| 10/10/2006||Sweden||Agreement with proposal|
| 9/15/2006||United Kingdom||We agree with the AEG's recommendations and note in particular the recommendation that unpaid FISIM be "accumulated to principal outstanding in the same way as (SNA) interest accruing but unpaid." We note, however, that SNA 93 (para 11.101) provides two options for the designation of accrued interest: (1) inclusion of accrued interest in the outstanding amounts of|
loans and deposits or (2) inclusion of accrued interest in the other subcategory of Other accounts receivable/payable.
By contrast, the MFSM (Para. 227) states: Accrued interest on deposits, loans, and securities other than shares should be incorporated into the outstanding amount of the fmancial asset or liability, rather than being treated as part of other accounts receivable/payable. For unimpaired loans, the practical impact of the SNA's alternative treatments is unlikely to be large, but for non performing loans the second treatment would presumably imply a more substantial accumulation of accruals within other receivables and the loss of this component from the FISIM calculation. A clarification is therefore needed on whether SNA Revl will retain the SNA93 options on the designation of accruals or whether it adopts the later and stricter MFSM treatment.
| 9/15/2006||Latvia||After deep discussions and expert consultations we basically support the
1993 SNA Update Issues.|
| 7/28/2006||Lithuania||In general we support the recommendations.|
| 7/25/2006||Central Bank of Costa Rica||We find important to harmonize the treatment of debt arrears in all macroeconomic statistics manuals. We agree with the recommendations given by the AEG on this issue.|
| 11/30/2005||Slovak Republic||SO SR agree with AEG recommendations.|
| 11/29/2005||Tadjikistan||Мы поддерживаем подход СНС к учету задолженности на основе начислений, так как это не предполагает каких-либо условных оценок. Следует ввести справочные статьи для гармонизации подходов, применяемых в различных разделах макроэкономической статистики.|
| 6/30/2005||Slovak Republic||We fully agree with AEG recommendations.|
| 6/30/2005||Serbia and Montenegro||We agree with the recommendations made at the December 2004 meeting of the AEG.|
| 6/22/2005||Bank of Ghana||There are in general, three methods of recording – cash basis, accrual basis, and due-for-payment basis. Clearly, these have their respective strenghths and weaknesses depending on either the type of transaction or the gap between transaction date and payment date etc. The original SNA had been based on accrual accounting, and the AEG recommends that this provision is maintained. Indeed, accrual accounting has two main advantages – (a) its timing is in full agreement with the way economic activities and other flows are defined in the SNA, (b) accrual accounting can be applied to monetary as well as non-monetary flows. Just as recommended for non-performing loans, the position of the AEG is that no imputation of transactions be shown above the line, when a liability goes into arrears. Rather, memorandum items or sub-headings be used where appropriate to show changes in the characteristics of the original instrument etc. For example, if the original contract provided for a change in the characteristics of a financial instrument, when it goes into arrears, this change should be recorded as a reclassification in the other change in volume of assets account. If the contract is otherwise renegotiated, the consequences are to be recorded as new transactions and recorded appropriately. We generally agree with the AEG recommendations, but wish to emphasise that in the case of memorandum items, these have to be brought to the attention of external users so as to prevent misinterpretations of the accounts. Moreover, on the harmonization of the various macroeconomic statistics as regards time of recording and treatment of arrears, more consultation of stakeholders is needed in order to ensure that the 1993SNARev1 does not run into conflicts too soon.|
| 6/3/2005||Central Bank of Venezuela||We support the following Balance of Payments Technical Expert Group proposals: Harmonization of the time when booked and the treatment of arrears in all manuals -no transaction should be booked when the liability is extinguished; therefore, we reject the current treatment in the Balance of Payments; showing arrears as memoranda items; and each contry should state the data that it deems relevant. |
When the instrument is unchanged, we support the proposal to continue showing the liability in the same instrument, until the liability is extinguished, but showing arrears as memoranda items. However we believe that the criteria set forth in paragraph 11.101 of the SNA93 should be considered.
Based on the analysis performed, we found that greater precision is required when reference is made to changes in the terms and conditions of the instrument, since there are differences if these changes are generated by mutual agreement or by application of the clauses set forth in the instrument. If by mutual agreement, a new transaction should be recorded, while if by application of clauses set forth in the instrument, this could be a reclassification of the instrument (change in volume).
| 5/19/2005||Bank of Indonesia||BI supports to include the issue of debt arrears in the paper on non performing loans since they relate each other. In the case of Indonesia, debt arrears are separated into (1) nominal value which is the outstanding loan recorded in the on-accounts, and (2) interest value which is the unpaid interest recorded in off-accounts. Hence, it is agreed that there is no impact on the macroeconomic statistics when a liability goes into debt arrears.|
| 5/19/2005||Swiss National Bank||We agree to the proposal that in case of arrears, no transaction should be imputed. If the terms and characteristics of a financial instrument change the finacial instrument should be reclassified.|
| 5/18/2005||Bank of Russia||We agree with the AEG recommendation that the time of recording and treatment of arrears should be harmonized in the various macroeconomic statistics. We consider that no transaction should be imputed when liabilities go into arrears and that the arrears should continue to be shown in the same instrument and reclassification and other changes in volumes rather than transaction are appropriate when the changes of terms and characteristics of financial instrument occur.|
We consider that data on arrears should be shown as memorandum items.
We agree with the opinion of the BOPTEG that the treatment of arrears in the Balance of Payments should be changed because the reflection of the arrears as a transaction makes difficulties for users to analyze real economical processes.
The approach of the mandatory presentation of the full information concerning arrears in the IIP will allow completeness of data on arrears sufficiently. The present materials don’t clarify whether the arrears of liabilities should be reflected in the IIP. This issue needs further explanation.
We suggest that issues on application of accrual principles to debt arrears and on nonperforming loans should be considered simultaneously.
| 5/18/2005||Central Bank of Chile||We accept the BOPTEG recommendation that no transactions should be imputed when a liability goes into arrears. According to this recommendation, the recording is upon accrual rather than on the payment date. Payments made (amortization), renegotiation, and write-offs would be recorded in the financial accounts. |
Given that interest is also recorded upon accrual and payment arrears are reflected in an increase of the original instrument, we would also agree to the posting of a memorandum item apart from the principal arrears.
| 5/16/2005||Croatian National Bank||We agree in principle with the AEG recommendations provided that the full harmonization of the SNA and FSI Guide treatment with the BPM5, ED Guide and GFS01 statistics has been achieved. |
| 5/16/2005||Jordan||Dos is in favor of not introducing any imputed transaction when arrears occur. Instead, the arrears can be shown in the original instrument. When a liability goes into arrears and there is a change in the financial instrument this change should be treated as other volume change. In any case the important issue is that recording and treatment of arrears should be harmonized in the various macro-economic statistics.|
| 5/16/2005||Eastern Caribbean Central Bank||We support the need to harmonize the time of recording and the treatment of arrears in the various macroeconomic statistics.|
| 5/13/2005||Central Bank of Hungary||We agree with the AEG recommendations.|
| 5/13/2005||National Bank of Kazakhstan||Time of recording and treatment of arrears should be harmonized in the various macroeconomic statistics. When liability is not paid in time no imputation takes place, arrears should be shown as memorandum item. In our opinion, it is necessary to give the examples of arrears reclassification. |
| 5/12/2005||European Central Bank||The ECB welcomes the decisions taken regarding debt arrears, and notably the approach to harmonise the recording of arrears in the various macroeconomic statistics.|
| 5/12/2005||Bank of Thailand||We think that arrears should be treated in the same way across all macroeconomic accounts. Recording should be made at the time the liability is extinguished. In the case where there is any change in the payment terms / alteration to the original contract, it should be treated as though the original contract is terminated and replaced by the new contract (i.e., record as new transaction rather than other changes).|
| 5/11/2005||India||India agrees with the decisions of AEG.|
| 5/10/2005||USA||The U.S. Bureau of Economic Analysis does not support the continued accrual of interest for debt that is substantially in arrears (for example, more than 90 days overdue). The continued accrual of interest can present a misleading picture of the financial position of the lender.|
| 5/10/2005||National Bank of Moldova||With respect to this issue we agree with the recommendation to record arrears in the original instrument applying the accrual principle. |
The recommended treatment for cases when the original contract provides a change in the characteristics of a financial instrument or when the contract is renegotiated is entirely consistent with the Balance of payments treatment.
| 5/9/2005||Australia||Australia agrees with the AEG recommendations|
| 5/9/2005||Maldives||The issue is closely linked with the treatment of non-performing loans or credit payable, where the borrower is in arrears. When the payment of the loan or credit payable is due, the question is how to record this if the borrower has not paid during the due date. The different options that could be considered are the following: a) impute the payment of the liability and change the liability to short term loan, b) retain the liability as is and change the liability based on the contract or the renegotiation of the contract. This would however depend much on how the bank or creditor institutions treat the transaction. We wish to agree with the recommendations of the AEG but emphasise that the treatment should be harmonized with other statistics and should be consistent with the treatment of financial and other institutions. |
| 5/9/2005||United Kingdom||We agree with the recommendation that the time of recording and treatment of arrears should be harmonized in the various macro-economic statistics; No transactions should be imputed when a liability goes into arrears (i.e., the debt continues to be recorded in the original instrument); If the original contract provided for a change in the characteristics of a financial instrument when it goes into arrears, this change should be recorded as a reclassification in the other change in volume of assets account and that, if the contract is renegotiated, the consequences are to be recorded as new transactions. |
| 5/9/2005||Central Bank of Iran||We support the principle that the time of recording and treatment of arrears should be harmonized in the various macroeconomic statistics.|
| 5/9/2005||Italy||We agree with the recommendations of the AEG but the decision depends also on the contribution of other institutions like the Bank of Italy.|
| 5/6/2005||Turkey||We agree with the recommendations made by the Advisory Expert Group on National Accounts at its second meeting in December 2004.|
| 5/6/2005||Commonwealth of Independent States ||We support the SNA approach to record debt arrears on accrual basis because it involves no imputations. Memorandum items should be introduced to harmonize approaches in various macro-economic statistics.|
| 5/6/2005||Macao, SAR China||We agree with the recommendations.|
| 5/4/2005||Denmark||Statistics Denmark agrees.|
| 4/29/2005||Central Bank of Colombia||i.) Time of recording and treatment of arrears should be harmonized in the various macroeconomic statistics.|
El Banco de la República de Colombia está de acuerdo con este punto ya que la armonización del tratamiento estadístico es muy importante para mejorar la coherencia en los principales indicadores macroeconómicos de los países.
ii.) No transactions should be imputed when a liability goes into arrears (i.e., the debt continues to be recorded in the original instrument).
El Banco de la República de Colombia considera que la metodología recomendada para los atrasos de deuda es apropiada dado que:
- En primer lugar, armoniza el tratamiento metodológico en balanza de pagos y en cuentas nacionales.
- En segundo lugar, evita confusiones en la interpretación de los datos ya que los atrasos se estaban registrando de manera similar a nuevas financiaciones de corto plazo.
- Las recomendaciones sugeridas implican una revisión de lo establecido en el Manual de Quinto de Balanza de Pagos (1993) y la guía para compiladores y usuarios de la deuda externa (2003).
iii.) If the original contract provided for a change in the characteristics of a financial instrument when it goes into arrears, this change should be recorded as a reclassification in the other change in volume of assets account.
El Banco de la República de Colombia considera que la reclasificación del pasivo ante un cambio en las características del instrumento financiero en el momento del atraso es apropiada ya que permite distinguir estos eventos del resto de los atrasos.
iv.) If the contract is renegotiated, the consequences are to be recorded as new transactions.
El Banco de la República de Colombia considera que las nuevas transacciones que se registran en el evento de una renegociación de la deuda son convenientes ya que representan un hecho económico relevante para el seguimiento estadístico de la deuda externa.
v.) It was suggested that consideration of these issues should be included in the paper concerning non-performing loans which the IMF has agreed to prepare.
El Banco de la República de Colombia está de acuerdo con que estos cambios metodológicos se resuman y justifiquen en documentos formales.
| 4/29/2005||Norway||Statistics Norway supports the views of the AEG.|
| 4/28/2005||Trinidad and Tobago||We agree with the recommendations of the AEG.|
| 4/25/2005||Bank of Sierra Leone||With reference to the above subject we agree with the recommendations of the Expert Group on National Accounts (AEG) especially where there is harmonization of definitions and other concepts between the Balance of Payments (BOP) and system of National Accounts (SNA).|
| 4/14/2005||Bank of France||Nous approuvons l’enregistrement des arriérés de dette sur la base des droits constatés et leur maintien sous l’instrument d’origine. Dans ce contexte, il semble souhaitable de continuer à comptabiliser les intérêts dans les mêmes conditions que pour les prêts sains. Il convient de rappeler à cet égard que la réglementation bancaire française prévoit que les intérêts sur créances douteuses sont enregistrés dans les mêmes conditions que les intérêts sur prêts sains. Par ailleurs, les intérêts impayés ne peuvent eux-mêmes porter intérêt. |
| 4/13/2005||Bank of Korea|| We agree with the AEG`s recommendation that the time of recording and treatment of arrears should be harmonized in the various macroeconomic statistics.
We think that the treatment of loans should be considered with the application of accrual principle of debt arrears because, by using memorandum items, the accrual basis accounting can record economic transactions most properly without the disturbing influence of leads and lags in cash flows.
| 4/12/2005||Greece||We agree with the recommendations of the AEG on the issues for which a decision has been taken, at the December 2004 meeting of the group.|
| 4/12/2005||Central Bank of Honduras||Debe darse atención a las recomendaciones de los especialistas en Balanza de Pagos. En el SCN 93, las recomendaciones no son precisas en relación al tratamiento de los atrasos si los términos y características de los instrumentos financieros se modifican. Generalmente, los préstamos se clasifican como improductivos cuando los pagos pactados muestran un atraso superior a un lapso predeterminado. En ese sentido, todos los préstamos improductivos ocultan atrasos. Al respecto en el V Manual de Balanza de Pagos, estos préstamos no incluyen atrasos porque se instituye un pasivo nuevo cuando los mismos se dan. |
| 4/11/2005||Central Bank of Kuwait||Kuwait agreed that:|
(a) Time of recording and treatment of arrears should be harmonized in the various macro-economic statistics.
(b) No transactions should be imputed when a liability goes into arrears (i.e. the debt continues to be recorded in the original instrument).
(c) If the original contract provided for a change in characteristics of a financial instrument when it goes into arrears this change should be recorded as a reclassification in the other change in volume of assets account.
(d) If the contract is renegotiated, the consequences are to be recorded as new transactions.
| 4/11/2005||Bank of Tanzania/National Bureau of Statistics||We support the decision that time of recording and treatment of arrears should be harmonized in the various macro-economic statistics and we will appreciate to get a copy of the paper concerning non-performing loans to be prepared by IMF so that we can continue to learn more about debt arrears issues.|
| 4/11/2005||Hong Kong, China||We support the AEG recommendation that the time of recording and treatment of arrears should be harmonized in various macroeconomic statistics. We also concur with the suggestion on the treatment of debt arrears.|
| 4/11/2005||Germany|| m2(c)de38c; |
| 4/11/2005||Malawi||I fully endorse the recommendations of the Expert Group on National Accounts.|
| 4/11/2005||Central Bank of The Netherlands||With respect to these issues we agree with the decisions taken by the AEG. They correspond fully with the proposals made by BOPTEG and BOPCOM. |
| 4/11/2005||Philippines ||We agree in principle with GFS/IMF/BPM recommendations. However, we cannot fully adopt the recommendations considering that our sources of data such as the Bureau of Treasury still follows modified accrual system of accounting for the payment of debts
| 4/11/2005||Central Bank of the Republic of Turkey||Central Bank of the Republic of Turkey (CBRT) supports that the time of recording and treatment of arrears be harmonized in various macroeconomic statistics and reclassification/other changes rather than transactions is appropriate if the terms and characteristics of financial instruments change when a liability goes into arrears. |
| 4/11/2005||Russian Federation||We agree with the recommendations made by the AEG on National Accounts.|
| 4/11/2005||South African Reserve Bank||We accept the recommendations of the AEG.|
| 4/11/2005||South Africa||South Africa agrees with the recommendations.|
| 4/11/2005||The Netherlands||We agree with the recommendations made at the December 2004 meeting of the Advisory Expert Group on National Accounts.|
| 3/18/2005||Palestinian Central Bureau of Statistics||PCBS supports the decision which consider that the time of recording and treatment of arrears should be harmonized in the various macroeconomic statistics, and continuing of considering debt arrears as the same instrument over its working life.|