APPENDIX 10
Memorandum by the Export Credits Guarantee
Department
CONTENTS
Introduction to ECGD |
Institutional Developments at ECGD since 2000
|
Mission and Status Review 1999-2000
|
Progress towards Capitalisation
|
Business Principles |
Transparency |
EGAC |
Internal Organisation |
Governance Structures |
New Customer Service Team |
New business and the long-term perspective |
New Business since 1999 |
FREF |
Active Portfolio Management |
The Legacy Portfolio |
Management of ECGD's historical debt
|
Account 1/Account 2 |
Debt payments and rescheduling |
Current and Future Issues |
ECGD's financial objective and competitiveness
|
Business strategy and the proposed Ministerially-led Strategy Forum
|
International strategy to achieve a level playing field
|
Costs/income balance |
Concluding Remarks |
|
ANNEXES |
Annex A: External reports |
Annex B: Customer Survey & ECA comparisons
|
Annex C: Claims payments 1980-1992
|
Annex D: Analysis of claims outstanding by market as at 31 March 1993
|
Annex E: Claims against recoveries and interest received
|
Annex F: Recoveries of sovereign and non-sovereign debt
|
Annex G: Account 1 unrecovered claims at 31 March 2003
|
INTRODUCTION TO
ECGD
1. ECGD is the UK's official Export Credit Agency (ECA).
It is a separate Government Department reporting to the Secretary
of State for Trade and Industry and derives its powers from the
1991 Export and Investment Guarantees Act. Its 400 staff are based
in London Docklands and in Cardiff.
2. ECGD's aim is to benefit the UK economy by helping
exporters of UK goods and services win business, and UK firms
to invest overseas, by providing guarantees, insurance and reinsurance
against loss, taking into account the Government's wider international
policy agenda.
3. ECGD's role is to help UK capital goods manufacturers
and investors trade overseas by providing them with insurance
and/or backing for finance to protect against non-payment. ECGD
operates on a break-even basis, charging exporters premium at
levels that match the risks and costs in each case.
4. The largest part of ECGD's operation involves underwriting
finance packages to support the sale of capital goods (such as
aircraft and machinery) and services, and to help UK companies
take part in overseas infrastructure projects such as the construction/upgrading
of hospitals, airports and power stations. Support can be given
for contracts as low as £25,000 but some of the projects
ECGD backs can go well beyond the £100 million mark.
INSTITUTIONAL DEVELOPMENTS
AT ECGD SINCE
2000
Mission and Status Review 1999-2000
5. The "ECGD Mission and Status Review 1999-2000"
(MSR) was published in July 2000. Its conclusions were informed
by the Trade and Industry Select Committee's January 2000 report
"The Future of the Export Credits Guarantee Department"
and by the International Development Committee's report "ECGDDevelopment
Issues" of December 1999, and by a wide-ranging public consultation
exercise.
6. The MSR strongly reaffirmed that ECGD's role is to
bring economic benefit to the UK by supporting exporters, and
its conclusions set out a new direction for ECGD. These included:
Introducing greater openness and transparency
to ECGD's operations.
Widening the remit and membership of the Export
Guarantees Advisory Council (EGAC).
Seeking to attract more small and medium-sized
exporters and investors.
Ensuring ECGD's policies and activities were consistent
with the Government's objectives of promoting sustainable development,
human rights, good governance and trade.
7. The review further recommended that ECGD move towards
a capitalised funding system, and that a government Trading Fund
would be the most suitable vehicle to deliver this. See Annex
A for details of two key external reports on ECGD released at
the time that had relevance in this context.
8. A Trading Fund is a means of financing trading activities
undertaken by the Government. Whilst operating within a framework
agreed with Ministers, a Trading Fund has greater freedom to manage
its financial affairs. In particular it can use its income to
settle its liabilities and retain any cash balances at year-end.
It is, however, still subject to the same centrally applied administrative
rules and procedures as a Government department.
PROGRESS TOWARDS
CAPITALISATION
9. ECGD initially planned to move to formal Trading Fund
status by April 2002. Further work revealed, however, that more
had to be done to put the Department's information and risk management
systems into shape and in July 2002 the Secretary of State made
an announcement to that effect.
10. As part of the MSR changes, the Department announced
(in March 2003) a package of measures to help UK exporters. This
included introducing an improved Country Cover regime; streamlining
procedures to approve more deals more quickly in line with ECGD's
Customer Charter; developing private sector links with banks with
the aim of making larger deals easier to complete; and restructuring
its process for the environmental and social screening of projects
to reduce the burden on industry, while maintaining the rigour
of ECGD's scrutiny.
11. ECGD is now preparing for a move to a Trading Fund,
to be preceded by a public consultation and a pilot period, the
latter to allow for testing and refinement of the financial framework
that will underpin the capitalised Trading Fund.
BUSINESS PRINCIPLES
12. A key recommendation from the MSR was that before
the end of 2000 ECGD should publish a statement of Business Principles
and policies and plans for achieving them. In September 2000,
ECGD recruited an expert in Business Principles and established
the Business Principles Unit to add impetus to achieving best
practice in this area. In December 2000, ECGD issued a statement
of its Business Principles.
13. This helped fulfil the MSR recommendation on openness:
that customers should know what is expected of them, to help ensure
that these additional processes are efficient and do not put them
at a competitive disadvantage.
14. Since January 2001, an impact analysis process has
been part of ECGD's case assessment process to ensure that the
environmental, social and human rights aspects of projects ECGD
supports are compatible with standards used by multinational financial
institutions such as the World Bank. The analysis covers not only
the exported goods themselves but also the overseas projects for
which they are destined.
TRANSPARENCY
15. One of the findings of the Mission and Status Review
was that there should be a presumption of transparency and openness
on ECGD's part, subject to respecting the legitimate confidence
of its customers and overseas buyers or borrowers.
16. As part of its Business Principles, ECGD has taken
several positive steps to improve transparency and is now matching
best practice amongst ECAs. ECGD has developed a far more pro-active
approach to stakeholder engagement than previously:
Since 2001, ECGD's Annual Report has included
a list of issued guarantees
High impact cases are now listed on the website
prior to the underwriting decision being made
Environmental Impact Assessments (EIAs) will be
publicly available for high impact cases before the underwriting
decision is made
Regular discussions now take place with customers
and NGOs on projects and policy.
17. ECGD, like all ECAs, cannot always disclose all information
about its business. However, commercial confidentiality is invoked
only where it is necessary to protect the competitive position
of UK companies.
EGAC
18. The Export Guarantees Advisory Council meets on a
regular basis to give advice to the Secretary of State for Trade
and Industry. The Council comprises senior figures from the exporting
and finance fields and other relevant areas. The role of the Advisory
Council is to advise on the underlying policies and principles
which ECGD needs to follow in order to achieve its Mission Statement,
particularly how ECGD should take account of the wider impact
of projects on overseas countries.
19. In order to reflect this broader role, the Council's
membership was revised in 2000-01 to bring in outside expertise
in the new areas highlighted in the Mission and Status Review:
taking greater account of the needs of smaller exporters; the
developmental benefits of projects ECGD supports; and their environmental
and other impacts. Three of the 10 members of the Council are
experts on sustainable development and corporate social responsibility.
20. The Council normally provides its advice to ECGD's
Senior Management Team, and also on occasions directly to Ministers
or to other Departments. The Secretary of State is statutorily
obliged to consult the Council on reinsurance issues. As part
of ECGD's drive to be more open and transparent, the Council's
minutes are published on ECGD's website.
INTERNAL ORGANISATION
21. In September 2001 ECGD's Underwriting Group was reorganised
from a geographic to a sectoral basis. ECGD's customers are now
handled by the same underwriting team regardless of the country
to which they wish to export.
22. Business managers regularly visit customers for relationship
meetings and have constant dialogue on new business. ECGD also
attends conferences and seminars in the pursuit of industry knowledge
and contacts generally. In short ECGD knows its customers far
better and aims to give them a better, more informed service than
before.
CEO/CHAIR
23. As part of ECGD's transition to a Trading Fund, the
Government decided to strengthen the Department's top management
structure by creating a new board with an independent Chair and
a new Chief Executive to succeed Vivian Brown.
24. Vivian Brown announced in May 2003 that he intended
to step down as ECGD's Chief Executive after more than five years
in post. A CEO designate has now been chosen after a thorough
selection process and an announcement on the identity of the candidate
is expected this spring.
25. In January this year, former banker Graham Pimlott
was appointed Chair. The role was designed to bring private sector
experience to the business of ECGD and to contribute to the strengthening
of ECGD's corporate governance. Mr Pimlott's extensive background
in investment and corporate banking fits this mandate.
GOVERNANCE STRUCTURES
26. In line with one of the recommendations of ECGD's
Mission and Status Review, three non-Executive Directors were
appointed to ECGD's Management Board in April 2001 to provide
an independent source of advice and expertise. They help with
strategic planning within ECGD and provide an independent perspective
to decision-making on the Board.
27. To help strengthen ECGD's internal controls and corporate
governance arrangements, two of the non-Executive Directors are
also part of ECGD's Audit Committee, one acting as its Chair.
NEW CUSTOMER
SERVICE TEAM
28. In July 2002, the Secretary of State for Trade and
Industry, Patricia Hewitt, announced that ECGD would focus its
attention on making it easier for companies to access its support.
29. Following this announcement ECGD improved access
to its services for companies new to export credit finance and
insurance by launching the New Customer Service Team (NCST) in
November 2002. The team provides prospective customers with the
necessary specialist advice and support about ECGD products and
the benefits of its facilities.
30. This initiative has received more than 2,000 enquiries
(of which about 200 have been from SMEs) and handled £15
million of firm business from three new customers (of which two
are SMEs). The NCST is also cultivating 36 prospective new customers
who have been issued with preliminary cost indications for £320
million of business. The success of these prospects depends upon
exporters signing contracts and fulfilling commercial requirements.
NEW BUSINESS AND THE LONG-TERM PERSPECTIVE
NEW BUSINESS
SINCE 1999
31. During the last five years ECGD's business has remained
concentrated in the aerospace and defence sectors.
ECGD SUPPORT TO DEFENCE EXPORTS (1998-99 to 2002-03)
|
Year | Defence as % of total
| Total (£m) |
|
1998-99 | 52
| 3,725 |
1999-2000 | 34
| 5,504 |
2000-01 | 48
| 5,662 |
2001-02 | 31
| 3,298 |
2002-03 | 50
| 3,532 |
|
Source: ECGD Annual Reports
32. The defence sector receives a significant proportion
of the overall assistance provided by ECGD as the table above
illustrates. ECGD's main customers for this business are usually
large UK companies but many smaller sub-contractors across the
country also benefit from support. ECGD's defence business mainly
concerns support services, such as manpower, training and repairs.
ECGD SUPPORT TO AEROSPACE EXPORTS (1998-99 to 2002-03)
|
Year | Aerospace as % of total
| Total (£m) |
|
1998-99 | 22
| 3,725 |
1999-00 | 28
| 5,504 |
2000-01 | 22
| 5,662 |
2001-02 | 22
| 3,298 |
2002-03 | 15
| 3,532 |
|
Source: ECGD Annual Reports
33. Support for aerospace remains a leading driver of
ECGD's business. ECGD helped to contain the turmoil in the world's
airline industry after 11 September by a measured response to
the withdrawal of cover for war terrorist acts by commercial insurers,
which left many airlines unable to comply with key covenants in
finance documentation. ECGD also continued to cover new business
with over £400 million underwritten in the remaining financial
year after the 11 September attacks. ECGD's commitment to the
sector during this period was particularly appreciated by leading
manufacturers and their suppliers. Despite the difficult circumstances
in 2001-02, ECGD issued guarantees to exporters and investors
in all sectors worth £3.3 billion, generating premium of
£77 million.
34. Bombardier became a customer of ECGD over the past
two years to cover its manufacture in Northern Ireland toward
the company's regional jets.
35. 2000-01 represented a milestone for ECGD. The total
amount of business supported was £5.66 billion, generating
premium of £109 million. This was the most successful year,
in terms of the value of guarantees issued, since the short-term
arm of ECGD's operations was privatised in 1991.
36. ECGD has classified the top 10 customers in any given
financial year, in terms of the business amount they have brought
in, as key customers. As ECGD's overall customer base has shrunken,
the relative dependence on these customers has increased. See
Annex B for details of ECGD's 2003 customer survey and ECA Comparisons
report.
ECGD SUPPORT TO TOP 10 CUSTOMERS (1998-99 to 2002-03)
|
Year | Top 10 as % of total
| Total (£m) |
Total
Customers |
|
1998-99 | 74
| 3,725 | 98
|
1999-00 | 72
| 5,504 | 93
|
2000-01 | 82
| 5,662 | 80
|
2001-02 | 85
| 3,298 | 54
|
2002-03 | 84
| 3,532 | 70
|
|
Source: Capital Pricing Division report and ECGD Annual
Reports
37. The performance of ECGD Credit Insurance Guarantees
issued after 1 April 1991 (Account 2) has been robust, with trading
surpluses reported in all, but one, of the last 13 years. There
was a trading deficit in only one year, 1997-98, as a result of
changes in risk and significant claims on ECGD following the South
East Asian debt crisis. However, ECGD returned a substantial trading
surplus (£129 million) the following year and restored its
cumulative trading surplus (wiping out the impact of 1997-98)
by 1999-2000, with significant trading surpluses reported each
year since.
FREF
38. Under the Fixed Rate Export Finance (FREF) scheme,
UK exporters can offer the overseas buyer long term finance at
fixed rates of interest. ECGD makes up any difference between
the fixed and the variable floating rates. This means ECGD taking
on interest rate risk in addition to the underlying credit risk.
39. The policy on FREF up to April 2001 was a very generous
one for exporters, and led to significant losses to the Exchequer
in the 1980s and 1990s. ECGD had a specific public expenditure
non-cash limited provision, which in recent years ran at around
£40-50 million a year (in 1990-91 it was over £500 million).
A fundamental review of the scheme in 1999 concluded that whilst
the ultimate aim should be to abolish FREF, a unilateral withdrawal
of the FREF scheme would have serious competitive implications
for UK exporters. Therefore the Government would work with other
countries to reduce and eventually abolish subsidies provided
through FREF-type schemes. ECGD and the Treasury are currently
working closely together to seek to remove where possible trade-distorting
subsidies within FREF type schemes, on a multilateral basis.
40. While the Government presses other countries to reduce
the subsidies they provide through FREF-type schemes, the review
recommended that ECGD should review the feasibility of operating
the scheme on a break-even basis. In April 1999 the Government
decided that FREF should operate on a break-even basis, and a
revised FREF scheme (new FREF) began in April 2001.
41. Meanwhile ECGD has the job of managing the run down
of the Old FREF portfolio. The costs of Old FREF (estimated at
around £100 million) are being shared between ECGD and Treasury,
with the latter bearing most of the risk (85.3% compared with
14.7%). This should have no impact on premium rates or the continued
provision of New FREF.
ACTIVE PORTFOLIO
MANAGEMENT
42. ECGD has developed an Active Portfolio Management
(APM) programme to achieve a more balanced portfolio by managing
down concentrations of risk (80% of its exposure being in 20 markets)
and thereby greater capital efficiency. This reflected a key recommendation
of the 1999 KPMG Risk Management Review.
43. As a new venture ECGD first had to develop a strategy
for taking forward APM, which it did with the help of outside
advisers. The initial plan was to offer part of the portfolio
to reinsurers in 2001. The launch was adversely affected by difficult
market conditions following the events of 11 September. It was
therefore decided to take broader soundings of the market. However,
procurement issues prevented completion of a competition that
included capital market as well as reinsurance risk transfer solutions.
In the meantime, ECGD has been able to pursue a trial programme
of Credit Default Swaps (CDSs) to start the transfer of risk in
some of its most concentrated markets to the private sector. A
CDS is an over-the-counter financial instrument through which
one party assumes another's credit risk in return for a premium.
44. The trials, involving the purchase of CDSs on China
and South Africa (these markets were selected for portfolio reasons
rather than because of concerns about the risks themselves), were
a success and delivered good value for money. ECGD will now be
considering how best to carry forward its APM programme in the
light of this experience.
THE LEGACY
PORTFOLIO
Management of ECGD's historical debt
45. The international debt crisis of the 1980s had a
severe negative impact on financial institutions in both the public
and private sectors. ECGD had to draw heavily on the Consolidated
Fund to meet its obligations and developed rigorous new financial
systems to try to prevent such a catastrophic loss recurring.
46. Claims payments started to rise significantly during
the financial year 1979-80 due to developments in Iran, Turkey
and certain African markets. The table at Annex C illustrates
the rising trend in claims and provision during the 1980s and
the adverse impact on ECGD's cash balance and reserves.
47. The surge in claims resulted from a series of sovereign
defaults. While the cause varied from country to country, the
defaults took place against the backdrop of oil crises, global
recession, inflation and excessive indebtedness across a broad
spectrum of emerging markets. The contribution of different countries
to the claims may be gauged from the analysis of claims outstanding
by market as at 31 March 1993 at Annex D.
48. Recoveries of claims paid started to pick up from
the mid 1980s. By the middle of the 1990s these exceeded the declining
level of claims being paid (Annex E). At 31 March 1981 the UK
had debt rescheduling agreements with 10 countries entered into
at various dates since 1972 (namely Chile, Ghana, Guinea, Indonesia,
Peru, Sierra Leone, Sudan, Togo, Turkey and Zaire). By 1990-91
the number of countries had risen to 55 and was still rising.
It will be seen from the table at Annex F that since the end of
the 1980s recoveries have been predominantly of sovereign debt.
Account 1Account 2
49. On the privatisation of its short-term business and
the introduction of new regulations, ECGD ring-fenced its guarantees
issued prior to 1991 into "Account 1". A new "Account
2" was established for guarantees issued for project business
since April 1991 and for Overseas Investment Guarantees.
50. Under its new arrangements, ECGD has been able to
make a net contribution to the Exchequer since 1991 in all but
one year (the exception occurring in 1997-98 as a result of paying
significant claims in Indonesia, a majority of which ECGD expects
to recover over time). Nevertheless, the debt crisis did leave
ECGD with significant liabilities and these have been the focus
of both Parliamentary and media interest in recent months.
51. As of April 2003, ECGD's un-recovered claims under
Account 1 stood at £5.4 billion and those under Account 2
£831 million, ie 85% of the principal debt outstanding for
recovery by ECGD was incurred prior to 1991 and largely as a result
of the global debt crisis of the 1980s. The markets principally
contributing to the unrecovered claims under Account 1 were Nigeria,
Poland and Iraq (see Annex G). In addition to these sums, moratorium
and delay interest of around £4 billion is also outstanding.
This represents the interest charged by ECGD on outstanding debts
where it is able to do so. Indeed, ECGD has received substantial
sums in interest payments for many years as well as recovery of
the original principal debt: for example, the Department earned
around £158 million of interest on account 1 in 2002-03.
52. In line with normal accounting practice, ECGD has
made provisions for loss against its old debts. This information
is published each year in its Annual Report. The Accounts for
2002-03 show that the Department expects to recover 37.5% of amounts
outstanding. This is comparable to other similar institutions;
indeed, in many instances ECGD and other export credit agencies
achieve a higher recovery rate than other institutions under the
multilateral Paris Club arrangements. ECGD is required to consider
value for money considerations in pursuing recoveries of old debts.
Debt payments and rescheduling
53. When a country experiences economic difficulties
and cannot meet its external repayment obligations, debt can be
restructured multilaterally on mutually agreed terms at the Paris
Club, a group of sovereign creditors. ECGD forms part of the Treasury-led
UK delegation to the Paris Club.
54. The Heavily Indebted Poor Countries (HIPC) Initiative
provides debt relief to the world's poorest and most heavily indebted
countries, with the aim of reducing debt-to-export ratios of these
countries down to a target of 150%. To receive debt relief under
the Initiative, eligible countries need to make a commitment to
poverty reduction and meet a number of conditions, such as completion
and implementation of a Poverty Reduction Strategy, measures to
reform public expenditure, maintaining macroeconomic stability,
and reaching certain targets in the health or education sector.
55. ECGD has written off £919 million of HIPC debt
(as of September 2003) and remains committed to writing off a
further £1.43 billion.
56. ECGD also offers a debt conversion scheme, allowing
it to sell Paris Club debt owed to the UK on condition that the
proceeds go towards assisting the social or economic development
of the debtor country.
57. As an example, in December 2003 ECGD sold £69.5
million of Jordanian debt to a local company to set up a state
of the art information and communications technology (ICT) link
within Jordan. Debt sales benefit all parties: ECGD recovers debt
(albeit at a discount) earlier than it would under a rescheduling
agreement, the debtor's hard currency obligations are reduced,
and the purchaser gets local currency at a discount for investment
in the local economy.
CURRENT AND
FUTURE ISSUES
ECGD's financial objective and competitiveness
58. ECGD's Account 2 (post-1991 business) has a specific
financial objective to operate with a reasonable confidence of
breaking even. To do this, it charges exporters premium at levels
that cover expected loss and other administrative and operational
factors. From this, reserves are built up to pay for claims if
overseas buyers/borrowers default on payment.
59. ECGD's `financial framework' is the detailed financial
criteria jointly agreed between ECGD and Treasury that provides
assurance that ECGD is operating within these specific objectives.
60. Competitiveness with other ECAs remains a priority
issue for many of ECGD's customers, with a number of major UK
exporters and associations emphasising the importance they place
on a competitive ECGD. This demand needs to be balanced against
HMG's requirements to provide value for money for taxpayers. The
Government will seek liberalisation on a multilateral basis: ECGD
and HM Treasury are working closely together to press other countries
to reduce their export subsidies.
Business strategy and the proposed Ministerially-led Strategy
Forum
61. The Secretary of State has decided to establish a
Strategy Forum to set Government policy for export credit support.
Ministers and senior officials from the DTI and HMT are to meet
ECGD's Chairman and Chief Executive and Chair of the Export Guarantees
Advisory Council to agree ECGD's medium to long term strategic
objectives and direction.
62. This is designed to provide a mechanism for key government
stakeholders in the provision of export credit support to agree
a clear policy for balancing the interests of taxpayers and exporters,
and an agreed means of reviewing progress. This should give ECGD's
Management Board regular strategic direction for developing the
Department's future.
International strategy to achieve a level playing field
63. Internationally, ECGD is working to maintain and
extend the multilateral framework for export credit disciplines
to further eliminate any trade-distorting subsidies and create
a level-playing field for UK exporters. The following are the
main policy issues being progressed:
The overall framework within which OECD export
credit agencies provide export credit support and the relationships
with the WTO has been revised.
Reform of fixed rate interest make up across ECAs.
Anti-Bribery and Corruptionfollowing the
successful conclusion of negotiations for enhanced procedures
for assessing project environmental impacts, the OECD's Export
Credit Group is now looking at enhancing anti-bribery and corruption
procedures.
The way in which export credit agencies price
to cover risk.
Aerospace. ECGD has led the reforms to harmonise
the support provided by the Airbus export credit agencies (ECAs)
(ECGD, Coface and Hermes).
Tied Aid. ECGD continues to monitor Tied Aid to
protect disciplines in this area, with the aim of minimising the
competitive disadvantage that UK exporters represent to foreign
competitors supported by mixed credits.
Costs/income balance
64. The development of ECGD's business base has to be
seen against the background of the shift in the economy of the
UK and other Western countries towards a service base.
65. International competitive pressures on large manufacturers
have increased vastly in recent years. Global economic interdependence
through transnational networks of multinational companies has
opened new opportunities to gain competitive advantages for specific
operations.
66. This has resulted in increased efforts in outsourcing
or relocating certain manufacturing bases, which are labour-intensive,
to low cost countries. This leaves high value-added and locally
bound operations in the UK. The result reduced UK capital goods
manufacturing to a small proportion of its former size, now mainly
in high-value added and niche production.
67. Accordingly, ECGD business has levelled off in recent
years. ECGD has increasingly relied on a few large companies in
the civil aerospace, defence and oil & gas sectors. As a result,
a review will be undertaken to establish the appropriate size
and shape of the department, consistent with the levels of business
and premium income anticipated in the future.
CONCLUDING REMARKS
68. Since the Trade and Industry Select Committee last
looked at ECGD, the Department has undergone a number of fundamental
changes following on from the Mission and Status review.
69. Despite a number of significant challengesboth
internally and in the wider economic environmentthe Department
supported a record amount of business in the financial year 2000-01.
It continues to support an average annual level of business around
£3.5 billion. The Department is on target to reach its financial
objectives for the current year.
70. In addition, ECGD has been at the forefront of international
efforts to reduce subsidies in export credits, improve the environmental
screening of projects, and in combating bribery and corruption
in ECA-supported projects.
71. Negotiations over the next stages in ECGD's evolution
are continuing. A consultation exercise is planned for customers
and stakeholders to help inform decisions Ministers will need
to take on ECGD's future. In this respect, the Trade and Industry
Select Committee's decision to revisit ECGD is well timed.
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