You have the French system, which is ruled like the legal system by concepts and where a credit is a credit whether it is given to a bank or to an individual, and the same goes for a debt. In the UK you have a functional approach. You have very different systems for consumer credit or for corporate credit, and different levels of protection.
The banking supervisors are in favour of this. Indeed, they regard it as an incentive to make appropriate risk provision in good time. By contrast, the absence of such an incentive may be a destabilising element in a financial system. Japan is a good example of this, too.