the act in itself is a step in the right direction since it heightens what the imf, in its last article iv consultation, 10 called the “ level of preparedness ”. the fact that legislative change is also still needed in germany before the key attributes and the eu directive can be fully and consistently implemented does not contradict my – in principle – positive assessment of the restructuring act. 3. 3 rigorous monitoring of the implementation of the new international standard experience over the past few years has shown that international standards can sometimes be futile if they are not implemented and applied in a consistent and timely manner. for this reason, the fsb wants to rigorously monitor the progress made in implementing the key attributes in its member states. what makes this all the more important is the fact that the key attributes take us into unchartered waters. moreover, implementation will require legislative and institutional changes – some of them extensive – in all g20 jurisdictions. last but not least, monitoring of consistent implementation is crucial for overcoming obstacles to cross - border cooperation which will play such an outstanding role. to facilitate the monitoring process, work is currently underway, as a matter of urgency, on an assessment methodology that will make it easier to objectively assess the level of implementation in individual countries. this instrument is to be used by various bodies : a ) countries will be able to perform a self - assessment in order to identify any gaps in implementation ; b ) the imf / the world bank will use this methodology when carrying out their fsap assessments ; c ) the fsb is already planning a first review for 2012 as part of its peer review process, and d ) the fsb peer review council, which has not yet been set up, will apply this instrument to global systemically important financial institutions. countries with a below - average performance in these assessments will be required to provide an explanation, and can expect the results to be published. i believe implementation must be monitored rigorously because the new standard closes a serious gap in the regulatory framework. 4. conclusion this gap illustrates perfectly that the regulatory framework before the financial crisis was not geared to the stability of the financial system as a whole. this failure to take sufficient account of the systemic stability perspective must and will be remedied. for this reason, let me draw your attention to the german government ’ s draft of the financial stability act, which the german cabinet passed yesterday. this act will assign central tasks of macroprudential oversight to the bundesbank

known to those who consider hiring them. the fsb is now considering whether to adopt such an approach more broadly. the uk ’ s fair and effective markets review ( femr ) recommended that the eu ’ s market abuse regulation should be extended to cover every major fixed income and currency market, that criminal sanctions be updated, and maximum prison terms extended. see : http : / / www. bankofengland. co. uk / markets / pages / fmreview. aspx the pra has introduced requirements for regulated firms to provide employment references to one another in a mandatory template when hiring senior managers. this includes information on an individual ’ s conduct record, and their fitness and propriety. all speeches are available online at www. bankofengland. co. uk / speeches this is all constructive but insufficient. that ’ s why we have emphasised measures to ensure firms and their employees take responsibility – individually and collectively – for their own conduct. these range from securing compliance with minimum standards to a common and dynamic understanding of good practice that is widely understood and collectively enforced. uk authorities have used their convening powers to encourage market participants to establish standards of market practice that are well understood, widely followed and, crucially, that keep pace with market developments. this is what the banking standards board is doing by promoting higher standards of conduct and competence across the uk banking system. it ’ s why the global ficc market standards board ( fmsb ) is establishing readily understood standards for their markets. and it ’ s why the fx committees will launch in may the first globally consistent code of conduct for fx markets. but codes are of little use if nobody reads, follows, or enforces them. this is where the uk ’ s senior managers regime comes in. senior managers regime the smr addresses the common refrain of senior management that they weren ’ t aware that misconduct was taking place in their firms. the smr sets a series of requirements for the most senior decision - makers of banks, building societies and major investment firms. the smr re - establishes the link between seniority and accountability. senior managers are now held accountable if they fail to take reasonable steps ( including training or proper oversight ) to prevent or stop regulatory breaches in their areas of responsibility. and the smr prescribes responsibilities – typically to the chair and ceo respectively – for developing and embedding a firm ’ s culture. under the related certification regime, firms must also annually assess and certi