Announcement concerning the Joint Association Letter

In April this year, ITFA led a joint industry association initiative, drawing the attention of the regulator to the Private Non-Payment Insurance market. Thanks to our continuous advocacy activities, we understood that the European Commission was preparing amendments to the EU Capital Requirements Regulation (CRR), aiming at boosting and facilitating bank lending amid COVID-19 crisis. Together with BAFT, Berne Union, IACPM, IUA, LMA, we were explaining, in the letter addressed to the European policymakers, that when considering regulatory and legislative actions they should ensure fair treatment between various providers and segments in the credit insurance market. You may find the letter in the member’s section of the ITFA website.

Our aim was two-fold:

• First, we wanted to make sure that the private risk insurers obtain similar treatment as public or government-related entities such as ECAs, namely concerning the provisioning rules for the non-performing exposures.
• Second, we wanted to raise awareness about the importance of the trade and export credit financing industry. Despite the uncertainty linked to the very unfortunate and bizarre situation in the past months, we believe it was wise to use the momentum to demonstrate the vital benefits our industry brings to the wider economy. Following up to the letter, ITFA also drafted concrete amendments to the draft legislative text, which was negotiated by the Member States and the European Parliament. Our amendments have not been adopted, which was mainly due to the time pressure and the necessity to prioritise among many extremely important issues for the banks. The legislative text had to be approved very quickly as there were many time-sensitive proposals relevant to the banking sector. The amendments to the CRR were adopted in the record time of two months. 

ITFA considers this initiative very useful, mainly for three reasons:

• First, we have established further links with the policymakers. The letter was sent to the European Commission, several members of the European Parliament and all 27 EU Member States. This will be very helpful for our discussions with the policymakers when discussing the importance of Non-Payment Insurance for the wider economy. Also, it will help us if we will want to address the very question of the level playing field related to the non-performing exposures among the providers by the time the CRR is reopened again.
• Second, the voice of ITFA was heard, we had various interviews with journalists and our views were published in various magazines and newspapers relevant for our industry.
• Last but not least, this ITFA led initiative has supported our reputation as a reliable partner for other associations.

As it is the case in life and even more so in politics, the journey is as important as the destination and the hard results might not be the most important ones.