of macroprudential policy beyond the banking sector. at least over the medium term, the covid - 19 pandemic is likely to accelerate trends that call for extending the reach of macroprudential policy to a larger set of financial institutions and financial transactions. as a case in point, digitalisation provides opportunities for new players, and non - banks may take a larger role in financial intermediation. to protect financial stability, macroprudential policy should be adjusted to also cover the systemic risks created by non - bank finance. over time, digitalisation may also boost cross - border banking and the provision of cross - border financial services, thus increasing the contagion channels of systemic risks between financial systems. this increases the importance of cross - border cooperation between macroprudential authorities, which should be systemically enhanced. related to digitalisation, let me recall that a number of central banks, including the ecb, are actively examining avenues to develop and adopt a central bank digital currency, or cbdc for short. on specific areas of concern, both residential and commercial real estate markets have often been a significant source of systemic risks and vulnerabilities. the pandemic is likely to have lasting but very diverse effects on real estate markets. therefore, a comprehensive analysis of the macroprudential risks on real estate markets and appropriate tools for addressing them would be most needed. in addition to state - of - the - art analytical methods and policy tools, macroprudential policy needs a strong institutional framework to operate effectively. in its early recommendation1 the european systemic risk board proposed clear mandates for macroprudential decision - makers, cooperation between relevant authorities, as well as a leading role for the central bank in macroprudential policy – irrespective of the specific institutional structure. importantly, as already noted by the imf some years ago2, the framework should be able to counter inaction biases that could arise because of lobbying or political pressures. the framework should ensure access to sufficient information and promote effective cooperation in risk analysis. survey results published recently by the czech national bank3provide interesting information on the views of academic and professional experts on macroprudential and monetary policy. according to the survey, sharing of data and knowledge and the capacity to act swiftly are key benefits of a framework in which the central bank conducts both monetary and macroprudential policy. however, further research on the institutional arrangements of macroprudential policy would

it, the amount of equity that a host regulator requires to be held in a subsidiary over and above the basel minimum may vary according to whether it is part of an “ spe group ” in which the parent / holding company is a source of strength through resolution. where that is the case, it may be possible to shade the subsidiary ’ s capital structure from equity to subordinated debt issued to the holdco. where the group as a whole is not a source of strength in resolution, a subsidiary may need more equity than otherwise. what i am describing would entail some recasting of the key pillars of international supervisory cooperation : the basel concordat, core principles of supervision, and capital accord. 3 there is no such thing as a “ bailin bond ”. bailin is a resolution tool. all creditors can face having to absorb losses. what matters is the creditor hierarchy notwithstanding the clarity in the financial stability board ’ s international standard on resolution, 4 and in the us and draft eu legislative regimes, it is still common for commentators and industry participants to refer to “ bailin bonds ”. 5 as i have said before, “ bailin ” is a verb not a noun. it is a power, not a special kind of bond. like other resolution tools, it can be applied to any kind of debt obligation. what is true is that if bonds are issued from a holding company and the resolution is topdown ( spe ), then those bonds will absorb losses before any creditors of the operating see financial stability board ( 2013 ), “ recovery and resolution planning for systemically important financial institutions : guidance on developing effective resolution strategies ” and tucker ( 2013 ), “ resolution and the future of finance ”. see tucker ( 2013 ), “ the reform of international banking : some remaining challenges ”. see financial stability board ( 2011 ), “ key attributes of effective resolution regimes for financial institutions ”. most recently in chapter 3, “ changes in bank funding patterns and financial stability risks ”, of the imf ’ s october gfsr, which misleadingly refers throughout to “ bail - in debt ”. bis central bankers ’ speeches subsidiaries ; holdco creditors are structurally subordinated to opco creditors. but if the losses are vast enough, then the haircuts imposed by the resolution authority can in principle permeate to any level of the creditor stack. in the case of insured deposits, that means deposit guarantee schemes ( dgs ) suffering losses, as they