34  This is an average of the total customer swaps initial margin for the largest five clearing members as reported to the CFTC at end May 2018. Because these are US figures only, they represent a lower bound on total customer initial margin for OTC derivatives at a large clearing member. 35 See Brooke et al (2015), ‘Measuring the macroeconomic costs and benefits of higher UK capital requirements’, Bank of England Financial Stability Paper No.35, https://www.bankofengland.co.uk/-/media/boe/files/financial-stability-paper/2015/measuring-themacroeconomic-costs-and-benefits-of.pdf?la=en&hash=9E3312E32D26EC1F02E25CB2F075356B484F0242. 16  All speeches are available online at www.bankofengland.co.uk/speeches  16  Chart 1: Major UK banks’ Tier 1 capital ratios 2008-17  (a)  Per cent  18 16  (b(c)(d)(e)  Basel III Tier 1  14 12 10 8 6 4 2 0 08  09  10  11  12  13  14  15  16  17  18  Source: PRA regulatory returns, published accounts and Bank calculations (a) This chart was in Box 2 of the June 2018 Financial Stability Report. (b) Weighted by risk-weighted assets. (c) From 2014, the ‘Basel III Tier 1 capital ratio’ is calculated as Tier 1 capital over risk-weighted assets. The CET1 element within Tier 1 and RWAs are according to the CRD IV definition as implemented in the United Kingdom. The additional Tier 1 element within Tier 1 excludes grandfathered instruments and other transitional adjustments. Prior to 2014, the chart shows Bank estimates; preference shares are used as a proxy for additional Tier 1 capital.
the Basel III finalisation package and the reforms contained in CRD V and CRR Il;    Making adjustments to the framework in response to new risks;    Making adjustments to the framework in response to unintended consequences. 13  For instance, a leverage ratio buffer for global systemically important banks (G-SIBs) that is based on the level of the risk-weighted GSIB buffer. There are some differences between the Basel leverage ratio regime and the UK regime but the amounts of Tier 1 capital major UK banks need under each are broadly similar – see Box 3 in the June 2018 Financial Stability Report, https://www.bankofengland.co.uk/-/media/boe/files/financial-stability-report/2018/june2018.pdf?la=en&hash=9D057C7302B80EF57D634020F50C6F46D782904C. 14 See https://www.bis.org/press/p171207.htm. 15 See the letter from the Financial Stability Board chair to G20 Finance Ministers and Central Bank Governors, 18 March 2018, http://www.fsb.org/wp-content/uploads/P180318.pdf. 6  All speeches are available online at www.bankofengland.co.uk/speeches  6  Remaining policy development  As mentioned, you should not expect a lot more reform. But there will be some further policy development to finish the job we started 10 years ago. For example, having implemented the Liquidity Coverage Ratio (LCR) back in 2015, we are polishing our Pillar 2 liquidity framework. This has not been adapted since the FSA introduced a new liquidity regime in 2010. Pillar 2 liquidity is intended to capture liquidity risks faced by banks that are not captured by the Pillar 1 LCR. Earlier this year we published a Statement of Policy on Pillar 2 liquidity.