We commends Minister Freeland and the federal government for releasing the long-awaited report on the implementation of consumer-directed finance. This report is a step towards creating a more robust, competitive, and consumer-friendly banking industry. The 34 recommendations in the report offer a holistic overview to how Fintechs can use the financial information stored with banks to provide an enhanced customer experience. 

As we work to make data accessible through a formalized API framework, some financial institutions are interrupting access to customer data based on operational data risk. 

The Minister’s recommendations seek to eliminate screen scraping and substitute a made-in-Canada approach that recognizes the potential for government and industry to collaborate, each with appropriate roles.

We agree that a made-in-Canada open banking system should have:

1. Common rules for open banking industry participants to ensure consumers are protected and liability rests with the party at fault;
2. An accreditation framework and process to allow third party service providers to enter an open banking system; and
3. Technical specifications that allow for safe and efficient data transfer and serve the established policy objectives.

However, seeking to operationalize this by January 2023 may leave many Canadians in limbo for over 18 months. We should all strive to make credit accessible for Canadians, many of whom do not have the ability to access credit in the time of a personal need.

We agree that consumers’ data needs to be protected; however, how can thin-file consumers have confidence in a system that may not allow them to access essential financial services while we build this future regime.