| 27/11/2006||Australia||We agree with the recommendations made by AEG at its Jan-Feb 2006 meeting.|
| 11/10/2006||Armenia||The National Statistical Service of the Republic of Armenia agrees with the most recent AEG recommendations.|
| 10/10/2006||Sweden||Agreement with proposal|
| 29/09/2006||Bank of Korea||We broadly support the recommendations. |
| 15/09/2006||United Kingdom||We can accept the three sets of recommendations made by the AEG. On standardised guarantees one of our earlier concerns about being able to see the information separately is now resolved in the proposed financial assets classification. On one-off guarantees the proposal deals with most aspects of the issue but leaves one unresolved. The proposal is that the guarantees should mainly be accounted for outside the system unless they are called. However, there are transactions inside the system which are affected by the existence of the guarantee - for example borrowers benefit from paying a lower rate of interest. If no fee has been paid this represents a subsidy which is not covered by the proposal.|
We also note that the recommendation to identify guarantees in the form of derivatives has implications for the SNA instrument classification which are not currently addressed under item 44 below.
| 15/09/2006||Latvia||After deep discussions and expert consultations we basically support the
1993 SNA Update Issues.|
| 18/08/2006||Netherlands||We generally support the recommendations made at the Frankfurt Meeting of the AEG. |
| 18/08/2006||Bank of England||See comments issue 44. The meeting report says: “(b) Guarantees that meet the definition of financial derivatives should be treated as financial derivatives. This should be clarified within the updated SNA by also specifying such types of guarantees as a sub-category of financial derivatives.” This is not reflected in the proposed subclassification of financial derivatives.|
| 18/08/2006||USA||We agree with the recommendations of the AEG.|
| 02/08/2006||European Central Bank||The ECB generally supports the recommendations made by the AEG.|
| 01/08/2006||National Bank/ National Bureau for Statistics Moldova||We support the recommendation that the guarantees that meet the definition of financial derivatives should be treated as financial derivatives. This outcome will generate a consistency between the SNA and the BPM5.|
| 01/08/2006||Reserve Bank of South Africa||We carefully worked through all the issues and would like to give our general support to the recommendations made by the AEG.|
| 31/07/2006||Macao SAR||Statistics and Census Service of Macao SAR agrees to the AEG recommendations and has no further comments.|
| 31/07/2006||Bosnia and Herzegovina||We agree with AEG recommendations on the update of the 1993 SNA and do not have any further comments.|
| 28/07/2006||Vietnam||We agree with a draft of Government dividends and capital transactions with public corporations and Granting and activation of guarantees in update SNA.|
| 28/07/2006||National Bank of Slovakia||Concerning the results of the most recent AEG meeting, we fully support the conclusions and recommendations made by the AEG.|
| 28/07/2006||Lithuania||In general we support the recommendations.|
| 28/07/2006||Bank of Portugal||We are of the same opinion of the AEG in respect of the proposed treatment of guarantees to distinguish between guarantees [covered by] financial derivatives; standardised guarantees; and one-off guarantees.|
We agree that guarantees that meet the definition of financial derivatives should be treated as financial derivatives.
We are in agreement with the proposed treatment of standardised guarantees as insurance. In fact, these guarantees are a form of protection against the risk of default.
We agree that one-off guarantees should be recorded outside the core accounts. These guarantees are considered as contingent liabilities of the guarantor and should only be recorded in the system if they are called.
| 28/07/2006||Bank of Poland||Please find our general support for the AEG recommendations made during its recent meeting in Frankfurt.|
| 27/07/2006||Bank of Sierra Leone||We agree with the recommendations made by the AEG.|
| 25/07/2006||Bank of Italy||We broadly support the conclusions.|
| 24/07/2006||Germany||The conceptual recommendations adopted by the AEG seem very interesting. At the same time we do see implementation problems. Therefore we would like to reserve our position for the time being. |
| 24/07/2006||National Bank of the Republic of Azerbaijan||We have analyzed the “Comment on the recommendations of the most recent Advisory Expert Group on National Accounts (AEG) meeting (January 30 – February 8, 2006) in Frankfurt” within the scope of our responsibilities and I am pleased to inform you that we are in agreement with the AEG recommendations. |
| 23/02/2006||South African Reserve Bank ||We would like to remain neutral on this issue.|
| 27/01/2006||Central Bank of El Salvador||Estamos de acuerdo en considerar el tratamiento de deuda del Manual de Finanzas Públicas para homogenizar.|
| 22/12/2005||Serbia and Montenegro||We agree with the suggested changes.|
| 14/12/2005||France||Les garanties ne constituent pas une dette de l'unité qui les accorde tant qu'elles n'ont pas été formellement appelées. L'INSEE attend la version définitive du texte pour se prononcer sur le point de savoir si des traitements plus élabores doivent être mis en oeuvre dans le cas de garanties « standards » faisant éventuellement l'objet d'échanges sur des marches.|
| 13/12/2005||Canada||Canada agrees that further clarification of insurance parallel and the exact nature of the imputed transfer need further work.|
| 12/12/2005||Bank of Korea||We are in agreement with the recommendation of Advisory Export Group(AEG). |
We agree with the retention of the current treatment of guarantees (that a guarantee is a contingency until it is activated). We assent to AEG's recommendation that all flows arising from the activation of guarantees be treated as other changes in volume of assets.
| 09/12/2005||European Central Bank||On item 37, guarantees, various issues have to be clarified – especially the treatment of standardised and one-off loans. The recommendations imply that all institutional units have to record standardised guarantees if applicable. This might raise significant measurement issues – especially for monetary financial intermediaries.|
| 09/12/2005||Russia||Rosstat largely supports the recommendations on the updating 1993 SNA, made at the July 2005 meeting of the Advisory Expert Group on National Accounts.|
| 02/12/2005||Netherlands||In relation to the recording of guarantees, we do agree with recommendation (b), that is to treat tradable or offsettable guarantees as financial derivatives. In the case of recommendation (c) and related recommendations on the recording of standardised guarantees, however, we have a slight preference for a recording outside the core system (recording as a memorandum item), for the following reasons:|
• In our opinion, the contingent character of standardised guarantees is very similar to provisions, and the relevant guarantees should preferably be treated as such, i.e. outside the core system.
• From a conceptual point of view, there hardly is a difference between stan-dardised guarantees and one-off guarantees. In our opinion, the difference is so minor that it does not justify a difference in treatment.
• We do feel somewhat uncomfortable about the “double-counting” of assets, i.e. the recording of a guarantee, in addition to the original underlying assets.
• Finally, we have a more or less practical argument: the implementation of the suggested recording of standardised guarantees is quite complicated and does imply quite a number of imputations.
| 02/12/2005||Australia||Australia agrees with the in-principle recommendations, and supports the decision to prepare a revised paper to clarify the issues of concern, for e-discussion. However, we are concerned that the technical reserves as defined in (d) would be extremely difficult to identify and collect.|
| 02/12/2005||Turkey||We agree with the recommendations made at the July 2005 meeting of the Advisory Expert Group on National Accounts.|
| 01/12/2005||Germany||We are pleased to express our agreement with the proposal for a continued discussion.|
| 01/12/2005||Israel||We agree with all the recommendations proposed on this issue. We would like to add that granting of guarantees by government almost always involves a benefit to the agent receiving the guarantee – as said in the issues paper “Some borrowers would have no access to loans in the absence of guarantees, while others would benefit from comparatively low interest rates”. Granting a guarantee may be an easier way for government to distribute benefits than through granting of subsidies or capital transfers. Even if it is considered to be too complicated to have estimates of the amount of benefits in the accounts, at least the fact that guarantees involve transfers of benefits to one of the sectors in the economy, should be explained in the SNA, and methods of estimating the size of such benefits could be suggested. |
| 01/12/2005||National Bank of Moldova||We agree with the treatment of guarantee and its activation suggested in international statistical guidelines: a guarantee should be considered contingent until it is activated. When the guarantee is activated for the whole debt liability the old liability should be eliminated from the balance sheets of the original creditor and the original debtor, and a new liability should be recorded in the balance sheet of the original creditor and the guarantor. Flows arising from activation of guarantee should be recorded as “other changes” when the original debtor and guarantor are from different sectors. The actual payments between the creditor and guarantor are financial transactions. |
The treatment of invocation of a loan guarantee should be supplemented with treatment of the case when the guarantee is activated only for one payment, which means that next payments will be made by original debtor.
| 01/12/2005||United Kingdom||We agree with the decisions with the exceptions and qualifications noted below. We think the typology proposed in recommendation (a) is valuable and helpful.|
• while accepting recommendations (c) and (d) relating to standardised guarantees, UK experts expressed some concerns about the detailed recording. and maintaining consistency across the manual. Treating this category of guarantee as being equivalent to insurance is acceptable. However we emphasise the need to show guarantees separately from insurance to reflect the different nature of the concepts, as mentioned in recommendation (d). We are pleased to see the request from the AEG for extra work on these issues, and may want to comment further when we have seen it.
• similarly while accepting recommendation (f) we feel that more detail is needed to fully understand the planned recording through the accounts.
• we are uneasy about recommendation (g). The proposed recording may not make analysis of the impact of the guarantees easy for users to see. However, recording outside the core accounts is possibly a good pragmatic conclusion for this revision, but there is still the problem that one off guarantees affect transactions inside the core accounts. For example when there is a guarantee in place the interest rate paid on borrowing will usually be lower. We note that the accountants are working on new standards for the reporting of guarantees but this work will probably be too late for use in the SNA revision.
| 30/11/2005||Slovak Republic||SO SR give support to AEG recommendation related to ongoing effort for clarification of issue.|
| 30/11/2005||Croatian National Bank||Croatian National Bank agree with the AEG recommendations. |
| 30/11/2005||Italy||Istat fully agrees with the recommendations made at the July 2005 meeting of the Advisory Expert Group on National Accounts.
| 30/11/2005||State Bank of Pakistan||We have gone through recommendations made by Advisory Expert Group (AEG) and fully agree with them.
| 29/11/2005||People's Bank of China||I agree with your improvements and have no other suggestions.|
| 21/11/2005||USA||We agree with the decision to accept the recommendations in principle, though clarification is needed for some of the details.|
| 19/05/2005||Bank of Indonesia||Since Indonesia has already applied that activation of guarantees as an on-accounts, BI suggests that guarantees will affect on the macroeconomic statistics.|
| 12/05/2005||Bank of Thailand||We agree with the treatment of guarantees as suggested in the existing international guidelines, i.e., guarantees remain a contingency until they are activated. Once activated, the old liabilities between the original creditor and the original debtor are eliminated from the balance sheets, and new liabilities between the original creditor and the guarantor are recorded in the balance sheets. |
Flows arising from activation of guarantees should be recorded as "other changes" in the volume of assets accounts.
| 09/05/2005||Australia||No AEG decision made. However, it is noted that the AEG "agreed that if a guarantee were to remain a contingent liability off the balance sheet, flows arising from its activation would be recorded as a capital transfer rather than being recorded in the other changes in volume of assets accounts as proposed". BOPTEG recommended that all flows arising from the activation of guarantees should be recorded in the Other Changes in Volume of Assets Account as opposed to recording the flows as transactions (see BOPTEG Outcome Paper #2: Activation of Guarantees). The ABS supports BOPTEG's recommendation.|
| 11/04/2005||Philippines||How do we treat loans guaranteed by the government which are later transferred as liabilities of the Government? These loans are later sold/exchanged for stocks or other types of financial investments.|