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For Release on Delivery
9:30 A.M. E.D.T.
May 21, 1992

Testimony by
Edward W. Kelley, Jr.
Member, Board of Governors of the
Federal Reserve System
before the
Committee on Banking, Finance and Urban Affairs
U.S. House of Representatives

May 21, 1992

I am pleased to appear today to comment on the Federal
Reserve's participation in the deliberations by the National
Advisory Council on International Monetary and Financial
Policies (NAC) of the FY 1990 Commodity Credit Corporation
(CCC) program for Iraq.
As you know, the NAC has been assigned by Congress the
responsibility to assist in formulating U.S. positions in
various international financial institutions and to evaluate
the policies and practices of U.S. government agencies that
make, or participate in making, foreign loans, or provide
various forms of credit guarantees as part of U.S. foreign
lending programs.

The Federal Reserve was designated a member

of the NAC under the Bretton Woods Agreements Act of 1945 and
has participated in its deliberations since.
The NAC is an advisory body.

The principal function

of the seven members of the NAC is to review proposed
transactions, programs, and policy issues related to those
institutions —

both national and multilateral in which the

United States is a member —

that are involved in making

foreign loans.
The diversity of interests, perspectives, and
expertise represented by the member agencies of the NAC allows
a thorough airing of divergent views on issues that come before
the NAC.

In most cases, a unanimity of views among NAC member

agencies is attained.

On those occasions when no consensus is

reached, it may indicate a fundamental difference on a
particular aspect of the lending program under consideration,

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often reflecting the particular vantage point and institutional
focus of the member agencies of the NAC.
In evaluating lending proposals and programs presented
to the NAC, the Federal Reserve draws upon its financial
perspective and expertise.

The Federal Reserve's principal

contributions to the NAC process over time have been its
ability to assess objectively the financial and economic
soundness of proposals brought before the NAC and to share this
expertise with other member agencies.
In light of this specialized focus of the Federal
Reserve in NAC deliberations, for those proposals that involve
major considerations other than economic and financial issues
where the Federal Reserve has special expertise (e.g., where
foreign policy or human rights issues are of overriding
importance), the practice of the Federal Reserve in NAC
deliberations is not to take a position on these matters and to
abstain in the formal NAC decisionmaking process.
With regard to the Federal Reserve's position
concerning the extension of CCC export credit sales guarantees
for Iraq, even prior to the FY 1990 request for such
guarantees, the Federal Reserve had become concerned about
Iraq's creditworthiness and about the size of the CCC export
credit sales guarantee programs that were being proposed for
Iraq by the U.S. Department of Agriculture.

The Federal

Reserve, therefore, was only willing to consider favorably
considerably scaled-down programs of such credit guarantees to
Iraq.

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In considering the request for $1 billion in
additional CCC export credit sales guarantees for Iraq for
FY 1990, Federal Reserve reservations were based on continued
concerns about Iraq's creditworthiness at that time.

The

growing external indebtedness of Iraq and questions about
Iraq's ability and willingness to service this debt led to a
growing Federal Reserve uneasiness in approving large, new CCC
export credit sales guarantees for Iraq.

The Federal Reserve

also noted Iraq's spotty debt-servicing record with other
bilateral official creditors, including incidents of unilateral
and selective reschedulings.

Finally, the Federal Reserve

questioned the appropriateness of allocating one-fifth of the
CCC's FY 1990 budget to one country, and of the CCC's having
such a disproportionate share of total CCC credits outstanding
to one country.
The unfolding Banca Nazionale del Lavoro (BNL) case in
the summer of 1989 reinforced the Federal Reserve's reserva­
tions and opposition about approving additional CCC export
credit sales guarantees for Iraq.

The revelations of the BNL

case, in fact, led the NAC to postpone a scheduled
consideration of the FY 1990 program of CCC export credit sales
guarantees for Iraq.

Only limited details concerning

allegations concerning the connection between the BNL case and
the CCC program to Iraq were known at the time that the NAC was
considering the proposal for additional export credit sales
guarantees to Iraq.

However, given the Federal Reserve's

ongoing and growing concern about Iraq's creditworthiness, even

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the limited allegations of linkages between the BNL case and
the CCC export credit sales guarantee program provided in our
view an additional reason to be cautious about further
extensions of such guarantees to Iraq.
The Federal Reserve's reservations and opposition
related to the FY 1990 CCC program for Iraq, therefore, were
based on its evaluation of Iraq's creditworthiness, which was
reinforced by the unfolding BNL case.