 Thank you very much for having accepted our invitation to be here today. This idea was, it's a very good idea to have interchanged and dialogue, we are going to put questions to you and you are going to put questions to us. The reason, I mean I would love to tell you that this idea was mine, but unfortunately it was not. It was a proposal, a specific proposal that was suggested to us by André Rieu. That's him that wanted to have this dialogue with the Portuguese young people, people that are less than 35 years old or around it and that are stakeholders and it doesn't matter if you are 36, but okay, it's a new generation. It's young professionals and I think it's really, when he suggested it, I thought, well what a marvelous thing because in fact we could have done it before but we didn't. Well, myself probably, I'm not sure if you know I am, but I'm a member of the board of Bank of Portugal and I have the portfolio of banking supervision among other issues, but this is the professional reason why I am in permanent contact with André Rieu and I'm very, very happy to welcome him here in Portugal. I'm starting to suspect that he likes us. In fact, after he was, I mean he took the job, he was for eight years in EBA as you know and he was the chairperson of EBA and he did old building up of EBA from scratch and now recently came to substitute Daniel Nui as the chair of the supervisory board so that's where the systemic banks, the most important banks are directly supervised and I sit around the table where is the chairperson. But for us, I mean people from other generations, it is really very difficult sometimes to understand how everything functions, how you have this kind of, what is exactly the kind of competencies that we have, how we function, how we organize ourselves, what we request from banks, what lessons we learned from the past crisis and probably for you, I don't know, that's what we want to find out, whether it is absolutely straightforward because that's the new reality, that's the new normal, that's what you are used to or if otherwise you have questions, you have suggestions that you want to make and that's the reason why, I mean we are here. So my purpose was not to make a speech, was to say that it's really great that you accepted to come, that we want to listen to your questions from my behalf, on my behalf I will try to answer but there may be questions that I don't know the answer, that's a possibility too but I'm sure that even those ones, there will be someone more experienced than I am and more responsible than I am and I give him the floor so that he answers. But Andrea, thank you very much. We had a couple of weeks ago the meeting of the supervisory board here in Lisbon it was really a big event and I thanked him then and I thank him now and this is the reason why I say that probably he likes us because it was, I mean if you do it twice so he has chosen to come here and to have this occasion to have a full program today and tomorrow with us the ones that operate here in Portugal be it the Portuguese or foreigners, it doesn't matter it matters that we are located here that's the responsibility that we have for financial stability here in Portugal and that all of us we have got to do our best. So the floor is yours and thank you very much. Thank you very much Elisa, thanks for organizing this event and all our knowledge. I think that I'm very happy to see so many young people here and I'm very glad that you helped us organize this event. First of all this is not for me to believe as pitch it's more to get questions and to listen, I mean that's the main purpose but let me say a few words before we start. Last Saturday I was at the wedding of my daughter who was probably in the age range of many people here around the room and she studied international development so there was a lot of people coming from all around the world emerging countries, US, Southeast Asia and a lot of European countries and talking with them, I mean it was clear that your generation has been particularly hit by the crisis by what happened in the last years. All of them have partners sometimes living in other countries finding jobs in other places, commuting some of them not having even the time and possibility to see their children growing every day and the same happens actually for many staff working with me for many young Europeans working with me at the ECB and I think that for people like you who have been working in finance who have studied maybe economics or law and were trying to start a career in finance exactly at the time when the crisis struck I think it must have been really difficult and the devastation left by the crisis has also led to an increase in the popular rage that we see in day to day life with the satisfaction with the political elites but also with challenges to the European project, to the European Union and I think it is something which we need to reflect the banking sector was at the epicenter of this earthquake and we have done a lot to fix the problems regulatory reforms, let's say establishment of European supervision strengthening of a number of safeguards within the banking sector in the official sector but the first point I want to raise is that eventually I think that the key point, the key change is culture it's really a change in the way in which people working in the industry behave themselves, think about their role and perceive their responsibilities vis a vis not only let's say the shareholders or the authorities but also towards the general public and the society at large and these are things that you cannot legislate these are things that cannot be fixed with the rules these are things that need to be fixed in other ways and need to be really nourished within the banking sector itself and sometimes when you talk about these issues of culture you hear a lot about tone from the top and also from the supervisors generally you try to go to the top management and say you need to change the culture but eventually the culture changes when you go really to the middle management I see that many of you are also head of departments but also from the voice and involvement of people from the bottom I would say from the experts, from people starting a career in banking making sure that they have voice, that they can speak up that they can see if they see something going in the wrong direction so culture is an important thing and feeling the responsibility for the culture I think is an important issue now, in reaction to the crisis one of the major changes has been of course to set up a European supervision to centralize functions for supervision at the European level and this is indeed also as Elisa knows very well a big cultural challenge in a sense because we were working together, cooperating since a long while but the supervisory cultures, traditions were very different and this means that this has been a big change a big change for everybody, for the banking industry for the national competent authorities and also for the people who have had this hot potato to deal with in Frankfurt so having something that works in terms of the interconnection with the national authorities is essential and that's why I'm very glad to come to each and every capital and I must say indeed Lisbon is the only one in which I've been twice already since I started my job at the ECB in January but it's also a challenge in terms of really having the banks understanding what we do, what we are, what we want and what are our new processes and it is a big, sometimes also meeting, you know, top manager of banks you realize that also them sometimes don't really understand what we do and why let's say the requirements are what they are and they look at the comparison and there is still a little bit of displacement in the mark so I think it's an important task for me to try to make sure that there is a clear understanding at all levels of the banking industry of what we are, what we do and trying to explain, be predictable, be transparent and be invisible so that's also part of this engagement that I want to have here with you today and finally the last thing I want to say is that the European banking sector has changed a lot let's say the first part has been mainly also driven by the regulatory reforms by European supervision to deal with the legacy of the crisis raise capital levels, clean the balance sheets, increase the liquidity buffers so be more resilient, there has been a lot of the leveraging this the leveraging has been also associated to large extent to repatriation of business refocusing on domestic business and this meant to some extent we have a less integrated market today than we had before the crisis which is an issue for us that believe in the single market in the European project but more generally there are structural challenges and there is also, and I think that this will be besides the completion of the process which we have started and brought to a significant point in terms of maturity of post crisis adjustment I think that the structural challenges in terms of consolidation, integration of the market but also dealing with the new competition coming from new players from fintech companies, digitalization of banking I mean these are all challenges that we rank high in the priorities that we will face going forward and of course digitalization is something which will be probably one of the top priorities also from the point of view of the development of the industry in the coming years and something for which you will probably be very much involved going forward I have always difficulties to, you know, I don't think I ever saw my daughter going to a branch of a bank I mean she's only doing it when, anyway so I think that this is something that will change quite a lot the way which banking is done around I would also say that speaking to young people for me is important because there is one point which I think has not been really followed up a lot after the crisis which is the fact that the banking industry was very much focused on the short term on short term profits, on short term assessment of risks and then when the heat came everybody realized that they didn't actually, there wasn't enough depth in the ability to look forward to have a longer perspective on what would happen after a while with the risks that were being taken and I think this short-sightedness has not yet been really addressed and again if you look forward to the banking sector you will have in 10, 15 years which will be the banking sector you will build from your progression in career is a banking sector that will need let's say attention to new issues I mentioned digitalization but of course also the issue of environmental transition green finance and the like are also other important topics so it is important when talking to the younger generations that this longer term perspective is very much present in what you do every day I know that you will be probably under pressure for targets achieving objectives in a short period of time but I mean it's also important to keep this longer perspective and we as supervisors need also to see how to put the right incentives for that as well so that's all I wanted to say as a way of introduction but I look forward very much to your question and to an interactive dialogue with you today thank you very much for being here so numerous, thank you thank you and now Ana Rita will be in charge I don't know how well you know her you may think that she comes from a TV channel but well she's always under pressure to move to the present profession that she has to a new challenges of course she will be 36 next month I wish, I wish no, Ana Rita she's in charge here in the bank of Portugal of the big institutions so those institutions that are under the direct supervision of the ECB and supervisory board and she works directly with the Luis Costa Freira with the head of supervision sitting there hiding there who is in charge of everything so Ana Rita you have got to stimulate the discussion so go ahead first of all I think it's an honor and a pleasure to be here I think I share this with the audience with Mr. Enrique and with Elisa and having the opportunity to basically liaise with the supervisor the one that indirectly or directly impacts your daily work and also an opportunity for you to share the main challenges and things that you would like really to share that affect your day to day work so I will open the floor I will start with a question I mean in order to open the floor which is to Mr. Enrique what were the main challenges that you encountered that you faced when you assumed this very challenging position in the banking industry because I mean you have to face with so many stakeholders what were the main challenges? In my new job the one I am now well I mean the first one was the clutter in my inbox I would say because I can tell you we had last year 2,000 decisions just short of 2,000 decisions so the decision making process is really very demanding and overwhelming actually so I think the most important challenges to have I must say the decision making process is very robust because it involves the national authorities it has of course the dialogue with banks so when things come to the final stage so to my table let's say the products are very robust I mean the system is ultra safe very strong but still you have responsibilities you have to understand everything go through it and it is quite a lot so that I think is the main responsibility the other big responsibility for me is the governance of the SSI the supervisory board I mean we need to ensure proper discussion building a good European atmosphere and willingness to work together and to have a genuine common perspective on the common European interest and that is also a challenge to ensure a balanced way of working for the authority now we open the floor for the audience I would ask if the ones that have questions state out your name, bank an area of the bank where you work do we see any candidates here? at the front hello, good afternoon my name is Rana Placid I'm from Milani BTP, risk office first of all I would like to thank you this opportunity of sharing our ideas our point of views and most of all our experiences so the point that I would like to raise for question and for discussion is the following so that everybody sees you are you listening to me? the point I would like to raise for discussion is the following nowadays institutions following an IRB approach are obliged to follow street and specific rules in the development of their risk models and how it is ensure this balance between the need of harmonization among the players ensuring a level playing field across the market and the idiosyncrasies of each institutions in practice and for instance how should an institution use their prudential risk metrics in use tests when we have such differences in some assumptions we know that some assumptions are requirements in a prudential perspective are different from internal management models so how can we achieve this balance for us sometimes it is a challenge and I would like to open this discussion it is a very good question but it is the level playing field so it is your perspective I think not mine let me be clear here I have been a strong supporter of the use of internal models in regulation I started with some doubts I must say in the early 2000 when the buzzer debates were ongoing I thought that it was a good idea exactly for the reason you mentioned for the use tests because for the supervisor it is an important entry point in the way in which banks themselves view, measure and manage risks so if you want to have a risk based supervision you need to understand how the banks measure the risks and allowing the use of internal models is an important tool to do exactly that when the crisis started though it was clear that nobody started trusting the models anymore so the investors, analysts lost completely any confidence in the measurement of risks and in the capital ratios that the banks were publishing because they thought that they were not they saw banks that were with the risk with the assets with the capital ratio of 18 20 percent going bust one day from the other and then they say well this is something that cannot be trusted and I remember that there was a lot of rating agencies analysts that started publishing their own estimates of course much less risk sensitive of the capital position of the banks so at that moment also in the supervisory debates there was a strong push to really take internal models and throw them in the bin so to move totally to a leverage ratio style approach and it was not emerging markets it was the US in particular that was very focused on that the US they had been the most vocal promoters of the use of internal models especially of credit risk internal models towards the end of the 90s early 2000s and they were having second thoughts and they started moving to a setting in which the supervisor itself the Fed was measuring risks more in a top-down way with their own models the SCAP, the first stress test that the Fed made was done entirely by the Fed it was a black box nobody knew what was the way that the Fed used to measure risks and to some extent this is still the case right now so the work that we have done since then has been a very extensive work to try to repair the supervisor reliance on internal models and ensure some consistency across banks and some reliability and trust because the lack of trust was started building up also in the industry itself because many banks were saying well I have a very high risk with dust density but my competitor in the neighboring country under the responsibility of another authority has a similar portfolio but much lower risk with dust so there is no competitive advantage no competitive equality and the like so we made a huge work to ensure exactly that reliability and comparability as this killed this use test and as you correctly said the adiosyncrasy, the fact that each bank is different, well I think we really didn't because all the work we are doing in the ECB now with the target review of internal models which the EBA has done for instance in the benchmarking is really to develop some common criteria in the areas where I mean we are actually in our view there were not compliance with the regulation already before so give clear guidance on what is expected for instance in the treatment of defaulted assets or stressed LGDs and the like but at the same time you leave a lot of leeway to the banks, to the risk managers of the banks to shape their own models and we do benchmarking and challenge so if you see that for the same type of assets you have a bank which is coming a little bit as an outlier then you start a supervisory process challenging but if the bank convinces you that they are modular right and that the outcome is correctly measuring risk we will have nothing to say about that so we need to strike this balance between the two objectives we have one in the bottom yes from BPI so a few moments ago you mentioned digitalization and I have a question about FinTechs and in one hand we see that the new capital requirements regulation it seems to introduce the same level or even more capital requirements on banks and in the other hand we see that specific regulation directed to investment firms are also being draft so my question is don't you think that European Central Bank and EVA should also create a legal framework for FinTechs thank you well let me put it like this if a FinTech company does banking activity as it is defined in European legislation which is mainly collecting deposits and granting loans it is a bank needs to comply with all the full of banking regulations, bank supervision as any other play if instead the FinTech company does a specific subset of financial activities competing with the banks in that specific segment well then there are different for instance take the payments area which is the area where the FinTech sector has invested the most in this area Elisa knows that very well because she was in the European Parliament when these legislations were passed it has been a deliberate choice of the legislators to increase the level of competition to the banking industry from known bank third party providers so there was a deliberate objective to increase competition and to have a lighter regulation of payments institutions than of banks so if FinTech wants to provide payment services and compete with the banking in that area they have to comply with the requirements for payments institutions and that's again absolutely fine and I think that at the beginning the banking industry was rather complaining on the access especially for instance of these providers to the bank accounts of the customers directly to the information in the accounts that sometimes is called open banking but now they have also themselves started providing the services in competition with the FinTech companies sometimes they have partnered with FinTech companies so I think that eventually there is going to be an advantage for the final users of these services so in a nutshell I would say that if somebody is doing banking needs to be supervised exactly as a bank and do everything like a bank if you are doing different segments I mean of course you are allowed to have a lighter regulation and to compete with the bank in that specific segment but this competition so far I don't think has been detrimental to the banks actually the banks have reacted in the positive way and this is leading to better services for the customers maybe one of the areas where I'm a little bit more concerned is that all that big techs are taking in this area because the companies like Facebook, Google Amazon they have a possibility of starting picking on the different points of the value chain creation for the bank from the payments to the effects services when you buy something abroad to the consumer credit and they have an amount of information and captive customers that is quite impressive so that's an area in which maybe we need to think a little bit more about how the unbundling of services would affect the overall credit creation process okay good afternoon I work at CGD with the compliance department in our country Bank of Portugal is responsible for surveilling the implementation of the obligations regarding anti-money laundering and counterterrorism financing on this regard how do you rate the exchange of information between ECB and national supervisor thank you thank you this is an area in which of course as you can imagine we have been thinking a lot we are still thinking we are in the agenda of our supervisory board last week a couple of weeks ago and as you know as you correctly say the ECB is not an AML supervisor anti-money laundering responsibilities are clearly not attributed to the ECB and they remain with the national authorities still there are a number of areas in which our activities to some extent interact with the activities of anti-money laundering supervisors think of the licensing process fit and proper internal governance internal controls also withdrawal of license I mean there are a number of areas in which basically the legislation itself now also in the supervisor review and evaluation process the legislation requests the provincial supervisor to consider also anti-money laundering issues so this means that we need to cooperate more and more with the authorities which are competent for anti-money laundering at the national level we have signed an MOU in January this year with all the European AML supervisors on exchange of information and cooperation and we have already started I would say very positively a system by means of which anything we find in our own site inspections for instance which may be relevant for the national anti-money laundering authorities we pass it to them as information further use and the other way around when an anti-money laundering authority finds problems they inform us and we are now thinking how to make this interaction and also our focus on AML issues as effective as possible to avoid duplications because of course we know that from the compliance side let's say you don't want to deal for the same topic hundreds of authorities so we are trying to streamline this as much as possible but of course we need to find a way to deal with this in enjoying that fashion do we have anyone else here hello good afternoon for all my question is about fit and proper models and if it's possible in the future to have only one model for all the European Central Bank participants and in the same matter of fit and proper gender diversity is very important in the parts of the banking institutions but how in your opinion how it must be implemented thank you all sorry Martin from sorry thank you well normally more than us would like to have a single approach to fit and proper because of course now as you know the fit and proper requirements are spelt out in directive which is implemented in different ways in all the 28 member states 19 for us and then also the national approaches also administrative approaches for so far have been quite different this means that when the ECB is responsible for fit and proper assessments as to run the same type of assessment sometimes even for the same person maybe in two different countries, in two institutions in two different countries we need to run a completely different sometimes completely different procedure in terms of times in terms of what we can check what we cannot check we could even come to different outcomes because of the different way in which the European law is implemented in national member states so this is of course for us not only administrative nightmare but also something which is not good for level playing field for efficiency, for effectiveness so indeed I remember I was still at the EBA and I wrote a letter together with Daniel Nui asking the parliament council and commission to consider harmonization of fit and proper requirements in the last legislative round unfortunately this was not accepted so we had to leave for the OMB with these differences and there is little we can do for the OMB so we'll keep going in this way but you are absolutely right I mean this is very suboptimal to say the least you raised the issue of gender diversity which is a topic which is also now addressed in the legislation the EBA produces regularly reports on gender diversity in bank boards monitoring that and reporting to the European institutions and there have been some progress but indeed this remains a relevant issue this is I think important I mean I would say the diversity is important in different direction in boards boards having different views in boards having people that is able to challenge decisions of the acceptors I think is key to a good governance in the banks we have seen if you look at the the most difficult cases we have had not only recent years but generally also from my when I started my supervisory career in the bank of Italy in the early 90s it was exactly the same when you have a dominant CEO when nobody is challenging when you have a very homogeneous culture everybody is doing exactly the same thing thinking exactly the same way you can be sure that eventually the bank is going to crash against the wall and so having diversity is a diversity in professional background diversity in experience expertise what you need to know to run a bank now is so wide that you cannot have everybody knowing everything you need to have a diversity of profiles and during the diversity is an important element in that respect as well we cannot do we cannot of course push this again by regulation or legislation I think that would not be but we can and we do highlight to both when we are dissatisfied in terms of the diversity that we see in both the interesting thing about it is coming from credit is that progressively the little units are are turning to include more gender balance in there we are always making this insisting that they should diversify that they should modernize that they should have qualified people because banking is a very serious business you cannot just put the nice guy that is I mean you have got to know to be informed and probably the new generation is really a source of positive hope but it is really something that progressively we see the change by insisting we are trying to be moderating the pressure that we put and never going to gender concerns to put someone that is incompetent in the job I mean that is not the purpose the purpose is really to make people look in the market for competent people with a diversified approach and this takes time but I think I hope I am not wrong but I think it is getting into the mind of people that really need to have qualified informed people that are available to spend time in that specific task and with a multiple way of looking at things and we are talking a lot about gender it is obvious but also different experiences and eventually even different ages so that you have a kind of a mixed a mixed vision on subjects but yes this is something that we have been following very carefully so it is let me see if I may add one point I mean you correctly put the two things together fit and proper on one hand and the diversity on the other I mean the problem I have this is really something I am scratching my head about is that the fit and proper is a very legal legal process the bar is very high to say that somebody is not fit and proper to be a member of the board of the bank also you need to have evidence if you say to somebody you cannot sit in the board of the bank you are actually banning this person from the banking sector so it is a big decision which is going to be challenged for sure and you need to have very strong evidence that something is wrong in many cases what we see is not that you have people who are not fit and proper but exactly the board is not you know when you look at the board in its in its totality you see the very something wrong there you see that it is something which is not giving you enough reassurances in terms of of a good governance of diversity and the like so we don't have strong tools there we don't have the bazooka of a fit and proper decision so I thought maybe you should use what in the old time of central bank was called moral persuasion so you call somebody say look this is not really looking pretty maybe you should consider changing and of course you see on the other side that people of course immediately follow up that's not how it is going actually you notice that the moral is working as well as it used in the good old days so it's very difficult for the supervisor to affect this aspect but it is something which is in my view crucial and we need to think more and more on how to increase our pressure on these aspects which is not anymore the capital requirement things on which you have a strong legal basis as a supervisor something on which in any case you need to to make sure that the cultural change in the banks is being actually brought to completion and this is an area in which I'm not yet confident we have achieved enough but from our experience here and I speak under the control of Van Riet and Luiz and Isabel because we feel that the qualitative aspects the governance aspects are really sometimes even more important than the more quantitative ones because the qualitative people that take decisions what are the basis for their decisions has been has been evidenced as one of the sources of risk and so we take very seriously the fit and proper and it is important that really there is a coherence in the criteria in the same in the internal market and particularly in the banking union and the supervision it's also it's always easier to have quantitative than qualitative because it's more subjective but anyway I think as you mentioned it's a cultural thing a culture that has got to be put in practice Hello, my name is Ana I'm from the legal department of Novo Banco and my question is related to FinTechs again Do you think that FinTechs are a game changer and how do you see the business the banking business activity in the next 10 years 10 or 20 years Well, surely they are a game changer I mean new technologies will play a strong role already now if you look at tomorrow I will be in a conference here in Lisbon and I will focus my remarks on profitability on the profitability at European banks but if you look now at the distribution of return on equity or return on assets at European banks you clearly see that the banks which are better placed in terms of profitability right now are those who have been more effective in investing in new technologies and restructuring their distribution network and achieving better cost efficiency especially in a period of low rates as we are right now so new technologies are indeed an important an important element FinTech companies are indeed they are a game changer because they are developing new tools new innovative tools sometimes from a regulatory point of view a supervisory point of view I am a bit concerned because of course they lack the compliance culture which is of course very well rooted in the banking sector I remember I was in a meeting with a number of FinTech companies virtual currency providers and the like the question I received most frequently was whether I could put all my rule book in a sort of algorithm so that they could put it into there let's say machines and then forget about all the compliance issues so it's clear that there is a cultural challenge there but in general let's say they are at the beginning they were presented very much as disrupters so as entities that would have actually displaced the incumbents the banking industry at the moment I think that they are more a challenger but as I said before you have different dynamics that have been unfolding some banks have developed their own internal FinTech let's say division or subsidiary some of both FinTech companies some have partnered with them and if you look at the market structure in several countries in these innovative services sometimes you have banks and FinTech companies competing on the same footing so it could indeed have a change of course there will be some banks which are laggards in this area and they might face indeed a competitive challenge of survival in the longer term but if banks are understanding what's going on and reacting I think that the FinTech challenge is not tremendous I mean it can be more for us as supervisors the challenge will be to exactly continuously police the perimeter of supervision so to understand whether the entities that we are supervising whether we are supervising all the entities which can create risks to the system as a whole and sometimes we might lag behind that's difficult to understand we have seen already in the run up to the crisis that the different phases of the banking production process were broken into different bits and pieces with mortgage brokers then rating agencies secretization special purpose vehicles for secretization so you had a banking chain that was built outside the regulated sector we cannot rule out with the FinTech developments you could have the same type of developments occurring so we need to be very alert and police the perimeter of supervision make sure that if somebody is doing banking somebody is attracted under the supervision as any other bank so that will be indeed our challenge I think okay we have a key a key one here on the bottom it raised in the hand first good afternoon my name is Khudrigan from BankBP and I would like to know what are ECB views on the low profitability of several European banks in comparison with US and Asia and how does that play with the higher compliance requirements for the banks well first of all I would I know that this is controversial when talking to bankers but I would like to push back on the argument that higher capital requirements are the driver of low profitability and on these I think that the fact the simple fact is first of all that you have jurisdictions like the US for instance which have implemented exactly the same requirements in Basel actually they have goal-plated the requirements in Basel with higher leverage ratios and with higher liquidity requirements and the US banks as you were pointing out are indeed more profitable than the European banks but also within Europe if you look I mean you have a distribution of return on equity and return on assets which is very different and even within an individual member state which reflects the fact that the regulatory framework cannot be the only the only driver indeed let's say there was a definite objective of the policy makers in the regulatory reforms because the very high return on equities that we had seen before the crisis in the 20-25% range well above other industries were actually explained by the excessively high leverage with which the banks were actually operating so that that is something that as we have seen was giving incentive to excessively staking it was not tolerable for the general perspective so but indeed I mean having said that I acknowledge that the low profitability of European banks is a concern for us as supervisors I mean as a supervisor you want to see banks which are healthy, generates good profits, attract investors and and are attractive investment propositions for and and this is not where the European banks are right now the price to book I think the average price to book of European banks is below 50 so 50 cents on the euro and this also means as a supervisor if you need to ask a bank to raise capital it's very difficult for them to go to the market and raise fresh capital so low profitability is indeed an issue what we can do to address this of course we cannot as supervisor let's say have a profit objective for the banks but what we can do is to and we do actually is to put pressure on banks to deal with cost efficiency issues investment in technologies I mentioned before is an important element we made the ECB analysis of business models I think it was one year and a half ago which showed that the strategic steering capabilities of the board for instance are a key driver of profitability so we are also pushing bankers to refocus business model and to increase their strategic steer but there are also some structural impediments to profitability and I think that two of them interrelated are lack of consolidation and remaining excess capacity in the system and lack of integration within the euro area the EU in general these two things mean that there is still difficulty in recovering profitability and I think we should try to do something to address these issues on the third row but we'll get there we'll get there Hello, good afternoon, my name is Miguel Volint I work in the legal department of Credit Agricula I guess my question is when drafting rules and guidelines to what point are specific realities of cooperative groups taken into consideration Thank you very much Well the first of all let me say that since already when I was at the European Banking Authority the dialogue with the European cooperative banks has been always very intense there has always been a lot of engagement, I've been participating in a lot of meetings with the European Association of cooperative banks and with actually I was also invited a couple of times which was an interesting experience I must say to visit not the top brass let's say of the cooperative groups but to visit the local cooperatives part of some groups just to see what were their difficulties in dealing with compliance issues and the like so the engagement has always been very intense of course there are cooperatives for instance when you look at the definition of capital or some let's say more specific accounting issues but there are also let's say more general topics the topic we have discussed the most is proportionality with the cooperative banking sector and it is an ongoing dialogue we know that whenever we meet we argue that we have done a lot in terms of proportionality and the industry argues that we have not enough in terms of proportionality and I think that that is a journey I mean something that we will need to continue working on it's clear that with the reform of the dimension that we have put forward after the crisis especially when you have small local banks even if they are integrated in larger groups the fixed cost of compliance by construction becomes much higher and becomes much more burdensome so can we do something to address that we can I think that we are doing it in terms of the intensity of supervision we have different boxes in which we slot all the banks to graduate the intensity of supervision according to the systemic relevance and complexity of the banks we have also in the regulation for instance in the reporting, reporting is always a big issue I remember when I was at the EBA we made a calculation that if you are a plain vanilla bank doing deposit taking and plain lending basically without internal models without anything specific you need to comply with 10% of the total corep and Finrep which are the European standards on reporting while of course a larger copper bank will have to comply with all of that but still let's say in the recent legislative package there has been a requirement to do even more to try to reduce the compliance cost the EBA will have to put proposals on that and we are also committed to do our own review in that respect so the engagement is very, very intense and we are very aware of what are the issues for this segment of the industry Good afternoon my name is Katarina from CACHA my question is about bureaucracy and reporting templates and all the burden that banks have nowadays that could jeopardize the decision making process in a timely and effective manner because when you are a manager and you have lots of reports you could see data in different ways and this could delay your decision making specifically I would like to say that while you are doing transversal exercises like ICAP or recovery plan or the EU white stress test ECB can change template like five times how do you see this burden for the institutions? Thank you Thank you, well first of all maybe this will surprise you but I'm sure it will be one of the main topics we will discuss with the supervisors here this issue is not an issue only on the industry it is also on the supervisory side so we do indeed have a challenge in the sense that this massive effort to build a supervision means to a large extent that when you have to bring different approaches across member states under a single umbrella in a single place the way in which we know how to do it at the European level is to sit around the table and write a paper so you have a tendency a natural tendency to become a little bit excessively rules based in the way in which you develop your approaches which means that again also from the supervisory side you might have supervisors that tend to follow the rule book follow the internal guidance and the like and then they tick all the boxes but maybe they don't have enough time to actually look at what the real risks at the banks are and what the real problems to be addressed are which is key for us as well as I said I think it was unavoidable probably in the first phase in which we had to build this new machine and make it work now we need to move to a more mature stage of the whole construction and this will need to require also some efforts in simplification and we have already had an internal simplification group that has worked to try to take exactly these issues for instance one of the outcomes of this simplification group has been that we should develop a sort of repository of our reporting and templates so that we try to see at least what are the different requests which are coming from different maybe directorate generals or different stress tests liquidity recovery planning as you say and try to see whether we can streamline it and avoid asking the same information twice try to stabilize the templates the requirements and try to move to a more let's say to a lighter framework having said that let me also say that what surprised me a lot in these first six months at the ECB is the amount of findings that I had from inspections on the quality of IT infrastructures, data management data integrity at banks all across Europe there is not one country this type of bank that it's across types of banks across countries that's really I think that there is a problem that the banking industry has maybe because you grew towards different mergers there are legacy systems you patched up different ITs sometimes also different requirements from the supervisors maybe the national central banks the national supervisor the ECB the EBA and the like so everything is disseminated in different places it's very difficult to have it together I think that also this effort to put the house in order on the banking side in terms of how you manage data and how you integrate your system I think that would be very very useful for instance one point that attracts me a lot is a system which the ECB is now working it's called DERD I can't remember what the acronym stands for but it's a system which is in developing a dictionary of common definitions of banking aggregates that would allow banks to basically report regularly on these granular let's say let's say data points and then instead of asking every time additional data collection it would be up to each supervisor or central banks to pick up these granular data and aggregate them in the way they like so that you don't have repetitive and continuous requests from different angles. I think that's something which has been experimented in Italy and those traits has worked well and maybe we should think about a system like that What an art college from when working in data science and artificial intelligence perfectly with the last answer so I've recently joined when coming from a different industry and I've seen a lot of the impact I think we've all seen it of artificial intelligence commercially but when I think about risk management I see also tremendous potential of using these techniques to make the banking system more robust and safer in general so I wanted to ask you about your views on how we should be using these new technologies as a regular editor and as a supervisor to make the system safer and also what's blocking us from doing that so why are big techs doing that so much and taking so much advantage of that and we are liking that Thank you It's a good question and I'm not sure I have a very smart answer to that maybe what I can say is that we are trying ourselves to invest in this in this area we have had a first experiment it's a very narrow one but for instance we have areas in which we have very lengthy complex detailed applications for instance in the area of passporting and there are many of them and they are continuously updated so it's really a hassle in terms of the administrative burden of dealing with that so we have developed an artificial intelligence tool that is able to scan all these applications and they like to exchange what are the relevant issues and see whether there is anything so that these streamlines a lot the bureaucratic work for us to deal with these applications so I see that there is there are a number of areas in which you have a heavily bureaucratic work on our side and on the side of of the banks as well in which maybe the compliance process could be streamlined quite significantly by using artificial intelligence anti-money laundering is not our cup of tea but it's another area in which sometimes I'm wondering whether the system we have is the best we can it's very paper based it's very cumbersome on customers and doesn't manage in many cases to catch up the big crooks so maybe we can use more this type of systems to identify red lights that can be addressing the authorities to the relevant points so this means that artificial intelligence can also be used on the supervisory side probably as a tool for identifying where are the main risks in certain areas we're still at the very beginning but we are investing on it you said that the banks have been doing some interesting work reducing their NBL portfolio however you said that they should finish building the roof while the sun is out do you think that amount of pressure might actually give us some prejudice in the long term strategy to return to profitability and if so how is the ECB planning on dealing with that thank you first of all let me acknowledge this banking sector has done a lot in terms of addressing the NPL problem as you know we have developed these policies identifying targets for banks and banks in Portugal have overachieved those targets and they have taken opportunity of a good macro-economic environment to make progress in that direction still let's say the levels remain relatively high and at least in comparison with the European average so the point is that again as there is still a good economic situation it is important to take all the opportunities to complete the job and again in terms of the impact on profitability before there was this reference comparison also with the US for instance this is really something I've been saying since 2011 I'm deeply convinced of that the big difference between the U and the US is that the US has decided to front-load the adjustment all at the beginning also with taxpayers money 600 billion dollars of the tarp on the table and they put Fanny May and Freddie Mac to the work in terms of cleaning the balance sheets of the banks they forced the bank to recapitalize upfront quite a lot and making them also accept preference shares from the state and the banks were then forced to clean up the balance sheets the crisis was completed in 3 years so in 3 years the US banks got to the NPL ratio that they had before the crisis we are now let's say 10 years after the crisis and we are still above we have not reached on average the pre-crisis level so I think that if you look also at let me take the case of Italy which I know because I've seen it also let's say more, more, more when I was a supervisor there when you see the game changer there has been when some banks have decided to buy the bullet and make some big sales of NPLs and the impact on the equity prices was positive then the other banks started then this was a game changer because all the other banks also started investing in that and the profitability eventually benefited because of course if you have if you download the NPLs you take the capital up front but then you free up your balance sheet and you can do more profitable business rather than keep your capital locked on loans that are not paying back so eventually let's say I think that there has been also on the side of the industry as also in our own camp in the supervisory community a little bit of myopia the idea that if you take a little bit more time things are going to be less painful and actually I really believe that in this area the faster you are the more brutal you are at the beginning the more bitter the medicine maybe in a short period of time but the easier and faster the rebound is so I remain convinced of that and again a lot has been done in the last two years in Portugal NPLs have been halved more than half now and the thing that now we are seeing the benefit also in terms of profitability the problem is that sometimes you cannot afford it I know and our cost of capital to replenish is too expensive so I mean it's but I completely agree that your comparison with the United States raises a lot of issues in relation to another element that is more of a macro but that micro-impact that's the the fact that the whole scheme of banking union is not yet completely finished and complete and so what the Americans did is a good lesson for us but we we are still far away from there I mean this is I want to say this because I think it encapsulates my judgment of what is wrong in the European Union right now in 2008, Lehman I was working at the Bank of Italy was head of department there and in the policy area and head of the policy area and I remember I received one day a memo that was coming from the Dutch finance ministry that was proposing to create a European bailout fund so the idea was we have a crisis which is affecting which is affecting which is affecting all the all the European banks so we should build up a European fund to support the banks to overcome this issue after after Lehman and at the time the Italian government and authorities included the Bank of Italy where I work had the impression that this was not our crisis this was structural finance was banks that had engaged in complex structural products our banks have not done that they are plain vanilla banks doing laws so I didn't manage to finish my memo because I was really believing that we needed a European framework to address the crisis that basically the Italian government had given a negative opinion on the project so there is the reduction of course the Italian government would not have been other governments I would not mention here because I was not involved in those parties that were also firing on the proposal and they killed very fast but let's say this to show that this risk reduction risk sharing type of debate sometimes turns around I mean people who are on one side of the debate at a certain juncture can find themselves at the other side of the debate at a different juncture so the point is that everybody is so short-sighted not to see that we are in a in a prisoners dilemma which cooperating and setting up common structure better off while if everybody wants to go alone everybody is worse off but it's so difficult that raises another element that is the engagement of people in some projects policy projects, European policy projects that requires that really there is someone putting pressure on politicians at least to finish what we have started in terms of banking union because otherwise we are really a bit stuck and we have several examples that pop up from this kind of discussion okay we have on the second row the gentlemen with the third there hello hello, Jean Miranda from LENI-BCP I'm from the investments and savings products department this is the follow-up question to the discussion this afternoon namely regarding profitability giving the current negative central rates that do not seem that they will change anywhere anytime soon at least and coupled with what we are doing with better risk profiles and being more careful with the type of loans that we are giving out there is some impact on profitability on banks and especially I would say on southern banks and periphery banks such as the ones in Portugal my question is this could lead to some sort of bank consolidation that we've experienced before and that might come again and how do you see this particularly vis-à-vis your comments regarding more competition coming from FinTech for example thank you well first of all let me say that I mean negative rates it goes without saying of course put some pressure on interest margins that's clear and straightforward at the same time I think that looking at that only is a bit simplistic because one should look at the counter-factional what would happen if the ECB stands would have been less accommodating and what would have been the macroeconomic outlook and what would have been the asset quality impact I mean it's clear that if you have lower interest rates it's also a situation in which you know the burden for borrowers is lower you can have borrowers coming back to let's say to health in an easier way and you have less difficulties also in dealing with the non-performing loans issue of course there is a differential impact according to the type of banks the banks which are more intensive in terms of deposit taking so that cannot go of course in negative territory because nobody is charging negative rates on depositors of course are going to be affected a bit more so there are some differential impacts but my point is that in general let's say this is a situation which is going to stay for longer and the banking sector needs to adjust to that to some extent and again for me the lesson is use this window as effectively as possible to deal with the asset quality issues to refocus the business model to deal with the cost efficiency issues and move ahead and bank consolidation could be part of that indeed if you look at any industry that has a crisis globally the automobile industry the steel industry in the crisis you build up a lot of capacity then the crisis comes and you have excess capacity in the sector and you need to more pop this excess capacity the way in which this has happened in all the industry has been through consolidation and in the European sector we didn't have this we have some consolidation but not a big wave of consolidation which means that we still have some banks that have maybe not viable business model that keep remaining in the market thanks also to accommodating monetary policy conditions they try to gamble for resurrection maybe applying very narrow margins and competing their way out of the crisis and this is an exercise in additional pressure on profitability in the sector so consolidation would be indeed an important way of addressing of addressing these of course we are supervisors so it's not up to us to design the structural system or enforce consolidation is up to the bankers sometimes when I speak to bankers about consolidation I see the body language in the room becomes very very very negative because in many cases bankers think that consolidation doesn't happen also because there are regulatory impediments or supervisory impediments to consolidation I mean on these as long as this is the case let's say I'm committed to try to do what we can to remove these impediments but eventually the choice is with the is with the bankers and this would be helpful also as you say correctly in terms of dealing with these fintech issues so this rethink of the business model these rethink of consolidation strategies need to be developed also with some strategic long-term thinking and investment in technologies investment in new distribution channels should be part of this thinking and the competition fintech to some extent can accelerate this process or could be a positive let's say trigger for the process In Portugal we had several experiments in terms of consolidation I mean a lot of them and it is true that sometimes I think this is another area where we should refine our tools in particular in what concerns the supervisory control over subsidiaries and branches because in fact if you have a very very systemic subsidiary and you are responsible in the ultimate circumstances you are responsible for the coverage of the deposits if something goes wrong so it depends on if you have a multiple point of entry or single point of entry in the case of branches very big branches of course you don't have to pay for the cover deposits but you have a very limited oversight of the practices and so I mean in normal business yes it makes sense and maybe there are some economies but there is in Portugal has this experience because we are a home and a host so we have this dual capacity to see both sides but when you are a host in fact and we had this trauma with Pokulhar that in fact we risked we asked to pay back the cover deposits of a small small entity but nevertheless the cover deposits were about 2 billion which at that time for the moment in macroeconomic terms Portugal was going through a really really big blow apart from the other impacts that are not a direct but they are indirect like the other deposits that could have been have to be covered by the national taxpayer so the scheme in which even inside banking union we manage the control and the responsibility for the supervision and resolution at the top level and when things go wrong the kind of liabilities and the obligations that fall on the desk of the host country this is really a crucial thing and this is what sometimes I mean I think we should address it more carefully but of course this comes from an experience because here you are in a I mean in a jurisdiction where we had it all so we can tell you a lot about the cost and benefits of the whole thing but it is true that I mean for instance do you have a capacity for a standalone entity in the resolution process when the big entity goes in the resolution can the entity is the resolution strategy including a standalone condition and the requirements for that and we have from the host country some oversight sufficient oversight all these these elements are very relevant because otherwise it's very imbalanced that you take decisions at European level and then you have to I mean to clean the desk the host country it is very imbalanced so before we correct these missing pieces in the structure it is difficult that you have I mean an enthusiasm with the idea of merging or of this consolidation because there are all these when things go wrong that's what rules are for it when everything goes right ok but in general I think in theory I mean in general I agree but when it comes to the details of it it's a bit more complicated let me clarify that I was talking about consolidation in general not necessarily cross-border actually to some extent I'm convinced that in the first phase where the driver for consolidation is mainly cost efficiency you have the best incentives where you have overlapping distribution networks so probably in the first phase it's more the national level which is the one which provides you with the greater let's say leeway for consolidation but indeed let's say also at the European level for instance when you have again sorry to use but I think we should in certain cases also use this as a benchmark if you take the US you have take Puerto Rico and Greece are two countries of the same size they both basically entered into a major fiscal crisis so the state went under great troubles it defaulted in the US it went in private sector involvement at the European level and the banking sector went under water because of that that's natural big crisis in the state and so in the in Greece basically this was all managed locally you know and the system is still now with 45% NPR years six years after the crisis in the US you had the FDIC that entered the banks in the weekend take control of bank via purchase and assumption and started selling the assets and the liabilities of the banks in Puerto Rico and the branches banks in Puerto Rico to banks from other states in the US and borrowers depositors didn't even notice I mean they received the letter saying your bank until yesterday was called bank A now tomorrow it's called bank B nothing changes nobody noticed and this helped the system the shock in Puerto Rico was distributed throughout the US in Europe the shock in Greece remained in Greece and went deeper and deeper and deeper this is the main problem we are in the banking union right now and if we don't have a more diversified banking sector you will never manage to address it but for this I mean I keep mentioning this example when we started this banking union in fact it was a post crisis initiative and when we looked around I mean the commission and the European Parliament we were looking around and they said okay the kind of example that you can really follow for more stability is the FDIC model so our purpose was to create an FDIC kind of system for Europe in which you start by creating stability in the market through a guarantee of deposits and then it evolved politically saying okay if you want a common guarantee of deposits please start with a single supervision and then yeah okay we did single supervision then now we go to single resolution okay we go and then when it came to now where is the guarantee of deposit then we are stuck here and that's the thing that that Europeans have got to go I mean to go forward because otherwise it can't work I mean we are it's a bit of a I mean I think it's something that is difficult to explain to the man in street because what are you talking about I mean but for people that are everyday in the business you realize how relevant such a thing is because then what happens is that the supervisor and the resolution authority has an easy task because okay you bail in the junior and then you transfer and you sell and you have got a kind of a backstop a strong backstop from the Federal Reserve that you can use to transfer it and if you don't have a buyer at that moment you can hold it and the buyers know that so there is not this tendency to destroy the price but in Europe we are in the middle let's see if the new I mean the new changes they can help because that's one of the elements that the IMF mentioned in the SUB so we'll see if we can do something but it's really I mean it's really a major issue but there was a question from the lady with the yellow jacket and the colleague right next to her Hi, my name is Anna Gays I'm from Credit Agrico also I read the speech you you gave I think recently in Ireland I think where you talk about the importance of good governance in a good decision making process in order to avoid the crisis in banking sector overall in the banking sector we are now overcoming one crisis and my question is do you think it can be a setback with Brexit giving that banks in UK and in Europe can make a lot of bad decisions or not and we hope not trying to retain clients and trying to show the market they are ok and they are not affected by it even more since you are having you will be losing the supervision of UK bankings so UK bankings so my question is do you think it can have a setback well Brexit is a challenge that goes without saying it's a major a let's say requested banks to make major adjustments we have been pushing banks actually both we ECB and the Bank of England on the other side of the channel started pushing banks to make preparations for Brexit already I think almost two years ago now and they are on the long list and they think that we ticked all the boxes so the banks did everything that we asked them to do so in terms of I shouldn't have the right licenses to continue serving their clients making all the projects in terms of we say moving business in such a way that they could continue let's say operating in a smooth way contingency planning so preparing for adverse contingencies so we have done all the possible preparation for that and I think the banks have done all we asked them to do I mean at the moment we I met Sam Woods the head of the Prudential Regulation Authority in the UK a few weeks ago we had the shortest discussion on Brexit ever I think I mean it's because we don't have anything to say anymore we have done all that we thought should have been done and we are happy with what the banks have done in terms of preparation having said that are we safe are we sure that everything will go right of course not I mean this will be in any case an event which can generate market dislocations markets are not pricing hard Brexit at all and this may happen let's say three months from now basically so there could be actually quite significant market disturbances associated to Brexit and I cannot say that we are in a safe place but what I can say is that both ourselves and the banks have done all that we could to prepare so we fastened the seat but then we hope the crash is not to damaging what can we do well I think we have time for one more because we're getting to the end she was first so we have room for one more thanks thank you very much from Milano BCP I work in marketing department I'm responsible for the Hobson and non-resident club customers of Milano BCP and I also represent Milano BCP in the FMA which is an association of the banks and the insurance companies and actually in this room in this console that I can have participation we are always a little bit concerned on the MIFI2 and how we are coping with this regulation that till now it's much more about costs and not of implementing it and not actually on the results that we were expecting from it about having our customers really more confident about our banking system and right now we have some delays some different implementations regarding all the customers the country that are trying to implement it and we still have this issue to leave and actually we are about to start another MIFI2 implementation we are starting about MIFI3 so what are you I want to your about the future of this regulation and what we can expect more from for the coming years I will disappoint you here I'm afraid because MIFI doesn't fall under the responsibilities of the ECB so I wouldn't dare to go into the field of my former colleagues in Paris what I can say is that I mean I'm disappointed by the lack of ambition on the Capital Markets Union project so I think that this is also linked to the question on Brexit that we had before now the Capital Markets Union was built originally also as a project let's be honest that was envisaging the London financial market to become a big financial hub Capital Market hub for all the Union basically and was part also the discussion when the UK was starting to consider a referendum for possible Brexit then Brexit occurred I think there has been a lack of strategic thinking on the Euro area side in terms of really making the policies that would allow a Capital Market a mature Capital Market to develop onshore in the Euro area linked to the Euro and this would have meant in my view again a much more integrated regulatory framework in terms of you know maximalization probably more than MIFI that has been able to deliver but also I think that's crucial more ambition in terms of giving a role to ESMA in terms of this process we have seen that several national capitals have been very reluctant to let ESMA take a greater role we have seen this recently in the reform in the discussion on the reform of the European supervisor authorities and I think you cannot have a Capital Market Union if there is no authority which is for it which is running with the project which is accountable for delivering on that project and so I'm afraid that we will not achieve as much as we could in that area at least at this juncture but I know the colleagues in Paris are doing their best to understand the issues that you raise. Andrea I think we have got to finish but if you allow there is someone that is really desperate to say he has been asking for the floor for a while so he will take care. Thank you my name is Andrea and I'm from Crete Grifle, strategic planning department so talking now about our generation our future as society how is addressing how is the ECB addressing climate action and ECG goals as supervisor and as monetary policy maker can we expect for instance a specific interest rate for bank champions in sustainability or other Well thanks for the question it's a good close to our conversation because it's looking more to the future I saw in his eyes I I generally believe that green finance sustainability will become more important also in the approach of the authorities more the central banking side the supervision there is this network on green of the financial system which has been established it's interesting because it was established of the G20 in which the US basically started exiting the Paris agreement and it was a clear let's say decision, deliberate decision of the central banking community for some reasons to maintain the focus of the public authorities on this issue and the ECB participates actively in this network which has issued a very interesting report if you want to look at it I think in mid-April and Frank Elderson who is sitting on our board is the chair of this network the ECB supervision has identified the sustainability risk as one of the key risk for ready for 2019 so as you maybe know every year we try to when we develop our work program we do a risk map so we ask the supervisors in all the jurisdiction to give us their priorities in terms of risk for the first year there was a number of supervisors told us that sustainability is an important area so we start the peering with a relatively high priority on our risk map in my view let's say there are two points I would make just for your consideration the first one is that as I mentioned before there is this issue of short-sightedness in risk management that you have not really take hold if you look at all the risk models that we have they all have a one year horizon basically in terms of PDs LGD estimations and the like but if you think about transition about environmental transition the risks are not something that you can quantify with a 12 months horizon you need to look ahead you need to look 10-15 years and check whether the the loans you are making are actually to the collateral you are taking for loan I mean is something which has value for the whole maturity of your exposure there are for instance in the Netherlands there are very strict regulations on houses which have how is it called the amiant I can't remember the asbestos asbestos so basically these their value will go to zero basically in I think by 2030 so basically if you accept this collateral these houses with asbestos basically you will lose all your value of your collateral in 10 years basically so these type of things need to be factored in and I think that this is a shift I very much believe also in stress testing for instance not the traditional stress testing that we do with the 3 years horizon but looking at the longer time frame of what would be the shift from brown to green sector what could be the impact also for bank land so these are the things that I see positively a little bit of concern that I have is when I hear the issue of sustainability is used in terms of asking for supporting factor I don't like supporting factor I would at least argue that they should change the name because I mean I don't think supervision should support anything I mean we're not here to support these or that activity no we are here to make sure that the risks are properly factored in your processes in the banks so I think that if you distort the risk assessment and the capital allocation from a policy perspective or one sector vis-à-vis the other I think you don't do a good service in terms of support and sustainability and green finance but if you do instead good taxonomies or what is green what is not green good transparency and good factor in the risk management of these elements I think you can do a great service to the future communities and future generations well thank you very much I think I don't know if you want to say something no I mean just to I've done a brief summary on the diversity of issues that you all touched upon which I think it's very positive I mean we've spoken about IRB models fintechs, AML governance profitability sustainability, business models corporate banking and the matter of proportionality, bureaucracy and reporting use of technology in areas besides the I mean the commercial one sustainability impact of brexit, NPLs I mean I think we've touched upon I think almost everything so thank you very much to the audience and I mean I think this was really really I think all of them want to thank you very much I think they recognize what a privilege it was to stay for two hours in front of the head of banking supervision in Europe in banking union at least in such an open and free and closed dialogue and on their behalf somehow I would like really to thank you I was kind of implying and joking that as you came twice to Portugal that you liked us but definitely we like you and your style thank you very much thank you