Appendix: Analysis of Exchange Rates Pursuant to the Act

Introduction 

Although reaching judgments about “whether countries manipulate the rate of exchange between 

their currency and the United States dollar for purposes of preventing effective balance of 

payments adjustments or gaining unfair competitive advantage in international trade” is 

inherently complex, there are several indicators that can provide helpful information in 

considering this question. However, no single indicator, or set of indicators, in and of itself, can 

establish that a specific economy has met the technical requirements for designation under the 

Act, and the context in which these questions are assessed varies with individual country 

circumstances. 

Some of the most important indicators, inter alia, are: (1) trade and current account balances; (2) 

protracted large-scale intervention in one direction; (3) rapid foreign exchange reserve 

accumulation; (4) capital controls and payments restrictions; (5) measures of undervaluation and 

real effective exchange rate movements; and (6) unusually heavy reliance on net exports for 

growth. These indicators affect one another, jointly reflecting the complex interactions in 

modern economies. 

Description of Indicators 

Trade and Current Account Balances – The current account balance reflects an economy’s 

excess of saving over investment; it can be measured as the net transactions on trade in goods 

and services (normally the largest component), plus net balances on income and transfer flows; it 

is also mirrored in capital and financial account inflows or outflows (including changes in 

foreign exchange reserves). Trade and financial flows will be affected by a number of factors 

that influence costs and prices in one economy relative to those of its trading partners – for 

example, exchange rate movements, growth in productivity, relative inflation rates and relative 

monetary conditions – as well as by cyclical forces such as an economy’s growth relative to that 

of its major trading partners. The mere existence of a large global current account surplus does 

not mean that an economy meets the requirements for designation under terms of the Act. 

Bilateral trade balances reflect unique patterns of demand or comparative advantage among 

countries and are therefore limited in their ability to help explain exchange rate movements. For 

example, it is quite understandable that the United States would have a large bilateral deficit with 

a country that is a major oil exporter. At the same time, in a multilateral trading system, an 

economy’s bilateral deficit with one economy can be offset by a bilateral surplus with another. 

Protracted Large-Scale Intervention in One Direction – Protracted large-scale intervention in 

one direction could reflect an effort by an economy’s authorities to maintain a given exchange 

rate level in the face of market pressure for the purposes of preventing effective balance of 

payments adjustment or gaining unfair advantage in international trade. Intervention can, 

however, be carried out for a number of purposes. IMF surveillance procedures, for example, 

provide that members should intervene in the exchange market if necessary to counter disorderly 

market conditions. In addition, countries may intervene in order to build reserves to meet 
external debt payments and establish a buffer against shocks. Evidence shows that the 

effectiveness of intervention in influencing the behavior of the exchange rate of a country with 

open capital markets is, at best, short lived, especially if such intervention is “sterilized.”

Rapid Foreign Exchange Reserve Accumulation – When a country’s financial authorities 

purchase foreign exchange, that country’s reserve holdings typically rise. There are many 

reasons why a country might wish to increase its reserves. A country may, for example, wish to 

accumulate reserves as insurance against sudden reversal of capital flows or the development of 

disorderly foreign exchange markets. It may need to repay debt. Some commodity producing 

countries, which see rapid gains in export earnings due to a rise in commodity prices, choose to 

save a portion of their currency earnings in order to build stabilization funds. Monetary 

authorities may intervene in the foreign exchange market, or maintain a fixed exchange rate, if 

the foreign exchange rate plays an important role in a monetary policy designed to achieve price 

stability. 

The adoption of a fixed exchange rate is often appropriate for small and highly open economies, 

where the domestic price level is largely determined by international prices, and therefore 

changes in the foreign exchange rate lead directly to corresponding changes in the domestic price 

level. Avoiding an exchange rate appreciation may be particularly important for economies that 

are trying to avoid or escape from deflation. In this instance, the accumulation of foreign 

exchange reserves may be both a way of preventing exchange rate appreciation, which would 

exacerbate downward pressure on prices, and a tool for increasing the domestic money supply. 

Exchange rate policy in this event is effectively part of domestic anti-deflation policy. In these 

cases it would be difficult to construe the reserve accumulation by such economies necessarily as 

attempts to “manipulate the rate of exchange between their currency and the United States dollar 

for purposes of preventing effective balance of payments adjustments or gaining unfair 

competitive advantage in international trade.” There is no universally agreed optimum level of 

reserves.1,2

Capital Controls and Payments Restrictions – Capital controls also warrant attention in making 

assessments. Capital controls can be applied to inflows (limiting upward pressure on domestic 

currency) or outflows (limiting downward pressure on domestic currency). Some countries have 

used controls on inflows out of concern that large, short-term portfolio investment from major 

financial centers could suddenly reverse – disrupting small domestic capital markets. Capital 

controls prevent capital from flowing to its most productive uses and can impose severe 

inefficiencies on an economy. 

 

1

 Several rules of thumb have been used over the years to measure reserve adequacy, particularly for developing and 

emerging market economies. At a time when reserves were seen as buffers against shocks to the trade accounts, it 

was proposed that reserves should be at least equal to three months imports. Following crises in several emerging 

market economies in the late 1990’s, it was proposed that reserve holdings should be equal to short-term external 

debt outstanding (residual maturity basis). 2

 The ratio of reserves to short-term liabilities of the banking system, such as M2 or M3, has been used, similar to

the ratio of reserves to short-term debt, as an indicator of reserve adequacy to reduce economies’ vulnerabilities to

external shocks. Changes in this ratio may provide some information, as well, on the degree to which changes in

reserves are sterilized. 

2
Payments restrictions limit the use of foreign currency to buy goods and services and can be very 

distortionary. The IMF severely discourages restrictions on current international transactions.

3

 

Countries that do not impose restrictions on current international transactions are deemed to meet

their obligations under Article VIII of the Fund’s Articles of Agreement. 

Measures of Undervaluation – A large “undervaluation” of a market exchange rate may exist 

relative to a medium- or long-run “equilibrium exchange rate.” Such an equilibrium exchange 

rate is typically estimated as the level of a real effective exchange rate implied by medium- or 

long-term equilibrium conditions in a specific model. Current movements of real effective 

exchange rates, reflecting changes in both nominal exchange rates and prices in major trading 

partners, are consequently critical to interpreting the state of ongoing adjustment. 

These models can provide valuable insights; however, these calculations need to be interpreted 

with caution since they are derived on the basis of numerous difficult and highly technical 

assumptions, and different models can focus on different features of an economy and produce 

very different results.4

 A recent IMF staff paper and an April GAO report examined a number of 

different estimates of the deviation of China’s real exchange rate from its estimated equilibrium

value and found very wide variation in the results. The IMF staff study notes that data problems 

are substantial; it may take some time for key underlying relationships to stabilize sufficiently to 

estimate relevant relationships with confidence; and even when stable the complexity of these 

relationships may make accurately explaining movements in exchange rates an elusive objective. 

Also, a currency may deviate substantially from its “equilibrium exchange rate” for a number of 

reasons; for example, the deviation could reflect supply and demand conditions in the 

marketplace (e.g., a currency could depreciate rapidly relative to its “equilibrium” value if 

confidence were lost in that country’s economic policy management). Further, a 

“misalignment” might reflect, for example, problems with the model’s description of market 

reaction to the fundamental macroeconomic policy mix. 

An unusually heavy reliance on the export sector for growth may provide an incentive to prevent 

balance of payments adjustment. This could, for example, be seen a critical offset to an 

economy’s weak domestic investment incentives. At the same time there are many conditions 

that naturally produce high export sector growth relative to the rest of an economy. For example, 

there may be extraordinary productivity gains concentrated in the external sector or the 

development of new resource deposits. 

 

3

 Section 2 of the Article VIII of the IMF’s Articles of Agreement states that each member undertakes the obligation 

of “avoidance of restrictions on current payments.” 4

 Dunaway, Steven and Li, Xiangming, “Estimating China’s ‘Equilibrium’ Real Exchange Rate, IMF Working Paper 

October 2005; and Table 2 of the General Accounting Office’s report, “Treasury Assessments Have Not Found 

Currency Manipulation, but Concerns about Exchange Rates Continue”. The IMF staff report can be found at

http://www.imf.org/external/pubs/cat/longres.cfm?sk=18614.0 and the GAO report at www.gao.gov/cgibin/getrpt?GAO-05-351. 

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Analysis of Indicators 

In considering the question of designating countries pursuant to the terms of the Act, a range of 

indicators needs to be assessed. One indicator, in and of itself, does not provide meaningful 

information. Rather, the pattern of indicators typically provides more useful information. For 

example, a country with a large current account surplus would be viewed one way if the country 

also had a large reserve buildup and a depreciating exchange rate and viewed another way if its 

reserves were falling and the exchange rate were appreciating. Patterns of movements of 

indicators must, however, be examined in terms of the specific country and the global economic 

environment. 

The complexity of the analysis can be seen, in part, in the following table of important numerical 

indicators. Countries in this table were selected to provide a cross section of significant major 

economies, without creating an unwieldy list. Periods were chosen that would yield data for the 

full set of countries.5

 Although more recent data for some countries may differ in significant 

respects from those in the table, it is important for the illustrative purposes of the table to use a 

full data set. 

Table 16

Real Effective External Sector Relative Dependence

Level Change Ratio to Ratio to short-term Change Exchange Rate Contribution to of GDP Growth

over period 2004 GDP external debt in reserves (% appreciation Growth Rate on External Sector

(%GDP) (%GDP) (%) (%) (%) over period) (Average %) (Average %)

2004 2001-2004 June 2005 June 2005 June04 to June05 Jan02-Sep05 2002-2004 2002-2004

Singapore 26.1 7.3 107.7 131.0 13.8 17.8 4.2 4.1

Saudi Arabia 20.5 15.4 8.0 142.5 12.4 -19.9 0.7 -2.9

Switzerland 14.6 6.6 9.8 9.1 -22.9 -3.8 0.4 0.3

Norway 13.5 -2.0 18.1 48.9 14.9 16.0 -0.9 -3.2

Malaysia 12.7 4.5 62.6 366.9 40.9 -13.3 -0.6 -6.8

Venezuela 12.7 11.1 20.7 607.2 29.0 -11.6 0.3 0.8

Russia 10.3 -1.0 25.2 402.0 75.0 20.9 -0.2 -6.8

Sweden 8.2 4.0 5.8 11.0 11.0 -0.2 1.3 0.4

Taiwan 5.8 -0.5 82.9 689.4 10.2 -6.0 1.9 -0.6

Korea 4.1 2.4 30.0 291.8 22.9 16.9 1.9 -1.1

Thailand 4.0 -1.3 28.7 387.4 11.6 4.0 0.2 -5.7

China 4.0 2.5 41.3 1242.9 51.1 -4.3 0.6 -7.9

Germany 3.8 3.6 na na na na 0.7 1.0

Japan 3.7 1.6 17.7 231.7 3.3 -6.5 0.7 0.1

Canada 2.2 0.0 3.2 23.3 1.0 20.0 -1.1 -5.0

Euro Area 0.6 0.6 1.8 5.1 -3.4 18.5 0.1 -1.1

India 0.0 -0.3 21.2 511.7 15.9 1.9 0.2 -6.1

Mexico -0.3 0.4 9.5 287.1 8.5 -3.9 0.3 -1.6

United Kingdom -2.0 0.2 1.8 2.0 9.6 -0.6 -0.7 -4.0

Turkey -5.2 -7.5 13.4 119.4 18.4 15.2 -3.0 -13.5

Spain -5.3 -1.4 na na na na -1.2 -5.3

United States -5.7 -1.8 0.3 2.8 0.4 -18.3 -0.6 -4.1

Australia -6.4 -4.1 6.5 28.3 26.8 40.0 -2.4 -8.4

Portugal -7.5 2.8 na na na na 0.4 0.7

Current Account Balance Foreign Exchange Reserves

As noted, reaching a judgment about what constitutes grounds for designation pursuant to the 

 

5

 For example, China and Saudi Arabia provide expenditure-based GDP series only on an annual basis. 6

 The “Contribution to Growth of the External Sector” is calculated as the annual change in real net exports (in the

National Income and Product Accounts) as a percent of real gross domestic product. The “Relative Dependence of

GDP Growth on the External Sector” is measured as the external sector’s contribution to GDP growth minus the 

contribution of the growth in domestic demand. This dependency measure reflects the view that a country will be

generally more concerned about the contribution of the external sector to GDP growth if the contribution of the 

domestic sector to GDP growth is relatively small. For example, Singapore’s export sector contributed 4.1 percent

to GDP growth in 2004 while domestic demand contributed only 0.1 percent. China’s export sector, on the other

hand, contributed only 0.6 percent to GDP growth in 2004 while domestic demand contributed 8.5 percent. Turkey’s

external sector subtracted 3.0 percent from GDP growth in 2004 while domestic demand contributed 10.5 percent.

The “Real Effective Exchange Rate” is J.P. Morgan’s Broad Real Effective Exchange Rate Index. 

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Act is complex and cannot be based on single indicators. Moreover, it is inherently subjective. 

There is no mechanistic or formulaic approach to rendering such assessments. That said, it may 

help, in considering these questions, to summarize different patterns by constructing simple 

weighted indices of indicators. For example, various indicators in Table 1 were assigned 

qualitative values of low, medium, or high (numerically 0, 1, or 2) and indexes were constructed 

using alternative weighting schemes. Obviously, the potential number of weighting schemes is 

enormous. But for illustrative purposes, three schemes are set forth7

: 

• One weighting scheme concentrated on changes in the current account, foreign exchange 

reserves and real effective exchange rates, assigning each a 1/3 weight. 

• Another concentrated on current account balances, changes in current account balances and 

relative dependence of GDP growth on the external sector, assigning each a 1/3 weight. 

• A third scheme weighted many factors in Table 1 equally. 

The three weighting schemes yielded the following rankings: 

Scheme I Scheme II Scheme III

Saudi Arabia 1.7 Venezuela 1.8 Singapore 2.0

Malaysia 1.7 Saudi Arabia 1.6 Switzerland 2.0

Venezuela 1.7 Singapore 1.4 Venezuela 2.0

China 1.3 Switzerland 1.4 Saudi Arabia 1.7

Japan 1.3 Malaysia 1.4 Sweden 1.7

Singapore 1.0 Sweden 1.4 Germany 1.3

Switzerland 1.0 Japan 1.4 Japan 1.3

Sweden 1.0 Taiwan 1.2 Norway 1.0

Taiwan 1.0 China 1.0 Malaysia 1.0

Mexico 1.0 Norway 0.8 Taiwan 1.0

United Kingdom 1.0 Russia 0.8 Korea 1.0

Russia 0.7 Korea 0.8 Euro Area 1.0

Korea 0.7 Germany 0.8 Portugal 1.0

Thailand 0.7 Mexico 0.8 Russia 0.7

India 0.7 United Kingdom 0.8 China 0.7

Norway 0.3 Thailand 0.6 Canada 0.7

Germany 0.3 Canada 0.6 Mexico 0.7

Canada 0.3 Euro Area 0.6 United Kingdom 0.7

Euro Area 0.3 India 0.6 Thailand 0.3

Turkey 0.3 Portugal 0.6 India 0.3

Australia 0.3 Turkey 0.2 Turkey 0.0

Portugal 0.3 Australia 0.2 Spain 0.0

Spain 0.0 Spain 0.0 Australia 0.0

A number of conclusions can be derived from Table 1 and the weighting schemes. 

• Several oil producing economies score high across the board on the various weighting 

schemes. These results reflect these economies’ recent experiencing large current account 

surpluses and reserve accumulations, while maintaining relatively fixed exchange 

arrangements and witnessing real effective depreciation. For example, Saudi Arabia ran a 

current account surplus in 2004 of over $50 billion, or more than 20 percent of GDP. Russia 

ran a current account surplus of nearly $60 billion, or greater than 10 percent of GDP, while 

reserves rose 75%. This is the expected result of rapidly increasing oil prices and limited 

short-term absorptive capacity of a number of oil exporters. The reserve increases in oil 

 

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 Scheme I assigns weights of 33 1/3 % to each of: change in the current account balance, change in reserves, and

change in the real effective exchange rate. 

 Scheme II assigns weights of 20% to each of: current account level, change in the current account, change in

reserves, change in the real effective exchange rate, and relative dependence of GDP growth on the external sector. 

 Scheme III assigns weights of 33 1/3 % to each of: current account balance, change in the current account balance 

and relative dependence of GDP growth on the external sector. 

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producing economies in certain respects reflect a policy choice to save the higher incomes 

generated from rising energy prices, rather than spending these resources. Though not 

spending these resources abroad results in larger global current account imbalances than 

would otherwise be the case, this choice may reflect a prudent use of national resources, 

especially given the variability in commodity prices and the fiscal policy stance. 

• Some major industrial countries also appear toward either the bottom or top of the various 

weighting schemes. For example, Germany has a large nominal current account surplus. 

Germany is part of the Euro Area, which as a whole has a modest current account surplus as 

a share of GDP. The euro is a freely floating currency, and European Central Bank reserves 

did not increase in 2004. Yet, Germany ran a current account surplus of 3.8% of GDP. 

Germany’s nominal current account surplus exceeded $100 billion. Absent external demand, 

German growth would have been slightly negative in 2004. On balance, Germany’s current 

account surplus is fundamentally associated with persistently weak domestic demand. 

 

• Switzerland has a large current account surplus. This does not reflect, however, its 

merchandise trade balance, but rather significant surpluses in trade in financial services and 

investment income. The Swiss franc is an independently floating currency. 

• Japan is in the upper half of the weighting schemes. Its current account surplus as a share of 

GDP in 2004 was 3.7%. The external sector provided an important contribution to overall 

growth. In dollar terms, Japan’s current account surplus was over $170 billion and its 

bilateral surplus with the United States over $75 billion. Japan has at times in the recent past 

intervened heavily in foreign exchange markets. However, it has not done so since March 

2004. Japanese reserves have not increased significantly since that time. The Japanese 

economy has recently strengthened. Though Japanese private saving has declined in past 

years and the public sector has run fiscal deficits, corporate saving has been strong, while 

growth in investment has been restrained due to low economic growth and financial sector 

weakness. 

 

• China is toward the upper end of the first weighting scheme, in the middle of the second, and 

toward the bottom of the third. China’s current account surplus as a share of GDP has risen 

in recent years, and continues to rise sharply this year. The currency is rigidly managed, and 

the real effective exchange rate has strengthened, reflecting the renminbi’s relationship to the 

dollar. China’s reserve accumulation was large and rapid last year, and reserves are 

continuing to rise rapidly this year. This explains the high ranking using the first weighting 

scheme. But China’s 2004 current account surplus, at 4.0% as a share of GDP, is more 

modest than that of many other economies listed in Table 1. Though the contribution of the 

external sector to growth was positive, this contribution was modest. These considerations 

impact China’s ranking in the second and third weighting schemes. 

• Malaysia tends to have a high ranking, on the whole, in the weighting schemes. It has a 

rigidly managed exchange rate. It ran a nearly 13% of GDP current account surplus last year, 

in part due to higher oil export earnings, and its reserves rose rapidly. Taiwan’s current 

account surplus was over 6% of GDP and South Korea’s over 4%. Both have relatively large 

levels of reserves, which rose appreciably last year. Their external sectors contributed 

6
significantly to growth. As discussed in the report, there have been important movements in 

the South Korean and Taiwanese currencies. 

• Singapore also has a relatively high ranking, on the whole, in the ratings. Its current account 

surplus was 26% of GDP, partly due to high saving given prospective demographic trends, 

but Singapore has a small bilateral deficit with the United States; the country pursues a

managed currency in terms of a currency basket, but the composition of the basket is not 

published. Singapore uses its foreign exchange rate as a monetary policy anchor. The real 

effective exchange rate appreciated 15 percent over the January 2002 – September 2005 

period.

Conclusions 

The three illustrative mechanical approaches above, using weighted indexes of indicators, 

produce very different outcomes. Saudi Arabia, Malaysia, Venezuela, and China are at the top 

of the first weighting scheme; Venezuela and Saudi Arabia are at the top of the second; while 

Singapore, Switzerland, and Venezuela are at the top of the third. An economy’s position on the 

list depends on specific characteristics. Increased oil prices have contributed to high and rising 

current account surpluses and rising reserves for some oil producers. China’s position on the list 

is heavily dependent on whether the weighting schemes factor in the current account as a share 

of GDP and the dependence of the economy on external growth. Singapore and Switzerland 

have large current account surpluses and strong growth of the external sector relative to that of 

domestic demand.

Although these numerical indicators provide insight into the operations of economies, a 

mechanistic application of them yields an incomplete picture of an economy’s performance and 

cannot provide determinative evidence that an economy should be designated pursuant to the 

terms of the Act. Additional analysis is necessary. First it is important to consider the many 

interactions among indicators. For example, growing productivity in the production of traded 

goods relative to the production of non-traded goods can raise the real exchange rate. Second, it 

is important to consider developments that are specific to an individual economy. Oil price 

changes affect oil producers and oil consumers differently. Third, it is important to consider 

policy changes that will likely affect the adjustment process but may not yet be producing 

results.

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