Accreditation working group meeting 1 – July 5, 2022

This discussion guide is provided to assist working group members in preparing for the meeting.

For questions or comments, please contact obbo@fin.gc.ca.

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Discussion guide

Objective

Accreditation is the process through which organizations would demonstrate their fitness to participate in the open banking system. The aim of this working group is to draft an accreditation framework to recommend to the government.

In their final report, the Advisory Committee on Open Banking (the Committee) noted that the crucial challenge in establishing an accreditation framework is to strike the right balance between promoting entry to the system for smaller participants while maintaining security and protection for all participants. Open banking will only provide value to consumers and the economy if service providers are able to participate and develop new services and products. At the same time, consumer trust in the system underpins participation and can be lost quickly if something goes wrong.

Approach and timelines

Meetings will be held approximately every three weeks. Members are encouraged to review the following material in advance of meetings:

The open banking lead, with support from the Department of Finance Canada (the Secretariat), will distribute documents guiding the discussion for each meeting which will also be available on the open banking implementation page. Members may also be asked to draft material for discussion.

Accreditation working group topics and timeline

Discussion

  1. Are there other topics that should be considered by the accreditation working group which were not captured in Annex A?
  2. What are your views on the proposed timeline and cadence of the work plan?

Accreditation criteria categories

The Committee recommends that the accreditation criteria be sufficient to demonstrate that the organization seeking accreditation is able to comply with the common rules related to liability, privacy and security, including having sufficient financial capacity to ensure consumers are protected in the event of loss.

As a starting point, the following accreditation criteria categories are proposed:

Category Description
Background information / Internal governance The information about the organization, its activities, and governance which must be provided to demonstrate soundness and legitimacy
Financial capacity How an organization must demonstrate sufficient financial capacity to compensate other parties in the event of a loss
Certification How an organization must demonstrate their compliance with technical standard requirements
Privacy and security How an organization must demonstrate their adherence to privacy and security requirements

Discussion

  1. Are there other categories for which accreditation criteria should be developed?
  2. Is there any information that may be challenging to provide?
  3. Are there initial views on what elements should come under each of the above criteria?

Annex A – Timeline of accreditation working group topics

Theme 1: Accreditation criteria
Timeline
July to Sept.  
Topic Outcome
Meeting 1 Accreditation criteria categories The categories of accreditation criteria that will be further developed in subsequent working group meetings
Meeting 2 Background information/ Internal governance The information about the organization, its activities, and governance which must be provided to demonstrate soundness and legitimacy
Meeting 3 Financial capacity How an organization must demonstrate sufficient financial capacity to compensate other parties in the event of a loss
Meeting 4 Certification How an organization must demonstrate their compliance with technical standard requirements (e.g., rules on consent)
Meeting 5 Privacy and security* How an organization must demonstrate their adherence to privacy and security requirements

*Dedicated working groups will address privacy and security issues.

Theme 2: Organizations required to be accredited
Timeline
Sept. to Oct.
Topic Outcome
Meeting 6 Organizations subject to accreditation Recommendation on the categories of organizations that should be subject to accreditation and whether there should be different tiers of accreditation
Theme 3: Accreditation process
Timeline
Oct. to Dec.  
Topic Outcome
Meeting 7 Time to accredit/ Refreshing accreditation/ Costs of accreditation Recommendations on key aspects of the accreditation process as they pertain to administrative measures
Meeting 8 Revocation of accreditation/Appealing an accreditation decision Recommendations of key decisions related to accreditation which effect ecosystem participation

Outcomes

Accreditation working group topics and timeline

Discussion 1

Are there other topics that should be considered by the accreditation working group which were not captured in Annex A?

Discussion 2

What are your views on the proposed timeline and cadence of the work plan?

Accreditation criteria categories

Discussion 3

Are there other categories for which accreditation criteria should be developed? 

Discussion 4

Is there any information that may be challenging to provide?

Discussion 5

Are there initial views on what elements should come under each of the criteria?

Accreditation working group attendees

Members

  • Central 1 Credit Union
  • Desjardins
  • Flinks
  • Laurentian Bank of Canada
  • National Bank of Canada
  • Plaid
  • Scotiabank
  • Stripe
  • TD Canada Trust
  • Vancity Credit Union
  • Wealthsimple

External guests

  • British Columbia Financial Services Authority
  • Competition Bureau Canada
  • Financial Consumer Agency of Canada
  • Office of the Superintendent of Financial Institutions

Chair

  • Abraham Tachjian, Open banking lead

Secretariat

  • Department of Finance Canada

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