Financial Data and Technology Association of North America

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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comments to the Office of the Superintendent of Financial Institutions (OSFI) as part of its public consultation on Draft Guidance B-13: Technology and Cyber Risk Management.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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FDATA North America Congratulates Chopra on Confirmation, Calls for Speedy Action on Open Finance Regulation

 

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

September 30, 2021, Washington, DC – The Financial Data and Technology Association (FDATA) of North America today issued a statement following the successful Senate confirmation for Rohit Chopra to be director of the Consumer Financial Protection Bureau:

“We congratulate Mr. Chopra on his confirmation and are eager to work with him and CFPB staff to advance an open finance regime in the United States. Section 1033 of the Dodd-Frank Wall Street Reform and Consumer Protection Act authorizes the CFPB to establish by regulation a consumer financial services data right in the United States. The Obama administration recognized a customer’s inherent right to their financial data, and so did the Trump administration. President Biden’s recent competition executive order similarly called for the CFPB to quickly issue a regulation honoring Section 1033. Now that Chopra is confirmed, that work can — and must — move forward.

“With nations across the world moving toward open banking, U.S. policymakers must work quickly to implement a customer-centric, 21st century financial services marketplace that boosts competition, better protects consumers, and helps improve financial inclusion.”

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, EQ Bank, Experian, 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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FDATA North America Submits Comments to US House Consumer Protection Subcommittee on the Future of Banking

September 29, 2021, Washington, DC – Today, FDATA North America submitted a letter for the record for the U.S. House Financial Services Committee’s Subcommittee on Consumer Protection and Financial Institutions hearing “The Future of Banking: How Consolidation, Nonbank Competition, and Technology are Reshaping the Banking System.” The letter outlines FDATA North America’s mission to advocate for a financial ecosystem in which the end user has complete utility of their financial data.

Throughout the letter, FDATA North America Executive Director Steve Boms highlighted the steps necessary for the Consumer Financial Protection Bureau (CFPB) to promulgate, by rule, a customer financial data right that will spur greater financial services innovation and competition as well as improve consumer financial access and inclusion and the importance of the subcommittee in . “As the CFPB works to promulgate a proposed rule under Section 1033 of the Dodd-Frank Act to improve competition in the financial services system, we hope that the subcommittee will continue to examine this vitally important space and encourage the Bureau to use its statutory authority to create a customer-centric, safe, competitive, and secure open finance system in the United States,” Boms stated.

To accomplish the goal of leveling the playing field for consumers and small businesses, expanding financial access and inclusion, improving competition in the financial services marketplace and, on a global level, ensuring that the United States’ financial services system remains competitive internationally, FDATA North America outlined its recommendations to the Bureau that it utilize its Section 1033 authority to issue a rule that adheres to five key principles:

  1. Create a legally binding customer financial data right;
  2. Define and clear enumerate the limited circumstances in which custodians of financial data may override customer consent;
  3. Supervise financial data aggregation firms;
  4. Coordinate with the prudential regulators on Regulation E modernization; and
  5. Recognize the need to permit current and legacy technology

Boms noted that the combination of these principles “would provide consumers and small businesses with safe, secure access to their financial data and, by extension, to critically important financial applications and tools that can meaningfully improve their financial wellbeing.”

Image result for paperclip iconFDATA North America Letter for the Record on the Future of Banking

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, Mogo, Morningstsar, M Science, MX, Petal, Plaid, Questrade, Rocket Mortgage, SaltEdge, Trustly, ValidiFI, VoPay, Wealthica, Xero, and others.

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FDATA North America Submits Comments to US Financial Regulators’ Request for Comment on Managing Risks Associated with Third-Party Relationships

September 23, 2021, Washington, DC – Today, the Financial Data and Technology Association (FDATA) of North America submitted comments to the US financial regulators as part of their proposed interagency guidance and request for comment on managing risks associated with third party relationships. The Federal Reserve, Federal Deposit Insurance Corporation (FDIC), and Office of the Comptroller of the Currency (OCC) sought comments on proposed guidance on sound risk management principles for banking organizations to consider in developing risk management practices for third-party relationships. In its response, FDATA North America expressed that streamlining the ability for banks to partner with third-party providers will be critical to the survival of small and community banks in the United States and to the financial wellness of their customers. 

Throughout the submission, FDATA North America Executive Director Steve Boms discussed the scope, tailored approach, and information security around these relationships from the perspective of the aggregation and fintech community. “Though the proposed guidance is directed toward insured depository institutions, it directly impacts third-party providers which [FDATA North America] represents and, by extension their customers,” Boms stated. 

Additionally, Boms discussed concern that the OCC’s 2020 FAQs on third-party risk management guidance have increased the complexity of bilateral data access agreement negotiations, thus creating an environment in which “the largest financial institutions are in a position of increased control over whether and how their customers will have the ability so share access to their financial data.” Therefore, Boms expressed that a solution to this problem would be to remove the interpretive role banks play today in this space through the creation of a regulatory structure in which prudential regulators “supervise and retain full responsibility for interactions only between banks and data aggregators,” while the Consumer Financial Protection Bureau (CFPB), upon finalization of a rule under Section 1033 of the Dodd-Frank Act, “is similarly responsible for supervising the relationship between data aggregators and third-party providers, and by extension, the end users.” Doing so, Boms stated, would eliminate the “legal grey area” which is currently stifling the growth and innovation of third-party financial tools to the detriment of US consumers. 

FDATA North America urged the agencies to embrace the letter and spirit of the July 2021 Executive Order on promoting competition in the American economy and ensure that any policy changes resulting from the development of this guidance do not interfere with the goals set out in the Order.

Image result for paperclip iconFDATA North America submission to financial regulators’ request for comment on third-party relationships

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, EQ Bank, Experian, 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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FDATA North America Submits Comments to House Fintech Task Force on Data Access

September 20, 2021, Washington, DC – Today, FDATA North America submitted a letter for the record for the U.S. House Financial Services Committee’s Task Force on Financial Technology’s hearing “Preserving the Right of Consumers to Access Personal Financial Data.” The letter outlines FDATA North America’s mission to advocate for a financial ecosystem in which the end user has complete utility of their financial data.

Throughout the letter, FDATA North America Executive Director Steve Boms discussed the importance of the Consumer Financial Protection Bureau (CFPB) utilizing the authority vested in it under Section 1033 of the Dodd-Frank Wall Street Reform and Consumer Protection Act to promulgate, by rule, a consumer financial data right that will spur greater financial access and inclusion. “FDATA North America has been encouraged by two important developments” that advance Section 1033, including:

  1. The issuance of an advance notice of proposed rulemaking by the [Consumer Financial Protection] Bureau (CFPB) pertaining to consumer access to financial records late last year; and
  2. Inclusion in President Joe Biden’s July 2021 Executive Order on Promoting Competition in the American Economy language that encourages the CFPB  to consider “commencing or continuing a rulemaking under section 1033 to facilitate the portability

Promulgation of Section 1033, Boms stated, comes at a critical moment whereby countries around the world are quickly embracing the notion that the customer should be in control of their own financial data. “The status quo, under which financial institutions continuously exercise control over their customers’ data, provides little benefit to the consumer or small business,” Boms noted. Additionally, innovation and competition in the financial services marketplace are stifled under the current environment that is controlled by commercial interests, prohibits the move to a modernized customer-centric, safe and secure open finance system in the United States.

Image result for paperclip iconFDATA North America Letter for the Record on Data Access

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, Mogo, Morningstsar, M Science, MX, Petal, Plaid, Questrade, Rocket Mortgage, SaltEdge, Trustly, ValidiFI, VoPay, Wealthica, Xero, and others.

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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 Applauds Release of Final Report of Canadian Advisory Committee on Open Banking

 

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

August 4, 2021, Washington, DC –The Financial Data and Technology Association (FDATA) of North America today issued a statement following Finance Minister Chrystia Freeland’s release of the report customer-directed finance (CDF) by the Advisory Committee on Open Banking. Executive Director Steve Boms said:

“This report is an important milestone in Canada’s move toward customer-directed finance, and in achieving a customer-centric, 21st century financial services marketplace that enhances financial access and boosts competition. Major markets around the world have implemented or are designing open finance regimes that give families and small businesses more control over their financial lives. The fintech community has worked tirelessly with policymakers over the last several years to ensure that Canadians are not left behind. We are grateful to Minister Freeland for finally moving this file forward.

“As we look forward to next steps of a Canadian CDF system, we urge policymakers to move quickly to begin implementation, and to ensure the framework allows for payment initiation and money movement use cases. The COVID-19 pandemic has demonstrated how important these services are to families and small businesses. The fintech community has supported Canadians during this crisis, offering seamless products that provide access to capital, payment and accounting services, and countless other applications. Payment initiation and money movement must be accounted for in this new regime.”

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, EQ Bank, Experian, Fiserv, Flinks, Interac, Intuit, Inverite, Kabbage, 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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