joachim wuermeling : exploring dora – the digital operational resilience act and its impact on banks and their supervisors speech by dr joachim wuermeling, member of the executive board of the deutsche bundesbank, at the european savings and retail banking group ( esbg ), virtual, 23 september 2021. * * * 1 introduction ladies and gentlemen, friends and colleagues, in 1974, reinhard mey, one of germany ’ s best - known singer - songwriters, released one of his biggest hits, “ uber den wolken ”, meaning “ above the clouds ”. in the song, the protagonist stands on an airfield watching a plane take off. he imagines that the sky beyond the clouds must be where freedom can be found. in the chorus he sings : “ above the clouds, freedom must be boundless. ” nowadays one could be tempted to change the words of the chorus to : “ inside the cloud, freedom is boundless. ” perhaps it is a little too sketchy to draw a parallel between the freedom above the clouds and the opportunities that come with cloud technologies. but still, let me focus on another parallel between reinhard mey ’ s song and cloud computing. for the protagonist in the song, the sky beyond the clouds seems boundless, probably without any rules. but in reality, of course, there are plenty of international rules for the clouds, for air traffic, and air traffic controllers use rules to keep the airspace organised and, above all, safe. without rules and oversight, air traffic would never be as safe and reliable as it is today, and it wouldn ’ t offer the freedom of travel we normally enjoy ( except when a virus comes along, of course … ). working in the cloud, having all your data available anytime, anyplace, seems boundless and offers many opportunities. but just like in air traffic, cloud providers and online traffic need rules and oversight in order to be stable and beneficial. the cloud is just one example of the potential, and also of the risks that come with the digitalisation in the financial sector. this is where dora comes into play. with dora – or, to give the act its full name, the digital operational resilience act –, the eu has begun to forge an oversight framework for banks ’ information and communications technologies ( ict ) risks and for critical ict third - party service providers. dora introduces stricter regulation of ict service providers, including cloud providers. so you could

andreas dombret : financial regulation as a global challenge introductory statement by dr andreas dombret, member of the executive board of the deutsche bundesbank, at a roundtable discussion organised by the canon institute for global studies and the ehess, tokyo, 15 july 2014. * * * ladies and gentlemen thank you for having me today ; it is a pleasure to be here. for me, one of the central lessons from the financial crisis is this : the financial system is global in scope, and it therefore requires global regulation. to push this idea further, i would define the term “ global ” in at least three dimensions and argue that regulation should be consistent in all of them. first, regulation needs to be consistent across borders and regions. where regulation varies from country to country, there is a danger of regulatory arbitrage – of banks moving their business to countries with the lightest - touch regulation. the problem with this behaviour is that the risks that are transferred could potentially affect the entire financial system. this is why the g20 have made the issue of financial market regulation a priority. in cooperation with the financial stability board and the basel committee on banking supervision, they are working to develop a consistent regulatory framework at the global level. even so, i ’ m concerned to see that some countries outside europe are adopting their own regulatory initiatives which breach the principle of cross - border consistency. i believe that the danger of banking regulation one day returning to the principle of “ every man for himself ” needs to be taken seriously. we must not let this happen. second, regulation not only needs to be consistent across borders and regions but also across different sectors. here, too, the central issue is the danger of regulatory arbitrage. one current example is the growth of the shadow banking industry, where financial enterprises conduct business which creates bank - like risks but is either regulated insufficiently or not at all. with banking regulation being tightened, banks have even more incentives to move their business to the shadow banking system. thus, the shadow banking industry may become a source of systemic risk. we therefore need to expand the regulatory framework in this area to ensure that it is consistent. third, regulation needs to be consistent across asset classes. take the regulatory treatment of government bonds as an example. unlike for all other forms of credit, banks do not have to hold capital against government bonds in line with the risks that they carry, and this inconsistency has dangerous side - effects. since the euro -