This Country Financial Accountability Assessment (CFAA) is also a "fiduciary" assessment, given it examines Brazil's Public Financial Management system, to form a judgment on the risk to Bank, and country funds within the Brazilian budget, and the level of accountability and transparency concerning such spending. Moreover, this CFAA will feed into the Bank's lending program, in particular a second Fiscal Reform and Structural Adjustment Loans in FY03. Partly reflecting the lack of a Public Expenditure Review, this CFAA also focuses on upstream budget development issues, including linkages with the government planning systems, as well as downstream budget execution issues. The Brazilian Government appears strongly committed to improving its public financial management, in particular, two major initiatives have been recently undertaken, which significantly impacts on public financial management: a) the Multi-Annual Plan for 2000-2003 adopted a new approach, aimed at improving resource allocation through a program-based approach covering all budget expenditures, involving the setting of program objectives, and measuring performance; and, b) the Law on Fiscal Responsibility, which appears likely to significantly impact on reinforcing commitments to fiscal discipline at the federal government level, and enforcing greater fiscal discipline on sub-national government. Nevertheless, the budget system is fragmented, and complex, hampering resource allocation in line with stated priorities, and, its execution does not reflect program priorities and more.