called for, in particular for reducing national options and discretions in eu directives. indeed, the inconsistent implementation as well as the “ gold plating ” of eu rules at the national level give rise to significant compliance costs for financial institutions operating across borders. second, we need to strengthen the basis and decision powers of the “ level 3 ” committees of supervisory authorities pursuing supervisory convergence and cooperation third, further improvements in the arrangements for the supervision of cross - border financial groups should be achieved. all authorities need to be adequately informed to effectively perform the ongoing supervision of cross - border institutions as well as to be fully prepared to address potential cross - border situations of financial distress. given the increased scope and intensity of the cross - border activities of eu banking groups, the need for effective information - sharing and cooperation in their supervision is now more important than ever. in this respect, the eurosystem underscores in particular the importance of strengthening information sharing also between supervisory authorities and central banks without supervisory responsibilities with respect to the major eu banking groups. next, i am turning to our role as catalyst for market activities fostering financial integration. the example i choose here is the single euro payments area, in short sepa initiative, led by the european payments council, which has started officially last month. it is a market - led initiative aiming at removing technical, legal and commercial barriers against smooth cashless cross - border payments in euro. the objective is to make cashless paying with euro as easy, efficient and safe as it is today within one country. this has genuine benefits for consumers, firms and public administrations having to conduct cross - border payments. the launch included both the roll - outs of the sepa credit transfer system and the sepa cards framework. the sepa direct debit system will follow before the end of 2009. the ecb has supported the european payments council in a variety of ways. for example, the ecb regularly organised meetings with stakeholders such as end - users, infrastructures providers and card schemes. we have also published a study of sepa ’ s potential economic impact, which highlighted, among other things, the room for cost reductions for banks. 6 the ecb is also very active in enhancing knowledge about financial integration. our research network on “ capital markets and financial integration in europe ” with the center for financial studies at the university of frankfurt and whose second symposium you are currently attending is one good example. a major task of the ecb in this area is also the “ report

in this way encourage more of this type of lending. the data also suggest that these types of transactions have not been a significant factor in the current crisis. specifically, less than 2 percent of the higher - priced and cra - credit - eligible mortgage originations sold by independent mortgage companies were purchased by cra - covered institutions. i now want to turn to the second question concerning how cra - related subprime lending performed relative to other types of lending. to address this issue, we looked at data on subprime and alt - a mortgage delinquencies in lower - income neighborhoods and compared them with those in middle - and higher - income neighborhoods to see how cra - related loans performed. 7 an overall comparison revealed that the rates for all subprime and alt - a loans delinquent 90 days or more is high regardless of neighborhood income. 8 this result casts loan origination data are from information reported pursuant to the home mortgage disclosure act ( hmda ). the hmda data do not identify subprime loans directly, in part because there is not a single definition of which loans fall into this category. rather, the hmda data indicate which loans are categorized as higher priced, including subprime loans and some alt - a loans. the analysis of data includes first - lien conventional loans for home purchase or refinance related to site - built homes. it excludes business - related loans to the extent they could be identified. for more information on hmda data and higher - priced lending, see robert b. avery, kenneth p. brevoort, and glenn b. canner ( 2007 ), " the 2006 hmda data, " federal reserve bulletin, vol. 93. about 17 percent of the higher - priced loan originations were made by cra - covered lenders or their affiliates to lower - income populations in areas outside the banking institutions'local communities. such lending is not the focus of the cra and is frequently not considered in cra performance evaluations. data are from first american loan performance ( lp ). for the analysis, zip code delinquency data were classified by relative income in two different ways. first, the data were classified using information published by the u. s. census bureau on income at the zip code tabulation area ( zcta ) level of geography. because the zcta data provide an income estimate for each zip code, delinquency rates can be calculated directly from the