to small country issues, albeit secondary to large country and large bank issues, at the basel committee. there are clearly routes through which a well - prepared small country can inject its views into the basel processes, often via regional consultation formats. the second commendation, and it is difficult to overstate its value, is the basel committee ’ s and fsi ’ s more recent and explicit adoption of proportionality as an accepted and important part of the framework. this allows small countries to adopt the basel rules texts in ways that are fully compliant with the texts, but very much simpler and cheaper to supervise and comply with. to take a topical example, the bahamas is currently consulting on a basel iii implementation that will require perhaps 10 per cent of the complexity of the full basel rules text. much of this simplification revolves around avoiding model - based approaches, but even the new standardised approaches give a great deal more freedom for small countries to adopt simpler but robust rules. please continue with proportionality, and encourage the imf to support this approach as they conduct fsap reviews. the matter i would ask you to reconsider is the increasingly fragile assertion that the basel committee is only making rules for large, internationally active banks. that may be the basel position, but it is not the imf position when it comes to fsaps. this applies to the basel core principles and the capital and liquidity frameworks. i certainly don ’ t suggest that you move away from making rules for internationally active banks, but please try to remember, ideally not just around the margins, that a great many non - member countries will strive to adopt the basel rules, both for international and domestic banks. 3. 2 assistance with rules adoption the second question is, does the basel committee and fsi assist small countries in adopting new and almost always more challenging international rules? your record on this is particularly good, in our experience. that ’ s the whole point of the fsi. we are also grateful that the basel committee, relative to some other international rule - making bodies, allows considerable time for consultation and for implementation of new rules. this conference is an obvious example of part of the extensive assistance given to non - member countries, as is the biennial icbs event. so please keep up the good work. 3. 3 opportunities to engage third, what about governance and use of staff? the bcbs and fsi secretariats and working groups naturally feature staff from member countries, but it is also the

, and deposits handily fund loans. so why would we do total loss absorption capacity ( tlac )? and what sort of resolution plan is possible when recapitalization from markets is most unlikely? we can ’ t afford to close a dsib, and we have no capital markets providers to take the failure risk. this is far from unusual in small countries — so why are we putting a lot of time into internal capital adequacy assessment processes ( icaaps ), recovery plans, resolution plans, and the like? because that is the international expectation. it would be better to develop a supersimplified but pragmatic approach that minimizes but does not eliminate the potential for public sector bailouts of dsibs. conclusion to sum up : the bahamian experience, and from what we have seen of other small country experience with the basel committee, has generally been positive. we are also deeply grateful for the work of the fsi, which is an extraordinarily helpful group. the same applies to the technical assistance on offer directly from basel committee member agencies and their associated national assistance bodies, plus the international multilateral development bodies. there are a few areas where we would like to see more consideration given to small country issues, but the bottom line is that the bcbs works for us, even though we aren ’ t a member and are unlikely ever to become a member. we are not yet in a position to say that about all international rule - making bodies, but that is a conversation for another day. i will conclude by thanking you personally and your agencies for your good work, and for the assistance and consideration you have shown the bahamas and other small nations over the years, and the assistance and consideration to come in the future.