The Canadian Bankers Association (CBA) strongly supports innovation and competition in Canada’s financial services sector. We were pleased to participate in the consultation process and thank Finance Canada and the Advisory Committee on Open Banking for its thoughtful and diligent analysis of consumer-directed finance within the Canadian context. We’re encouraged to see alignment with stakeholder concerns that have been raised around security and privacy of customer data, which are fundamental to the success of this important initiative. Banks in Canada are trusted custodians of data and will continue to put their customers at the centre of trusted innovation.

We believe consumer-directed finance can enhance the financial services landscape for Canadians. Along with the benefits it provides, key risks should also be addressed, which we stated in our response to Finance Canada’s consultation paper in February 2019. The CBA’s submission to the department underscored our views regarding the potential risks and mitigation strategies associated in four important areas: Consumer Protection, Privacy and Confidentiality, Financial Crime, and Financial Stability. In order for Canadians to truly benefit from consumer-directed finance, these risks need to be addressed.

The banking sector will continue to work with the government in its ongoing, multiphase process. We welcome continuous dialogue between the banking sector and key stakeholders to arrive at an outcome that optimizes the possibilities of consumer-directed finance by recognizing Canada’s unique characteristics, while also protecting the interests of customers in a digital environment.