¹ Int’l Monetary Fund Board of Governors Res. 66-2, Fourteenth General Review of Quotas and Reform of the Executive Board (Dec. 15, 2010), in IMF, Selected Decisions and Selected Documents of the International Monetary Fund 14–18 (2014), at http://www.imf.org/external/pubs/ft/sd/2013/123113.pdf [hereinafter IMF Selected Decisions and Documents] (proposing amendments to Articles XII, XXI, and XXIX, and to Schedules A, D, E, and L of the IMF’s Articles of Agreements); G-20: Fact Sheet on IMF Reform, The White House (Nov. 12, 2010), at https://www.whitehouse.gov/the-press-office/2010/11/12/g-20-fact-sheet-imf-reform; Chan, Sewell, Debt Crisis Highlights I.M.F.’s Renewed Role, N.Y. Times, Nov. 26, 2010, at B3 Google Scholar (“Under pressure from the United States, Europe has ceded two seats on the fund’s board. . . .”);see also Truman, Edwin M., IMF Reform is Waiting on the United States, Peterson Inst. Int’l Econ., Mar. 2014, at 1 Google Scholar, available at https://www.piie.com/publications/pb/pb14-9.pdf (identifying the Obama administration as the “principal architect” of the reform package).

² See Calmes, Jackie, I.M.F. Breakthrough Is Seen to Bolster U.S. on World Stage, N.Y. Times, Jan. 6, 2016, at B1 Google Scholar.

³ IMF Press Release, IMF Executive Board Approves Major Overhaul of Quotas and Governance, IMF Press Release No. 10/418, (Nov. 5, 2010) [hereinafter Press Release No. 10/418].

⁴ Id.

⁵ Factsheet: IMF Quotas, IMF (Jan. 27, 2016), at http://www.imf.org/external/np/exr/facts/quotas.htm [hereinafter Factsheet: IMF Quotas].

⁶ Articles of Agreement of the IMF, Art. III(4) sec. (a), 60 Stat. 1401, 2 UNTS 39 [hereinafter IMF Articles of Agreement]; Fact Sheet: IMF Quotas, supra note 5 (explaining that quota reviews allow the IMF to “assess the adequacy of quotas both in terms of members’ balance of payments financing needs and in terms of its own ability to help meet those needs” and to increase members’ quotas “to reflect changes in their relative positions in the world economy”).

⁷ Press Release No. 10/418, supra note 3.

⁸ Id.

⁹ Id. The Congressional Research Service explains: “In addition to its quota resources, the IMF maintains standing multilateral borrowing arrangements to temporarily supplement available quota resources and borrowing. The main borrowing arrangement, the New Arrangements to Borrow (NAB), is a set of credit arrangements between the IMF and 38 member countries that can provide about $510 billion of supplementary resources to the IMF.” Rebecca M. Nelson & Martin A. Weiss, Cong. Research Serv., R42844, IMF Reforms: Issues for Congress 3 (2015).

¹⁰ Truman, supra note 1, at 2.

¹¹ Nelson & Weiss, supra note 9, at 4.

¹² Id.;see also Edwin M. Truman, The Congress Should Support IMF Governance Reform to Help Stabilize the World Economy, Peterson Inst. Int’l Econ., Mar. 2013, at 7, available at http://www.piie.com/publications/pb/pb13-7.pdf (“IMF use of borrowed resources involves a second layer of rules, which tends to undermine the basic governance structure of the institution.”).

¹³ IMF Executive Directors and Voting Power, IMF, at https://www.imf.org/external/np/sec/memdir/eds.aspx (last updated Feb. 21, 2016).

¹⁴ Alexander Mountford, The Formal Governance Structure of the International Monetary Fund, IMF Doc.No. BP/08/01, at 11 (Mar. 2008) (“The election rules are quite complex but are intended to ensure a reasonable geographical balance in member countries’ representation, and to facilitate the continuation of constituency arrangements that members have made among themselves and wish to preserve.”).

¹⁵ Id.; see also Nelson & Weiss, supra note 9, at 8 n.17.

¹⁶ See Mark S. Copelovitch: The International Monetary Fund in the Global Economy 45 (2010). For example, Austria, Belgium, Luxembourg, Turkey, and several central and eastern European countries had formed a group to elect a single executive director, who casts the combined voteson behalf Of the “constituency” that elected him or her. Id. For some of these groups, the largest country traditionally held the executive director position, while for others, the seat rotates among countries in the group. Id.

¹⁷ Press Release No. 10/418, supra note 3.

¹⁸ IMF, Bd. Of Governors Resolution No. 66-2 (Dec. 15, 2010).

¹⁹ Id.

²⁰ Nelson & Weiss, supra note 9, at 9.

²¹ IMF Articles of Agreement, supra note 6, Art. III(3) sec. 2(c) (“An eight-five percent majority of the total voting power shall be required for any change in quotas.”);see also id. Art. III(3) sec.3(certain decisions regarding payments when quotas are changed must be approved by a 70 percent majority of the total voting power).

²² Id. Art. XXVIII(a).

²³ IMF Press Release, IMF Board of Governors Approves Major Quota and Governance Reforms, IMF Press Release No. 10/477 (Dec. 16, 2010) (“When voting ended on December 15, 2010, Governors representing 95.32 percent of the total voting power had cast votes in favor of a Resolution on Quota and Reform of the Executive Board.”).

²⁴ IMF Members’ Quotas and Voting Power, and IMF Board of Governors, Int’l Monetary Fund (Apr. 18, 2016), at https://www.imf.org/external/np/sec/memdir/members.aspx#1.

²⁵ 22 U.S.C.§286c (2012) (“Unless Congress by law authorizes such action, neither the President nor any person or agency shall on behalf of the United States (a) request or consent to any change in the quota of the United States . . . or (e) accept any amendment under article XXVIII of the Articles of Agreement of the Fund.”).

²⁶ Nelson & Weiss, supra note 9, at 11–12.

²⁷ Truman, supra note 12, at 5–7.

²⁸ Id.; see also Jim DeMint, Editorial, How the U.S. Can Help Europe: Just Say No, Wall St. J., Dec. 9, 2011, at A15.

²⁹ See Office of Mgmt. & Budget, Exec. Office of the President, Budget of the U.S. Government, Fiscal Year 2014 132 (2013); Office of Mgmt. & Budget, Exec. Office of the President, Budget of the U.S. Government, Fiscal Year 2015 186 tbl. S-9 (2014); Office of Mgmt. & Budget, Exec. Office of the President, Budget of the U.S. Government, Fiscal Year 2016 117 tbl. S-9 (2015).

³⁰ Talley, Ian, White House Pushes IMF Changes, Wall St. J., Dec. 28, 2013, at A4 Google Scholar.

³¹ Ed O’Keefe, Senate Ukraine Aid Bill Will Not Include IMF Changes, Wash. Post (Mar. 25, 2014), at https://www.washingtonpost.com/news/post-politics/wp/2014/03/25/reid-considering-dropping-imf-language-from-ukraine-aid-bill/; see Ukraine Freedom Support Act of 2014, Pub. L. No. 113-272, 128 Stat. 2952.

³² The Annual Testimony of the Secretary of the Treasury on the State of the International Financial System: Hearing before the H. Comm. on Financial Services, 114th Cong. 76–77 (2015) (statement by Jacob Lew, Secretary of the Treasury).

³³ Consolidated Appropriations Act, 2016, Pub. L. No. 114-113, § 9, 129 Stat. 2242, 2828-34 (2015) (to be codified at 22 U.S.C. §§ 286e-2, 286ww, 286xx, 286o).

³⁴ Id.

³⁵ See IMF Press Release, IMF Executive Board Approves Exceptional Access Lending Framework Reforms, IMF Press Release No. 16/31 (Jan. 29, 2016).

³⁶ Consolidated Appropriations Act, 2016, § 9, 129 Stat. at 2828.

³⁷ Calmes, supra note 2; Ian Talley, How Congress Finally Passed IMF Governance Overhauls, Five Years After the Deal Was Signed, Wall St.J. (Jan. 4, 2016), at http://blogs.wsj.com/economics/2016/01/04/how-congress-finally-passed-imf-governance-overhauls-five-years-after-the-deal-was-signed/(“Critics say the IMF’s so-called ‘systemic exemption’ loophole, which allowed the fund to green-light an unprecedented amount of money to Greece in 2010 despite clear signs the country’s debt was unsustainable, fuels irresponsible borrowing by countries and feck less risk-taking by markets.”).

³⁸ Consolidated Appropriations Act, 2016, § 9, 129 Stat. at 2828.

³⁹ Press Release No. 16/31, supra note 35.

⁴⁰ IMF Press Release, IMF Managing Director Christine Lagarde Welcomes U.S. Congressional Approval of the 2010 Quota and Governance Reforms, IMF Press Release No. 15/573 (Dec. 18, 2015) (“The United States Congress approval of these reforms is a welcome and crucial step forward that will strengthen the IMF in its role of supporting global financial stability. The reforms significantly increase the IMF’s core resources, enabling us to respond to crises more effectively, and also improve the IMF’s governance by better reflecting the increasing role of dynamic emerging and developing countries in the global economy. A more representative, modern IMF will be even better equipped to meet the needs of all its 188 member countries in the 21st century.”) (statement of IMF Managing Director Christine Lagarde).

⁴¹ Jonathan Spicer, Osborne Calls U.S. Congress’s China Stance a “Tragedy,” Reuters (Dec. 7, 2015), at http://uk.Reuters.com/article/uk-britain-osborne-idUKKBN0TQ2BL20151207.

⁴² An Lu, China’s Zhou Says IMF Members Frustrated with Quota Reform Delay, Xinhuanet (Apr. 17, 2015), at http://news.xinhuanet.com/english/2015-04/18/c_134160977.htm (statement of China’s Central Bank Governor Zhou Xiaochuan).

⁴³ Perlez, Jane, China Creates a World Bank of Its Own, andthe U.S. Balks, N.Y. Times, Dec. 4, 2015, at A1 Google Scholar.

⁴⁴ What is the AIIB?, The Asian Infrastructure Investment Bank, at http://euweb.aiib.org/html/aboutus/introduction/aiib/?show=0 (last visited Apr. 25, 2016).

⁴⁵ Perlez, Jane, U.S. Opposing China’s Answer to World Bank, N.Y. Times, Oct. 9, 2014, at A1 Google Scholar.

⁴⁶ Higgins, Andrew & Sanger, David E., 3 European Powers Say They Will Join China-Led Bank, N.Y. Times, Mar. 17, 2015, at A4 Google Scholar.

⁴⁷ U.S. Dep’t of Treasury Press Release, Remarks of Secretary Lew at the Asia Society Northern California on the International Economic Architecture and the Importance of Aiming High (Mar. 31, 2015), at https://www.treasury.gov/press-center/press-releases/Pages/jl10014.aspx.

⁴⁸ Calmes, supra note 2.