OPEN FINANCE Archives - Financial Data and Technology Association (FDATA)

August 3, 2023by rebecca rebecca No Comments

FDATA North America Submits Comments to Canada’s Standing Committee on Finance Pre-2024 Budget Consultations

August 3, 2023, Washington, DC – 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 2024 budget. Our submission stressed that Canada needs to remain diligent in its pursuit of an open banking framework which will provide Canadians much needed relief in banking fees and other expenses, that Canada must recognize that other countries are rapidly implementing their own open banking regimes, and remain keenly aware that every day that passes without open banking development risks leaving Canadians further behind their international counterparts and competitors.

Our letter also expressed disappointment with the lack of progress on the open banking file, and called on the government to:

Include language in Budget 2024 to implement the recommendations that Open Banking Lead Abraham Tachjian will provide in his forthcoming final report and rapidly implement Canada’s open banking system, including funding for the development of a neutral, transparent, and nimble governance function;
Include language in Budget 2024 outlining the government’s approach to open finance, the next logical step after open banking, and the framework needed to truly unlock market innovation and competition to benefit Canadian consumers and businesses; and
Amend the Canadian Payments Act to enable Payments Canada to expand its membership to include federally regulated payment service providers, providing access to its forthcoming real-time payment system.

In the submission, we also asserted that any open banking governance entity in Canada must be neutral (i.e. not controlled by any particular stakeholder(s) with commercial interests in the ecosystem), transparent (i.e. it invites and considers stakeholder input and subjects its decisions to an open, publicly visible process), and nimble (i.e. capable of making binding decisions relatively quickly and without undue bureaucracy), with all stakeholders in the open banking system agreeing to comply with the decisions and determinations made by the open banking governance entity as a condition of being active in the market.

A full copy of the submission is available here.

September 30, 2022by rebecca rebecca No Comments

FDATA North America Highlights Importance of API Standards and Monitoring

September 29, 2022, Washington, DC -As both Canada and the United States continue to move towards open banking via APIs, it is essential that minimum API standards be set to ensure that consumers and SMEs have uninterrupted access to their financial data.

To this end, FDATA has developed four principles that will be critical to the design of a well-implemented API environment in North America. These principles cover data scope, reliability standards, fallback options, and the necessity of establishing a neutral monitoring agency. These principles can be found here, and below:

Any non-proprietary data available to an end user through a data provider’s online customer portal or paper statement must also be required to be made available in any API a data provider implements in an open banking environment. At present, data providers unilaterally determine which data elements their customers can and cannot share with third parties. In a true open banking environment, the customer – not their financial services provider – is empowered to make this decision. Within the PSD2 framework in Europe, this has led to services being withdrawn as API functionality did not keep pace with pre-existing technologies.

Any APIs built by data providers to facilitate data sharing in an open banking environment must, at a minimum, be as reliable as that data provider’s customer-facing online portal. Regulatory agencies in both Canada and the United States have understandably set prescriptive requirements regarding the uptime of online customer-facing portals at financial institutions to ensure that consumers and SMEs have continual access to their data. This same standard must apply in any open banking environment.

To the extent data requested by a customer is not available through an API connection, a fallback option must be permitted to be used to access the requested data. The legal customer data right upon which an open banking environment is built cannot be ignored if a data element requested by a customer is not available through a data provider’s API or if that API is down or unresponsive. Screen scraping must be maintained as a fallback option that may be used to access any data not included in or available from a data provider’s API.

A neutral entity must be responsible for regularly monitoring the robustness, reliability, and usability of data providers’ APIs in an open banking environment. A neutral entity should be tasked with the responsibility for regularly measuring and reporting, among other metrics: the uptime of all open banking providers’ APIs; whether all of the data available to the end user on the data provider’s online customer portal and/or paper statement is available through the API; the responsiveness of the API; whether the API is constructed in such a manner that it introduces unnecessary friction in the customer’s data connectivity journey. These measurements should be the basis upon which a fallback option is permitted. Ideally, these metrics would be made publicly available to facilitate the ability of end users to identify the effectiveness of their financial provider’s data sharing capabilities. Such an entity should come from outside of the sector itself in order to not be perceived as having their own fiduciary interest in the metrics delivered.

Issues related to API robustness, reliability, and user experience have stunted the growth of open banking use cases in multiple markets across the globe that have moved more quickly than North America toward implementing legally binding customer financial data rights. It has been evident from experiences in Europe, the United Kingdom and Australia that well-defined standards without equally well-defined systems to measure them in a way that all parties can agree to leads to increased friction and a technical overhead placed on the regulator which they may not be well-positioned to adjudicate. Ensuring at the outset minimum API requirements for any open banking data providers, as well as a neutral monitoring entity to measure the quality and reliability of those APIs, will prevent Canada and the United States from experiencing similar issues as we begin our own North American open banking journey.

September 26, 2022by rebecca rebecca No Comments

FDATA North America Submits Comments to Canada’s Standing Committee on Finance Pre-2023 Budget Consultations

September 26, 2022, 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 2023 budget.

In its comments, FDATA North America called on the government to:

Include language in Budget 2023 asserting the importance of governance in an open banking framework, and that any open banking governance entity must be neutral, transparent, and nimble;
Allocate sufficient and sustained funding in Budget 2023 towards the implementation of an open banking framework and governance entity; and
Include language in Budget 2023 outlining its approach to Open Finance, the next logical step after Open Banking, and the framework needed to truly unlock market innovation and competition to benefit Canadian consumers and businesses. This includes an amendment to the Canadian Payments Act to grant federally regulated payment service providers access to Payment Canada’s forthcoming real-time retail payment system and make them eligible for membership in Payments Canada.

In the submission, FDATA NA also asserted that any open banking governance entity in Canada must be neutral (i.e. not controlled by any particular stakeholder(s) with commercial interests in the ecosystem), transparent (i.e. it invites and considers stakeholder input and subjects its decisions to an open, publicly visible process), and nimble (i.e. capable of making binding decisions relatively quickly and without undue bureaucracy), with all stakeholders in the open banking system agreeing to comply with the decisions and determinations made by the open banking governance entity as a condition of being active in the market.

A full copy of the submission is available below:

FDATA North America 2023 Pre-Budget Consultations

April 4, 2022by rebecca rebecca No Comments

FDATA NA and Paytechs of Canada Release Landmark Survey on Canadian Consumer and Small Business Attitudes Toward Financial Sector and Open Banking

Contact: Steve Boms ([email protected]); Alex Vronces ([email protected])

April 4, 2022, Toronto and Washington, DC: More than half of Canadians feel stress when interacting with Canada’s financial services sector and believe they would benefit from increased competition and transparency in the financial services market, according to a landmark survey commissioned by FDATA North America and Paytechs of Canada. The findings indicate this is especially true among women, young people, and new Canadians. Among the biggest sources of dissatisfaction are high fees and a lack of choice.

The findings are derived from two surveys conducted by Pollara Strategic Insights. One was of a randomly-selected sample of 2,001 Canadians 18 years of age or older. The other was of a randomly-selected sample of 600 Canadian small business owners. In each, respondents were asked about their experiences with Canada’s financial services sector.

“As the government advances critically important initiatives to modernize Canada’s financial services market, including open banking and payment modernization, the voices of consumers and small businesses must be at the center of the conversation,” said Steve Boms, Executive Director of FDATA North America. “These first-of-their-kind surveys clearly demonstrate Canadians’ hunger for a more competitive, transparent, and innovative Canadian financial system.”

“At a macro level, we’ve long known that the Canadian financial services sector isn’t as productive as it could be because of barriers to competition and innovation, which is part of the reason why the government is modernizing its approach to financial sector policy,” said Alex Vronces, executive director of Paytechs of Canada. “These surveys shine a light on the often-neglected human cost of less competition and innovation for consumers and businesses.”

“The survey findings show that navigating the financial services sector is a stressful experience for about half of Canadians and small business owners.” said Dan Arnold, Chief Strategy Officer at Pollara. “So it is not surprising that both audiences see the potential benefits that reforms to the sector could bring.”

Key Findings:

About half of Canadians (52%) and small business owners (51%) feel stress when interacting with the financial services sector. Those who operate larger small businesses (10+ employees) are significantly more stressed (72%). Moreover, the majority (54%) of these larger small business owners feel the amount of time they spend dealing with the financial services sector is getting in the way of them actually running and growing their business, twice the overall level among small business owners (26%). Immigrant small business owners are more likely to be stressed by their interactions with the sector.
Over two-thirds of Canadians believe more competition in the financial services sector would lead to a greater choice in products (70%) and lower financial services fees (67%). Moreover, small business owners are over four times more likely to agree than disagree with the sentiment that Canadian small businesses would benefit from increased competition in the financial services sector (64% vs. 14%).
Among specific changes tested, Canadians are most likely to feel they would personally benefit from easier ways to “shop around” to get the best possible rate (75% would benefit), easier ways to transfer money quickly and securely (73%), and tools that help make personalized investment decisions (69%).
Among specific changes tested, small business owners are most likely to feel they would benefit from easier ways to “shop around” to get the best possible rate (73% would benefit), better ways to transfer funds between different accounts (68%), and alternatives to credit cards with lower interchange fees for merchants (62%).
There is widespread agreement among the users of Non-Bank FinTech Apps that they are easy to use (91%), have lower fees (82%), and help save money (73%).

To access the full survey data, click here.

For media enquiries or interviews, please contact:

Steven Boms

Executive Director, FDATA North America

[email protected]

Alex Vronces

Executive Director, Paytechs of Canada

[email protected]

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 financial tools to better manage their finances.

About Paytechs of Canada

Paytechs of Canada is a not-for-profit association that provides a harmonized voice for technology companies that move money. Our mission is to make Canada’s financial sector more competitive and innovative, without compromising its safety and soundness. Serving millions of Canadians on a daily basis, our membership includes payment processors, financial technology companies, and financial institutions, among others.

March 22, 2022by rebecca rebecca No Comments

FDATA North America Applauds Choice for Canadian Open Banking Lead

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

March 22, 2022, Washington, DC – The Financial Data and Technology Association (FDATA) of North America today issued a statement following the announcement that Abraham Tachjian will serve as Canada’s Open Banking Lead. In its August 2021 report, the Minister of Finance’s Advisory Committee on Open Banking recommended the appointment of an Open Banking Lead who would report to the Associate Minister of Finance Canada as a critical first step in the delivery of open banking in Canada.

Executive Director Steve Boms said:

“Today represents an important step forward in Canada’s efforts to deliver open banking by 2023. We are encouraged by this action and look forward to working with Open Banking lead Tachjian to ensure a competitive, customer-centric open banking ecosystem in Canada that boosts financial access and inclusion.

“Consumers and small businesses also should be pleased with this forward momentum. Around the world, open banking regimes have led to greater financial access and competition, lower pricing, improved financial outcomes. Canadian consumers have increasingly moved toward digital financial services, particularly throughout the pandemic. Today’s announcement is a meaningful step towards the realization of an innovative, customer-centric financial services system in Canada.”

In a letter to Freeland sent in early November 2021, FDATA said the Open Banking Lead should be responsible for working with industry to create the policy and governance standards under which open finance can be delivered in early 2023 as set forth in the report.

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, Brian J. Costello, Direct ID, Envestnet Yodlee, EQ Bank, Experian, finansystech, Fiserv, Flinks, Hank Payments, Interac, Intuit, Inverite, Kabbage, Mogo, Morningstsar, M Science, MX, Petal, Plaid, Questrade, RocketMortgage, SaltEdge, Trustly, ValidiFI, Vaultree, VoPay, Wealthica, Xero, and others.

March 2, 2022by rebecca rebecca No Comments

FDATA North America Submits Letter to NIST on Draft Open Banking Report

March 2 2022, Washington, DC – Today, the Financial Data and Technology Association (FDATA) of North America submitted a comment letter to the US National Institute of Standards and Technology (NIST) on its draft report “Cybersecurity Considerations for Open Banking Technology and Emerging Standards.”

The letter expressed appreciation for the Institute’s research in this important policy space, but respectfully offered that this report, published in January, would significantly benefit from expanded input from market and government stakeholders to appropriately frame the current open banking environment in the United States as well as to accurately reflect the significant regulatory attention that has already been given to this space.

The letter states that “as one of the earliest federal government research publications on open banking, it is crucial that this report accurately define and describe all the elements of open banking that are relevant to policymakers. Unfortunately, in many cases we believe that NISTIR 8389 falls short. From the onset, the definition and framing of open banking is too narrow, and critical distinctions between customer-permissioned data access – the foundation of open banking – and non-permissioned data mining, as well as the important differences between propriety and non-proprietary data, are insufficiently distinguished. Use cases are inaccurately described, and the full impact of Section 1033 of the Dodd-Frank Wall Street Reform and Consumer Protection Act on the development of open banking in the United States could be better articulated.”

FDATA NA is concerned that certain errors and omissions in this paper could misinform both the public and key policymakers as they develop open banking regulations. In the absence of this meaningful stakeholder engagement, we are concerned that this draft paper also does not fully appreciate the market and regulatory environment in which open banking use cases are currently delivered to consumers and small businesses in the United States today and will be in the future. Our letter therefore urged NIST to consider input from key stakeholders and republish a revised version of this report.

FDATA Response to NISTIR 8389

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.

February 22, 2022by rebecca rebecca No Comments

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.

FDATA 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.

February 7, 2022by rebecca rebecca No Comments

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.”

FDATA 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.

September 30, 2021by rebecca rebecca No Comments

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.”

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.

September 29, 2021by rebecca rebecca No Comments

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:

Create a legally binding customer financial data right;
Define and clear enumerate the limited circumstances in which custodians of financial data may override customer consent;
Supervise financial data aggregation firms;
Coordinate with the prudential regulators on Regulation E modernization; and
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.”

FDATA 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.