ITFA对热辩论的PRA咨询文件的回应突出了两件事。首先，保险公司和银行实际上能够努力捍卫他们的共同利益。其次，鉴于PRA纸张6/18的潜在后果，它还表现出很有必要，让他们近距离。

在180页的长期响应中，ITFA，与其他行业机构协调，向英国监管机构详细解释，详细介绍了不同的保险产品如何帮助银行有效地降低与其贸易融资活动相关的风险。它还解释了为什么这些产品 - 鉴于所使用的文件和普遍的市场实践 - 绝对符合资本要求监管的先决条件（CRR - 欧洲第三条规则的欧洲实施），以有效地实现风险加权减少的风险。

但现在银行和保险公司之间的合作却又受到挑战。所谓的巴塞尔IV将于1月1日由国家监管机构实施^英石, 2022. The aim is clearly to harmonize the market by reducing the differences between how different banks calculate capital reserves needed to make when putting risks on their balance sheet. And with Basel IV the playing field seems indeed more levelled: Experts say the new rules could allow a bank only to get capital treatment that’s maximum 7.5% better what the a Standard Approach bank could achieve.

今年欧洲立法者正在努力将巴塞尔IV融入我们的法律框架，即通过调整CRR。但是什么可能改变，为什么ITFA有关此事？

There are many amendments to the existing Basel III rules – new floors have been introduced, applicable regimes have changed among many others. Here I will focus only on the two changes that have the most important impact on the cooperation between banks and insurance companies:

Advanced vs Foundation Internal Rating Based Approach

度均nt banks use different models to calculate the capital allocation they need to buffer the risks they take onto their balance sheet. For the Standard approach the regulator clearly defines the required capital weighting for each rating class and risk category. Conversely, when using an Internal Rating Based Approach – the so-called IRB, the bank uses its own models to determine the risk weighted assets.

Here again there are two different treatments. The Foundation IRB, where only the PD (Probability of Default) is individually modelled, and the Advanced IRB (A-IRB), which most large European banks use, whereby PD and LGD (Loss Given Default) will be determined by the banks own models.

根据新规则，无法在A-IRB下再次评估与大型企业（收入> EUR 500 M）和FI风险相关的所有资产，但必须使用基础IRB的预定义LGDS（F-IRB）或标准方法。

LGD floor for Financial Institutions of 45%

Basel IV will also introduce new floors for the LGD: for small corporates evaluated under A-IRB this floor will be 25%, for large Corporates which will have to be now evaluated as per the F-IRB, the floor is 40% and for Financial Institutions it is 45%.

What does this mean?

首先，银行的风险缓解行为可能存在另一种转变。过去，银行主要使用信用风险保险来管理信贷风险。在过去的几年里，这已经向保险转向了投资组合管理，减少风险加权资产的工具，甚至改善其企业客户的工具。

Basel IV might reduce the efficiency of insurance for capital management purposes when applying an LGD floor which is certainly meant for RWA related to lending exposure as opposed to RWA relief when mitigating risks.

Furthermore, ITFA has worked hard to create bridges between insurers and banks – mainly by educating and thus erasing doubts on efficiency of this risk mitigation tool. Basel IV will now increase complexity for using risk insurance and probably bring back some of these doubts: if the LGD of an insurance is set at 45%, while Corp only show 40% or even 25% the regulator gives the impression that one is better off with a corporate guarantee then with an insurance policy.

This will lead, on the one hand, to the fact that banks need to allocate more capital to support their corporate customers to the same extend as today. Ultimately banks will therefore probably lend less. On the other, this could lead to an unwanted anti-selection of the assets which banks will have insured: the capital relief a banks gets is function of the difference between the LGD of the insurer and the obligor as well as the difference of the PD between the insurance and obligor – if the LGD of insurance companies has such a high floor, banks will only have an interest to show insurers their lesser rated assets.

However, the business model of insurance is based on a varied book of assets – anti-selection is something insurers dread. Therefore cooperation with banks might lose attractiveness and insurers might quit this market again after having only entered it really over the last 15 to 20 years.

Why does the regulator attribute such a high LGD to Financial institution?

This could mainly be to prevent systemic risks. Indeed – as the financial crisis in 2008/09 has shown, when banks go into bankruptcy the deposits of the retail customers need to be protected in priority, therefore nothing is left in the insolvency mass to hand out to the creditors. This would be similar for insurance company: in case of an insolvency, a creditor of an insurance company has little hope of getting anything back, as the policy holders will be first reimbursed. And this is exactly the point.

When working on harmonizing capital allocation rules, the regulator did not recognize the specificity of the insurance-bank product concerning the position as a policy holder: the bank who is getting risk cover under a trade credit insurance is exactly one of these senior creditors – this is backed by law in most jurisdictions. Therefore the LGD under an insurance policy should be close to 0.

巴塞尔IV的另一个目标是减少对银行系统的系统性风险的意外后果。因此，当银行从另一家银行获得不资料的封面时，高LGD可能会有理识。但保险公司与银行有完全不同的商业模式。对于大多数全球保险公司而言，信用风险只代表未成年人只是其风险组合的小份额。保险公司受到大型天然灾难的影响。此外，保险公司有重新保险，以进一步多样化他们的书籍。ID EST这两个市场并不密切相关。监管机构标准化越多，我们就越需要向监管机构解释产品的特殊性。如果您在不考虑到特殊性的情况下标准化，您将对产品的可行性产生意外后果。

此外，巴塞尔IV对评级机构带来更大的依赖，如标准方法，F-IRB银行无法使用自己的模型，但需要使用大型评级机构的模型。最后的金融危机表明，这甚至可能会增加系统风险，因为评级机构的失误判断可能会导致整个银行系统的脆弱性增加。

What can we do?

我们需要更好地解释信用保险产品和保险业务模式，以便监管机构可以看到细节。透明度非常重要 - 我们并不是一些模糊的企业，以隐藏风险，而是一个良好组织，结构化的规范和合法的全面的市场缓解银行组合，从而减少了这些系统风险。

At the moment, ITFA is working on a survey with its member banks to provide the regulator with data. This data is crucial in order to prove that our business model works and the impact it has on the real economy.

How much time do we have? Normally new laws need at least to be voted 18 months before the implementation date. As the Basel committee requested the new rules to be in force by January 2022., we have time only until June 2019!

It is therefore important to use the momentum of the PRA response now and to rally forces again – mainly to educate and explain... Because we are convinced that the credit insurance products are exactly fulfilling the aim of the regulator: it is making the bank system safer by shifting risk away from it to a highly diversified insurance market – specialized in risk management and with a risk approach which does not correlate with the one banks have.

Anyone who is interested in raising the issue further, should get in touch with Silja Calac – chair of the ITFA Insurance Committee.

silja_calac@swissre.com.