these appropriately anonymised data available to the research community is an opportunity to enhance our knowledge. and it also adds a further control mechanism for the authorities, which reinforces the quality of public debate and of democracy. the data laboratory recently launched by the banco de espana ( belab ) is a good example of this service to society, since it places the microdata of many of our main databases at the disposal of researchers. another example is the recent agreement between the national statistics institute, the tax revenue service, the social security and the banco de espana, as holders of a significant amount of administrative information and of granular data collected for statistical purposes, for the joint design of a collaborative data system to which researchers will have access, provided that the information to be used is for scientific purposes in the public interest. the purpose of this agreement is also to promote the future inclusion of other institutions that hold administrative records or other granular databases of research interest. it is our obligation as the participating authorities to put this agreement swiftly into practice, and to establish what might be an unprecedented landmark in information availability for economic research and evaluation purposes in spain. the need to improve the economic and financial education of the population quality data, technical ability, and analytical rigour and independence would thus seem to be the necessary ingredients for setting in place an assessment culture leading to the evidence - based formulation of public policies. in my view, this recipe will be like one for bread without yeast. a third key ingredient is needed : an appropriate economic and financial education for the public at large. with citizens able to critically internalise in their individual economic and financial decisions both the fundamental results of these independent evaluations and the various benefits and costs associated with different courses of action, it would be easier to set an assessment culture in place. under this scenario, economic policymakers would not only observe the long - term benefit for general prosperity that credibly committing to evidence - based policies can provide ; they would also appreciate the potential short - term political return of incorporating the results of these evaluations into their decision - making. yet as i have previously stated, spain ’ s starting position is not a good one. once again, resorting to an example close to home to illustrate the point, it is telling that over 40 % of the spanish population does not properly understand the meaning of inflation. 4 we are aware what this means about citizens ’ actual capacity to understand and assess the performance of institutions – such as the european central bank and

auditors ( irba ) recently issued a new rule on mandatory audit firm rotation, which limits audit firm appointments to a maximum period of 10 years. the efforts by irba to improve independence are to be welcomed. the sarb has been proactive with regard to auditor independence, for example section 61 of the banks act provides that the registrar of banks must approve the appointment of an auditor before such an auditor can take up office. such an appointment further requires that the audit committee do a proper assessment of the suitability of the auditor to hold office, after which the office of the registrar of banks would also do a fit and proper assessment prior to the approval of the auditor ’ s appointment. the sarb, from a supervisory perspective has furthermore, for many years now, required large banks to appoint joint auditors as this further reduces the independence - related risk. the sarb therefore, while broadly supportive of the principle of mandatory audit firm rotation, believes that banks should be exempted from these requirements as our supervisory standards and practices as it relate to auditor independence far exceed those that have recently been put in place. we further believe that the maximum period of appointment should be increased from the proposed 10 years to a longer period of between 15 and 20 years, as individual audit partner rotation is already in effect. the challenges around skills shortages are furthermore a reality that may act as an obstacle to achieving this objective of rotating audit firms after 10 years. if mandatory audit firm rotation is retained in the current form, the sarb may be compelled to revisit the requirement of joint auditor appointments for large financial institutions due to some of these practical considerations. although the removal of the requirement of joint auditors for large financial institutions will lead to reduced audit fees and other efficiencies, we believe that this is likely to weaken auditor independence and may detract from the current high levels of audit quality and thus possibly erode the effective oversight and supervision of banks. this would not be in the public interest. we page 6 of 9 further remain unconvinced that mandatory audit firm rotation represents an effective policy intervention to address the stated secondary objectives of redressing the high levels of market concentration and to promote transformation within the auditing profession. as a regulator, the sarb as a rule does not comment on individual firms. we, however, took the extraordinary step to comment publicly on the developments surrounding kpmg last week as they are the auditors to three of the big four banks, as well as