Accountability in International Development
Emergency Without Evidence: IMF COVID-19 Financing and the Collapse of Fiduciary Standards in Sub-Saharan Africa
How $24 billion in emergency financing was deployed across 35 countries without the governance safeguards the Fund's own frameworks require — and what this means for accountability in the next crisis.
Between April 2020 and December 2021, the IMF approved emergency financing to 35 Sub-Saharan African countries totalling $24.1 billion through its Rapid Financing Instrument and Catastrophe Containment and Relief Trust. This paper examines whether the Fund's accountability architecture — fiduciary risk registers, post-disbursement audits, and remedial procedures — functioned as designed. The findings are negative. Fiduciary risk registers remain unpublished for seventeen countries. Post-disbursement audits are incomplete in nine. In five — including Nigeria, Malawi, and Zimbabwe — documented governance failures have not triggered prescribed remedial procedures. The paper argues that emergency conditions were used to suspend accountability rather than to accelerate it, and that this pattern represents a structural failure requiring institutional reform, not a temporary deviation.
I. The Architecture of Emergency Lending
The IMF's Rapid Financing Instrument was designed for speed. Unlike standard programme lending, which requires an Article IV consultation, a Safeguards Assessment, and a set of structural benchmarks, the RFI can be approved by the Executive Board within days of a member country's request. This speed was deliberately designed for genuine emergencies — balance of payments crises requiring immediate liquidity that cannot wait for the standard programme process.
When COVID-19 struck in March 2020, the Fund deployed the RFI at an unprecedented scale. Between April 2020 and December 2021, it approved 35 disbursements to Sub-Saharan African countries, ranging from $22.4 million to the Comoros to $3.4 billion to Nigeria. The average time from request to Board approval was eleven days.
Speed was appropriate. The governance vacuum that followed was not.
II. The Fiduciary Framework That Was Not Applied
The IMF's own frameworks — the 2005 Guide on Resource Revenue Transparency, the 2019 How to Notes on PFM in emergencies, and the Fund's Safeguards Assessment Policy — provide clear guidance on what should accompany emergency disbursements in low-capacity settings. Fiduciary risk registers should be published within 90 days of disbursement. Commitment to post-disbursement audit is a standard condition. Where pre-existing governance concerns exist — as documented in recent Article IV consultations — enhanced monitoring should be triggered automatically.
None of these mechanisms operated as designed across the majority of the 35 disbursements reviewed in this paper.
| Country | Disbursement | Risk Register Published | Post-Disbursement Audit | Remedial Action |
|---|---|---|---|---|
| Nigeria | $3.4 billion | No | Incomplete | None documented |
| Malawi | $91.1 million | No | Not commenced | None documented |
| Kenya | $739 million | Partial | Complete | Partial |
| Zimbabwe | $962 million | No | Not commenced | None documented |
| Senegal | $442 million | Yes | Complete | N/A |
III. Country Case Studies
Nigeria: The $3.4 Billion Disbursement
Nigeria's April 2020 RFI disbursement of $3.4 billion was the largest single emergency disbursement to any African country in IMF history. It was approved eleven days after the request was received. The Article IV consultation for Nigeria, completed in February 2020, had flagged significant concerns about public financial management — specifically, the weakness of commitment controls at the federal level and the absence of a functioning Treasury Single Account consolidation across parastatals.
These concerns did not delay the disbursement. They did not trigger enhanced monitoring conditions. They have not, as of the date of this paper, been addressed in any published post-disbursement assessment.
The Nigerian government's own audit reports for FY2020 document $1.2 billion in expenditure that could not be matched to approved budget lines. The IMF has not publicly acknowledged this finding in any programme document.
Malawi: Documented Diversion and Institutional Non-Response
Malawi's $91.1 million RFI disbursement in May 2020 was followed, within six months, by documented evidence of misappropriation. The Malawian National Audit Office's June 2021 report identified $9.3 million in COVID-19 fund expenditure that could not be reconciled. The report was tabled in parliament and covered by international media. The IMF's response — a single line in a subsequent staff report acknowledging "PFM weaknesses" — was inadequate by any standard that the Fund's own frameworks would prescribe.
IV. Structural Causes and Institutional Reform
This paper does not argue that the IMF should have withheld emergency financing from countries in acute need. The counterfactual — smaller, slower disbursements through standard programme mechanisms — would have caused genuine harm in 2020. The argument is different: that the choice to move fast on disbursement did not require, and should not have entailed, the suspension of the accountability architecture that should govern what happens after disbursement.
Several structural reforms would address the failure pattern documented here. First, fiduciary risk registers should be mandatory, published, and time-bound for all RFI and CCR Trust disbursements above $100 million. Second, the Fund's existing Safeguards Assessment capacity should be deployed in parallel with disbursement, not deferred to the next Article IV cycle. Third, where member country audit institutions document post-disbursement misappropriation, the IMF should have a defined institutional response procedure — currently none exists.
None of these reforms requires a change to the Fund's Articles of Agreement. All are within the authority of the Executive Board. The question is whether the Board — whose largest shareholders are also among the Fund's largest contributors to the emergency financing pool — has the institutional interest in demanding them.
Accountability in International Development
Emergency Without Evidence: IMF COVID-19 Financing and the Collapse of Fiduciary Standards in Sub-Saharan Africa
How $24 billion in emergency financing was deployed across 35 countries without the governance safeguards the Fund's own frameworks require — and what this means for accountability in the next crisis.
Between April 2020 and December 2021, the IMF approved emergency financing to 35 Sub-Saharan African countries totalling $24.1 billion through its Rapid Financing Instrument and Catastrophe Containment and Relief Trust. This paper examines whether the Fund's accountability architecture — fiduciary risk registers, post-disbursement audits, and remedial procedures — functioned as designed. The findings are negative. Fiduciary risk registers remain unpublished for seventeen countries. Post-disbursement audits are incomplete in nine. In five — including Nigeria, Malawi, and Zimbabwe — documented governance failures have not triggered prescribed remedial procedures. The paper argues that emergency conditions were used to suspend accountability rather than to accelerate it, and that this pattern represents a structural failure requiring institutional reform, not a temporary deviation.
I. The Architecture of Emergency Lending
The IMF's Rapid Financing Instrument was designed for speed. Unlike standard programme lending, which requires an Article IV consultation, a Safeguards Assessment, and a set of structural benchmarks, the RFI can be approved by the Executive Board within days of a member country's request. This speed was deliberately designed for genuine emergencies — balance of payments crises requiring immediate liquidity that cannot wait for the standard programme process.
When COVID-19 struck in March 2020, the Fund deployed the RFI at an unprecedented scale. Between April 2020 and December 2021, it approved 35 disbursements to Sub-Saharan African countries, ranging from $22.4 million to the Comoros to $3.4 billion to Nigeria. The average time from request to Board approval was eleven days.
Speed was appropriate. The governance vacuum that followed was not.
II. The Fiduciary Framework That Was Not Applied
The IMF's own frameworks — the 2005 Guide on Resource Revenue Transparency, the 2019 How to Notes on PFM in emergencies, and the Fund's Safeguards Assessment Policy — provide clear guidance on what should accompany emergency disbursements in low-capacity settings. Fiduciary risk registers should be published within 90 days of disbursement. Commitment to post-disbursement audit is a standard condition. Where pre-existing governance concerns exist — as documented in recent Article IV consultations — enhanced monitoring should be triggered automatically.
None of these mechanisms operated as designed across the majority of the 35 disbursements reviewed in this paper.
| Country | Disbursement | Risk Register Published | Post-Disbursement Audit | Remedial Action |
|---|---|---|---|---|
| Nigeria | $3.4 billion | No | Incomplete | None documented |
| Malawi | $91.1 million | No | Not commenced | None documented |
| Kenya | $739 million | Partial | Complete | Partial |
| Zimbabwe | $962 million | No | Not commenced | None documented |
| Senegal | $442 million | Yes | Complete | N/A |
III. Country Case Studies
Nigeria: The $3.4 Billion Disbursement
Nigeria's April 2020 RFI disbursement of $3.4 billion was the largest single emergency disbursement to any African country in IMF history. It was approved eleven days after the request was received. The Article IV consultation for Nigeria, completed in February 2020, had flagged significant concerns about public financial management — specifically, the weakness of commitment controls at the federal level and the absence of a functioning Treasury Single Account consolidation across parastatals.
These concerns did not delay the disbursement. They did not trigger enhanced monitoring conditions. They have not, as of the date of this paper, been addressed in any published post-disbursement assessment.
The Nigerian government's own audit reports for FY2020 document $1.2 billion in expenditure that could not be matched to approved budget lines. The IMF has not publicly acknowledged this finding in any programme document.
Malawi: Documented Diversion and Institutional Non-Response
Malawi's $91.1 million RFI disbursement in May 2020 was followed, within six months, by documented evidence of misappropriation. The Malawian National Audit Office's June 2021 report identified $9.3 million in COVID-19 fund expenditure that could not be reconciled. The report was tabled in parliament and covered by international media. The IMF's response — a single line in a subsequent staff report acknowledging "PFM weaknesses" — was inadequate by any standard that the Fund's own frameworks would prescribe.
IV. Structural Causes and Institutional Reform
This paper does not argue that the IMF should have withheld emergency financing from countries in acute need. The counterfactual — smaller, slower disbursements through standard programme mechanisms — would have caused genuine harm in 2020. The argument is different: that the choice to move fast on disbursement did not require, and should not have entailed, the suspension of the accountability architecture that should govern what happens after disbursement.
Several structural reforms would address the failure pattern documented here. First, fiduciary risk registers should be mandatory, published, and time-bound for all RFI and CCR Trust disbursements above $100 million. Second, the Fund's existing Safeguards Assessment capacity should be deployed in parallel with disbursement, not deferred to the next Article IV cycle. Third, where member country audit institutions document post-disbursement misappropriation, the IMF should have a defined institutional response procedure — currently none exists.
None of these reforms requires a change to the Fund's Articles of Agreement. All are within the authority of the Executive Board. The question is whether the Board — whose largest shareholders are also among the Fund's largest contributors to the emergency financing pool — has the institutional interest in demanding them.
Accountability in International Development
Emergency Without Evidence: IMF COVID-19 Financing and the Collapse of Fiduciary Standards in Sub-Saharan Africa
How $24 billion in emergency financing was deployed across 35 countries without the governance safeguards the Fund's own frameworks require — and what this means for accountability in the next crisis.
Between April 2020 and December 2021, the IMF approved emergency financing to 35 Sub-Saharan African countries totalling $24.1 billion through its Rapid Financing Instrument and Catastrophe Containment and Relief Trust. This paper examines whether the Fund's accountability architecture — fiduciary risk registers, post-disbursement audits, and remedial procedures — functioned as designed. The findings are negative. Fiduciary risk registers remain unpublished for seventeen countries. Post-disbursement audits are incomplete in nine. In five — including Nigeria, Malawi, and Zimbabwe — documented governance failures have not triggered prescribed remedial procedures. The paper argues that emergency conditions were used to suspend accountability rather than to accelerate it, and that this pattern represents a structural failure requiring institutional reform, not a temporary deviation.
I. The Architecture of Emergency Lending
The IMF's Rapid Financing Instrument was designed for speed. Unlike standard programme lending, which requires an Article IV consultation, a Safeguards Assessment, and a set of structural benchmarks, the RFI can be approved by the Executive Board within days of a member country's request. This speed was deliberately designed for genuine emergencies — balance of payments crises requiring immediate liquidity that cannot wait for the standard programme process.
When COVID-19 struck in March 2020, the Fund deployed the RFI at an unprecedented scale. Between April 2020 and December 2021, it approved 35 disbursements to Sub-Saharan African countries, ranging from $22.4 million to the Comoros to $3.4 billion to Nigeria. The average time from request to Board approval was eleven days.
Speed was appropriate. The governance vacuum that followed was not.
II. The Fiduciary Framework That Was Not Applied
The IMF's own frameworks — the 2005 Guide on Resource Revenue Transparency, the 2019 How to Notes on PFM in emergencies, and the Fund's Safeguards Assessment Policy — provide clear guidance on what should accompany emergency disbursements in low-capacity settings. Fiduciary risk registers should be published within 90 days of disbursement. Commitment to post-disbursement audit is a standard condition. Where pre-existing governance concerns exist — as documented in recent Article IV consultations — enhanced monitoring should be triggered automatically.
None of these mechanisms operated as designed across the majority of the 35 disbursements reviewed in this paper.
| Country | Disbursement | Risk Register Published | Post-Disbursement Audit | Remedial Action |
|---|---|---|---|---|
| Nigeria | $3.4 billion | No | Incomplete | None documented |
| Malawi | $91.1 million | No | Not commenced | None documented |
| Kenya | $739 million | Partial | Complete | Partial |
| Zimbabwe | $962 million | No | Not commenced | None documented |
| Senegal | $442 million | Yes | Complete | N/A |
III. Country Case Studies
Nigeria: The $3.4 Billion Disbursement
Nigeria's April 2020 RFI disbursement of $3.4 billion was the largest single emergency disbursement to any African country in IMF history. It was approved eleven days after the request was received. The Article IV consultation for Nigeria, completed in February 2020, had flagged significant concerns about public financial management — specifically, the weakness of commitment controls at the federal level and the absence of a functioning Treasury Single Account consolidation across parastatals.
These concerns did not delay the disbursement. They did not trigger enhanced monitoring conditions. They have not, as of the date of this paper, been addressed in any published post-disbursement assessment.
The Nigerian government's own audit reports for FY2020 document $1.2 billion in expenditure that could not be matched to approved budget lines. The IMF has not publicly acknowledged this finding in any programme document.
Malawi: Documented Diversion and Institutional Non-Response
Malawi's $91.1 million RFI disbursement in May 2020 was followed, within six months, by documented evidence of misappropriation. The Malawian National Audit Office's June 2021 report identified $9.3 million in COVID-19 fund expenditure that could not be reconciled. The report was tabled in parliament and covered by international media. The IMF's response — a single line in a subsequent staff report acknowledging "PFM weaknesses" — was inadequate by any standard that the Fund's own frameworks would prescribe.
IV. Structural Causes and Institutional Reform
This paper does not argue that the IMF should have withheld emergency financing from countries in acute need. The counterfactual — smaller, slower disbursements through standard programme mechanisms — would have caused genuine harm in 2020. The argument is different: that the choice to move fast on disbursement did not require, and should not have entailed, the suspension of the accountability architecture that should govern what happens after disbursement.
Several structural reforms would address the failure pattern documented here. First, fiduciary risk registers should be mandatory, published, and time-bound for all RFI and CCR Trust disbursements above $100 million. Second, the Fund's existing Safeguards Assessment capacity should be deployed in parallel with disbursement, not deferred to the next Article IV cycle. Third, where member country audit institutions document post-disbursement misappropriation, the IMF should have a defined institutional response procedure — currently none exists.
None of these reforms requires a change to the Fund's Articles of Agreement. All are within the authority of the Executive Board. The question is whether the Board — whose largest shareholders are also among the Fund's largest contributors to the emergency financing pool — has the institutional interest in demanding them.
Accountability in International Development
Emergency Without Evidence: IMF COVID-19 Financing and the Collapse of Fiduciary Standards in Sub-Saharan Africa
How $24 billion in emergency financing was deployed across 35 countries without the governance safeguards the Fund's own frameworks require — and what this means for accountability in the next crisis.
Between April 2020 and December 2021, the IMF approved emergency financing to 35 Sub-Saharan African countries totalling $24.1 billion through its Rapid Financing Instrument and Catastrophe Containment and Relief Trust. This paper examines whether the Fund's accountability architecture — fiduciary risk registers, post-disbursement audits, and remedial procedures — functioned as designed. The findings are negative. Fiduciary risk registers remain unpublished for seventeen countries. Post-disbursement audits are incomplete in nine. In five — including Nigeria, Malawi, and Zimbabwe — documented governance failures have not triggered prescribed remedial procedures. The paper argues that emergency conditions were used to suspend accountability rather than to accelerate it, and that this pattern represents a structural failure requiring institutional reform, not a temporary deviation.
I. The Architecture of Emergency Lending
The IMF's Rapid Financing Instrument was designed for speed. Unlike standard programme lending, which requires an Article IV consultation, a Safeguards Assessment, and a set of structural benchmarks, the RFI can be approved by the Executive Board within days of a member country's request. This speed was deliberately designed for genuine emergencies — balance of payments crises requiring immediate liquidity that cannot wait for the standard programme process.
When COVID-19 struck in March 2020, the Fund deployed the RFI at an unprecedented scale. Between April 2020 and December 2021, it approved 35 disbursements to Sub-Saharan African countries, ranging from $22.4 million to the Comoros to $3.4 billion to Nigeria. The average time from request to Board approval was eleven days.
Speed was appropriate. The governance vacuum that followed was not.
II. The Fiduciary Framework That Was Not Applied
The IMF's own frameworks — the 2005 Guide on Resource Revenue Transparency, the 2019 How to Notes on PFM in emergencies, and the Fund's Safeguards Assessment Policy — provide clear guidance on what should accompany emergency disbursements in low-capacity settings. Fiduciary risk registers should be published within 90 days of disbursement. Commitment to post-disbursement audit is a standard condition. Where pre-existing governance concerns exist — as documented in recent Article IV consultations — enhanced monitoring should be triggered automatically.
None of these mechanisms operated as designed across the majority of the 35 disbursements reviewed in this paper.
| Country | Disbursement | Risk Register Published | Post-Disbursement Audit | Remedial Action |
|---|---|---|---|---|
| Nigeria | $3.4 billion | No | Incomplete | None documented |
| Malawi | $91.1 million | No | Not commenced | None documented |
| Kenya | $739 million | Partial | Complete | Partial |
| Zimbabwe | $962 million | No | Not commenced | None documented |
| Senegal | $442 million | Yes | Complete | N/A |
III. Country Case Studies
Nigeria: The $3.4 Billion Disbursement
Nigeria's April 2020 RFI disbursement of $3.4 billion was the largest single emergency disbursement to any African country in IMF history. It was approved eleven days after the request was received. The Article IV consultation for Nigeria, completed in February 2020, had flagged significant concerns about public financial management — specifically, the weakness of commitment controls at the federal level and the absence of a functioning Treasury Single Account consolidation across parastatals.
These concerns did not delay the disbursement. They did not trigger enhanced monitoring conditions. They have not, as of the date of this paper, been addressed in any published post-disbursement assessment.
The Nigerian government's own audit reports for FY2020 document $1.2 billion in expenditure that could not be matched to approved budget lines. The IMF has not publicly acknowledged this finding in any programme document.
Malawi: Documented Diversion and Institutional Non-Response
Malawi's $91.1 million RFI disbursement in May 2020 was followed, within six months, by documented evidence of misappropriation. The Malawian National Audit Office's June 2021 report identified $9.3 million in COVID-19 fund expenditure that could not be reconciled. The report was tabled in parliament and covered by international media. The IMF's response — a single line in a subsequent staff report acknowledging "PFM weaknesses" — was inadequate by any standard that the Fund's own frameworks would prescribe.
IV. Structural Causes and Institutional Reform
This paper does not argue that the IMF should have withheld emergency financing from countries in acute need. The counterfactual — smaller, slower disbursements through standard programme mechanisms — would have caused genuine harm in 2020. The argument is different: that the choice to move fast on disbursement did not require, and should not have entailed, the suspension of the accountability architecture that should govern what happens after disbursement.
Several structural reforms would address the failure pattern documented here. First, fiduciary risk registers should be mandatory, published, and time-bound for all RFI and CCR Trust disbursements above $100 million. Second, the Fund's existing Safeguards Assessment capacity should be deployed in parallel with disbursement, not deferred to the next Article IV cycle. Third, where member country audit institutions document post-disbursement misappropriation, the IMF should have a defined institutional response procedure — currently none exists.
None of these reforms requires a change to the Fund's Articles of Agreement. All are within the authority of the Executive Board. The question is whether the Board — whose largest shareholders are also among the Fund's largest contributors to the emergency financing pool — has the institutional interest in demanding them.
Accountability in International Development
Emergency Without Evidence: IMF COVID-19 Financing and the Collapse of Fiduciary Standards in Sub-Saharan Africa
How $24 billion in emergency financing was deployed across 35 countries without the governance safeguards the Fund's own frameworks require — and what this means for accountability in the next crisis.
Between April 2020 and December 2021, the IMF approved emergency financing to 35 Sub-Saharan African countries totalling $24.1 billion through its Rapid Financing Instrument and Catastrophe Containment and Relief Trust. This paper examines whether the Fund's accountability architecture — fiduciary risk registers, post-disbursement audits, and remedial procedures — functioned as designed. The findings are negative. Fiduciary risk registers remain unpublished for seventeen countries. Post-disbursement audits are incomplete in nine. In five — including Nigeria, Malawi, and Zimbabwe — documented governance failures have not triggered prescribed remedial procedures. The paper argues that emergency conditions were used to suspend accountability rather than to accelerate it, and that this pattern represents a structural failure requiring institutional reform, not a temporary deviation.
I. The Architecture of Emergency Lending
The IMF's Rapid Financing Instrument was designed for speed. Unlike standard programme lending, which requires an Article IV consultation, a Safeguards Assessment, and a set of structural benchmarks, the RFI can be approved by the Executive Board within days of a member country's request. This speed was deliberately designed for genuine emergencies — balance of payments crises requiring immediate liquidity that cannot wait for the standard programme process.
When COVID-19 struck in March 2020, the Fund deployed the RFI at an unprecedented scale. Between April 2020 and December 2021, it approved 35 disbursements to Sub-Saharan African countries, ranging from $22.4 million to the Comoros to $3.4 billion to Nigeria. The average time from request to Board approval was eleven days.
Speed was appropriate. The governance vacuum that followed was not.
II. The Fiduciary Framework That Was Not Applied
The IMF's own frameworks — the 2005 Guide on Resource Revenue Transparency, the 2019 How to Notes on PFM in emergencies, and the Fund's Safeguards Assessment Policy — provide clear guidance on what should accompany emergency disbursements in low-capacity settings. Fiduciary risk registers should be published within 90 days of disbursement. Commitment to post-disbursement audit is a standard condition. Where pre-existing governance concerns exist — as documented in recent Article IV consultations — enhanced monitoring should be triggered automatically.
None of these mechanisms operated as designed across the majority of the 35 disbursements reviewed in this paper.
| Country | Disbursement | Risk Register Published | Post-Disbursement Audit | Remedial Action |
|---|---|---|---|---|
| Nigeria | $3.4 billion | No | Incomplete | None documented |
| Malawi | $91.1 million | No | Not commenced | None documented |
| Kenya | $739 million | Partial | Complete | Partial |
| Zimbabwe | $962 million | No | Not commenced | None documented |
| Senegal | $442 million | Yes | Complete | N/A |
III. Country Case Studies
Nigeria: The $3.4 Billion Disbursement
Nigeria's April 2020 RFI disbursement of $3.4 billion was the largest single emergency disbursement to any African country in IMF history. It was approved eleven days after the request was received. The Article IV consultation for Nigeria, completed in February 2020, had flagged significant concerns about public financial management — specifically, the weakness of commitment controls at the federal level and the absence of a functioning Treasury Single Account consolidation across parastatals.
These concerns did not delay the disbursement. They did not trigger enhanced monitoring conditions. They have not, as of the date of this paper, been addressed in any published post-disbursement assessment.
The Nigerian government's own audit reports for FY2020 document $1.2 billion in expenditure that could not be matched to approved budget lines. The IMF has not publicly acknowledged this finding in any programme document.
Malawi: Documented Diversion and Institutional Non-Response
Malawi's $91.1 million RFI disbursement in May 2020 was followed, within six months, by documented evidence of misappropriation. The Malawian National Audit Office's June 2021 report identified $9.3 million in COVID-19 fund expenditure that could not be reconciled. The report was tabled in parliament and covered by international media. The IMF's response — a single line in a subsequent staff report acknowledging "PFM weaknesses" — was inadequate by any standard that the Fund's own frameworks would prescribe.
IV. Structural Causes and Institutional Reform
This paper does not argue that the IMF should have withheld emergency financing from countries in acute need. The counterfactual — smaller, slower disbursements through standard programme mechanisms — would have caused genuine harm in 2020. The argument is different: that the choice to move fast on disbursement did not require, and should not have entailed, the suspension of the accountability architecture that should govern what happens after disbursement.
Several structural reforms would address the failure pattern documented here. First, fiduciary risk registers should be mandatory, published, and time-bound for all RFI and CCR Trust disbursements above $100 million. Second, the Fund's existing Safeguards Assessment capacity should be deployed in parallel with disbursement, not deferred to the next Article IV cycle. Third, where member country audit institutions document post-disbursement misappropriation, the IMF should have a defined institutional response procedure — currently none exists.
None of these reforms requires a change to the Fund's Articles of Agreement. All are within the authority of the Executive Board. The question is whether the Board — whose largest shareholders are also among the Fund's largest contributors to the emergency financing pool — has the institutional interest in demanding them.