs are authorized to start issuing pre-LEIs to a number of entities under satisfaction with defined requirements.
4. Greater Transparency
a) How does the LEI Support Financial Stability?
The implementation of LEI will have a dramatic impact on the global transparency of financial transactions. Regulators will be able to incorporate LEI into their surveillance analysis to assist them in identifying entity, group, business line, or geographical risk concentrations. Equally important, the LEI will help individual firms more effectively measure and manage their counterparty exposure and improve operational efficiencies. In the post-credit crisis world, the absence of standard identifiers for entities and the lack of an authoritative source of legal hierarchy structures are significantly increasing the cost of doing business.
b) Systemic Risk Assessment and Monitoring by Financial Regulators
A primary objective of the LEI Solution is to help global regulators ability to monitor and analyze threats to global financial stability by being able to effectively measure systemic risk across financial entities and their transactions across jurisdictions. The financial crisis demonstrated the extreme complexity of interrelationships and dependencies that exist between parties, counterparties, issuers, guarantees, and guarantors and how strains can rapidly spread through the financial network when one or more of the nodes within these relationships come under pressure. In principle, a system of unique identification of every entity would help to map these types of relationships in the financial system and allow a better understanding of key exposures ahead of a crisis.
While the LEI on its own will not measure systemic risk, when combined with transaction information on the risks being exchanged by counterparties, LEI will allow regulators and parties to the transactions to gain a more complete and accurate picture of risks than ever before. Such a framework will provide a transparent, open and fair system, that protects against the risk of abuse of dominant market positions, and that facilitates quick adoption. Potential users, both regulators and industry, would be granted free and open access to the LEI and to shared reference information for any entity across the globe and could build this into their internal automated systems. The LEI will facilitate improved micro-prudential and macro-prudential risk analysis, supervision and regulation; reduce cost for industry in collecting, cleaning, and aggregating data, and in reporting data to government regulators; reduce firms’ operational risks and improve their internal risk management; and enhance industry’s market discipline.
c) Relevance for Beneficial Ownership
The LEI is expected to provide greater transparency into the beneficial owners of legal entities, by facilitating research into the owners of legal entities to include individuals and entities with 10% beneficial ownership or less. Relationships data among LEs that is compiled by the GLEIS will allow for greater opportunities to track down relationships among LEs and their affiliates across jurisdictions and the ultimate beneficial owner. Being able to track relationships among legal entities based on accounting / consolidation standards will allow better insight into the ultimate parent of an entity.
5. Public Element
The public nature of the GLEIS- by making available and accessible to the public, free of charge- higher quality and accurate financial data overall should provide a valuable ‘building block’ to facilitate multiple financial stability objectives including micro and macro assessment of risks, risk management, and financial fraud. But as the LEI system is by nature a public good, there is a need to make sure that the gains for the broader public are captured and that provision of the LEI is not exploited in ways that do not benefit the public. Incentives for suppliers of the LEI to exploit their privileged position and overcharge registrants, restrict access, cut corners on data quality, or to use a position of privileged access to LEI information to supply other revenue-generating services on non-competitive terms, constitute serious challenges to the public nature of the LEI. These arguments provided the motivation for the FSB mandate to produce recommendations for a governance framework for the LEI that identifies and provides strong protection of the public interest.
6. Federated System and Regionalism
The effective implementation of the GLEIS requires the adoption of a system that will ensure the maximization of benefits across the globe. In order to ensure broader coverage and, accordingly, generate the maximum network benefits, the system should be able to expand quickly to include new jurisdictions and new registrants across the globe. The FSB’s recommendation for the GLEIS to be built and to operate on a federated system is premised on the requirement for global system that relies and integrates local implementation of commonly applied global standards. In particular, the global LEI system should be designed, operated and governed in a manner that draws on distributed local elements and local infrastructures where possible. Drawing on such local arrangements provides additional flexibility to deliver a high level of local validation of reference data for the legal entities registering for a LEI, as well as meeting local jurisdictional requirements. Such principles and standards will facilitate the consistent integration into a global system of entities from jurisdictions with different regulatory, legal systems and local language character sets. It is important to reflect and take into account such characteristics if all such jurisdictions are to feel comfortable in joining the system over time.
The design of the LOUs reflects such a federated approach to the GLEIS. The LOU will build on local business registry or numbering services to maximize the use of local infrastructures. In some jurisdictions, there may no LOU and entities wishing to acquire an LEI will need to apply across borders or to the COU until the local infrastructure is established. In the latter case, if an LOU is subsequently created, it will be important to ensure that the LEI is portable (transferable) to the local jurisdiction. That is likely to provide additional flexibility, for example to map and incorporate existing local registration and identification schemes into the global system and thus support the key objective. The federated system will also allow the accommodation of local jurisdictional differences such as a local language, legal framework, etc
7. My Role and Responsibilities
I was nominated since September 2012 to coordinate the Relationships Working Group, and a member of the Operations WG, 2 of the 3 WGs set up by the Private Sector Participants Group (PSPG) to assist the Financial Stability Board (FSB) in the implementation of the G20 decision. Since then, I have been coordinating the second phase of the Relationships work - following the preparation and submission of recommendations by myself, and my colleague, during the first phase to the ROC (February 2013).
My responsibilities include coordinating and organizing the weekly calls for the Relationships WG and preparing the agenda and relevant documents for discussion following which I draw up minutes of the meeting. At the end of the second phase, I will have to prepare a series of recommendations based on the CES List of Questions (April 10, CES List of Questions), around which the numerous weekly calls and discussions are held the result of which is to come up with specific responses. This requires ongoing and constant research and preparation into the topics discussed, for which I often have the sole responsibility. Moving this relationship agenda forward, I enlist the collaboration of the U.S. SEC, FASB, and the international IFRS as well as representatives from the private sector.
8. Products and Deliverables
Detailed recommendations on Relationships questions have to be prepared and finalized for submission to the CES and the ROC. The projected time frame for the second phase Relationships work is end of 2014. The first set of Recommendations was delivered to the ROC in February 2013. Publicly available documents and Progress Reports on the LEI can be found at the following: http://www.financialstabilityboard.org/search/?sp_q=LEI&adv=1
Coordinator, Relationships Working Group, PSPG
6. 18. 2013
The GLEIS Governance Structure: see notes below
Source: The Financial Stability Board, A Global Legal Entity Identifier for Financial Markets, 8 June 2012, Financial Stability Board
Chris Legg, a public policy scholar with the
Mr. Legg began his lecture by outlining some key background information on the 2008-09 financial crisis and the emergence of G20 as a response to the crisis. He laid out an introduction on the construction and operating mechanism of the IMF. He also touched on some quota representation issues with the IMF; some statistical evidence showed the underrepresentation of quota for the
To know more of this issue from Mr. Legg’s perspective, please follow the
The Guide for Staff Relations with Civil Society Organizations (CSOs) was prepared in 2003 to provide guidance to IMF staff for effectively engaging with CSOs: http://www.imf.org/external/np/cso/eng/2003/101003.htm
The Guide is now being revised to reflect the evolving role of the IMF and of its engagement with CSOs over the past 10 years. Dr. Bessma Momani, an independent consultant, is to identify and assess the best practices so that to provide recommendations on how to conduct public consultations on policy issues. CSO input is seen to be the key in revision and preparation of a new version of the Guide. Comments should be submitted no later than midnight (Washington DC time) on Friday, August 2, 2013. The details on submissions and further steps of the Process can be found here: http://www.imf.org/external/np/exr/consult/2013/csoguide/index.htm
Page 1 of 20