SIFMA recommended a new approach to strengthen cross-border cooperation among regulators to "enhance the coherence of their respective regulations" and "enshrine[] cooperation within legally binding trade agreements." In a paper titled "Bilateral Regulatory Cooperation," SIFMA described current financial regulatory cooperation and offered "a middle way" for future endeavors.
SIFMA explained that typical cooperation arrangements have notable weaknesses that include:
- the lack of predictability or robust processes due to the "ad-hoc nature" of current mechanisms;
- a lack of transparency in existing dialogues;
- minimal consultation with the financial services industry; and
- delayed responses to emerging technologies and developments due to a lack of "forward planning."
SIFMA proposed a model that would address these shortcomings, and urged regulators to incorporate best practice mechanisms that include:
- creating clear timetables;
- issuing clear goals and objectives;
- ensuring transparency;
- consulting with the industry and other stakeholders; and
- a continuous process of following up.
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