Professional Documents
Culture Documents
Tarun Das*,
Economic Adviser, Ministry of Finance, India.
And Consultant to the World Bank
March 2002
1
2
Management of Contingent Liabilities in Philippines-
Policies, Processes, Legal Framework, and Institutional Arrangements
1. This report is a part of a wider study on the Public Expenditure, Procurement and
Financial Management Review (PEPFMR) for the Philippines being prepared by the
World Bank. The objective of the PEPFMR exercise is to examine selected issues in
the allocation and management of public resources, which are of interest to the
Government of Philippines and the World Bank. In particular, the objectives of the
World Bank study are as follows:
(i) To help the authorities establish more effective and transparent mechanisms and
policies to allocate, utilize and manage available public resources so as to
promote economic growth, improve delivery of basic social services, and reduce
poverty; and
(ii) To fulfill the World Bank’s fiduciary responsibility and serve as the core
background analytical framework for future operations in Philippines. The
PEPFMR findings and recommendations will constitute part of the core analytical
work for a proposed Public Finance Strengthening Loan (PFSL), and attendant
programs and adjustment loans.
2. A key focus area of the PEPFMR is the identification and management of public
contingent liabilities, which pose threats to fiscal stability and overall macro-
economic stability and, therefore, require better monitoring and management. These
liabilities include exposures under obligations such as government guarantees on
loans; performance guarantees to BOT projects, guarantees on guarantee institutions
and deposit insurance, and fiduciary guarantees to public pension, provident and
insurance institutions. Certain other categories of government's contingent liabilities
include forward contracts for foreign exchange, various implicit obligations
associated with bank failures, and possible recapitalization of failing corporations.
These issues donot come under the purview of the PEPFMR.
3
dissemination of information on outstanding guarantees of the government guarantee
institutions that are explicitly or implicitly backed by the national government.
4. The report examines the legal framework, policies, processes and institutional
arrangements for monitoring public contingent liabilities in the Philippine
government with special emphasis on state guarantees to Government Financial
Institutions (GFIs) and Government Owned and Controlled Corporations (GOCCs).
The report identifies the key issues and concerns, and describes, analyzes and
assesses the steps already taken by the authorities. In addition, it provides country-
specific recommendations in the short-, medium- and long term for the improvement
as per international sound practices.
5. The findings are based on examination of available reports on the subjects and
discussions with the concerned entities involved in receiving, issuing, approving,
managing and recording state contingent liabilities (focusing for the present on
explicit ones which are recognized under legal laws and contracts for both domestic
and external liabilities) during a mission to Manila during 17 February to 2 March
2002.
6. The consultant has worked under the continual guidance of the PEPFMR task team
leader (TTL) Mr. Amitabha Mukherjee who specified the broad objectives and scope
of the study and also indicated the key technical officials and policy makers in the
Philippines who are responsible for the approval, issue, recording, monitoring and
management of contingent liabilities.
7. During visit to Manila, the Consultant maintained close interactions with Mr. Lloyd
McKay, Lead Economist, World Bank Office at Manila (WBOM), Ms. Laura
Pascua, Under-Secretary, Department of Budget and Management (DBM) and the
Chairperson of the counterpart team (PER Working Group) established by the
Government of Philippines; Ms. Nieves Osorio, Undersecretary, Department of
Finance (DOF), Government of Philippines (GoPh), Ms. Soledad Emilia J. Cruz,
Director, Corporate Affairs Group, DOF, GoPh., and Ms. Xuelin Liu, Country
Economist, Philippines Country Office, Asian Development Bank.
8. The Consultant has also benefited greatly from detailed discussions with various
officials of the government of Philippines and GOCCs, who are responsible for
issuing, approval, monitoring and auditing of contingent liabilities and formulation of
policies. A list of key officials with whom detailed discussions were held in Manila is
given at Annexure-D.
Contingent liabilities are defined by the System of National Accounts 1993 as contractual
financial arrangements that give rise to conditional requirements either to make payments
or to provide objects of value. A key characteristic of such financial arrangements, as
distinguished from the current financial liabilities, is that one or more conditions or
events must be fulfilled before a contingent liability takes place. A key characteristic that
4
makes such liabilities different from normal financial transactions is that they are
uncertain.
Contingent liabilities represent potential claims against the government, which have not
yet materialized, but which could trigger a firm financial obligation or liability under
certain circumstances. Several studies have shown that contingent liabilities, once
materialized, can be a major factor in the build up of public sector debt and can pose
significant risks to the government’s balance sheet.
Contingent liabilities are of two main types- explicit and implicit. Explicit contingent
liabilities are based upon legal and contractual commitment or formal acknowledgement
of a potential claim, which can be realised in particular situations. Explicit contingent
liabilities include bonds or other liabilities contracted by the government with put options
for lenders, credit-related guarantees, performance guarantees, various types of
government insurance schemes (e.g., against banking deposits, crop failure, natural
disasters, etc.), or legal proceedings representing claims for tax refunds or against
government providers of services such as health care, education, defense, housing, etc.
Implicit contingent liabilities represent potential claims where the government does not
have a contractual obligation to provide financial support, but society expects the
government to provide assistance because of moral considerations. Implicit contingent
liabilities arise when the cost of not assuming them are considered to be very high in
terms of social and economic disruptions. For example, bailing out weak banks or failed
financial institutions or meeting the obligations of the subnational (state and local)
governments or the Central Bank in the event of default following systematic crisis may
be viewed as an implicit contingent liability of the central government.
Other implicit contingent liabilities include disaster relief, corporate sector bail outs,
municipal bankruptcy, defaults on non guaranteed debt issued by sub-nationals and state-
owned enterprises or government obligations under a fixed exchange rate regime to
defend its currency peg. These risks can be particularly significant in emerging market
countries undergoing financial sector and capital convertibility reforms and where the
regulatory and disclosure standards may be weak.
5
forward exchange losses of the oil companies during the oil crisis of the late 1970s and
rehabilitation of weak banks.
Contingent liabilities are complex and not easy to quantify. A single and uniform
framework for their measurement may not be appropriate. 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 recognised that cash based accounting systems,
even supplemented by off-budget and off-balance sheet transactions, are not suited for
managing contingent liabilities. Only the accrual based 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 as well as expected value and
expected present value of contracts.
6
4. Practices of Managing Contingent Liabilities in Philippines
At present, the government of Philippines does not have a comprehensive Act to monitor
all contingent liabilities. It has only one tool to manage its contingent liabilities related to
external sector. Republic Act 4860 (Foreign Borrowings Act), as amended from time to
time, sets a ceiling of $7.5 million on outstanding government guarantees for foreign
loans of the government-owned and controlled corporations (GOCCs). Items, which are
required to be charged against this ceiling, are the guaranteed principal amounts (i.e.,
disbursements less repayments, excluding interest payments and other bank fees) of loans
incurred and bonds issued. The national government charges a fixed 1 per cent annual
guarantee fee regardless of the risk profile of the guaranteed loan or institution.
The Department of Finance (DoF) reviews and approves requests of GOCCs for
national government guarantees. After approval by the DoF, the Bureau of the Treasury
(BTr) is mandated to keep track of government guarantees issued and to ensure that total
outstanding guarantees at any time donot exceed the ceiling prescribed under RA 4860.
However, borrowings of certain GOCCs (e.g., LRTA, MWSS, NDC, NEA, NIA, NPC,
PNOC, and PNR etc.) are explicitly exempted in their charters from being charged
against this ceiling. These exemptions render the ceiling a less effective control
mechanism, especially since some of the exempted corporations are the giant GOCCs
with large outstanding loan balances.
7
Based on current practices, guarantee fees collected are treated as part of
government's general revenues and are not kept in a separate account to fund future
guarantee calls. Given government's cash-based accounting and budgeting frameworks,
government does not presently provide reserves for expected guarantee calls. The
corporations are also not required to conform to standard prudential norms in
provisioning and reserve policy for contingent liabilities. The GOCCs donot estimate and
disclose their off-balance sheet contingent liabilities in their annual reports. Only when a
guarantee is called does the government set up the needed budget to fund payments and
only for that portion due in the current year.
As in most countries, government budgets in the Philippines are done on a cash basis and
not on accrual basis. Non-cash expenditures such as depreciation of assets, taxes owed
but not yet paid, donot appear in the budget. Consequently, guarantees and other off-
budget arrangements are made liberally and there is no hard budget constraint. Although
it is possible to note guarantees and other non-cash items as memorandum items in the
cash-based budgets and accounts, complete incorporation of these liabilities requires a
shift from cash-based to accrual based budgeting and accounting.
8
Table-2: Summary of government contingent liabilities
Maximum exposure for each type as in October 2001
9
(a) Direct guarantees on loans
As per the data supplied by the Bureau of the Treasury, as of October 2001, total
contingent liabilities of the national government due to guaranteed loans amounted to
P491.4 billion, which is equivalent to 14.8 per cent of GDP or 17.2 per cent of national
government debt. This includes P17.6 billion in assumed guarantees of formerly
rehabilitated GOCCs (mainly Philippine National Bank and Development Bank of
Philippines). The bulk (97 per cent) of the contingent liabilities consist of guarantees on
foreign debts of GOCCs, including borrowings of GOCCs whose charters exempt them
from the ceiling provided under RA 4860. Domestic debts guaranteed include bond
issuances of the Home Development Mutual Fund and the National Development
Company as well as agrarian reform bonds of the Land Bank.
A breakdown of the above data by GOCCs is not readily available. Instead, information
culled from 1999 Commission on Audit reports indicate that National Power Corporation,
which enjoys automatic government guarantee on its bonds, has the largest share (42 per
cent) of outstanding foreign loans of GOCCs in 1999. Government financial institutions,
like Bangko Senetral ng Pilipinas (21 per cent) and Development Bank of Philippines
(15 per cent) also have large outstanding foreign loans.
There are some weak corporations, for which the risk of government being called to
service their loans is very high. A review of the financial performance on the basis of
Audit Reports indicate that LRTA and PNR had negative networth for the past three
years, and four others (NEA, NFA, NIA, NPC) had been registering losses leading to
declining networth.
In the short run, government should systematically assess the financial health of each of
GOCCs to ascertain their creditworthiness and the government's risk in guaranteeing their
debts. The existing guarantee limit under RA 4860 must be enforced for all GOCCs.
Based on this assessment, government may opt to impose more stringent criteria before
guaranteeing loans and adjust guarantee fees depending on credit rating of the
institutions.
In the medium term, the government should review and amend the charters of GOCCs as
necessary to ensure that the guarantee limits apply to all GOCCs. Where desirable and
possible, GOCCs could be privatised to avoid the risk. Weak GOCCs either need to be
strengthened with feasible capital and manpower restructuring or closed with legal
compensations to all stakeholders. In general, the process of auditing for the GOCCs
10
needs to be strengthened with discloser of all contingent liabilities in their balance sheets.
In any case, there should be no automatic guarantee of contingent liabilities by the
national government and risk based fees be charged for all guarantees.
The government has already taken some steps in the right direction. The Investment
Coordination Committee of the DOF has created a Technical Working Group to help it
complete an inventory of all contingent liabilities, review the sources of contingent
liabilities, develop means for minimizing and sharing risks across government and quasi-
governmental organizations, monitor projects guarantees, and build institutional capacity
for effective management of contingent liabilities. The government has recognized the
complexity of issues relating to continent liabilities and is devoting resources to the
difficult task of measuring them.
In order to attract private sector participation and financing for critical infrastructure
projects in power, road, rail transport and water supply, the government of Philippines
issued guarantees for BOT projects for mitigating some of the risks posed by the political
and economic environment in the Philippines. Some of the risks assumed by the
government include currency, market, political and regulatory risks as well as force
majeure events (such as natural calamities, war, revolution, labour agitation and strikes,
changes of law, compulsory acquisition of assets by government in public interest etc.).
The results indicate that the Sual and Pagbilao power projects and the MRT-III light rail
transit project have the highest risks for losses, and the main risk factors arise from
currency and demand risks and time-overruns in implementation of projects. However, it
may be noted that in the case of the power projects, neither the NPC nor the national
government assumes the costs of these risks as these costs are actually passed on to
consumers. For MRT-III on the other hand, the government already provided US$76
million in subsidy in 2000.
11
Table 4: Indicative and Explicit NG Exposures
under BOT Projects* (In P billion)
Indicative* Explicit*
In the Philippines, several corporations have been set up to guarantee loans in the
agriculture, small enterprise, housing and export sectors. The biggest among these is the
Home Guaranty Corporation (HGC). HGC is particularly noteworthy because it has an
authorized capital of P50 billion and an allowable guarantee limit of 20 times its
networth. Since all of HGC's obligations and loan guarantees are backed automatically
by sovereign guarantees, the government is potentially exposed to over P1 trillion in
contingent liabilities from HGC alone.
In addition to loan guarantees, HGC's bond issuances also carry sovereign guarantees.
These bonds are issued mainly to pay for calls on the corporation's loan guarantees,
payment of which are based on the total guaranteed amounts. Since the real estate slump
following the Asian crisis, guarantee calls on HGC have risen substantially and have
strained HGC's cash position. Reorienting HGC's guarantee scheme towards cashflow
guarantee may be needed to help HGC manage the guarantee calls. A further point of
concern would be pressure for it to do "formula lending" for low-income housing similar
to what NHMFC was doing (i.e., with no credit evaluation).
Aside from HGC, there are a host of much smaller government guarantee institutions
which include the Trade and Investment Development Corporation of the Philippines
(TIDCORP), the Guarantee Fund for Small and Medium Enterprises (GFSME), the Small
Business Guarantee Fund Corporation (SBGFC) and the Quedan and Rural Credit
Guarantee Corporation (Quedancor). Except for the SBGFC (which will be merged with
the GFSME), guarantees of the TIDCORP, Quedancor and GFSME are backed by the
national government.
12
A 1998 study on the Quedancor, SBGFC and GFSME noted substantial losses in these
programs, with all three-guarantee institutions suffering negative net operating income
from 1992 to 1997. The study, moreover, observed that the number of loans guaranteed
by the programs is small and the additional number of loans that were stimulated by the
guarantee schemes is even smaller. Government decision to continue infusing hefty sums
into these institutions should thus take these factors into consideration.
The most current audited balance sheet (2000) of the SSS shows a total reserve fund of
P170.4 billion comprising Pension Reserve Fund of P151.8 billion, Employees
compensation Fund P18.4 billion and Mortgagors’ Insurance Fund P0.2 billion.
However, this does not accurately represent the unfunded liabilities of the institution.
In 2000 the benefits of the SSS exceeded contributions by PhP3.5 billion. But, it
managed to overcome the gap by its earnings from investment. However, this may not be
feasible for all the years to come. According to estimates made by the Secretariat of the
Presidential Retirement Income Commission (PRIC) on the basis of the World Bank
PROST model, the implicit public debt in the case of termination of the program in 1999
would have amounted to P1.48 trillion or about 50% of GDP. The program's unfunded
liabilities were estimated at P1.3 trillion. The PRIC Secretariat further estimated that cash
flow will turn negative and the benefit payments will start dipping into reserves by 2003.
Actuarially it is headed for the morgue with reserves expected to run out by 2011. Office
of the Chief Actuary of the SSS also agrees with these estimates.
In fact, for a long period there had been deteriorating actuarial fund life of the social
security system and fund ratio due to the following factors:
This deficiency is largely accounted for by the basic mismatch between the benefit rate
and the contribution rate. In the case of the SSS, even for the high-income contributor,
the ratio between the present value of the stream of benefits divided by the present value
13
of the stream of contributions, or the benefit ratio works out to 1.60. For the beneficiaries
of the minimum pension, the benefit ratio is estimated at 7.93.
Table-5 below indicates that by international comparisons, the SSS contribution rate is
low while its administrative cost is high and the return on investments is poor. At present
the SSS contribution rate at 8.4 per cent (comprising 3.3 percent contribution by the
employee and 5.1 percent by the employer) is much smaller compared to that of GSIS
and similar funded and aged social security programs in other countries. It compares
unfavorably with the GSIS with a contribution rate of 21 per cent. The SSS contribution
rate is also one of the lowest among the similar pension systems for other countries such
as Malaysia with a contribution rate of 23 per cent, Singapore 32 per cent, China 30 per
cent, Vietnam 20 per cent, Turkey 20 per cent and Egypt at 30 per cent.
The SSS funds are also being utilized to subsidize consumer loans, housing loans and
development loans, which constitute about 50 per cent of total investments. At the end of
October 2001, housing loans comprised 26 per cent of total investments, member loans
15 per cent, development loans 8 per cent, government sector loans 17 per cent, equities
in private sector 29 per cent, and real estate 4 per cent. Moreover, because of political
considerations, the SSS is not allowed to diversify its investments by investing in foreign
assets. The result is that the SSS has become actuarially unsound.
Demographic transition in Philippines has also exacerbated the SSS’s financial plight.
Due to an increase in expectation of life, more people are living longer and the pension
benefits have to be paid for a longer period.
As the name suggests, Government officials are the members of the GSIS while private
employees are the members of SSS. The most current audited balance sheet (2000) of the
GSIS shows a total reserve fund of P166 billion comprising Social Insurance Fund pf
14
P154 billion, Optional Life Insurance Fund P6.8 billion, General Insurance Fund P4.8
billion, and Employees Compensation Insurance Fund P0.5 billion. However, this does
not accurately represent the unfunded liabilities of the institution. The PRIC Secretariat
estimated that the implicit public debt of GSIS at the end of 1999 stood at P538 billion
compared with a pension reserve of P136.4 billion resulting in its unfunded liabilities
amounting to P401.6 billion.
According to a study made by the World Bank (2000) the implicit total public pension
debt for the Philippine is estimated to be 107 per cent of GDP. It may, however, be noted
here that the Philippines is not the only country having problem with contingent liabilities
relating to pension and provident funds. Governments all over the world face similar
problems, many of which are yet to explicitly recognize that the problem exists. Table-6
below highlights the severity of the problem with implicit pension debt in some countries,
which indicates that the situation in Philippines is not as bad as in some emerging
markets.
Although the financial position of GSIS is better than that of the SSS, it is estimated that
the current benefits of GSIS at the existing rates would exceed the current contributions
in 1924, and there would be serious liquidity problem in 2041 and the reserves would be
exhausted in 2068.
The better health of GSIS is due to a better match between benefits and contribution with
the benefit ratio ranging between 1.05 for the highest income bracket and 1.40 for the
lowest income member. The contribution rate at 21 percent is almost two and half times
of that of SSS. Although there is little scope for enhancing the contribution rate, which is
reasonable at 21 per cent, there is scope for improving the compliance rate and to
rationalize the benefits among the members in different income brackets. There is also
scope for enhancing the qualifying period for getting pension and to increase the
retirement age commensurate with the increase in expectation of life.
15
It may not be politically feasible to amend the Act for removal of automatic government
guarantee in the case of financial problem faced by GSIS or SSS. However, both the
systems should move from defined benefits system to defined contribution system.
There is also need for strengthening the Asset Liability Management (ALM) system in
both these organizations to minimize the risks given defined contributions.
The present thrust of the GSIS on the “Back to Basics Policy” is in the right direction.
Under the policy, the GSIS concentrated on essential activities where it is efficient such
as administration of benefits, limiting direct lending operations to salary and housing
loans to its members, and phased out peripheral programs, which can be more efficiently
handled by the private sector. The SSS can learn from these experiences of GSIS.
There is also a need to separate life and non-life components of insurance. While
government can provide some subsidies for life insurance for targeted groups of people
due to social reasons, there should be no subsidies for non-life insurance, which can be
fully funded and better managed by the private sector.
While Pag-IBIG appears in better shape financially than the pension institutions, the
quality of its portfolio is a point of concern. It is reported that the institution's non-
performing mortgage loans comprise 30% of its mortgage portfolio, which under the
worst case scenario (no recoveries) translates into a potential loss of P12 billion based on
mortgages outstanding at the end of 1999 (net of loan loss provisions). Actual losses,
however, would most likely be lower given recoveries on acquired assets and a 22%
government guarantee on a portion of the portfolio.
Philippines banks had very difficult time in recent years. Despite internal and external
shocks, the banking system continued to hold its ground in 2000 with growing deposits,
manageable asset quality, and desirable capital adequacy ratio. Deposits of commercial
banks grew by 7.5 per cent in 2000. While savings deposits accounted for 60.7 per cent of
total deposits, time and demand deposits comprised 28.4 per cent and 10.9 per cent
respectively.
16
BSP is the regulator for all banks – which are categorized as expanded commercial banks,
non-expanded commercial banks, government banks and foreign banks. It is mandatory
for all banks to disclose the off balance sheet (i.e. contingent) liabilities in their balance
sheet. However, BSP itself does not disclose its contingent liabilities in national interest.
There are strict prudential norms for making provisions for loss assets and sub-standard
assets. Commission on Audit is responsible for auditing all GOCCs including government
banks and BSP.
Philippines banks, particularly the government banks, at present are beset with the
problems of high levels of non-performing assets and low rate of return, although they
have reasonable capital adequacy ratios. Moreover, both the capital and the non-
performing assets are unevenly distributed among the banks.
The asset quality of the banking system exhibited steady worsening since 1997. The non-
performing loan (NPL) ratio of the banking system increased to 17.3 per cent at the end
of 2001 compared to only 2.8 per cent at the end of 1996 (Table-7). The NPL ratio for the
non-expanded commercial banks (NEKBs) was the highest at 22.8 per cent, and that for
foreign banks was the lowest at 4.8 per cent, while the NPL ratio for government banks
stood at 17.8 per cent at the end of 2001. Restructured loans of commercial banks
increased substantially in 2000-2001 and accounted for 6 per cent of total loans.
Table-7 Gross NPL ratios (Non performing loans as percentage of total loans)
However, the banking system remained adequately capitalized. The average capital
adequacy ratio (CAR) of the banking system stood at 16.4 per cent at the end of 2000,
lower than 17.5 per cent achieved in 1999. Notwithstanding the decline, the ratio
remained well above the BSP statutory floor rate of 10 per cent and the Bank for
International Settlements (BIS) standard of 8 per cent. Meanwhile, bank provisions for
possible loan defaults improved to 6.5 per cent of total loans at end-December 2000 from
5.8 per cent in 1999. On the other hand, the proportion of banks’ reserves for probable
losses to total NPLs declined to 43.5 per cent at the end of December 2000 from 45.2 per
cent at the end of 1999.
17
The ratio of real estate loans to total loans (inclusive of inter bank loans) of commercial
banks dropped marginally to 11.3 per cent at the end of 2000 from 11.6 per cent at the
end of 1999. The current ratio continued to remain well below the BSP’s norm of 20 per
cent ceiling on bank lending to the real estate sector.
Bank’s profits continued to fall with the average return on equity (ROE) declining from
3.3 per cent in 1999 to 2.6 per cent in 2000. Return on assets (ROA) also declined from
0.5 per cent in 1999 to 0.4 per cent in 2000. The rural banks posted the highest ROE at 7
per cent followed by the commercial banks at 2.9 per cent. The ROE of the thrift banks
deteriorated to (-) 1.7 per cent in 2000 from the positive ROE of 7.4 per cent in 1999.
As in the case of most emerging markets, the government of Philippines is also exposed
to significant explicit and implicit risks from the financial sector. Explicit risk arises from
the deposit insurance system under which deposits up to PhP100, 000 (about US$2000)
are fully insured. Under the assumptions that the existing deposits would not be split in
anticipation of a bank failure, the maximum exposure faced by the system is about
PhP352 billion (amounting to 10 per cent of GDP). In contrast, the deposit insurance fund
has reserves on only PhP20 billion so the failure of any of the country’s large banks
would probably exhaust the reserve.
There is also an implicit risk from the possibility of a “too big to fail” bank facing a bank
run or imminent failure. While it is difficult to estimate the probability for the occurrence
of such an event, there are troubled banks in the Philippines. In a study on the basis of
1999 data, Standard and Poor’s has estimated that in the event of a “worst case scenario”
the gross non-performing assets of the Philippines banking system would be in the range
of 15 to 30 per cent of all banking system assets. This would lead to a fiscal cost to the
government amounting to 7 to 15 per cent of GDP in the event of a systematic crisis. This
is roughly the magnitude of the Mexico’s crisis in 1994-95 and much larger than
estimates of the fiscal cost of the Philippine banking crisis in the 1980s.
18
• External guarantees provided by nationalised banks, developmental financial
institutions, EXIM banks etc.
• Default of an institutional government and public or private entity on external non-
guaranteed debt and other external liabilities.
• Clearing the liabilities of privatised entities with significant foreign participation
• Take-over of strategically important foreign companies
• Bank failure (beyond state institutions) where deposits of non-residents are also
affected
• Investment failure of a state-run investment fund with participation by foreigners
• Default of the central bank on its obligations to foreign exchange contracts
• Environmental damage affecting offshore areas, where foreign claims are involved
Information on all these liabilities are not readily available. However, as indicated earlier,
the bulk (97 per cent) of the national government guarantees consist of guarantees on
foreign debts of GOCCs, and the National Power Corporation, which enjoys automatic
government guarantee on its bonds, has the largest share (42%) of outstanding foreign
loans of GOCCs. Government financial institutions, including the BSP, also have large
outstanding foreign loans.
Government financial institutions (GFIs), such as the Land Bank (LBP) and the
Development Bank of the Philippines (DBP), are allowed to incur foreign loans from
multilateral funding agencies and re-lend funds to private sector entities for industrial,
agricultural and other development projects. While the concerned GFI generally takes on
the credit risk, it also seeks national government guarantee to cover the foreign exchange
risk. The national government provides the service, in the absence of hedging facilities in
the private market, to take advantage of concessional loans from the multilateral funding
agencies. In exchange, it charges guarantee fees based on the difference in peso T-bill
and the interest rate on the foreign loan. These fees are generally adequate to cover
exchange rate risk over time, since the expectations on peso depreciation are factored in
the T-bill rates. Unfortunately, the BTr does not monitor these loans with foreign
exchange cover separately.
External Debt
19
Table-9-A: International Comparison of Top Fifteen Debtor Countries in 1999
Source: Global Development Finance, 2001, Country Tables, the World Bank.
Source: Global Development Finance, 2001, Analysis and Summary Tables, The World Bank.
Note: For Severely Indebted countries, either PV/XGS > 220 or PV/GNP > 80
For Moderately Indebted countries, either 132 < PV/XGS < 220 or 48 < PV/GNP < 80
And For Less Indebted countries, Both PV/XGS < 132 and PV/GNP < 48.
20
Total external debt of the Philippines declined marginally from US$52 billion at the end
of 1999 to US$51.1 billion at the end of 2000. Public sector accounted for 66 per cent of
total debt stock at the end of 2000 and around 66 per cent of the public debt consisted of
liabilities of the National government.
By creditor type, bilateral and multilateral creditors combined accounted for the bulk (48
per cent) of the country’s sources of external financing. Foreign holders of bonds and
notes represented 25.8 per cent of total external debt while banks and other financial
institutions provided 21.5 per cent of total credits.
• The ratio of debt services to exports of goods and services improved from 14.3
per cent in 1999 to 12.3 per cent in 2000.
• The maturity profile of the country’s external debt remained concentrated in
medium- and long term (MLT) loans constituting 88.6 per cent of total debt at the
end of 2000.
• The average maturity of MLT loans stood at 16.6 years in 2000, although it
declined marginally from 16.9 years in 1999.
All these indicators indicate that although the current situation is manageable,
government has substantial exposure to external sector risks and needs to have
appropriate policies to deal with exchange rate fluctuations. It is desirable that the
government fixes benchmarks for the interest rate, maturity and currency mix of the
future external loans. It may also like to put a limit on external debt and the national
government guarantees to be provided on external debt.
21
6. Management of Contingent Liabilities- cross Country Experiences
Provision of government guarantees per see is not bad. But, problems of contingent
liabilities arise when the risks inherent in such contingent liabilities are not properly
assessed and quantified, and adequate provision is not made in the event of default by the
borrower. As a result, when guarantees are invoked, it leads to heavy budgetary burden
on the issuing Governments. Contingent liability, therefore, became a bad word.
The conventional budgeting system on the basis of cash accounting followed by most
Governments also contributed to the growth of contingent liabilities. In such a budgeting
framework, guarantees appeared as an off balance-sheet item or a memorandum item in
the Budget. Since they did not appear as part of the overall balance sheet and resource
utilisation statements, they were often viewed as a free resource, which encouraged
Governments to issue guarantees liberally for attracting private sector investment,
Even in cases where the risks were understood, very often the Governments did not
bother because the implications of such contingent risks was to be felt in the long run
only and there was no immediate budgetary implications.
The problem of moral hazard also surfaced. With Governments willing to extend all
support to foreign investment, investors sometimes insisted on blanket guarantees. Once
they could get commitment for assured returns as in the case of many BOT projects on
power, the investors sometimes did not make serious appraisal of the projects and their
risk/return profile. As a result, unviable and uneconomic projects were also taken up for
investment, which led to situations where Governments often ended up paying the
minimum assured returns to the investors from its own budgetary resources.
However, there is no fundamental difference between the risks associated with direct
loans taken by the Government and those associated with Government guarantees. If
there is a shortfall of demand or income of a project funded by direct loans, the
Government has less revenues than expected, and it must use general taxes to pay back
lenders. With a guarantee, the Government also must use taxes to pay out the contingent
22
liability if the primary borrowers default. If the Government takes the preservation of the
facility, in both cases it is responsible for making debt service payments. In some cases,
guarantees can be better than direct loans because guarantees can be made more explicit
and can cover only sub sets of risks, while the rest of the risks can be assigned to the
private operators and insurance companies. But Government should make proper
appraisal and use discretion while granting guarantees.
Explicit contingent liabilities may represent a significant balance sheet risk for a
government and are a potential source of future tax rate variability. However, unlike most
government financial obligations, contingent liabilities have a degree of uncertainty. They
are exercised only if certain events occur or do not occur and the size of the actual fiscal
outgo depends on the structure of the undertaking.
Sound public policy requires that a government needs to carefully manage and control the
risks of their contingent liabilities. The most important aspect of 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.
For a government seeking to manage risks for contingent liabilities the first step should
be to determine its degree of risk aversion in the area of contingent liabilities and the
extent of the balance sheet risk it wishes to be accountable for. It also needs to decide
whether it wishes to manage its own balance sheet solely, or whether to be accountable
for risks generated in other parts of the public sector or in the private sector.
Experience in the industrialised countries suggests that more complete disclosure, better
risk sharing arrangements, improved governance structures for state-owned entities and
sound economic policies can lead to very substantial reductions in the government’s
exposure to contingent liabilities.
Annexure-B presents a brief survey on the experiences of ten countries viz. India,
Australia, Canada, Columbia, Czech Republic, Hungary, New Zealand, Philippines the
United Kingdom and United States with regard to the management of contingent
liabilities. The choice of countries was based on the advanced nature of the consideration
of the problem of contingent liabilities and the ready availability of such information.
Individual country practices differ in dealing with contingent liabilities, but all countries
share a common set of principles to capture maximum contingent liabilities affecting
government budget.
In all the countries surveyed, the consideration of contingent liabilities was an integral
part of improving transparency in government operations in general and fiscal
transparency in particular. Indeed it is tied to a process of bringing “open government” so
that citizens and outsiders (foreign investors, commercial banks, credit rating
organisations, multilateral financial institutes etc.) can more accurately assess the
government’s financial position.
23
All countries adopted the Government fiscal framework in line with the IMF’s Guidelines
on Fiscal Transparency. In addition, these countries also publish information of the
International Investment Position and report information on the new foreign exchange
reserves template introduced by the IMF under the SDDS.
In all the countries either the Department of Finance or the Ministry of Finance or the
Treasury is in charge of approval and issue of government guarantees except in the
United Kingdom where the respective Ministries/ Departments are empowered to
approve such guarantees.
In most of the countries either the Department of Finance or the Ministry of Finance or
the Treasury is in charge of monitoring of guarantees. However, in the countries such as
the United Kingdom, Columbia, Hungary and New Zealand where a full-fledged Public
Debt Office (PDO) exists, the PDO monitors guarantees as a part of overall risk
management for the government in ALM framework.
In general the USA and New Zealand avoid automatic guarantee and makes proper
evaluation of risks before providing any kind of guarantee. However, other countries
provide automatic guarantees, particularly fiduciary guarantees for insurance or certain
items for social reasons. Government of India provides automatic guarantee to Small
Savings Scheme, Public Provident Funds and Life Insurance, Australia to certain
liabilities of government controlled financial institutions, Canada to Crown Corporations
on insurance, Hungary to reinsurance of priority lending, Philippines to some of the
GOCCs under their respective charters and UK to items of national security.
Generally implicit contingent liabilities relating to Pension, Provident and Insurance are
not monitored regularly due to lack of proper methodology and adequate information.
Up-to-date data are readily available at regular intervals in Australia, Canada, Hungary,
New Zealand, U.K. and U.S.A. But no such data, except for government guarantees, are
made available for India, Columbia, Czechoslovakia and Philippines.
24
(vi) Reporting to general public:
All information relating to monitored contingent liabilities are disseminated for general
use. However, some countries may not reveal certain information in national interest or
for their adverse effects on the financial markets. For example, in the case of the United
Kingdom, the law allows non-reporting of certain contingent liabilities, which are
important for reasons of national security or commercial confidentiality.
All the countries, as indicated below, either have in place or in the process of enacting
particular legislation for monitoring and reporting of contingent liabilities.
India: Proposed Fiscal Responsibility and Budget Management Act under article 292
Australia: Charter of Budget Honesty Act (BHA) 1998
Canada: Financial Administration Act
Columbia: Law 448 enacted on 21-07-98
Czech Republic: Law of Budgetary Rules
Hungary: Public Finance Act 1992
New Zealand: Fiscal responsibility Act, Public Finance Act, Local Government Act,
Philippines: Republic Act 4860 (for only guarantees given to foreign loans)
UK: Code of Fiscal stability
USA: Federal Credit Reforms Act 1990
25
(ii) Contingent liabilities regulated by law:
The scope of contingent liabilities, which are monitored, vary across the countries
depending on their magnitudes and importance. Items, which are monitored regularly in
different countries, are indicated below:
India: All Guarantees, Public Provident Fund, Small Savings Scheme, Life Insurance
Australia, Canada, New Zealand: Guarantees, indemnities, uncalled capital
Columbia- Contingent Liabilities of state entities
Czech Rep- Guarantees, hidden debt
Hungary- Guarantees, reinsurance
Philippines- Guarantees to GOCCs
UK, USA- All material contingent liabilities
In all the countries, there are independent audit organizations, which audit not only the
annual balance sheet but also the contingent liabilities. The details of the Audit Offices in
different countries are indicated below:
India: Comptroller General of Accounts
Australia: National audit Office
Canada, Columbia, Czech Rep: Yes
Hungary- State Audit Office
New Zealand: Yes, applies Generally Accepted Auditing Principles (GAAP)
Philippines- Yes by Commission on Audit
UK: National Audit Office
USA: Yes, applies Federal Financial Accounting Standards
26
(c) Policy Framework and Practices
India, Australia, Canada, Columbia, Hungary, New Zealand and U.S.A. have designated
Contingency Redemption Fund, which can be used in the case of recall of guarantees. But
the governments of Czech Rep, Philippines and U.K. donot have any such funds.
It is generally accepted that the accrual accounting is the best suitable accounting
methodology for measuring risk relating to contingent liabilities. In
Australia, Canada, Hungary, New Zealand, and U.S.A., budgeting is done on the basis of
accrual accounting. But the countries of India, Columbia, Czech Rep, Philippines, and
U.K. still use mainly cash accounting, although accrual accounting may be used for
certain items like committed loan repayments and interest payments.
Governments of Australia, Canada, Hungary, New Zealand, U.K., and U.S.A. include a
statement on fiscal risk in their budget, while so such statements are given in the budgets
of India, Columbia, Czech Rep, and Philippines.
In Australia, Canada, Columbia, Hungary, New Zealand, U.K., and U.S.A., a full-fledged
Public Debt Office (PDO) exists. The PDO is in charge of managing overall risk of both
loans and guarantees in the framework of Asset Liability Management (ALM). But, no
such integrated PDO exists in India, Czech Republic, and Philippines.
27
7. Tasks for Philippines Government
An efficient fiscal management system requires that the government treat any non-cash
program involving a contingent fiscal risk like any budgetary or debt item. Most
importantly, the system has to make the potential fiscal cost of off-budget programs
visible ex-ante. Accrual-based budgeting and accounting systems help fiscal discipline
but are neither sufficient nor necessary in their entirety. Disclosure of full fiscal
information is most critical. Disclosure of face values of contingent liabilities as in the
case of the USA enables the markets to analyse and measure the complete fiscal risks and
thus indirectly assist the government in its risk assessment. Formulation of efficient rules
and regulations on the use of government guarantees, pension funds and insurance
programs, and on the operations of the government owned and controlled corporations
(GOCCs) and subnational governments are also equally important.
On the basis of effective risk analysis, the government can design the appropriate
programs that would still deliver the desired outcomes but minimise the government’s
risk exposure. The objective would be particularly to expose the government only to
those risks that are beyond control of the parties under the program and that would spread
the potential cost of the program between the government and the beneficiaries. Under a
state guarantee, for instance, the government would identify and cover in the guarantee
contract only selected risks, which may be shared by it, while other risks may be left to
be assumed by other stakeholders or beneficiaries. With respect to the autonomous public
sector agencies, the government should strengthen the financial and managerial
accountability of their staffs by remunerating sound risk analysis and early warning
signals rather than short-term profits of these agencies.
28
The following specific tasks are required to be completed in the near term:
First, to create a full fledged institutional structure in the DoF to manage contingent
liabilities. For this purpose, it is necessary to set up a Middle Office for management of
Contingent Liabilities in the DOF with sanction of sufficient budget and recruitment of
technical experts. The main reason for locating it in the Department of Finance is that
there are strong links between budgeting and sovereign liability management functions.
At the same time, it would help to mitigate conflicts in objectives between fiscal
management and monetary policy, through active co-ordination between the middle
office and the BSP.
The middle office is usually an entity, which serves as the risk manager, formulates and
advises on the sovereign liability management strategy and develops benchmarks for
assessing the risk-cost trade-off of the contingent liabilities. The role of the “middle
office” is to identify, quantify and monitor contingent liabilities, make analysis of risk,
provide advice and management information system (MIS) inputs for formulation of
appropriate policies in the overall framework of the public debt and contingent liability
management, keeping into perspective the long-term financial requirements for economic
development and maintaining fiscal sustainability.
The Middle Office will advise the government on the following tasks:
29
The scope of the middle office at the initial stage should include both explicit and implicit
contingent liabilities and could gradually be expanded to include management of both
internal and external debt. The Middle Office should immediately deal with fixation of
ceiling on contingent liabilities, their allocation between domestic and external sectors
and among competing sectors (such as agriculture and allied sectors, industry, transport,
communications, power, banking and other financial services, real estate etc.). It should
also develop benchmarks for currency composition of external loans, maturity, interest
rates, composition of loans under floating and fixed interest rates etc. for which
guarantees may be considered.
The middle office can also review the contractual obligations for BOT projects, estimate
monetary obligations of the national government, suggest inputs for feasible unbundling
of risks and for possible renegotiating of contracts, specify early warning systems for
defaults, provide advice to improve the legal, institutional and regulatory framework
affecting BOT/ PSP projects.
The middle office should also act as the apex monitoring unit for all contingent liabilities.
Thus, data on contingent liabilities should be regularly transferred by different agencies
to the middle office. The middle office should ensure that it develops a completely
computerised data recording system, which is amenable to modern risk management
analysis and can be easily retrieved and cross-classified by various characteristics such as
sector, currency, interest rate, and maturity.
The middle office would be responsible for bringing out an annual status report on
contingent liabilities, which should enhance the transparency and accountability of the
liability position of the government. The report should clearly define and disclose the
main objectives of contingent liability management, the strategic benchmarks of the
liability portfolio and performance of portfolio management by the relevant agencies as
measured by the cost of the actual liability portfolio relative to the benchmark portfolio.
Based on the risk-management framework and cost-risk trade-off, the Middle Office
would be expected to determine strategic benchmarks for the contingent liability
portfolio. The strategic benchmarks could be the proportion of domestic and foreign
currency debt; the currency composition, average duration, mix of floating-fixed interest
rate debt and maturity structure of foreign currency debt portfolio; and maturity structure
and duration for the domestic debt portfolio, for which government guarantees can be
provided.
Strategic benchmarks, designed by the Middle Office, should have the approval of the
Secretary of Finance. For this purpose, the Contingent Liability Advisory Committee
should advice the Finance Secretary periodically on the appropriateness of the framework
and the strategic benchmarks.
30
Once, the strategic benchmarks are approved, the Middle Office should regularly
disseminate the relevant benchmarks to the concerned agencies involved for contracting
or issuing government guarantees. This would enable them to determine their liability
management strategy so as to be consistent with the strategic benchmarks.
The middle office should be staffed with officials with the necessary expertise from the
DOF, and on a deputation basis from the other organisations mentioned above.
Investment in infrastructure and human resource development should be an area of
priority for the government to promote professional approach towards contingent liability
and overall debt management.
(a) Manual for measurement of all contingent liabilities- explicit and implicit
(b) Manual on prudential norms for income recognition, asset classification and
provisioning for advances and investment portfolio.
(c) Guidelines for risk management and Asset and Liability Management (ALM)
framework.
(f)
As an
initial step towards risk management, it is necessary to promote disclosure and
accountability with regard to at least explicit contingent liabilities. In its Code of Good
Practices on Fiscal Transparency, the IMF also recommends that countries should
disclose in their Budget documentation the main central government contingent
liabilities, provide a brief indication of their nature and extent and indicate the potential
beneficiaries. The Code suggests that best practice in the area would involve providing
an estimate of the expected cost of each contingent liability wherever possible and the
basis for estimating expected cost.
31
Best management practice for contingent liabilities is to make adequate provision for
expected losses and to hold additional assets against the risk of unexpected losses. In
cases where it not possible to derive reliable cost estimates, the available information on
the cost and risk of contingent liabilities should be summarised in the notes to the Budget
tables or the government’s financial accounts.
GOCCs also should estimate and disclose their contingent liabilities. Once the concepts,
definitions, methodology and data problems have been resolved and key organisational
challenges have been addressed, all the GOCCs must be directed to disclose their
contingent liabilities in their Annual Reports and to have appropriate policies for
contingent liability management
1. .
4. Reporting to DOF
All government departments and GOCCs may be required to submit half yearly reports
to the Middle Office in DOF on their contingent liabilities and risk mitigation measures.
6. Capacity Building
As the co-ordinating organisation and nodal office, DOF may formulate time bound
program for capacity building within government and GOCCs for management of CLs. It
is also necessary to improve infrastructure and hardware and software capacities for
information systems, central databases networks and interface with all organisations
dealing with CLs.
7. Limit on Guarantees
DOF may issue an Executive Order for removing all automatic guarantees on some
GOCCs and to put a limit on guarantees. Future requests for guarantees may be examined
on the basis of normal appraisal procedures for providing either loans or grants.
32
(a) Pension Funds and Social Security: SSS and GSIS are the major sources of explicit
and implicit contingent liabilities of the government, and reduction of risk arising from
unfunded or underfunded pension liabilities is needs to be given urgent attention.
Contribution rates for SSS are much lower than the benefits and need to be increased to
reduce the current gap between contributions and benefits. Management of the
investment portfolio of the reserve funds for both SSS and GSIS needs to be fully
professionalised and insulated from political interference.
To provide a truly equitable, universal and meaningful social security protection, the SSS
must align its benefits and hence its contributions to that of similar programs both locally
and internationally. There is an urgent need to enhance the SSS contribution rate to at
least 12 per cent in the current year and to double the present rate of 8.4 per cent, if not to
the level of GSIS rate, in a phased manner in three years. It is estimated that the gradual
increase in the SSS contribution rate from 8.4 per cent to 20 per cent will increase the
actuarial life of the social security fund by at least 20 years.
While increases in social security contributions are always politically sensitive, the task
faced by the Philippine policy makers may not be difficult on considering the fact that the
GSIS members are already contributing 21 per cent. Therefore, actions to bring benefits
and contribution in line with each other are urgently required for fiscal sustainability of
the social security system.
Although there is little scope for enhancing the contribution rate of GSIS, which is
reasonable at 21 per cent, there is scope for improving the compliance rate and to
rationalize the benefits among the members in different income brackets. There is also
scope for enhancing the qualifying period for getting pension and to increase the
retirement age commensurate with the increase in expectation of life.
It may not be politically feasible to amend the Act for removal of automatic government
guarantee in the case of financial problem faced by GSIS or SSS. However, both the
systems should move from defined benefits system to defined contribution system.
There is also need for strengthening the Asset Liability Management (ALM) system in
both these organizations to minimize the risks given defined contributions.
The present thrust of the GSIS on the “Back to Basics Policy” is in the right direction.
Under the policy, the GSIS concentrated on essential activities where it is efficient such
as administration of benefits, limiting direct lending operations to salary and housing
loans to its members, and phased out peripheral programs, which can be more efficiently
handled by the private sector. The SSS can learn from these experiences of GSIS.
There is also a need to separate life and non-life components of insurance. While
government can provide some subsidies for life insurance for targeted groups of people
due to social reasons, there should be no subsidies for non-life insurance, which can be
fully funded and better managed by the private sector.
33
(b) The banking sector urgently needs strengthening. Cross-country evidence suggests
that timely rehabilitation is one of the key factors in determining the success of bank
rehabilitation efforts. The current level of asset performance, the system could face
severe difficulty if another major external shock such as that of 1997 occurred or if the
economy’s growth rate slowed significantly. The government is currently attempting to
encourage private sector driven measures to restructure banks. But the effectiveness of
privately led asset management companies is subject to question. In the meantime, the
government should also continue its efforts to improve capital standards and supervision.
It is also equally important to improve the supervision and regulation of the banking and
insurance system and capital markets, including the use of such instruments as mandatory
risk limits and minimum capital adequacy norms. Stronger accounting and disclosure
requirements for private corporations are important mechanisms for limiting the
likelihood that a systemic crisis might occur, and will limit the government's exposure if
it does.
The Philippine banks have been entertaining sales of their non-performing loans to the
U.S. opportunity funds for the past several months. Several banks are presently in
negotiations with U.S. investment banks and opportunity funds. But these negotiations
have not resulted in significant transactions, as most of the banks do not have the capital
adequacy to sustain large write-offs in their NPLs without adversely affecting their
capital base.
These measures are in the right directions and need to strengthened and brought to their
logical ends on time bound schedule.
(c) GOCCS: Auditing and accounting of the GOCCs need to be strengthened. It may
also be desirable to institute performance contacts and sign Memorandum of
Understanding (MOUs) with major GOCCs and GFIs (as being done in India) indicating
their medium term corporate objectives and planning and annual targets on both physical
and financial achievements.
In the medium and long term the following tasks may be completed:
One important task for the medium term is to move towards the full accrual system of
accounting as required under the Revised Government Statistics (GFS 2000) the IMF. The
Government accounts in the Philippines, as in the case of many countries, are currently
34
maintained on mainly cash basis, and not on complete accrual basis. It is generally
recognised that cash-based systems are not suitable for measuring, recording and
monitoring contingent liabilities, which can be captured by only accrual accounting.
The accrual accounting model is widely used in business financial reporting where it
provides a measure of profitability of the business. In government, it can be used to
assess inter-generational or inter-temporal equity, which implies that one generation or
one period should not be made to pay for the benefits extended to and enjoyed by another
generation or period. A simple measure of inter-generational equity is what is called Net
Asset/Equity, which is defined as the balance of assets and liabilities. If Net Asset/Equity
is negative, it implies that the future generations will have to bear the burden of
additional taxation if the Government has to honour its commitments.
There is an increasing awareness on this issue and many governments are switching over
to accrual based accounting. The Philippine government has already decided to proceed
towards accrual accounting for bringing more transparency in reporting. The decision
needs to be implemented on priority basis.
2. Improvement in Audit
It is necessary to strengthen both the internal and external audit teams to deal with
accrual system of accounting and to measure and report properly the explicit and implicit
contingent liabilities. A full audit of the non-bank financial institutions may be called for.
Equally important, a broader role for resident auditors in reviewing the financial
statement of GOCCs would ensure that not only are transactions properly booked in the
balance sheet but also profit and loss statements are reflective of the true financial
positions of the corporations.
It should be made mandatory for all GOCCs, particularly for SSS, GSIS, RSBS, HGC
and Pag-ibig, to disclose contingent liabilities in their annual reports and balance sheets.
35
In India there is also a system of signing a Memorandum of Understanding (MOU)
between a public sector undertaking (PSU) and the concerned administrative ministry of
the department on the annual targets on various aspects of physical and financial
performance. The achievement of the PSU in terms of the targets under MOU is audited
as per performance auditing by the statutory auditors and the specific grades are awarded
to the PSUs. The similar system of signing MOUs with GOCCs and their performance
auditing may be introduced by the government of Philippines for better monitoring the
overall performance of the GOCCs.
3. US System of Provisioning
In the long run, budgeting for contingent liabilities would ideally follow the U.S. example
where both direct and contingent liabilities are integrated in the budget based on their
subsidy costs, i.e., for loans, the present value of amounts not repaid and the difference
between the interest rate charged from borrowers and government’s cost of funds; for
guarantees, the present value of the difference between cash payments for defaults and
cash received from fees and recoveries. The main advantage of adopting this approach is
that government becomes indifferent as to choosing between cash subsidy, a loan or a
guarantee on loans. The US system of budgeting and management of contingent liabilities
are discussed in details in Annexure-3.
The system of charging a uniform flat rate of guarantee fee is not good for effective
management of contingent liabilities. The guarantee fee charged needs to be based on the
cost of borrowing, plus the cost of provisioning and the cost of building-up reserves for
unanticipated losses. Guarantee fees collected should not be taken as general revenues;
rather be kept in a separate contingency fund or contingent liability redemption fund.
Where sophisticated risk adjusted pricing is possible, the revenue from the guarantee fee
as risk premium 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 through fee income. The amount of capital allocated would reflect the
governments risk preferences.
In the long run, the Philippines government may move towards setting up a full-fledged
Public Debt Office under the overall charge of DOF. Major functions of public debt
managers as regards management of contingent liabilities of the government may include
valuing contingent exposures, discussing with the sovereign credit rating agencies the
extent of the government's exposure and its policy response, restructuring contingent
claims and analysing their possible effects on the governments future financing needs.
36
In the long run, the middle office for the contingent liability management may be
converted into a middle office for the overall public dent management. The need for a
middle office, however, cannot be viewed in isolation. It should be analysed in the
context of total structure of liability management comprising the Head Office (i.e. the
office responsible for final approval of guarantees), Front Office (responsible for
appraisal of guarantee requests and making negotiations with the lenders), Middle Office
(responsible for measurement, monitoring, policy formulation and risk management) and
Back Office (responsible for auditing, accounting, data consolidation, and functions of the
dealing office). The institutional character assumes significance in view of the need for
an active risk management framework, professional approach and expertise required for
management of debt and contingent liabilities.
The role of a public debt manager in managing contingent liabilities of the government
owned and controlled corporations (GOCCs) depends on the degree to which
management of GOCCs is decentralized, the quality of the corporate governance in these
corporations and their technical capability for risk management. For example, in a well
board managed and completely decentralized public sector structure, the GOCCs may be
responsible for designing their own guarantees and underwriting instruments, for
implementing the necessary provisioning and reserving and for managing any subsequent
restructuring in their assets and liabilities. Within this framework the government may
wish to have a central agency such as the Department of Finance, the Treasury or the
Public Debt Office to be responsible for evaluating risk-covering instruments in order to
standardize budgetary procedures and to control their fiscal impact.
International Experience
The primary requirement for a debt office is to bring the size of public debt at sustainable
levels. Without sustainability of debt, risk management would not have much impact
towards insulating the debt portfolio from systemic risks. The main risks that needs to be
37
managed for the sovereign debt portfolio are foreign currency risk, interest rate risk,
credit risk, liquidity risk, refinancing risk, operational risk and payments and settlement
risk. Many debt offices have addressed management of market risks like currency and
interest rate risk by establishing a risk management framework for the sovereign debt in
an asset-liability management framework.
The institutional structure for public debt management, world wide, could be broadly
characterised into two categories – setting up of a centralised public debt office and
scattered debt management responsibilities. The former category of a centralised debt
office, which has been the showcase for countries currently strengthening their debt
management capacity, is mainly found in advanced countries and a few emerging market
economies. For these countries, there has been a preference to locate the debt office as a
separate entity under the Ministry of Finance or within the mainstream Ministry. There
are also some instances of locating the debt office outside the Ministry as an autonomous
agency, but with a Memorandum of Understanding (MOU) signed between the Ministry
of Finance and the Public Debt Office. This institutional mechanism is usually,
safeguarded, by public debt legislation or legal statutes.
Although, independent set-up for the Public Debt Office and the Ministry of Finance are
regarded as somewhat separate watertight compartments for locating the debt office, in
reality, however, there is a very thin dividing line between the two. The Ministry of
38
Finance always exercises some measure of control over the operations of the debt office,
irrespective of its location. This is unavoidable because it is the liability of the
Government that is to be managed by the debt office. Therefore, even among the most
independent set-ups like National Treasury Management Agency of Ireland and the
Swedish National Debt Office which are entrusted with day-to-day management
responsibilities, the Ministry of Finance determines the policy, sets the operational
guidelines and the benchmarks under which the debt office is required to operate.
Continual upgrading the professionalism for management of public debt and contingent
liabilities is essential for maintaining debt sustainability over time. Once the public debt
management responsibility is centralised and a computerised debt recording system
functions efficiently, the main challenge is to develop a risk management office (or
middle office). Building a sound risk management capability within a sovereign debt
management operation can take several years given the experiences of Belgium,
Colombia, Ireland, New Zealand and Sweden. However, there is no uniform model for
this and it needs to be country-specific.
Given that risk management skills are a scarce resource and training staff in this area is
very expensive, a strategy needs to be developed to hire new staff with these skills and to
have an intensive training program for existing staff. Appropriate policies also need to be
formulated to retain these staff given their obvious marketability. The manager or the
head of the middle office should also have strong technical and public policy skills.
39
Government may examine the feasibility of privatising some of the weak GOCCs.
Privatisation does not imply outright sale of the public enterprises but a combination of
various measures to reduce the control of government in the equity holding, management
and policy formulation relating to the public enterprises.
It is important to design contingent liabilities in such a way that they have risk sharing
mechanisms embodied in them, and ensuring that all the risks are not under control of the
beneficiary given that this creates moral hazard risks for the government. Sound risk
sharing arrangements would include providing termination dates for the contingent
claims, pricing the contingent liability on a risk adjusted basis and charging the
beneficiaries accordingly. It also requires beneficiaries to post collateral securities and to
strip down blanket risk guarantees into different risk dimensions so that risk can be more
evenly distributed between the government and the potential beneficiaries. All new
commitments should be scrutinised thoroughly and, whenever possible, must embody
risk sharing arrangements and sunset or termination clause.
Given the substantial support that public-private infrastructure partnerships are likely to
receive from the government, government may work toward establishing capabilities to
audit the award of these projects. The goal would be to assure the public that the
government had achieved value for its money. In the United Kingdom, the National Audit
Office supplements its own skills with those of professional advisors, including lawyers,
investment bankers, and accountants. Skills within government units in India could be
augmented through a similar system.
Government risk sharing should only be considered as a last resort. To prevent excessive
government exposure, decisions should be transparent and based on explicit cost-benefit
analysis for the project to be guaranteed, including an assessment of the likely cost to
taxpayers and the impact of alternative forms of government support.
Guarantees of "policy risks" should support a credible reform program but not be
regarded as a substitute for it. In the medium-term policy reforms for enabling private
participation in infrastructure projects should obviate the need for a guarantee. All the
stakeholders viz. Private operators, beneficiaries, banks and government should share a
part of the risk. In structuring guarantees the government must ensure that the normal
"performance incentives" for private investors are not undermined, essentially by not
covering "normal business risk," including exchange rate and interest rate movements,
and some other market risks which can be covered by the insurance companies and
capital markets.
40
9. Reforms in Pension Funds.
As discussed earlier, in the medium term, the government should move towards defined
contribution schemes or fully funded programs for SSS and GSIS to make them
financially viable and more sustainable over time.
Sound macro economic system supported by strict fiscal and monetary discipline is the
best defense against any economic and financial crisis leading to contingent liabilities.
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.
41
References
Brixi, Hana P., Hafez Ghanem and Roumeen Islam. "Fiscal adjustment and contingent
government liabilities: case studies of the Czech Republic and Macedonia".
Das, Tarun; Anil Bisen, M.R. Nair and Raj Kumar (2001) External sector related
contingent liabilities- A case study for India, commonwealth Secretariat, London.
Kharas, Homi & Deepak Mishra ”Hidden Deficits and Currency Crisis”, World Bank
draft paper, April 1999.
Klein, Michael, “Risk, Taxpayers, and the Role of Government in Project Finance”,
World Bank Policy Research Paper No. 1688, Dec 1996.
Kumar, Raj “Debt Sustainability Issues – New Challenges for Liberalising Economies in
External Debt Management” Reserve Bank of India, Mumbai, 1998.
42
Lewis, Christopher & Ashoka Mody ”Contingent Liabilities for Infrastructure Project –
Implementing a Risk Management Framework for Government”, World Bank, Aug
1998.
Marcus, A.J. and Shaked, 1, (1984), The Valuation of FDIC Deposit Insurance Using
Option Pricing Estimates, Journal of Money, Credit and Banking.
Merton, R.C. (1990), ‘An Analytic Derivation of the Cost of Deposit Insurance and Loan
Guarantees: Application of Modern Option Pricing Theory’, Continuous – Time Finance
Mody, Ashoka and Dilip Patro, “Methods of Loan Guarantee Valuation and Accounting.”
World Bank Discussion Paper No. 116, November 1995.
Mody, Ashoka “Contingent Liabilities in Infrastructure: Lessons of the East Asian Crisis,
World Bank, Washington, 2000.
Schick, Allen, “Budgeting for Fiscal Risk”, World Bank Internal Draft, Sep 1999.
Towe, C.M. (1991),'The Budgetary Control and Fiscal Impact of Government Contingent
Liabilities', IMF Staff Papers Vol. 38 (1)
U.K. H M Treasury, “Fiscal Policy: Public Finances and The Cycle”, 1997.
43
United States General Accounting Office. Budgeting for Federal Insurance Programs.
GAO/AIMD-97-16, September 1997.
World Bank, “Dealing with Public Risk in Private Infrastructure.” Edited by T Irwin, M
Klein, G.E. Perry and M Thobani, Washington DC.
44
Annexure-A: National Government Guarantees to GOCCs
9. Light Rail Funds borrowed from any source, private or Automatic P300 million
Transit public, foreign or domestic Subsidiary
Authority
10. Local Water Both the principal and interest Automatic Pesos 1,000
Utilities Subsidiary million for
Administration domestic loans
and US$500
million for
foreign loans
45
Annexure-A. National Government Guarantees to GOCCs: Continued
13. Manila Both principal and the interest of the bonds Automatic The total
Waterworks and issued by said System by virtue of this Act, and Solidary principal
Sewerage shall pay such principal and interest in case of indebtedness of
System the System fails to do so. the System
exclusive of
interest, shall not
exceed One
Billion Pesos at
any given time
14. National The payment of all loans, credits and other Automatic
Development indebtedness contracted by the Company Solidary
Company
Loans, credits convertible to foreign currencies, Subject to
or other forms of indebtedness, from foreign contract,
governments or any international financial Solidary
institution or fund source, including foreign
private lenders.
15. National The payment by the NEA of both the principal Automatic U.S. $500M
Electrification and the interest of the bonds or other evidences Solidary
Administration of indebtedness, and shall pay such principal
and interest in case the NEA fails to do so;
16. National Food Both the principal and the interests of the bonds Automatic
Authority and other evidences of indebtedness and shall Subsidiary
pay such principal and interests in case the
Authority fails to do so
46
Annexure-A National Government Guarantees to GOCCs: Continued
21. Philippine Loans, credits, indebtedness and bonds Subject to US$1 billion
Aerospace issued contract,
Development Solidary
Corporation
22. Philippine Government Guarantee. The Government of Implicit
Health the Philippines guarantees the financial
Insurance viability of the Program
Corporation
23. Philippine bonds or other securities and loans Subject to
National Oil contract,
Company Solidary
25. Philippine Ports Loans or other indebtedness of the Authority Subject to Total outstanding
Authority contract indebtedness
shall not exceed
the networth of
the Authority.
47
Annexure-A National Government Guarantees to GOCCs: Completed
27. Philippine Principal and interest of domestic and foreign Subject to Total principal
Tourism loans contract domestic debt
Authority not to exceed 200
million pesos
while total
foreign debt not
to exceed
US$200 million
28. Public Estates Bonds, credits, loans, transactions, Subject to
Authority undertakings or obligations of any kind which contract
may be incurred by the Authority
31. Southern Both the principal and interests on bonds, Automatic The bonds issued
Philippines debentures, collaterals, notes or such other Subsidiary shall not exceed
Development obligations incurred by the Authority pesos
Administration 500 million
32. Investment Trade and The payment of obligations incurred Automatic Shall not exceed
Development by the Corporation under the provisions of this Subsidiary fifteen (15) times
Corporation Decree is fully guaranteed by the Government its subscribed
(TIDCOR) of the Republic of the Philippines capital stock
surplus
48
Annexure-B
This annexure surveys the experiences of ten countries – India, Australia, Canada,
Columbia, Czech Republic, Hungary, New Zealand, Philippines the United Kingdom and
United States with regard to the management of contingent liabilities. The choice of
countries was based on the advanced nature of the consideration of the problem of
contingent liabilities and the ready availability of such information. The situation in
other countries such as Bulgaria and Thailand was also examined, but it was not possible,
without further investigation, to clearly spell out the legal and accounting regime in place
and how such liabilities are recorded and managed. Individual country practices differ in
their dealing with contingent liabilities, but all countries share a common set of principles
to capture maximum contingent liabilities as they affect the government budget.
In all the countries surveyed, the consideration of contingent liabilities was an integral
part of improving transparency in government operations in general and fiscal
transparency in particular. Indeed it is tied to a process of bringing “open government” so
that citizens and outsiders (foreign investors, commercial banks, credit rating
organisations, multilateral financial institutes etc.) can more accurately assess the
government’s financial position.
In this survey it was not possible to ascertain the technical details and methodology for
the measurement of contingent liabilities and associated risks. But countries such as New
Zealand Treasury, the General Directorate of Public Credit in Columbia and the public
debt offices in Canada, UK and USA monitor explicit contingent liabilities of the
government as part of overall asset-liability management. In any case, the risks
associated with contingent liabilities have to be considered as part of reducing balance
sheet risk for the government.
All frameworks tended to look at the issue as part of the Government fiscal framework, in
line with the IMF’s Guidelines on Fiscal Transparency. In addition, these countries also
publish information of the International Investment Position and report information on
the new foreign exchange reserves template introduced by the IMF under the SDDS.
While all frameworks generally define contingent liabilities as costs borne by the
Government if a particular event occurs, the precise scope and the detailed items reported
vary across countries. Nevertheless, in most frameworks there is provision to publish
information in the form of quantifiable and non-quantifiable contingent liabilities. Some
examples of quantifiable contingent liabilities are loan guarantees, non-loan guarantees,
indemnities, warranties, promissory notes, callable share capital in international
organisation and liabilities arising out of legal proceedings and disputes (though usually
within maximum limits).
49
Non-quantifiable liabilities include guaranteed benefits payable by national pension,
provident and insurance schemes, environmental contingencies, exchange rate risks and
in some cases (e.g. UK) liabilities relating to privatisation. There is also an implicit
reason for the non-disclosure or partial disclosure of contingent liabilities for tactical
reasons such as “moral hazard” (arising out of say, bank failures) or litigation claims
against the Government (e.g. litigation involving health matters).
Most Governments have in place Acts pertaining to powers to borrow, invest and enter
into other financial obligations on behalf of its citizens, and the responsibilities to report
major contingent liabilities to the parliament through budget documents and other
financial reports. The legal framework usually sets out the maximum amount of new
borrowing and guarantees that the Congress, Parliament or the Minister of Finance can
approve over a specified period, usually the fiscal year. The authority to borrow and to
issue guarantees is delegated to the Minister of Finance or the principal public debt
manager under the Ministry of Finance or Treasury, and requires the Finance Minister to
be accountable for these decisions to the Parliament.
In all regimes, the need to report on contingent liabilities is also underpinned by fiscal
legislation, the main Act and Regulations. The most comprehensive is the Federal
Reform Act of USA, whose important objective is to neutralise budgetary incentives,
making policy makers indifferent to whether they choose grants, direct loans or
guarantees. The conditions for the recognition, measurement and disclosure of
contingent liabilities are clearly spelt out.
The legislative arrangements of the countries surveyed indicate that the regimes delegate
powers to the Minister of Finance on the design and issue of guarantee instruments and
other implementation aspects.
Some countries, such as Colombia and Sweden, are passing this responsibility onto the
government debt manager. In the case of Sweden, the Swedish National Debt Office is
the only government agency that can issue government guarantees. The Office has
developed a model for pricing guarantees in which clients are charged a risk based
premium and all revenues and losses are met from a fund, which is separate from the
Budget. In Colombia, the General Directorate of Public Credit is currently developing a
methodology for valuing contingent liabilities based on Monte Carlo simulations. It will
use this model to evaluate the risks associated with a wide range of government
guarantees, and to establish clear budgetary procedures for disclosure and provisioning.
(c) Accounting
Among the ten countries surveyed, in five countries i.e. India, Czech Republic,
Columbia, Philippines and the united Kingdom, conventional budget is prepared on the
basis of cash accounting i.e. transactions and events are recognised when cash is received
or paid. The financial results are measured in terms of inflows and outflows of cash and
50
changes in the cash balance. The focus of such reporting is on budgetary compliance and
maintaining liquidity solvency- two aspects of Government’s finances that are of prime
concern to the Parliament and to the executives for current decision making. However,
cash accounting has a number of serious drawbacks, such as the following:
In the other countries surveyed i.e. Australia, Canada, Columbia, Hungary, New
Zealand, and the United States of America, there is a clear preference for using the
accrual accounting framework, although the degree of implementation of this method
varies from country to country. Accrual accounts also show cash transactions but also
record contingent liabilities when they are created. By measuring changes in assets and
liability structure, it also provides invaluable information on the financial position of the
Government.
It is generally accepted that cash-based accounting systems are not well suited to record
contingent liabilities, which are often treated as off-balance sheet items. The preferred
method is certainly the accrual-based accounting systems, which can capture contingent
liabilities as they are created. Within such systems, contingent liabilities are recorded at
face value and expected present value of contracts. The Governments of Canada and the
United States have formulated standards for accounting contingent liabilities.
None of the frameworks actually sets out the valuation methods for estimating the
contingent liabilities. Rather, greatest reliance is on the exposure method. This is to list
the maximum exposure or the maximum potential amount than can be lost from
51
contingent liabilities. Thus a guarantee covering the full amount of a loan outstanding
would be recorded at the full nominal value of the underlying loan. Such lists are given
by the UK, New Zealand and Australian regimes. The obvious limitation of the method
is that there is no information on the likelihood of the contingency occurring. Further
research is necessary to ascertain the valuation methodologies that underpin the
calculation of the contingent liabilities.
In most of the regimes surveyed, the reporting of the contingent liabilities is set out as
indicated in the following sections. Further work is required to ascertain at the country-
level how each contingent liability is identified, measured, recorded, monitored and
managed.
Table-A.1 summaries the existing systems for data recording and monitoring, legal and
institutional set up, policy framework and risk management in ten countries surveyed
here. It may be observed that as judged by transparency, accountability, legal set up,
policy framework and risk management Australia, Canada, Hungary, New Zealand and
the USA provides international best practices for monitoring and management of
contingent liabilities.
52
Table-A.1 Management of contingent liabilities - Country experiences
53
Table-A.1 Management of contingent liabilities - Country experiences: Continued
54
deals with contingent liabilities
55
Public Debt Office, which also Management Office
deals with contingent liabilities
56
(f) Does there exist independent (f) Yes (f) No
Public Debt Office, which also
deals with contingent liabilities
57
(f) Does there exist independent (f) Yes, UK Debt (f) Yes, President’s Office of
Public Debt Office, which also Management Office Management and Budget
deals with contingent liabilities
Annexure-C
With the introduction of the Federal Credit Reform Act of 1990 (effective since the fiscal
year of 1992), the US Federal Government replaced a parallel budgeting system for
contingent liabilities with new budgetary rules for direct and guaranteed loans. These
provisions are designed to neutralise budgetary incentives, making policy makers
indifferent to whether they choose grants, direct loans or guarantees. The primary
interest is to ensure that subsidy costs of grants, direct loans and guarantees are taken into
account in budgetary discussions.
The standards for accounting for liabilities, including contingent liabilities are set out in
the Statement of Federal Financial Accounting Standards, “Accounting for Liabilities of
the Federal Government (September 1995)” published by the President Office of
Management and Budget. These standards apply to general-purpose financial reports to
US Government reporting entities.
(a) Ensure a timely and accurate measure and presentation in the President’s budget
of the costs of direct loan and loan guarantee programmes;
(b) Place the cost of credit programmes on a budgetary basis equivalent to other
federal spending;
(c) Encourage the delivery of benefits in the form most appropriate to the needs of
beneficiaries, and
(d) Improve the allocation of resources among credit programmes and between credit
and other spending programmes.
• For each fiscal year in which the direct loans or the guarantees are to be obligated,
committed or disbursed, the President’s budget reflect the long-term cost to the
government of the subsidies associated with the loans and guarantees. The subsidy
cost is to be estimated as the present value of the projected cash outflows discounted
at the average rate of marketable Treasury securities of similar maturity.
• Before direct loans are obligated or loan guarantees are committed, annual
appropriations generally are enacted to cover these costs. However, mandatory
programmes have permanent indefinite appropriations.
• Borrowing authority from Treasury covers the non-subsidy portion of direct loans.
• There are budgetary and financing controls for each credit programme.
58
59
Contingencies
• Probable: The future confirming event or events are more likely than not to occur.
• Reasonably possible: The chance of the future confirming event or events occurring is
more than remote but less than probable.
• Remote: The chance of the future event or events occurring is slight.
A contingent liability should be recognised when all of these three conditions are met.
• A past event or exchange transactions has occurred (e.g. a federal entity has breached
a contract with a non-federal entity).
• A future outflow is probable (e.g. the non-federal entity has filed a legal claim against
a federal entity for breach of contract and the federal entity believes that the claim is
more likely to be settled in favour of the claimant).
• The future outflow or sacrifice of resources is measurable.
A contingent liability should be disclosed if any of the conditions for liability recognition
is not met and there is at least a reasonable possibility that a loss may have been incurred.
“Disclosure” is regarded as an integral part of the basic financial statements. Disclosure
should include the nature of the contingency and an estimate or a range of the possible
liability or a statement that such an estimate cannot be made.
In some cases, contingencies may be identified but the degree of uncertainty is so great
that no reporting is necessary in the federal financial reports. Specifically, contingencies
60
classified as remote need not be reported in general purpose federal financial reports,
though law may require such disclosures in special purpose reports.
Implementation
Conversion to the subsidy cost basis has entailed the maintenance of separate budgetary
accounts for the subsidised and unsubsidised portions of loans and guarantees.
Programme accounts receive appropriations for subsidy costs; financing accounts handle
the cash flows associated with the non-subsidised portion. Programme accounts are
included in the budget; financing accounts, however, are recorded as “means of
financing” and their cash flows are not included in budget receipts or outlays.
Future Legislation
The subsidy cost basis is currently used only for direct and guaranteed loans, not for other
contingent liabilities. However, legislation tabled in the United States Congress during
1999 shifts all US Government insurance programmes to this basis. The legislation
provides that beginning with fiscal year 2006, insurance commitments could be made
only to the extent that budget resources were appropriated to cover their “risk-assumed
cost”. This cost is defined as “the net present value of the estimated cash flows to and
from the Government resulting from an insurance commitment or modification thereof”.
As the volume of insurance commitments is many times greater than that of loan
guarantees, this legislation would have an enormous impact on the budgetary treatment of
contingent liabilities.
61
Annexure-D
Partial List of Persons Met during visit to Manila: 17 February to 2 March 2002
1. Mr. Lloyd McKay, Lead Economist, World Bank Office at Manila (WBOM).
2. Ms. Hazel Malapit, Consultant, World Bank Office at Manila.
3. Ms. Laura Pascua, Under-Secretary, Department of Budget and Management
(DBM) and the Chairperson of the counterpart team (PER Working Group)
established by the Government of Philippines;
4. Mr. Romeo de Vera, Consultant, DBM.
5. Ms. Estee Manglo, Division Chief, Planning, DBM.
6. Mr. Jo Abundo, Director, DBM.
7. Mr. Edgardo Jose L. Compos, Senior Strategy Adviser for Public Sector Reforms,
DBM and Adviser to AGILE.
8. Ms. Nieves Osorio, Undersecretary, Department of Finance (DOF), Government
of Philippines (GoPh).
9. Ms. Soledad Emilia J. Cruz, Director, Corporate Affairs Group, DOF, GoPh.
10. Ms. Dolly Celam, Corporate Affairs Group, DOF.
11. Ms Emelina Silao-Blanco, Corporate Affairs Group, DOF, GoPh
12. Mr. Richard S. Ondrik, Chief Country Officer, Philippines Country Office
(PhCO), ADB.
13. Ms. Xuelin Liu, Country Economist, PhCO, ADB
14. Mr. Romeo L. Bernardo, MD, Lazaro Bernardo Tiu & Associates Inc.
15. Ms. Marie Christine G. Tang, Senior Associate, Lazaro Bernardo Tiu &
Associates Inc.
16. Ms. Patricia K. Buckles, Mission Director, United States Agency for International
Development (USAID), Philippines.
17. Mr. Francis A. Donovan, Deputy Mission Director, USAID.
18. Mr. Joseph S. Ryan Jr., Chief, Economic Development and Governance, USAID.
19. Mr. Karoly K. Okolicsanyi, Financial Markets Development Adviser, USAID.
20. Mr. Tony Cintura, Deputy Director (Economic Research), Bangko Sentral ng
Pilipinas.
21. Mr. Guillermo Carague, Chairman, Commission on Audit.
22. Ms. Emma Espina, Assistant Commissioner, Commission on Audit.
23. Mr. Gilbert Llanto, Deputy Director General, National Economic & Development
Authority (NEDA).
24. Mr. Reynaldo P. Palmiery, Executive Vice President & COO, GSIS
25. Ms. Enrigueta P. Disuanco, Senior Vice President (Corporate Services), GSIS.
26. Ms. Maria Fe-Santos-Dayco, Vice President and Actuary, GSIS.
27. Ms. Corazon S. De La Paz, President and CEO, SSS.
28. Ms. Maribel D. Ortiz, Assistant Vice President (Research), SSS.
29. Ms. Virgina E. Gallarde, Assistant Vice President (Actuary), SSS
62