July 29, 2022
Japanese Bankers Association

JBA Comments on “ Developing the Implementation Approach for the Cross-Border
Payments Targets: Interim report ”

We, the Japanese Bankers Association (JBA), appreciate the opportunity to provide
comments on “Developing the Implementation Approach for the Cross-Border
Payments Targets: Interim report”, dated July 6, 2022.
We hope that our comments will contribute to further discussions.

General comment
The measurement of KPIs by using each supporting data source is not clear, making
it difficult for the private sector to assess appropriateness of KPIs, potential sourcesof data, and use of proxies. As a next step, we would suggest the FSB should outreachto each jurisdiction on specific sample of estimated KPIs before finalization, tofacilitate further feedback from the private sector.

Responses to specific questions
1. Has the FSB identified appropriate potential sources of data for efficiently
monitoring progress toward the Roadmap’s targets? What, if any, additional or
alternative public or private data sources should the FSB also consider and for what
KPIs?
[Wholesale target for transparency]
With regard to the target of transparency in interbank settlements, since some banks
do not use SWIFTgpi for interbank transfers, it is not possible to obtain sufficient
data when conducting sample surveys on transactions that include: a. Expected time
to fund delivery, b.Payment tracking status, and c. Terms of service

[Wholesale target for transparency/Retail target for cost]
Regarding ”Sample Survey” we would like to know more details including potential
respondents, survey items, and timing of releasing the survey criteria. Is the survey
criteria planned to be the same every year?
[Retail target for cost]Sample survey of banks and NBPSPs should be well designed following the six
principles presented in the section 1 of the Targets report.

Such survey will

likely entail new data collection. If there is other more promising option such as
certain payment data aggregator, it should be fully explored before determining
scope of survey
Actual costs of cross-border payments are repriced to a lower price according to
the volume of total transactions including lending, deposits etc. Such gap shouldbe mentioned in the “Remaining Gaps” column.

[Retail target for cost/Retail target for speed]
What kind of institutions/entities is assumed as payment data aggregator? Do they
already exist?
[Remittance segment]
World Bank’s survey is one of the most comprehensive data sources for this market
segment, but it sometimes leads to some gaps between the costs paid by survey andthe actual costs. In addition, when considering costs, you should consider using aweighted average based on the transaction volume, and the World Bank's $ 500
remittance survey.

2. Has the FSB defined the KPIs appropriately, such that they are closely andmeaningfully tied to the relevant target? What, if any, additional considerations
should inform the calculation of the KPIs so that they provide sufficiently
representative measurements of progress toward the targets without being overly
burdensome?

We have no comment on this topic.

3. The FSB is evaluating the use of proxies for monitoring progress toward some ofthe targets. Are the proxies proposed appropriate? What, if any, additional or
alternative proxies should the FSB consider that are sufficiently representative andsimplify monitoring?
[Retail target for cost/Retail target for speed]
While use of average transaction size as proxy to identify use case seems to be apractical approach, determination of threshold requires careful study of the datafrom the country.

(End)