another option is for g - sibs to issue glac - eligible instruments from a holding company and downstream the proceeds ( often referred to as “ structural subordination ” ). another option that has been suggested is either to prefer excluded liabilities or subordinate eligible liabilities in statute – although agreeing changes to national insolvency laws could prove challenging. again, whatever the approach, adequate disclosure at the legal entity level will be crucial to allow creditors to identify easily their position in the creditor hierarchy. with such adequate disclosure, there is no a priori reason why the cost of meeting such a requirement would differ between the approaches. a final, crucial, aspect in rationalising g - sibs ’ liability structures to make them resolvable is to ensure that the loss - absorbing capacity is issued from the right place in the group. g - sibs have hundreds, sometimes thousands, of legal entities. applying resolution tools to each one is not possible. therefore the resolution strategy for each g - sib will involve resolving either the whole group, or parts of the group, by applying resolution tools to a single parent, or a small number of intermediate parent entities – or, in fsb parlance, resolution entities which serve as the point or points of entry to resolution. there must be mechanisms in place to ensure that key operating subsidiaries of each resolution entity have reliable access to the glac issued by the resolution entity. one way of achieving this is for the resolution entity to downstream the resources raised by external issuance of glac - eligible instruments to material subsidiaries as long - term debt that ranks junior to the subsidiaries ’ non - capital instruments. this pre - positioned intragroup glac could contain provisions that allow the losses to flow up to the resolution entity by converting the intragroup debt to equity without placing the subsidiary into resolution, if home and host authorities agree this is necessary. since, in a cross - border resolution of a g - sib, it is in the interests of both home and host resolution authorities that key subsidiaries that are not themselves resolution entities do not formally enter resolution, and instead resolution tools are applied only to resolution entities, this will incentivise cooperation between home and host and reduce incentives to ringfence assets locally in an uncooperative manner. so, if there is sufficient glac of adequate quality that is distributed appropriately within g - sib groups, we will have made a further, major step in making g - sibs

- up on settlement risk. the longer settlement is delayed due to operating hours the greater the settlement risk becomes. expanding operating hours will make cross - border payments faster and reduce settlement risk but, as the report points out, there are also risks and operational and policy implications to assess when reviewing expansion of operating hours. parties involved in rtgs systems may need to review and enhance existing operational procedures, risk monitoring tools and mitigation measures, and central banks and other authorities, will need to consider issues related to monetary policy, financial stability, and resolution policy for troubled institutions. undertaking the assessments of access and operating hours is critical the reports encourage central banks and authorities to review the benefits, risks and barriers of expanding access and operating hours and set out a framework to do so. the report on access sets out a holistic framework that central banks and authorities can follow and by providing realworld examples and case studies of jurisdictions that have successfully expanded access. and the report on expanding operating hours encourages authorities to assess the three end - states and reviewing the opportunities, risks and policy implications for each of them. while the reports say “ encourage ”, i would really urge central banks to undertake such reviews – the more that change, the greater our ability to meet the fsb global targets. with building blocks 10 and 12 being foundational for the roadmap, undertaking the assessments and taking action to expand access and operating hours will also have a direct positive impact across many building blocks. the bank of england ’ s renewed rtgs service i want to bring this to life by outlining what the bank of england will be doing in response to these two reports and how our rtgs renewal programme will support this work. the bank is in the process of a multi - year project to renew rtgs. while changing our domestic infrastructure, this programme also has an eye to opportunities to enhance cross - border payments. there are two key milestones approaching : chaps payments will migrate to enhanced iso 20022 messaging in april 2023, followed by the switchover of the core settlement engine in spring 2024. the new rtgs platform will have the capability to extend operating hours to 22 / 5, and with further changes, to near 24 / 7 operation. and it will be built with the capacity to accommodate a significant increase in account holders. importantly, it will be a modular design with a strong foundation on which to build additional innovative functionality. we are currently consulting industry on a menu of features which could be introduced to rtgs