The Clearing House Payments Company L.L.C. (“TCH”), the American Bankers Association, and the Bankers Association for Finance and Trade submitted comments to the Committee on Payments and Market Infrastructures (“CPMI”) regarding proposed ISO 20022 harmonization requirements for enhancing cross-border payments. Though supportive of efforts to enhance cross-border payments, the organizations voiced concern that the proposed requirements do not strike the right balance between flexibility and uniformity which may lead to slower, more expensive and less accessible cross-border payments. The letter encouraged CPMI to issue its final harmonization standards as recommended guidelines and not as requirements, noted that CPMI’s proposed timeline puts the ISO 20022 migrations for U.S. high value systems at risk, objected to the proposal to identify all depository institutions in cross-border payments with BICs, and raised a number of practical concerns. 

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