• The IBFed appreciates the opportunity to provide comments on the Consultative Document. At this time, we support each jurisdiction’s own bank supervisory agencies in their efforts to address the challenges and opportunities related to emerging fintech technologies while continuing to encourage comparably equivalent national regulatory approaches. Bank supervisors have the authority to supervise banks. Developing an international fintech regulatory framework may have its merits in certain circumstances, as is demonstrated by FATF for example, but could be premature regarding the fast-changing digital environment and because most bank supervisors don’t have the authority to provide this oversight within their own jurisdiction let alone across borders.

IBFED Response to BCBS on, 31 Oct 2017