The FSB is conducting a survey as part of its work under Building Block 6 of the Roadmap for enhancing Cross-border Payments, where the FSB agreed to conduct a stocktake of existing national and regional data frameworks relevant to the functioning, regulation and supervision of cross-border payment arrangements, and to identify issues relating to cross-border use of those data by national authorities and by the private sector. 

The FSB wishes to gather stakeholders’ feedback in order to better understand how requirements applicable to data – e.g., where and what data must be stored/retained, where it may be transferred, the rules governing the security or access to data, could affect (either enabling or impeding) cross-border payments, by potentially affecting cost, speed, access, security of cross-border payments, or interoperability of cross-border payment networks. Stakeholder views are also requested on what any potential frictions are, as well as which policies are most effective.

Many of the frictions contributing to these challenges arise from their cross-jurisdictional nature. One of the key topics to consider is how existing national and regional data frameworks interact with and affect the functioning, regulation and supervision of cross-border payment arrangements. 

Data Frameworks within scope include:

  • Domestic data frameworks, including rules, regulations, guidelines and supervisory guidance, that affect the provision of - or access to - cross-border payment services in one or more jurisdictions, or the manner in which those services utilize cross-border payments data in one or more jurisdictions, such as:

    • Frameworks regulating access to data, such as open banking frameworks

    • Frameworks regulating data privacy, security or storage, such as data location requirements, electronic communications, data sharing with use of third-party providers

    • Requirements for data retention, e.g., required data items for regulatory compliance

    • Multilateral, bilateral trade agreements covering use and sharing of data across borders

  • Implementation of international standards from the FSB and other standard-setting bodies, including BCBS, CPMI, FATF, IAIS, IOSCO, if not included as part of formal domestic data frameworks.

  • Other international efforts, arrangements, or agreements that jurisdictions may implement in their domestic data frameworks or that may affect cross-border data flows.

In particular, the FSB invites feedback from banks, non-banks, financial market infrastructures, academics and industry associations on the following issues:

  1. How, in your view, do data-specific requirements or objectives of existing national and regional data frameworks, such as those listed above, currently affect (either positively or negatively):

    1. the cost and speed of delivering payments,

    2. access and transparency (e.g., through compliance costs or through measures enabling or reducing competition) and

    3. other aspects that affect the delivery of, or regulatory compliance with respect to, cross-border payments?

  2. More specifically, what barriers to cross-border use of data do you see in existing data frameworks that will impede our ability to address the four challenges faced by cross-border payments?

  3. What areas of improvement could you suggest in data frameworks in order to overcome these barriers? Are there effective practices you would highlight to the FSB membership?

  4. Can approaches to data frameworks in one jurisdiction impact the provision or supervision of cross-border payments services in other jurisdictions? Are there particular issues that you would like to highlight?

  5. Are there particular payment corridors (especially related to emerging markets) that you wish to highlight to the FSB as facing specific challenges relating to data frameworks?

Responses to the survey will support FSB member authorities in the analysis of the constraints on cross-border data flows imposed by existing national and regional data frameworks.

Please submit your feedback via the online survey. The survey closes on Friday 14 January 2022 at 08:59 AM CET.

For questions please contact the FSB.