, many of the remaining firms are in a weakened financial condition, and may need balance sheet as well as organisational restructuring in order to survive and prosper. recent research 1 at the central bank has confirmed that stressed balance sheets are clear early warning signs of subsequent loan default. but the research also indicates that some well - run firms can ride these problems out, notably if they are being run by an experienced owner that has been with the firm through other ups and downs. many balance sheets are stressed because of unwise property investments made on the side of a viable non - property business. restructuring these balance sheets without losing the true value of the resources, human, technological and physical, that are now engaged in each firm ’ s core business, is a key challenge for corporate restructuring in ireland today. overall, this is a challenge that will absorb the efforts of banks, law firms, and – that most elusive of professions, well - represented here today – workout specialists. cf. fergal mccann and tara mcindoe - calder. “ determinants of sme loan default : the importance of borrower - level heterogeneity, ” central bank of ireland research technical paper 6rt12, september 2012. bis central bankers ’ speeches the modern economy is driven by firms : they generate the bulk of employment, and the output that supports the wages and salaries, as well as feeding directly and indirectly into the tax revenue needed to support the social and economic infrastructure that underpins all of economic activity. healthy firms are a prerequisite for a growing economy that creates jobs. too many of even the surviving irish firms have not yet recovered from the crash and need restructuring. corporate failures in the last big downturn in ireland restructuring of distressed companies is not a new phenomenon in ireland or anywhere else. reflecting on ireland ’ s experience with corporate financial distress over the years, many resonant names come to mind. companies fail in good times as well as bad times, but it is the downturns that see the vast bulk of corporate restructuring business. the last big downturn in ireland was in the 1980s. and i well remember some of the big names that got into trouble in those days and were either helped or not helped by the government of the day. take irish shipping, for example, which got caught up in over - ambitious expansion and over - indebtedness as it built a large fleet of leased vessels well beyond that company ’ s traditional goal, which aimed at controlling sufficient

routing flexibility for merchants and debit card pricing in several ways. as discussed in more detail below, the statute provides for a minimum number of networks per debit card and establishes the ability of merchants to direct the routing of debit card transactions over those networks. the statute also contains provisions, not subject to implementing rules by the board, that protect the merchant ’ s ability to provide pricing incentives for customers to use different forms of payment. 2 in addition, the statute provides overall limitations on interchange fees through standards to be set by the board. input to the rulemaking. as input to the development of our proposed rule, board staff held numerous meetings with card issuers, networks, merchants, consumer advocates, and others to deepen our understanding of the debit card industry. these discussions provided information about the structure and mechanics of the debit card system, fraud losses and fraud - mitigation activities, and fees and costs associated with debit card transactions. staff also reviewed written submissions by interested parties that highlighted issues to be considered in implementing the statute. 3 to obtain further input, last fall the board surveyed debit card issuers that would be subject to the interchange fee standards, payment card networks, and large merchant acquirers. we requested information about the volume, costs, fees, fraud - prevention activities, and fraud losses associated with different types of debit card transactions. we also asked about the statute prohibits payment card networks from inhibiting merchants from providing a discount or other incentive for any particular form of payment, as long as any discount for card use is clearly disclosed and does not differentiate on the basis of issuer or payment card network. the meeting summaries and written submissions are posted on the board's public website at http : / / www. federalreserve. gov / newsevents / reform _ interchange. htm. bis central bankers ’ speeches network exclusivity arrangements and routing restrictions. the information gathered through these surveys informed our development of the proposed rule. based on this information, we published a proposed rule for public comment in december. the comment period closes next tuesday, february 22. we will carefully review all the comments we receive before we adopt a final rule. let me turn now to the substance of our proposed rule. i will summarize each major statutory requirement, and then describe how the proposed rule implements it, including alternative approaches we considered. prohibition on network exclusivity and routing restrictions. the statute requires the board to prescribe