The Clearing House Association (TCH) submitted comments to the Financial Action Task Force (FATF) in response to its revised proposal to update Recommendation (R.16) and Interpretive Note (INR.16). While the second proposal included a number of improvements, TCH 

• Suggested further refinements to new informational requirements for payment messages,
• Reiterated its request that FATF expand the availability of the exemption for purchases of goods and services made through card networks so that it applies to purchase transactions conducted with a merchant through any payment network that has an AML/CFT risk profile similar to payment card networks, and
• Urged FATF not to prescribe confirmation of payee or beneficiary alignment checks as solutions to push-payment fraud and instead to require that financial institutions apply risk-based pre-payment or post-payment measures designed to mitigate the risk of push-payment fraud.

To ready the full comment letter click, here.