solvency 2 review must include a full and frank assessment of the framework that has now been in place for three years. of course, insurers have significantly improved their risk and capital management under solvency 2, and the insurance market is now more resilient and better equipped to cope with financial crises. but these positives must not be allowed to overshadow the questions that need to be asked after such a radical change, particularly about the impact on equity investment and the financing of the european economy, along with issues relating to volatility and complexity. the very fact that we ’ re calling it a “ review ” for 2020 means that, by definition, maintaining the status quo cannot be an option. as the preparatory work gets underway, i would like to see every topic, even the most awkward, raised and dealt with. i urge insurers to play an active role in the consultations and i can assure you that the acpr will make its presence felt in the coming discussions. in this regard, we are naturally supporting efforts by the french treasury and insurers to improve the prudential treatment of long - term equity investments already during the 2018 review. on a topical note, i would add that it is crucial for supervisors to apply all prudential requirements with equal rigour. the string of failures by insurers doing business on the french market under the fps, particularly in construction insurance, is a reminder of the importance of this. the acpr is obviously working hard to deal with this crisis, which is affecting tens of thousands of french policyholders. but the requisite convergence of supervisory practices also needs to become a reality very soon. i know that gabriel bernardino and eiopa are making this a priority. finally, let me be clear : it is unreasonable to apply the new ifrs17 accounting framework right now, given the current state of the discussions. aside from the complexities of creating a european governance framework for these standards, there is also an obvious issue of timing, and fortunately, the iasb appears to be reopening discussions on this. implementing ifrs17, which will be costly and complex, will follow on from implementation of solvency 2, a process that has kept insurers very busy. beyond the question of timetabling, there are major substantive issues. we want an agreement on identifying groups of loss - making contracts. as it stands, the draft is unworkable. we also want to see completion of

##t cannot yet be fully compared with national credit transfers. for instance, it is not always possible to make payments with a scheduled execution date and / or periodic payments. the online banking applications for the sct – if it is available at all – are sometimes more complex than those for national credit transfers. often, the sct is offered in the same way as other cross - border instruments for payments to countries outside europe, although it should be considered a domestic payment instrument. based on data collected by the eurosystem, half a year after the launch of the sct, sct transactions account for only about 1. 4 % of total credit transfers in the euro area. the use of scts seems to be mainly restricted to cross - border transactions. although corporates which, together with public administrations may bring a critical mass of payments to the sepa environment, claim that they can see the benefits of sepa, they are still taking a cautious source : european payment profit pool analysis, mckinsey & company, 2005. approach towards its actual implementation. one of the major difficulties cited relates to obtaining iban and bic information. in this respect, i am happy to observe that in italy the iban became the single, exclusive standard used to identify current accounts in the execution of domestic payments as of january 2008. i expect that the provision of good quality services for deriving iban from national account numbers and reliable directory services will also help to overcome this obstacle in other countries. do you sdd? although some sepa direct debit pilot projects have been launched by banks, infrastructures and it providers, it cannot be denied that the sdd is having some engine trouble. i have recently discussed the three main problems faced by the sdd, namely the migration of mandates, the uncertainty of users and the multilateral interchange fee for direct debits. it is claimed that it is a heavy burden to have to sign new mandates when switching from the national direct debit schemes to the sepa direct debit schemes. nevertheless, some countries have already found a solution to ensure the continued legal validity of existing direct debit mandates, while others are still looking for an answer. the european commission and the european payments council are gathering information on this issue, and i would welcome more transparency in this regard. owing to different national business practices, many opinions were voiced, in particular about the sdd, even before the product was visible : “ it is not safe enough ” ; “ it is