##licability may also vary with changes in the market. the bottom line for today ’ s banking institutions, particularly the largest and most complex ones, is that they must continue to monitor very carefully the embedded risks of their products and services, pay close attention to subtle changes in business practices that could affect the risks related to a given product, and fully understand how the risks in all their business lines intersect and combine to affect the risk profile of the consolidated entity. current perspective on risk - management challenges commercial real estate now that i have described in fairly broad terms the types of risk - management challenges institutions may encounter, i think it would be helpful to provide some concrete examples. as you are likely aware, the u. s. banking agencies recently issued for public comment supervisory guidance on commercial real estate ( cre ), which focused particularly on cre concentrations. regardless of its size, we believe an institution involved in cre lending would benefit from a review of the guidance. as you know, cre played a central role in the banking problems of the late 1980s and early 1990s and has historically been a highly volatile asset class. over the past dozen years, cre concentrations have been rising and are now at record levels at many banking organizations. for certain groups of banks - such as those between $ 1 billion and $ 10 billion - - average cre concentrations, which can include owner - occupied cre, are today above 300 percent. this compares to a previous peak of cre concentrations of 200 percent seen in the late 1980s and early 1990s. the agencies ’ cre concentration guidance, which excludes owner - occupied cre, is intended to reinforce existing risk - management guidelines on cre, and it offers institutions some suggestions for improving their risk - management practices. the agencies share a concern that some institutions ’ riskmanagement practices are not keeping up with the growth in their cre exposures. the guidance describes the key risk - management elements for an institution ’ s cre lending, because banks, in order to attract new business and sustain loan volume, may be inclined to occasionally make some compromises and concessions to borrowers. as supervisors, we want to ensure that loan - to - value standards and debt - service - coverage ratios are meeting the organization ’ s policies - - and that there is not an increasing number of exceptions to those standards and ratios. we also continue to monitor whether lenders routinely adjust covenants, lengthen maturities, or reduce collateral requirements. additionally, the guidance re

services. at the same time, a developed payment system ensures the protection of the integrity of the financial system and the euro currency, the reduction of negative effects from the phenomenon of money counterfeiting, consumer protection and the advancement of market practices, reduction of the effects of money laundering activities and terrorism financing, increased access to financial services and financial inclusion. in line with the stabilization - association agreement and the berlin process, the reform process and the advancement of the payment system through the development of local instant payments and the integration of the payment system at the regional level will also accelerate access to the single euro payment area of the european union known as sepa. this is tasked with effectively bringing domestic and cross - border payments within the eu to the same level of cost, time efficiency and security as well as access to the eu's instant payment system known as tips which is part of of the eurosystem since 2018. this enables payment service providers to offer funds transfers to their customers in real time and around the clock, every day of the year, where individuals and businesses can transfer money between each other within seconds, regardless of their local bank's business hours. even the latest regulation for cash operations marks a very big advance in terms of alignment with the requirements and standards for membership in sepa, as well as tips. therefore, the cbk has started taking actions within the strategic plan 2024 - 2028 for the activities that are planned and related to the field of the payment system, which are as follows : advancing the legal and technical infrastructure of the cbk for membership in the sepa payments scheme and access to the eu instant payments system ( tips ) ; developing the technical infrastructure for enabling instant payments 24 / 7, creating the national qr code and the standardization of the api for the interconnection of systems ; reducing cash payments and promoting electronic payments ; while for two of the following activities we already have developments, such as : creating opportunities for access to the payment system of non - bank service providers, as well as enabling the possession of iban, to increase access to finance, within the " payment account " concept, where we have approved the regulation, 2 / 4 bis - central bankers'speeches also today, we are carrying out the foreseen activity : empowering the national payments council as an advisory body for joint actions regarding the digitization and standardization of payment systems and instruments ; the advancement of the payment system presents significant challenges both from the perspective of the cbk and