In order to avoid investor and ratings agency opprobrium, banks will consider a range of actions, including cutting lending, rather than go beyond their capital risk appetite – which is typically well above regulatory buffers. Conversations with investors and rating agencies were largely consistent with this view. Banks also face internal risk appetite constraints which may be higher than regulatory requirements and buffers, especially given that capital is often managed on a forward looking, rather than a ‘spot’, basis. 8  All speeches are available online at www.bankofengland.co.uk/news/speeches and @BoE_PressOffice  8  Together, this suggests that banks may be unwilling to use all of their capital headroom, let alone dip into regulatory buffers. This underlines the point I made earlier about even management buffers not necessarily being fully usable. Approach 2 – the impact of countercyclical buffer releases The second approach looks at whether there’s any empirical evidence that releasable regulatory buffers provided effective support for firms to support lending, as intended. Reducing CCyB rates lowers the level at which distribution restrictions and requirements for capital conservation kick in. The release effectively increases the management buffer while reducing the regulatory buffer by the same amount. At the onset of the pandemic, eight of the 27 Basel member jurisdictions had a CCyB rate above zero; during the pandemic, six of these fully released it, and one partially released.
Project Greenprint has focused on four digital utilities: an ESG disclosure portal; an ESG registry of green certifications; a data orchestrator; and a digital marketplace  MAS is piloting the ESG Disclosure Portal with SGX, to enable listed companies to carry out baseline sustainability reporting against a set of 27 core metrics. Titled ESGenome, the SGX portal allows companies' one-time inputs to be automatically mapped across a range of major sustainability standards and frameworks  9/11  BIS - Central bankers' speeches  Sustainability reports can be automatically generated from these inputs. For the next stage, we plan to scale ESGenome into a national-level disclosure utility that meets the reporting needs of all companies, following a public consultation. We will also cater for cross-border interoperability, to allow banks and investors to tap on disclosures outside Singapore. The ESG Registry uses distributed ledger technology to record and maintain the provenance of green certifications issued by various sectoral bodies. Titled ESGpedia, it allows banks to access various green certifications through a single interface. We will continue to build up the Registry's network of certifications, providing more confidence to users of these data. Data orchestration entails aggregating ESG data from multiple data sources to meet specific green and transition financing needs. This requires interoperability and consent-based access to major ESG data providers, utilities providers, sectoral platforms, and of course the ESG Registry itself. We are already doing small-scale pilots to identify financing gaps and technology solutions for decarbonisation in priority sectors such as energy, real estate, agriculture, and transportation.