the measures are more binding. as i said, overall, we judge that the measures – as currently designed and calibrated – continue to meet their objectives. as a result, there will be no change in loan - to - income ( lti ) and loan - tovalue ( ltv ) limits or the allowances for 2020. we did look at a number of options for managing allowances. in some cases alternatives would have ended up with a less operationally flexible regime than is currently in place. in short, we have not found a way that is more flexible than the existing regime, while at the same time meeting the objectives of the measures. our macroprudential policies are broader than the mortgage measures. first, the countercyclical capital buffer ( ccyb ) aims to strengthen the resilience of the banking sector to a future downturn. today, we are announcing the latest quarterly review of the ccyb, with the rate remaining at 1 per cent. but, as i said earlier, the macro - financial outlook in ireland is subject to significant uncertainty and we remain ready to adjust the ccyb rate in either direction as appropriate. second, the other - systemically important institutions buffer ( o - sii buffer ). the objective of the o - sii buffer is to reduce the probability of failure of systemically important financial institutions, given the potentially greater impact of failure of those institutions on the domestic economy. today i can announce that we have also completed the annual review of the o - sii framework, 4 / 6 bis central bankers'speeches identifying six institutions as systemically important with buffer rates between 0. 5 and 1. 5 per cent. reflecting brexit - related relocation of eu activities to ireland, two institutions, barclays bank ireland plc and bank of america merrill lynch international dac have been designated as o - siis for the first time, both with a buffer rate of 0. 75 per cent. third, the systemic risk buffer. i started my remarks by outlining the substantial gains, to growth, jobs and the public finances from the openness of the irish economy. and that this also creates vulnerabilities to the global cycle and the potential for structural macroeconomic shocks. a resilient banking system requires sufficient capital buffers to absorb these structural shocks. in july, the minister for finance agreed to transpose the systemic risk buffer ( syrb ) into irish law and to designate its implementation and cal

likely that the focus on supervisory outcomes will be given even greater weight as a result – supervisory engagement is all to the good, but only so far as it leads to successful, transformative outcomes. observers may sometimes suggest that our calibration of prism overemphasizes the high impact firms at the expense of assigning fewer resources to low and medium low impact firms. probably that is not the majority view in the present audience, and i think it is clearly wrong during this period of post - crisis repair of the main firms. however, it is something which we are keeping under review. our engagement model will also evolve in tandem with european developments. the convergence of prudential supervisory practice and enforcement policy has long been talked about and stated as a worthy aim, while national supervisory authorities went about their ordinary business. only colleges of supervisors, for internationally active insurance and banking groups, gave a modicum of substance to this aim. but the time of actual common supervisory practice and enforcement, as set out by european authorities with the powers and the resources to ensure adherence, is about to come. for euro area banking supervision, the ssm is actively writing a supervisory manual which already runs to 700 pages, and it has commenced the recruitment of staff in frankfurt to implement the model in the banks it will supervise. much of the prism model approach and reasoning has been taken on board by the ssm ; it will have been one of the main precursors of the ssm approach – but it will be superseded like all national models by the single euro area supervisory approach in banking. bis central bankers ’ speeches in insurance, convergence will not be as strong nor come as fast. there is no institution that can play the role of the ecb, and solvency ii will come into force two years after crd 4. yet, in the coming years, eiopa will endeavour to work on increased convergence of supervisory practices. eiopa and its staff will step up its review of national approaches, and will likely develop a cohesive supervisory manual for insurance in europe. enforcement for supervision to be successful it must be underpinned by an appropriate recourse to enforcement. enforcement is a necessary component of any effective regulatory framework. where regulated entities fail to comply with their regulatory requirements, enforcement is an important tool to effect deterrence, achieve compliance and promote the behaviours and high standards that we expect. we aim, through our approach, to leave little doubt that where there is clear evidence of regulatory breach