The Clearing House Payments Company L.L.C. (“TCH”), the American Bankers Association (ABA), and BAFT (Bankers Association for Finance and Trade) (together the “Associations”) submitted a joint comment letter on the proposed ISO 20022 harmonization requirements for enhancing cross-border payments (the “Proposed Harmonization Requirements”) issued by the Committee on Payments and Market Infrastructures (“CPMI”).
The Associations are supportive of the G20 effort to enhance cross-border payments and understand the important benefits that common messaging standards, especially for the ISO 2022 format, could provide for cross-border payments.
At the same time, we believe there are many practical considerations that must be taken into account when developing standards and that without the appropriate balance of flexibility and uniformity, standards can have unintended consequences. We are concerned that overall the Proposed Harmonization Requirements have not struck the right balance and, if finalized and mandated in their current form, would make cross-border payments slower, more expensive, and less accessible than they are today.
Read and/or download the full comment letter below.
