POLIC IES F OR SH PARTICIPATING IN CHANGE AR Promoting public sector E D accountability to all P R O SP ER ITY IN YANM ARM ALL ABOARD Policies for shared prosperity in Myanmar This Policy Note was prepared by: Shabih Mohib (Team Leader and Program Leader); May Thet Zin (Economist); Rob Boothe (Public Sector Specialist) and Soren Davidsen (Senior Governance Specialist) with inputs from Elizabeth Moorsmith (Senior Conflict Specialist) and Corey Pattison (Conflict Specialist) under the guidance of Robert Taliercio (Practice Manager, Governance). ALL ABOARD Policies for shared prosperity in Myanmar participating in change: Promoting public sector accountability to all PARTICIPATING IN CHANGE Promoting public sector accountability to all Myanmar has a unique opportunity to enable people’s participation in change by promoting transparency and accountability throughout the public sector, including in revenue collection, the management of public expenditure, public policy making, and service provision. This could have a pivotal impact on the effectiveness of the public sector and thereby its ability to promote inclusive growth. In Myanmar, the public sector’s historically narrow revenue base and its limited role in public service delivery have led to weak development outcomes.1 A history of opacity and lack of public engagement in policymaking (figures 1 and 2) have fueled corruption and compounded the loss of public trust in government. Figure 1: Transparency of policy-making as viewed by firms Figure 2: Openness of government indicator, Rule of Law Index3 Source: Investment Climate Surveys, Source: The World Justice Project, Rule of Law Index 2014 various years, Myanmar ICA 2014 Yet evidence from other countries shows that active citizen participation can lead to improvements in the quality of public services and development outcomes. Since 2011, Myanmar has begun a process of transformation through more transparency in its Union Budget, increased government spending on socio-economic priorities, decentralized governance, and adoption of community development programs.2 Seizing the opportunity to further improve public sector accountability is critical in the context of growing expectations of improved service delivery and welfare. 1 Please see Policy Note on “Closing the gap: Expanding access to social services.” 2 Please see Policy Note on “Growing together: Reducing rural poverty in Myanmar.” 3 The World Justice Project, Rule of Law Index: This factor measures the extent to which the society has clear, publicized, accessible, and stable laws; whether administrative proceedings are open to public participation 1 Context and opportunities for change Recent reforms have opened up the opportunity and other minerals, the revenue from which by some for Myanmar to respond to large service delivery estimates could account for over 20 percent of GDP. needs. Myanmar currently has a relatively small general These natural resources have an immense bearing on government. 4 General government revenues are at Myanmar’s development prospects. In the gas sector, around 10 percent of GDP, compared to 30 percent the Myanmar Oil and Gas Enterprise is able to retain for emerging markets and middle income countries, around 55 percent of its after tax profits. However, there and 17 percent for low income countries. General are strong arguments for channeling these profits to the government spending is at around 15 percent of GDP, Union Budget.5 Of greater concern are the potentially compared to just over 30 percent for emerging markets large illicit flows of gems and other mineral resources and middle income countries, and 20 percent for low and big rents appropriated by small groups, preventing income countries. As such, the scope for reducing the country as a whole from reaping the benefits of the size of general government is limited; however, these non-renewable national assets. significant potential exists for improving the efficiency and effectiveness of government operations to deliver Myanmar has embarked on the initial phases of better services to the entire population of Myanmar. a transition from a centralized to a decentralized system of government based on its Constitution. This process could be better informed through This also provides opportunities for strengthened greater transparency of public spending plans. public sector accountability by bringing the state Other than the enacted Budget, there is little publicly closer to the people. Initial steps have been taken to available information on government spending priorities establish legislative and executive bodies at State and at the Union, and State/Region level. Neither the budget Region level. But unsurprisingly, the transition is expe- proposal submitted to the Parliament, nor the audited riencing functional tensions between newly established financial statements of the government are currently sub-national institutions and traditional arrangements published. This means that citizens cannot influence of central governance. Although in reality spending and budget allocations or know how much was actually spent revenue assignments of State and Region authorities from their taxes on social, administrative, and economic are still very limited, it will be important to clarify the services. There are also differences in the way budget management responsibility of and accountability for data is classified compared to international standards, selected sub-national public services. which pose challenges in fiscal policy analysis. The publication of budget proposals could help to promote The recent signing of a Nationwide Ceasefire debate not only among parliamentarians, but also civil Agreement offers new opportunities for coordination society groups, the media and the general public to and cooperation between the government and ethnic ultimately improve the quality of budget allocations. administrations in parts of the country that to date have de facto been administered independently. This There is much scope to enhance revenue collections also provides new avenues to promote accountability. through both policy and administration reforms. Managing this transition has many complexities in The government’s tax effort is currently hampered by terms of service delivery, expanding the revenue an official assessment system for tax declaration that base in a fair and equitable manner, agreeing the is susceptible to corrupt practices due to negotiations assignment of fiscal responsibilities for different levels between individual tax officers and taxpayers. The of government, including revenue sharing between the institutional arrangements are highly fragmented with Union Government, and States and Regions. many fees, charges, and levies collected by different government agencies, which increases compliance Whilst Myanmar has a functioning civil service there costs. are a number of areas that warrant closer attention to improve overall performance and service delivery. The management of natural resource rents This is a large area covering the management of the deserve particular attention. Natural resources play civil service, coordination across government, pay a significant role in Myanmar’s economy with the gas and grading of civil servants, meritocratic recruitment, sector at around 8-10 percent of GDP, but also gems promotion and deployment processes, and retention of public servants in hardship areas. 4 This does not cover extra-budgetary or wider public sector 5 Please refer to WB, “Realigning the Union Budget to activities (e.g. State Economic Enterprises). Myanmar’s development priorities: Myanmar Public Expenditure Review 2015.” 2 Recent developments Since 2011, Myanmar has embarked on important spending away from general public services towards Public Finance Management reforms, gradually social sectors, in particular education and health.6 A turning the Union Budget into an instrument for gradual decline in capital investments has provided development. These reforms have been based on fiscal space for salaries and wages of public servants, comprehensive diagnostic studies of PFM systems and essential goods and services in the social sectors. and processes in Myanmar, including the Public The government has also started diversifying financing Expenditure and Financial Accountability Assessment sources away from Central Bank financing of fiscal report (2013), which is publicly available. The Myanmar deficits – through securing foreign loans and grants for Public Expenditure Review (2015) is a comprehensive capital projects, and auctioning of treasury bills. analysis of spending policies, which included a major effort to transfer fiscal data for the first time to an Since 2011, progress has been made in increasing electronic database referred to as BOOST. To enhance the transparency and fairness of the revenue col- transparency, Union Budget debates are now televised, lection system. A large taxpayers’ office was estab- the enacted budget is published as well as for the first lished in April 2014 and a Self-Assessment System for time a Citizens’ Budget, which helps to communicate large taxpayers introduced in 2015 to efficiently direct budget policies in an accessible manner. These are big tax collection efforts where returns will be the highest. steps particularly when considering where the budget Public officials have been brought into the tax-net to process was four years ago. expand the tax base; commercial tax rates have been harmonized and standardized at 5% for most goods; PFM reforms have already started to deliver and a taxpayer service function has been established. results. The development of a Medium-Term Fiscal In addition, Myanmar has secured candidacy of the Framework has helped to maintain discipline over Extractive Industries Transparency Initiative (EITI) with spending growth while encouraging strategic the first report published in early 2016 – a major mile- resource allocation across sector priorities. For stone in the transparency of natural resource revenue example there has been a major reprioritization in management. 6 Please see Policy Note on “Closing the gap: Expanding access to social services.” 3 The above reforms have helped to improve compli- Myanmar has made significant gains in improving ance rates and strengthen enforcement capacity of response times for some public services. For the Internal Revenue Department, and have begun to example, the issuance of passports and driver licenses contribute to increased revenue collections. General in main urban centers like Yangon has been cut from government revenues have grown from 6 percent of more than 2 months prior to 2010 to less than 2 GDP in 2009 to around 10 percent in 2013 (figure 3). weeks. Similarly the government has implemented an Income taxes and consumption taxes make up the bulk e-visa system that allows visitors to apply for a tourist of revenues in Myanmar, like in other countries though visa on-line and within five days have the application the actual level of tax receipts is still significantly lower processed. Myanmar is currently piloting one-stop (figure 4).7 One off measures (eg. telecom licensing shops in several States and Regions, and is also receipts) have also contributed to higher revenues. considering the establishment of one-stop service provision desks at all township offices where citizens can obtain information regarding all public services. Figure 3: Government revenue 2009-2013 (% of GDP) Figure 4: Revenue composition 2013-2014 (% of GDP) Source: WDI and WB Staff estimates Source: Ministry of Finance BOOST database and WDI 7 Based on a sample of East Asian countries: Cambodia, China, Indonesia, Korea, Lao PDR, Malaysia, Philippines and Thailand 4 Republic of Korea Pakistan Vietnam Thailand Malaysia Regional experiences and lessons Vietnam’s experience with revenue reforms may On public expenditure transparency and reform, offer good insights, in particular for the transition Thailand could offer a number of useful lessons from an Official Assessment system to a Self- from its transition from input-based to performance- Assessment system, which Myanmar is currently based budgeting. The effects of the Asian Financial undergoing. This is a major reform with potentially high Crisis in 1997 highlighted the need to significantly returns – but it requires political and management will, reform budget management in Thailand so as to focus significant building of technical capacity and reskilling on public service performance and actively manage of tax inspectors and auditors, and institutional rede- fiscal risks. Budget management reform was part sign. Vietnam piloted its Self-Assessment System in and parcel of broader public sector management 2004 for 2 provinces starting with Value Added Tax reform. The government’s focus turned to outputs, and Corporate Income Tax. After the successful pilot, outcomes, performance measurement, transparency, the authorities rolled out the Self-Assessment system accountability and people-oriented development. across all provinces for all tax types in 2006. Whilst the system is constantly evolving based on emerging challenges, Thailand’s budget reforms Moving from the administered assessment system significantly improved fiscal discipline – with budget to a self-assessment system was a centerpiece of deficits at less than 3 percent of GDP on average over Vietnamese Tax Administration reforms and has the last decade. This not only helped to focus more on contributed to lowering compliance costs and service delivery results but also helped to build up fiscal increasing tax yields. Government revenues went up buffers (e.g. through falling debt stocks), which enabled from around 18 percent of GDP in the late 1990s to 27 Thailand to effectively weather the 2008 global financial percent of GDP in 2011.8 Vietnam’s domestic revenue crisis. By 2015 the total public debt to GDP stood at capacity has been central to linking government 43 percent of GDP, giving Thailand the fiscal space to spending to development priorities. It has provided implement countercyclical fiscal policy. stability, predictability and autonomy in prioritizing resources according to the country’s development priorities. 8 Revenue to GDP have fallen more recently due to tax rate cuts and falling oil revenues. 5 Significant room for improvement remains, including publishing the budget proposal, periodic reports on implementation, and audited financial statements, as well as meeting international good practice on the types of disclosures made and the standards applied. Others in the region have gone through similar Figure 5: Open Budget Index scores budget reforms, which although are long-term in (higher score = more transparent) nature can also have large payoffs in the short- term. For example, The Republic of Korea initiated major reforms in response to the Asian Financial Crisis including the introduction of Medium-Term Expenditure Frameworks. These led to more predictable and per- formance oriented budgeting. Malaysia has gradually built up its performance-based budgeting system over a period of 30 years, and over time provided more and better information on service delivery standards. Establishing greater fiscal transparency has been a common thread across all reformers. Evidence shows that fiscal transparency is both important for macroe- conomic management and for promoting citizen partic- ipation and government accountability in public service delivery. Several standards have been developed to assess the degree of fiscal transparency including the Source: International Budget Partnership Global Initiative for Fiscal Transparency,9 Organization for Economic Cooperation and Development (OECD) “Best Practices for Budget Transparency10”; the Open There has also been a growing trend in countries on Budget Partnership’s Open Budget Index11; and the ‘Citizen Centric Service Delivery’, which may provide IMF Code of Good Practices on Fiscal Transparency. good lessons for Myanmar in setting standards of public service delivery. In these cases, citizen feedback These set out not only good practice in terms of is used to improve quality and responsiveness from disclosure of fiscal reports, but also in terms of the fiscal public agencies. Such a system of citizen engagement data classification, coverage and comprehensiveness helps strengthen trust in government, and also of those reports. Myanmar is currently ranked among allows the government to constructively engage with countries with the least transparent budgets in the citizens over everyday issues. Building citizen trust in world (figure 5), but has begun to move towards government services and government responsiveness greater transparency by publishing its budget and by to citizen feedback will be especially important in areas introducing a citizen’s budget. 9 http://www.fiscaltransparency.net/ 10 http://www.oecd.org/gov/budgeting/ 11 http://internationalbudget.org/opening-budgets/ open-budget-initiative/ 6 where government presence has been historically for quality of teaching as measured by standardized limited, including independently administered areas testing. Furthermore, the government initiated a public in Myanmar. Some examples are discussed in Box 1 awareness campaign so parents knew the standards of below. education they could expect their children to receive. Such reforms, undertaken in 2000s, have contributed For example, countries in Latin America such as Peru to marked improvements in quality of education; for and Chile have implemented nationally mandated example, In Peru, the proportion of children ranked education standards, with a variety of dimensions in the lowest category of testing scores fell from 46% ranging from quality of infrastructure and accessibility in 2006, to 30% in 2007, to just 23% in 2009. Further of textbooks and equipment, to minimum standards examples of promoting accountability for service delivery performance are listed in the box below. The World Development Report 2004, “Making Services Work for Poor People” noted that the main difference between success and failure was the degree to which poor people themselves were involved in determining the quality and the quantity of services they received. It documented three ways in which services could be improved: by increasing poor clients’ choice and participation in service delivery, so they can monitor and discipline providers; by raising poor citizens’ voice, through the ballot box and making information widely available; and by rewarding the effective and penalizing the ineffective delivery of services to poor people. With Myanmar’s recent reforms and development, the country is well placed to improve all three relationships. The successful elections in November 2015 contributed to strengthening the first link from people to policy makers. The second link between policy makers and providers can be strengthened by incentivizing public servants’ performance. This will also require strengthened institutions. Deployment and in particular retention of e.g. health and education workers in poor and remote areas can be improved through recruitment of public servants from these areas, enhanced career progression and better access to infrastructure. Several countries in the region have made innovative reforms to strengthen accountability between people and service providers - the third link above. Countries have taken different routes to establishing modes of ‘citizen centric service delivery’, which may be relevant for both Union level agencies in Myanmar but also municipal authorities. Malaysia around 2000 started providing public services like renewal of car registration, driving licenses, passports and other administrative procedures in convenient locations that the public can access easily. In 2008 the govern- ment established one-stop service centers. Malaysia also established minimum standards for waste collection with a helpline to report any fall in standards, which local authorities are required to address. This type of a feedback mechanism is also practiced in Thailand for street lighting, waste collection, and street cleaning. In early 2008 one district in Pakistan’s Punjab province, recognized the need to strengthen citizens’ role in the monitoring of service delivery – the third link above. The district began to contact citizens on their cell phones to learn about the quality of the service they had received. Those spot checks became the basis for a social audit system that spanned all 36 districts in Punjab by 2014. The provincial government outsourced much of the work to a call center, which surveyed citizens about their experiences with 16 different public services. The data from that call center helped district coordination officers identify poorly performing employees and branches, thereby enhancing the capability of the government to improve service delivery. By early 2014, the province was sending about 12,000 text messages daily to check on service quality. More than 400,000 citizens provided information between the beginning of the initiative and 2014. Known as the Citizen Feedback Monitoring Program, the Punjab’s social audit system became the template for similar innovations in other provinces and federal agencies in Pakistan. Box 1: A framework for stronger accountability and improving services for the people of Myanmar 7 8 PARTICIPATING IN CHANGE Promoting public sector accountability to all Policy options Enhanced transparency of public finances: strengthen trust and understanding between state and The public has welcomed and embraced recent citizens on tax matters, and has begun to introduce a measures to enhance budget transparency, as client-centered strategy of compliance management, reflected in Parliamentary debates, the media with a strong focus on taxpayer services and outreach. reporting, and third party budget analysis, Preliminary results of this approach appear very including debates promoted by Civil Society successful – with 95 percent compliance. Myanmar Organizations. Myanmar can build on these plans to establish Medium Taxpayer Offices for major efforts, including the current practice of cities like Yangon and Mandalay, and to roll out self- publishing the enacted budget, by further assessment in these jurisdictions. This will help to disclosing a number of strategic documents further create much needed fiscal space, strengthen such as: Citizens’ Budget a Medium-Term the trust between the state and the public, and ensure Fiscal Policy Statement, the Union Budget a fairer and transparent tax system. After introducing proposal submitted to the Parliament, the self-assessment with corresponding enforcement and audit report, and more detailed information taxpayer service mechanisms, Cambodia managed to on Union spending at the State/Region grow revenues from 10% of GDP to 17% of GDP in just level. This could be complemented with 5 years. efforts to gradually adopt international standards of fiscal data classification. The Empowering local governments to represent their government could also consider releasing citizens through fiscal decentralization:12 Myanmar detailed budget data captured in the BOOST has taken the first steps towards providing state and database to promote research and analysis region governments the tools to better meet the specific on public finances. For example, researchers needs of citizens in their areas. The introduction of a in Moldova combined the publically released simple, rules based system of intergovernmental fiscal BOOST data on public expenditure with service transfers, and the growing share of local government delivery output data to identify relative efficiency revenues will help Myanmar to achieve the vision of spending on education. This helped guide of decentralized local self-governance articulated policy interventions for education towards areas in the 2008 Constitution. Important next steps will and schools of greatest need. include clarifying expenditure assignments for various tiers of government, determining the assignment of Fair and transparent tax collections: Myanmar different taxes and revenues sources, either fully or in has committed to modernizing and improving its proportion, which are allocated to states and regions, tax system by moving towards self-assessment and and establishing appropriate institutional arrangements voluntary compliance. This program is already being to manage fiscal decentralization, including a technical piloted in the newly established Large Taxpayer’s secretariat office within the Ministry of Finance. Office in Yangon. The LTO has recognized the need to 12 Please see also Policy Note on “Growing together: Reducing rural poverty in Myanmar.” 9 Public engagement and feedback on policy reforms: Adopting minimum standards for public services: Myanmar is transitioning from a closed system with Sub-national authorities, in particular municipal author- strict controls over the flow of information, towards a ities, are currently able to impose fees and charges for more open system where information is shared with local public services. Myanmar could therefore benefit the public through various channels. Progress has from establishing some comparatively equitable basic been rapid since 2010, and from a relative perspective minimum service delivery standards for municipal unrivalled as compared to progress in the region13. services across the country – including in de facto Civil society organizations are growing in number and independently administered areas. Some of the key engagement in policy discussions. Access to infor- minimum standards could include: Response time for mation on public finance and public policies has also waste collection, street cleaning, and street lighting and improved as noted above. To move this forward, the establishing a system where residents can report any government could consider conducting public consul- outages and agencies report back to them when the tations on all legislative instruments pertaining to public issue has been resolved. finance management (e.g. the Public Debt Law) and institute a process feedback on consultations. Most industrialized countries identify service delivery standards to help citizens hold local governments to Based on this experience the government could con- account; good examples include municipal govern- sider developing a general Law on Regulating Issuance ments in the United States, which publish statistics on of Legal Documents that mandates consultation and frequency of waste collection, cost/efficiency of service publication of all legal documents to ensure their effec- provision, number of incidents reported where waste tiveness. Following commitments made under the its was not collected, and customer satisfaction. Similarly, WTO agreement and other bilateral trade agreements, Canada establishes minimum standards for education Vietnam passed a law in 2006 requiring publication of with respect to attendance, standardized test scores, and public comments on all draft legal normative doc- graduation rates – schools receive financing on the uments before being passed. Publicizing drafts of laws basis of meeting or improving on these basic minimum and inviting comments reduced uncertainty on the part standards. of the business environment and citizens about what laws will say.14 13 Myanmar has committed to joining the Open Government Partnership by 2016 (http://www.opengovpartnership.org/) 14 The effect of introducing this law was reflected in improved scores on legal transparency in several surveys from 2006 and onwards. See http://eng.pcivietnam.org/pci-data-c16.html 10 The table below proposes short-term (within 1 year) and long-term (within 3-5 years) policy options for the next five years (2016-2020) to help deliver on the above objectives of enhanced transparency of public finances; a fair and transparent tax system; empowering local governments to meet local needs; Public engagement and feedback on policy reforms; adopting minimum standards for public services. PARTICIPATING IN CHANGE Promoting public sector accountability Objectives to all Short-term Options Long-term options Roll out the self-assessment system of Publish tax expenditures and compli- tax declarations for all taxpayers. ance rates for all tax types both online and in the government gazette A fair and transparent Publish and disseminate annual EITI Reconciliation Report, including tax system increasing coverage onf the jade and gems sub-sectors. Strengthen National EITI Secretariat within the Ministry of Finance Publish Citizens’ Budjet, the Medium- Publish quarterly budget execution Term Fiscal Policy Statement, the data, annual audit report, and more Enhanced Union Budget proposal submitted detailed information on Union spending transparency of to the Parliament and put on MOF at the State/Region level both online public finances website the BOOST database on and in the government gazette. public finances to promote research Gradually adopt international and analysis. standards of budjet classification.15 Establish a secretariat function for Refine existing institutional arrange- Empowering local fiscal decentralization to provide ments and civil service mechanisms governments to technical advice on key policy to promote more flexible management meet local needs questions, including the assignment of within a framework of accountability expenditures and revenues for results. Public Conduct public consultations on all Develop a general Law on Regulating legislative instruments pertaining Issuance of Legal Documents that engagement and to public finance management (e.g. mandates consultation and publica- feedback on the Public Debt Law) and institute a tion of all legal documents to ensure policy reforms process feedback on consultations. their effectiveness. Publish current performance by Adopt minimum standards on Adopting government agencies with regards to response time for waste collection, basic municipal services. street cleaning, and street lighting and minimum establish a system where residents standards for can report any outages and agencies public services report back to them when the issue has been resolved. 15 IMF Government Finance Statistics Manual, UN Classification of Functions of Government. 11 PARTICIPATING IN CHANGE Promoting public sector accountability to all References Besley, Timothy, Rohini Pande, and Vijayendra Rao,“Participatory Democracy in Action: Survey Evidence from South India,” Journal of the European Economic Association, 3(2-3), April-May, 2005 Chaudhuri, Shubham, K.N. Harilal, and Patrick Heller, “Building Local Democracy: Evaluating the Impact of Decentralization in Kerala, India,” World Development, 35(4), 2007 Myanmar Public Expenditure and Financial Accountability Assessment (World Bank and UK, 2013) Myanmar Public Expenditure Review (World Bank and Australia, 2015) Díaz-Cayeros et al (2013): Díaz-Cayeros, Alberto, Beatriz Magaloni, and Alexander Ruiz-Euler, “Traditional Governance, Citizen Engagement, and Local Public Goods: Evidence from Mexico,” World Development, 53, January 2014 Guidelines for Public Debt Management (IMF and World Bank, 2014) Gonçalves, Sónia, “The Effects of Participatory Budgeting on Municipal Expenditures and Infant Mortality in Brazil,” World Development, 53, January 2014 Beyond the Annual Budget: Global Experience with Medium-Term Expenditure Frameworks (World Bank, 2013) Pardhan et al (2011): “ Improving Educational Quality through Enhancing Community Participation: Results from a Randomized Field Experiment in Indonesia Service Delivery Indicators (http://www.sdindicators.org/) 12 ALL ABOARD Policies for shared prosperity in Myanmar GROWING TOGETHER FINANCING THE FUTURE BREAKING BUSINESS AS USUAL ENERGIZING MYANMAR CLOSING THE GAP PARTICIPATING IN CHANGE Reducing rural poverty Building an open, modern and Fostering competitiveness and a dynamic Enhancing access to Expanding access to Promoting public sector in Myanmar inclusive financial system environment for private sector growth sustainable energy for all social services accountability to all “This Policy Note is part of a series entitled All Aboard! Policies for shared prosperity in Myanmar” CLOSING THE GAP GROWING TOGETHER BREAKING BUSINESS AS USUAL Expanding access to Reducing rural poverty Fostering competitiveness and a dynamic social services in Myanmar environment for private sector growth FINANCING THE FUTURE ENERGIZING MYANMAR PARTICIPATING IN CHANGE Building an open, modern and Enhancing access to Promoting public sector inclusive financial system sustainable energy for all accountability to all PARTICIPATING IN CHANGE Promoting public sector accountability to all ALL ABOARD Policies for shared prosperity in Myanmar The World Bank Myanmar No.57, Pyay Road 61/2 Mile, Hlaing Township, Yangon, Republic of the Union of Myanmar. www.worldbank.org/myanmar www.facebook.com/WorldBankMyanmar myanmar@worldbank.org