The Clearing House (TCH) submitted a letter to the BCBS responding to the Committee’s FinTech Consultative Document. The letter highlights several general principles to guide regulators’ approach to financial innovation and addresses the consultation’s ten recommendations. Specifically, the response asserts that regulators should focus on regulating the activity, rather than the entity, such that a fintech firm and an incumbent would be subject to the same regulation for the same activity, and the regulation would change depending on the activity undertaken and the risk to the consumer and system.