The IIF has submitted comments in response to the Financial Stability Board’s (FSB’s) consultation on “Recommendations for Regulating and Supervising Bank and Non-bank Payment Service Providers Offering Cross-border Payment Services,” published on July 16, 2024. These comments draw upon discussions with our Cross-border Payments Task Group (XPTG) as well as frequent consultation with our members.

The IIF advocates that standards should be risk-based to the activity at hand and considers it unfavorable for rules originally designed for banks to simply be applied to non-bank PSPs in the name of reducing frictions. Rather, the risk-based activity approach would help the industry as a whole, particularly in what is presently a very competitive and dynamic space. At the same time, we emphasize the need to avoid unintended consequences to the security and safety of payments flows or negative impacts to the G20 cross-border payment objectives. The IIF and its members stand ready to engage in additional discussions and consultations on these topics, and we look forward to the final recommendations by end-2024.