Steering Committee meeting 1 – December 7, 2022

An Open Banking Canada Steering Committee meeting was held on December 7, with all working group members to provide an update and examine issues that have not been discussed yet, including governance and technical standards.

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

On this page:

Meeting presentation

Ground rules

  1. Members are welcome to communicate in the official language of their choice.
  2. Use the "Reaction/Raise hand" function during the designated discussion periods to intervene.
  3. Introduce yourself before speaking by stating your name and organization.
  4. Limit speaking time to two minutes.
  5. Use the "Mute" function when you are not talking, so we can clearly hear whoever is speaking.
  6. No more than one participant per organization.
  7. Meeting materials will be posted online on the open banking implementation site.

Progress to date

Chart #: Chart Title
Text version

This graphic outlines the progress made to date divided into two sections.

On the left side, there are three boxes, each highlighting different achievements. These are described from top to bottom.

  1. Over 150 stakeholder meetings
  2. Review of other jurisdictions such as United Kingdom and Australia
  3. Ongoing policy work on governance and technical standards

On the right side, a larger box highlights achievements related to the working groups in five boxes. These are described from left to right.

  1. Four working groups on accreditation, liability, privacy and security
  2. Balanced representation of industry, government regulators and consumer representatives
  3. Progress made in the span of just four months from July 2022 to October 2022
    1. Two accreditation meetings left
    2. Two liability meetings left
    3. One privacy meeting left
    4. One security meeting left
  4. Diverse expertise of participants: CEOs, risk professionals, legal, technology, business, regulators, consumer advocacy
Approximately 100 participants, 80 industry participants and 20 federal and provincial regulator representatives

Introduction

As per the Open Banking Canada Steering Committee Terms of Reference:

The scope of the Steering Committee differs from the working groups established by the Open Banking Lead.

Whereas the working groups are forums for select members to support the Open Banking Lead in the development of accreditation and common rules requirements, the Steering Committee is a venue for broader discussion with all stakeholders on points such as general updates, progress made in a given working group or any other topic the Open Banking Lead deems fit.

Steering Committee members can also:

  1. Raise novel issues with cross disciplinary implications that may not be properly addressed   in existing working groups; and,
  2. Introduce proposals for resolving concerns.

The Steering Committee is a consultative, rather than a decision-making, body.

Agenda

11:00 – 11:05 am Welcome and ground rules
11:05 – 11:10 am Introduction
11:10 – 11:20 am Accreditation
11:20 – 11:30 am Discussion
11:30 – 11:50 am Technical standards
11:50 am – noon Discussion
Noon – 12:45 pm Lunch break
12:45 – 12:55 pm Remarks by Hon. Randy Boissonnault
12:55 – 1:15 pm Governance considerations
1:15 – 1:30 pm Discussion
1:30 – 1:40 pm Key governance functions
1:40 – 1:55 pm Discussion
1:55 – 2:00 pm Overview of five jurisdictions
2:00 – 2:15 pm Discussion
2:15 – 2:30 pm Closing remarks and questions

Accreditation process

Possible accreditation requirements

These requirements have been prepared based on preliminary input from accreditation and other working groups.

Operational
  • Risk-management processes and governance to address principal security risks
  • Internal dispute mechanism and membership in an external complaints body
  • Certification demonstrating conformance to technical requirements
  • Traceability framework to trace consumer data
  • Adoption of standard consumer consent flows and implementation of consent management dashboard
  • Processes in place to meet reporting obligations
Organizational
  • Information on the organization's services, structure, management and their experience
Financial
  • Insurance or comparable financial guarantee

The above lists are not final, non-exhaustive and subject to change.

Technical standards

The Advisory Committee on Open Banking's report advised the Government to:

Any decision will need to be grounded in the public policy principles.

Public policy principles

  1. Accessible and inclusive for all credited system participants without requiring additional arrangement.
  2. Enable a positive consumer experience without overly onerous steps that the consumer must follow to realize the benefits of open banking.
  3. Enable the safe and efficient transfer of data among system participants.
  4. Capable of evolving with technological change to keep pace with the rapidly evolving sector.
  5. Sufficiently flexible to enable the development of new and innovative products.
  6. Compatible and interoperable with international approaches.

Considerations

Governance

The Advisory Committee on Open Banking's report recommended that:

Considerations

With the Committee's recommendations as guiding principles, many considerations are being taken into account in the development of system governance, such as:

Key governance functions

Administration

  1. Managing the scope of the system (data fields, read vs write)
  2. Maintain tech standards, including updating specifications and certification requirements
  3. Update accreditation criteria, approve of accreditation (internally or through third party)
  4. Maintain consumer experience guidelines
  5. Manage a public registry of accredited participants

Supervision

  1. Monitor tech performance to ensure the system and its participants works as intended
  2. Monitor and supervise compliance with common rules
  3. Monitor and supervise conflict resolution processes
  4. Promote consumer education and financial literacy

Resolution

  1. Resolve conflicts between participants and direct liability
  2. Resolve conflicts between consumers and participants
  3. Promote the privacy of individuals

Overview of five jurisdictions

Jurisdiction Approach/System Status
United Kingdom The Open Banking Implementation Entity (OBIE), is overseen by the Competition and Markets Authority (CMA). The Financial Conduct Authority (FCA) authorizes organizations to join the open banking system. The UK leads the way in OB implementation. OBIE has undergone a series of governance reforms, and the government has begun work to create a new entity that would oversee a broader scope of data.
European Union Each EU country has a designated National Competent Authority (NCA) (typically a central bank or financial services regulator) responsible for overseeing the respective country's OB framework. The EU has not signaled changes in approach to governance but is examining the potential to move to a single technical standard across the EU.
Australia Implementation under the purview of the Australian Competition and Consumer Commission (ACCC), data standards managed by a data standards body; privacy overseen by the Australian privacy regulator. Australia is now looking at creating a dedicated entity to oversee its Consumer Data Right and related rules.
Brazil Open banking initiated and overseen by Brazil's central bank with implementation being managed by industry, with balanced representations Brazil is set to move to Open Finance. The initial structure will be replaced with a definitive structure when the last stage of implementation begins.
United States Initially industry-led; with guidance from Consumer Financial Protections Bureau (CFPB). CFPB is now moving to a more regulated approach. Draft rules to be released early 2023; final rules in place by early 2024.

Closing remarks

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