24  All speeches are available online at www.bankofengland.co.uk/news/speeches and @BoE_PressOffice  24  References Aikman, D, Haldane, A, Hinterschweiger, M and Kapadia, S (2018), ‘Rethinking financial stability’, Bank of England working papers 712, Bank of England. Bailey, A (2020), ‘The central bank balance sheet as a policy tool: past, present and future’, speech available at https://www.bankofengland.co.uk/-/media/boe/files/speech/2020/the-central-bank-balancesheetas-a-policy-tool-past-present-and-future-speech-by-andrew-bailey.pdf Bank of England (2021), ‘Responses to the Bank of England’s March 2020 Discussion Paper on CBDC’ available at https://www.bankofengland.co.uk/paper/2021/responses-to-the-bank-of-englands-march-2020discussion-paper-on-cbdc Bernanke, B (2004), ‘The Great Moderation’, Speech given at the meetings of the Eastern Economic Association, Washington, DC, February 20, 2004. Bholat, D, Broughton, N, Ter Meer, J and Walczak, E (2019), ‘Enhancing central bank communications using simple and relatable information’ Journal of Monetary Economics, Elsevier, vol. 108(C), pages 1-15. Botsman, R (2017), ‘Who Can You Trust? How Technology Brought Us Together – and Why It Could Drive Us Apart’, Portfolio Penguin. Briault, C, Haldane, A and King, M (1997), ‘Independence and Accountability’, Towards More Effective Monetary Policy, Palgrave Macmillan UK, p. 299-340. Coenen, G, Montes-Galdon, C and Smets, F (2020), ‘Effects of state-dependent forward guidance, largescale asset purchases and fiscal stimulus in a low interest rate environment’, CFS Working Paper No. 639. Evanoff, D D, Haldane, A and Kaufman, G C (ed) (2015), ‘The New International Financial System: Analyzing the Cumulative Impact of Regulatory Reform’ World Scientific Books, World Scientific Publishing Co. Pte. Ltd., number 9604, June Fischer, S. (1999), ‘On the Need for an International Lender of Last Resort’ The Journal of Economic Perspectives, 13(4), 85-104.

At the same time, the industry has asked the Committee not to sacrifice risk sensitivity where it makes sense, even if it means that the rules may become somewhat complicated. Indeed, the complexity of the New Accord stems partly from the options the industry requested to ensure that a blanket rule would not unfairly disadvantage a particular business or exposure. You need only read a few of the comment letters on our website to see that many of the latest suggestions would tend to increase the complexity of the New Accord even further. Nonetheless, the Committee is aware that it is easier to enforce a simpler rule than a complicated one. As we complete the text of the new rules, we will continue to simplify and streamline the framework. Conservatism A second important theme addressed in comment letters suggested that the Committee may have adopted an overly conservative approach to some aspects of the framework, resulting in much higher capital charges than banks feel are necessary. Respondents attribute what they view as excessive levels of conservatism to different sections of the New Accord, including, as I mentioned earlier, the calibration of capital requirements to both EL and UL. We have heard similar concerns about conservatism in the securitisation proposals, in the treatment of certain credit risk-related hedges, and in the recognition of insurance products within the operational risk proposals. Questions about conservatism are important, as we are trying to align capital more closely to risk.