Reserve Bank of Australia & The Missing Bar Numbers

Early in 2014 I lodged a Freedom of Information (FOI) Request with the Reserve Bank of Australia (RBA) to release the list of Gold bars that make up Australia's official reserves. After initial rejection, an appeal with The Office of the Australian Information Commissioner resulted in the RBA providing the list (melter/assayer, gross weight, assay and fine weight), but without revealing the serial numbers.

With 99.9% of Australia's Gold reserves being stored with the Bank of England (BoE) it pleased me to see that in 2014 the RBA had performed an audit on Australia's Gold reserves. I wrote another FOI Request to gather more information on the audit as the single line of text in the Annual Report was lacking in detail, "During the year in review, the Bank audited its gold holdings, including that portion held in safe custody at the Bank of England."

The result of the second FOI Request was a small cache of emails including communications with the BoE prior to the audit.

Something I had read, but overlooked the importance of, when the Gold bar list was originally provided was the difference between the BoE's bar number and the refiner bar number (I'd initially assumed that they were one and the same).

"The only information we will withhold from release are the individual bar numbers, as this information remains confidential (in the opinion of both the Bank of England and the Reserve Bank of Australia). The Bank of England (as our custodian) use their own numbering system to uniquely identify each bar and have reaffirmed to us that these numbers should not be disclosed to third parties as the information is confidential." RBA

Though an anonymous comment on my post had picked up on the difference.

"What a joke from BoE and RBA re serial numbers. Each bar has it own number from the refiner, that is what should have been disclosed and could have without any confidentiality breach. The BoE special internal numbers did not have to be disclosed and are useless anyway in terms of ensuring the validity of the bar list.

Is the RBA saying that it and the BoE do not know the refiner bar numbers or have never recorded it? I find that hard to believe and if true is damning on their vault management."

Warren James at Screwtape Files followed up with an article on the emails from the audit. Amongst the humour (audio conversation between the RBA & BoE is a must listen) he highlights that the email communication mentions the BoE number.

"Each bar is marked with a unique BoE number" Maybe that was what BoE & RBA got confused with and why they didn't supply the serial numbers. If that were the case then the mixup would be gross incompetence in the whole matter. Definitely the BoE should not disclose their own internal tracking number since it would reveal detail about how the bank functions.

To clarify there was a difference between the two numbers (and if so to question why the refiner number couldn't be released) I wrote to the RBA again. If the BoE catalogues and tracks their Gold bars using an internal number, then what legitimate reason does the RBA have for withholding the refiner bar number following the original FOI Request? I received a response to my questions last week (questions in bold, RBA response in italics):

Is the unique Bank of England bar number different to the refiner bar number? It is our understanding that the Bank of England bar numbers are different to any markings that are placed on bars by the bar manufacturers. All bar lists relating to the RBA’s gold holdings show only one serial number per bar, the BoE serial number.

If so, why was the refiner bar number withheld from publication (oversight, on purpose or not present on the bar list)? N/A, for the reason detailed in answer to question 1.

If so and the refiner bar number is not used internally by the BoE (as a unique identifier, which their internal bar number acts as), can these be released as an extension of RBAFOI-131418 or would I need to submit a new request?  This question is based on the assumption that there are two unique numbers on each bar, being the Bank of England bar number and a ‘refiner bar number’. As noted above, all documentation provided to the RBA has only one unique serial number per bar, which we understand to be the Bank of England’s own numbering system.

When I discussed the above response with Warren James via email he suggested that it could be seen as the BoE intentionally withholding key information. I disagreed at the time, pointing out that there are benefits to having a unique BoE number such as no chance of duplicating serial numbers (something Warren highlighted occurs with some refiners restarting a number sequence) and providing multiple bar numbers may result in confusion or errors. At my request Warren provided some interesting stats from his bullion bars database indicating that for 248,063 Gold bars, there was only 206,403 unique serial numbers, so it can be estimated that roughly one in five bars could share a serial number with another. In my eyes this highlights the need for a BoE internal number that can be unique to each bar they manage, but Warren wrote further:

"The serial number is specifically named by LBMA as one of the marks required to be London Good Delivery, so I had always counted it as part of the 'standard' - at least it has been since year 2000 (ref. p44 of 'The London Good Delivery List, building a global brand 1750-2010 by Timothy Green').. it's just one of those key bits of metadata which cannot not be casually discounted. 

From a data design perspective ... 

•Even for their own internal systems they would still be capturing every marking on the bar, and for most London Good Delivery bars it will be there. 

•Bar Serial number is definitely stored in their database (or spreadsheet?), because it's a part of the LGD System they would need it on their inter-transfers. 

•In terms of data extraction, it's a trivial matter to include an extra column of data. 

•They weren't just culling redundant information > otherwise it is possible to remove GrossWeight or FineWeight, since Assay can be used to determine one or the other.

The absence of the serial number is deliberate, the only question is why? There shouldn't be an issue if it is actually allocated.

I think the BoE just decided they didn't want the detail out in the wild, because it allows the bars to be traced with high accuracy."

In a comment on Screwtape Files he concludes:

"So the industry standard for LBMA good delivery is Serial+Refiner+Weight+Assay, and the BoE leave out the serial number. Not only that, but the RBA don't question the omission. Without that key bit of differentiating information it isn't possible to track or trace the bars in any meaningful way. This appears to be the intent of BoE.

Definitely they store the information > Serial Number is always present in any other industry 'weight list'. Makes you wonder about the quality of the audit which was conducted - open for abuse since the key information is controlled by Bank Of England."

I think Warren raises some solid points and after giving it further thought I do agree that the refiner bar number should be provided to the RBA (and any other central bank or party that the BoE is custodian for) and don't see why it shouldn't also be available to the public given that it differs to the unique internal number that BoE uses to identify and manage each of the bars they store.

It does cast doubt on the veracity of the RBA's audit of Australia's Gold. Can you think of any other audit scenario where an internal reference number is accepted (by an external auditor) in place of the manufacturers own (which doesn't get checked at all)? One might hope that if they take the opportunity to audit Australia's Gold again (something they were invited to do), that they do so more thoroughly. I think the likelihood of them finding a discrepancy (such as a missing bar) is slim, but a half-baked audit negates the rationale for performing one in the first place.

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Reserve Bank of Australia Releases Gold Bar Details

A few months ago I wrote about an FOI request that I had applied for with the Reserve Bank of Australia (RBA):

BoE Tells RBA: Don't Release Gold Bar Details (FOI)

It had been rejected based on the Bank of England (BoE) claiming the information was confidential, the RBA used this response to suggest that release of the information would cause damage to the international relations of the Commonwealth.

I lodged an appeal with the OAIC (as recommended by Peter Timmins of Open and Shut) and it was successful (mostly, as explained further down).

The argument for review of the decision was as follows:

My request for a list identifying the gold bars that form Australia’s 80 tonnes gold reserves was denied on the basis that it would divulge information shared in confidence between a foreign government (or authority of) and Government of the Commonwealth (or authority of), however the custody arrangement of Australia’s Gold between the Reserve Bank of Australia (RBA) and the Bank of England (BoE) is purely a commercial relationship, rather than a governmental relationship. Furthermore the RBA has revealed to multiple individuals via general enquiry that “at 30 June 2011, 99.9% of the gold is held in the United Kingdom, at the Bank of England”, which is inconsistent with the exemption claim that correspondence between the RBA and the BoE regarding their commercial custody arrangement is confidential. Given that the RBA has openly revealed the location of the gold, further to the total physical amount, there is no reason to expect that revealing the physical properties of the bars would in any way risk the security of the asset.

Releasing the document/s requested is in the matter of the public interest. How can the BoE restrict the ability of the RBA to comply with a valid FOI request regarding a matter of public interest in the stewardship by the RBA of the Australian public’s gold?

The US Government has published a bar list of deep storage gold reserves in the matter of transparency and public interest and I think it’s a reasonable expectation that Australia follows this lead in order to allay any fears of the public, proving that the gold is there and physically accounted for.

The review process took some time, it was around 7 weeks from initial contact with the OAIC to this point.

I'm pleased to inform readers that upon reconsideration (the RBA contacted the BoE again in relation to the request), details of the bars have been released (minus the serial number). The FOI Officer provided this reasoning on retaining confidentiality of the serial number:

We are in a position to release to you melter/assayer, gross weight, assay and fine weight information relating to the bars in the inventory.  The only information we will withhold from release are the individual bar numbers, as this information remains confidential (in the opinion of both the Bank of England and the Reserve Bank of Australia). The Bank of England (as our custodian) use their own numbering system to uniquely identify each bar and have reaffirmed to us that these numbers should not be disclosed to third parties as the information is confidential.

We note that this information is broadly consistent with the example you quote in your application for review (namely the US inventory of deep storage gold reserves), although our list is not aggregated into groups of bars.

The Bank is of the view that withholding of the bar details is required, to ensure that our obligations to the Bank of England (in terms of confidentiality of their information) are maintained.  This also accords with the burdens placed on the Bank in terms of section 33(a)(iii), which exempts information the disclosure of which would, or could reasonably be expected to, cause damage to the international relations of the Bank.  Section 33(b) also exempts ‘any’ information exchanged in confidence between the Bank of England and the Reserve Bank of Australia.

You can access the file which contains the records below:

RBAFOI - Inventory of Gold holdings

Further to the bar list, Warren from Screwtape Files (who has constructed a Bullion Bars Database, the largest known public repository of historical bar lists on the internet) provided the following information showing the refiner breakdown compared with a much larger data set he has compiled from various sources:

... If a refiner is not listed in the RBA document, then it's not shown in the other columns.

(i.e. you'll note the GLD comparison will not add up to 100%, neither does the 'Universe'.)

Explanation of the other columns:

PercentageUniverse = every single gold bar we have on record (247,477)
PercentageGLDHistorical = every gold bar ever seen across 700+ GLD bar lists (157,593)
PercentageGLDCurrent = every single gold bar currently in GLD (approx 64,000 in this sample).

Basically what you can see is that the BoE composition is somewhat different.

I haven't yet checked for any direct matches for weight, fineness + refiner, but a few random checks on the Royal Mint bars were negative, it's my guess the only matches to ETF data would be coincidental (i.e. expected from statistics).

* NULL means there are no matches

Click Table To Enlarge

While it's not a complete record of each bars attributes (lacking serial number), it does confirm that Australia's Gold reserves are held in allocated form as identifiable bars (which to the best of my knowledge wasn't already publicly known). The below is a description from the IMF on allocated vs unallocated Gold (from a central bank reserve asset perspective):

Allocated gold

4. Allocated gold is gold deposited under a safe-keeping or custody arrangement. It is “a specific and uniquely numbered physical piece of gold, which remains in the ownership of the individual or institution placing it for safe custody with a bank” (paragraph 15 of Philip Turnbull, BOPTEG issues paper # 27A). The owner of allocated gold keeps legal ownership over the allocated gold even if it is deposited with a custodial facility provider. In the economic system, it remains an asset without a counterpart liability.

Unallocated gold

5. Unallocated gold represents a claim on a fixed quantity of gold. “Account providers hold title to a reserve base of physical (allocated) gold and issue claims to account holders denominated in unallocated gold. The account holder does not hold title to physical gold but instead holds an unsecured claim against the account provider, in effect a deposit with the account provider” (paragraph 13 of Chris Wright and Stuart Brown, issues paper for the fourth AEG meeting). The account holder does not have legal ownership of the physical gold but is an unsecured depositor. The account holder is a creditor to the account provider, and so in the economic system this asset has a counterpart liability. Unallocated gold targets the professional gold market.

6. In many cases, similar to deposits, an account holder of unallocated gold account deposits its physical gold to its account provided by, for instance, a bullion bank. Then, the account holder undertakes gold transactions (outright purchase/sale, gold swaps, and gold deposits) via the account. But specific gold bars are not ascribed to the holder unless the holder takes delivery of the gold. The bullion bank can use the deposited physical gold for its own trading purpose and so does not necessarily have 100 percent backing in physical gold for the unallocated gold accounts.

A positive result from the OAIC review which I will be closing (despite the lack of serial number). Unfortunately the process for such a review will become more difficult in the near future due to the government announcing that the OAIC will be abolished. Peter Timmins wrote about the issue when first announced in the budget:

The changes wipe the review model adopted in the reform package of 2010, and it's back to where things used to be and we know they didn't work properly then. Not to mention the gaps: in effect no one has the leadership function so essential to the culture change talked about for 30 years but still a long, long way off and going in the wrong direction under this government; and no mention also of the what happens regarding the role the OAIC played in moving towards a government wide information policy. The AAT cannot provide inexpensive FOI review - the flagfall is $816, refundable but for $100 if the applicant meets with some success.

Not likely to have been an amount I would have risked for the information that was provided to me in this case. With the OAIC being wound up at the end of this year, I would encourage you to get any FOI requests lodged soon if you want the opportunity to have any rejections reviewed by the OAIC given the lengthy process it took for my results.

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BoE Tells RBA: Don't Release Gold Bar Details (FOI)

Two months ago I wrote a Freedom of Information (FOI) request to the Reserve Bank of Australia (RBA). Here is the crux of my email:

This is a request under the Freedom of Information Act.

I request that a copy of the following documents [or documents containing the following information] be provided to me: An inventory (bar) list forming the 80 tonnes official Gold reserves (stored with the Bank of England), including details which identify the individual bars by refiner, weight, finesse, serial number and any other identification recorded for audit purposes.

In order to help determine my status to assess fees, you should know that I am a representative of online media and this request is made as part of news gathering and not for a commercial use.

While Gold holdings do fall under the operations of the bank, the position held has remained unchanged and published for well over a decade and I see no risk in providing details of the bars which underpin this position.

The RBA does state they are exempt from the FOI Act in relation to banking and market operations:

The Reserve Bank is exempt from the FOI Act in relation to documents in respect of its banking operations (including individual open market operations and foreign exchange dealings) and in respect of exchange control matters.

I assumed that Gold reserves sit within this exempt area given that it is detailed in the 'Operations in Financial Markets (Reserves Management)' section of the annual reports. However, given that their Gold holdings are public knowledge, as is the RBA's activity in the Gold leasing market, I could think of no logical reason that providing the information would be damaging to the institution or their operations.

The two (primary) responses I received are below.

February 28th (in aid of extending their deadline):

This email is intended to provide you with an update in relation to the processing of your request under the Freedom of Information Act 1982 (the Act).  It is also a formal notice as required under s27 (see below).

In terms of s27, (consultation – business documents) of the Act, the Reserve Bank of Australia is required to consult with a ‘person, organisation or undertaking’ in the event that (they) might reasonably wish to make an exemption contention that the document is exempt from release in terms of s47 (business).  Consistent with the terms of the consultation process provided for in s27, we have determined in writing that consultation is required, and therefore an extension of processing time (by a further 30 days) to enable consultation to take place (s15(6)) is provided for by the Act.

April 1st (today, April Fools?!):

Further to earlier correspondence regarding your FOI request, I wish to advise you that we have received a response from the Bank of England regarding information about the Reserve Bank of Australia’s gold inventory (as held by the Bank of England).

The Bank of England has advised us that it regards the information about the gold holdings that has been exchanged with the RBA to have been exchanged in confidence.  This is consistent with the Reserve Bank of Australia’s own view about our interactions with the Bank of England in relation to the gold holdings (i.e. we also regard our exchanges with the Bank of England to have been made in confidence).

Accordingly, I have decided to deny access to the information sought in terms of section 33(b) of the Freedom of Information Act 1982 (the Act) ‘as information or matter communicated in confidence by or on behalf of a foreign government [or] an authority of a foreign government … to an authority of the Commonwealth’ (being the Reserve Bank of Australia). Further, I have decided to deny access to the information sought also in terms of section 33(a)(iii) of the Act, which pertains to documents affecting international relations of the Commonwealth. I have decided that disclosure of the information sought by you would, or could reasonably be expected to, cause damage to the international relations of the Commonwealth.

So basically the situation is as follows:

99.9% of Australia's Gold reserves, 80 tonnes, are stored with the Bank of England (BoE), news of which first came to light on this site in December 2012.

Petitions to repatriate Australian Gold have garnered public support, but not to a critical level needed for it to become a political issue (you can still sign it here).

Supposedly this Gold belongs to Australia (managed by the RBA), yet when a member of the public requests a list of the Gold bar details (of which revealing would pose no risk that I can think of), the RBA says that they are unable to. Why? Because the BoE (who are merely a custodian of the Gold) said that it needs to be kept a secret.

In the final email, along with the advice that they would withhold the information, I was provided a document which detailed some options should I choose to challenge the decision. Included (amongst various options) are requesting an internal review, review by Administrative Appeals Tribunal, Review by Federal Courts or complaining to the Ombudsman. If anyone has any experience with challenging an FOI decision or ideas on what grounds I could do so then I would welcome your thoughts in the comments below (in a timely fashion as I only have around a month for any challenge). Alternatively you are welcome to email me (address at top right of blog under social media buttons).

Any other opinions or comments on the outcome so far are welcome, as are any thoughts on risks or reasoning the Bank of England may have for keeping the Gold bar details a secret.

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