A wave of retrenchment by global financial institutions may be undermining years of progress in providing the world’s poor with financial services.

What appeared to be only a vague concern a year ago is now front and center in discussions regarding global financial regulation. The reason: new regulatory and legal uncertainty regarding financial services, stemming from record fines levied on a handful of banks for failures to comply with international sanctions and anti-money laundering rules. A recent successful civil action in the U.S. against Arab Bank has further increased banks’ worries about their possible civil liability. Rightly or wrongly, the financial industry is reading these actions as raising the bar for compliance. As a result, we are seeing key and vocal market players use these developments to justify a wholesale retreat from services that are a lifeline for millions of people at the bottom of the economic pyramid.

For example, late last year a big bank in Australia sent letters to companies providing remittance services laying out a stark choice: close their accounts, or the bank would unilaterally shut them down. Accounts held by remittance companies have also been closed by banks in the U.K., the U.S., and New Zealand. If these remittances providers do not find alternatives, we may experience a global reduction in remittance services, and—due to reduced competition—increased cost to use those that remain in operation.

Remittance services are not the only targets. Trade finance and civil society organizations have also been affected. For instance, in the Netherlands an NGO involved in supporting the peace-building work of women's groups and women leaders in the Middle East and North Africa was recently refused a bank account by a large international bank. After the NGO explained to the bank that its work entails working with partners in the region, the bank decided not to provide a bank account in order to avoid any risk of funds (indirectly) ending up in Syria. And there are many examples like this, hampering the work of NGOs and humanitarian organizations, particularly in areas of conflict where they are most needed. In recent months, stories like this have become too numerous—and too widespread geographically—to be ignored; this is a global phenomenon.

This trend of account closures has become known as “de-risking”—a term that confuses more than it clarifies. Risk management, when properly carried out, is an essential and healthy component of running a bank. Under international financial industry norms, banks are expected to use a risk-based approach to evaluate whether to do business with a potential customer, and to monitor transactions for signs of suspicious activity. If there is a reasonable basis to believe a particular client creates significant risks regarding money laundering (ML) or terrorist financing (TF), a bank is fully justified in ultimately refusing to offer services.

 “De-risking,” however, is very different. The influential Financial Action Task Force (FATF), the standard setter for combating money laundering and terrorist financing, noted in an October 2014 statement that “de-risking refers to the phenomenon of financial institutions terminating or restricting business relationships with clients or categories of clients to avoid, rather than manage, risk.” The result, criticized by FATF, is the “wholesale cutting loose of entire classes of customers.”

Our concern lies not with the principle that some clients may be too risky for banks. Rather, the problem is the magnitude of de-risking. Current de-risking measures are excluding many clients that conduct legitimate transactions. And, because de-risking ends up pushing clients and transactions towards the informal and shadow financial system, it can actually increase global risks in this area.

It is therefore urgent for the international community to act. We need to better grasp what is really happening, and why. We believe that the solutions going forward will have to build on three pillars:

1. Public authorities need to provide more meaningful information on ML/TF risks to the financial industry, clarify their regulatory expectations, and adopt a genuinely risk-based approach in their supervisory and enforcement actions.
2. Financial institutions need to step up their understanding of the risks of their customer base, and direct internal control efforts accordingly. Risk management approaches should focus more on individual clients, and not write off entire sectors.
3. Countries with significant inflows of remittances need to improve the effectiveness of their regulatory regimes to combat ML/TF, and to provide more comfort to global financial institutions with banking relationships with clients in the developing world.

Millions of people in developing countries depend on remittances to help pay for basic necessities like food and shelter. In recent years we have seen important progress with banks and mobile network operators introducing innovative ways to serve the poor—including “mobile money” solutions that have enormous potential for enabling cross-border transactions. It would be a shame to see that trend reversed. Let’s not have those at the bottom of the economic pyramid pay for the criminal behavior of a few, and let’s make sure that enforcement action really targets the “bad guys.” Preserving access to the global financial system for the poorest and most vulnerable is a critical imperative, both economically and ethically.

Event Information

The year 2015 will be a milestone year, with the adoption of the Sustainable Development Goals (SDGs) and the post-2015 development agenda by world leaders in September; the Addis Ababa Accord on financing for development in July; and the conclusion of climate negotiations at COP21 in Paris in December. The draft Addis Ababa Accord, which focuses on the actions needed to attain the SDGs, highlights the key role envisaged for the multilateral development banks (MDBs) in the post-2015 agenda. Paragraph 65 of the draft accord notes: “We call on the international finance institutions to establish a process to examine the role, scale, and functioning of the multilateral and regional development finance institutions to make them more responsive to the sustainable development agenda.”          

Against this backdrop, on April 18, 2015, the Global Economy and Development program at Brookings held a private roundtable with the leaders of the MDBs and other key stakeholders to discuss the role of the MDBs in supporting the post-2015 development agenda.

The meeting focused on four questions:

1. What does the post-2015 development agenda and the ambitions of the Addis and Paris conferences imply for the MDBs?


Given the ability of the MDBs to leverage shareholder resources, they can be efficient and effective mechanisms for scaling up development cooperation, particularly with respect to the agenda on investing in people and to the financing of sustainable infrastructure. New roles, instruments and partnerships might be needed.

2. How can MDBs best take advantage of the political attention that is being paid to the various conferences in 2015?   


The World Bank and selected regional development banks have launched a series of initiatives to optimize their balance sheets, address other constraints and enhance their catalytic role in crowding in private finance. And new institutions and mechanisms are coming to the fore. But the responses are not coordinated to best take advantage of each MDB’s comparative advantage.

3. What are the key impediments to scaling up the role and engagement of the MDBs?


Views on constraints are likely to differ but discussions should cover policy dialogue, capacity building, capital, leverage, shareholder backing on volume, instruments on leverage and risk mitigation, safeguards, and governance. 

4. How should the MDBs respond to the proposal to establish a process to examine the role, scale and functioning of the multilateral and regional development finance institutions to make them more responsive to the sustainable development agenda?   


A proactive response and engagement on the part of the MDBs would facilitate a better understanding of the contribution that the MDBs can make and greater support among shareholders for a coherent and stepped-up role.

Event Materials

• Participant List
• MDB PostEvent Summary

Executive Summary ¹

The regional banks play an important role in the economy providing funding to consumers and small- and medium-sized businesses. Their model is simpler than that of the large Wall Street banks, with their business concentrated in the U.S.; they are less involved in trading and investment banking, and they are more reliant on deposits for their funding. We examined the balance sheets of 15 regional banks that had assets between $50 billion and $250 billion in 2003 and that remained in operation through 2014.

The regionals have undergone important changes in their financial structure as a result of the financial crisis and the subsequent regulatory changes:

• Total assets held by the regionals grew strongly since 2010. Their share of total bank assets has risen since 2010.

• Loans and leases make up by far the largest component of their assets. Since the crisis, however, they have substantially increased their holdings of securities and interest bearing balances, including government securities and reserves.

• The liabilities of the regionals were heavily concentrated in domestic deposits, a pattern that has intensified since the crisis. Deposits were 70 percent of liabilities in 2003, a number that fell through 2007 as they diversified their funding sources, but by 2014 deposits made up 82 percent of the total.

• Regulators are requiring large banks to increase their holdings of long term subordinated debt as a cushion against stress or failure. The regionals, as of 2014, had not increased their share of such liabilities.

• Like the largest banks, the regionals increased their loans and leases in line with their deposits prior to the crisis. And like the largest banks, this relation broke down after 2007, with loans growing much more slowly than deposits. Unlike the largest banks, the regionals have increased loans strongly since 2010, but there remains a significant gap between deposits and loans.

• The regional banks’ share of their net income from traditional sources (mostly loans) has been slowly declining over the period.

• The return on assets of the regionals was between 1.5 and 2.0 percent prior to the crisis. This turned sharply negative in the crisis before recovering after 2009. Between 2012 and 2014 return on assets for these banks was around 1.0 percent, well below the pre-crisis level.

As we saw with the largest banks, the structure and returns of the regional banks has changed as a result of the crisis and new regulation. Perhaps the most troubling change is that the volume of loans lags well behind the volume of deposits, a potential problem for economic growth. The asset and liability structure of the banks has also changed, but these banks have a simpler business model where deposits and loans still predominate.

Downloads

• Download the revised paper
• Media summary

Earlier this summer, we examined how the Big Four banks – Bank of America, Citigroup, JPMorgan Chase, and Wells Fargo – performed before, during, and after the 2007-09 financial crisis.  We also blogged about the lending trends within these large banks, expressing concern about the growing gap between deposits taken and loans made by the Big Four, and calling on policymakers to explore the issue further.  We have conducted a similar analysis on the regional banks - The regional banks: The evolution of the financial sector, Part II - and find that these smaller banks are actually faring somewhat better than their bigger counterparts.

Despite the mergers and acquisitions that happened during the crisis, the Big Four banks are a smaller share of banking today than they were in 2007.  The 15 regionals we evaluated, on the other hand, are thriving in the post-crisis environment and have a slightly larger share of total bank assets than they had in 2007.  The Big Four experienced rapid growth in the years leading up to the crisis but much slower growth in the years since.  The regionals, however, have been chugging along: with the exception of a small downward trend during the crisis, they have enjoyed slow but steady growth since 2003.

There is a gap between deposits and loans among the regionals, but it is smaller than the Big Four’s gap.  Tellingly, the regionals’ gap has remained basically constant in size during the recovery, unlike the Big Four’s gap, which is growing.  Bank loans are important to economic growth, and the regional banks are growing their loan portfolios faster than the biggest banks.  That may be a good sign for the future if the regional banks provide more competition for the big banks and a more competitive banking sector overall.

Community banks play a key role in their local communities by offering traditional banking services to households and lending to nearby small businesses in the commercial, agriculture, and real estate sectors. Because of their close relationship with small businesses, they drive an important segment of economic growth. In fact, compared to all other banks (and to credit unions), small banks devote the greatest share of their assets to small business loans.

In this paper, titled "The community banks: The evolution of the financial sector, Part III," (PDF) Baily and Montalbano examine the evolution of community banks before, through, and after the financial crisis to assess their recovery.

The authors find that despite concerns about the long-term survival of community banks due a decline in the number of banks and increased Dodd-Frank regulations, they continue to recover from the financial crisis and are in fact out-performing the Big Four banks in several key measures.

Although the number of community banks has been steadily declining since before 2003, most of the decline has come from the steep drop in the smallest banking organizations—those with total consolidated assets of less than $100 million. Community banks with total consolidated assets that exceed $300 million have in fact increased in number. Most of the decline in community banks can be attributed to the lack of entry into commercial banking.

In a previous paper, Baily and Montalbano showed that the gap in loans and leases among the Big Four has widened since the financial crisis, but the new research finds that community banks seem to be returning to their pre-crisis pattern, although slowly, with the gap between deposits and loans shrinking since 2011. While total deposits grew gradually after 2011, though at a pace slower than their pre-crisis rate, loans and leases bottomed out in 2011 at $1.219 trillion.

The authors also examine community banks' return on assets (ROA), finding it was lower overall than for the Big Four or for the regionals, and has come back to a level closer to the pre-crisis level than was the case for the larger banks. The level of profitability was slightly lower for community banks in 2003 than it was for the larger banks—about 1.1 percent compared to 1.7 percent for the regional banks—but it did not dip as low, reaching a bottom of about -0.1 percent compared to -0.8 percent for the regional banks.

Baily and Montalbano also find that total assets of the community banks increased 22.5 percent (adjusted for inflation, the increase was 7 percent); the average size of community banks has increased substantially; total bank liabilities grew steadily from 2003-2014; the composition of liabilities in post-crisis years looked largely similar to the composition in the pre-crisis years; and securitization—which plays a relatively small role in the community banking model—has been steadily increasing in the time period both before and after the crisis. 

To read more, download the full paper here.

The paper is the third in a series that examines how the financial sector has evolved over the periods both before and after the financial crisis of 2007-2008. The first paper examines the Big Four banks, and the second takes a closer look at regional banks.

Downloads

• Download "The community banks: The evolution of the financial sector, Part III"

Neel Kashkari, the newly appointed President of the Federal Reserve Bank of Minneapolis, is super-smart with extensive experience in the financial industry at Goldman Sachs and then running the government’s TARP program, but his call to break up the big banks misses the mark.

Sure, big banks, medium-sized banks and small banks all contributed to the devastating financial crisis, but so did the rating agencies and the state-regulated institutions (mostly small) that originated many of the bad mortgages.  It was vital that regulation be strengthened to avoid a repetition of what happened – and it has been.  There should never again be a situation where policymakers are faced with either bailing out failing institutions or letting them fail and seeing financial panic spread.

That’s why the Dodd-Frank Act gave the authorities a new tool to avoid that dilemma titled “Orderly Liquidation Authority,” which gives them the ability to fail a firm but sustain the key parts whose failure might cause financial instability.  Kashkari thinks that the authorities will not want to exercise this option in a crisis because they will be fearful of the consequences of imposing heavy losses on the original owners of the largest banks.  It’s a legitimate concern, but he underestimates the progress that has been made in making the orderly liquidation authority workable in practice.  He also underestimates the determination of regulators not to bail out financial institutions from now on.

To make orderly liquidation operational, the Federal Deposit Insurance Corporation (FDIC) devised something called the “single point of entry” approach, or SPOE, which provides a way of dealing with large failing banks.  The bank holding company is separated from the operating subsidiaries and takes with it all of the losses, which are then imposed on the shareholders and unsecured bond holders of the original holding company, and not on the creditors of the critical operating subs and not on  taxpayers.  The operating subsidiaries of the failing institution are placed into a new bank entity, and they are kept open and operating so that customers can still go into their bank branch or ATM and get their money, and the bank can still make loans to support household and business spending or the investment bank can continue to help businesses and households raise funds in securities markets.  The largest banks also have foreign subsidiaries and these too would stay open to serve customers in Brazil or Mexico.

This innovative approach to failing banks is not magic, although it is hard for most people to understand.  However, the reason that Kashkari and other knowledgeable officials have not embraced SPOE is that they believe the authorities will be hesitant to use it and will try to find ways around it.  When a new crisis hits, the argument goes, government regulators will always bail out the big banks.

First, let’s get the facts straight about the recent crisis.  The government did step in to protect the customers of banks of all sizes as well as money market funds.  In the process, they also protected most bondholders, and people who had lent money to the troubled institutions, including the creditors of Bear Stearns, a broker dealer, and AIG, an insurance company.  This was done for a good reason because a collapse in the banking and financial system more broadly would have been even worse if markets stopped lending to them.  Shareholders of banks and other systemically important institutions lost a lot of money in the crisis, as they should have.  The CEOs lost their jobs, as they should have (although not their bonuses).  Most bondholders were protected because it was an unfortunate necessity.

As a result of Dodd-Frank rules the situation is different now from what it was in 2007.  Banks are required to hold much more capital, meaning that there is more shareholder equity in the banks.  In addition, banks must hold long-term unsecured debt, bonds that essentially become a form of equity in the event of a bank failure.  It is being made clear to markets that this form of lending to banks will be subject to losses in the event the bank fails—unlike in 2008.  Under the new rules, both the owners of the shares of big banks and the holders of their unsecured bonds have a lot to lose if the bank fails, providing market discipline and a buffer that makes it very unlikely indeed that taxpayers would be on the hook for losses.

The tricky part is to understand the situation facing the operating subsidiaries of the bank holding company — the parts that are placed into a new bank entity and remain open for business.  The subsidiaries may in fact be the part of the bank that caused it to fail in the first place, perhaps by making bad loans or speculating on bad risks.  Some of these subsidiaries may need to be broken off and allowed to fail along with the holding company—provided that can be done without risking spillover to the economy.  Other parts may be sold separately or wound down in an orderly way.  In fact the systemically important banks are required to submit “living wills” to the FDIC and the Federal Reserve that will enable the critical pieces of a failing bank to be separated from the rest.

It is possible that markets will be reluctant to lend money to the new entity but the key point is that this new entity will be solvent because the losses, wherever they originated, have been taken away and the new entities recapitalized by the creditors of the holding company that have been “bailed in.”   Even if it proves necessary for the government to lend money to the newly formed bank entity, this can be done with reasonable assurance that the loans will be repaid with interest.  Importantly, it can be done through the orderly liquidation authority and would not require Congress to pass another TARP, the very unpopular fund that was used to inject capital into failing institutions.

There are proposals to enhance the SPOE approach by creating a new chapter of the bankruptcy code, so that a judge would control the failure process for a big bank and this could ensure there is no government bailout.  I support these efforts to use bankruptcy proceedings where possible, although I am doubtful if the courts could handle a severe crisis with multiple failures of global financial institutions.  But regardless of whether failing financial institutions are resolved through judicial proceedings or through the intervention of the FDIC (as specified under Title II of Dodd-Frank) the new regulations guaranty that shareholders and unsecured bondholders bear the losses so that the parts of the firm that are essential for keeping financial services going in the economy are kept alive.  That should assure the authorities that bankruptcy or resolution can be undertaken while keeping the economy relatively safe.

The Federal Reserve regulates the largest banks and it is making sure that the bigger the bank, the greater is the loss-absorbing buffer it must hold—and it will be making sure that systemically important nonbanks also have extra capital and can be resolved in an orderly manner.  Once that process is complete, it can be left to the market to decide whether or not it pays to be a big bank.  Regulators do not have to break up the banks or figure out how that would be done without disrupting the financial system.

Editor's note: This piece originally appeared in Bloomberg Government. 

Editor's Note: Johannes Linn discusses the potential of multilateral development banks in the latest G-20 Research Group briefing book on the St. Petersburg G-20 Summit. Read the full collection here.

The origins of the multilateral development banks (MDBs) lie with the creation of the World Bank at Bretton Woods in 1944. Its initial purpose, as the International Bank for Reconstruction and Development, was the reconstruction of wartorn countries after the Second World War. 

As Europe and Japan recovered in the 1950s, the World Bank turned to providing financial assistance to the developing world. Then came the foundation of the InterAmerican Development Bank (IADB) in 1959, of the African Development Bank (AfDB) in 1964 and of the Asian Development Bank (ADB) in 1966, each to assist the development of countries in their respective regions. The European Bank for Reconstruction and Development (EBRD) was set up in 1991, following the collapse of the Soviet Union, to assist with the transition of countries in the former Soviet sphere. 

The MDBs are thus rooted in two key aspects of the geopolitical reality of the postwar 20th century: the Cold War between capitalist ‘West’ and communist ‘East’, and the division of the world into the industrial ‘North’ and the developing ‘South’. The former aspect was mirrored in the MDBs for many years by the absence of countries from the Eastern Bloc. This was only remedied after the fall of the Bamboo and Iron curtains. The latter aspect remains deeply embedded even today in the mandate, financing pattern and governance structures of the MDBs. 

Changing global financial architecture 

From the 1950s to the 1990s, the international financial architecture consisted of only three pillars: the International Monetary Fund (IMF) and the MDBs represented the multilateral official pillar; the aid agencies of the industrial countries represented bilateral official pillar; and the commercial banks and investors from industrial countries made up the private pillar. 

Today, the picture is dramatically different. Private commercial flows vastly exceed official flows, except during global financial crises. New channels of development assistance have multiplied, as foundations and religious and non-governmental organisations rival the official assistance flows in size. 

The multilateral assistance architecture, previously dominated by the MDBs, is now a maze of multilateral development agencies, with a slew of sub-regional development banks, some exceeding the traditional MDBs in size. For example, the European Investment Bank lends more than the World Bank, and the Caja Andina de Fomento (CAF, the Latin American Development Bank) more than the IADB. There are also a number of large ‘vertical funds’ for specific purposes, such as the International Fund for Agricultural Development and the Global Fund to Fight AIDS, Tuberculosis and Malaria. There are  specialized trust funds, attached to MDBs, but often with their own governance structures.

End of the North-South divide 

Finally, the traditional North-South divide is breaking down, as emerging markets have started to close the development gap, as global poverty has dropped and as many developing countries have large domestic capacities. This means that the new power houses in the South need little financial and technical assistance and are now providing official financial and technical support to their less fortunate neighbors. China’s assistance to Africa outstrips that of the World Bank.

The future for MDBs 

In this changed environment is there a future for MDBs? Three options might be considered: 

1. Do away with the MDBs as a relic of the past. Some more radical market ideologues might argue that, if there ever was a justification for the MDBs, that time is now well past. In 2000, a US congressional commission recommended the less radical solution of shifting the World Bank’s loan business to the regional MDBs. Even if shutting down MDBs were the right option, it is highly unlikely to happen. No multilateral financial institution created after the Second World War has ever been closed. Indeed, recently the Nordic Development Fund was to be shut down, but its owners reversed their decision and it will carry on, albeit with a focus on climate change. 

2. Carry on with business as usual. Currently, MDBs are on a track that, if continued, would mean a weakened mandate, loss of clients, hollowed-out financial strength and diluted technical capacity. Given their tight focus on the fight against poverty, the MDBs will work themselves out of a job as global poverty, according to traditional metrics, is on a dramatic downward trend. 

Many middle-income country borrowers are drifting away from the MDBs, since they find other sources of finance and technical advice more attractive. These include the sub-regional development banks, which are more nimble in disbursing their loans and whose governance is not dominated by the industrial countries. These countries, now facing major long-term budget constraints, will be unable to continue supporting the growth of the MDBs’ capital base. But they are also unwilling to let the emerging market economies provide relatively more funding and acquire a greater voice in these institutions.

Finally, while the MDBs retain professional staff that represents a valuable global asset, their technical strength relative to other sources of advice – and by some measures, even their absolute strength – has been waning. 

If left unattended, this would mean that MDBs 10 years from now, while still limping along, are likely to have lost their ability to provide effective financial and technical services on a scale and with a quality that matter globally or regionally. 

3. Give the MDBs a new mandate, new governance and new financing. If one starts from the proposition that a globalised 21st-century world needs capable global institutions that can provide long-term finance to meet critical physical and social infrastructure needs regionally and globally, and that can serve as critical knowledge hubs in an increasingly interconnected world, then it would be folly to let the currently still considerable institutional and financial strengths of the MDBs wither away.

• The mandate of the MDBs should be adapted to move beyond preoccupation with poverty eradication to focus explicitly on global and regional public goods as a way to help sustain global economic growth and human welfare. Moreover, the MDBs should be able to provide assistance to all their members, not only developing country members. 

• The governance of the MDBs should be changed to give the South a voice commensurate with the greater global role it now plays in economic and political terms. MDB leaders should be selected on merit without consideration of nationality. 

• The financing structure should be matched to give more space to capital contributions from the South and to significantly expand the MDBs’ capital resources in the face of the current severe capital constraints.

In addition, MDB management should be guided by banks’ membership to streamline their operational practices in line with those widely used by sub-regional development banks, and they should be supported in preserving and, where possible, strengthening their professional capacity so that they can serve as international knowledge hubs. 

A new MDB agenda for the G20 

The G20 has taken on a vast development agenda. This is fine, but it risks getting bogged down in the minutiae of development policy design and implementation that go far beyond what global leaders can and should deal with. What is missing is a serious preoccupation of the G20 with that issue on which it is uniquely well equipped to lead: reform of the global financial institutional architecture. 

What better place than to start with than the MDBs? The G20 should review the trends, strengths and weaknesses of MDBs in recent decades and endeavour to create new mandates, governance and financing structures that make them serve as effective pillars of the global institutional system in the 21st century. If done correctly, this would also mean no more need for new institutions, such as the BRICS development bank currently being created by Brazil, Russia, India, China and South Africa. It would be far better to fix the existing institutions than to create new ones that mostly add to the already overwhelming fragmentation of the global institutional system.

Event Information

The year 2015 will be a milestone year, with the adoption of the Sustainable Development Goals (SDGs) and the post-2015 development agenda by world leaders in September; the Addis Ababa Accord on financing for development in July; and the conclusion of climate negotiations at COP21 in Paris in December. The draft Addis Ababa Accord, which focuses on the actions needed to attain the SDGs, highlights the key role envisaged for the multilateral development banks (MDBs) in the post-2015 agenda. Paragraph 65 of the draft accord notes: “We call on the international finance institutions to establish a process to examine the role, scale, and functioning of the multilateral and regional development finance institutions to make them more responsive to the sustainable development agenda.”          

Against this backdrop, on April 18, 2015, the Global Economy and Development program at Brookings held a private roundtable with the leaders of the MDBs and other key stakeholders to discuss the role of the MDBs in supporting the post-2015 development agenda.

The meeting focused on four questions:

1. What does the post-2015 development agenda and the ambitions of the Addis and Paris conferences imply for the MDBs?


Given the ability of the MDBs to leverage shareholder resources, they can be efficient and effective mechanisms for scaling up development cooperation, particularly with respect to the agenda on investing in people and to the financing of sustainable infrastructure. New roles, instruments and partnerships might be needed.

2. How can MDBs best take advantage of the political attention that is being paid to the various conferences in 2015?   


The World Bank and selected regional development banks have launched a series of initiatives to optimize their balance sheets, address other constraints and enhance their catalytic role in crowding in private finance. And new institutions and mechanisms are coming to the fore. But the responses are not coordinated to best take advantage of each MDB’s comparative advantage.

3. What are the key impediments to scaling up the role and engagement of the MDBs?


Views on constraints are likely to differ but discussions should cover policy dialogue, capacity building, capital, leverage, shareholder backing on volume, instruments on leverage and risk mitigation, safeguards, and governance. 

4. How should the MDBs respond to the proposal to establish a process to examine the role, scale and functioning of the multilateral and regional development finance institutions to make them more responsive to the sustainable development agenda?   


A proactive response and engagement on the part of the MDBs would facilitate a better understanding of the contribution that the MDBs can make and greater support among shareholders for a coherent and stepped-up role.

Event Materials

• Participant List
• MDB PostEvent Summary

The replenishment process for concessional resources of the multilateral development banks is broken. We have come to this conclusion after a review of the experience with recent replenishments of multilateral development funds. We also base it on first-hand observation, since one of us was responsible for the World Bank’s International Development Association (IDA) replenishment consultations 20 years ago and recently served as the external chair for the last two replenishment consultations of the International Fund for Agricultural Development (IFAD), which closely follow the common multilateral development bank (MDB) practice. As many of the banks and their donors are preparing for midterm reviews as a first step toward the next round of replenishment consultations, this is a good time to take stock and consider what needs to be done to fix the replenishment process.

So what’s the problem?

Most of all, the replenishment process does not serve its key intended function of setting overall operational strategy for the development funds and holding the institutions accountable for effectively implementing the strategy. Instead, the replenishment consultations have turned into a time-consuming and costly process in which donor representatives from their capitals get bogged down in the minutiae of institutional management that are better left to the boards of directors and the managements of the MDBs. There are other problems, including lack of adequate engagement of recipient countries in donors’ deliberations, the lack of full participation of the donors’ representatives on the boards of the institutions in the process, and inflexible governance structures that serve as a disincentive for non-traditional donors (from emerging countries and from private foundations) to contribute.

But let’s focus on the consultation process. What does it look like? Typically, donor representatives from capitals assemble every three years (or four, in the case of the Asian Development Bank) for a year-long consultation round, consisting of four two-day meetings (including the meeting devoted to the midterm review of the ongoing replenishment and to setting the agenda for the next consultation process). For these meetings, MDB staff prepare, per consultation round, some 20 substantive documents that are intended to delve into operational and institutional performance in great detail. Each consultation round produces a long list of specific commitments (around 40 commitments is not uncommon), which management is required to implement and monitor, and report on in the midterm review. In effect, however, this review covers only half the replenishment cycle, which leads to the reporting, monitoring, and accountability being limited to the delivery of committed outputs (e.g., a specific sector strategy) with little attention paid to implementation, let alone outcomes.

The process is eerily reminiscent of the much maligned “Christmas tree” approach of the World Bank’s structural adjustment loans in the 1980s and 1990s, with their detailed matrixes of conditionality; lack of strategic selectivity and country ownership; focus on inputs rather than outcomes; and lack of consideration of the borrowers’ capacity and costs of implementing the Bank-imposed measures. Ironically, the donors successfully pushed the MDBs to give up on such conditionality (without ownership of the recipient countries) in their loans, but they impose the same kind of conditionality (without full ownership of the recipient countries and institutions) on the MDBs themselves—replenishment after replenishment.

Aside from lack of selectivity, strategic focus, and ownership of the commitments, the consultation process is also burdensome and costly in terms of the MDBs’ senior management and staff time as well as time spent by ministerial staff in donor capitals, with literally thousands of management and staff hours spent on producing and reviewing documentation. And the recent innovation of having donor representatives meet between consultation rounds as working groups dealing with long-term strategic issues, while welcome in principle, has imposed further costs on the MDBs and capitals in terms of preparing documentation and meetings.

It doesn’t have to be that way. Twenty years ago the process was much simpler and less costly. Even today, recent MDB capital increases, which mobilized resources for the non-concessional windows of the MDBs, were achieved with much simpler processes, and the replenishment consultations for special purpose funds, such as the Global Fund for HIV/AIDS, tuberculosis, and malaria and for the GAVI Alliance, are more streamlined than those of the MDBs.

So what’s to be done?

We recommend the following measures to fix the replenishment consultation process:

1. Focus on a few strategic issues and reduce the number of commitments with an explicit consideration of the costs and capacity requirements they imply. Shift the balance of monitoring and accountability from delivery of outputs to implementation and outcomes.
2. Prepare no more than five documents for the consultation process: (i) a midterm review on the implementation of the previous replenishment and key issues for the future; (ii) a corporate strategy or strategy update; (iii) the substantive report on how the replenishment resources will contribute to achieve the strategy; (iv) a financial outlook and strategy document; and (v) the legal document of the replenishment resolution.
3. Reduce the number of meetings for each replenishment round to no more than three and lengthen the replenishment period from three to four years or more.
4. Use the newly established working group meetings between replenishment consultation rounds to focus on one or two long-term, strategic issues, including how to fix the replenishment process.

The initiative for such changes lies with the donor representatives in the capitals, and from our interviews with donor representatives we understand that many of them broadly share our concerns. So this is a good time—indeed it is high time!—for them to act.