an ad hoc statistical survey initiated last summer of all less significant banks will enable us to intervene further with requests for additional information, including through on - site inspections, and we will send warning letters should it emerge that banks are underestimating these risks. we therefore now have a situation that does not seem to require any new generalized government measures. two years on from the start of the pandemic, banks can assess for themselves the possibility of restructuring their loans to firms that are able to overcome temporary difficulties, by analysing individual exposures and taking on the related risk. although the banking system as a whole is not in a bad condition, there are still some cases of fragility, mainly concerning small and medium - sized banks with a traditional business model. for many of these, low credit quality adds to the difficulty of curbing costs and responding to the challenges of technological innovation. last year, as i announced at this very meeting, we conducted a survey on a broad sample of the banks under our supervision, asking them to provide a self - assessment of the sustainability of their business models. the responses returned a diverse picture. most banks have balanced financial conditions, together with a sufficiently clear and informed view of the trends, risks and opportunities of the current market situation. for a non - negligible number of them, there were some uncertainties at strategic level and some weaknesses around their ability to generate adequate income flows, sometimes associated with low capitalization. in our experience, the corrective action requested by the bank of italy is all the more effective the faster the banks react. for some of the less proactive banks with managerial shortcomings, the weaknesses could result in a crisis in the absence of suitable corrective measures ; therefore, they were asked to make a rapid assessment of possible options to prevent deterioration and to return to the path of full sustainability. these issues will remain central to discussions with the bank of italy in the months to come and more incisive interventions could be made if there are any uncertainties and delays in taking the necessary corrective action. the european commission is currently revising the bank recovery and resolution directive ( brrd ). in the public consultation, together with the ministry of economy and finance, we underlined the importance of a greater harmonization of the national insolvency rules for non - systemically important banks in order to avoid disorderly liquidations that might provoke an unjustified loss of value and contagion risks. taking inspiration from

of digital distribution channels. the number of intermediaries managing the whole life cycle of a product entirely at a distance – marketing, acquiring new customers, providing services – is on the increase. business models that envisage collaboration between different kinds of financial intermediaries or between intermediaries and non - financial corporations are spreading ; there is a marked rise in the use of ‘ platforms ’ that give techno - financial conglomerates the chance to offer customers access to a growing variety of services, such as the outsourcing of corporate functions, including key ones. the asset management industry is dominated by open - end funds ( with more than €1, 200 billion of assets under management ), especially by investment funds incorporated abroad, which represent almost 80 per cent of the total undertakings for collective investments in transferable securities ( ucits ) located in italy. of these funds, known as ‘ roundtrip ’ funds, nearly two fifths are owned by italian groups that have transferred most of their managed assets to other eu countries, mainly for industrial, regulatory or tax reasons ( especially to ireland and luxembourg ). closed - end alternative funds mainly reserved to professional investors – credit, private equity and venture capital funds – have increased strongly, though with a still modest amount of assets under management. the greater recourse to technological innovations may bring significant benefits to operators, intermediaries and, looking ahead, to firms and households as well. intermediaries in particular will be able to exploit the advantages linked to digitalization in order to reduce their costs and improve the quality of the services they provide. using digital solutions makes it possible to broaden the range of products and better define their features according to customer needs, to improve creditworthiness assessment, and to promote inclusion, guaranteeing easy access to financial services at low cost for those who make little or no use of the traditional system. alongside the opportunities provided, the digital transition also poses considerable challenges for intermediaries and the regulatory and supervisory authorities. the former have to increase investment in order to limit financial, operational and reputational risks. the latter, which continue to coordinate closely within the forums for international cooperation, are engaged in updating the regulatory framework and the monitoring tools designed to balance the need to promote innovation with preserving the overall stability of the system and protecting savings. digitalization has increased exposure to cyber attacks, fraud and the misuse of personal data. italian banks reported 14 serious incidents in 2021, up from 4 in 2018. the damage was