Status: Draft -- Not PublishedWill be live at 05/11/2017 00:00
IIF Response to FSB Proposed Framework
For the past several years the Institute of International Finance (IIF) has been consistently underscoring the importance of evaluating the effectiveness of the agreed reforms and potential unintended consequences, and we welcome the Financial Stability Board's (FSB) recent Consultation Document. The formulation of a framework to conduct such analysis is a fundamentally important initiative that we fully support, and we value this opportunity to provide our input.
While we are encouraged by the decision to develop a framework for post-implementation evaluation, we note in our comments the importance for the FSB to expand the scope of examination and broaden the opportunities for evaluation. In our comment letter we also outline the industry's priorities regarding the analysis to be conducted. Given the limitations of time and resources, effective prioritization will be an essential feature of the future FSB work program. Finally, we underline that it is vital to establish a clear governance structure for the analysis to be conducted.