##rutinising seriously the wisdom of increased top - down prefunding requirements for ccp resolution. it is doubtful that such requirements would be effective or proportionate, given the very low probability of ccp resolution and the marked differences between ccps ’ risk profiles. what is more, increasing funding requirements could discourage the use of ccps and instead push counterparties towards riskier and more opaque bilateral clearing. and while i would not 1 / 4 bis central bankers'speeches exclude cases where additional financial resources should be available for both recovery and resolution, ring - fencing resources for resolution only may distort the incentives of all stakeholders to support a successful recovery. that said, the resolution authority should have flexibility to determine the optimal choice of available tools, as well as the best point in time for entry into resolution, as long as the “ no creditor worse off ” principle is respected. it is helpful to assess how further guidance could support authorities in assessing potential resolution funding needs for individual ccps, taking into account, for example, the specific risk characteristics of the products they clear, the types of market they serve and the concentration in ccp memberships. i fully support work currently under way in the fsb in this respect. today, i would like to focus on three key areas where more work is needed. first, more international cooperation is needed. authorities responsible for several major cross - border ccps have not yet embarked on resolution planning and no cross - border crisis management arrangements are yet in place. 5 this could be because of barriers to sharing confidential information, including different approaches as to what is considered confidential and what timely. if that is true, then these barriers need to be removed. likewise, authorities may be reticent to engage with others while legislative frameworks are still evolving. assessing the cross - border implications of a ccp resolution takes time and discussions should get under way as soon as possible. cpmi and iosco are conducting some work in this respect. second, authorities need to better understand how a ccp resolution might look like. ccp resolution scenarios cannot be defined in absolute, quantitative terms given the nature of market events causing resolution. there will always be considerable uncertainty around ccp resolution and related funding needs. nevertheless, further steps should be taken to improve the analytical foundation of ccp resolution planning and to better prepare authorities. while the fsb is addressing this issue in its report, i see two steps in particular. first, cpmi and iosco have recently published

class traded in well - functioning, liquid markets. prior to the loan - level initiative, however, there was insufficient transparency in order to assess the risk profile of the abs. third, there was a coordination problem among abs market participants in 2012. although many acknowledged the need for enhanced transparency in the abs market, there was no market infrastructure that could have been supplied by individual actors. a bundling of efforts was needed and a catalyst role of the ecb was called for in an exceptional situation where market participants did not provide the market infrastructure. such a situation is exceptional, but not unprecedented, as we see if for example in the field of benchmarks or market agreements. so these are the three main reasons why the ecb prioritised abs transparency. let me add, however, that the ecb does not believe that abs should warrant special treatment where it is not justified from a theoretical, empirical and practical perspective. the ecb is interested in abs 1 / 3 bis central bankers'speeches insofar as they can help us achieve our policy objectives in compliance with our legal obligations, while ensuring risk equivalence in our collateral framework. having said that, the ecb will also – in the not too distant future – have to review the specific role of abs in the context of the broader issue of qe beyond 2017. as regards its achievements, the loan - level initiative set an example of swift and convincing action to show that european abs were, broadly - speaking, less risky than feared. and this was done in spite of the many technical difficulties of establishing common templates covering eur 1 trillion of assets from many different jurisdictions and asset classes. a set of common templates were established which are easily accessible to market participants. today loan level data is widely used by market participants and we can be confident that the initiative improved the transparency on abs. yet, it is no secret that the revival of the european abs market is, broadly speaking, still anaemic at the moment. market - placed issuance is at historic lows. the investor base has not recovered. the eu abs markets are impacted by bank deleveraging, unfavourable regulatory treatment and relative costs of funding of alternative instruments. admittedly, the sizeable eurosystem covered bond purchase programme and long term loan operations have also represented viable funding alternatives for banks. thus, the extended timeframe in creating legal certainty through forthcoming regulation on securitisation, the “ sts regulation ” has been regrettable. the ec