Finally, we must remember that the application of strict standards, as required by the law, will, at least in the short term, limit the access to owner-occupied housing of certain low income groups. I sincerely believe that in the medium and long-term the effect will be more positive, by fostering greater price stability over the business cycle. We should remember that runaway growth of prices is the main factor that ultimately restricts access to owneroccupied housing. In any event, it is up to public authorities to shape the social measures that aim to guarantee decent homes for the less well off. It should be noted that construction of subsidised housing is currently at low levels, despite the economic recovery. Certain initiatives in our neighbouring countries are of interest, such as the role played by the deposits and consignments fund in France or the state guarantee arrangements in the Netherlands for housing up to a certain value. It is true that banks must not forget to apply strict economic criteria in their business, but it is just as true that a fair and responsible society should not be guided by economic criteria alone. 11/15  Use of the new macroprudential tools. In the last part of my speech I would like to depart a little from the real estate credit law to discuss the new macroprudential tools recently introduced by Royal Decree-Law 22/2018. As I have already mentioned, the crisis highlighted the insufficiency of microprudential supervision to identify, prevent and mitigate the materialisation of systemic risk.
Let me first explore some features that make financial market infrastructures different from other financial institutions: •  Service continuation (“critical services”) is more important in the case of FMIs. They are utilities at the heart of the financial system. Their smooth operation is essential for all other types of financial service. •  In most cases, there are only a few, if any, substitutes or alternative providers. •  Unlike banks, FMIs have ex ante loss allocation rules that they can draw on for the purpose of recovery. •  Not all FMIs are exposed to credit risk (but they are still systemically important). •  The size and composition of their balance sheets (e.g. rarely subordinated debt instruments) is different, which makes bail-in as a recovery or resolution tool difficult. •  To the extent that the use of a CCP is mandatory, it is absolutely essential that the relevant clearing services are preserved regardless of the circumstances. In conclusion, the recovery of CCPs in order to maintain service continuation is much more important for CCPs than for other financial institutions. That’s why the PFMIs require CCPs to be able to allocate any losses that are not already covered by regular risk management. [slide 8] So if the recovery of CCPs is so vital, is there any scope for resolution at all? I think there is, for a number of reasons: First of all, the attempt to recover may simply fail: the ex-ante recovery plans may prove inadequate ex post.