Monday 17 November 2008

What was not in the G20 Summit and why it matters: Natural resources, Technology, Democracy, Aging, Equity, etc

Below this text is the full G20 Summit Communiques. It is worth reading, not so much for what it says as for what it does not mention. Hopefully we will see a discussion why climate change, depletion of natural resources, an aging population, urbanization and poverty are totally, or almost totally, ignored in a situation when humanity has a unique opportunity not just to repair a broken financial system, but also change direction so that the current unsustainable development could turn into a sustainable.

It should be acknowledged that as a band-aid for a financial system that has been bleeding it does contain some good parts. Obvious and positive short-term measures to secure liquidity and short-term trust have been included, but no international initiative to explore new ways for the financial system to deliver on the most important areas of today has been indicated. That could still happen in April during the next meeting, but only if someone show leadership.

Some people have compared this meeting with Bretton Woods 1944, a meeting that created what today has evolved into the World Bank, IMF and WTO.

Two things are important to remember when people make parallels to Bretton Woods. First of all that the Bretton Wood meeting was prepared for more than two years and the meeting itself was going on for three weeks. This extended G21 meeting was prepared for three weeks and meant to send a signal to the markets that there is a willingness to react among the world leaders. It is quite obvious that not many thinkers have been involved in the preparations of this meeting, from an optimistic perspective this can be seen as an opportunity for future meetings (April 30 2009).

Second that the main architect, Keynes had a vision that reached beyond a few economic institutions. Would the leaders of today come together in the same spirit they would look at the challenges of today and not just try to create a Bretton Woods II. It might be worth remembering the words of Keynes in a situation when as many suffer from obesity and male nutrition, when we are destroying our planet in the hunt for natural resources without a serious discussion about the overconsumption in the OECD.
“The day is not far off when the economic problem will take the back seat where it belongs, and that the arena of the heart and head will be occupied . . . by our real problems - the problems of life and of human relations, of creation and behaviour and religion.”
Keynes, J.M., foreword to Essays in Persuasion, 1931

The potential to start doing something more important exist in a few places, such as acknowledging that governments around the world have allowed the financial markets to grow out of control:
“increasingly complex and opaque financial products”
Hopefully this could result in a discussion about how future financial products should be developed and monitored.

A little gem is also (congratulation to the person who managed to get it in):
“Credit Ratings Agencies that provide public ratings should be registered“
This could open up an interesting discussion about what is required to be registered and what criteria that are helping sustainability that what criteria that are pushing countries and companies in an unsustainable direction. The rating agencies are one of the parts of the financial system that few have scrutinized from a sustainability perspective.

What will probably be the most important legacy of the meeting is the important role “emerging economies” have been given. Not only were they mentioned seven times in the final text, as the front page of Hindustan Times declared on a front page headline “Power shift to new economies” their role are now seen as very important.

There are a few other parts that might be used to continue some important discussions, but compared to what’s needed there is a gulf. As we look at things that are missing there are some disturbing facts:

Market/markets: 39 vs. Democracy: 0
This is like reliving the MAI (Multilateral Agreement on Investment) discussion again. The end of MAI was thought to be the end of simple free trade arguments and economic dogma without any other concerns. One of the main arguments was that the MAI was created without any concerns of democracy and only focused on securing the right of the market (large corporations). 10 years after the death of MAI the panic response of the world’s leaders are dangerously close to the same narrative. It is important that the urgent actions are not based on principles that will undermine the long-term work for sustainable development.

Poverty: 3
Let us turn to one of the few positive things in the text. Poverty is mentioned three times. A closer look reveals however that two of these times poverty is used as an excuse for business as usual… Hopefully the poor and emerging markets, together with honest OECD countries will not accept this is the future.

Technology: 0
A very strange omission is the lack of reference to technology. It was the emergence of IT and new technology that generated discussions about frictionless economy, and that information technology would help create transparency in the system (an argument used by Greenspan among others). The fact that technology both needed to solve challenges like climate change and also is needed to create a more transparent and accountable system, but still is not discussed is telling. One main reason for this is probably that many of the policy makers don’t understand today’s technology, neither the new smart solutions that are available to solve the climate crisis or the options that could help create a smarter financial system, using open source is only one part of it. With many engineers in the top and science knowledge China and India could play an important part.

Aging/Demographic: 0
The fact that much of the stress in the current financial system is due to the fact that the aging population in OECD creates a challenge for the way the pension funds act. Instead of taking long-term concerns they are under increased pressure to deliver high returns in the short run. This is a trend that is growing and no one knows how to solve this. The fact that it is not even mentioned by the G20 is more than strange, even more so when the largest owner on the stock markets around the world is pension funds.

Equity: 0
While it is good that poverty is mentioned three times it would have been good to have a discussion about equity and how the current financial system is helping those in most need of resources. Trickle-down theories have been shown to be wrong and a financial system that not only create more inequity but also fail to even consider the poor in most of its instruments and initiatives have demonstrated that a new framework is needed. Instruments like micro finance can’t be seen as the solutions as they can only provide some support.

Consumption: 0
The urge for more, more than we can pay for, but also more than the planet can sustain was a main driver that pushed the system over the edge. Still the mantra among most “experts” is that consumption must increase, without any discussions about what direction this consumption should have. Voices have also been heard that emerging markets, and especially China, must increase its domestic consumption. Not seldom is China seen as a possible rescue for non sustainable industries such as the automotive industry.

Natural Resources: 0
The fact that natural resources is not mentioned is maybe not surprising, but still worrying. It is well known that the current economic development is destroying the planet, and that the trend is accelerating. Only two years ago one of the last major voices admitted that what scientists and NGOs have said since the 70’s is true.
“The world does not have the resources for another 5 billion people or so to behave the way that Americans do today. It may not be about to run out of energy and commodities, but higher prices will certainly force big changes in lifestyles. The era of cheap raw materials is over.”
The Economist, A survey of the world economy, September 16 2006
The price of natural resources is of less importance as this can be affected by many factors, still these prices create challenges in themselves. Without significant resources and a financial system that are coordinated to deliver a resource efficient development by creating a new infrastructure we will find ourselves in a situation where low prices don’t create any pressure to change, and where high prices result in some new investments but where most is directed to exploration of resources that fit within the current infrastructure and distribution system. The investments in Coal to Liquid, CCS and tar sand are examples of this. While not necessarily destructive on a case by case basis they are proof of the difficulty to change the current economic system into a sustainable system that can allow people to be lifted out of poverty and people in the OECD to continue to enjoy a high quality of life.

Climate Change: 1
What might be the greatest challenge of our time and a challenge that requires significant changes in the financial system, Climate Change, is only mentioned once. A special meeting to discuss what opportunities, but also challenges, the current financial crisis present for solutions to climate change could be one way of ensuring that the policy makers don’t “forget” climate change. This is especially important as many have used the financial crisis as an argument for investments in green technology. This is positive, but coordinated action to ensure effective measures is important. If this don’t happen there is a significant risk that policy makers will use the financial crisis to provide domestic jobs and impose protectionistic measures that would make long-term measures more difficult even if they could deliver some short-term benefits.


Below is the full text:
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G20 Summit Communiques
Sunday, 16 November 2008
1. We, the Leaders of the Group of Twenty, held an initial meeting in Washington on November 15, 2008, amid serious challenges to the world economy and financial markets. We are determined to enhance our cooperation and work together to restore global growth and achieve needed reforms in the world's financial systems.

2. Over the past months our countries have taken urgent and exceptional measures to support the global economy and stabilize financial markets. These efforts must continue. At the same time, we must lay the foundation for reform to help to ensure that a global crisis, such as this one, does not happen again. Our work will be guided by a shared belief that market principles, open trade and investment regimes, and effectively regulated financial markets foster the dynamism, innovation, and entrepreneurship that are essential for economic growth, employment, and poverty reduction. Root Causes of the Current Crisis

3. During a period of strong global growth, growing capital flows, and prolonged stability earlier this decade, market participants sought higher yields without an adequate appreciation of the risks and failed to exercise proper due diligence. At the same time, weak underwriting standards, unsound risk management practices, increasingly complex and opaque financial products, and consequent excessive leverage combined to create vulnerabilities in the system. Policy-makers, regulators and supervisors, in some advanced countries, did not adequately appreciate and address the risks building up in financial markets, keep pace with financial innovation, or take into account the systemic ramifications of domestic regulatory actions.

4. Major underlying factors to the current situation were, among others, inconsistent and insufficiently coordinated macroeconomic policies, inadequate structural reforms, which led to unsustainable global macroeconomic outcomes. These developments, together, contributed to excesses and ultimately resulted in severe market disruption.
Actions Taken and to Be Taken:

5. We have taken strong and significant actions to date to stimulate our economies, provide liquidity, strengthen the capital of financial institutions, protect savings and deposits, address regulatory deficiencies, unfreeze credit markets, and are working to ensure that international financial institutions (IFIs) can provide critical support for the global economy.

6. But more needs to be done to stabilize financial markets and support economic growth. Economic momentum is slowing substantially in major economies and the global outlook has weakened. Many emerging market economies, which helped sustain the world economy this decade, are still experiencing good growth but increasingly are being adversely impacted by the worldwide slowdown.

7. Against this background of deteriorating economic conditions worldwide, we agreed that a broader policy response is needed, based on closer macroeconomic cooperation, to restore growth, avoid negative spillovers and support emerging market economies and developing countries.
As immediate steps to achieve these objectives, as well as to address longer-term challenges, we will:
Continue our vigorous efforts and take whatever further actions are necessary to stabilize the financial system.
Recognize the importance of monetary policy support, as deemed appropriate to domestic conditions.
Use fiscal measures to stimulate domestic demand to rapid effect, as appropriate, while maintaining a policy framework conducive to fiscal sustainability.
Help emerging and developing economies gain access to finance in current difficult financial conditions, including through liquidity facilities and program support. We stress the International Monetary Fund's (IMF) important role in crisis response, welcome its new short-term liquidity facility, and urge the ongoing review of its instruments and facilities to ensure flexibility.
Encourage the World Bank and other multilateral development banks (MDBs) to use their full capacity in support of their development agenda, and we welcome the recent introduction of new facilities by the World Bank in the areas of infrastructure and trade finance.
Ensure that the IMF, World Bank and other MDBs have sufficient resources to continue playing their role in overcoming the crisis.

Common Principles for Reform of Financial Markets:
8. In addition to the actions taken above, we will implement reforms that will strengthen financial markets and regulatory regimes so as to avoid future crises. Regulation is first and foremost the responsibility of national regulators who constitute the first line of defense against market instability.
However, our financial markets are global in scope, therefore, intensified international cooperation among regulators and strengthening of international standards, where necessary, and their consistent implementation is necessary to protect against adverse cross-border, regional and global developments affecting international financial stability.
Regulators must ensure that their actions support market discipline, avoid potentially adverse impacts on other countries, including regulatory arbitrage, and support competition, dynamism and innovation in the marketplace.
Financial institutions must also bear their responsibility for the turmoil and should do their part to overcome it including by recognizing losses, improving disclosure and strengthening their governance and risk management practices.

9. We commit to implementing policies consistent with the following common principles for reform.
Strengthening Transparency and Accountability: We will strengthen financial market transparency, including by enhancing required disclosure on complex financial products and ensuring complete and accurate disclosure by firms of their financial conditions. Incentives should be aligned to avoid excessive risk-taking.
Enhancing Sound Regulation: We pledge to strengthen our regulatory regimes, prudential oversight, and risk management, and ensure that all financial markets, products and participants are regulated or subject to oversight, as appropriate to their circumstances.
We will exercise strong oversight over credit rating agencies, consistent with the agreed and strengthened international code of conduct.
We will also make regulatory regimes more effective over the economic cycle, while ensuring that regulation is efficient, does not stifle innovation, and encourages expanded trade in financial products and services.
We commit to transparent assessments of our national regulatory systems.
Promoting Integrity in Financial Markets: We commit to protect the integrity of the world's financial markets by bolstering investor and consumer protection, avoiding conflicts of interest, preventing illegal market manipulation, fraudulent activities and abuse, and protecting against illicit finance risks arising from non-cooperative jurisdictions.
We will also promote information sharing, including with respect to jurisdictions that have yet to commit to international standards with respect to bank secrecy and transparency.
Reinforcing International Cooperation: We call upon our national and regional regulators to formulate their regulations and other measures in a consistent manner.
Regulators should enhance their coordination and cooperation across all segments of financial markets, including with respect to cross-border capital flows. Regulators and other relevant authorities as a matter of priority should strengthen cooperation on crisis prevention, management, and resolution.
Reforming International Financial Institutions: We are committed to advancing the reform of the Bretton Woods Institutions so that they can more adequately reflect changing economic weights in the world economy in order to increase their legitimacy and effectiveness.
In this respect, emerging and developing economies, including the poorest countries, should have greater voice and representation. The Financial Stability Forum (FSF) must expand urgently to a broader membership of emerging economies, and other major standard setting bodies should promptly review their membership.
The IMF, in collaboration with the expanded FSF and other bodies, should work to better identify vulnerabilities, anticipate potential stresses, and act swiftly to play a key role in crisis response. Tasking of Ministers and Experts

10. We are committed to taking rapid action to implement these principles. We instruct our Finance Ministers, as coordinated by their 2009 G-20 leadership (Brazil, UK, Republic of Korea), to initiate processes and a timeline to do so.
An initial list of specific measures is set forth in the attached Action Plan, including high priority actions to be completed prior to March 31, 2009.
In consultation with other economies and existing bodies, drawing upon the recommendations of such eminent independent experts as they may appoint, we request our Finance Ministers to formulate additional recommendations, including in the following specific areas:
Mitigating against pro-cyclicality in regulatory policy;
Reviewing and aligning global accounting standards, particularly for complex securities in times of stress;
Strengthening the resilience and transparency of credit derivatives markets and reducing their systemic risks, including by improving the infrastructure of over-the-counter markets;
Reviewing compensation practices as they relate to incentives for risk taking and innovation;
Reviewing the mandates, governance, and resource requirements of the IFIs; and
Defining the scope of systemically important institutions and determining their appropriate regulation or oversight.

11. In view of the role of the G-20 in financial systems reform, we will meet again by April 30, 2009, to review the implementation of the principles and decisions agreed today.

Commitment to an Open Global Economy
12. We recognize that these reforms will only be successful if grounded in a commitment to free market principles, including the rule of law, respect for private property, open trade and investment, competitive markets, and efficient, effectively regulated financial systems.
These principles are essential to economic growth and prosperity and have lifted millions out of poverty, and have significantly raised the global standard of living.
Recognizing the necessity to improve financial sector regulation, we must avoid over-regulation that would hamper economic growth and exacerbate the contraction of capital flows, including to developing countries.

13. We underscore the critical importance of rejecting protectionism and not turning inward in times of financial uncertainty. In this regard, within the next 12 months, we will refrain from raising new barriers to investment or to trade in goods and services, imposing new export restrictions, or implementing World Trade Organization (WTO) inconsistent measures to stimulate exports.
Further, we shall strive to reach agreement this year on modalities that leads to a successful conclusion to the WTO's Doha Development Agenda with an ambitious and balanced outcome. We instruct our Trade Ministers to achieve this objective and stand ready to assist directly, as necessary.
We also agree that our countries have the largest stake in the global trading system and therefore each must make the positive contributions necessary to achieve such an outcome.

14. We are mindful of the impact of the current crisis on developing countries, particularly the most vulnerable.
We reaffirm the importance of the Millennium Development Goals, the development assistance commitments we have made, and urge both developed and emerging economies to undertake commitments consistent with their capacities and roles in the global economy.
In this regard, we reaffirm the development principles agreed at the 2002 United Nations Conference on Financing for Development in Monterrey, Mexico, which emphasized country ownership and mobilizing all sources of financing for development.

15. We remain committed to addressing other critical challenges such as energy security and climate change, food security, the rule of law, and the fight against terrorism, poverty and disease.

16. As we move forward, we are confident that through continued partnership, cooperation, and multilateralism, we will overcome the challenges before us and restore stability and prosperity to the world economy. Action Plan to Implement Principles for Reform This Action Plan sets forth a comprehensive work plan to implement the five agreed principles for reform. Our finance ministers will work to ensure that the taskings set forth in this Action Plan are fully and vigorously implemented. They are responsible for the development and implementation of these recommendations drawing on the ongoing work of relevant bodies, including the International Monetary Fund (IMF), an expanded Financial Stability Forum (FSF), and standard setting bodies.

Strengthening Transparency and Accountability
Immediate Actions by March 31, 2009.
The key global accounting standards bodies should work to enhance guidance for valuation of securities, also taking into account the valuation of complex, illiquid products, especially during times of stress.
Accounting standard setters should significantly advance their work to address weaknesses in accounting and disclosure standards for off-balance sheet vehicles.
Regulators and accounting standard setters should enhance the required disclosure of complex financial instruments by firms to market participants.
With a view toward promoting financial stability, the governance of the international accounting standard setting body should be further enhanced, including by undertaking a review of its membership, in particular in order to ensure transparency, accountability, and an appropriate relationship between this independent body and the relevant authorities.
Private sector bodies that have already developed best practices for private pools of capital and/or hedge funds should bring forward proposals for a set of unified best practices. Finance Ministers should assess the adequacy of these proposals, drawing upon the analysis of regulators, the expanded FSF, and other relevant bodies.
Immediate Actions by March 31, 2009.
Supervisors should collaborate to establish supervisory colleges for all major cross-border financial institutions, as part of efforts to strengthen the surveillance of cross-border firms. Major global banks should meet regularly with their supervisory college for comprehensive discussions of the firm's activities and assessment of the risks it faces.
Regulators should take all steps necessary to strengthen cross-border crisis management arrangements, including on cooperation and communication with each other and with appropriate authorities, and develop comprehensive contact lists and conduct simulation exercises, as appropriate.

Medium -term actions
Authorities, drawing especially on the work of regulators, should collect information on areas where convergence in regulatory practices such as accounting standards, auditing, and deposit insurance is making progress, is in need of accelerated progress, or where there may be potential for progress.
Authorities should ensure that temporary measures to restore stability and confidence have minimal distortions and are unwound in a timely, well-sequenced and coordinated manner.

Reforming International Financial Institutions
Immediate Actions by March 31, 2009.
The FSF should expand to a broader membership of emerging economies.
The IMF, with its focus on surveillance, and the expanded FSF, with its focus on standard setting, should strengthen their collaboration, enhancing efforts to better integrate regulatory and supervisory responses into the macro-prudential policy framework and conduct early warning exercises.
The IMF, given its universal membership and core macro-financial expertise, should, in close coordination with the FSF and others, take a leading role in drawing lessons from the current crisis, consistent with its mandate.
We should review the adequacy of the resources of the IMF, the World Bank Group and other multilateral development banks and stand ready to increase them where necessary. The IFIs should also continue to review and adapt their lending instruments to adequately meet their members' needs and revise their lending role in the light of the ongoing financial crisis.
We should explore ways to restore emerging and developing countries' access to credit and resume private capital flows which are critical for sustainable growth and development, including ongoing infrastructure investment.
In cases where severe market disruptions have limited access to the necessary financing for counter-cyclical fiscal policies, multilateral development banks must ensure arrangements are in place to support, as needed, those countries with a good track record and sound policies.

Medium -term actions
We underscored that the Bretton Woods Institutions must be comprehensively reformed so that they can more adequately reflect changing economic weights in the world economy and be more responsive to future challenges.
Emerging and developing economies should have greater voice and representation in these institutions.
The IMF should conduct vigorous and even-handed surveillance reviews of all countries, as well as giving greater attention to their financial sectors and better integrating the reviews with the joint IMF/World Bank financial sector assessment programs. On this basis, the role of the IMF in providing macro-financial policy advice would be strengthened.
Advanced economies, the IMF, and other international organizations should provide capacity-building programs for emerging market economies and developing countries on the formulation and the implementation of new major regulations, consistent with international standards.

Risk Management
Immediate Actions by March 31, 2009.
Regulators should develop enhanced guidance to strengthen banks' risk management practices, in line with international best practices, and should encourage financial firms to reexamine their internal controls and implement strengthened policies for sound risk management.
Regulators should develop and implement procedures to ensure that financial firms implement policies to better manage liquidity risk, including by creating strong liquidity cushions.
Supervisors should ensure that financial firms develop processes that provide for timely and comprehensive measurement of risk concentrations and large counterparty risk positions across products and geographies.
Firms should reassess their risk management models to guard against stress and report to supervisors on their efforts.
The Basel Committee should study the need for and help develop firms' new stress testing models, as appropriate.
Financial institutions should have clear internal incentives to promote stability, and action needs to be taken, through voluntary effort or regulatory action, to avoid compensation schemes which reward excessive short-term returns or risk taking.
Banks should exercise effective risk management and due diligence over structured products and securitization.

Medium -term actions
International standard setting bodies, working with a broad range of economies and other appropriate bodies, should ensure that regulatory policy makers are aware and able to respond rapidly to evolution and innovation in financial markets and products.
Authorities should monitor substantial changes in asset prices and their implications for the macroeconomy and the financial system.

Promoting Integrity in Financial Markets Immediate Actions by March 31, 2009.
Our national and regional authorities should work together to enhance regulatory cooperation between jurisdictions on a regional and international level.
National and regional authorities should work to promote information sharing about domestic and cross-border threats to market stability and ensure that national (or regional, where applicable) legal provisions are adequate to address these threats.
National and regional authorities should also review business conduct rules to protect markets and investors, especially against market manipulation and fraud and strengthen their cross-border cooperation to protect the international financial system from illicit actors. In case of misconduct, there should be an appropriate sanctions regime. Medium -term actions
National and regional authorities should implement national and international measures that protect the global financial system from uncooperative and non-transparent jurisdictions that pose risks of illicit financial activity.
The Financial Action Task Force should continue its important work against money laundering and terrorist financing, and we support the efforts of the World Bank - UN Stolen Asset Recovery (StAR) Initiative.
Tax authorities, drawing upon the work of relevant bodies such as the Organization for Economic Cooperation and Development (OECD), should continue efforts to promote tax information exchange. Lack of transparency and a failure to exchange tax information should be vigorously addressed.
Medium-term actions
The key global accounting standards bodies should work intensively toward the objective of creating a single high-quality global standard.
Regulators, supervisors, and accounting standard setters, as appropriate, should work with each other and the private sector on an ongoing basis to ensure consistent application and enforcement of high-quality accounting standards.
Financial institutions should provide enhanced risk disclosures in their reporting and disclose all losses on an ongoing basis, consistent with international best practice, as appropriate.
Regulators should work to ensure that a financial institution' financial statements include a complete, accurate, and timely picture of the firm's activities (including off-balance sheet activities) and are reported on a consistent and regular basis.

Enhancing Sound Regulation Regulatory Regimes Immediate Actions by March 31, 2009.
The IMF, expanded FSF, and other regulators and bodies should develop recommendations to mitigate pro-cyclicality, including the review of how valuation and leverage, bank capital, executive compensation, and provisioning practices may exacerbate cyclical trends. Medium-term actions
To the extent countries or regions have not already done so, each country or region pledges to review and report on the structure and principles of its regulatory system to ensure it is compatible with a modern and increasingly globalized financial system.
To this end, all G-20 members commit to undertake a Financial Sector Assessment Program (FSAP) report and support the transparent assessments of countries' national regulatory systems.
The appropriate bodies should review the differentiated nature of regulation in the banking, securities, and insurance sectors and provide a report outlining the issue and making recommendations on needed improvements. A review of the scope of financial regulation, with a special emphasis on institutions, instruments, and markets that are currently unregulated, along with ensuring that all systemically-important institutions are appropriately regulated, should also be undertaken.
National and regional authorities should review resolution regimes and bankruptcy laws in light of recent experience to ensure that they permit an orderly wind-down of large complex cross-border financial institutions.
Definitions of capital should be harmonized in order to achieve consistent measures of capital and capital adequacy.

Prudential Oversight
Immediate Actions by March 31, 2009.
Regulators should take steps to ensure that credit rating agencies meet the highest standards of the international organization of securities regulators and that they avoid conflicts of interest, provide greater disclosure to investors and to issuers, and differentiate ratings for complex products.
This will help ensure that credit rating agencies have the right incentives and appropriate oversight to enable them to perform their important role in providing unbiased information and assessments to markets.
The international organization of securities regulators should review credit rating agencies' adoption of the standards and mechanisms for monitoring compliance.
Authorities should ensure that financial institutions maintain adequate capital in amounts necessary to sustain confidence. International standard setters should set out strengthened capital requirements for banks' structured credit and securitization activities.
Supervisors and regulators, building on the imminent launch of central counterparty services for credit default swaps (CDS) in some countries, should: speed efforts to reduce the systemic risks of CDS and over-the-counter (OTC) derivatives transactions; insist that market participants support exchange traded or electronic trading platforms for CDS contracts; expand OTC derivatives market transparency; and ensure that the infrastructure for OTC derivatives can support growing volumes.

Medium-term actions
Credit Ratings Agencies that provide public ratings should be registered.
Supervisors and central banks should develop robust and internationally consistent approaches for liquidity supervision of, and central bank liquidity operations for, cross-border banks.