Clearly, in economic terms, the cost of litigiousness and its terrible effect on the reputation of the entire sector more than exceeds any hypothetical benefits that individual banks might have obtained through questionable practices. Society has clearly evolved and, in tandem, so have demands regarding the transparency, diligence, rigour and integrity expected of banks. I believe the sector is responding to this challenge, which involves achieving a significant cultural change in the way banks relate to their customers. I have pointed out that it is premature to analyse the results of this Law in terms of potential improvements to legal certainty, but we can see a change in the number of complaints submitted to the Banco de España. As you will know, in recent years the problems related to mortgage loans have led to the change in the number of complaints lodged with the Banco de España. This is due in particular to two issues: the above-mentioned floor clauses and mortgage loan arrangement costs, which saw a record number of complaints submitted in 2017. However, mortgage loan complaints made last year fell to levels of a decade ago. We expect this trend to continue. But apart from one-off changes in the time series, I wish to emphasise the fact that the problems behind these complaints stem from operations entered into prior to the enactment of the Law in question.
The ESRB approach uses the concept of residual risk, which is the difference between the level of risk and the current resilience of the financial system.12 In setting up the framework, policymakers need to establish the level of residual risk that they consider acceptable. Regular macroprudential policy decisions would then follow a two-stage process. Policymakers assess the level of residual risk in the system, and if that diverges from the acceptable level, they then assess the policy tightening or loosening required to realign it. Conclusion Let me conclude. Over the past eight years, the implementation of macroprudential policy in Europe has substantially improved, and the ESRB has played a valuable role in facilitating that process. The ESRB’s success derives from its broad membership. Systemic risk takes different forms over time, so discussions incorporating a wide range of viewpoints and experience are vital if policymakers are to successfully safeguard the stability of the financial system. 1 See, for example, European Commission Staff Working Document, Coping with the international financial crisis  at the national level in a European context, p.11, which shows that even in 2015 the contribution of the state to financial sector repair represented more than 10% of total public debt in many countries. 2 ESRB (2014), ESRB Flagship report on macroprudential policy in the banking sector. 3 Kelber, A. and Monnet, É. (2014), “Macroprudential policy and quantitative instruments: a European historical  perspective, Financial Stability Review, Banque de France, April, 18: 151–160. 4 Some discussion had certainly taken place prior to the crisis.