Likewise, CPMI’s planned publication of final harmonization requirements in late 2023, with a November 2025 effective date, will put U.S. ISO 20022 implementations at risk for delay. Hence, CPMI should allow both CHIPS and the Fedwire Funds Service to complete their migrations before proposing changes to ISO 20022 standards. If such an extension cannot be accommodated, TCH suggests not only extending the public consultation period to June 30, 2023, but also issuing harmonization standards as recommendations rather than requirements. TCH also asked that CPMI more clearly state its intentions regarding whether non-ISO based systems will need to accommodate the data that would be required under Proposed Harmonization Requirements. If there are expectations for non-ISO based systems, CPMI should conduct outreach to the operators and participants of such systems and allow additional time beyond June 30, 2023, for non-ISO 20022-based payment systems to review and respond to the Consultative Report.
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