. 39. see european systemic risk board ( 2023 ). 40. see financial stability board ( 2023b ). 41. see european systemic risk board ( 2023 ). 42. see https : / / www. ft. com / join / licence / efeefef3 - 0ec1 - 4aa4 - 8bf0 - 0938f8f18097 / details? ft - contentuuid = 126d8b02 - f06a - 4fd9 - a57b - 9f4ceab3de71, accessed 13 april 2023. 43. see allen ( 2022b ). 44. see organisation for economic co - operation and development ( 2010 ). 45. see https : / / www. bis. org / about / bisih / about. htm, accessed 03 april 2023. 46. see financial stability board ( 2020 ). these recommendations are currently under revision. 47. see financial stability board ( 2022 ). 48. some requirements are stricter than for stablecoins under the european legislation ( mica ). for example, at present, no stablecoin issued on a permissionless blockchain may be classified as a group 1 asset. 49. mica also foresees that issuers of e - money tokens, stablecoins referenced to one single currency, should be required to be issued either by a credit institution, as defined in the capital requirements regulation, or by an e - money institution authorised under the revised electronic money directive ( “ emd2 ” ). 50. see european systemic risk board ( 2023 ). 51. minto, prinz and wulff ( 2021 ) discuss regulatory arbitrage in financial markets. 52. various surveys suggest that the vast majority of consumers do not own crypto - assets. an ecb survey conducted in belgium, germany, spain, france, italy and the netherlands in november 2021 revealed that 10 % of households owned crypto - assets ( european central bank 2022 ). a survey conducted in germany found that 4 % of the population held crypto - assets at the end of the year 2021. see zahlungsverhalten in deutschland 2021 ( bundesbank. de ). an ecb survey covering the entire euro area also found that 4 % of the population owned crypto - assets at the end of the year 2022. see study on the payment

german banks fell from 19 % to 8 %. liquidity provision through central banks increased. [ 15 ] more recently, the volume in the german interbank market has increased, but it remains far below the values observed prior to 2008 ( chart 3 ). chart 3 : interbank exposures have declined following the global financial crisis. while the interbank market is a channel for direct contagion in the financial system, common exposures to the same shock can lead to indirect contagion effects. this risk is particularly acute at the current juncture. higher interest rates and higher risk to the growth outlook expose vulnerabilities in the financial system that have built up over time. maturity transformation exposes banks to interest rate risk. adverse shocks to the real economy can increase credit risk for many banks quite broadly. 1. 3 complexity a highly complex entity can be systemically important. complexity can have different dimensions, such as the volume of derivatives business, a large number of ( international ) affiliates, or operational complexity. the more complex a bank is, the greater the costs and time needed to resolve it. [ 16 ] a cross - border resolution of such an entity requires coordination among authorities in multiple jurisdictions. [ 17 ] a vivid example of the resolution of a complex entity is the lehman brothers insolvency : it took 14 years after the bank ’ s failure to resolve it. 1. 4 substitutability very specialised providers of financial services can be systemically important, even if they are small or not highly complex. providers of infrastructure such as the payment systems services are one example. if such an institution experiences distress or even fails, other services can be disrupted as well and liquidity may dry up. the more specialised the institution, the more costly it is to replace its services. 1. 5 leverage time and again, leverage in the financial system has been a trigger of financial crises. high leverage makes borrowers vulnerable to adverse shocks such as a rise in interest rates or losses in income. this increases credit risk and leads to losses for financial institutions. poorly capitalised – highly “ leveraged ” – financial institutions respond by cutting the provision of financial services and credit, which has negative repercussions for the real economy. therefore, the reform agenda of the past decade has focused on reducing leverage in the financial system. banks are indeed better capitalised than they used to be – while leverage in the private and public sector has continued to increase. 2 are crypto - assets