Trade Barriers in Banking, Securities,

and Other Related Financial Services

General Comments

CSI is deeply committed to the liberalization of trade in banking, securities and related financial

services and is fully supportive of the current bilateral negotiations to reduce or eliminate

discriminatory restraints on foreign participation in financial markets.

Financial services activities contribute to economic growth for individual countries, across

regions and globally, for developed and developing markets alike.  Stability of domestic

financial markets is reinforced by the healthy participation of local and international firms on a

non discriminatory basis who are equally encouraged to invest capital, talent and technology in

environments marked by regulatory strength and transparency.

In order to take advantage of the enormous contribution financial services can make to all sectors

in the negotiating economies, CSI recommends that negotiators achieve substantive

commitments for cross  border and local presence activities consistent with the following goals:

* Remove barriers to establishment by foreign investors in the financial sector and allow

competitive operations through wholly owned subsidiaries, branches or other forms of presence

such as representative offices important to providers of financial services.  Remove "economic

needs tests" and other geographic or product specific restrictions applied with discrimination to

financial firms from abroad. Commit to grandfather investment in operations and activities by

foreign financial firms through presence already established.

* Schedule commitments to support financial services provided cross border without local

establishment and by consumption abroad in order to take advantage of technological and

communications advances and to enable domestic users of financial services to expand their

employment of electronic commerce capabilities.

* Schedule commitments to reflect actions taken to implement transparency in the regulatory

process for financial services. Transparency benefits both regulators and market participants by

reinforcing public consultation in the development of regulations and by the non discriminatory

application of rules and procedures.

* Schedule commitments to facilitate the temporary entry of key financial services personnel

required for managerial, technological, systems or risk managements purposes.

* Schedule commitments to support the provision and transfer of financial information, financial

data processing and the provision of advisory and software related services essential to operation

of financial markets domestically and globally.

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