CBRF Submits Comments to IOSCO on Cross-Border Regulation

Members of the Cross-Border Regulation Forum ("CBRF"), including SIFMA, the Association for Financial Markets in Europe and ISDA, submitted a comment letter to IOSCO regarding the task of cross-border regulation.

In the letter, the CBRF (i) set out the reasons for its belief that effective coordination is important and detailed the possible consequences of sub-optimal coordination, (ii) offered its views on the coordination tools discussed in the IOSCO Report, and (iii) expressed its opinion that IOSCO can and should play a leading role in promoting "coordinated and consistent regulatory approaches."

The CBRF agreed with IOSCO that a "one-size-fits-all" tool for regulatory coordination doesn't exist. However, it commented that of the three tools discussed in the IOSCO Report, "deference" has the greatest advantage for policymakers and market participants. According to the CBRF, global principles for cross-border regulation must be "sufficiently granular to facilitate common interpretations and cross-border deference."

Additionally, the CBRF said that more attention needs to be paid to the legislative phase of regulatory policymaking, and urged individual jurisdictions to "empower" IOSCO to play an enhanced role in the process.

See: CBRF Comment Letter.