Sovereign Wealth Funds: New Challenges from a Changing Landscape
by Edwin M. Truman, Peterson Institute for International Economics
Testimony before the Subcommittee on Domestic and International Monetary Policy, Trade and Technology, Financial Services Committee, US House of Representatives
September 10, 2008
Download text with tables [pdf]
Chairman Gutierrez and members of the Subcommittee on Domestic and International Monetary Policy, it is a pleasure to testify before you today on the challenges posed by sovereign wealth funds.
The broadest definition of a sovereign wealth fund (SWF) is a collection of government-owned or government-controlled assets. Narrower definitions may exclude such assets as government financial or nonfinancial corporations, purely domestic assets, foreign exchange reserves, assets owned or controlled by subnational governmental units, or some or all government pension funds. However, it is useful to keep these broader concepts in mind when discussing SWFs. The reason is that many of the anxieties that are conventionally associated with SWFs, narrowly defined, more appropriately are concerns about the management of government assets other than those of sovereign wealth funds.
The accountability of SWFs has been the focus of my research and analysis. I use "sovereign wealth fund" as a relatively broad descriptive term for a separate pool of government-owned or government-controlled assets that includes some international assets. I include all government pension, as well as nonpension, funds to the extent that they manage marketable assets. The basic objectives of both types of SWFs are essentially the same. They raise virtually identical issues of best practice with respect to government control and accountability regardless of their specific objectives, mandates, or sources of funding.
Sovereign wealth funds, on my terms, may be funded from foreign exchange reserves, earnings from commodity exports, receipts from privatizations, other fiscal revenues, or pension contributions. (Table 1 [pdf] lists 56 sovereign wealth funds of 38 countries.) These funds have been around for more than half a century with a range of structures, mandates, and economic, financial, and political (primarily domestic, but in some cases maybe international) objectives—normally a mixture.1 Consequently, it is perilous to generalize about sovereign wealth funds and any associated threats to US economic and financial interests.
With that important qualification, my six summary conclusions are:
It is useful to place the activities of sovereign wealth funds in a broader perspective. The size of global capital markets is at least $200 trillion.2 A conservative estimate of financial assets owned or controlled by governments is $15 trillion, or about 8 percent of global financial assets.3 Governments in the United States own or control more than $3 trillion (20 percent) of the global governmental total.4 The United States is in the business of sovereign wealth management.
International assets owned or controlled by governments are at least $10 trillion: $6 trillion in foreign exchange reserves, $2.7 trillion in assets of nonpension SWFs, and at least $1.3 trillion in government pension funds.5 Excluding our modest holdings of foreign exchange reserves, the international assets of US SWFs are about $800 billion mostly in the form of the pension funds of state and local governments. The aggregate amount of international assets held by US sovereign wealth funds is second only to the estimated SWF holdings of the United Arab Emirates.
As an additional point of reference, at the end of 2007, US total holdings of foreign assets were $15.4 trillion. About 93 percent was managed by the private sector. Foreign holdings of US assets were $17.9 trillion. About 80 percent was managed by the private sector.6 US holdings of international financial assets are about 20 percent of the global total.
Over the past five years, the size of the global capital market has doubled, but asset holdings of SWFs have quadrupled. I expect them to continue to expand rapidly. The explosive growth of SWFs reflects the sustained rise in commodity prices as well as aspects of global imbalances. However, the increased international diversification of financial portfolios—the weakening investors' so-called home bias—is at least as significant as macroeconomic factors in explaining the growth of SWFs.
In my judgment, it is a mistake to conflate the important issues raised by the growth of sovereign wealth funds with the probably more serious issues raised by global imbalances, in general, and our large and continuing current account deficits, in particular. As evidence, consider the fact that in Germany there is great concern about sovereign wealth fund investments, but Germany is in perpetual current account surplus and has a positive net international investment position. SWFs are part of the ongoing globalization of the international financial system.
The increasing relative importance of SWFs has exposed two tensions.
The first is the dramatic redistribution of international (or cross-border) wealth from the traditional industrial countries, like the United States, to countries that historically have not been major players in international finance. The newcomers have had little or no role in shaping the practices, norms, and conventions governing the system. Consequently, the leaders and citizens of many of those countries feel they have little stake in the health and stability of the international financial system.
The second is the fact that governments own or control a substantial share of the new international wealth. This redistribution from private to public hands implies a decision-making orientation that is at variance with the traditional private-sector, market-oriented framework with which most of us are comfortable even though our own system does not fully conform to that ideal; witness the current tribulations of our so-called government-sponsored agencies.
These twin tensions, in turn, are manifested in five more specific concerns.
First, home governments may mismanage the international investments of their SWFs, damaging their own economic and financial health and stability, including via large-scale corruption in handling the huge amounts involved. It is a well-known, though often ignored, regularity that governments are not good at picking economic winners; for example, government-owned banks tend to be less profitable than private banks. These concerns about financial mismanagement are the principal reason why it is in the interests of the citizens of every country with an SWF to favor the establishment of internationally agreed SWF best practices.
Second, governments may manage their SWF investments in pursuit of political objectives, raising national security concerns, or economic power objectives—for example, promoting state-owned or state-controlled national champions as global champions. Such behavior contributes not only to political conflicts between countries but also to economic distortions.
Third, financial protectionism may be encouraged in host countries in anticipation of the pursuit of political or economic objectives by the funds or in response to their actual actions. Development of and compliance with SWF best practices would help to diffuse this source of backlash against globalization. At the same time, countries receiving SWF investments should be as open as possible to such investments subject to the constraints of national security considerations narrowly defined.
Fourth, in the management of their international assets, SWFs may contribute to market turmoil and uncertainty. They also may contribute to financial stability, but their net contribution is difficult to establish a priori, in particular if their operations are opaque but also because judgments can be reached only on a case by case basis.
Fifth, foreign government owners of the international assets may come into conflict with the governments of the countries in which they are investing. For example, government ownership adds a further dimension in balancing open markets and appropriate conventional microprudential, as well as the newly rediscovered macroprudential, supervision and regulation of the financial system.
At this point, these concerns, with the important exception of the first—potential adverse economic and financial implications for the countries with the SWFs—are largely in the realm of the hypothetical. The others are much more salient in the context of cross-border investments by government-owned or government-controlled financial or nonfinancial corporations. Nevertheless, a loud, often acrimonious, public discourse about SWFs is under way in many countries, not only in the countries receiving SWF investments but also in the countries making the investments.
The challenge is to make the world safe for sovereign wealth funds.
Starting in May 2007, I have advocated the establishment of an internationally agreed voluntary set of best practices for SWFs. My view was that the natural place to start was with the current practices of individual funds today. To this end, I created a scoreboard for 46 of the 56 funds listed in table 1 [pdf], including the 12 pension SWFs.7 The scoreboard rates funds on their current practices and includes 33 elements grouped in four categories: (1) structure, (2) governance, (3) accountability and transparency, and (3) behavior. We have the funds based on systematic, regularly available, public information. At least one fund receives a positive score on each element. In fact, at a minimum, several do.
Table 2 [pdf] provides a summary of the scoreboard results for all elements and for each of the four categories.8 Let me offer a few summary observations:
First, all sovereign wealth funds are not the same. Nor is there one cluster of "good" funds and another cluster of "bad" funds. The overall scores range from 95 to 9 out a possible 100. The rating of each fund can be improved.
Second, the funds are in three broad groups: 22 funds with scores above 60, 14 funds with scores below 30, and 10 funds in a middle group. The top group includes funds of a number of developing countries, including Thailand (84), Timor-Leste (80), Azerbaijan (77), China's pension fund (77), Chile (71), and Kazakhstan (71). The middle group includes funds of nonindustrial countries as diverse as Russia (51), Mexico (49), Kuwait (48), and Singapore, whose two funds are in this group (45 and 41). Singapore's two funds have close-to-identical overall scores, but their scores differ on several individual elements. The bottom group includes two funds from Abu Dhabi (15 and 9) each of which, nevertheless, reportedly has an excellent reputation in financial markets.
Third, as you can see from table 2 [pdf], there is a strong correlation (0.967) between the total scores for the 46 SWFs and the category of accountability and transparency. Many commentators like to stress the transparency of SWFs, but in my view the central issue is their accountability to their own citizens (as direct or indirect owners of the assets), to citizens (including government officials) in the countries in which they invest, and to participants in financial markets. Transparency is only a means to this end.
Fourth, 11 nonpension SWFs have estimated assets more than $60 billion. We scored nine of these funds.9 Two are in the top group (those of Norway (92) and Hong Kong (67)) and two are in the bottom group (one in Abu Dhabi (9) and one in Qatar(9)).
Fifth, again focusing on the nine largest nonpension funds that we scored, four funds say that their investment decisions are made exclusively by investment managers (Norway (92), Kuwait (48), and the two Singapore funds (45 and 41)). We could find no such statements for the other five funds (Hong Kong (67), Russia (51), China's investment corporation (29), Abu Dhabi (9), and Qatar (9)).10
Taking this information at face value, would it be right to infer that in the first four cases there is no political influence on investment decisions and in second five cases investment decisions are guided by political considerations? Quite frankly, I doubt it. In the latter cases, it is reasonable to conclude that the political authorities may influence, guide, or approve major investment decisions. We know that is the case for China Investment Corporation.
In the former cases, it is difficult to conclude that political considerations are completely absent from investment decisions. For example, it would be a stretch to imagine that the investment managers in Singapore's Government Investment Corporation or Temasek did not consider the potential international (and domestic) political ramifications of their large investments in foreign financial institutions before they committed to making them. This observation merely reinforces my earlier point: When a government entity makes an investment decision (no matter how it is formally structured to insulate it from political pressures), its decisions will be interpreted at home and abroad through a political lens. Just ask the Norwegians about the brouhaha over their reported disinvestment in Icelandic government bonds!
Finally, although each of the 12 representative pension SWFs is in the top group, that group of 22 funds also includes 10 nonpension SWFs. Thus, it is not unreasonable, in my view, to hold nonpension SWFs to the standard of accountability of pension funds. Chile's pension and nonpension SWFs both score in the top group (71). On the other hand, China's National Social Security Fund is in the top group (77), but the China Investment Corporation is in the bottom group (29). It is reasonable to ask why the latter entity cannot be as accountable as is the former entity.
Turning to the issue of sovereign wealth funds and their potential to disrupt financial markets, any investor with a large portfolio has that potential whatever his or her motivation. However, the very size of such portfolios helps to inhibit them from doing so, in other words, discourages them from shooting themselves in their feet.
At the same time, it is inappropriate in my opinion to view SWFs as cornucopias available to be tapped to rescue the US or the global financial system. For every SWF investment in a US financial institution, that fund has to disinvest, or not invest, in some other asset, normally in the United States or at least in US dollars. If they invest in Citigroup, they don't invest in General Motors.
Some observers of private equity firms and hedge funds have concerns about the implications of such entities for the stability of our economy and financial system. I do not share most of those concerns though I have long favored increased accountability for large private equity firms and hedge funds. However, the facts do not support those who argue that SWFs are not like hedge funds and private equity firms in their speculative activities. Sovereign wealth funds invest in hedge funds, in private equity firms, and in other highly leveraged financial institutions whose activities, including the use of leverage, are indistinguishable from hedge funds and private equity firms. In effect, sovereign wealth funds are providing the capital that those firms subsequently leverage to generate high rates of return for the funds. They are no different from other investors except that their stakes may be measured in the billions rather than in the hundreds of millions of dollars.
Should we be concerned about SWF investments in US financial institutions? In most countries, financial institutions are subject to special regulatory regimes, in part, because they are viewed as quasi-public utilities and, in part, because financial institutions have special privileges in the form of access to discount windows, deposit insurance, and payments systems. The basic question is whether foreign government ownership, even if indirect or noncontrolling, is compatible with this special status.
Even in the case of a stake that is less than, say, 5 percent and not associated with board membership, will the government of the sovereign wealth fund that is a shareholder seek to exercise what I would call "undue influence" over the financial institution in its business and investment decisions? Or otherwise come into conflict with US government regulators and supervisors? "Undue influence" is a vague term. Presumably all shareholders, exercising their shareholder rights, seek to influence the decisions of the entities in which they have stakes. Nevertheless, in my view, this is more of a problem in the case of investments in regulated financial institutions than in the case of investments in nonfinancial institutions, whose assets are less portable. Therefore, it is reasonable to ask the supervisors and regulators what procedures they have in place to reduce the probability that the government owners of sovereign wealth funds do not seek to exercise "undue influence" over the decisions of financial institutions in which they have significant stakes.11
At the same time, it is highly probable that foreign investors—governmental or nongovernmental—in US financial or nonfinancial institutions will complicate the enforcement of US securities laws. But this is a fact of life in the 21st century. It does not provide a sufficient basis for limiting or barring such investments. Financial markets are global. This reality presents enforcement challenges. Limiting portfolio investments to countries that are currently our friends does not eliminate potential problems. There is often no consensus about who are our "friends," and today's friends may be regarded differently tomorrow. Moreover, as we learned in the case of Crédit Lyonnaise and Equitable Life, which involved the French government, blood is thicker than water.
What about those SWF investments in hedge funds and private equity firms? Are they a matter for concern? As I see it, in effect, the SWFs are hiring these entities to manage their investments and maybe to develop some additional expertise for the SWF as a byproduct. Whether one approves of such investments depends on one's view of the activities of hedge funds and private equity firms. Sentiment is not uniform on such matters. In my view, the principal concern is the nature of the contract between the SWF and the hedge fund or private equity firm. If it is an arms-length contract, then I would have no concern. If the SWF can direct and shape the investment policies of the entity, I would have more concern. As I said earlier, I favor greater accountability by large hedge funds and private equity firms in general, and not just to their counterparties but also to the general public and including about the nature of arrangements with their principal investors.
How should the US Congress and the administration address sovereign wealth fund investments in the United States? Notwithstanding my view that the greatest economic and financial risks associated with SWFs are to the citizens of the countries whose governments have accumulated the large stocks of international assets, authorities in the United States and other countries where those assets are invested also have legitimate concerns about how they will be managed. Those concerns focus primarily on acquisition of large or controlling stakes by foreign governments in private institutions. At present, this is the exception not the rule for SWFs.
My interpretation of the recent exhaustive report by the Monitor Group on equity investments by sovereign wealth funds is that they are rather small in aggregate. The global total value of all "deals" from 2000 to the first quarter of this year was reported to be $250 billion, less than 10 percent of the assets of SWFs, and many of those deals did not involve controlling stakes.12 However, one area of concern and potential conflict is the apparent use by a few countries, such as China and potentially Brazil, of their SWFs to promote the expansion of their own economic enterprises.
Of course, the current, largely benign pattern could change, and foreign government-owned or government-controlled financial and nonfinancial corporations do acquire stakes in companies, including controlling stakes. The 2007 Foreign Investment and National Security Act (FINSA) revised the framework and procedures of the Committee on Foreign Investment in the United States (CFIUS). With these changes and the existing powers of the Securities and Exchange Commission as well as other US financial regulators, we are well positioned to evaluate and, if necessary, to mitigate, block, or pursue any US acquisitions or investment by an SWF or other foreign government entity to protect our national security or to enforce our laws and regulations governing financial markets and institutions.
With respect to economic security concerns, the greatest risk to the US economy is that we will erect unnecessary barriers to the free flow of capital into our economy and, in the process, contribute to the erection of similar barriers in other countries to the detriment of the health and continued prosperity of the US and global economies. We may not in all cases be comfortable with the consequences of the free flow of finance and investment either internally or across borders, but on balance it promotes competition and efficiency.
The challenges posed by SWFs to the countries with the funds and to the international financial system require, in my view, a multilateral, two-pronged approach of what I would call "reciprocal responsibility" by the countries with the SWFs and by the countries receiving investments by them.
To this end, I have advocated the establishment of an internationally agreed voluntary set of best practices for SWFs. The news on this front is positive.
Last week it was announced that the IMF-sponsored International Working Group of Sovereign Wealth Funds had reached agreement in principle on Generally Accepted Principles and Practices (GAPP) for Sovereign Wealth Funds covering their institutional framework, governance, and investment operations—the so-called Santiago Principles. I do not think it is important whether the resulting document is called principles, practices, or both. I do not think it is important whether they are "generally accepted" or "best." What is important is the content, which we do not know yet. The reports I have read are encouraging. I am confident that the content will be less than perfect, but members of this committee understand that in politics compromise is necessary if you are going to get anything done. I will be surprised if the GAPP template does not "score" at least 70 on my scoreboard.
I believe that the IMF should be congratulated on facilitating an agreement in record time—less than a year since the first call by the International Monetary and Financial Committee (IMFC) and less than six months after the start of intensive work. It is significant that the agreement is expected to be embraced by 23 countries, including all but one country with a nonpension SWF with more than $50 billion in foreign assets. (The exception is Hong Kong. Saudi Arabia was an observer, and as a formal matter does not have an SWF.) Over the next year, I expect that there will be a substantial improvement in the scores of most SWFs on my scoreboard.
I know that there are concerns about the voluntary nature of this agreement and about its enforcement. I would point out that very few international agreements have enforcement mechanisms, which does not mean that they are useless. Moreover, in the case of SWFs, we need to be sensitive to the risk of regulatory arbitrage. If too much emphasis is placed on sovereign wealth funds as defined in the Santiago Principles, countries will just disband their funds and conduct the same activities through more clandestine means.
The second prong of reciprocal responsibility regarding SWFs involves strengthening the investment frameworks of countries that receive SWF investments to ensure that appropriate investments are welcomed. This involves primarily the industrial or OECD countries. Again, doing so is in the interests of the recipient countries as well as the investing countries.
A less-well-publicized exercise to this end is under way in the Organization for Economic Cooperation and Development (OECD) headquartered in Paris. It seeks to build on existing Declarations and Codes of that organization. A June 4–5, 2008 OECD Ministerial Council Meeting in Paris adopted a Declaration on Sovereign Wealth Funds that weakly called for recipient countries not to erect protectionist barriers, not to discriminate among investors in like circumstances, and to restrict the use of safeguards where are national security concerns are involved. The OECD process is not scheduled for completion until next year.
How are observers to judge results to date or in prospect and are they likely to be sufficient to provide comfort to countries that are not members of the OECD seeking to invest in those countries with their SWFs? I have three concerns.
First, OECD investment codes are binding only on investments from other members. Members commit to use their best efforts to extend them to nonmembers, but this is a potential loophole that should be closed.
Second, a country's decision to invoke the national security "exemption" from a policy of open investment is not subject to appeal or discussion even within the OECD as part of its so-called peer review process. The country alone makes the decision.
Third, more than half of OECD members have lists of sectors closed off from foreign investment. Links to national security for some of them are tenuous, for example, maritime dredging and salvaging in the United States. It is noteworthy that Germany's proposed new foreign investment legislation will also have a test of "public order" as well as national security. Furthermore, Canada recently prevented Alliant Techsystems of the United States from buying the space technology division of MacDonald-Dettwiler, which specializes in satellites and space robotics. This seems like a questionable national security call for such close allies. As another example, Japan rejected the Children's Investment Fund's expanded investment in a Japanese power producer on the grounds of a potential disruption of "public order." Finally, New Zealand recently prevented the Canada Pension Plan from buying a substantial stake in the Auckland airport because the investment failed to meet the test of being a "benefit to New Zealand."
What are we to conclude about the OECD efforts? My conclusion is that OECD members have more work to do.
In conclusion, the phenomenon of sovereign wealth funds is a permanent feature of our global economy and financial system. Their potential impacts on US economic and financial interests may be disquieting, but they do not endanger our economy or financial system. US authorities should exhaust all multilateral approaches to make the world safe for SWFs—in the form of SWF best practices and open financial environments—before turning to any additional, bilateral remedies for concerns that to date are largely imaginary.
Scoreboard for Sovereign Wealth Funds
This appendix presents the elements of the scoreboard described in the testimony. For each of the 33 questions, if the answer is an unqualified yes, we score it as "1." If the answer is no, we score it as "0." However, partial scores of 0.25, 0.50, and 0.75 are recorded for many elements, indicated by (p) in the descriptions below.
The four categories in the scoreboard are listed below with subcategories where relevant. The words in bold are keyed to the results presented in table 3 [pdf] for each SWF on each element.
1. Is the SWF's objective clearly communicated? (p)
2. Is the source of the SWF's funding clearly specified? (p)
3. Is nature of the subsequent use of the principal and earnings of the fund clearly stated? (p)
4. Are these elements of fiscal treatment integrated with the budget? (p)
5. Are the guidelines for fiscal treatment generally followed without frequent adjustment? (p)
Other Structural Elements
6. Is the overall investment strategy clearly communicated? (p)
7. Is the procedure for changing the structure of the SWF clear? (p)
8. Is the SWF separate from the country's international reserves?
9. Is the role of the government in setting the investment strategy of the SWF clearly established? (p)
10. Is the role of the managers in executing the investment strategy clearly established? (p)
11. Are decisions on specific investments made by the managers? (p)
12. Does the SWF have in place and publicly available guidelines for corporate responsibility that it follows? (p)
13. Does the SWF have ethical guidelines that it follows? (p)
Transparency and Accountability
Investment Strategy Implementation
14. Do regular reports on investments by the SWF include information on the categories of investments? (p)
15. Does the strategy use benchmarks? (p)
16. Does the strategy limit investments based on credit ratings? (p)
17. Are the holders of investment mandates identified?
18. Do regular reports on the investments by the SWF include the size of the fund? (p)
19. Do regular reports on the investments by the SWF include information on its returns? (p)
20. Do regular reports on the investments by the SWF include information on the geographic location of investments? (p)
21. Do regular reports on the investments by the SWF include information on the specific investments? (p)
22. Do regular reports on the investments by the SWF include information on the currency composition of investments? (p)
23. Does the SWF provide at least an annual report on its activities and results? (p)
24. Does the SWF provide quarterly reports? (p)
25. Is the SWF subjected to a regular annual audit? (p)
26. Is the audit published promptly? (p)
27. Is the audit independent? (p)
28. Does the SWF indicate the nature and speed of adjustment in its portfolio? (p)
29. Does the SWF have limits on the size of its stakes? (p)
30. Does the SWF not take controlling stakes? (p)
31. Does the SWF have a policy on the use of leverage? (p)
32. Does the SWF have a policy on the use of derivatives? (p)
33. Are derivatives used primarily for hedging?
1. Table 1 [pdf] also lists the dates when the funds were established, the sources of their funding, and estimates of their size. The table includes 44 SWFs that I have identified that are not hard-wired to government pension funds and 12 representative pension SWFs. Note that the data in table 1 [pdf], in the other tables in this testimony, and described in the text include the government pension SWFs of Chile and Thailand that were not part of the analysis presented in my Blueprint for Sovereign Wealth Fund Best Practices released as Policy Brief 08-3 by the Peterson Institute for International Economics, April 1, 2008.
2. International Monetary Fund, Global Financial Stability Report, April 2008, table 3 [pdf] provides a figure of $190 trillion as of the end of 2006. The total includes stock market capitalization, public and private debt securities, and commercial bank assets.
3. This estimate includes $6 trillion in foreign exchange reserves, $6 trillion in government pension funds (excluding the US social security fund and government pension funds that invest exclusively in government assets or are not involved in the management of marketable assets), and $3 trillion in assets of nonpension sovereign wealth funds.
4. US governmental financial assets include $3 trillion in state and local government pension funds, $50 billion in other subnational SWF assets, and $40 billion in foreign exchange reserves.
5. Based on various estimates, government pension funds around the world hold about $6 trillion in assets, and roughly 25 percent of those are foreign.
6. US and foreign data on the international stocks and flows of financial assets generally do not distinguish government from nongovernment investors. The above estimate of assets controlled by US governmental units includes federal government assets as reported by the Commerce Department (The US Net International Investment Position at Yearend 2006, Bureau of Economic Analysis, BEA 08-32, June 27, 2008) plus estimated holdings of $750 billion by state and local government pension funds that are included in our statistics among private-sector assets. In the same Commerce Department release, foreign official assets in the United States include foreign exchange reserves and some holdings of sovereign wealth funds, but the data as collected do not distinguish between the two categories. The figures cited exclude, on the asset and liability side, the "gross positive fair value" of derivatives.
7. We scored the two new Russian SWFs as the single fund it was before its recent transformation. The remaining nine funds, indicated by "c" in table 1 [pdf], are either too new to score or we could not find sufficient information to do so.
8. Table 3 [pdf] provides the results for each fund on each element. The appendix provides a list of the 33 elements.
9. The two funds that we did not score are in Saudi Arabia, whose reported nonreserve assets are regarded by some as a de facto SWF, and in Dubai, in which case we could not find enough information about its Investment Corporation.
10. One should not necessarily conclude from this evidence that there is higher-level interference in investment decisions in these funds; their governance policies are unclear on this point.
11. I also think it is reasonable to consider whether we need to improve the quality of our statistical information on US assets and liabilities of governments and government-owned or -controlled entities, including sovereign wealth funds. At present, we have very little, systematic information aside from liabilities that are lumped in with foreign exchange holdings.
12. Miracky, Michael, Davis Dyer, Drosten Fisher, Tony Glodner, Loic Lagarde, and Vincent Piedrahita, "Assessing the Risks: The Behavior of Sovereign Wealth Funds in the Global Economy," Monitor Group, June 2008.