board. our goal was to produce clear and comprehensive rules to protect consumers from unfair practices while maintaining the viability of a market for responsible mortgage lending. the rules would apply stricter regulations to higher - priced mortgage loans, which we have defined broadly so as to cover substantially all of the subprime market. 5 the regulations would be enforceable by state and federal supervisory and enforcement agencies as well as by consumers themselves, who could recover statutory damages for violations above and beyond actual damages. the proposed rules cover a range of practices. first, the rules would prohibit a lender from engaging in a pattern or practice of making higher - priced loans that the borrower cannot reasonably be expected to repay from income or from assets other than the house. of course, appropriate attention to the borrower's ability to repay is a fundamental feature of good underwriting. under the proposal, a " higher - priced mortgage loan " would have an annual percentage rate that exceeds the yield on comparable treasury securities by 3 percentage points or more for first - lien loans or 5 percentage points or more for subordinate - lien loans. second, we found that the prevalence of " stated - income " lending led to many borrowers receiving mortgages that they could not afford. consequently, we would require lenders to verify the income or assets they rely on to make credit decisions for higher - priced loans - standard industry practice, in fact, for most lending until quite recently. third, our proposal would require higher - priced loans to have an escrow account for realestate taxes and hazard insurance. this rule would help ensure that borrowers can afford their payments and avoid the cases in which borrowers, especially first - time borrowers, did not understand that the monthly principal and interest payment was not the only financial obligation associated with homeownership. escrowing has become standard practice in the prime market, and our proposal would make it standard practice for this part of the market, as well. fourth, the proposed rules would ban prepayment penalties in situations in which the borrower may be especially vulnerable. for example, prepayment penalties would be prohibited where the borrower's debt - to - income ratio exceeds 50 percent and, when permitted, would be required to expire at least sixty days before a scheduled increase in the loan payment. the rule would also ban prepayment penalties that could enable a " loan flipping " scheme, in which a lender or its affiliate refinances the

mainly on domestic markets right now. however, we should not disregard the potential that cbdcs may have for enhancing cross - border payments. they could be used to process instant payments and should also help to extend their reach. in many countries, one of the reasons for pursuing cbdcs is to increase financial inclusion. furthermore, cross - border payments made in central bank money may contribute to lower risk. however, increased involvement of central banks entails its own risk : the risk of crowding out private competitors. cbdcs should therefore be designed around the principle of " do no harm ". they should also continue to rely on services provided by the private sector to the greatest possible extent, including for a significant portion of the cross - border chain. 3 / 4 bis - central bankers'speeches even if interlinked cbdcs were to become a reality, central banks would still have to rely on private actors for certain tasks. one example is currency exchange, since this is typically a market - based business, including managing and dealing with the inherent exchange rate risk. project icebreaker, an experiment conducted by the bank of israel, the bank of norway and the bank of sweden in cooperation with the bis innovation hub in the nordics, has shown that banks still have a place in a world of interlinked cbdcs. and, just like interlinked faster payment systems, a solution based on interlinked cbdcs would still rely on private actors to provide attractive front - end solutions. 5 closing remarks all of this shows that, in order to enhance cross - border payments, we need cooperation, not only between banks and central banks, but also with other players as well. regulators will have to coordinate efforts to harmonise regulation. central banks will have to be active in two different roles. as operators of payment systems, we may have to adjust our systems and communicate with the market on how best to expand their services. as leaders, we will have to continue to support and coordinate the actions resulting from the roadmap. ultimately, all stakeholders will have to come together to find solutions that are beneficial for all parties and work together to improve the global payments landscape. which brings me back to nelson mandela : with close collaboration on a global scale, which might be hard to imagine today, this may become a reality in the future. 1 financial stability board, g20 roadmap for enhancing cross - border payments, october 2021. 2 committee on payments and market infrastructures