On April 18, 2025, BAFT responded to the second public consultation on the Proposed revisions to R.16 (the “consultation”).
Click below to read the comment letter in its entirety.
Policy News
BAFT Publishes Updated Master Trade Loan Agreement (MTLA) – 2025 English Law
The 2025 Master Trade Loan Agreement (MTLA) is designed as an industry-standard document used for lending between financial institutions to finance or refinance specified trade transactions. The 2025 MTLA – English Law reflects changes based on current market expectations, law, and practice including the demise of LIBOR, and the impact of Brexit―as EU Law no longer applies to the UK.
Click on the link below to read more about the 2025 MTLA.
BAFT Comment Letter to the USTR to Identify Unfair Trade Practices
On March 11, BAFT submitted a letter in response to USTR’s request for comments to assist in reviewing and identifying unfair trade practices and initiating necessary actions to investigate harm from non-reciprocal trade arrangements.
Click on the link below to access the comment letter.
BAFT Comment Letter to the Federal Reserve in Response to Expansion of Fedwire Funds Service and National Settlement Service Operating Hours
On September 6, 2024 BAFT made its’ submission to the Board of Governors of the Federal Reserve System in response to the Expansion of Fedwire Funds Service and National Settlement Service Operating Hours
Click on the link below to access the comment letter.
BAFT Response to FSB Recommendations for Regulating and Supervising Bank & Non-Bank Payment Service Providers Offering Cross-Border Payment Services Consultation Report
On September 2, 2024 BAFT made its’ submission to the Financial Stability Board (FSB) in response to the Recommendations for Regulating and Supervising Bank and Non-Bank Payment Service Providers Offering Cross-Border Payment Services Consultation Report.
Click on the link below to access the comment letter.
BAFT White Paper Explores Uneven Regulations in the Payments Industry
WASHINGTON – BAFT, the leading global financial services association for international transaction banking, today released a new white paper, “Uneven Regulations in the Payments Industry.” The paper sheds light on the disparities and challenges in regulatory frameworks governing the global payments landscape.
This comprehensive publication offers a deep dive into the complexities of payment regulation and its implications for financial institutions, fintech firms, regulators, and consumers alike.
“In an era of rapid technological advancement and evolving payment methods, the regulatory environment has struggled to keep pace, resulting in a patchwork of regulations across jurisdictions,” said Deepa Sinha, vice president for payments & financial crimes, BAFT. “BAFT’s white paper serves as a vital resource for industry stakeholders seeking to navigate this complex regulatory landscape and advocate for greater harmonization and standardization.”
Key highlights of the white paper include:
- Overview of Payment Regulations: It examines the diverse approaches taken by regulatory bodies in different jurisdictions around the world. From traditional banking regulations to emerging fintech regulations, it analyzes the regulatory frameworks governing various payment instruments, including cards, digital wallets, real-time payments, and cross-border transactions.
- Challenges and Inconsistencies: The paper explores the fragmentation, duplicative requirements, and conflicting mandates in existing regulation that hinders interoperability and innovation in the payments ecosystem.
- Impact on Market Participants: It offers an analysis of the compliance burden, operational costs, and market access barriers imposed by divergent regulatory requirements and how these uneven regulations impact financial institutions, fintech firms, payment service providers and consumers. It also discusses the implications for competition, consumer protection, and financial inclusion in an increasingly globalized payments landscape.
- Regulatory Convergence: The paper takes a closer look at potential pathways for collaboration among regulatory bodies at the domestic, regional, and international levels.
- Industry Recommendations: It provides an outline of strategies and practical recommendations to promote regulatory convergence, streamline compliance processes, and enhance the efficiency and effectiveness of payment regulation.
- Call to Action: Lastly, it includes a push for industry stakeholders to work towards an inclusive, competitive, and fair environment in which consumers will effectively benefit from a broad and safe offering, while still maintaining provider profitability and sustainability.
Click here to read BAFT’s Uneven Regulations in Payments. The white paper is also available within BAFT’s Library of Documents under the Guidance and Industry Practices section.
About BAFT
BAFT, the leading global financial services association for international transaction banking, helps bridge solutions across financial institutions, service providers and the regulatory community that promote sound financial practices enabling innovation, efficiency, and commercial growth. BAFT engages on a wide range of topics affecting transaction banking, including trade finance, payments, and compliance.
BAFT Media Contact:
Blair Bernstein
Senior Director, Public Relations
[email protected]
+1 (202) 663-5468