unsecured money markets, such as the eurodollar market, where nonbanks lend to banks. 5 this change in money market activity would clearly have been problematic if it had resulted in a loss of control over the policy rate, but there is no evidence that it has, as can be seen in figure 2. so, to evaluate the consequences of this change, we are led to ask ourselves questions such as : is the interbank market special? ulrich suggests reasons why we might think that it is, but the answer is not clear to me, and further research would be welcome. let me elaborate a bit on the differences between these two types of market activity and their implications for rate volatility and market discipline. in the pre - crisis system, a bank ’ s reserves position evolved, in part, due to payment requests made by its customers, which were somewhat random and thus hard to anticipate. so an important share of interbank market activity was motivated not by fundamentals, but rather the need to fulfill a requirement imposed by the central bank. i always found this type of trading a bit artificial, but perhaps this is just a matter of taste. a byproduct of the scarcity of reserves is that central banks had to lend a considerable amount of intraday credit to facilitate the settling of payments. in the u. s., the average of the daily peak level of daylight overdrafts provided by the federal reserve was roughly $ 140 billion in 2006. in the u. s., only depository institutions ( banks ) and a small number of other institutions, such as governmentsponsored enterprises, which include the federal home loan banks, can have an account with the federal reserve. depository institutions are subject to reserve requirements. in 2006, total balance requirements averaged approximately $ 15 billion, composed of required reserve balances ( the portion of reserve requirements not met with vault cash ) and contractual clearing balances. the amount of reserves held in excess of requirements was about $ 1. 7 billion on average. banks also used around $ 35 billion in vault cash to satisfy reserve requirements ; however, since vault cash cannot be used to clear fedwire payments, it has no intraday impact on federal funds trading activity. during the first half of 2016, less than 5 percent of fed funds transactions were interbank transactions, based on the fr2420 data, or about $ 3 billion per day on average. nonbank financial institutions, such as mutual funds

amando m tetangco, jr : protecting the consumers of financial services in the philippines keynote address by mr amando m tetangco, jr, governor of bangko sentral ng pilipinas ( the central bank of the philippines ), at the launch of the banking code for consumer protection, bank marketing association of the philippines general membership meeting, manila, 24 october 2012. * * * mr. allan tumbaga, president of the bank marketing association of the philippines ( bmap ) ; mr. patrick cheng, president of chamber of thrift banks ; mr. edward garcia, president of the rural bankers association of the philippines ; mr. cesar virtusio, executive director of the bankers association of the philippines ; officers and members of bmap ; mbm peter favila ; former bap president gigi montinola ; friends in the banking sector ; colleagues from the bsp ; ladies and gentlemen, good afternoon. it is my pleasure to join you in launching the new banking code for consumer protection. the bangko sentral commends bmap, as well as the rest of the industry associations for working together in updating the code. this is tangible proof of your responsiveness and commitment to provide the best service possible to your clients. it is also evidence of your recognition that the lifeblood of the banking system comes from client deposits and investments, and that their trust is something that banks must strive to preserve. this is why bankers, from top management down to the frontline staff, must exercise prudence and vigilance in ensuring that banking operations are optimally carried out. the preservation of public trust is likewise the underlying imperative for the bangko sentral ’ s policy and regulatory actions. this drives us to constantly emphasize that the business of banking requires serious effort to keep operations within the bounds of safety, soundness and professional management. this practice, in itself, is already equivalent to protecting the consumers of financial services. however, responsible banking is more than just business savvy and prudent risk management. responsible banking means a conscientious focus on clients by putting their best interest at heart. it means recognizing that they deserve the highest standards of service. client - centered banking entails embedding consumer protection in business operations. products and services must be designed, priced and delivered in ways that match client needs. adequate measures must be in place to ensure that the consumers are not unduly disadvantaged by business processes.