in place for settlement of bank customers ’ complaints and claims. under the existing two - tier complaints system, in the event of a dispute bank customers must first contact the bank concerned, which must necessarily have a customer service department or unit. if they are not satisfied with the response received, they may then apply to the claims departments of the financial supervisors – the banco de espana, the national securities market commission ( cnmv ) or the directorate general of insurance and pension funds ( dgsfp ), according to the subject - matter of the claim – which will issue a non - binding opinion. this system has several problems. on the one hand, it is not sufficiently flexible to provide customers improperly treated with due satisfaction in a reasonable period of time. and on the other, there is no arrangement in place for a third party to issue an opinion that is binding on banks if they are unable to reach an agreement with their customers. accordingly, consumers are all too often obliged to go to the courts to obtain due reparation. certain regulations recently passed in spain, such as law 10 / 2014 of 26 june 2014 on the regulation, supervision and solvency of credit institutions, and law 5 / 2015 of 27 april 2015 on the promotion of business financing, include provisions designed to foment improvements in the existing institutional arrangements for customer protection. in any event, irrespective of any present or future legislative changes in this respect, i believe that banks have the capacity to drive improvements in the short term. for the moment, they appear to be readier to comply with the non - binding opinions issued by the banco de espana ’ s claims system. in addition, it would be appropriate to consider the possibility of developing centralised and binding dispute settlement arrangements, such as those in place in other european countries, possibly with the participation of the industry, to correct the shortcomings of the present system. bis central bankers ’ speeches 6. final thoughts let me finish by saying that in mid - 2010, at the height of the financial crisis, alexandre lamfalussy, one of the architects of european monetary and financial integration, with whom i was fortunate enough to work with in the mid - 1990s and who passed away just a few days ago, ended one of his last public speeches as follows : all the actors – central banks, governments, international organisations and, naturally, market participants – are navigating in waters uncharted by reliable historical experience. the complexity of the current situation is

to highlight three : i ) those resulting from the far - reaching changes in the regulatory and supervisory framework ; ii ) those arising from the lower business profitability ; iii ) and lastly, those associated with restoring banking customer confidence in the wake of the reputational damage suffered during the crisis. i ) regulation the first main challenge facing banks is the need to adapt to the new european regulatory and supervisory framework. as i have said, spanish banks have successfully adapted to the new capital requirements, comfortably meeting the new limits established in the prudential regulations deriving from basel iii which have now been incorporated into spanish law and are to be gradually phased in. in addition, bearing in mind the present composition of spanish banks ’ balance sheets, no major adverse impact is to be expected from the upcoming introduction into european legislation of the new limits on liquidity and leverage. it is true, however, that certain requirements could become somewhat more demanding, as a consequence of the harmonisation of the different national applications of the european legislation being undertaken by the ssm and which could affect, among other things, the implementation schedules for the basel accord. in any event, even assuming immediate and comprehensive application of basel iii, the capital ratios of spain ’ s significant institutions would generally remain at relatively comfortable levels, although they would decline by more than the average for the institutions supervised by the ssm. it should also be noted that the work on the harmonisation of solvency ratios is not confined to the calculation of regulatory capital, but also includes measuring the total risks assumed ( the so - called risk - weighted assets ) on which the capital requirements are based. in this respect, spanish banks are somewhat better prepared than other euro area peers for an increase in supervisory demands. thus, according to the figures recently published by the banco de espana, 2 spain ’ s banks are among the group of institutions that apply the strictest criteria – owing to the lesser use of internal models and their higher conservative nature – to measure the risk - weighted assets used to calculate the solvency ratios. a key development that could play a significant part in shaping banks ’ balance sheet management policies is the forthcoming introduction of the minimum requirements for lossabsorbing capacity in the event of resolution of banks. these requirements, which are being analysed at a global level by the financial stability board and, at the european level, by the see the financial stability report, may 2015. bis central bankers ’ speeches european banking authority, aim to make it possible to handle the