, which mixes public and private investment towards the real economy ; and ( iii ) the banking union, which addresses persistent financial fragmentation. these initiatives, however, lack the unified governance of a financing union, which would help circumvent bureaucratic barriers and foster synergies. in addition, progress towards a financing union is still needed in four key areas : first, providing incentives for cross - border investments – mainly in equity – through accounting, taxes and insolvency laws. strengthening the free movement of capital within the eu requires overcoming a wide range of legal obstacles. we should improve the 2 / 5 bis central bankers'speeches predictability of insolvency frameworks, eliminate tax - related biases that penalise equity and harmonise the accounting rules for small businesses ; second, developing pan - european savings products more oriented towards long - term investment. this could be done through a variety of savings vehicles : the creation of european venture capital funds, new market initiatives for green bonds, securitised portfolios that are diversified across member states, and so on and so forth ; third, completing the banking union ; fourth, controlling financial activities and risks that are of vital importance for the euro area, such as supersystemic ccps. improvements in these four areas are needed so as to reach significant gains for digitalisation, sme ’ s scaling - up or energy transition. in each of these fields we have significant investment needs. as part of the financing union, completing the banking union allow me now to dwell for a moment on the third area of progress, which is also my third concentric circle : completing the banking union. the banking union is a major step forward for the euro area and is now operational, based on the single rulebook and – already – two pillars : the single supervisory mechanism ( ssm ) since end - 2014 ; and the single resolution mechanism ( srm ) since the beginning of 2016. those two pillars will have to be complemented by a third pillar : deposit insurance, where we could find practical and reasonable compromises. but there are two additional challenges that are less often mentioned : consistency, and consolidations. the first challenge in order to complete the banking union is to achieve better consistency between regulation, supervision and resolution, at three levels : first, in the concrete mechanisms : finalising and simplifying the resolution pillar should be a priority. the case of the italian banks has illustrated just how complex it is to combine the resolution regime laid

of the ssm too, daniele nouy, insisted on this point last week. we still lag far behind the american market in this respect : the market share in the united states of the top five banks is more than 40 % whereas the market share in the euro area of the top five banks is less than 20 %. sound and safe cross - border consolidations would make banks better able to diversify their risks across the euro area, and channel savings more effectively towards investments across borders ; this would foster the financing union i talked about. from a supervisory point of view, it involves supporting an approach on a consolidated basis by granting more waivers on liquidity and capital so as to allow more flexible capital allocation and limit ring - fencing. swift execution of cross - border transactions is also essential : the implementation of a fast - track process by the ssm would address this issue. from a resolution point of view, internal mrel requirements could be a tool to facilitate the resolution of institutions, but they would become meaningless if calculated on a national basis. indeed, having internal mrel in all countries could be an obstacle to the single market and european banking crossborder mergers. finally, we should address business and legal impediments to cross - border mergers : information asymmetry, non - performing loans ( npl ) or anti - takeover legal structures in different countries. as a first concrete step, i suggest that the european banking authority publish a comprehensive stock - taking of all the regulatory and supervisory obstacles to cross - border activities and mergers. the aim is crystal clear : within a monetary and banking union, a crossborder merger must not be more difficult and cumbersome than a “ domestic ” merger. the logic of the banking union is that it should be considered for banking purposes as a unique jurisdiction. before i conclude, i would like to add a few words on financial regulation. no one, i hope, can seriously dispute that after the financial crisis it was necessary to significantly strengthen regulation to reduce risks. is there any need to recall the disastrous consequences that this crisis inflicted on the real economy, the social dramas, and the democratic fragmentation with the rise of populism? financial stability is a common good that needs to be guaranteed. remarkable achievements have been carried out since 2009 under the impetus of the g20 and the financial stability board. for banks in particular, the majority of the basel iii work – let ’ s say 80 % – has already been done in 2010 –