Moving the Dial: Fostering a Culture of Supervisory Effectiveness

9th October 2025 

Key takeaways

• Following banking crisis authorities are blamed for ineffective supervision, but then policy debates focus exclusively on regulatory reforms, with little attention paid to supervisory processes and practices.
• There are four drivers for effective supervision:
  1. Supervisory judgment: ample room for judgment and empowerment of supervisors, within a well-defined risk appetite framework;
  2. Documentation and persuasion: constructive dialogue with firms, based on clear documentation of weaknesses and effective communication, to prompt firm-led remediation;
  3. Bias to action, with structured escalation of measures if firms are unwilling or unable to move
  4. Checks and balances, including a strong second line of defence and an emphasis on transparency
• These drivers represent the key building blocks of an open and effective supervisory culture.

I am very glad that the issue of supervisory effectiveness is taking centre stage in discussions within the international supervisory community. I would like to praise the team at the IMF for having raised the issue already back in 2010² and then again immediately after the spring 2023 turmoil³, building on the experience of the Financial Sector Assessment Programs (FSAP). I consider particularly important that the Basel Committee on Banking Supervision (BCBS) recently decided to work on this topic, publishing a very informative review of economic literature and conducting an important stock take of good practices. The recent FSI paper on qualitative measures⁴ is also providing an essential reference in this debate. I was always struck by the dissonance between the heavy criticism aimed at supervisors after banking crises and the almost exclusive focus of the successive policy debates on regulatory repair, with little or no attention paid to supervisory processes and practices.

There is also a conjunctural element that makes effective supervision particularly important. The regulatory pendulum is in full swing back in a number of jurisdictions, as post-crisis regulatory reforms are increasingly seen as an obstacle to innovation and growth. The complexity of the regulatory framework is portrayed as the driver of excessive compliance costs, impinging on banks’ lending capacity. While I disagree with these views, there is a concrete possibility that the safeguards to financial stability will be lowered, or that the regulatory framework will not be appropriately upgraded to cover for new emerging risks. In my experience as a supervisor without regulatory powers at the ECB I realised that there is quite a lot you can achieve with supervisory tools to foster the safety and soundness of banks, also in areas in which the regulatory framework is not helpful or not yet developed. Effective supervision could avoid major gaps leading to new crises. Also, Neil Esho, the Secretary General of the BCBS, in a recent roundtable here in Basel noticed that a risk sensitive regulatory framework is complex by construction, as it needs to reflect all the nuances of good risk measurement and management practices. One way to simplify the regulatory framework, he argued, would be to embody risk sensitivity more in the supervisory toolbox, rather than in formal, codified rules. Effective supervision could therefore help simplifying the regulatory framework.

Progress on supervisory effectiveness requires candid and deep discussions within the international supervisory community, overcoming the traditional reluctance to express judgment on weak practices. The reality is that all of us could do better and be more effective; we will not improve until we accept criticisms and start learning from each other. In this spirit, I will focus my remarks today on areas in which supervisors might find it difficult to be effective. I will argue that finding the right balance in these areas of our difficult job would provide the building blocks of a culture of supervisory effectiveness.

Supervisory judgement 

The foundational building block of effective supervision is judgment. The very concept of safety and soundness, which is at the centre of the first core principle for effective supervision of the Basel Committee, requires a judgment call, under imperfect information, on the perspective viability of a bank and its ability to ensure continued respect of regulatory requirements. Of course, supervisors need to investigate and act on breaches of regulatory requirements that have already occurred – an activity that might also require a good degree of supervisory judgment. But we all agree, I believe, that supervisors are not simply policemen identifying rules breaches. They have the much more delicate task of assessing and challenging banks’ culture, strategy, practices and decisions that might lead to excessive risk-taking and disruptive crises.⁵ It is an intrinsically forward-looking, and therefore judgmental, role. The unique position of the supervisor, enabling peer comparisons and a system-wide view of the system, attributes a particular value and strength to these judgment calls. I have always seen the essence of the supervisors’ role as an external, independent element in the governance of banks, aimed at creating guardrails that prevent private business decisions of highly leveraged, publicly insured institutions from generating unwarranted harm to the general interests.

The prospective, judgmental nature of prudential supervision requires the authority to intervene well before requirements, or even buffers or early warning triggers specified in the rulebook, are breached. On the financial side this orientation took strong prominence in the aftermath of the Global Financial Crisis, with the central role taken by supervisory stress test in challenging banks’ capital trajectories and determining the additional capital requirements and buffers imposed by the authority. Supervisory stress tests are conducted within a well-defined methodological framework, but they still rely on supervisory judgment, which can create tension with firms. In the US, the top-down nature of the exercises, fully managed by the Federal Reserve staff, and the opaqueness of the methodology driving the results have originated major controversies with the banks, culminating in a lawsuit. In the EU the banks run the scenarios designed by the supervisors using their own internal models, but within a constrained methodology developed by the European Banking Authority (EBA) and supervisory challenge of the results by the ECB teams, also using peer benchmarking and top-down models. In this case the industry’s criticism focuses on the realism of some methodological assumptions and on the judgment calls made by supervisors on the banks’ estimates of risk parameters. While the overall framework for supervisory stress tests should be subject to debate and some of the criticisms raised by the industry are well founded,⁶ I see the usefulness of these exercises, and the credibility of the results, as closely linked to the room left to supervisory judgment and to the effective challenge raised to banks’ own assessment of risks.

The issue of supervisory judgment becomes even more controversial as we move from financial projections to the inner mechanisms driving firms’ strategies and risk-taking behaviour – culture, governance and management, business model, risk controls. Sometimes a distinction is drawn between financial and non-financial risks, which I don’t think is particularly relevant in the discussion of supervisory effectiveness: if the governance lacks proper check and balances, if the business model is not sustainable, if risk controls are not effective, these weaknesses are bound to materialise, at a later stage, in the balance sheet of the firm and in its viability. I would argue that the effectiveness of supervision crucially depends on the ability of the authority to make early judgment calls in these areas and obtain satisfactory remediation before the weaknesses translate into the deterioration of financial indicators and potential breaches of regulatory requirements. If something is wrong with the culture of a firm, cutting across these “non-financial” elements, this will sooner or later materialise in financial consequences in ways that might be difficult to foresee. If supervisors intervene only when financial indicators are deteriorating, they would be entering the picture when the problem is already beyond repair.

This is where the key challenge of supervisory effectiveness lies, in my view. Shaping the culture of a firm, its internal governance, its business model is the very core of its private autonomy. Supervisory interventions are easily viewed as bureaucratic intrusions into areas that belong to banks’ board and senior management. Supervisory judgment could be seen as an inappropriate challenge to the inner functioning of the bank and to the key persons and organisational mechanisms shaping and overseeing it. Tensions do easily arise.

It should not surprise us that after the Global Financial Crisis supervisors focused their attention much more on these core drivers of the long-term viability of banks. The highest number of findings and measures and the least satisfactory scores in the supervisory assessment of the ECB, the PRA and the Fed are all in the areas of internal governance, business model sustainability, internal controls. This is one of the lessons from the crisis: you need to fix fundamental issues to protect the stability of the sector, rather than simply tick boxes and check financial indicators. At the same time, it shouldn’t surprise us that firms’ culture, governance and business model are the areas in which it is most difficult for supervisors to be really effective and move the dial. Scores are sticky, remediation takes long time and sometimes fails to materialise in time to avoid disruptive crises, as shown in the spring 2023 turmoil. We have to acknowledge that this is a real challenge and that the difficulties we face might also stem from some weaknesses in supervisory approaches adopted so far. 

In dealing with this challenge, we should also appreciate that the exercise of supervisory judgment requires a favourable cultural environment within authorities. In hindsight, supervisory judgment may well prove wrong. If mistakes hamper the career of supervisors, staff will shy away from difficult judgment calls and try to play safe, acting only on the basis of compelling evidence. This might prove to be too late. The leadership of supervisory authorities should aim at creating an environment of psychological safety in the exercise of judgement, reassuring the staff and middle management in words and deeds that there will be no punishment for wrong calls made in good faith.

A report of the Institute of International Finance recently criticised the excessive room for supervisory discretion, arguing that constraints should be put in place to ensure a more consistent application of rules and guidelines.⁷ However, the same report also argues that supervisors often give limited consideration to firm-specific factors, such as business model and geographical footprint. I strongly believe that reducing the room for supervisory judgment and bringing the supervisory process to a mere check of compliance with regulatory requirements would be a huge mistake. Undermining supervisory judgment would carry more risks for financial stability than outright deregulation, as it would weaken the firm-specific safeguards that really anchor the system. Rules can and often are easily circumvented; effective supervisory assessments cannot be easily dismissed. However, it is only fair to recognise that supervisory judgment, as any other strong empowerment of public authorities, needs to be exercised within an appropriately balanced and controlled framework. Let me now focus on what I see as the key components of such a framework.

Documenting and persuading 

When supervisory judgment focuses on cultural, governance and strategic weaknesses effective remediation is crucially dependent on the board and senior management of the firm recognising this assessment and taking ownership of the problem. If dealing with supervisory findings is just seen as a routine compliance exercise, requiring some formal adjustments to tick the box and make the supervisor happy, those weaknesses are likely to persist while the divergence of views between the supervisor and the bank is only likely to widen. The bank will think it has done all the supervisor requested, but scores remain poor and measures are not lifted. The supervisor will remain convinced that the underlying problem is not addressed and might consider raising the pressure on the bank.

Ensuring buy-in from the bank is essential. This means that supervisory judgment needs to be well substantiated in clear and well documented findings. Also, these findings need to be effectively communicated to the bank, with extensive engagement with key persons and bodies. Documenting and persuading are key elements in ensuring timely remediation. The lack of accepted metrics to measure the problem requires that the supervisor digs deep into the toolbox and does not shy away from testing new tools.

Board effectiveness reviews or thematic on-site inspections are sometimes used to gather evidence and buttress supervisory judgment. They entail in depth analysis of board documentation and minutes, observation of board and committees meeting, interviews with board members and senior managers, surveys with middle management and staff at different level of seniority, use of information gathered from whistleblowers. De Nederlandsche Bank went one step forward by establishing a team of organisational psychologists that is now also supporting the ECB in its supervisory reviews. Sometimes the Board could be asked to perform a self-assessment, or to mandate a review to an independent consultant – this tool is formalised in the UK, with a specific power entrusted to the PRA and the FCA to ask for independent review (so-called section 166 reviews). In a nutshell, all these practices aim at gathering evidence from the bank itself and present it to the board and senior management. Organising the evidence and presenting it to the bank with a compelling narrative is a fundamental ingredient for success. If the board recognises the picture painted by the supervisor, the preconditions for change are laid down. A remediation programme can then be agreed, with clear milestones and often also change in key people at the bank.

It is a delicate process, requiring special skills. It is advisable to have some senior staff involved. At the PRA Senior Advisors take a leading role in board effectiveness reviews, assisted by the supervisory team and sometimes specialised staff. But it would also be important to provide supervisors with ad hoc training, both in interviewing, gathering evidence from behavioural patterns and effectively communicating results and persuading boards and senior management of the need to change. If supervisors and bankers are on a different wavelength techniques need to be deployed to enhance understanding and avoid confrontation. In my experience, supervisory training is made widely available on technical issues, less so for these specialised skills related to gathering evidence and communicating with firms on cultural and organisational issues.

It would also be very helpful to have techniques and metrics that enable supervisor to provide credible markers of cultural and governance issues. New technologies can and hopefully will increasingly provide help to supervisors. Analysis of metadata from internal mail traffic is already being used to understand communication and reaction patterns, influence and status of different people and functions, thus obtaining empirical evidence on possible shortcomings. To my knowledge these instruments are not yet used in supervisory processes, but some authorities are already investigating their potential application on cultural and governance issues. There is a general effort to adopt SupTech instruments to increase the efficiency and effectiveness of supervision. This is an area where the application of new technologies could be particularly helpful.

Another area where supervisors could sharpen their focus is the use of market information. Stock prices, CDS spreads, market implied default probabilities, funding costs are already regularly monitored by supervisors. But the administrative nature of supervision implies that the attention of supervisors is predominantly focused on official data reported by banks. Having access to confidential information, supervisors might be led to believe that they “know better” and don’t need market intelligence beyond what is already flashing on their monitors. They might also consider that entering into a dialogue with the buy side could raise a risk of breaches in confidentiality requirements supervisors are legally bound to respect. As a consequence supervisors are generally reluctant to engage in a dialogue with market analysts, rating agencies and investors. When I was at the EBA and did not have direct supervisory responsibilities, I realised the wealth of information that can be gained from these exchanges of views. Market intelligence might have already captured some weaknesses of a bank’s internal dynamics; supervisors should make an effort and not miss potentially useful information.

Finally, we have to acknowledge that the administrative nature of supervisory tasks might generate behaviours that hinder effective supervision. There might be several supervisory teams (line supervisors, horizontal specialists, on-site examiners, different authorities…) engaging with the banks and identifying a variety of findings related to culture and governance – after all, these aspects affect the firms across all lines of business. There might be a tendency to throw at the firm all findings and expect remediation, without a clear prioritisation of what really matters. Effective supervision needs to be focused on the key drivers of risk. Supervisors need to prioritise and drop issues off the table, even if they run the risk of being criticised if something goes wrong in lower priority areas. As already mentioned, the leadership and senior management of the authority has to be credible in supporting prioritisation. Developing a well understood risk appetite framework could be of great help in this process. Good collaboration and exchange of information between authorities is also very important in selecting priorities and avoiding an overload of recommendations. The criticisms raised by the industry on the lack of focus, overlapping requests, excessively minutiose findings should be taken seriously.

Taking action

While ideally the efforts to document weaknesses and persuade boards and senior management should lead to the desired changes, there could well be cases in which the bank is unwilling or unable to remediate the shortcomings identified by the supervisor. Supervisors might be tempted to reiterate their concerns but postpone more decisive action, in the hope that sustained pressure could eventually bring about the desired results. Such hesitation could be very costly, though. Deeply seated weaknesses rooted in cultural and governance shortcomings are unlikely to disappear in the absence of determined action. While succession planning and change in key positions at the bank could provide a welcome opportunity to get the necessary action, they may well require a long time to be enacted and there is a risk of losing momentum and failing to achieve the supervisory goal. There should be a bias to action, with quantitative or qualitative measures incorporated in a well-defined escalation ladder, clearly communicated to the firm.

There is some debate in the supervisory community as to whether (actual or suspended) additional capital requirements could be a good measure to prod the bank into action on move to timely remediation of governance and risk control issues. My personal view is that capital add-ons are a very effective tool in presence of weaknesses in internal risk controls, which are likely to materialise down the road in the bank balance sheet. But on their own they aren’t likely to address more deeply seated problems in the culture and governance of a bank. I think the case of Credit Suisse is a good example in this respect.

The report of the Expert Group on the ECB’s Supervisory Review and Evaluation Process⁸ provides a nice representation of an escalation ladder of qualitative measures, leading from recommendations to non-binding measures, and then to legally binding requirements within a well-defined time frame. 

All this is conceptually easy and well understood, but it might prove quite difficult in practice. First, as already mentioned, it requires dedicated effort and consistent communication from the top that supervisors decisions to escalate are supported by the senior leaders of the authority and that in case of mistakes or successful lawsuits the staff will not be targeted or penalised in career progression. In my experience, supervisory staff maintain some scepticism that this would be the case and tend to pass responsibility to higher hierarchical levels, often leading to delays and complications in the escalation to harsher measures. Second, the triggers for escalation are not always easily verifiable, which could generate controversy and tensions throughout the process. Third, most importantly, supervisory authorities tend to exhibit a rather low legal risk appetite. This is especially true of central banks, often entrusted with prudential supervision – central banks place a significant value on their external reputation and do not like to lose cases in Court. As a result, escalation to harsh, impactful measures might occur only in presence of blatant breaches of regulatory requirements. This could significantly undermine action on cultural and governance issues, where rules can only define general, high-level requirements. I think a well-functioning supervisory framework is one in which decisions of the authority are subject to a rigorous challenge process, which however recognises appropriate leeway to supervisory judgment within an appropriate due process. In such a framework the authority needs to have a robust legal risk appetite framework and accept that some cases might be lost, without renouncing to act on well-founded supervisory judgment.

Individual accountability regimes, such as the Senior Managers and Certification Regime introduced in the UK, provide an important avenue to address shortcomings in culture and governance leading to regulatory breaches, as responsibilities are clearly allocated. Similarly, other authorities are using re-assessments of the fitness and propriety of managers and key function holders in cases of clear conduct or prudential breaches. It is more controversial to use this tool in an ex-ante fashion, before an actual breach. But extending the review of the cultural and governance shortcomings identified in the bank to assess the responsibilities of individual managers could be an interesting avenue for achieving effective supervisory results.

Checks and balances 

The ingredients of effective supervision mentioned so far entail a very strong empowerment of supervisors: their judgment, which banks might consider vague, subjective and reflecting personal preferences, drives a  process requiring change in the fundamental pillars of private autonomy – cultural values, governance arrangements, strategy; if banks are not persuaded by the evidence gathered by supervisors, an escalation of administrative measures, up to harsh enforcement actions, should be deployed to force remediation. If this strong power is to be perceived as legitimate and last through time, it must be exercised with adequate self-awareness and within an appropriate framework of checks and balances. There needs to be real room for internal and external challenge.

The first component in a good set of checks and balances is a strong second line of defence. Supervisors should walk their own talk: they ask banks to have a strong second line of defence, robustly challenging risk-taking behaviour of front-line functions; they should apply similar challenge internally, with a clear risk appetite framework and horizontal checks to ensure consistency of supervisory judgments across banks and appropriate use of the tools available – pushing to action when line supervisors might be reluctant to move up the escalation ladder, or restraining action where they seem to be excessively trigger happy. My impression is that the development of a strong second line of defence in supervisory authorities is still in its infancy and should be at the centre of discussions in the supervisory community. In general, the second line of defence seems to be granted a lower organisational stature than the first line exercising direct supervision of banks – something we often criticise in the organisation of banks. When a second line function is established under tight budgetary constraints it might prove painful to distract resources from first line tasks. In many cases, the function is intervening only with ex-post quality controls, without playing a real role during the supervisory process. Also, its activity is not always taking front stage in the documents disclosed by supervisory authorities.

I also see the interplay between vertical functions (i.e., line supervision of individual firms) and horizontal functions (i.e., independent on-site teams or risk specialists teams conducting reviews across firms) as an important component of checks and balances. The industry often criticises these arrangements as duplicative and generating noise in the dialogue with their supervisor.⁹ I see them as a constructive application of a four-eyes principle: line supervisors have the better understanding of the individual bank and its weaknesses, but they could miss important aspects, could be excessively relying on the same data and metrics used by internal risk management functions, or could develop an excessively adversarial approach towards the bank’s management. Horizontal functions can provide a fresh perspective, adding value to the supervisory process if appropriate coordination is assured and a consistent set of messages is conveyed to the banks – something that unfortunately is not always happening.

Another essential ingredient is transparency in the conduct of supervisory tasks. As supervisors exercise a strong, intrusive set of powers, there needs to be appropriate efforts to explain their behaviour, the priorities they pursue, the results they are achieving in fostering the public interest in the stability of the banking sector. Transparency is essential to accountability and to my knowledge all authorities publish annual reports, provide regular testimonies to Parliamentary Committees, engage in public speeches, press and social media activities to present their policies and views. Yet, we have to recognise that there are different perspectives on the subject. The banking industry generally complains about a lack of transparency in supervisory methodologies, which leads to excessive discretion and decisions that may be perceived as arbitrary. I don’t believe transparency should aim at constraining supervisory judgment, or to move the supervisory process towards the mechanistic application of codified methodologies, to be disclosed in detailed, published guidance. But in general I think that supervisors could go further in explaining their actions and publishing material that enables the industry and the public to appreciate or criticise their direction of travel. There is still a dominant culture in supervisory authorities which sees transparency more as an accountability obligation than a tool for effective supervision. Confidentiality requirements are often interpreted very strictly. Most importantly, there is a concern that detailed, rules-like supervisory metrics could be reverse-engineered and gamed by the banks. I believe we should overcome these fears and embrace transparency. Forward guidance is becoming less fashionable in monetary policy, but I think it could be very useful in supervision. By explaining to banks what is expected of them, where the supervisory lens will focus the most, which results the supervisors expect to attain via their actions, the dialogue with the industry will be more focused and constructive. You cannot have effective supervision without a clear identification of the targets you want to achieve in a specified period of time and an ex-post assessment of the success in pursuing those objectives. I also think that we could extract useful metrics from the dynamics of the scores supervisors assign to banks, for instance measuring how long it takes to bring a risk profile back within tolerance. The assessments conducted by the second line of defence could also be widely disclosed, without mentioning individual firms.

Finally, besides the mechanisms for challenge provided in each legal system, I am convinced that supervisors should themselves seek external, independent challenge to the way they conduct their functions. This frequently occurs after a crisis, where supervisors face external pressure and the objective of the review is to identify mistakes and apportion blame. While these are necessary exercises, it would be more important to regularly rely on authoritative independent experts to review specific areas of supervision and provide suggestions for improvements. The report of the Expert Group that reviewed the Supervisory Review and Evaluation Process of the ECB in 2023 was extremely valuable in identifying areas where process and practices could be improved. Openness to external scrutiny is important also to bolster the reputation and credibility of the authorities.

Conclusions: supervisory culture 

My remarks today focused mainly on the difficult challenges supervisors face in dealing effectively with banks’ weaknesses in core areas, such as internal culture, governance and business model sustainability. While focusing on this challenge we should also ask ourselves whether the culture of supervisory authorities should also be subject to the same type of scrutiny. As Wayne Byres correctly noticed, “…if poor culture and governance can produce poor decisions and practices in any sort of firm, why should we not expect these issues to challenge a financial supervisor too?”.¹⁰

Personally, I find it difficult to discuss supervisory culture in abstract term. But I think the drivers of effective supervision I submitted to your attention today represent the key building blocks of an open and effective supervisory culture. Ample room for judgment and empowerment of supervisors, within a well-defined risk appetite framework; constructive dialogue with firms based on clear documentation of weaknesses and effective communication, to prompt firm-led remediation; a bias to action, with structured escalation of measures if firms are unwilling or unable to move; a thorough set of checks and balances, including a renewed emphasis on transparency - these are in my view the tracts of an effective, challenging and open supervisory culture.

Following the stock-take of research and practices for effective supervision, we now need to have a candid and open debate in the international supervisory community. I applaud the FSI and the BCBS for organising this event and kick-starting the discussion.

Endnotes

1. This contribution reflects personal views built throughout my experience at different supervisory authorities and does not necessarily reflect the views of my former and current employers. Its content, released by the Forum on Financial Supervision, was presented at a closed door meeting on supervisory effectiveness organised by the Financial stability Institute and the Basel Committee on Banking Supervision in Basel on 24 September 2025.
2. J Viñals, J Fletcher, A Narain, J Elliott, I Tower, P Bologna and M Hsu, The Making of Good Supervision: Learning to Say “No”, IMF Staff Position Note, May 2010
3. T Adrian, M Moretti, A Carvalho, H K Chon, K Seal, F Melo and J Surti, Good Supervision: Lessons from the Field, IMF Working Paper 23/82, September 2023
4. M Balan, F Restoy and R Zamil, Act early or pay later: the role of qualitative measures in effective supervisory frameworks, FSI Insights on policy implementation No 66, April 2025
5. Conti-Brown and Vanatta make an attempt to plot different paradigms of supervision in a chart running on two axes, one covering the punitive or collaborative style of the authority, the other its retrospective or prospective attitude. The Police paradigm is at the extreme of the Punitive/Retrospective range, while the Management Consultant paradigm lies at the extreme of the Collaborative/Prospective range. My focus on the role of judgment definitely stresses the prospective dimension of the function, while is more modular on the other axis, depending on the situation of the firm and the task at hand.  See P Conti-Brown and S Vanatta, Focus on bank supervision, not just bank regulation, Brookings Institution, November 2, 2021, as well as the discussion in M Hsu, Evolving Banking Supervision, Remarks Before the Joint European Banking Authority and European Central Bank International Conference, September 3, 2024
6. I have criticised the current set up for supervisory stress tests and proposed some radical changes in A Enria, The future of stress testing – realism, relevance and resources, Speech at the European Systemic Risk Board (ESRB) Annual Conference, 26 September 2019
7. A Portilla, K Rismanchi and  G Kobayashi, Improving Supervisory Effectiveness – Addressing Concerning Trends in Banking Supervision, September 2025 Improving Supervisory Effectiveness – Addressing Concerning Trends in Bank Supervision > The Institute of International Finance
8. Expert Group’s Report to the Chair of the Supervisory Board, Assessment of the European Central Bank’s Supervisory Review and Evaluation Process, 17 April 2023 Assessment of the European Central Bank's Supervisory Review and Evaluation Process, p. 41, Exhibit 4
9. See for instance the report of the Institute of International Finance already mentioned in footnote 6
10. Wayne Byres, Time to Tackle Unfinished Business, Starling Compendium, 2023

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