bank offers. also regulated was bank product advertising, the information to be included on noticeboards, the customer ombudsman and the functioning of claims services, which had already been introduced in may 1987. 1 / 6 bis central bankers'speeches following their introduction, transparency regulations have evolved over time, in line with changes in society and the growing level of demands made of the banking sector. a good example of this was law 2 / 2011 on sustainable economy, which marked a milestone on the road towards advanced regulation of conduct. for example, this legislation includes for the first time so - called “ responsible lending ” and modernises claims services. several european directives addressing this field have also been approved. banco de espana circular 5 / 2012, which replaced circular 8 / 1990, includes all these features. i honestly believe that the current rules accurately regulate transparency obligations regarding bank products and services both in the pre - contractual stage and over the life of the operation. evidently, in parallel with these regulatory developments, there have been most significant changes in society, public opinion and jurisprudence, especially in the past decade. our supervisory framework has also evolved. now, in addition to focusing on formal compliance with conduct obligations, it also envisages the management and mitigation of these risks by banks and their incorporation into the business model. i shall briefly refer to these aspects today. but i will also broach the need to enhance customers ’ financial knowledge. in my view, this is a key element of which little mention is usually made. the cost of litigiousness clearly, the changes in customer safeguard regulations and in jurisprudence mean that what was appropriate in the past has ceased to be so today. undoubtedly, banks have acted questionably ; but to be completely fair, we should acknowledge that the legal playing field on which banks operate has changed significantly. traditionally, transparency rules have focused on ensuring that customers receive all due information and that, at least formally, they declare to have understood it and accept the conditions to be applied to them. however, the financial crisis has given rise to more demanding legislation. regulations now require that banks not only inform but that they act more honestly, impartially, transparently and professionally than before, bearing in mind the greater status, rights, interests and needs of their customers. this phenomenon, extensively aired in the media in recent years, is apparent also in the figures on claims lodged with the banco de espana. most claims have concerned mortgage loan contracts. they span both those

is part of the minimum capital pillar 1, and is directly reflected in the solvency ratio. elsewhere, reputational aspects, which are very important for the banking sector, are also evaluated as part of pillar 2. both pillars of the capital framework repeatedly mention the concept of “ risk ”. a quick search of the text of the european solvency regulation will bear this out : the word risk appears no fewer than 1, 500 times. however, there are clear differences between so - called financial risks ( such as credit and market risk ) and non - financial risks, which by their nature are more difficult for credit institutions and supervisors to address. non - financial risk is directly related to malpractice or non - compliance proper to conduct risk ; but going beyond this conference ’ s theme, it also refers to it events, reputation, governance and cyber security. unlike credit or market risks, non - financial risk is unconnected to specific financial decisions, is much more difficult to quantify than traditional risks and can only be reduced or mitigated. despite all these difficulties, or perhaps precisely because of them, non - financial risk has been firmly on regulators ’ and supervisors ’ radar screen since at least 2004. this followed the approval of basel ii which, as i indicated earlier, included a capital requirement for operational risk. today, the measurement and management of these risks remains equally complicated, but their importance for banking business has in fact increased. evidence of this is the map of risks and vulnerabilities annually published by the single supervisory mechanism ( ssm ). viewing the snapshot for 2021, we can see how a large portion of the sector ’ s weaknesses are related to non - financial risk. this is not really anything new. in previous exercises the ssm has also included these components. and logically so. allow me a few examples : ( i ) reporting systems and technological platforms have become essential, and as any banker can confirm, they have become a key component of any viable business model ; ( ii ) the prevention of money laundering has taken on a most significant dimension in europe, following various scandals and cases of fraud. indeed, an overhaul of the attendant regulatory and supervisory framework is on the table ; ( iii ) finally, given what has been discussed in this conference, i need not convince you that the nature of the retail banking business calls for great care as regards conduct towards customers. on this last point, there have been many scandals in recent years. in fact, calculating all