The Clearing House Payments Company, L.L.C. (TCH) submitted feedback to the Financial Stability Board (FSB) in response to the FSB’s interim report titled “Developing the Implementation Approach for Cross-Border Payments Targets.” The FSB seeks information to aid in the development of quantitative targets that can be used to assess progress made with respect to the cost, speed, transparency and access goals of the G20’s Roadmap for Enhancing Cross-Border Payments. In its feedback, TCH noted that it does not track payment activity over its networks using the segment definitions developed by FSB and would therefore be unable to report data based on those segments. TCH further noted that its networks that support cross-border payments do so through a correspondent banking model, which means that that the payment taking place over TCH’s network is only a portion of the cross-border payment and TCH would, it believes, therefore not have the data requested by the FSB. With respect to certain Key Performance Indicators (KPIs) proposed by the FSB to assess payment speed in wholesale and retail segments, TCH observed that it does not have a truly end-to-end view of the payments that are made over any of its networks, and that it does not know when a payment has been initiated and when a payee is credited

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