COALITION PROVISIONAL AUTHORITY REGULATION NUMBER 3:
PROGRAM REVIEW BOARD
6/11/2003

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IRW Commentary:

Responsibility.  The Program Review Board functions much as a finance ministry. "The Board shall be responsible for recommending expenditures of resources from the Development Fund for Iraq..." It shall "review identified requirements for the relief and recovery of Iraq, prioritize these requirements, and integrate the prioritized requirements into a funding plan…" The PRB oversees not only the assets of the DFI but also funds appropriated by the U.S. Congress, Iraqi property vested in the U.S. Treasury, and Iraqi assets seized during the war. The Board does not "oversee the manner in which approved spending requirements are executed."

Governance.  "The Board shall report directly to the Administrator of the CPA."

Membership.  Membership is consistent with the "objective of furthering meaningful representation of the Iraqi people and the Iraqi interim administration in the process of developing budgets for the relief and recovery of Iraq." Members of the PRB may concurrently be officials of the U.S. Departments of Defense, Treasury, or State.

Voting members are:

• Chairman
• Director, Economic Policy
• Director, Civil Affairs Policy
• Director, USAID
• Director, Operations
• Director, Security Affairs

Voting ex officio members are representatives of:

• Commander of Coalition Forces
• U.S. Department of Treasury
• U.S. Department of Defense
• U.S. Department of State
• Iraqi Ministry of Finance
• United Kingdom
• Australia
• Chairman, International Coordination Council

Non-voting members are:

• CPA Comptroller
• CPA General Counsel
• Program Coordinator of the Board
• Representative of the U.S. Office of Management and Budget
• U.S. Office of the Secretary of Defense
• International Monetary Fund
• World Bank

The UN Special Representative of the Secretary General for Iraq and a representative of the International Advisory and Monitoring Board serve as observers.

Concerns:
The mandate of the Program Review Board is that which many expected the International Advisory Board would have. Yet the PRB is subordinated directly to the Administrator and includes no voting members outside Coalition representatives. There is only one Iraqi national represented, and it is still unclear whether the chairman and directors will be U.S. officials or Iraqi nationals. The regulations went into force by approval of the Administrator, not by consensus.

Approved spending plans are to be published in Arabic, but there are no provisions for disclosure of draft spending recommendations, thus removing the opportunity for public comment. There is also no requirement for reporting in English, thus weakening the opportunity for international NGO's to monitor spending. No body has been given responsibility to audit the execution of spending.

The role of the IFI's is also vague: "The IFI's should be given an opportunity to consult with the Board on projects of significant value."