’ s important to analyse in advance whether the intended measures can achieve their goal. 2. 3 new challenges at the same time, the consumer credit market is undergoing accelerated changes that may lead to new challenges for regulation. one of these changes relates to mobile applications and the proliferation of market channels. indeed, one of the main problems concerns the cost of credit obtainable at very short notice, especially via mobile applications. it ’ s speedy but expensive, because the estimated default risk is higher. these very short - term loans for modest amounts, so called “ payday loans ” or “ flash credit ”, are often negotiated on loan platforms on a peer - to - peer basis, by - passing national legislation. companies operating in this segment don ’ t always assess the consumers ’ borrowing capacity correctly, nor do they include any comparable rates in their offers. some countries, like the netherlands, have introduced regulations on this type of lending, but that causes these activities to move to other member states or onto the internet. such practices show the need for coordination between countries and regulation at european level. on the other hand, in order to maintain sound access to the credit market, we also have to consider some consumer characteristics. over - indebtedness often goes hand in hand with underdeveloped financial literacy. in that regard, the most vulnerable groups are poorly educated consumers, young people, the unemployed, the elderly and migrants. research in the united states and germany also shows that lenders offer products on far less favourable terms to consumers with a lower level of financial literacy. therefore, programmes offering financial education right from primary school, or providing training for the elderly or for migrants, should be encouraged. and of course, these observations also justify the importance of appropriate regulation. so, without any doubt, regulation can have an impact on access to finance for certain categories of consumers. any change in the regulations should therefore pay attention to the need for finance and the potential credit constraints, but also to the risk of over - indebtedness. and as the market is open to lenders that are not subject to national regulation, this also highlights the need for uniform legislation throughout the european union. mortgage loans if you allow me, i would also like to say a few words about mortgage loans. at the end of last year, household debt in belgium stood at 63 % of belgian gross domestic product, one of its highest levels in recent decades. overall, it has been increasing since 2002 and for the past six

regime to reduce the losses to the broader financial system and economy upon the failure of a sifi. the goal has been to compel sifis to internalize the costs their failure would impose on society and to offset any implicit subsidy that such firms may enjoy due to market perceptions that they are too - big - to - fail. the effort to reduce the likelihood of sifi failure has worked through several channels. the basel committee in 2011 agreed on a framework of graduated common equity risk - based capital surcharges for systemic firms, and we are working toward proposing rules to implement this surcharge framework in the united states. consistent with the dodd - frank wall street reform and consumer protection act, the federal reserve proposed a broad set of enhanced prudential standards for large u. s. bank holding companies in december 2011. the federal reserve also now performs rigorous annual supervisory stress tests and capital bis central bankers ’ speeches plan reviews of the largest banking firms to ensure that these firms can continue to operate and lend through times of severe economic and financial stress. in addition, in december the federal reserve proposed enhanced prudential standards for foreign banks under the dodd - frank act. the proposal generally would require foreign banks with a large u. s. presence to organize their u. s. subsidiaries under a single intermediate holding company that would be subject to the same capital and liquidity requirements as u. s. bank holding companies. the proposal is designed to increase the resiliency and resolvability of the u. s. operations of foreign banks, help protect u. s. and global financial stability, and promote competitive equity for all large banking firms operating in the united states. in addition to reducing the probability of sifi failure, global regulators also have striven to reduce the potential damage to the financial system and the economy if a failure of a major financial firm were to occur. the financial stability board ( fsb ) has proposed new standards for statutory resolution frameworks, firm - specific resolution planning, and cross - border cooperation. in the united states, dodd - frank created an orderly liquidation authority and required all large bank holding companies to develop resolution plans. other countries that are home to large global banking firms are working along similar lines. strengthening resilience of financial markets reducing the likelihood of a severe financial crisis also requires strengthening the capacity of our financial markets and infrastructure to absorb shocks. toward that end, u. s. and global regulators have worked to improve the transparency and stability of