The Canadian Bankers Association and its members are committed to fostering responsible innovation and competition in Canada’s financial services sector as we meet evolving consumer needs in a digital and data driven economy. We are supportive of a consumer‑centric approach to using innovative technologies to provide important benefits for Canadians.

We look forward to collaborating closely with government authorities, regulators and cross‑sectoral partners to provide Canadians with safe access to innovative products and services. We strongly support a resilient, consumer‑centric framework that helps Canadians realize the benefits of robust, secure and consumer‑driven data exchanges while appropriately managing the risks.

For the above reasons, below are the recommended high‑level principles vital for shaping a successful consumer-driven banking framework with read access, which allows approved service providers to only receive consumer financial data with consent, in the initial phase:

1. A Hybrid Model: Canada's journey towards consumer‑driven banking embraces a principles‑based, made‑in‑Canada approach, drawing from industry expertise to deliver on policy objectives set by the government. This model should be economically sustainable to encourage participation, innovation and competition for the benefit of consumers.
2. Consumer Protection: To ensure that consumers receive consistent protections including options for all participants to take reasonable steps to protect consumers against security and fraud risks. These protections would also ensure that the participant receiving the data will be accountable and liable for the data transfer initiated by the customer.
3. Prohibit Screen Scraping: Prohibit screen scraping practices within a specified timeframe to safeguard consumers, even by organizations that do not opt-in to the framework.
4. Reciprocity: All participants (including financial institutions, FinTechs, BigTechs, and other non FIs) must adhere to the principle of reciprocity to eliminate any potential data asymmetry. This in turn will empower Canadians to securely access and share their financial data.
5. A Fit‑For‑Purpose Entity: A proper governance entity with the appropriate mandate, capacity and resources must be created at the outset, recognizing the government’s policy objective of a cross-sector consumer data right, and the need for this entity to successfully supervise the framework across disparate disciplines such as market conduct, privacy, and security.
6. Efficient Implementation: An effective and consultative approach to the expansion of scope (breadth of data to be shared, entities that can participate and functionality) that follows a clear timeline and focuses on leveraging industry strengths for consumer‑centric use cases that will ultimately expedite the delivery of consumer-driven banking benefits to Canadians.
7. Accreditation Framework: Promote a level playing field where participants are subject to common rules, for example, security, privacy, liability, fraud, and data protection, that foster consumer trust in the system throughout its evolution.
8. Regulatory Harmonization: Leverage existing and applicable regulatory and legislative frameworks where appropriate and foster intergovernmental coordination to avoid duplicative, conflicting, or residual obligations and ensure a consistent consumer experience.
9. A Single Technical Standard: A principles‑based, market‑driven approach to standards development and a timely announcement on the use of the FDX standard, with which all participants must demonstrate compliance, to ensure interoperability and provide participants with needed clarity to meet government timelines.