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There's considerable subtlety involved in judging
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whether lending activity at premium interest rates does or does not constitute a subsidy.
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Almost always, it will be profitable
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if paid back relative to the lender's borrowing costs.
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Almost always, it will be at an interest rate
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that is lower than the borrower could borrow at on the markets.
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And almost always, in the case of public or quasi-public activity,
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there will be a reasonable argument
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that the lender is better at collecting than the private sector would have been.
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So, the question of evaluating subsidy is difficult.
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The position that I always took as Secretary of the Treasury,
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with respect to the IMF, was,