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Remove these targets: 1) Total number of countries that have reached their Heavily Indebted Poor Countries Initiative (HIPC) decision points and number that have reached their HIPC completion points (cumulative) Comment: HIPC is now irrelevant. There are only two countries (Somalia and Sudan) which may go through the HIPC process. 2) Debt relief committed under HIPC initiative Comment: HIPC is now irrelevant. 3) International reserves (net of annual interest payments on the debt) expressed Comment: This has little relevance to debt policy. International reserves are not the only way for countries to protect themselves against externally caused financial crises; capital account management and other policies are alternatives which may be much more effective. Furthermore, holding large amounts of international reserves imposes an opportunity cost on governments because the resources could have been invested usefully for sustainable development. Change these targets: 1) Number of countries assessed by the IMF as being: In/at high risk/moderate risk of debt distress The IMF debt sustainability framework does not properly assess debt's relationship to sustainable development for a number of reasons: - It basis 'sustainability' on whether a debt is and can be paid, not the impact of debt payments on sustainable development (for example, on poverty and inequality) - It is only carried out properly, including producing a risk rating, for low income countries. - It does not properly take into account domestic government and private sector debts, external private sector debts, contingent liabilities and payment obligations accruing to governments from public-private partnerships - It has a conflict of interest by being carried out by two large creditors, the IMF and World Bank Alternative indicators should therefore be used instead / as well. If the IMF debt sustainability framework is used, it should be made to align with the SDGs by: - carrying out the assessment for all countries - basing the assessment on the impact of debt burdens on sustainable development - fully including domestic government and private sector debts, external private sector debts, contingent liabilities and payment obligations accruing to governments from public-private partnerships within the analysis - over time, moving assessments to an independent body which is neither a creditor nor a debtor 2) Debt service as a percentage of exports of goods and services Comment: Debt service is one of several relevant indicators. If choosing only one debt service indicator, it would be most relevant to use debt service as a percentage of government revenue, as this most shows the financial impact on debt on government finances, and so the ability of a government to finance sustainable development. As well as debt service to revenue, and debt service to exports, other indicators which could be used include public debt to GNI, external debt to GNI, international investment position, and current account balance. Oher indicators which should be used: 1) "number of countries entering debt distress which receive comprehensive debt relief". Comment: HIPC is out of date. But if countries enter debt distress, they still need comprehensive debt relief to get them out of it, and thereby enable sustainable development to take place. 2) "no country in debt distress for two successive years, and minimum number of countries at high and moderate risk of debt distress." Comment: Rather than just measuring how many countries are in debt distress, there should be a goal of not allowing any country in debt distress to continue in that state, and minimising those at risk. 3) Number of countries that have passed comprehensive national vulture funds legislation, weighted by proportion of international debt covered by such legislation. Comment: One barrier to effective international debt resolution are the actions of vulture funds and holdout creditors. One measure of showing international action on debt problems would be the number of countries which have passed legislation which enforces internationally agreed debt restructurings, weighted by how much international debt (debt owed under non-domestic law) is covered by such legislation. 4) Number of countries that audit their debt stock based on responsible lending and borrowing principles. Comment: The quality of debt matters more than the numerical amount. If loans are well spent they can enable sustainable development. However, they can also fund activities which undermine sustainable development, and in addition leave damaging debt burdens. The more debt aits are held, the more investigation there is of the quality of loans and debt, and ability of stakeholders to advocate for better lending and borrowing. 5) Percentage of debt stock that contains properly collective-collective action clauses. Comment: One proposal that has been suggested to deal with the problem of vulture funds is to properly collectivise collective action clauses. Those advocating this approach (as opposed to an international legal framework) should therefore also be advocating a target for how much of a country's debt governed under international law is covered by collective action clause which are truly collective across all of that country's debt under international law. This should include all bilateral, multilateral and private debt owed under international law (not just bonds). 6) Percentage of debt stock covered by legal frameworks for sovereign debt restructurings Comment: The failure at the heart of international debt is the lack of legal frameworks for debt restructurings.