IDB-9: Financial and Risk Management
This paper analyzes whether the Inter-American Development Bank (IDB, or Bank) has fully and effectively implemented the IDB-9 requirements related to risk and financial management. IDB-9 included four requirements in this area: (i) adopt a rule-based Income Management Model (IMM); (ii) implement the recently introduced risk-based Capital Adequacy Policy; (iii) execute a set of agreed actions to enhance the short-term sustainability of the Fund for Special Operations (FSO); and (iv) continue strengthening the Banks Risk Management Framework. The Bank has fully implemented the IDB-9 financial and risk management actions. The highly detailed and prescriptive nature of the requirements aided implementation. In terms of effectiveness, the IMM imposes financial discipline and enhances financial selfsustainability by linking Bank expenses directly to income through loan charges. The CAP supports prudent risk management and the Banks AAA rating. The actions taken for the FSO will not be sufficient to ensure the Funds sustainability until 2020, as mandated in IDB-9, and Management is preparing to propose additional measures for the Board¿s approval. A few issues with the IMM and CAP merit further review going forward. First, the IMM is very strict, with a high administrative expense coverage rule and its inclusion of nonoperational expenses. Second, it is not clear that the reserve ratios for sovereignguaranteed (SG) and non-sovereign-guaranteed (NSG) exposure adequately reflect their relative levels of risk or lead to the most effective leveraging of scarce Bank capital. Third, the Bank¿s unused borrowing capacity rule¿though perhaps reassuring to potential investors¿is outdated and is not relevant to the maintenance of the Bank¿s AAA rating, while a criterion that rating agencies do consider relevant¿country portfolio concentration¿is not factored into the Bank¿s rules. Finally, the IDB-9 architecture is inward-looking and does not promote a focus on the Bank¿s financial competitiveness. In light of these findings, OVE suggests that the Bank (i) consider introducing greater flexibility in the IMM by setting an administrative coverage band and perhaps excluding certain nonoperational expenses; (ii) review the capital accumulation rule and the reserve ratios for SG and NSG exposures; (iii) update the Bank¿s financial rules by phasing out the borrowing authority limit; and (iv) use the financial and risk management architecture as input to strategic decision-making on the projected size of the Bank, the blend of SG and NSG lending, expected countercyclical support, the role of the FSO, and the Bank¿s approach to future capitalization.