In the wholesale financial markets, these predictions came true, as concerns about risk and efficiency led to the widespread adoption of electronic technologies in back offices of financial firms and in payment and settlement systems. Yet in the retail payments system, we have tended to underestimate the size of the hurdles confronting a shift away from paper.
Ensuring that managers are "fit and proper" for their job is key for sound and robust governance. The recent episode of bank stress has shown that culture matters and that banks need to be properly managed, as otherwise trust erodes. In addition, I am concerned that all proposals still impose freezes on the macroprudential buffers of a bank when the output floor becomes binding.