The number of fines levied on 12 November alone amount to almost three quarters of the number levied in 2013. 20  See Dudley (2014) and Shafik (2014). BIS central bankers’ speeches  9  In the UK, we have introduced a remuneration code prescribing that payment of bonuses must be deferred for a minimum of three years and, after payment, be exposed to clawback for up to seven years. Bonuses can be reduced – or clawed back – if evidence emerges of employee misconduct or failures of risk management. We are consulting on extending deferral periods, widening the scope for groups of employees to have their bonuses reduced where there are more pervasive issues of performance or risk management, and considering options to prevent individuals sidestepping these rules. In an international labour market there is a particular role for international standards and coordination to ensure a level playing field. It is unfortunate, for example, that new European rules to cap bonuses to half (or with shareholder approval, two-thirds) of total pay have the undesirable side effect of limiting the scope for remuneration to be cut back. This makes the case for additional reforms to ensure that the burden of excessive risk-taking and misconduct by staff can still be borne by those staff. Standards may need to be developed to put non-bonus or fixed pay at risk. That could potentially be achieved through payment in instruments other than cash.

Basel Committee on Banking Supervision (2010b), Results of the comprehensive quantitative impact study, www.bis.org/publ/bcbs186.pdf. Basel Committee on Banking Supervision (2010c), Assessing the Macroeconomic impact of the transition to stronger capital requirements. Macroeconomic impact assessment of OTC derivatives regulatory reforms, www.bis.org/publ/othp1220.pdf. Caruana, J (2012), Building www.bis.org/speeches/sp120208.pdf. a  resilient  financial  system,  Dudley, W (2014) Enhancing financial stability by improving culture in the financial services industry, www.ny.frb.org/newsevents/speeches/2014/dud141020a.html. European Banking Authority (2014), Simple, Standard and Transparent securitisations, www.eba.europa.eu/documents/10180/846157/EBA-DP-201402+Discussion+Paper+on+simple+standard+and+transparent+securitisations.pdf. European Central Bank and Bank of England (2014), The case for a better functioning securitisation market in the European Union: A Discussion Paper, www.bankofengland.co.uk/publications/Documents/news/2014/paper300514.pdf. Financial Policy Committee (2014), The FPC’s review of the leverage ratio: a consultation paper, www.bankofengland.co.uk/financialstability/Documents/fpc/fs_cp.pdf. FSB (2014a), Adequacy of loss-absorbing capacity of global systemically important banks in resolution: consultative document, www.financialstabilityboard.org/wpcontent/uploads/TLAC-Condoc-6-Nov-2014-FINAL.pdf. FSB (2014b), Letter from FSB Chair to G20 Leaders, www.financialstabilityboard.org/2014/11/fsb-chairs-letter-to-g20-leaders-for-the-brisbanesummit. FSB (2014c), Reforming major interest rate benchmarks, www.financialstabilityboard.org/wpcontent/uploads/r_140722.pdf. FSB (2014d), Report to the G20 Brisbane Summit on the FSB’s review of the structure of its representation, www.financialstabilityboard.org/2014/11/fsb-review-of-the-structure-of-itsrepresentation. FSB (2014e) Global Shadow Banking Monitoring http://www.financialstabilityboard.org/wp-content/uploads/pr_141030.pdf. Report  2104,  Haldane, A (2014), Why institutions matter (more than ever), Managing global finance as a system www.bankofengland.co.uk/publications/Documents/speeches/2014/speech772.pdf. BIS central bankers’ speeches  21  IMF (2014a) Global financial www.imf.org/external/pubs/FT/GFSR/2014/01/pdf/text.pdf. IMF (2014b), Staff Report for the 2014 Article www.imf.org/external/pubs/ft/scr/2014/cr14312.pdf. stability IV  Consultation:  report, Singapore,  IOSCO (2014), A comparison and analysis of prudential standards in the securities sector, www.iosco.org/library/pubdocs/pdf/IOSCOPD438.pdf. Macroeconomic Assessment Group on Derivatives (2013) Macroeconomic Impact Assessment of OTC derivatives regulatory reforms, http://www.bis.org/publ/othp20.pdf.