From: Janaki Nagulan Sent: February 14, 2019 10:30 PM To: OBBO (FIN) Subject: A Review into the Merits of Open Banking Dear Advisor Committee, RE: https://www.fin.gc.ca/activty/consult/2019/ob-bo/pdf/obbo-report-rapport-eng.pdf I was doing some reach and ran into your consultation document. The government must have clear guiding principles, data is gold and must be treated with care. It is great that everyone wants access to data but the true owners of the data get very little benefit from it (e.g. Facebook, Google – lured by free services). Please find below responses to the questions raised: 1. Would open banking provide meaningful benefits to and improve outcomes for Canadians? In what ways? Yes it would. I am a product manager for a record keeping system used by banks, insurance companies and fund manufactures. My views are based on this experience. * 750 Billion of intergenerational wealth transfer is anticipated over the next 5-6 years. With this brings the risk of fraud and elderly risk. Currently there are no solutions in Canada that validates that the ‘account holder name’ and banking details (Bank number, transit number and account number) match. Similar organization is the US would be https://www.agilepayments.com/checking-account-verification-services/ * Open banking would benefit financial institutions as client risk scores would be created and shared between banks without the need for 3rd party validations that costs consumers. 2. In order for Canadians to feel confident in an open banking system, how should risks related to consumer protection, privacy, cyber security and financial stability be managed? * Systems must be designed for privacy taking into consideration an individual’s preference to be excluded from OPEN banking. * As we all know the 2017 Equifax security breach. Banks and other large financial institutions have the deep pockets to protect their client’s data. Opening financial data means other new ‘start-up’ now have access to sensitive financial information. A strict validation process must be followed to access the data and be user permission based as the onus of risk must be clear. The last we need is fraudulent start-ups luring unsuspecting clients only for the purpose of getting financial data. 3. If you are of the view that Canada should move forward with implementing an open banking system, what role and steps are appropriate for the federal government to take in the implementation of open banking? * Process to validate authenticity of an organization accessing details * Clear accountability rules when fraud occurs, as this would be a huge concern for banks who hold the client relationship * Clear data security guidelines with data encryption at rest, and in transit rules * Clear usage guidelines: what will the data be used for must be clearly communicated to the consumer o Several user consented solutions exists but what data is moved over once authentication if approved is not clear e.g. all bank details including mortgage, transaction data. Data acquired is only used for the pre-communicated purpose, not an afterthought. o Banks and large financial institutions are heavily regulated but with OPEN data we need to be careful who has access to the bank data and will they also be governed by the high banking standards * Ideally one set of API (JSON format) that everyone follows through. Otherwise we are looking at unnecessary costs for all involved. In order to respect privacy and confidentiality, please advise when providing your comments whether you: * consent to the disclosure of your submission in whole or in part; Yes I do * request that your identity and any personal identifiers be removed prior to publication; or, Please remove my identify from publication to the public. I however am open to additional conversations from the Ministry of Finance or this committee requiring additional clarification * wish that any portions of your submission be kept confidential (if so, clearly identify the confidential portions). No Jana Nagulan Director, Product & Solutions OOO Alert: Larsen & Toubro Infotech Canada 2810 Matheson Blvd E #500, Mississauga, ON L4W 4X7, Canada T +1 (289) 374-8791 | C +1 (416) 543-2927