Appendix 2: Bank of England response
The Monetary Policy Committee (MPC) and the Court
of the Bank of England welcome the Treasury Committee's Report
into "The MPC of the Bank of England: ten years on".
Both the MPC and Court acknowledge the thoroughness with which
the Committee has undertaken its task. The MPC would also like
to take this opportunity to thank the Committee for the manner
in with which it has conducted its regular scrutiny of the MPC's
decisions over the past decade. Those hearings have been an essential
ingredient in establishing the legitimacy of the present monetary
framework.
The first part of the Committee's Report contains
reflections on the economic context and on the monetary policy
framework. The MPC's views on the economic context were conveyed
at length in the Bank's original submission to the enquiry and
further commentary here is unwarranted.
With regard to the monetary policy framework, the
Committee endorses the present symmetric inflation target for
the Consumer Prices Index, with the numerical value for that target
set annually by the Chancellor of the Exchequer. While the framework
is a matter for the Government and HM Treasury rather than the
Bank of England, the MPC welcomes the Committee's support for
the current framework, which the MPC believes has served the country
well over the past decade.
The rest of the Committee's Report contains a number
of recommendations relating to the MPC as a body and the transparency
of the MPC. These are more directly addressed to the MPC or Court
and MPC/Court's responses are recorded below. For ease of reference,
the Committee's recommendations are re-iterated (in bold, numbered
paragraphs), with the MPC/Court's response following, as appropriate.
We are mindful of the need to ensure that the
MPC remains independent, and to allow a flexible system of terms
and conditions that can enable recruitment from the widest base.
We therefore recommend that, should the Bank of England Act 1998
be modified in the future, a new term of office for 'external'
MPC appointments be instituted, based on a six-year term, with
no option of reappointment, with a three year minimum, after which
continuation would take place only with the agreement of both
the Non-Executive Committee of the Court of the Bank of England
and the postholder. This would give the flexibility to remove
those who are unfit for the job, retain flexibility for those
who might wish to leave the post early, and ensure continuation
was not at the discretion of the Chancellor of the Exchequer.
(Paragraph 68).
The length of term for all members of the MPC is
a matter for Government and Parliament. However, both the MPC
and Court believe that the spirit of the Committee's recommendation
for longer, but non-renewable, terms for the external members
is desirable. From the MPC's perspective, some turnover of external
members is desirable in order to ensure regular injections of
fresh thinking, but longer terms help to build and maintain the
MPC's experience; the particular length of term chosen should
balance these two considerations. But it would not be sensible
to expect all external members to commit to serve a longer term,
as that might make some candidates unwilling to join the Committee.
That is particularly the case for academics, who are generally
unable to secure leave of absence for more than three years.
Whatever length of term the Government chooses, Court
does not believe that it should play a role in the appointment
or re-appointment of MPC members, as that would usurp the proper
role of Government in determining the make-up of the MPC, as well
as potentially weakening the independence of members approaching
re-appointment. But in the unlikely event that an individual's
behaviour is unfit or incompatible with their continued membership
of the MPC, Court should be able to remove them at any time, a
power that it has already under the existing Bank of England Act.
We find the explanations of why the full-time
option was removed for all 'external' members unconvincing, especially
for new members of the Monetary Policy Committee. We recommend
that all working patterns be available to 'external' members of
the MPC, so that they may undertake their duties as they see fit,
as their career progresses. (Paragraph 70).
The terms and conditions for external members is
a matter for Court. The Chairman of NedCo holds annual meetings
with individual MPC members and has discussed this matter with
the 'external' members.
Court is of the view that the formulation of monetary
policy is not a full-time occupation. 'Internal' members of the
MPC spend a significant part of their time executing line management
responsibilities, rather than setting interest rates; it is not
practical to try to provide such additional line responsibilities
for the 'external' members. Moreover, it is not their previous
employment that distinguishes 'external' members from 'internal'
members a majority of the current group of 'internal' members
were, for instance, appointed from outside the Bank. Rather, it
is that the 'external' members continue to have links outside
the Bank after they have taken up membership of the MPC, thus
facilitating the injection of fresh thinking into the MPC's deliberations.
Court therefore believes that 'external' membership
should normally be part time typically the equivalent of
three days/week. However, Court recognises that some flexibility
may be required while an appropriate additional role external
to the Bank is secured, when external members come from a business
or financial market background and cannot continue their existing
employment on a part-time basis. Consistent with this, Court notes
that securing suitable additional external employment would be
facilitated if appointments to the MPC are made in a timely fashion
and would ask that the Treasury also recognise this issue at the
time of appointment.
We welcome the changes to the appointments process
for 'external' members of the Monetary Policy Committee outlined
by the then Chancellor of the Exchequer in evidence to us in June
2007. We welcome the fact that Government will advertise for different
qualities and skills for each new 'external' member of the Monetary
Policy Committee. We hope that they will lead to timely appointments
of experts suited to the role of Monetary Policy Committee member.
We note that there is no current proposal for a confidential pool
created of experts who could be nominated to the Monetary Policy
Committee where posts need to be filled at short notice. We therefore
recommend that the Government consider adding a note to candidates
as part of the appointments process asking them if they would
be willing to form part of such a pool if not selected for the
current vacancy. (Paragraph 79).
Court and the MPC believe that the maintenance of
a confidential pool of candidates with the appropriate skills
and experience would be valuable and would help facilitate vacancies
being filled in a timely fashion. Court and the MPC therefore
support this recommendation and would welcome the opportunity
to work with the Treasury on succession planning.
We welcome the Government's commitment to enable
appointment hearings by this Committee for nominees for the post
of 'external' member of the MPC to take place prior to formal
appointment. We note that the Government considers such hearings
would be "non-binding". We consider it important that
such hearings can be scheduled sufficiently far in advance of
the date of the formal appointment to enable the Chancellor of
the Exchequer to be able to give proper consideration to any view
expressed by the Treasury Committee without there being a danger
of the MPC membership being temporarily reduced as a result of
reconsideration of a nominee. We recommend accordingly that nominations
be announced at least three months prior to the date on which
the vacancy falls to be filled. We also consider that, if the
Treasury Committee were to reach an adverse opinion on a nominee,
which would only be after careful and considered reflection, the
Committee ought to have the power to require a debate in the House
of Commons on the nomination. (Paragraph 82).
Court and the MPC believe that it is important that
vacancies are filled in a timely fashion after due process has
been fulfilled, including appointment hearings before the Committee.
Court and the MPC therefore welcome the recommendation that nominations
be announced at least three months in advance in order to allow
these to take place before a new member joins the MPC. The suggestion
that the Committee should have the power to require a debate in
the House of Commons in the event that it considers a nomination
unsuitable is a matter for Parliament.
We have heard differing views on the need for
monthly meetings of the Monetary Policy Committee. With hindsight,
it would have been better if the Bank of England Act 1998 had
not mandated monthly meetings, but had left the number of meetings
each year to be determined by the Court of the Bank of England
on the recommendation of the Governor, but subject to the following
conditions: that there were to be a minimum of eight annual meetings,
that Monetary Policy Committee meetings were to be evenly spaced
across the year, and that MPC meetings were to be pre-announced
with a year's notice, except in 'emergency' cases. We therefore
recommend that, should changes to the Bank of England Act 1998
be required for any other purpose, these changes be made at that
time. (Paragraph 86).
While the MPC does not see the need for change as
pressing, were the Bank of England Act to be amended for other
reasons, the MPC would welcome scope for greater flexibility in
regard to the timing of its meetings. It agrees that the stipulation
of a minimum of eight meetings each year would be sensible, although
the requirement that they be evenly spaced would mitigate against
them being held at optimum points in the data release cycle.
We believe that the present Court of the Bank
of England is too large and should be reduced in size. We note
the role played by the Court in the accountability process of
the Monetary Policy Committee. We will continue to monitor the
decisions of the Court, and at times may request additional information
from it relating to the Monetary Policy Committee to ensure that
it is undertaking its proper functions as related to the Monetary
Policy Committee. (Paragraph 91).
Court concurs with the Committee's recommendation
to reduce its size. Court welcomes the Committee's interest in
its oversight of the MPC and its processes and is ready to provide
additional information when requested.
We acknowledge the efforts the Monetary Policy
Committee has made in educating the public, especially via its
programmes for younger people, about its role, and the need for
low inflation. However, certain of the Bank's own measures of
the public's understanding remain low. We recommend that the Monetary
Policy Committee and the Bank of England consider what the public
need to know about the monetary policy framework, and then, with
assistance from the Treasury if needed, consider a public education
campaign to put across those points. It is important that if there
are more uncertain times ahead, the public must understand and
support the reasons behind movements in interest rates. (Paragraph
99).
The MPC fully concurs with the Committee about the
importance of educating the public regarding the case for low
inflation and the Bank's role in securing price stability. The
MPC believes that it has been reasonably successful in reaching
the professional and business audience, through both its speaking
programme, regional visits and the activities of the Agents, though
of course there is always more that can be done. And the widespread
use in schools of the Bank's general teaching resources and the
success of the Target 2.0 Competition have helped to get the message
out to the young. But reaching a much wider audience is significantly
more challenging, though we are deliberately trying to increase
our involvement in events with such an audience. We are also planning
to have a special exhibition on inflation and its control in the
Bank's museum this year. And the Bank's website is being developed
in order to make it more informative for the general public. The
MPC will continue to place a high priority in advancing this agenda.
Whether or not the Monetary Policy Committee provides
a forecast of future interest rates, there appears to us to be
a need for more information to be provided by the Monetary Policy
Committee to aid both financial markets and the general public.
We therefore welcome the Governor's thoughts on providing more
information around possible policy reactions should certain risks
crystallise. However, we also recommend that the Bank undertake
regular work to assess the current academic thinking on the feasibility
and desirability of publishing an interest rate forecast, and
keep this matter under review. (Paragraph 108).
The MPC is continually trying to improve the presentation
of the thinking behind its interest rate decisions, both in the
Minutes and in the quarterly Inflation Report. In this
respect, in Section 5 of the August 2007 Report, the MPC
expanded its coverage of the risks to the conjuncture and the
associated implications for policy. With regard to publishing
a forecast for interest rates, the MPC is watching with interest
the small number of other central banks that have recently begun
to do this. Bank staff are in regular contact with their counterparts
at these central banks and also seek to keep abreast of academic
thinking on this issue. The MPC keeps its own procedures under
constant review in the light of experience elsewhere, as well
as developments in academic thinking.
We have heard different views on the need for
immediate transparency on the voting pattern of the MPC. We have
concluded that the balance of arguments supports the need for
immediate transparency of MPC voting, which would allow financial
markets to assess the strength of the support within the MPC for
any given decision. We recommend accordingly that the Bank of
England publish, alongside the interest rate decision, the outcome
of the vote, indicating which individual MPC members voted which
way. (Paragraph 112).
The MPC remains doubtful of the wisdom of revealing
the vote before the associated explanation. Knowledge of
which way someone voted does not explain why they voted that way.
Given that a member could not expand on the reasons for his/her
vote until after publication of the minutes, releasing the vote
at the time of the decision runs the risk of encouraging media
speculation on the reasons for an individual's vote and increases
the simple-minded tendency to portray members as 'hawks' or 'doves'.
Moreover, the vote does not always provide a good guide to how
close a rate decision was. Each member could agree that a decision
is extremely finely balanced, yet the result turn out unanimous.
Conversely, if the MPC is quite polarised, a 5-4 to hold would
not indicate that a vote to change rates is necessarily near at
hand. So in the MPC's view, little value should be attached to
individual votes without the accompanying explanation that appears
in the Minutes. The MPC therefore continues to believe that the
current arrangements are to be preferred.
We were pleased to hear that the Bank is considering
a structured set of discussions between professional economists
and staff members of the Bank, and members of the Monetary Policy
Committee. We recommend that the Bank provide to this Committee
within six months an outline of a plan for such meetings, that
allows for a diverse membership of participants, and allows for
an open and transparent record to be kept. (Paragraph 113).
MPC welcomes the Committee's endorsement of moves
to strengthen contact with professional economists external to
the Bank. We are presently deliberating over the most suitable
format and frequency for such events and will be in touch with
a range of potential outside participants to gather their suggestions.
We expect to host the first such event sometime in the first half
of 2008.
We are concerned about the effects on the debate
within the Monetary Policy Committee of having a paragraph assigned
to each member. However, we believe greater thought should be
given by the Monetary Policy Committee to ensuring that the balance
of views of members is more identifiable with particular individuals,
rather than just identifying how individual members voted. We
therefore recommend that, whenever the minutes at the moment refer
to "one member", that member be named within the text.
(Paragraph 116).
The Committee's own Report amply covers the disadvantages
of associating views in the minutes with particular members, namely
that it may discourage free debate and the exposure of arguments
in order merely to test them. The MPC believes that these reasons
apply just as much to arguments advanced by one member as to those
advanced by more than one member, and that speeches, media interviews
and appearances before the Committee offer plenty of opportunity
for the exposure of the views of individual members.
We have listened with care to the arguments against
each member of the Monetary Policy Committee providing an annual
report to this Committee. We have particularly reflected upon
the concern that such reports might focus attention on a particular
date. However, we are persuaded that regular reports by each member
of the Monetary Policy Committee to this Committee would further
enhance their individual accountability and enhance the value
of our regular hearings with members of the Monetary Policy Committee
about inflation reports. To overcome concerns about timing, we
will request each member to prepare his or her report for a 12-month
period ending with a different month. We wish to receive a report
on that basis from each member of the Monetary Policy Committee
which:
- lists the work they have
undertaken to promote transparency in and wider understanding
of monetary policy in the preceding year;
- assesses their own voting
record in the Monetary Policy Committee over that period; and
- sets out their thoughts on monetary prospects
for the coming year. (Paragraph 119).
There are now (at least) four appearances annually
by the MPC before the Committee. Together with the increased questioning
by the Committee of all MPC members, that has improved the accountability
of the MPC to Parliament.
The MPC notes the Committee's desire for annual individual
reports in order to enhance individual accountability and the
value of the hearings. However, the suggested content of these
reports does raise some issues. In particular, the MPC has tried
to strike a balance between its collective and its individual
communications with the markets, media and general public. That
balance would potentially be disturbed if members were each to
provide a lengthy written individual annual report containing
an evaluation of their voting records and an assessment of monetary
policy prospects, detracting from the collective message that
is embodied in the Inflation Report and MPC Minutes. Moreover,
because of the lags in the effects of monetary policy on inflation,
members cannot in any case properly assess their voting record
over the past year. And because interest rate decisions are taken
one month at a time, neither is it possible for MPC members to
set out their thoughts on the prospects for interest rates.
MPC members can, however, explain the reasons for
their votes over the past year. And linked to that, they can explain
their view of the outlook for inflation and the risks they see
to that outlook. But the MPC believes that the voting record and
speeches given by each member already provide the necessary background
for scrutiny by the Committee. Individual accountability would
then be best enhanced by the Committee using its ability to probe
viewpoints and differences among members in oral questioning rather
than through the provision of additional written reports.
The MPC therefore suggests that, in the future, individual
members will provide a standard form to the Committee containing
a record over the previous year of: votes cast; on-the-record
speeches (with web links); and other activities promoting understanding
and transparency.[2] Members
could provide this information to any timetable that the Committee
desires. But perhaps the most effective arrangement would be for
each of the five members called to appear before the Committee
at a regular hearing to submit such a form. In that way the information
would be fresh and up-to-date and thus a suitable point of departure
for the Committee's oral questions.
2 It is worth noting that the level of such activities
should be expected to vary across MPC members, given the range
of their other responsibilities. Back
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