Canada

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FDATA North America Submits Comments to Canada’s Department of Finance in Response to 2022 Budget Consultation

February 22, 2022, Washington, DC – Today, the Financial Data and Technology Association (FDATA) of North America submitted comments to the Canadian Department of Finance, Finance Minister Chrystia Freeland and Associate Minister Boissonnault as part of the Canadian government’s 2022 Pre-Budget consultation.

With the resumption of Parliament, and Budget 2022 planning well underway, our letter urged the Department to fully implement all phases of the Advisory Committee on Open Banking’s recommendations, which lay out a thoughtful, well-researched approach to building a “made in Canada” open finance system that puts consumers and small businesses at the center of a more competitive financial marketplace.

Our letter also clarified that the first step to achieving this important goal, and to provide market stakeholders with a legally binding policy framework under which such a regime can be delivered, is to appoint an Open Banking Lead, which should be responsible for working with industry and government stakeholders to create the policy and governance standards under which open finance can be delivered in early 2023.

We also called on the government to begin work on the Advisory Committee’s second phase, which must include write access – a critical component of account creation and account switching capabilities – as well as modernization of the Canadian Payments Act to ensure payments service providers, including credit unions and fintechs, have access to the critical Payments Canada system. As we say in the letter, these are thorny issues which require much consideration and engagement and will take time to get right. 

Image result for paperclip iconFDATA Finance Canada Budget 2022 submission


ABOUT FDATA NORTH AMERICA
FDATA was heavily involved in the UK Open Banking Working Group in 2015. In 2016, the working group’s output was published by Her Majesty’s Treasury as the Open Banking Standard. FDATA North America was founded in early 2018. Its members collectively provide tens of millions of consumers in Canada, the United States, and Mexico with aggregation-based tools to better manage their finances.

Members include air (Alliance for Innovative Regulation), APImetrics, Basis Theory, Betterment, BillGo, Codat, Direct ID, Envestnet Yodlee, Equitable Bank, Experian, Finansystech, Fiserv, Flinks, Interac, Intuit, Inverite, Kabbage, Mogo, Morningstsar, M Science, MX, Petal, Plaid, Questrade, Rocket Mortgage, SaltEdge, Trustly, ValidiFI, Vaultree, VoPay, Wealthica, Xero, and others.

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FDATA North America Submits Comments to OSFI’s Consultation on Technology and Cyber Risk Management

February 7, 2022, Washington, DC – Today, the Financial Data and Technology Association (FDATA) of North America submitted comments to the Office of the Superintendent of Financial Institutions (OSFI) as part of its public consultation on Draft Guidance B-13: Technology and Cyber Risk Management.

Throughout the response, FDATA North America discussed the interplay between B-13 and the development of open banking in Canada, particularly that the harmonization of efforts between the Department of Finance’s open banking work and OSFI’s approach to third-party cybersecurity risk will be essential. FDATA North America’s Executive Director Steve Boms noted that as OSFI develops its technology guidelines for third-party technology partners to banks, “we respectfully offer that significant consideration has already been undertaken on this issue by the Department of Finance, and stakeholders would benefit from some form of public documentation that clearly distinguishes OSFI’s authority and responsibilities with regards to third-party financial technology providers from those of the Department of Finance as it works to implement a Canadian open banking system.” Boms noted that publicly clarifying how these two projects will interact will provide clear direction to the marketplace about how third-party providers can continue to offer their valuable financial services and products in an innovative, competitive marketplace. 

Additionally, FDATA North America touched on the importance of clarification from OSFI that providers with whom consumers engage directly, without any intervention from their federally regulated financial institution (FRFI), do not fall under the B-13 framework. Thus, the goal of the consultation should be to ensure that FRFIs third-party risk management requirements mirror their ability to oversee entities with whom they have direct relationships, and not to overburden FRFIs with system-wide oversight that instead “should fall to a collaborative regulatory effort including Finance Canada’s open banking accreditation regime.”

Boms concluded by noting that in order to facilitate enhanced market competition and customer choice, “it is imperative that OSFI with the Department of Finance to harmonize regulatory expectations of customer-selected financial providers as open banking takes hold in Canada.”

Image result for paperclip iconFDATA North America Submission to OSFI’s B-13 Consultation on Technology and Cyber Risk Management


ABOUT FDATA NORTH AMERICA
FDATA was heavily involved in the UK Open Banking Working Group in 2015. In 2016, the working group’s output was published by Her Majesty’s Treasury as the Open Banking Standard. FDATA North America was founded in early 2018. Its members collectively provide tens of millions of consumers in Canada, the United States, and Mexico with aggregation-based tools to better manage their finances.

Members include air (Alliance for Innovative Regulation), APImetrics, Basis Theory, Betterment, BillGo, Codat, Direct ID, Envestnet Yodlee, Equitable Bank, Experian, Finansystech, Fiserv, Flinks, Interac, Intuit, Inverite, Kabbage, Mogo, Morningstsar, M Science, MX, Petal, Plaid, Questrade, Rocket Mortgage, SaltEdge, Trustly, ValidiFI, Vaultree, VoPay, Wealthica, Xero, and others.

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FDATA North America Joins Industry Trade Groups in Letter to Department of Finance on Implementation of Recommendations from the Advisory Committee on Open Banking Report

November 10, 2021, Washington, DC – Last week, the Financial Data and Technology Association (FDATA) of North America, along with the Paytechs of Canada Association and the Canadian Lenders Association (CLA), sent a joint letter to Finance Minister Chrystia Freeland requesting that the Department adopt the phase one and two recommendations of the Advisory Committee on Open Banking report and urging its public support for the same.

In the letter, the groups, whose organizations represent nearly 250 financial technology companies, emphasize the importance of swift implementation of the recommendations to ensure Canada remains competitive in the global market. Countries around the world, from the United Kingdom and New Zealand to Australia and the United States, have seen marked improvements in financial access and inclusion through open finance products delivered by technology-based financial services providers. “By contrast, Canadian consumers or small businesses have no legally binding right to their own financial data, which stifles competition and innovation in the financial services marketplace,” the groups state. 

Additionally, the groups state that a delay of implementation of the Advisory Committee’s recommendations open the door for some of Canada’s large financial institutions to dismiss the government’s intention to deliver open finance in line with the report’s recommendations, which undermine the certainty around the commitments.

“It is critically important that the government confirm to financial institutions, financial technology companies, and Canadian consumers and small businesses its intention to implement an open finance regime in line with all of the Advisory Committee’s recommendations,” the groups state. Specifically, they point to the appointment of an open banking lead “as soon as possible,” creating a legally binding financial data right, and beginning work on the Advisory Committee’s second phase, “which must include payment initiation and account creation capabilities, as well as a formal governance entity.” 


ABOUT FDATA NORTH AMERICA
FDATA was heavily involved in the UK Open Banking Working Group in 2015. In 2016, the working group’s output was published by Her Majesty’s Treasury as the Open Banking Standard. FDATA North America was founded in early 2018. Its members collectively provide tens of millions of consumers in Canada, the United States, and Mexico with aggregation-based tools to better manage their finances.

Members include air (Alliance for Innovative Regulation), APImetrics, Basis Theory, Betterment, BillGo, Codat, Direct ID, Envestnet Yodlee, Equitable Bank, Experian, Finansystech, Fiserv, Flinks, Interac, Intuit, Inverite, Kabbage, Mogo, Morningstsar, M Science, MX, Petal, Plaid, Questrade, Rocket Mortgage, SaltEdge, Trustly, ValidiFI, VoPay, Wealthica, Xero, and others.

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Member Spotlight: Interac


In 1984, Canada’s top financial institutions came together to create Interac Association, a cooperative venture dedicated to giving Canadians broader access to their money through a single shared network. Twelve years later, eight of the founding institutions created Acxsys Corporation, a new entity that would develop new business partnerships and services for financial transfer, online payments, and international services.

To better fund innovation and reduce certain business, operating and legal complexities, the two entities reorganized in 2018 to form Interac Corp. Today, Interac is one of the most trusted financial service brands in Canada, operating an economical, world-class debit payments system with broad-based acceptance, reliability, security, and efficiency, helping more than 30 million Canadians families and businesses feel more in control of their money.

The Interac team are natural collaborators. They know that the benefits of co-operation outweigh the risks of fragmentation. The diversity of thought that exists when companies (and even competitors) come together produces better outcomes and solutions. Interac is a proud member of FDATA North America and is actively working with industry and government colleagues across the ecosystem to explore open banking solutions for Canadians.

The financial services company’s Innovation Lab and New Ventures team has a mandate to look ahead at the company’s three plus year horizon for new innovations. They research, develop strategies and pilot new solutions before taking them to market.

A foundational requirement of emerging solutions is to build consumer trust. Canadians need to trust that new technology is not only secure, but that it will provide meaningful benefits in their lives. A recent Interac survey found being in control of their financial data is important to 90 per cent of respondents, and more than half said a new financial data sharing option will “greatly benefit” Canadian consumers.

At Interac, leaders share in this optimism for open banking to support consumer needs and they are committed to collaborating with financial institutions and fintech companies and serving as a bridge for the ecosystem. The team sees great promise for Canada’s future open banking framework to enable the development of data-driven products and services that will increase access to affordable solutions tackling pressing personal and business needs such as debt reduction, benefits processing, financial planning, and the provision of faster loans.

Oscar Roque, VP, Strategy and Emerging Solutions at Interac, sees an opportunity to form a minimum viable ecosystem (MVE) for open banking, grounded in a clear, easy, and transparent consent experience. “Our collective participation in building an MVE will set the stage for data portability and empower Canadians to take control of their data – all for the betterment of our society.”

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FDATA North America Submits Comments to Ontario’s Privacy Protection Engagement Consultation

September 3, 2021, Washington, DC – Today, the Financial Data and Technology Association (FDATA) of North America submitted comments to Ontario’s consultation on efforts to strengthen and modernize privacy protections in the province. 

In its comments, FDATA North America called on the Ontario government to include a legally binding financial data access and portability right in any forthcoming data protection legislation or regulation. Executive Director Steve Boms pointed to other countries around the world who have provided legally binding data access, privacy, and portability regimes for their citizens and pointed to existing statutory and regulatory protections that work towards achieving this goal. “Ontario, and Canada more broadly, must support the rights of individuals to access and transfer their financial data, through data portability, to keep pace with other international standards that consider this right to be a key feature of a modern privacy regime,” Boms noted. 

In order to build an ecosystem in which Ontarians’ financial data is protected while providing for the right to benefit from data access and data portability rights, Boms highlighted the importance of competition and adequate protections for data privacy and security in a data-driven financial services ecosystem. Doing so will deliver lower costs, better services, and better outcomes for consumers’ and small business’ financial outcomes, he stated. Boms noted that approximately four million Canadians already utilize at least one financial technology application which relies on consumer consent and enables them to control which providers they allow to access their data, how their data is being used, and when access to their data is revoked. 

Boms concluded by noting that while the federal government moves forward slowly, Ontario can – and should – provide for stronger financial data access rights for its residents more quickly. 

Image result for paperclip iconFDATA North America Submission to Ontario Government on its Privacy Protection Engagement Consultation


ABOUT FDATA NORTH AMERICA
FDATA was heavily involved in the UK Open Banking Working Group in 2015. In 2016, the working group’s output was published by Her Majesty’s Treasury as the Open Banking Standard. FDATA North America was founded in early 2018. Its members collectively provide tens of millions of consumers in Canada, the United States, and Mexico with aggregation-based tools to better manage their finances.

Members include air (Alliance for Innovative Regulation), APImetrics, Basis Theory, Betterment, BillGo, Codat, Direct ID, Envestnet Yodlee, Equitable Bank, Experian, Fiserv, Flinks, Interac, Intuit, Inverite, Kabbage, Marble, Mogo, Morningstsar, M Science, MX, Petal, Plaid, Questrade, Quicken Loans, SaltEdge, Trustly, ValidiFI, VoPay, Wealthica, Xero, and others.

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FDATA North America Submits Comments to Alberta’s Privacy Protection Engagement Consultation

August 18, 2021, Washington, DC – Today, the Financial Data and Technology Association (FDATA) of North America submitted comments to Alberta’s consultation on efforts to strengthen and modernize privacy protections in the province. 

In its comments, FDATA North America called on the Alberta government to include a legally binding financial data access and portability right as it considers how best to promulgate data privacy standards in the province. FDATA North America Executive Director Steve Boms noted that a holistic and evidence-based approach should be taken “that recognizes the importance of data access and portability for consumers and small businesses across the province” while taking into account the realities of modern technology and digital business. 

In order to build an ecosystem in which Albertans’ financial data is protected while providing for the right to benefit from data access and data portability rights, Boms highlighted the importance of competition and adequate protections for data privacy and security in a data-driven financial services ecosystem. Doing so will deliver lower costs, better services, and better outcomes for consumers’ and small business’ financial outcomes, he stated. Boms noted that approximately four million Canadians already utilize at least one financial technology application which relies on consumer consent and enables them to control which providers they allow to access their data, how their data is being used, and when access to their data is revoked. 

Boms concluded by noting that while the federal government moves forward slowly, Alberta can – and should – provide for stronger financial data access rights for its residents more quickly. 

Image result for paperclip iconFDATA North America Submission to Alberta Government on its Privacy Protection Engagement Consultation


ABOUT FDATA NORTH AMERICA
FDATA was heavily involved in the UK Open Banking Working Group in 2015. In 2016, the working group’s output was published by Her Majesty’s Treasury as the Open Banking Standard. FDATA North America was founded in early 2018. Its members collectively provide tens of millions of consumers in Canada, the United States, and Mexico with aggregation-based tools to better manage their finances.

Members include air (Alliance for Innovative Regulation), APImetrics, Basis Theory, Betterment, BillGo, Codat, Direct ID, Envestnet Yodlee, Equitable Bank, Experian, Fiserv, Flinks, Interac, Intuit, Inverite, Kabbage, Marble, Mogo, Morningstsar, M Science, MX, Petal, Plaid, Questrade, Quicken Loans, SaltEdge, Trustly, ValidiFI, VoPay, Wealthica, Xero, and others.

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FDATA North America Submits Comments to Canada’s Standing Committee on Finance Pre-2022 Budget Consultations

August 3, 2021, Washington, DC – Today, the Financial Data and Technology Association (FDATA) of North America submitted comments to Canada’s Standing Committee on Finance (FINA) as part of its pre-budget consultations in advance of the 2022 budget.

In its comments, FDATA North America called on the government to fully embrace a digital-first future for its financial sector as well as a consumer-centric model for its privacy arena, and pointed to a customer-directed finance (CDF) environment as a cornerstone of this future system. This new legal framework will “improve access to financial services, ensure a more level regulatory system for financial service providers, improve competitiveness, and foster innovation, all of which will contribute to health and sustained macroeconomic growth.” 

To achieve a modernized open finance system that mitigates risks and protects consumers and small businesses by ensuring that providers’ privacy protections meet regulatory standards, that customer privacy is assured regardless of whether their chosen service provider is a financial institution or non-bank fintech, and recourse mechanisms to make consumers affected by a data breach whole, FDATA North America suggests that the government should include language in Budget 2022:

  1. implementing a CDF regime that include clear definitions of consumer and small business financial data rights, scope, and portability; and
  2. to enshrine a new CDF Implementation Entity (IE) tasked with the design and implementation of open finance in Canada. 

Without this framework, Canada will remain in a financial status quo where consumers and other end users lack control of their personal information and cannot benefit from financial innovation. By delaying this approach, FDATA North America argues that Canada risks falling further behind as a world leader in digital innovation and misses an opportunity to provide cutting-edge financial services to its consumers and small businesses.

Image result for paperclip iconFDATA North America Submission for the Pre-Budget Consultations in Advance of the Upcoming Federal Budget


ABOUT FDATA NORTH AMERICA
FDATA was heavily involved in the UK Open Banking Working Group in 2015. In 2016, the working group’s output was published by Her Majesty’s Treasury as the Open Banking Standard. FDATA North America was founded in early 2018. Its members collectively provide tens of millions of consumers in Canada, the United States, and Mexico with aggregation-based tools to better manage their finances.

Members include air (Alliance for Innovative Regulation), APImetrics, Basis Theory, Betterment, BillGo, Codat, Direct ID, Envestnet Yodlee, Equitable Bank, Experian, Fiserv, Flinks, Interac, Intuit, Inverite, Kabbage, Marble, Mogo, Morningstsar, M Science, MX, Petal, Plaid, Questrade, Quicken Loans, SaltEdge, Trustly, ValidiFI, VoPay, Wealthica, Xero, and others.

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FDATA North America Options for Governance of Customer-Directed Finance in Canada

FDATA North America Options for Governance of Customer-Directed Finance in Canada

Earlier this year, Canada’s Open Banking Advisory Committee submitted recommendations to the Minister of Finance regarding the need for a customer-directed finance regime in Canada. Quite a lot has happened since then – both globally and in the financial technology sector – but the Department of Finance has continued to consider how to deliver customer-directed finance in Canada.

As the department enters the second phase of its consultative process, FDATA North America provided several suggestions that should act as a guide for the deployment of a successful open finance regime, gleaned from experience in other markets.

FDATA North America’s suggested governance models note that the core of any successful framework is a customer data right – and that only government can implement this open finance tenet, and that it is the foundation of every successful customer-directed finance framework globally. The document warns that a customer-directed finance model that defers decisions around data rights to industry results in an ecosystem in which incumbents are further empowered to determine how much control their customers may have over their data – to the detriment of competition, innovation and financial access.

As such, the document proposes governance models with the strong recommendation that industry alone cannot deliver customer-directed finance but can provide technology solutions that meet the policy standards set by government.

Image result for paperclip iconFDATA North America’s suggested governance models


ABOUT FDATA NORTH AMERICA
FDATA was heavily involved in the UK Open Banking Working Group in 2015. In 2016, the working group’s output was published by Her Majesty’s Treasury as the Open Banking Standard. FDATA North America was founded in early 2018. Its members collectively provide tens of millions of consumers in Canada, the United States and Mexico with aggregation-based tools to better manage their finances. Existing FDATA North America members include: air (Alliance for Innovative Regulation), API Metrics, Betterment, Direct ID, Envestnet Yodlee, EQ Bank, Experian, Fintech Growth Syndicate, Fiserv, Flinks, Interac, Intuit, Kabbage, Mogo, Morningstsar, M Science, MX, Petal, Plaid, Questrade, Quicken Loans, TransUnion, Trustly, ValidiFI, VoPay, Wealthica, Xero, and others.

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FDATA North America Outlines Competition Issues Surrounding Open Banking

FDATA North America Outlines Competition Issues Surrounding Open Banking

Contact: Kerrie Rushton, (202) 365-6338, [email protected]

July 17, 2020, Washington, DC – Today, the Financial Data and Technology Association (FDATA) of North America released a paper on competition issues surrounding customer-directed finance and the financial data access competitive landscape in Canada. The paper’s release comes ahead of a virtual presentation by FDATA North America Executive Director Steve Boms, Senator Colin Deacon, and Michael Binetti, partner at Affleck Greene McMurtry LLP.

A replay of the webinar can be found here.

Consumers and small businesses in Canada have become increasingly reliant on financial services and products offered by financial technology (“fintech”) providers. Today, as many as four million Canadians utilize fintech tools to improve their financial wellbeing. Regardless of the type of product or service offered by fintech firms, all rely on the ability of the consumer or small business to grant them access to their financial data, which is typically held at a financial institution.

The paper, “Competition Issues in Data-Driven Consumer and Small Business Financial Services in Canada,” outlines how restrictions on consumer-directed access to individual financial data raise serious competition concerns in the market for data-driven financial services and underscores the need for the Canadian government to advance a customer-directed finance ecosystem.

“The financial impact from COVID-19 – and the government’s refusal to allow fintech lenders to participate in its response – is the latest in a growing string of examples that underscore the need for Canada to have a customer-directed finance regime as soon as possible,” said Senator Colin Deacon. “FDATA North America’s paper makes clear that the absence of such a regime is actively thwarting competition in the financial marketplace. Accordingly, I urge the Department of Finance to expedite its consultation process and to submit to Parliament draft legislation as soon as possible that would allow Canada to join the growing number of innovative economies that provide consumers and small businesses choice and autonomy over their financial data.”

Highlights from “Competition Issues in Data-Driven Consumer and Small Business Financial Services in Canada”:

  • The innovation in financial services is powered by consumers and small businesses granting permission for access and use of their data, often in conjunction with cutting edge machine learning and other data analytics technology.
  • As consumers and businesses face a deteriorating economic landscape, it is critical to maintain competition in the market for these data-driven financial services.
  • Competition issues cannot take a back seat as the regulatory and technological framework in data sharing continues to evolve. As open finance develops, competition laws provide a critical backstop to ensure that existing competition in the market for data-driven consumer financial services is not stifled.

Click here to read the paper.


ABOUT FDATA NORTH AMERICA
FDATA was heavily involved in the UK Open Banking Working Group in 2015. In 2016, the working group’s output was published by Her Majesty’s Treasury as the Open Banking Standard. FDATA North America was founded in early 2018. Its members collectively provide tens of millions of consumers in Canada, the United States and Mexico with aggregation-based tools to better manage their finances. Existing FDATA North America members include: air (Alliance for Innovative Regulation), API Metrics, Betterment, Direct ID, Envestnet Yodlee, EQ Bank, Experian, Fintech Growth Syndicate, Fiserv, Flinks, Interac, Intuit, Kabbage, Mogo, Morningstsar, M Science, MX, Petal, Plaid, Questrade, Quicken Loans, TransUnion, Trustly, VoPay, Wealthica, Xero, and others.

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