CP6/18 is of interest to a wide range of our members, both UK based and those from overseas accessing the City's centre of excellence in export financing. It could also detrimentally impact the ability of our members to finance exports by British manufacturers by increasing the cost of credit protection.

As highlighted in the CP, credit risk mitigation (CRM) is used by our members for sound risk management reasons and, with the capital benefits provided in the Capital Requirements Regulation (CRR), enable more affordable and long-term lending to be provided by our members to the wider economy. For example, export finance products support the supply of goods by manufactures to overseas markets by mitigating payment and political risk for the manufacturer. We highlight below a number of examples where the proposals may have unintended consequences.