Comment Letters

2024

BAFT Comment Letter to the OFAC Regarding the Extending Record Retention Requirements – Posted: October 16
BAFT Submission to the Federal Reserve System Regarding Expansion of FFS and NSS Operating Hours – Posted: September 6
BAFT Comment Letter to the FSB Recommendations for Regulating and Supervising Bank and Non-Bank Payment Service Providers Offering Cross-Border Payment Services Consultation Report – Posted: September 6
BAFT Submission to the Fed/OCC/FDIC for their Notice of Public Response to the Proposed Basel III Endgame Framework – Posted: January 16

2023

ABA, BAFT & TCH Joint Comment Letter on ISO 20022 Harmonization Requirements – Posted: May 31

BAFT Response to the UK PRA Proposals on Basel 3.1 Framework – Posted: April 5

ICC, BAFT, ITFA, AFB & ACT Response to the UK PRA on Basel 3.1 Framework– Posted: April 5

2022

BAFT Statement for the Record, When Banks Leave: The Impacts of De-Risking on the Caribbean and Strategies for Ensuring Financial Access, to the U.S. House of Representatives Committee on Financial Services – Posted: September 14

BAFT Comments on SEC Proposed Rule: The Enhancement and Standardization of Climate Related Disclosures for Investors – Posted: June 17

BAFT Comments on Consultation on a Potential New Term Interest Rate to Replace CDOR in Certain Financial Instruments – Posted: June 13

BAFT Comments to UNCITRAL on Guidelines for International Identity Management – Posted: May 27

BAFT Comments to IASB on Supplier Finance Arrangements Proposed Amendments to IAS 7 and IFRS 7 to Enhance the Transparency of Supply Finance Arrangements – Posted: March 28

BAFT Comments to FASB on the Proposed Accounting Standards Update for the Disclosure of Finance Program Obligations to Enhance the Transparency of Supplier Finance Programs – Posted: March 21

BAFT Comments on Refinitiv’s Consultation on Potential Cessation of CDOR – Posted: February 28

BAFT Comments on European Commission’s Proposed “Banking Package” to Implement Basel III – Posted: February 23

BAFT Comments on ICC Standards for Sustainable Trade Finance – Posted: February 9

2021

BAFT Response to Request for Information and Comment on Financial Institutions’ Use of Artificial Intelligence – Posted: June 29

BAFT Responds to FMSB Consultation on use of Term SONIA – Posted: May 28

BAFT Priorities for EXIM Foreign Content Requirements – Posted: May 14

BAFA Recommendation for US-UK Collaboration – Posted: March 17

BAFT CDOR Cessation Priorities – Posted: March 1

BAFT Response to ICE LIBOR Consultation on Potential Cessation – Posted: January 25

2020

BAFT Comments on Changes to EXIM’s Content Policy with Respect to the Program on China and Transformational Exports – Posted: December 10

Joint Letter to Congress Supporting Passage of the National Defense Authorization Act for Fiscal Year 2021, Especially AML Modernization and Beneficial Ownership Registry Provisions – Posted: December 03

BAFT and BPI Joint Comment Letter on Notice Issued by FinCEN to Renew Without Change the Information Collection under Section 312 of the USA PATRIOT Act (Due Diligence Programs for Correspondent Accounts for Foreign Financial Institutions) – Posted: November 27

BAFT and The Clearing House (TCH) Joint Response to Notice of Proposed Rulemaking Issued by FinCEN and the Federal Reserve regarding Changes to the Recordkeeping and Travel Rules – Posted: November 25

Industry Associations’ Joint Response to FinCEN’s ANPR on Anti-Money Laundering (AML) Program Effectiveness – Posted: November 16

BAFT Response to the EBA’s Call for Input on ‘De-risking’ and Its Impact on Access to Financial Services – Posted: September 11

BAFT Response to EC Public Consultation on AML Action Plan – Posted: August 28

Letter to the Export-Import Bank of the United States: Request To Renew Partnership With Private Export Funding Corporation (PEFCO) – Posted: August 12

Letter Supporting Anti-Money Laundering (AML) Reform Provisions in National Defense Authorization Act – Posted: July 21

Credit Insurance and its Role in Facilitating Bank Lending in the Times of COVID-19 – Posted: April 14

ARRC Consultation on Spread Adjustment Methodologies for Fallbacks in Cash Products Referencing USD LIBOR – Posted: April 1

Proposed Rule: Remittance Transfers under the Electronic Fund Transfer Act – Posted: January 22

BAFT Response to EC Basel Consultation – Posted: January 10

2019

BAFT Signs on to a Letter in Support of EXIM – Posted: November 15

BAFT Comment Letter to the Federal Reserve Regarding its Proposed Faster Payments Service, FedNow – Posted: November 11

Coalition Letter to the House in Support of Long-term Reauthorization of the U.S. Export-Import Bank – Posted: September 11

Coalition Letter to the Senate in Support of Long-term Reauthorization of the U.S. Export-Import Bank – Posted: September 11

Industry Response to CFPB – Posted: July 1

BAFT Statement for the Record on EXIM Reauthorization – Posted: June 28

AML-BO Joint Trades Letter of Support for the Corporate Transparency Act – Posted: June 12

Industry Briefing: Intraday Liquidity Management in Europe – Posted: May 14

AML-BO Joint Trades Letter of Support – Posted: May 10

AML – BO Joint Trades Letter of Support – Posted: March 20

2018

BAFT Comment on FRB Notice Regarding Faster Payments – Posted: December 19

BAFT Response to GFFT Framework for FPC Survey – Posted: June 29

BAFT Response to General RFI RT Rule – Posted: June 29

PRA Consultation Letter Regarding Eligibility of Guarantees as Credit Risk Mitigation – Posted: May 21

AML-CFT Reform Bill Joint Letter of Support – Posted: January 31

2017

Support for Convention on the Assignment of Receivables in International Trade – Posted: December 17

BAFT Statement for the Record Ex-Im Board Hearing – Posted: November 1

BAFT Response to BCBS Consultation on Fintech – Posted: November 8

Trade Priorities Letter – Posted: August 11

TCH/CBA/BAFT/ABA Comment Letter on CFPB Assessment of Remittance Rule – Posted: May 23

BAFT/IIF Comment Letter on BCBS Correspondent Banking Consultation – Posted: February 23

BAFT Comment Letter on the OCC FinTech Charter – Posted: January 17

2016

BAFT MAS FinTech Regulatory Sandbox Consultation Comments – Posted: July 8

BAFT Comments on OCC Whitepaper on Innovation – Posted: May 31

Basel Committee on Banking Supervision Comment Letter – Revisions to the Standardized Approach for Credit Risk – Posted: March 11