( 2021 ). businesses surveyed could respond as having deferred payments to more than one type of creditor, meaning that the total number of smes that deferred payments to either trade creditors or landlords is between 7 and 14 per cent. 3 please see the “ nfc resilience ” section of recent financial stability reviews from the central bank for more on this. 4 more details on scarp are available from the department of enterprise, trade and employment, here. 5 greenwood et al. 6 mcgeever et al. ( 2021 ) show that between 2016 and 2019, the number of liquidations of insolvent businesses was typically between 1, 500 and 2, 000. 3 / 3 bis central bankers'speeches

of scale associated with the nfb model are sufficiently high that the industry structure would tend toward oligopoly, or even monopoly. that is, too much franchise value might be created. in that event, there would be significant additions to the cost side of the proposal ’ s ledger, in the form of the price and quantity effects that result from non - competitive industry structures. regardless of the eventual structure of the industry, nfbs essentially would be monolines, with highly correlated risk exposures. they could be particularly vulnerable to funding difficulties in times of deteriorating credit conditions. yet by the terms of the g - m proposal, they apparently would not be able to hedge interest rate or other risks. g - m propose giving nfbs access to the discount window to forestall liquidity problems and runs on the nfbs, presumably in the same way that deposit insurance stopped runs on traditional banks. here again though, the analogy is not a perfect one. while banks and their depositors are assured that the federal deposit insurance corporation will keep the latter whole in the event of the former ’ s failure, the federal reserve does not make binding commitments to lend to any institution and actively discourages reliance on the window for regular funding. a third question about the g - m proposal arises because of the significant changes in current law and practice that would be required were the proposal to be adopted. the prohibition on abs holdings by anyone other than nfbs is the obvious and major example. but there are several others : in addition to the possibly problematic features of discount window lending in general for the proposal, the federal reserve has traditionally opened the window to nondepository institutions only in particularly stressed conditions. under the dodd - frank act, any use of credit ratings in federal regulations will be prohibited, an obvious complication to the g - m proposal. this part of dodd - frank has accelerated and expanded the efforts already underway at the federal banking agencies to lessen regulatory reliance on ratings. in truth, it may pose no greater challenge for the g - m proposal than for many existing capital rules. 4 the relative dormancy of these markets is also due in part to the limited supply of the loans needed to feed the securitization process. for a discussion of some of the issues raised in the context of capital requirements, see board of governors of the federal reserve system ( 2010 ), “ advance notice of proposed rulemaking regarding alternatives to the use of credit ratings in the risk - based