The Clearing House and Bank Policy Institute (the Associations) submitted comments to the Financial Stability Board (FSB) in response to its report that proposed policy recommendations intended to strengthen consistency in the regulation and supervision of banks and non-banks in their provision of cross-border payment services. While the Associations think the report accurately describes the commercial environment for retail cross-border payments and reasonably portrays some of the inconsistencies in the supervision and regulation of banks and non-banks, they requested that the FSB consider further (1) the significant impact that supervisory expectations for sanctions screening have on the cost and speed of cross-border payments, (2) the disparity in regulation and supervision of banks and non-banks, and (3) the fallacy in policies that treat banks and non-banks differently when giving weight to public policy goals, business models and the value of innovation. 

A copy of the letter may be found here.