The Clearing House Payments Company and The Clearing House Association, on behalf of its members, submitted comments on draft guidance to implement revised Recommendation 16 (R.16), which addresses payment transparency requirements, released by the Financial Action Task Force (FATF). Overall, The Clearing House supports the Guidance but recommends several clarifications to ensure that R.16 is implemented consistently with FATF’s stated objectives: improving payment transparency while preserving proportionality, interoperability, payment efficiency, data protection, and financial inclusion.

In its comments, The Clearing House urges FATF to develop clearer implementation milestones to support implementation of revised R.16 by the end of 2030; clarify that holistic ongoing monitoring does not require real-time or payment-by-payment alignment checks; recognize that domestic payment market infrastructures should not be required to support cross-border R.16 data requirements for activity their systems do not permit; revise its discussion of debit payments to reflect how certain payment methods operate in practice; and recognize that deposit account numbers, like card account numbers, can be tokenized. In addition to these five key areas, the letter also recommends several other changes to make the guidance more accurate and effective. To read the letter in full, click here.