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, in bis central bankers ’ speeches which a wider group of creditors would effectively become equity holders, and who would share in the losses sustained by a failing entity. for this to work, there needs to be a market for the relevant securities that is genuinely independent of the deposit - taking sector – we can ’ t have banks hold one another ’ s bail - in debt. in a resolution, a host of operational complexities would also have to be sorted out. a resolution needs the support of foreign regulators if it is to be recognised across borders. it needs temporary stays on derivatives contracts so that counterparties don ’ t scramble for collateral at the onset of resolution. and it needs to be structured and governed well enough to withstand potential legal challenges and sustain market confidence. a proposal for “ total loss - absorbing capacity ”, or tlac, was announced at the g20 summit in brisbane last year. consultations and impact assessments are under way, and an international standard on loss - absorbing capacity will be agreed by the g20 summit in antalya later this year ; guidance on core policies to support cross - border recognition of resolution actions should be finalised shortly after. it is fair to say that in its main submission to the inquiry, the reserve bank counselled caution as far as “ bail - in ” and so on is concerned. we would still do so. the inquiry also favours a cautious approach. again, though, the world seems to be moving in this general direction. it isn ’ t really going to be credible or prudent for australia, with some large institutions that everyone can see are locally systemic, not to keep working on improvements to resolution arrangements. the third set of recommendations from the inquiry i want to touch on are those related to the payments system. the inquiry generally supported the steps the payments system board ( psb ) has taken since its creation after wallis, but raised a few areas where the board could consider consulting on possible further steps. as it happens, these dovetail well with issues that the psb has been considering for some time. the reserve bank has since announced a review of card payments regulation and released an issues paper in early march. among other things, it contemplates the potential for changes to the regulation of card surcharges and interchange fees. surcharging tends to be a “ hot button ” issue with consumers and generated a large number of ( largely identical ) submissions to the financial system inquiry. but virtually all of the