The Clearing House Payments Company, L.L.C. (TCH) submitted comments to the Committee on Payments and Market Infrastructures (CPMI) in response to an interim report on governance and oversight of cross-border interlinking arrangements.  TCH agreed with the report’s observation that interlinking arrangements are one of the most promising solutions for enhancing cross-border payments and that governance and potential oversight of the arrangements will be important factors in their success or demise.  TCH believes it is critical that interlinking arrangements be able to develop in a supportive, predictable, and balanced regulatory and supervisory environment.  To foster such an environment TCH encouraged CPMI to (i) continue to approach governance for interlinking arrangements in an open, non-prescriptive way; (ii) not assume that interlinking arrangements will require separate oversight and instead consider whether existing supervisory risk management frameworks may be sufficient; and (iii) develop well-defined, public criteria for determining what would make an interlinking arrangement subject to oversight and how oversight would be coordinated among different jurisdictional authorities, preferably with a “lead” supervisor. 

To read the full comment letter click here.