Published: March, 2016
The Guidance is timely; the Guidance is extremely valuable; the Guidance is very carefully drafted; the Guidance is comprehensive; the Guidance moves us forward very considerably. The following comments are intended to complement the Guidance in various ways, by highlighting topics or nuances which might usefully receive some additional attention of emphasis or by suggesting additional considerations that might have merited inclusion.
The following paper was prepared by Dr. Daniel Schydlowsky as commentary on the Basel Committee on Banking Supervision’s draft document, “Guidance on the application of the Core principles for effective banking supervision to the regulation and supervision of institutions relevant to financial inclusion.” Dr. Schydlowsky is the former Superintendent of Banks and Insurance in Peru, and currently a fellow at the Mossavar-Rahmani Center for Business and Government at the Harvard Kennedy School. The paper was submitted on behalf of the Center for Financial Inclusion.