In its comments, TCH stressed that FX is just one component of cross-border payments and reiterated earlier calls for the public sector to vigorously address compliance-related frictions in such payments. While supporting efforts to further the adoption of PvP settlement in appropriate circumstances, TCH urged the CPMI to recognize safe alternatives to manage FX settlement risk, such as presettlement netting. TCH also emphasized its support to move real-time gross settlement systems toward 24/7 operations, which could facilitate PvP settlement but also provide myriad benefits beyond reduction of FX settlement risk.
TCH urged the public sector to tackle regulatory barriers that inhibit PvP adoption, including by strengthening local rules to ensure robust cross-jurisdictional settlement finality protection, and to advance efforts to report and measure FX settlement risk exposures in a more standardized way. The private sector, TCH noted, is best positioned to provide innovative solutions that support increased adoption of PvP settlement. The private sector is also well positioned to lead efforts to establish an international value date convention, which could enhance the efficiency and effectiveness of FX settlement and contribute to the reliable measurement and monitoring of FX exposures.
To read the full comment letter, click here.