Status: Draft -- Not PublishedWill be live at 08/17/2022 12:55
IIF Submission to the FSB on Data and KPIs for the G20 Payments Roadmap
The IIF has made a submission to the Financial Stability Board (FSB) in response to the FSB’s July 6 Interim Report, Developing the Implementation Approach for the Cross-Border Payments Targets. In broad terms, the IIF and its members welcome the progress made by, and our engagement with, the FSB’s Targets Data Group (TDG) and we particularly welcome a number of features of the report, including the emphasis on leveraging existing data sets as much as possible, including public sector data sets such as the World Bank’s Remittance Prices Worldwide (RPW) database and the Global Findex data set, as well as the CPMI Red Book. Our members are, however, concerned by the proposals in the paper for new surveys of banks and other institutions. The submission points out any survey of banks, financial institutions and trade associations is likely to be a significant new data lift, at a time when payments ecosystem actors are coping with significant ongoing operational and compliance challenges including those arising from the level of financial sanctions imposed in response to the Russia–Ukraine conflict. In our view, there is also significant work that would need to be done by the TDG in advance to define the governance structure and confidentiality regime around data submitted in any survey before the industry would have confidence in participating. Detailed answers to the FSB’s specific consultation questions are set out in an Annex to the letter.