On behalf of the more than 200 members of the US-China Business Council (USCBC), we appreciate the opportunity to engage with the People’s Bank of China (PBOC) and China Banking and Insurance Regulatory Commission (CBIRC) with regards to the draft revision of the Administrative Measures for Bank Card Clearing Institutions (“draft measures”). USCBC member companies are important stakeholders in China’s financial services and technology industries, and have a strong interest in supporting the continued advancement of China’s financial reform and opening. We believe that further liberalization of China’s financial services industry to foreign competition would advance economic reforms, contribute to upgrading China’s financial markets, and reduce systemic risk.
While China has made steady efforts in the past year in opening its financial technology sector to foreign companies, the draft measures include provisions—some new and others retained from existing measures—that could negatively impact market access and business continuity for foreign electronic payment service (EPS) suppliers.
We also encourage China to incorporate the commitments it made under the WTO decision on EPS suppliers from 2012 into the final measures and would be pleased to work together constructively with PBOC and CBIRC to advance our shared objective of improving China’s financial technology ecosystem for the benefit of Chinese consumers, Chinese businesses, as well as the foreign business community in China.