The Clearing House Association submitted a letter in response to the Financial Stability Board’s Survey on Cross-Border Payment Services Transparency.   The Association explained that the primary law governing cross-border payment transparency in the U.S. is CFPB’s Remittance Transfer Rule and summarized the rule’s requirements.  Noting that the market for cross-border payments has changed significantly since the rule was adopted in 2013, the Association urged the Board to consider those changes before  making recommendations modeled on it. 

Additionally, the letter explained that the rule applies to senders only and that it would be difficult for institutions to disclose exchange rates and fees to recipients of cross-border transfers.  It further noted that financial institutions have increased payment transparency through use of Swift GPI tracker, Swift Go, and ISO 20022 message specifications that enable disclosure of fees. To read the full letter click here.