ACH stands for Automated Clearing House. It is an electronic network of banks for processing small-value transactions. It has gained significant popularity.

The ACH network bank system operates in different modes in different countries. In the United States of America, it is operated by the NACHA ACH Network.

The problem for regulators is that so much has been done to overhaul banking and financial regulation since the collapse of Lehman Brothers that knowing how the system would now respond in a crisis is impossible.

Two unconnected statements from authorities in the US and Britain in the past 24 hours should cause concern for those who worry that the global banking system has become more dangerous in the six years since the crisis, not less.

On Wednesday, the US Federal Reserve published its annual bank capital plan review that saw the North American businesses of Citigroup, HSBC, RBS and Santander all rejected for what it said were “qualitative concerns”.

This morning, the Bank of England’s Financial Policy Committee (FPC) released a statement from its latest meeting in which it warned obtusely that “changes to the structure and functioning of markets as banks adapted business models to the aftermath of the financial crisis” meant it had become more difficult to assess the impact of “unexpected developments from any source”.

What the Fed and the Bank both appear to be saying is that big banks remain too complex and that changes made to financial and bank regulation since the crash in 2008 have resulted in the job of assessing systemic risk becoming much harder.

Left unspoken to a large extent in both statements was the spectre of growing financial risks in emerging markets.

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