) ; the online register of non - possessory liens and that of foreclosures and bankruptcy proceedings ; the extension to consumers of the marcian pact forfeiture clause. further improvements might include additional specialization of judges in bankruptcy proceedings and reducing regional differences in courts ’ performance. an important contribution on the european front could come from a regulatory provision eliminating or limiting the measures that discourage banks with advanced internal ratings - based ( airb ) models from selling their npls ‘ en bloc ’. including the impact of such sales in estimates of the loss given default ( lgd ) parameter automatically raises capital requirements considerably on all performing loans and consequently reduces capital ratios. analyses based on a sample of italian banks show that this reduction could be significant. the measure would take account of the exceptional nature of the present economic situation and the need to combine supervisory with macroprudential objectives. banks ’ capital and support measures an exceptionally deep and protracted recession such as the one experienced by the italian economy has undoubtedly had serious repercussions for the banks. nevertheless, at the origin of the worst crises we also find corporate decisions that were undermined by misconduct and distortions in the allocation of credit. the fact that the greatest difficulties involve banks which taken together account for a relatively small share of the industry ’ s total assets is an indication of the overall resilience of the system. since the onset of the financial crisis, and partly as a result of pressure from the supervisory authorities, italy ’ s banks have almost doubled their cet1 ratios and are continuing to increase them, including by raising funds on the market. the national and european supervisory authorities have been monitoring the most critical situations for some time. the measures adopted were designed to reach orderly solutions and avoid repercussions for the stability of the banking system, within a rapidly changing regulatory environment that precluded any recourse to the instruments successfully used in the past and before the new instruments became fully available. various measures were taken to deal with the different situations. with the help of the national resolution fund, to which all banks contributed, four banks at risk of failure were placed under resolution at the end of 2015, thus avoiding any need for a publicly funded recapitalization, although to cover the losses it was also necessary to reduce the value of subordinated bonds to zero. the only alternative to resolution was to wind them up, which would have cost their creditors even more and involved others in addition to shareholders and subordinated bond holders

of the pilot regime. this new technological landscape offers many opportunities to develop new payment solutions that can improve general welfare. whether this potential will be realized or not it depends on the way we design psd3. however, because of the new technological infrastructure underlying the payment ecosystem, we cannot proceed with the same 1 / 4 bis - central bankers'speeches mindset that guided us in the past. on the contrary, we need to be creative and to approach the drawing board with three pillars in mind : i ) how to solve the eternal question of whether to regulate entities, activities, or both ; ii ) the fact that the whole ecosystem is evolving continuously and swiftly ; and iii ) the need to promote publicprivate partnerships aimed at designing pro - innovation regulations ; let me now elaborate on them. to answer the first question about who or what should we be regulating, i think we should first and foremost grasp the profound implications of the new technological environment ; for me, the most striking feature is that the supply chain of a payment service is increasingly being fragmented among specialized and interdependent actors caught up in the structure created by the technology, even in absence of any contractual relationship. to make clear what i am trying to say, let's recall that before psd2 came into existence, the main actors in the field of payment services were traditional psps ( banks, electronic money institutions and payment institutions ) and the regulations were centred on these entities. the psd2 has contributed to bringing the exclusivity of the bank - customer relationship to an end ; it allows new players such as third party providers ( tpps ) to offer new services to their customers, namely open banking services, without having any contractual relationship with the incumbent payment services providers on whose books these customers hold their savings. as a matter of fact, psd2 laid out a regulatory framework establishing that psps have to grant access to payments accounts to tpps through technology solutions, known as application programming interfaces – apis. here we can clearly see the innovative and disruptive potential of psd2 and how it was able to foresee well in advance the technological leap that the payment industry could make for the benefit of the whole financial world : as a matter of fact, in the'open'system, the technological standards replace the traditional'private rules'( such as the agreements typical of card schemes ) and become technological law themselves. this is why, in the context of open banking, agreements are not only unnecessary