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fintech commentary letter GFIN

Comment Letter to the Global Financial Innovation Network 

Oct 15, 2018

The Global Financial Innovation Network (GFIN), composed of 11 regulatory authorities from around the world, is seeking to formally launch an effort that would potentially lead to greater regulatory collaboration through information sharing efforts, testing initiatives, and the development of a global regulatory sandbox.

The GFIN requested comments regarding how this effort can best address the various challenges related to innovative firms offering products and services across borders. The Milken Institute Center for Financial Markets identified the following recommendations and questions for the effort.

Recommendations

  • Develop a list of problem statements at the outset that the GFIN looks to address.
  • Think big, but start small. The GFIN should focus on two of its three core functions at the outset before even considering the development of a global sandbox.
  • Recommend against the creation of a Steering Committee due to regulatory competitiveness concerns.

Key Questions for the GFIN 

  • What specific steps will the GFIN take to work with regional, multi-jurisdictional efforts to harmonize cross-border regulations?
  • How will the GFIN capture and quantify whether its three core functions have contributed to, or been directly responsible for changes to existing regulatory approaches?