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BAFT Comments on OCC Whitepaper on Innovation

by Patrick Devilbiss | May 31, 2016
Today, BAFT submitted a comment letter to the OCC in response to their white paper on innovation released in March. Read the comment letter

BAFT, a global association of organizations engaged in international transaction banking, commended the OCC for initiating important public dialogue on financial services innovation and made five key recommendations:

  1. Modernize the regulatory model and adopt principles similar to those in the Framework for Global Electronic Commerce of 1996, specifically as it relates to distributed ledger technology (DLT).
  2. Allow the private sector to lead and consider a ‘regulatory sandbox’.
  3. Take time to monitor developments in the early stages and defer regulation to avoid unintended consequences or stifling innovation.
  4. When necessary, regulate according to risk of the activity, not the technology utilized.
  5. Coordinate with other regulatory authorities (both nationally and internationally) to facilitate innovation on a global basis. This will help avoid overlapping, complex requirements and ensure consistency and competition.
The full comment letter can be found here.