Dear Vice-President,
The Swiss Finance Council (SFC) engages in dialogue around policy developments in finance at a European and international level. It represents the interests of internationally active Swiss financial institutions and provides a source of knowledge and experience in finance for policy-makers and the industry at large.
The SFC would like to thank the European Commission for the opportunity to comment on the consultative document on ‘Fintech, towards a more competitive and innovative European financial sector’. In addition, we are pleased that the Commission set up a cross-sectoral Fintech Task Force and would welcome opportunities to engage on this topic further, in order to contribute to the Commission’s considerations regarding a policy approach towards technological innovation in financial services.
The SFC would like to express its full support for the responses provided to the consultation by the joint trade associations, BBA/Payments UK, AFME and EBF, as well as the letter submitted by the EFR. To complement these responses, we would like to take the opportunity to highlight a few aspects of particular relevance to our members.
We believe that digitalisation can play a pivotal role in transforming Europe into a more competitive ecosystem for innovation that contributes to stronger economic growth and creating new jobs. The financial sector is well placed to facilitate our vision of a ‘global digital ecosystem’ described in our recent Discussion Paper ‘Banks and Investors in a Digital World’, provided technologies continue to develop and are regulated in a way that is technology-neutral, promotes interoperability and unfettered access across borders, whilst ensuring security for all participants.
It is essential that the different aspects covered in the Commission’s consultation are considered not only from the perspective of the EU Single Market but also takes in to account the global dimension which characterises the digital transformation in financial services. We highlight this via concrete challenges in the cross-border context described in our letter.
For a successful EU Digital Single Market (DSM), we emphasise the need to reach out to other global financial centres to align regulatory approaches, possibly seek compatibility and jointly foster innovation. 2 Digitalisation has no borders, if we start to set up borders with varying degrees of regulations or standards on a country-by-country or region by region basis we will stifle the market, provide enough divergence for criminals to leverage and fail at the one of the basic tenants of innovation - competition in a global environment.
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