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INTERNATIONAL LOANS;

THE NEW INTERAGENCY

EXAMINATION TREATMENT

Remarks
Jo h n
Federal

of

J. B a l l e s , P r e s i d e n t

Re s e r v e

Bank

Meeting
Ba n k e r s ' Association

Coronado,
April

of

San

Fr a n c i s c o

with
for

Fo r e i g n

California
9,

1984

Tr a d e

1

-

-

INTERNATIONAL LOANS:

THE NEW INTERAGENCY

EXAMINATION TREATMENT

LDC D e b t P r o b l e m

As

y o u k no w,

Recovery

and F i n a n c i a l

provisions
I would
the

relating

like

to

Some
Each

which,

straits

in 1982,

developed
erupted,
these

additional

"b i g -b a n k

persuade




U.S.

was

of

the

lending,

implications

history

of

the

Ac t

painfully

so,

of

the a l a r m

over M e xico's

with

examination

debt

of

," a n d
it

the

of

treatment

the

International

the

Fu n d ,

took

a

in

the

great

"LDC

of

U.S.

in the

banks

debt

have

of

by l e s s

to

of

first
kept

U.S.

banks

in

the de ba te

Monetary

members

Un i t e d

financial

"crisis"

during

deal

,

debt

Concerns

role

reluctant

So m e

useful

the

the

LDC

pronounced

quite

was

of

over

was

it

to

when

renegotiations

first

that

owed

voiced

particularly

at

is

a l o t of p r e s s .

Controversy

support

Co n g r e s s

international

the

to b o l s t e r

bailout

some

contained

the

were wide ly

alive,

Co n g r e s s

of

which

concern

received

subsequent

to L D C s

oh

1983,

International

they

o v e r t h e a m o u n t of

over p r o p o s a l s
The

has

countries
and

today

perhaps

starting

concerns

lending

on

is a w a r e ,

States

supervision

the

,

loans

crisis"

United

as

year passed

S t a b i l i t y A c t of

concentrate

background

of us

last

to t h e

Ac t , e s p e c i a l l y

international

a

Congress

Fund,

approve
argued
effort

St a t e s ' best

it
to

was

INTERESTS

TO A P P R O V E

LEGISLATION
FEDERAL

THAT

BANK

OF

AS

WERE

REGULATORS

FINALLY

REGULATORS

SUPERVISION
IT WERE,

THE

ADDITIONAL
PASSED,
TO

TAK E

INTERNATIONAL
CLOSE

EARLIER

TH E

CERTAIN

THE

FOCUSED

ON F O U R

POINTS,

FEDERAL

BANKING

REGULATORS CONSULT

COUNTERPARTS
DIRECTLY

ON W H A T

THEREFORE
DESIGNED

ABOUT

OTHER

TO S T R E N G T H E N

Re q u i r e m e n t s

of

of

these

FOR A S S E T S

EXPOSURE

PROCEDURES

I SHOULD
AN D

TRANSFER

PAST ,
BUT

SOME

IT




IS T H A T

TO C O U N T R Y

TO S T R E N G T H E N

TH E

"MARCHING

RESERVE

THE

THE

ESSENTIALLY

NOT

I WILL

THE

AND O T H ER

THAT

THE

FOREIGN

.. D O E S

TODAY,
OF

AND

O R D E R S ,"

REQUIREMENT

THEIR

ADEQUACY

IMPROVE

NOTE
RISK

a

Ad,

SYSTEM

requirement

VALUE
THE

RISK

BEAR

CONCENTRATE

WHICH

ARE

U.S.

OF

BANKING
MORE

THE

PARENTHETICALLY

USUAL

HAVE

MADE

PRACTICE

special

BECAUSE

AGENCIES

CLOSELY

AND

THAT

reserves

OF R I S K .

SHOULD

be

A

MONITOR

ESTABLISH

OR T R A N S F E R

ADEQUACY

INTERCHANGEABLY

that

IS I M P A I R E D

THAT COUNT RY

IN E V A L U A T I N G

WRITERS

IS THE

is

WHOSE

FOR A S S U R I N G

INTO A C C O U N T

AND

—

WITH

REQUIREMENTS

THE

Ac t

SECOND R E Q U IREMENT
BANK

CAPITAL

DIRECTED

CONGRESS

OF T H E S E

In THE

LENDING.

first

SE T A S I D E

TO

I W A N T TO D I S C U S S

ON T H E

INTERNATIONAL

The

BANK

THESE

IMF,

THE

ALSO

STEPS

FEDERAL

HAD R E C O M M E N D E D

FOR

CONGRESS

LENDING,

TO W H A T

ONE

SUPPORT

RISK

ARE

TAKEN

OF A B A N K 's C A P I T A L .
I WILL

THROUGHOUT

USE

MY T A L K.

DISTINCTIONS

BETWEEN

NOW

THE

TO T R E A T

COUNTRY

RISK

In THE

THE T W O T E R M S

T W O AS E S S E N T I A L L Y

-

THE

S A ME,

RISK

AMD

I SHALL

I AM T A L K I N G

FOLLOW

ABOUT

COUNTRY

W I L L BE U N A B L E

SERVICE

AND RE P AY

I WILL
MINUTE,

BUT

FIRST

R E Q U I R E M E N T OF

RECEIVED

IN C O N N E C T I O N

LOAMS
THE

ASSOCIATED

ORIGINAL

CONSIDERATION
IN T H E

LOAN

OF

FINAL

ASSOCIATED

RESTRUCTURED
EXPENSES,

FEES

OVER

THE

PUT

IN A

A THIRD

WITH

ARRANGING

THE

OUT

ESPECIALLY

FOR C O M M E N T

CALLED

LENDING,

HOWEVER,

THUS

ONLY

MOST

RECOVERY

THE

INCOME
FOR

SYNDICATION.
AS R E C E I V E D ,

LOAN.

OF

TO THE

THE

CAREFUL

IT W A S D E C I D E D
FEE

FEE

INCOME

INCOME

ON

OUT-OF-POCKET
AND WI L L

HAVE

FEES,

TO T H E E X T E N T

RENDERED

COMMITMENT
PRIOR

WHEN

FOR

AFTER

SYNDICATION

AS R E C E I V E D

SERVICES

FELT

ON R E S T R U C T U R E D

AN A D J U S T M E N T TO Y I E L D
OF

FEES

As Y O U W I L L R E C A L L ,

TO A M O R T I Z E

ABOVE

T HE

CONGRESS

FEES

EARNINGS,

RECEIVED,

LI F E

REMUNERATION




TO

THE A C T

HANDLING

LOAN

ONE,

LOANS,

AND

REPRESENT

LOAN ,

TERM

ISSUED

INTO

FOR

INTERNATIONAL

BE C O N S I D E R E D

INCOME

OF

OF C R E D I T .

OVERSTATED

RE STRUCTURED
OVER

METHODS

INCLUDING

COMMENTS

C A N BE T A K E N

INTO

OF

ON A L L

THEY

TAKEN

IN A G I V E N

EXCHANGE

BIT A B O U T

EXTENSIONS

PROPOSALS

LOANS,

WILL

FOREIGN

REQUIREMENTS

A LITTLE

WAS A LO N G

REGULATIONS

TO BE A M O R T I Z E D
HOWEVER,

WITH

INCOME

OF THE

WITH

TWO

SAY

BANKS

IN

REGULATORY

AMORTIZATION

FIRST

ACCOUNTING

SOME

IMMEDIATELY

ENOUGH

BORROWERS

THE

Ac T , W H I C H D I R E C T S F E D E R A L B A N K R E G U L A T O R S TO

THE

OF

THAT

BASICALLY,

LOANS,

L E T ME

ALTERNATIVE

PRACTICE

CONVENTION,

RISK

TO O B T A I N

THE

CONSIDER

THE

-

THAT

IS T H E

THEIR

DISCUSS

3

THAT

IN C O N N E C T I O N

FEES ALSO

M A Y BE

DISBURSEMENT

OF

THE

-Z|-

In ter a g e n c y ,Coy n i r y E x p o s u r e R i s k C o m m i t t e e
In d i s c u s s i n g
INVOLVE
REVIEW

I S S U E S OF
WHAT

REGULATORS

the

have

been

equal

HAVE

The

Office

of

Committee,

C o m m i t t e e 's m e e t i n g

debt

ratios

-servicing
hold

to

their

experience
among
risk

the
will

several

in

members
be

field

impaired

the

of

FEDERAL

was

three

THE

just

aspects

times

Reserve,

BANKING

The

organizations

lending,

other

TO

established,

banking

as

to

they

of t h e i r

a year,

has

FDIC, a n d t h e

the

presented

briefings
a

be

foreign
is

is

first

their

to

IS U S E F U L

IN 1979,

AREA,

summaries

in

Ac t , w h i c h

the

Currency,

give

and

for

taken

, a

at

set

the

of

impression
of

D istrict
of

their

,

After

on

a

country

purposes

.

and

countries
which

Reg i o n

or

lending
how

of

interviews

informed

examination

financial

in

'

field
order

current

discussion

's t r a n s f e r

There

are

,

transfer

," o r

or

, and

, a vote

alternatives




Federal

bankers

assessed

F i r s t , the
"v a l u e

the

to

opinions

the

OTHER

foreign

meets

of

IT

Committee

which

--- e c o n o m i c

intended

with

Risk

information

abilities

examiners
obtain

IN T H I S

to d i v e r s i f y

from

of

AND THE

in t h e i r

encouraged

variety

RISK,

is to e n c o u r a g e

the C o m p t r o l l e r

A wide

economic

DONE

exposure

representation

requirements

OR T R A N S F E R

RESERVE

Committee

their

lending,

two

Country Exposure

diversify
long

COUNTRY

ALREADY

of

first

THE F E D E R A L

InterAgency
purpose

the

risk

" l o s s ,"

may

be

classified

Se c o n d , the

as

country

" s u b s t a n d a r d ,"
may

be

listed

-

FOR

COMMENT
),

classified

DISCUSS

AN D D I S C U S S I O N
A nd

finally

THE C O U N T R Y

TRANSFER RISK,)
RISK
AND

IS E I T H E R
DISCUSSION

WHICH

, the

Co m m i t t e e

REPORTS
may

IN E X A M I N A T I O N

(BU T

decide

NOT

not

REPORTS.

to

(THIS L A S T

I N V O L V E S C O U N T R I E S WIT H L I T T L E OR NO

IN THE

THE

TWO C A S E S —

FIRST

CLASSIFIED
—

-

IN E X A M I N A T I O N

AT ALL

SET OF C A S E S U S U A L L Y

5

OR L I S T E D

COMMITTEE

IS M AD E A V A I L A B L E

THA T

IS,

AS A P P R O P R I A T E

PREPARES

WHERE TR AN SF ER
FOR

A STANDARD

COMMENT

ANALYSIS

TO AND U S E D BY E A C H F E D E R A L B A N K

REGULATOR,
1 MENTION
OF YO U ARE

THE C O U N T R Y R l S K C O M M I T T E E ,

A W A R E OF,

i!P ■ 1 :h F e DERA:

FOR TWO R E A S O N S ,

IN B A N K S '

This

listing

is a c c o m p l i s h e d
RISK

If '"EXPOSURE"
PURPOSELY
PURPOSE

FlRST,

I AM S URE M A N Y

I W A N T TO P O I N T OUT

R r OUL/’,,'i:S A L R E A D Y H A V E B E E N A C T I V E L Y

ENCOURAGING DIVERSIFICATION

TRANSFER

WHICH

by t h e

WHERE WE AKN ES S
IN T R E S E

HIGHLIGHTED

OF E N C O U R A G I N G

P O L I C I E S AND P R A C T I C E S

for

comment

IN P A R T I C U L A R

COUNTRIES
IN THE
EACH

INTERNATIONAL PORTFOLIOS,

APPEARS

EXAMINATION
BANK'S

and

discussion

COUNTRIES

IS E V I D E N T ,

CONSIDERABLE,
REPORT

DIRECTORS

FOR

TH E

TO R E V I E W

IN I N T E R N A T I O N A L L E N D I N G ,

of

THEY

ARE

SPECIFIC
THEIR

W I T H A V I E W TO

ACHIEVING GREATER DIVERSIFICATION.
Co n c e n t r a t i o n s
TRANSFER RISK




TAKE

credit

OR W H E T H E R

IS O NL Y ONE OF M A N Y
ANALYSTS

of

, whether

in c o u n t r i e s

subject

to

IN O T H E R P A R T I C U L A R F I E L D S OF L E N D I N G ,

C O N S IDE RAT IONS T H A T OUR E X A M I N E R S A N D

INT O A C C O U N T

IN A S S E S S I N G

THE

ADEQUACY

OF A B A N K ' S

-

capital

,

Al t h o u g h

GUIDELINES

REFERRING

IN T O A C C O U N T

WHEN

THE

AMOUNT

THE

ABILITIES

NAME

DECIDING

AND THE

IS T H A T

OF

OF M A N A G E M E N T ,

SECOND
IT

IDENTIFY

R isk

REASON

ASSETS

MANY

THE

ratio

F A C T O R S ARE T A K E N
-- F A C T O R S

QUALITY

AND C O N C E N T R A T I O N S

OF

SUCH

AS

OF A S S E T S ,
CREDIT,

TO

WHOSE

TRANSFER

reserve

w i l l

SINCE

COMMITTEE

VALUE
FOR
RISK

, of

THE

Re s e r v es

THE

BE A C C O M P L I S H E D ,

EARNINGS

HAS

an

ALLOCATION

HAVE

WILL

ADD P A R E N T H E T I C A L L Y ,

ACCOUNTING

DETAILS,

THAT

M A Y BE S E T

UP,)

RESERVES
CLEAR

I N T E N T OF T H E

BE D E T E C T E D
REPORTED

MORE

TWO C O N D I T I O N S ,
TRANSFER-RISK
A PROTRACTED
FOREIGN




CONGRESS

COUNTRY

AN O N - G O I N G

OF

TO M A K E

OF P U B L I C
PAYMENTS

ARE

THAT
BASIS,

TO C U R R E N T

GOING

INTO THE

IS T H A T

POTENTAL

IT

IS

LOSSES

SO T H A T A B A N K ' S

ITS T R U E

SPECIFIED

OR P R I V A T E

on

OF W A Y S T H E S E

REQUIRES

ON T H E I R

effect

HOWEVER,

REPRESENT

WHICH

RESERVES,

INABILITY

POINT,

OR

BE E S T A B L I S H E D .

WITHOUT

TO E N S U R E

ACCURATELY

EITHER

RELATED

ON

TO

TO

RISK

A SPECIAL

BE C H A R G E D

A COUPLE

THE M A I N

AND R E C O G N I Z E D

EARNINGS

ARE

MANDATE

BY T R A N S F E R

immediate

(I W O U L D

RISK C O M M I T T E E

CONGRESS'S

IMPAIRED

WILL

, have

THERE

COUNTRY

IMPAIRED CREDIT,

RESERVE

RESERVE

THAT

BEEN

EACH

course

THE

EARNINGS,

TH E

issued

ADEQUACY

EARNINGS,

FO R D I S C U S S I N G

IS T H R O U G H

ALLOCATED"

Th i s

CAPITAL,

ON C A P I T A L

QUALITY

has

B U T A FEW,

My

"

-

Reserve

TO M I N I M U M

"Al l o c a t e d " Tr a n s f e r

WILL

Federal

the

6

POSITION.

ESTABLISHING
IN T H E ACT,

BORROWERS

EXTERNAL

ONE

IS

IN A

INDEBTEDNESS.

The

other

is

RESTORATION
The

a

lack

of

OF D E B T

a g e n c i e s may

AMD

DURING

THE

ADDITIONAL
It 's
GENERALLY
NET

NEW

HAVE

COUNTRIES'
REASON
MAY

STRENGTHEN
HELP

EXPOSURE)

SUCH

THE

BY THE

orderly

ARE

TRANSFER

NEW

UNDER

HAVE

CREDITS.

TO BE M A D E
ON T H E

A N D AN

IN S U P P O R T

WHETHER
SUBJECT
OF

IS,

to

ECONOMIC

correct

MANNER.

TO THE

the

THE

CIRCUMSTANCES,

REDUCE

THESE

THE

TH E

AND
RISK

NEW LOANS
RESERVES

WILL

LOANS'

PERFORMANCE.
Bank

Re p o r t i n g

on

Co u n t r y

Exposure

As I m e n t i o n e d e a r l i e r ,
NEW

Act

is t h a t

EXPOSURES




MORE

regulators
CLOSELY.

another

are

YOU

of t h e r e q u i r e m e n t s

to m o n i t o r

WILL

SOON

OF

BY T H E

APPROPRIATE

(THAT

BASIS

be

RESERVES

OF T H E A D J U S T M E N T P R O C E S S ,

THE Q U A L I T Y

AGENCIES

RISK

designed

IN AN O R D E R L Y

FUNCTIONING

must

10 P E R C E N T

INITIALLY,

APPROVED

are

judgment

IMPAIRED,

IMPLEMENTING

AS P R O G R A M S

LENDING,

that

BE

IS

best

YEAR,

AT L E A S T

THAT

and

WOULD

DIFFICULTIES

IMPROVE

WILL

THESE

Fu n d , w h i c h

OF O U T S T A N D I N G

SUBSEQUENTLY
DETERMINED

TO

SUCH

THIS

SUBSEQUENT

THAT

IN C O U N T R I E S

Monetary

IS T H A T

THEREBY

IN E A C H

N O J BE R E Q U I R E D ,

ECONOMIC

the

reserves

iii u'HICH A L O A N ' S V A L U E

TO N O T E

PROGRAMS,

In t e r n a t i o n a l

for

discretion

THAT GE N E R A L L Y

YEAR

IMPORTANT
WILL

their

special risk-related

15 P E R C E N T

LENDING

ADJUSTMENT

exercise

STATED

FIRST

prospects

SERVICE.

as to t h e a m o unt of
HELD,

definite

banks'

OF T H E

country

BE E X P E R I E N C I N G

THE

BE

RESULTS
BANK

OF T H I S

REPORTING

ANNUAL
FROM

DIRECTIVE,
ON C O U N T R Y

BASIS,

USED

"g o o d

news

TO P R O V I D E

" is

COUPLE

OF C H A N G E S ,

ADDITION

ON E X P O S U R E

REPORTING

YOUR

MORE

OF Y O U R

(BANKS,

EXPOSURE

ASSETS,

IN A N Y

OF T H E

SECOND

3 / 4 OF

CASES,

FOR
THE

REQUEST,

AND

Examination
T he

of

REQUIREMENTS

EXAMINATION




Ba n k s

OF

and

OF

YOUR

INFORMATION

REQUIRE

WILL

FOR

OF

YOU

TO

1 P E R C E N T OR

IN S U C H C A S E S Y O U W I L L H A V E TO S H O W

AND

THE

DEBTORS

OTHERS),

SOMEWHAT

AND GI VE

TOTAL

BE A V A I L A B L E
THERE

LESS

EXPOSURES

OF Y O U R

R isk

BY B R O A D C A T E G O R I E S

THE A M O U N T M A T U R I N G

TO C R E D I T

GUESS

A

PERCENTAGE

ACCOUNTS

1 PERCENT

I WOULD

ARE

A CERTAIN

WHICH

WILL

SOME

ADDITION,

PROVIDE

COUNTRY

REQUIRES

INFORMATION

being

FOR

THERE

IMPORTANT,

PART

OR AL L

ACCOUNT

is

USED

BECAUSE

FIRST

SECTOR,

PERTAINING

BEEN

WHICH WILL

SHORTENED

PERIOD,

report

THE

LIST

INFORMATION

HAS BEEN

same

HAS

BUT

EXCEEDS

EXPOSURE,

PART

the

INCREASED

FROM A SEM I ­

E N D OF E A C H

THAT

A SMALL,

THAT

TIME

REPORT,"

SUMMARY

IN 1 Y E A R OR L E S S

THE

SAME

B A N K ' S ASSETS,

THE P U B L I C

MATURING
YEAR,

BANK'S

THE

virtually

INCLUDING

IS A T W O - P A R T

REPORTING

AMOUNT

THE

HAVE

TO A Q U A R T E R L Y

INFORMATION

TO A N Y C O U N T R Y

LIST

THE

THE

that

COUNTRY

I SAY " V I R T U A L L Y

TH E

EXPOSURE

IN A D D I T I O N ,

T IME,

TH E

THE R E G U L A T O R S

6U D A Y S TO 45 D A Y S F O L L O W I N G
Th e

The

SINCE

MAY

IN O V E R

1

DETAILED

IN C O U N T R I E S
ASSETS,

TO T H E

WHICH

IN B O T H

PUBLIC

BE A L O T OF

UPON

REQUESTS!

Ma n a g e m e n t

THE N E W A C T A L S O W I L L
BANKS,

THE A M O U N T

FOR

BE

REFLECTED

E X A M P L E , BANK

EXAMINERS

IN

-

PROBABLY

WILL

country

risk

focuses

on

our

BE D I S C U S S I N G

-m a n a g e m e n t

three

examiners

strengths

T he

first

socio

where

type

of

or

is

part

very

and

that

,

whole

project
third

of

of

DETAIL,

the

on

YOUR

OWN

examination

important

in

management

enabling

abilities

and

the

This

system

), a s

to

and

per

the

control

is

of

from

to

your

internal

in

or

these
data

lenders

,

officers

by

the

the

B a n k 's

level

in

establishment
all

maturities

and

trade

and

each

for

as

of

foreign

financing

,

.

the

like

bank

's o w n

reporting

,

country

,

perhaps

for

, such

exposure

bank

assume

the

economic

economic

define

to

(a n d

limits

the

undertaking

involves

, and

country

from

willing

risk

, in

international

country

the

country

evaluate

In f o r m a t i o n

management

as

to

, including

foreign

credit

financing

,

reports

involves

well

of

r i s k

, and

typically

limits

is

at

bank

management

developments

obtained

the

's r i s k

procedures

sources

senior

component

management
monitor

's o w n

or

in

country

are

variety

categories

-term




This

social

funds

component

lending
a

and

stationed

country

as

b a n k

a

commentaries

exposure

different

T he

a

directors

aggregate
lending

IN G R E A T E R

decision

of

borrower

second

of

foreign

long

the

-p o l i t i c a l

The
board

bank

from

by

traveling

each

political

comes

provided

,

, and

their

component

covers

, and

countries
areas

reach

YOU,

.

evaluation
trends

to

-

WITH

systems

components

9

country
system

T he

risk
which

reporting

is

used

system

SHOULD

:0 Slk-‘
-i C O M P L I A N C E

DESIGMK!!

WITH

THE

BANK'S

OWN

I N T E R N A L P O L I C I E S A N D L IM I TS ;

IT S H O U L D

TO THOSE P O L I C I E S

IT S H O U L D E S T A B L I S H A M E T H O D TO

REPORT

THE E X C E P T I O N S ;

A N N U A L R E V I E W OF
Se t t i n g

the

bank

ACCOMPLISH

THEM,

MANAGEMENT

TO

ARE

AND L IMITS;
AMD

IT S H O U L D P R O V I D E FOR AT L E A S T AN

THE P O R T F O u i O
's o v e r a l l

TAKING

C O M P O S I T I O N OF EA C H C O U N T R Y ,

goals

, determining

INTO A C C O U N T

IMPLEMENT

THE

WANT

INCLUDING

TO A S S U R E

THE R I S K

POLICIES,

B AS I C D I R E C T O R R E S P O N S I B I L I T I E S

OPERATIONS,

I D E N T I F Y A NY E X C E P T I O N S

COUNTRY

to

INVOLVED,

AND M O N I T O R I N G

DIRECTING

THE R E S U L T S

IN E V E R Y A S P E C T OF BA N K

INTERNATIONAL LENDING,

THAT YOUR

methods

RISK

OUR E X A M I N E R S WILL

MANAGEMENT

SYSTEM

IS

C O M P R E HE NS IV E AND E F F E C T I V E ,
I SHOULD
THROUGH

THAT

REGULATIONS

CORPORATIONS,
NOT

NOTE

A P P L Y TO

THE A d

IS B E I N G

A F F E C T O N L Y U.S.

WHICH

AND B A N K

CURRENTLY

HOLDING COMPANIES,

U.S, B R A N C H E S

AND

IMPLEMENTED

DOMESTIC

BANKS,

EDGE

T H E R U L E S C U R R E N T L Y DO

A G E N C I E S OF F O R E I G N B A N K S OR

C O M M E R C I A L L E N D I N G C O M P A N I E S W H I C H ARE S U B S I D I A R I E S OF F O R E I G N
ban k s

,

Ho w e v e r , c o n s i d e r a t i o n

currently

R E G U L A T O R S AS TO W H L iH E R T H O S r
THE R E G U L A T I O N ,

AND

TIES

THE R E G U L A T O R S HAVE

is

being

given

by

the

S H O U L D BE M A D E S U B J E C T TO
I N V I T E D C O M M E N T ON THE

SUBJECT,
This

i s s u e of w h e t h e r

INSTITUTIONS
COMPLICATED




SHOULD
ONE,

BE

branches

SUBJECT

ON T H E

ON E

and a g e n c i e s

TO THE P R O V I S I O N S

H AND,

SOM E

OBSERVERS

of f o r e i g n
OF

THE

ACT

IS A

POINT OUT THAT

11

-

O U R P O L I C Y OF A C C O R D I N G
ORGANIZATIONS

IN T H I S

OTHER

H A N D,

MAJOR

COUNTRIES

BANKS'

THERE

NATIONAL

COUNTRY

IS OUR

THAT

WORLD-WIDE

THE

OPERATIONS

HO M E

IS THE

FALL

CONSOLIDATED
INTO

THE

MENTIONED,
TIME,

AMD

ONLY

THE

INTERESTED

FEDERAL

INTERNATIONAL
FIRST

THAT

TO D E V E L O P I N G

CHARACTERISTIC

COUNTRY

DEVELOPMENT
W hat

I do

DEVELOPMENT




OF

make

THE

THE

CENTRAL

B A N K S OF

OF T H E

GENERAL

SOLVENCY

THE

ACCOMPLISH

HOME

OF

BEEN

the

SUPERVISION

GENERAL

HAS

OF

COUNTRY

that

TRANSFER

RISK

STILL

RECEIVING

a

remarks

ON A

WOULD

As I

SOLVENCY,

REACHED

NOR

COMMON

IS

IT W R O N G

FINANCE

STAGES

TO A L A R G E
THE W E S T

AT T H I S

COMMENTS

DURING

ECONOMIC

GROWTH,

GROWTH,

FROM

subject

BANK

THIS

L E T ME
LENDING
NATION

IS A

A S W E L L AS TO
OUR OWN

BORROWING

FOR

THE

CENTURY,

, h o w e v e r , is

IN THE L A S T

WITH

CORPORATIONS

19T H

the

COUNTRIES,

WRONG

ON F O R E I G N

THE

on

FOR A D E V E L O P I N G

OF E C O N O M I C

EXTENT

disturbing

FINANCING

BASICALLY

TO A L L G R O W I N G

EARLY

few

LESS-DEVELOPED

IS N O T H I N G

TO H E L P

find

to

to

COUNTRIES,

IN T H E

RELIED

like

LENDING

THERE

TO B O R R O W A B R O A D

COUNTRIES

ISSUE

ON T H E

L E N D ING TO LDCS

Finally, I would

SAY

THEM,

AGAINST

SUPERVISION

ARE

INCLUDING

on t h e a r g u m e n t

THAT CAN

AGENCIES

BANKING

PARTIES,

INTERNATIONAL

OF

is b a s e d

ON T H I S

TO A L L

REST WITH

RESERVES

OF

NO D E C I S I O N

FOR

WITH

SHOULD

ONE

BASIS.

CATEGORY

ARGUES

SUPERVISION

This agreement

FULLY

TREATMENT

AGREEMENT

supervisor.
COUNTRY

-

TEN YEARS.

the

wide

THROUGH

swing

in

MOST

OF

THE

12

-

1970s,
that

funds

were

interest

often

were

developing
borrowed

rates

,

nations

took

CIRCUMSTANCES,

LEADING

to

IN

LENDING,

APPROACH

EXACERBATED

MAKE

IN,

AND

PROGRAM
Banks

IS

a

IN THE P A S T

IN T H E I R




WERE

THE

OF

WITH

TO E L I M I N A T E
not

LONG-RUN

I SUBMIT

the

face

ENCOURAGED

;

of

BY

AFTER TROUBLE

TOOK

FUNDS

PLACE,

FROM
IN A

COUNTRIES

T H E I R H E A V Y B U R D E N OF

TO M A N A G E
OF

l e n d

THE
THAT

SUCH

A FEAST-OR-

A FINANCIAL

CAUSES

OF

SYSTEM.

THE

EXCESSIVE

RETRENCHMENT

PROBLEM.

comparison

JOINTLY

WAY

to

,

and

in

HOWEVER,

BORROWING

IS ONE

PROBLEM,

with

domestic

In D O M E S T I C

IN F I N A N C I A L

do t h i s

credit

IN S E N T I M E N T

AND L E A V I N G

inflation
eager

growth

IN E F F E C T

WITHDRAWAL

markets

IN T H E S E

AND O V E R - I N V E S T ,

LARGE

of

were

cheap

economic

COUNTRIES

IS A D I S R U P T I V E

MY P O I N T C L E A R .

CUSTOMER

the

RECESSIONS,

SHIFT

rate

, banks

TO C A R R Y AND S E R V I C E

INTERNATIONAL-DEBT

Perhaps

of

the

capital

As E V E R Y F I N A N C I A L M A N A G E R K N O W S ,

D EBT .

1.F O V E R - L E N D I N G

HAS

AND

for

funds

their

AND WORLD

AN A B R U P T

DESPERATE STRUG GL E
FOREIGN

with

maintain

TO A S T E A D Y

international

advantage

BORROWING

1982,

in

allowing

Flush

TO O V E R - S P E N D

INTERNATIONAL

FAMINE

, after

INCREASES

TH E M A R K E T

plentiful

negative

heavily

OIL-PRICE

SURFACED

so

-

THE

TROUBLE,

just

LENDING,

AND

PUT THE

as a s e r v i c e

INTEREST

WORKS

TO DO SO.

to

practices

will

WHEN A L O N G - T E R M

THE L E N D I N G

MANAGEMENT,

WASTE

lending

BANK

USUALLY

GOES

OUT A R E S T R U C T U R I N G

CUSTOMER

BACK

society,

but

ON T R A C K .
because

it

is

15

-

In

INTERNATIONAL

CONSIDERABLY
BANKS
WORK

ARE

DIFFERENT,

NOT

OUT,

GOVERNMENT

OF

YEARS

WITH

Solving

in

are

financial

banks

can

country

.

are

at

a

T he

problem

in

because

problem

is

community

one

United

WITH

THE

TO DO T H A T

A FEW

TO L E A V E ,

to

retrench

.

sovereign

, there
in

exacerbate

is

their
the

to

the

problem

-d e b t

does

problem

country

L ike

collective

security

that

the

world

a

stability

community

face

and

jointly

regard,

the

IMF—f u n d i n g

, the

fall

of

that

that

on

of
banks

financial

the

world

international

through

November

stride

the

joined

the

truly mark ed

towards

bill's

the

economy
debt

banking

cooperation

ITS

the

President

a milestone

international

passage

other

bill which

and s i g n i n g
IMF-member

is

's d e b t -

, including

resolve

to

burden

world

nation

little

lending

not

is

debtor

indeed

Fo r t u n a t e l y , h o w e v e r , the

and

With

States




alone

a

prosperity

collective

stability,

Left

process

into l a w l a s t

world's

A ND

,

In t h i s
signed

ASKED

NATION

PROGRAM

ATTEMPTED

the

, must

coordination

then

, when

?

solution

,

QUICKLY

do

international

stake

BANKS

to

than

the

problems

developing
alone

banks

other

, and

COMMERCIAL

IN T O A S O V E R E I G N

A STABILIZATION

SOME

AND WERE

LENDING,

ARE

D e bt P r o b l e m

trouble

do

servicing

COUNTRY,

THE C O N S T R A I N T S

DOMESTIC

TO GO

STIPULATE,

PERU

LDC

the

What

THE

HOWEVER,

UNLIKE

IN A P O S I T I O N

LET ALONE

BACK

LENDING,

-

in the

financial
into law,

nations

in

the

and

14

-

INCREASING

THE

RESOURCES

Fu n d ,

The

result

is

ASSIST

THE

DEBTOR

NATIONS

AVAILABLE

that

DIFFICULT

DEBT

SO-CALLED

"CONDITIONALITY"

TO

IMF

CREDIT

ADOPTING

OF-PAYMENTS
OF

FINANCING

ECONOMIC

WHAT

CUSTOMERS,

BANKS

AND

DO

IS W H A T

amount

of

else

to

WITH

assess

international

individual

THE

and

prudence

in

the

Co n g r e s s

international

international

coordination

international

financial

accountable

for

Su m m a r y

and

Co n c l u s i o n

L e t me

summarize.

deal

of c o n c e r n




their

IMF

banks

risks

in

in

risk

have

is

system

own

risk

The

in r e c e n t

THE

LENDING
cannot

to

,

THAT

REDUCING

; individual

T h IS

IS

TO D O M E S T I C

PROGRAMS.
on

That

IMF

lending

is

high

the

the

can

In s h o r t , t h e

safeguard

OF

INTERNATIONAL

rely

a

ACCESS

BALANCE-

COUNTRY,

lending

on

IS T H E

THE A V A I L A B I L I T Y

international

-t a k i n g .

VERY

COUNTRY'S

LENDING
IN

to

EFFORTS

IMPLEMENTATION

DOING

in

SOME

MEANS

THAT

BORROWING

insisted

lending

FOR

MEANS

LONG-TERM

coordination

responsibility

agencies

UPON

THEY NOW ARE

IN C O O R D I N A T I O N

anyone

THIS

IN T H E I R

O U T OF

BORROWING

MONETARY

equipped

OF T H E S E

PROGRAM

BY T H E

Ne v e r t h e l e s s , u l t i m a t e l y
upon

THE

ADJUSTMENT

PROGRAMS

better

L O A N S , WHICH

UPON

IN S H O R T ,

been

FEATURE

IMF

OF

INTERNATIONAL

THEMSELVES

A KEY

CONTINGENT

ADJUSTMENTS

PRECISELY

LENDING

IS M A D E

has

TO H E L P

IS C O N D I T I O N E D

DEFICITS,

TO THE

IMF

the

SITUATIONS,

AN A P P R O P R I A T E

-

ever
why

, and

replace

standard
purpose

are

of
of

of

the

still

-t a k i n g .

LDC- d e b t p r o b l e m h a s c a u s e d a g r e a t

years.

Fortunately,

no

regulatory

soundness

banks

or

as a r e s u l t

of

-

15

-

U N P R E C E D E N T E D C O O P E R A T I O N A M O N G NATIONAL. G O V E R N M E N T S ,
I N T E R N A T I O N A L A G E N C I E S AND C O M M E R C I A L BANKS,

THE W O R L D HAS BEEN

ABLE TO W E A T H E R A S E R I E S OF P O T E N T I A L L Y H I G H L Y D I S R U P T I V E
IN THE A R E N A OF

INTERNATIONAL

FINANCE,

FROM THESE EXPERIENCES,

LOT HAS BEEN L E A R N E D A B O U T THE H A Z A R D S OF

I N TE RNATION AL LENDING,

AND THE S U C C E S S WE HAV E HAD

IN M A I N T A I N I N G

FINANCIAL STABILITY THROUGH

INTERNATIONAL COOPERATION

B O L S T E R E D OUR C O N F I D E N C E
C O N T I N U E TO DEAL W IT H

STORMS

INTERNATIONAL
HAS

IN D E A L I N G WITH F U T U R E P R O B L E M S ,

IMMEDIATE PROBLEMS,

E N H A N C E THE L O N G - R U N V I A B I L I T Y OF

CONGRESS

INTERNATIONAL

As WE

HAS A C T E D TO

L E N D I N G BY

M A N D A T I N G A S T R E N G T H E N I N G OF THE R E G U L A T O R Y AND S U P E R V I S O R Y
FRAMEWORK
LEARNED

OF

I N T E R N A T I O N A L BAN K L E N D I N G ,

S U F F I C I E N T L Y FR O M PA S T E X P E R I E N C E S

L E N D I N G ON A S O U N D E R F O O T I N G ,




HOPEFULLY,
TO PUT

WE ALL HAVE

INTERNATIONAL

A