March 27, 2023, Washington, DC – FDATA North America today submitted its response to draft regulations from the Bank of Canada and Department of Finance that would implement the Retail Payment Activities Act (RPAA). The letter noted that adoption of these proposed regulations would see as many as 2,500 payment service providers (“PSPs”) overseen under a strong regulatory framework and would, once finalized and implemented, meaningfully advance the modernization of Canada’s financial services marketplace. It also respectfully suggested that the implementation of these regulations should facilitate an expedited inclusion into the scope of Canada’s open banking framework of payment use cases.
The letter strongly supports the objectives of the draft regulations and the underlying Act, but noted the absence of the critical component of end-user education. FDATA therefore suggested that the Bank of Canada and/or the Department of Finance develop an end user education plan to be deployed in concert with the implementation of the draft regulations, and that government work with market stakeholders, including PSPs, in an effort to provide consumers and SMEs with consistent information about the benefits and protections afforded to them under the draft regulations.
FDATA also expressed appreciation for inclusion of a clear timeline within which applications submitted by PSPs would be required to be reviewed by the Bank of Canada and the Department Finance. Since many FDATA members have experienced regulatory delays in application processing in other jurisdictions’ payment modernization and/or open banking frameworks, FDATA welcomes the certainty provided by the regulatory-imposed timelines for consideration of a PSP’s application.