Monday, April 30, 2018

The Institute of International Finance (“IIF”)1 welcomes the Treasury’s continued efforts in support of Executive Order 13772 on Core Principles for Regulating the United States Financial System (the “Executive Order”).2 We are pleased to provide our comments on this occasion in respect of the upcoming 4th Report, on Non-Bank, Non-Insurer Financial Institutions, with the aim of contributing to a constructive policy dialogue on the difficult role of policy-makers, regulators and supervisors in ensuring a resilient and stable financial system, providing a level playing field for all participants (banks and non-banks), and fostering an innovative, secure and competitive financial market and investment climate that fully supports capital formation, economic growth, and job creation.

We appreciate that the scope of Treasury’s 4th Report is extremely broad, and our comments are concentrated within that scope, specifically on technological innovation and related competition issues in the financial system. Our comments relate to informed consumer and investor choice, financial stability, and the need for an efficient regulatory structure for cross-sectoral and cross-border competition in the FinTech ecosystem3, consistent with the Core Principles.

IIF Authors

Brad Carr

Brad
Carr
Senior Director, Digital Finance Regulation and Policy
+1-202-857-3648
bcarr@iif.com

Daniel Pujazon

Daniel
Pujazon
Policy Advisor
+1 202 857-3644
dpujazon@iif.com

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