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BAFT Comments on Proposed Guidelines for FinTech Regulatory Sandbox

by User Not Found | Jul 08, 2016
Today, BAFT submitted a comment letter to the Monetary Authority of Singpaore in response to their proposed guidelines for a FinTech Regulatory Sandbox <a href="">Read Here</a>

BAFT, a global association of organizations engaged in international transaction banking, applauded MAS for its leadership in crafting a proposed regulatory sandbox that balances both risk mitigation and the need to create a nurturing environment for innovation.  Key comments and recommendations include:


  1. A well-crafted regulatory sandbox is one critical way that governments across the world can foster a more nurturing environment for financial services innovation and economic growth.
  2. It is important to consider the global nature of emerging financial technology as MAS pursues both its regulatory sandbox as well as its conversations with partner regulatory authorities around the world. A harmonization of standards and requirements across the world and the de facto creation of a “global sandbox” is the best path forward to growing innovative products and solutions, as well as maintaining the regulator’s responsibilities to protect citizens and the financial system at large.
  3. MAS should refine its evaluation criteria for assessing a proposal’s Sandbox suitability, clarifying terms that may have varied interpretations and ensuring there are open lines of communication between applicants and regulators.
  4. MAS should be flexible in terms of the timelines presented for entities to maintain their status in the sandbox. Companies showing sincere commitment to the regulatory guidelines, and staying within the bounds of those guidelines, should be allowed to continue testing.
  5. MAS should hold confidential any information that may be included in an entities’ application.  Any proprietary information – especially if such information involves a truly innovative product – should not be publicly accessible or risk a significant chilling of the potential effectiveness of the Sandbox.
  6. If a solution is found to be valuable to the marketplace, and does not present risks to citizens or to the overall financial system, it should be allowed to go into full production.  If laws or regulations inhibit that, then we would urge policymakers to change such rules.