The IIF has responded to the Committee on Payments and Market Infrastructure’s (CPMI’s) consultation paper on harmonization requirements for enhancing cross-border payments in a comment letter dated May 31, 2023.

In its submission, the IIF supports the guiding principles set by the CPMI and believes these principles will improve harmonization of how ISO 20022 is used across the globe to enhance cross-border payments.

The IIF recognizes a case for further articulation of the reform proposals, such that high impact channels and payment types are prioritized.

The IIF further identifies a need for a dedicated governance framework to drive and oversee the harmonization effort.

Other key points made include:

• While our members agree in principle with many proposed requirements, some requirements are viewed as less obviously beneficial when weighed against cost.
• We support the objective of greater transparency to end users but find that the proposal to increase transparency of cross-border payments would benefit from clarification of the meaning, scope, and purpose of the desired transparency. 
• We consider the use of the term “requirements” to be potentially inaccurate given the intention that the proposals be implemented as guidance rather than regulatory requirements. 

The comment letter continues the close engagement of the IIF with the global standard setting bodies on the enhancement of cross-border payments.