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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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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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Member Spotlight: M Science

M Science is a groundbreaking analytics firm that provides research, data, and pioneering methodologies to financial institutions and corporations. Their experts take unstructured data in near real-time and discern critical insights that help clients make smarter, more informed business decisions. Specifically, the firm provides:

  • Data-driven research that leverages data and domain expertise to provide in-depth analysis and insights on public and private companies.
  • Direct access to experts for more in-depth research and insights.
  • Data analytics that enable investment management and corporate clients to integrate curated data into their own workflow and process.
  • Data dashboards, in a web-based, on-demand platform hosting multi-sourced data feeds that are curated and customizable to clients’ needs.

Founded in 2002, the company serves clients around the world from offices in New York, Portland, London and Hong Kong.

A cornerstone of M Science’s offering is its compliance first approach to partnerships though its comprehensive due diligence program and commitment to consumer privacy.

At the core of M Science’s mission is the belief that data can revolutionize the way the world does business. In a June 2020 Forbes column, M Science’s Michael Marrale explained, “By creating insights derived from disparate datasets and expertly synthesized by alternative data analysts, operators and investors have granular visibility into company business operations.”

The alternative data M Science provides also has revolutionized the marketplace for institutional investors. In an April 2019 Marketwatch column, Marrale said, “Alternative data provides investors with a greater degree of transparency into how companies are performing. From purchase data that tracks retail sales, to social analytics that measure online brand popularity, to geo data that measures locations and traffic, investors can now take a much deeper look into business operating fundamentals in a way our research landscape didn’t previously allow.”

M Science continues to use their insights to help businesses navigate shifts caused by COVID-19, most recently by launching a new Retail and Consumer Brands Intelligence Platform. Leveraging tested analytic models and a myriad of data inputs, the solution delivers insights to more than a dozen industries including Animals and Pet Supplies, Apparel, Garden and Home, Sporting Goods, and Toys and Games. The platform’s focus on ecommerce makes it a valuable tool for traditional retailers and brands, as well as DTC and online-only players. As noted by Head of Product Elizabeth Coleman, this information will prove “more valuable than ever” as players in the space try to address shopping behaviors changed by the pandemic.

In addition to providing a revolutionary approach to data and research, M Science is an industry leader in its commitment to diversity, equity and inclusion. Indeed, this commitment fuels an innovative mindset within the company. M Power, M Science’s diversity taskforce steers recruiting and educational initiatives to foster diverse perspectives and an environment that drives better results. M Science also is proud to collaborate with American Corporate Partners (ACP), a national non-profit organization dedicated to helping military veterans transition to the private sector through one-on-one mentoring relationships with corporate professionals.

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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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