A good example of this was Law 2/2011 on Sustainable Economy, which marked a milestone on the road towards advanced regulation of conduct. For example, this legislation includes for the first time so-called “responsible lending” and modernises claims services. Several European Directives addressing this field have also been approved. Banco de España Circular 5/2012, which replaced Circular 8/1990, includes all these features. I honestly believe that the current rules accurately regulate transparency obligations regarding bank products and services both in the pre-contractual stage and over the life of the operation. Evidently, in parallel with these regulatory developments, there have been most significant changes in society, public opinion and jurisprudence, especially in the past decade. Our supervisory framework has also evolved. Now, in addition to focusing on formal compliance with conduct obligations, it also envisages the management and mitigation of these risks by banks and their incorporation into the business model. I shall briefly refer to these aspects today. But I will also broach the need to enhance customers’ financial knowledge. In my view, this is a key element of which little mention is usually made. The cost of litigiousness Clearly, the changes in customer safeguard regulations and in jurisprudence mean that what was appropriate in the past has ceased to be so today. Undoubtedly, banks have acted questionably; but to be completely fair, we should acknowledge that the legal playing field on which banks operate has changed significantly.

I say partially because there were still some restrictions on the remuneration of sight deposits and the setting of certain commissions. We had to wait until 1987 until deposittaking institutions were free to set interest rates and commissions, with such freedom becoming extensive to all credit institutions two years later. Naturally, following liberalisation, the need to regulate transparency in relation to the setting of and changes to interest rates and fees became particularly important. It was also necessary to better clarify customer rights, and to establish reporting obligations to the Banco de España. In this respect, Law 26/1988 on the discipline and intervention of credit institutions set in place the regulatory powers for establishing a transparency regime, which was implemented by a Ministerial Order dated 12 December 1989. Banco de España Circular 8/1990 on the transparency of operations and customer protection finally drew all these legal strands together. Among other aspects, this Circular included for the first time the need to publicise the famous APR, whose aim was and still is to allow customers to make a uniform comparison of return or cost among different bank offers. Also regulated was bank product advertising, the information to be included on noticeboards, the customer ombudsman and the functioning of claims services, which had already been introduced in May 1987. 1/6  BIS central bankers' speeches  Following their introduction, transparency regulations have evolved over time, in line with changes in society and the growing level of demands made of the banking sector.