The IIF has responded to the European Banking Authority (EBA)'s consultation on "The EBA's approach to fintech". The response stresses that supervisory and regulatory approaches should balance addressing risks from new business models and structures with supporting innovation, including at existing institutions. Specifically, the IIF argues that a regulatory framework addressing fintech risks and opportunities in the financial sector should be:

• risk-based, to address risks regardless of the business model involved in them;
• flexible, to address risk regardless of the underlying technology;
• holistic, to incorporate tech-related risks that have traditionally not been associated with finance;
• based on cross-border cooperation, to prevent arbitrage and regulatory fragmentation.'