such safeguards, which do have a bearing on the design of euro area integration, should not prevent euro area members from taking the decisions that are necessary for the smooth functioning of emu. to sum up, a lot has already been done over the past five years to draw the lessons of the financial and sovereign debt crisis. but this is not the end of the process. as most of you are lawyers, you know very well that once legislation has been enacted, implementation by the relevant authorities is equally important. at the european level, the agreed tools and procedures have to be fully enforced by the commission and the member states. this applies in particular in the field of economic governance. at the national level, member states have to adjust their domestic regulatory framework to the new european environment. enjoying the benefits of being part of the banking union should come together with the adequate responsibilities. in some cases, the timeline for implementation is ambitious and requires speedy and determined action by national authorities : for example, the main provisions of brrd need to be transposed until 31 december 2014. a number of member states, including smaller ones, have to close a number of outstanding gaps and loopholes. bis central bankers ’ speeches further legislative action is necessary to complete the single market for financial services let me now turn to the next five years and the legislative agenda for the eu. i see a number of areas where further progress is required in order to complete the single market for financial services. this would benefit all 28 member states : if i may use again the metaphor, solidifying the walls of the ground floor is in the interest of all co - owners. but it may be even more important for those involved in the construction of the additional floor, i. e. the euro area member states. two major legislative proposals which are highly symbolic for citizens as an eu response to the crisis are now on the table and need to be carefully analysed against their potential benefits and drawbacks. let me mention first the commission ’ s proposal on structural measures for banks. a few years after the start of the crisis, assessing the banking sector ’ s structure and reflecting on how to make banks safer is essential. a coherent approach would contribute to reducing the potential fragmentation caused by different national structural regulations. nevertheless, the devil is in the detail when implementing such reform, especially because the potential benefits are still untested. second, in a different domain, the ecb shares only some of the objectives that have motivated the proposal for a financial

each employee, the rules create significant administrative problems and may conflict with state privacy requirements that restrict access to information concerning an employee's salary. although the rules also allow a bank to pay referral fees in the form of " points " in a bonus program, the rules require that any points awarded must not only be nominal, but also must be the lowest amount awarded for any product or service covered by the bonus program. thus, for example, the points awarded for a securities referral could not exceed the amount of points awarded for a safe deposit referral, even if the points awarded for the securities referral were nominal in amount. failure to address all exceptions or adopt cure or leeway periods the interim final rules also fail to address the scope of a majority of the exceptions to the definitions of " broker " and " dealer " that were adopted in the glb act. given the fact that the board believes that many of the sec's interpretations of the scope of the exceptions it has chosen to address do not comport with the unambiguous words of the glb act and the legislative intent of the congress, we are concerned about the manner in which the sec will interpret the other exceptions. the board fears that if the sec does not adopt rules concerning the scope of all of the exceptions, it will aggressively interpret some of the exceptions through enforcement actions and no - action letters, without banks and other members of the public having the opportunity to comment on these interpretations. the interim final rules also fail to provide any cure or leeway periods to banks that are attempting in good faith to comply with the exceptions when they discover that some of their securities transactions do not comply with the exceptions due to inadvertent errors or unforeseen circumstances. given the complexity of the exceptions, it is expected that banks that are attempting to conform their securities activities to the exceptions will identify some securities transactions that do not meet the terms of the exceptions. in some circumstances, banks will not even be able to confirm that their securities transactions will comply with an exception at the time they are conducted. for example, banks will not be able to confirm that they meet the " chiefly compensated " standard in the trust and fiduciary exception until they review all of their compensation earned at the end of the year. for these reasons, the board believes that the sec must provide banks that have adopted policies reasonably designed to comply with the exceptions a reasonable period of time to cure any inadvertent or unforese