Joint Trade Comment Letter re: ISO 20022 Harmonization Requirements

To the Secretariat of the Committee on Payments and Market Infrastructures:

The Clearing House Payments Company L.L.C. ("TCH"), the American Bankers Association, and the Bankers Association for Finance and Trade (together the "Associations") appreciate the opportunity to comment 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.

As further discussed in our comments below, the Associations respectfully request that CPMI prevent negative impact to ISO 20022 implementations and cross-border payments by encouraging rather than mandating ISO 20022 harmonization standards. Moreover, the harmonization standards should

• not give preference to BICs or Swift services;
• better account for the practical limitations and needs of end users, banks, and market infrastructures; and
• recognize existing legal requirements for data that must be included in payment messages and the needs of financial crime stakeholders.

Download the joint comment letter to read the full text.