trading behavior of banking entities. indeed, that is what congress intended in enacting these provisions. congress has itself made the judgment that this prohibition will enhance financial stability and is socially desirable. the task of the agencies is to implement congressional intentions, as manifest in the statute itself, as efficiently and effectively as possible. the approach taken in the proposed rulemaking is concededly not a simple one. but, at least to date, it has seemed the most feasible. two alternative approaches have been suggested, and we considered each prior to issuing the proposed regulation. one considerably simpler approach would be to articulate high - level principles for differentiating prohibited and permitted activities and then leave it to the firms to self - report violations based on internal models or other devices, presumably with compliance and systems monitoring by regulatory agencies. while having the virtue of simplicity at the outset, this approach would provide little bis central bankers ’ speeches clarity about whether an activity is permitted or prohibited. it seems quite likely that, either formally or informally, the regulatory agencies would regularly be asked to offer guidance or approve specific practices. otherwise, this approach would essentially rely on self - policing by banking entities. a second alternative would be to establish definitive bright lines for determining whether an activity is permitted or prohibited. this approach would be very difficult in practice, at least with current information and data, because of the many asset classes, business models, and transaction types covered by the statutory provisions. hard - and - fast rules would also run the risk of being either too restrictive, and thus inadvertently classifying legitimate, customerdriven market - making or hedging activity as prohibited, or too narrow, and thus failing adequately to capture the full range of activities that are prohibited under the statute. the more nuanced framework contained in our proposal was designed to realize some of the advantages of both of these approaches while minimizing their potential adverse effects. the dodd - frank act provides a long conformance period for firms that are subject to the volcker rule. the agencies have proposed to use that conformance period to study the effects of the statutory prohibitions on the activities of banking entities before the volcker rule is fully implemented. to assist in this undertaking, the agencies have proposed to begin collecting and reviewing trading data that should help firms subject to the statutory provisions, as well as the agencies in our efforts, to monitor and understand the contours of the activities that are prohibited, permitted, and affected by the statutory provisions that make up the vol

of the smooth functioning of payment systems. however, the involvement of central banks in retail payment systems is, in general, less pronounced than in large - value payment systems, mainly because retail payment systems entail significantly lower systemic risks. nevertheless, the eurosystem is concerned with efficiency issues related to cross - border retail payments. at present, the performance of cross - border retail payment systems is clearly lagging behind the policy objectives of economic and monetary union and, indeed, the expectations of many european citizens and small enterprises. after the introduction of the euro banknotes and coins on 1 january 2002, these differences in service levels for national and cross - border payments within the single currency area will become even more apparent. against this background, the ecb strongly advocates the creation of a single payment area in order to fully reap the benefits of the single currency. in order to give a clear signal to the banking industry and the public, the ecb published a number of objectives in september which it expects the industry to fulfil and which should contribute towards substantial improvements. the current inadequacies are linked, in part, to the still predominant recourse to correspondent banking and the lack of adequate interbank infrastructures. more efficient funds transfer arrangements have been set up in recent years, but they are too fragmented and economies of scale are very limited. one pre - condition, therefore, for achieving a substantial enhancement in the processing of cross - border retail payments is undoubtedly the fact that the banking industry must implement common technical features in the processing of funds between banks. however, this is unlikely to be sufficient. the banking industry must also improve substantially its internal procedures for processing cross - border payments, as well as its communication with the customer. this, in turn, requires a more extensive use of automation and standardisation. in this respect, i should like to draw attention to the standards agreed within the framework of the european committee for banking standards, which i consider to be of particular importance. the ecb is organising meetings with all parties involved in order to bring the implementation of the standards forward. once the conditions related to interbank processing and internal procedures have been met, it should be possible for the banking industry to decrease substantially the price of cross - border credit transfers and to reduce the execution time to that needed for domestic payments plus one day. the ecb expects the banks in the euro area to achieve substantial improvements by 1 january 2002 at the latest. the ecb will act as a catalyst for