The Wolfsberg Group (the Group) is pleased to provide a response to the FSB’s consultations on Recommendations for Regulating and Supervising Bank and non-bank Payment Service Providers Offering Cross-border Payment Services, and Recommendations to Promote Alignment and Interoperability Across Data Frameworks Related to Cross-border Payments. The business of cross-border payments is core to many of our members and is more complex than may appear at first glance and we welcome the opportunity to be part of the dialogue on this topic and contribute our members’ expertise gained by through processing many millions of payments every month. As set out in previous publications, the Group believes strongly in the principle of ‘same business, same risk, same rules’ to ensure a level playing field across the different types of entities that facilitate cross-border payments and we welcome the issuance of clear guidance around the common practice of payment bundling for all parties involved that sets out clear roles and responsibilities for parties within the payment chain as they relate to bundled payments. All parties to a payment chain have obligations that should be explicit, including the payment market infrastructures or financial market infrastructures that are used to send payment information.