new provisions, designed in part through discussions with associations of banks, other intermediaries and consumers, to make the protections for correctness in dealings with customers more effective. with these new rules we intend to make the documents for customers clearer, more concise and comparable. the instruments governing the most common products, mortgage loans and current accounts, will be especially incisive. for some time now we have intensified our controls. as far as it is within our power, we have directed them to substantial and not merely formal compliance with the rules. in the last three years we have performed checks at 452 intermediaries and more than 2, 300 branches. where we have found specific violations of the rules on notifying the public of the conditions offered, we have initiated sanction procedures ( a total of 49, 11 of which have concluded with the levying of sanctions ). in 206 cases, though the grounds for formal sanction were lacking, we called upon the intermediary to comply more closely in substance with the rules ; we asked for the introduction of organizational arrangements and internal controls to guarantee better customer relations. where necessary, intermediaries were required to refund sums of money unduly collected from customers and report on this to the bank of italy. recently we have extended our controls to banks ’ websites, in order to make sure that on - line customers have protection equivalent to that enjoyed by those using the traditional branch network. bank customers often write to the bank of italy to report what they consider to be incorrect conduct. we receive nearly 6, 000 letters a year. in every single case we respond to the writer and ask the bank involved to explain its position, providing a clear answer and reporting it to us. where necessary, we take the appropriate supervisory measures. on mortgage loans, we have reminded intermediaries of the need to join in the interbank procedures for loan portability. recent rules changes now allow sanctions for noncompliance. on current accounts, we conduct an annual sample survey of banks ’ terms and conditions, whose results will be presented in our annual report. * * * the crisis has highlighted the need to correct some significant features of the international financial architecture. more robust capital requirements for banks together with measures to counter their pro - cyclical effects ; limits on excessive leverage for financial institutions ; the extension of prudential rules to segments of financial business that in some countries have largely escaped coverage ; strengthening the role of central banks in guaranteeing the macroeconomic

return of inflation tendencies in the economy, and the equilibrium level of the real interest rate in the future. here we encounter one of the most interesting topics of economic discussion these days : the secular stagnation hypothesis. it has got a lot of attention but has not convinced everybody. the issue is intensely debated by academics. many countries were hard hit by the global financial crisis. recovery has been slow and uneven although it has been taking place. productivity growth has been slowing down for many years, almost globally. for the future, we can think of two scenarios. in the first, the deceleration of growth would turn out to be temporary. in that case, the issues raised by the low interest rate environment and the lower bound problem would eventually become less topical. the equilibrium real interest rate would return to more customary levels, and any deflationary tendencies would recede. the average interest rate level would be normalized. i still inclined to think that scenario to be the likely one. see http : / / www. suerf. org / studies / 6359 / cash - on - trial. bis central bankers ’ speeches in the second scenario, we would face a permanent and significant slowdown of productivity growth. this would imply that the equilibrium interest rates could be very low for a very long time, perhaps occasionally negative. the central banks would be more likely to hit the lower bound for interest rates more often. that would be the case in which removing the lower bound for interest rates would be something to think about. this is clearly a complicated matter : • the experience with alternative monetary policy measures would have to be assessed : how well can we substitute other monetary policy instruments for interest rate policy if needed? • the realism of a world with occasionally negative nominal interest rates would have to be considered, not only in money markets, but in retail banking too. the customer resistance to negative nominal rates for their savings could be very stiff. bank profitability could be a serious issue. • finally, the pros and cons of a payment system without cash would have to be examined. what would be lost in terms of convenience, resilience and privacy if cash was discontinued? should it be replaced with something new? before a judgement could be passed regarding the future of cash, all these aspects would need to be carefully considered and balanced. * * * currently, the role of banknotes in payments is diminishing, and the role of credit and debit cards is growing. curiously, the