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"GFMA wants to take the opportunity to draw your attention to the numerous extraterritorial issues, both new and previously raised, that risk impeding or disrupting the efficient functioning of our global financial markets. In particular, GFMA is concerned about duplicative, incompatible, or conflicting requirements, regulatory uncertainty, and the impact that these will have on competition and consumer choice. Fragmented or conflicting regulation – even when the policy objectives are the same – would negatively impact the ability of market users and participants to raise capital, manage risk and contribute to economic growth.
Through the Financial Markets Regulatory Dialogue (FMRD) and other forums, GFMA respectfully urges you to continue to explore the extent to which the issues that we have identified can be resolved and, to this end, GFMA will be providing its findings to you in the near term. The key issues can be summarised as follows:
Our shared goal and interest is to implement reforms in a coordinated and consistent manner. We emphasise the urgency of addressing these issues and note that the most recent developments on Legal Entity Identifiers (LEIs) and the Foreign Account Tax Compliance Act (FATCA) demonstrate the extent to which the FMRD, and cooperative dialogue between the industry and regulators, can lead to solutions that meet policy objectives within a framework that allows global firms to respond to their clients’ needs."