Karsten Wenzlaff, Advisor
August 26th, 2025
October 28, 2026 | NCFA Story Intelligence | Regulation And Policy, Digital Assets Blockchain And Tokenization, Competition And Market Structure, Capital Markets Infrastructure And Funding

Binance thought it was leaving Canada in 2023. The regulatory fight stayed behind.
Binance never entered Canada the way a bank or securities dealer would. It didn’t open a Canadian branch, build a local exchange or wait for a Canadian licence. Changpeng Zhao was a Canadian entrepreneur who had studied computer science at McGill, but Binance launched in Shanghai in July 2017 and grew into the world’s largest crypto exchange by trading volume within about six months. The product was global from the start. Borders came later.
By 2021, Canadian regulators were catching up with what that model meant on the ground. Ontario pushed Binance out. Binance hired former regulators, incorporated in Alberta and tried to build its way back in. Then Canada tightened the rules again. On May 2, 2023, Binance told securities regulators it planned to withdraw nationally.
Eight days later, the OSC opened an investigation. The next day came a sweeping demand for company records. On May 12, Binance told the public it was leaving Canada.
The exit and the investigation crossed in real time. Binance was trying to close one Canadian chapter while the regulator was opening another.
Three years later, that unfinished business has reached the Supreme Court of Canada. Ontario’s Court of Appeal has already ruled that part of the OSC summons went too far. The OSC wants that ruling overturned. Nine interveners now include civil liberties groups, securities regulators and four governments.
What follows is a story of a borderless crypto company meeting national regulators, leaving some markets, adapting in others, and discovering that a market exit doesn’t make the regulatory past disappear.
Ontario Puts a Border Around a Borderless Exchange 2021
Binance enters 2021 with the advantages that made it enormous. It is fast, broad and easy to reach across borders. Regulators see the same features and start asking who is accountable when local investors use the platform. Binance: The low-down on the drama-ridden crypto exchange was already tracking warnings and restrictions from the UK, Japan, Malaysia, Thailand and other markets that summer. Ontario joins the push.
In March, securities regulators tell crypto platforms serving the province to start the registration process or face enforcement. Binance doesn’t register. On June 25, it makes Ontario a restricted jurisdiction and tells users to close their active positions by year end.1
Binance’s scale has created leverage. It has also created a supervision problem for regulators.
Ontario treats access as local activity. The OSC’s position is that platforms offering securities or derivatives to Ontario users can’t avoid provincial rules simply because the company or servers sit somewhere else. For internet based finance, the customer’s location can pull a global platform into a local regulatory system.
Binance starts planning a return. By early 2022, Binance is doing something that would have looked unlikely months earlier. It hires former Canadian regulators, incorporates in Alberta and starts building toward full registration. Binance hires ex-regulators and incorporates in Alberta to charter compliance course in Canada catches the pivot. A few months later, Alberta-based Binance Canada expects to return to Ontario by 2024 shows how far the strategy has moved. The company isn’t talking about abandoning Canada. It is talking about coming back to Ontario through the front door.
Ontario Is Supposed to Be Closed but Trading Continues 2021 to 2022
The attempted reset quickly runs into the controls Binance says are already in place.
On December 29, 2021, Binance tells Ontario users it can continue operating in the province. The OSC publicly says it can’t. Binance later acknowledges that its message was wrong. The company also tells the OSC that Ontario trading restrictions are in place while some Ontario users can still trade.
By March 2022, the disagreement is no longer informal. Binance signs a legally enforceable undertaking, agrees to block new Ontario accounts, wind down restricted products, strengthen controls and report back to the regulator.2
Binance is trying to prove it can be regulated in Canada while the OSC is testing whether its existing controls actually work.
The undertaking records the sequence in Binance’s own words. It says the company announced its Ontario withdrawal in June 2021, incorrectly told users in December that operations could continue, and later confirmed that some Ontario investors had continued trading after restrictions were supposed to be in place.
Binance committed to prevent new Ontario accounts, identify existing accounts, block trading except for permitted transactions, wind down leveraged and other restricted products, waive or reimburse certain withdrawal fees, train relevant staff and retain an independent third party to assess whether its controls worked.
The document doesn’t say Binance can never return. It says the controls stay in place unless OSC staff provide written confirmation that they can be removed.
Binance agrees to end operations in Ontario; OSC Publishes Binance’s Undertaking Statement shows why the 2022 agreement was more than another exchange announcement. Binance had moved from a voluntary market exit to enforceable commitments about who could use the platform and what the company had to prove to the regulator.
The OSC gets enforceable controls. The undertaking turns account restrictions, product wind downs and monitoring into commitments the regulator can supervise. Binance is no longer only deciding what Ontario access should look like on its own.
Binance still sees a Canadian future. The company pursues registration outside Ontario and talks publicly about returning. That makes the national exit in 2023 more than a market withdrawal. It ends an attempted compliance strategy.
Regulators Around the World Start Closing the Gaps 2021 to 2023
Canada is only one front in a much larger regulatory push. By 2023, Binance has spent years building for a global crypto market while regulators keep answering with national licences, local entities and customer protections. Britain restricts Binance Markets Limited. The Netherlands fines the company for operating without registration. Japan warns it about serving residents without registration. Australia examines how it classifies derivatives customers.
The pressure isn’t only legal. Banking relationships, product access, executive attention and market share all start carrying a regulatory price. Will Binance Severes U.S. Ties in Face of Crypto Crackdown captures the mood in February 2023, when Binance is already reconsidering parts of its US exposure.
Binance can keep operating globally, but it can’t keep operating everywhere in the same way.
Binance Decides Canada Isn’t Worth the New Rules May 2023
For a while, Binance looks prepared to absorb the cost of becoming a regulated Canadian business. In 2023, that calculation flips.
New Canadian requirements tighten expectations around custody, leverage, stablecoins and investor limits. Those rules don’t make crypto trading impossible. Other platforms stay. But they narrow the product Binance can offer and increase what it has to build around compliance.
On May 2, Binance tells the Alberta Securities Commission, acting for the CSA, that it plans to withdraw. Ten days later, it tells the public that Canada’s rules around stablecoins and investor limits have made the market “no longer tenable.”7
Binance Withdraws from Canadian Market due to Tightened Crypto Regulations records the exit. Dispelling FUD: Why Binance’s Exit from Canadian Crypto Markets Strengthens Canada’s Ecosystem captured the opposing industry view that stricter Canadian rules could strengthen the market rather than weaken it.
Canada can tighten investor protections and still make the market less attractive to some global firms. Binance decides the trade no longer works for its business.
Binance blames the rule set, not Canada itself. The company says it delayed the decision while looking for another route and hopes to return someday. Canada is a relatively small market for Binance, but the evidence doesn’t establish that size alone drove the exit. The company’s own explanation focused on the rule set and the product limits that came with it.
Other platforms make a different calculation. Some exchanges also leave, while others pursue Canadian registration and accept narrower product menus. Every platform has to decide whether the local opportunity justifies the controls, product limits and ongoing supervision required to stay.
Leaving Canada Doesn’t End the Investigation 2023 to 2025
On May 10, only eight days after Binance privately tells regulators it intends to leave, the OSC opens an investigation. On May 11, an investigator issues the summons. On May 12, Binance announces its Canadian exit to the public.
The exchange is trying to leave the market. The regulator is trying to reconstruct what happened before the door closes.
Within weeks, OSC Pursues Binance Investigation, Unfazed by Crypto Exchange’s Departure from Canada is already documenting the next fight. Binance argues that the OSC is reopening conduct covered by the 2022 undertaking. The OSC maintains it still has investigative authority.
Leaving Canada changes Binance’s future business. It doesn’t settle its Canadian past.
The OSC investigation order identifies allegations involving unregistered trading, distributions without a prospectus, possible steps to circumvent Ontario securities law and compliance controls, and allegedly misleading statements to the regulator. Binance disputes aspects of the OSC’s case, and those allegations aren’t findings of wrongdoing in the Supreme Court proceeding.
The summons then goes much wider than a narrow request for documents tied to one transaction. It demands, for the period beginning January 1, 2021, “all communications regarding Ontario (or Canada generally)” among directors, officers, employees, contractors, agents and consultants of Binance and related entities.8
That wording is what ultimately troubles the Ontario Court of Appeal. A regulator can compel business records. A regulated firm also has a lower expectation of privacy than an ordinary person in many contexts. But the Court says even a low privacy expectation doesn’t permit a demand without a reasonable foundation to believe the records may be relevant.
The Court later describes the request as “staggering in its breadth” because it could capture communications across virtually anyone working for Binance or related entities, across all of Canada, without limiting every category to the subjects under investigation.
The OSC remains free to investigate and issue another summons that complies with the Charter. The dispute is about how broad the compulsory demand can be, not whether Binance is beyond investigation.
The OSC case isn’t the only Canadian issue that survives Binance’s exit. FINTRAC later imposes a C$6.002 million administrative monetary penalty. It says Binance failed to register as a foreign money services business and failed to report 5,902 large virtual currency transactions of C$10,000 or more between June 2021 and July 2023. FINTRAC says Binance officially ceased all Canadian operations on September 25, 2023 and was required to be registered until then.9
Binance has appealed the FINTRAC decision to Federal Court. This is a separate legal track under federal anti money laundering legislation and doesn’t determine the OSC Charter case.
FINTRAC Fines Binance $6M CAD for Compliance Failures captured the Canadian compliance overhang after the exchange had already announced its departure.
A company can stop onboarding customers, close a product or leave a jurisdiction. Regulators can still investigate conduct that occurred while the business was active there.
Regulators need records to reconstruct the past. Cross border platforms can spread staff, systems and legal entities across several countries. Without compulsory powers, investigators may struggle to establish who made a decision, which controls existed and what customers were told.
Broad demands carry real operating costs. A request covering years of email, chat, files and other communications can trigger preservation, data collection, legal review, privilege screening and cross border privacy work. A global exchange can spend heavily on that process. A smaller fintech may feel the same demand much more sharply.
Ontario’s Top Court Says the OSC Went Too Far November 2025
Binance tries several routes to challenge the investigation and summons. The Capital Markets Tribunal says it lacks jurisdiction to revoke them. The Divisional Court declines to decide the Charter challenge in the way Binance asks. The OSC itself later says it lacks jurisdiction to vary or revoke the summons. The Court of Appeal finally reaches the constitutional issue and sets the summons aside. The regulator can keep investigating, but it has to ask again within Charter limits.10
The ruling protects relevance, not secrecy. The Court accepts that regulators have strong production powers and that privacy expectations for regulated business records can be low. It still requires a reasonable basis to believe compelled records may matter to the investigation.
The OSC sees a wider enforcement problem. The regulator argues that the Court of Appeal’s approach could make investigations slower and more difficult, particularly before investigators know exactly where useful evidence sits. Binance answers that regulators have had relevance limits for decades and can draft demands around the conduct they are actually investigating.
A New Binance Inherits the Old Binance’s Problems 2023 to 2026
While Canadian courts examine the old Binance, regulatory pressure is forcing the company itself to change.
The pressure peaks in 2023. US regulators sue. Senior executives leave. Binance Faces Leadership Crisis as Top Executives Resign Amid Regulatory Pressure appears in July while the company is losing key legal, strategy and compliance leaders.
In November, Binance pleads guilty in the United States to criminal violations involving anti money laundering law, money transmission registration and sanctions. It agrees to pay US$4.3 billion, strengthen compliance and accept independent monitoring. Founder Changpeng Zhao pleads guilty to a separate Bank Secrecy Act offence and steps down as CEO.11
Richard Teng takes over. Binance establishes its first board. Licences, local entities and compliance spending move from the edges of the business model toward the centre.
The company that once treated regulatory borders as friction is rebuilding itself around them.
The Binance that emerges after the US settlement looks more like a conventional global financial company than the founder led organization regulators confronted earlier.
By December 2024, Teng said Binance had moved from a founder and CEO led structure to a board led model and held about 20 licences and registrations worldwide. Reuters reported that the company had created its first board and was still weighing a permanent global headquarters.12
Japan shows what that new approach can look like in practice. Binance didn’t simply keep serving local users from the global platform after regulator warnings. It bought a registered local exchange, launched Binance Japan and migrated users into the local structure.
At the end of 2025, Binance announced that its global platform had received authorization under Abu Dhabi Global Market’s regulatory framework. ADGM described it as the first crypto exchange to secure a formal global licence from its Financial Services Regulatory Authority.13
None of that erases earlier conduct or decides the Canadian case. Compliance has moved from something Binance repeatedly collided with into infrastructure it increasingly needs for market access.
The Binance Fight Becomes Bigger Than Crypto 2026
The Supreme Court grants the OSC leave to appeal on May 21. By October, the case has attracted groups that have little to do with crypto trading. The Court grants intervention rights to the attorneys general of Canada, Ontario, Quebec and British Columbia, the Canadian Taxpayers Federation, the British Columbia Securities Commission, the Canadian Civil Liberties Association, the Canadian Constitution Foundation and Quebec’s workplace safety commission. It rejects several other applications, including the Canadian Forum for Financial Markets. The fight now reaches beyond one exchange. Section 8 of the Charter and the limits on compulsory record demands in regulated industries are at stake.
Investor protection still needs effective investigations. Regulators can’t police complex markets without access to records. Cross border digital businesses make that harder because relevant evidence may sit across entities, employees and systems that don’t line up neatly with one province.
Constitutional limits still matter inside regulated markets. Laura Paglia of the Canadian Forum for Financial Markets told Advisor.ca that securities regulators need broad powers, but argued that demands should remain proportionate and consider compliance costs. CFFiM was denied intervener status, so its view is industry commentary rather than a submission the Supreme Court will hear.14
Binance has already tried several endings in Canada.
First it left Ontario. Then it hired regulators and built an Alberta operation that was supposed to bring it back. Then it accepted an Ontario undertaking. Then it decided the national rules were no longer worth the trade and left Canada altogether.
The legal history kept going.
FINTRAC imposed a penalty tied to the years Binance operated here. Investors pursued a separate class action. Ontario courts rejected Binance’s attempt to force those investors into costly Hong Kong arbitration, a dispute later followed by Ontario Court Orders Binance To Pay Investor Legal Costs. The OSC kept investigating. The company that left Canada in 2023 is still litigating here in 2026.
Binance changed too. Zhao stepped down. A board arrived. Local licences and compliance teams became part of the growth strategy. Japan went from warning Binance to hosting a locally registered Binance business. Abu Dhabi became a regulated global base.
The Supreme Court case is now much bigger than Binance.
The Court is being asked to decide where constitutional limits sit when a regulator with legitimate investigative powers demands a very large volume of company records. A ruling that gives regulators wider latitude could make it easier to investigate complex businesses whose people, systems and data span multiple entities and countries. A ruling that requires a tighter connection between requested records and suspected conduct could force regulators to narrow summonses earlier and give companies stronger grounds to challenge sweeping demands.
Either way, the decision could shape how securities regulators design investigations, how regulated firms preserve and produce records, and how much compliance cost companies may face when regulators come looking for evidence. Depending on how broadly the Court reasons, its impact could also reach beyond capital markets into other regulated sectors that rely on statutory production powers.
That helps explain why governments, another securities regulator and civil liberties organizations have joined a dispute that began with one crypto exchange. The precedent could influence the balance between effective supervision and protection against regulatory overreach across Canadian business.
Binance spent years learning that global reach doesn’t erase national borders. Canada’s highest court is now deciding where one of those borders sits for regulators themselves.
Once a regulator has authority to investigate, how much of a company can it force open?
Binance left Canada. The company moved on. The answer could matter to regulated businesses long after this case is over.
INVESTOR GUIDE
7 Questions to Ask Before Choosing a Crypto Exchange in Canada
A current guide to registration, custody, transfers, funding, fees and operational risks Canadian investors should check before sending money to a crypto platform.
FINTECH INTELLIGENCE
Are Regulators Opening Markets While Raising Costs?
Market access can improve while evidence, records and supervision requirements get tougher, changing the economics for both incumbents and smaller entrants.
REGULATORY INSIGHT
Canada Proposes Stablecoin Market Entry Rules
Canada’s new stablecoin proposal shows how market access can depend on local custody, supervision and operating requirements, even when the underlying product is global.
REGULATION AND POLICY
National Security Is Now Part of Financial Supervision
Financial supervision is expanding beyond traditional capital and conduct questions into sanctions, cyber threats, ownership and state linked risk.
The National Crowdfunding & Fintech Association (NCFA Canada) is a financial innovation ecosystem that provides education, market intelligence, industry stewardship, networking and funding opportunities and services to thousands of community members and works closely with industry, government, partners and affiliates to create a vibrant and innovative fintech and funding industry in Canada. Decentralized and distributed, NCFA is engaged with global stakeholders and helps incubate projects and investment in fintech, alternative finance, crowdfunding, peer-to-peer finance, payments, digital assets and tokens, artificial intelligence, blockchain, cryptocurrency, regtech, and insurtech sectors. Join Canada's Fintech & Funding Community today FREE! Or become a contributing member and get perks. For more information, please visit: www.ncfacanada.org
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October 26, 2026 | NCFA Regulatory Insight | Regulation And Policy, Digital Assets Blockchain And Tokenization, Payments And Money Movement

On October 24, 2026, the Canadian government published proposed Stablecoin Regulations that put operating rules behind Canada's federal stablecoin framework. Issuers would face Bank of Canada registration and supervision, one to one reserves, Canadian custody requirements and redemption obligations. Stablecoin payment activity would also enter the Retail Payment Activities Act framework. Consultation closes December 23, 2026 at 11:59 p.m. Eastern.
NCFA's Stablecoin Regulatory Intelligence provides the definitive guide to the framework and implementation path. The operating rules now make a strategic choice much easier to see. A company can take on the capital, custody and supervision required to issue a stablecoin, or build payments, wallets, compliance and infrastructure around regulated coins instead.
Covered issuers would need reserves equal to the value of their stablecoins at the end of each trading day. Those reserves must be held with a qualified custodian incorporated in Canada. Issuers would also need to redeem at par, generally start payment within three business days and maintain the systems needed to manage security, risk and recovery.
That brings banking, custody and operating capacity into the business much earlier. A company can build the technology first, but it can't operate at scale without institutions willing to hold its reserves, systems that can process redemptions and enough capital to keep the business running while those relationships are put in place.
Registration can also affect launch timing. A national security review can delay entry and ultimately prevent an issuer from operating in Canada. Founders and investors therefore have to plan for more uncertainty before launch. Canada is already opening more of its financial infrastructure to regulated non bank participants, but stablecoin issuers will still have to meet a much higher operating bar.
The government's regulatory analysis estimates C$88,521 in annualized incremental compliance and administrative costs across five assumed issuers, or about C$17,704 each. That isn't a realistic estimate of what it costs to launch a stablecoin issuer. It covers selected regulatory tasks, not the broader cost of reserves, Canadian custody, technology, legal work, liquidity, security, staffing and distribution.
An issuer averaging less than C$500 million outstanding would also pay a C$25,000 annual Bank of Canada base assessment. That rises to C$350,000 from C$500 million to less than C$1 billion and C$750,000 at C$1 billion or more. Larger issuers also share variable supervisory costs, and the Bank expects to recover about C$2.5 million a year from the issuer market.
The assessment is only one piece of the business model. An issuer still has to spread custody, compliance, technology and redemption costs across enough customers and transaction volume to make the business worthwhile. Canada isn't shutting out smaller issuers, but the economics favour companies that can reach scale or arrive with customers, distribution or strong financial institution partners.
A fintech that truly needs its own stablecoin may decide the investment is worth it. Another company may reach customers faster by using an existing regulated stablecoin and putting its capital into payments, software, distribution or customer acquisition. Issuing the coin is becoming one way to compete in the market, not the only way to enter it.
Canadian PSPs and wallets will want access to stablecoins their customers already use, especially large U.S. dollar products. The proposed rules can recognize stablecoins issued by financial institutions operating under Canadian, provincial or foreign laws when those regimes provide similar protections for reserves, redemption, custody and yield.
A clear recognition process would give Canadian companies more stablecoins, liquidity and payment networks to build with. A slow or uncertain process would leave them with fewer options and could make integrations more expensive. Foreign issuer access therefore affects Canadian fintechs even when they have no plans to issue a stablecoin themselves.
The U.S. OCC finalized its GENIUS Act issuer rules on October 21, 2026, and they take effect January 18, 2027. Canada is still at the proposed regulation stage and currently plans to bring its framework into force in fall 2027. The OCC still has to open its application process, but U.S. firms now know the final federal rules while Canadian firms still have time to influence theirs.
NCFA's analysis of who can issue stablecoins under the new U.S. rules shows the same split emerging south of the border. Issuers carry the reserve, redemption and supervision burden. Payments and infrastructure companies can build around regulated stablecoins without taking on the full cost and responsibility of issuing them.
Canada doesn't need dozens of domestic issuers to build a competitive stablecoin market. It needs credible stablecoins that Canadian banks, PSPs, wallets and infrastructure companies can connect to without unnecessary cost or delay. The December 23 consultation gives market participants a chance to improve custody rules, proportional supervision, registration and access to credible foreign stablecoins before the framework is finalized.
Canada's custody rules give domestic financial institutions a role even when the stablecoin issuer is based elsewhere. Reserve assets must be held with a qualified custodian incorporated or formed in Canada and protected from claims against the issuer or custodian. A global issuer that wants to operate here may therefore need a Canadian bank or custodian as part of its setup.
That creates business in custody, reserve management and banking services without requiring the financial institution to compete for stablecoin users. Financial institutions also follow a different path under the Stablecoin Act because the issuer regime doesn't apply to stablecoins they issue. Canada could therefore support several ways to participate in the market rather than forcing every company through the same regulatory model.
Payments offer a much larger entry point. Finance Canada estimates that about 30 additional PSPs, including some crypto platforms, wallets and payment processors, would newly enter the Retail Payment Activities Act framework. More than 2,000 PSPs were already covered as of July 2026. The government doesn't expect those existing firms to face additional RPAA compliance costs when they add prescribed stablecoin payment functions because similar requirements already apply to their fiat payment activity.
More than 2,000 regulated PSPs could potentially add stablecoin functionality without becoming stablecoin issuers. Payment companies can build merchant acceptance or international transfers. Wallets can add payment and settlement features. Banks and custodians can manage reserve assets. Compliance firms can provide screening, monitoring and reporting tools.
Those companies compete for transactions, distribution and customer relationships rather than for the economics of issuing the money itself. NCFA has already tracked this move toward stablecoins as payment infrastructure. The proposed rules make it easier to see where Canadian firms can enter the market.
The commercial market around stablecoins could become much larger than the issuer market. A small number of regulated coins can support many PSPs, wallets, custodians, banks, compliance providers and software companies. For founders, that creates more ways to participate without tying up capital in reserves or running a redemption system.
Canadian PSPs and wallets will want access to stablecoins their customers already use, especially large U.S. dollar products. The proposed rules can recognize stablecoins issued under Canadian, provincial or foreign laws when those regimes provide similar protections for reserves, redemption, custody and yield.
Clear recognition would give Canadian companies more stablecoins, liquidity and networks to build with. A slow or uncertain process would leave them with fewer choices and could raise integration costs. Foreign issuer access therefore affects Canadian fintechs even when they have no plans to issue a stablecoin themselves.
The U.S. OCC finalized its GENIUS Act issuer rules on October 21, 2026, with an effective date of January 18, 2027. Canada is still consulting on proposed regulations and currently plans to bring its framework into force in fall 2027. The OCC still has to open its application process, but U.S. firms now know the final federal issuer rules while Canadian firms can still influence Canada's operating details.
The same commercial split is emerging in the U.S. Issuers carry the reserve, redemption and supervisory obligations. Payments and infrastructure companies can build products around regulated stablecoins without taking on the issuer's full operating burden.
Canada doesn't need dozens of domestic issuers to build a competitive stablecoin market. It needs credible stablecoins that Canadian banks, PSPs, wallets and infrastructure companies can connect to without unnecessary cost or delay. The December 23 consultation gives market participants a chance to improve custody rules, proportional supervision, registration and access to credible foreign stablecoins before the framework is finalized.
Canada may not need a large number of domestic stablecoin issuers to build a strong market. The bigger opportunity is to make regulated stablecoins easy for Canadian banks, PSPs, wallets and infrastructure companies to use. If those firms can connect to credible issuers without unnecessary cost or delay, stablecoins can become another financial rail for payments, settlement and treasury services. The strategic advantage then comes from the businesses built on top of that infrastructure, not from maximizing the number of companies issuing the underlying coins.
The National Crowdfunding & Fintech Association (NCFA Canada) is a financial innovation ecosystem that provides education, market intelligence, industry stewardship, networking and funding opportunities and services to thousands of community members and works closely with industry, government, partners and affiliates to create a vibrant and innovative fintech and funding industry in Canada. Decentralized and distributed, NCFA is engaged with global stakeholders and helps incubate projects and investment in fintech, alternative finance, crowdfunding, peer-to-peer finance, payments, digital assets and tokens, artificial intelligence, blockchain, cryptocurrency, regtech, and insurtech sectors. Join Canada's Fintech & Funding Community today FREE! Or become a contributing member and get perks. For more information, please visit: www.ncfacanada.org
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Oct 17, 2026 | Last Updated: Oct 30, 2026 | NCFA Fintech Whisperer | Artificial Intelligence And Data, Capital Markets Infrastructure And Funding, Competition And Market Structure, Cross Border Payments And FX, Cybersecurity Fraud And Financial Crime, Digital Assets Blockchain And Tokenization, Digital Identity And Trust, Embedded Finance, Payments Infrastructure And Money Movement, Regulation And Policy, Risk Compliance And Regtech, Sustainable Finance ESG And Financial Inclusion, Digital Banking And BaaS, Treasury Liquidity And Cash Management, Wealthtech Investing And Trading, Open Banking Open Finance And Data Sharing

] Image: Freepik
This live weekly NCFA intelligence page tracks financial technology developments that significantly affect how fintechs build, sell, raise capital, and operate under scrutiny. Coverage prioritizes Canada and includes global events that directly influence competitive conditions, market access, and execution realities across fintech sectors. This page will be updated throughout the week with market movers in a live format and then each week we'll close the prior week's contents in prep for the upcoming week, and continue on a rolling basis. (Missed prior week's Fintech Whisperer? (December 6-12, 2025, December 13-19, 2025, January 1-9, 2026, January 10-16, 2026, January 17-23, 2026, January 24-30, 2026, January 31-February 6, 2026, February 7-13, 2026, February 14-20, 2026, February 21-27, 2026, February 28-March 6, 2026, March 7-March 13, 2026, March 14-March 20, 2026, March 21-March 27, 2026, March 28-April 3, 2026, April 4-10, 2026, April 11-17, 2026, April 18-24, 2026, April 25-May 1, 2026, May 2-8, 2026, May 9-15, 2026, May 16-22, 2026, May 23-29, 2026, May 30-June 5, 2026, June 6-June 12, 2026, June 13-June 19, 2026, June 20-June 26, 2026, June 27-July 3, 2026, July 4-July 10, 2026, July 11-July 17, 2026, July 18-July 24, 2026, July 25-July 31, 2026, August 1-August 7, 2026, August 8-August 14, 2026, August 15-August 21, 2026, August 22-August 28, 2026, August 29-September 4, 2026, September 5-September 11, 2026, September 12-September 18, 2026, September 19-September 25, 2026, September 26-October 2, 2026, October 3-October 9, 2026, October 10-October 16, 2026).
Sezzle is trying to move from distributing credit through banking partners toward owning a federally supervised banking platform. If approved, that would give it more control over deposits, credit products, funding and customer economics. The next signals are OCC and FDIC decisions, capital requirements and how much of Sezzle's current partner model eventually moves inside the bank.
Mortgage technology only earns its place when it improves underwriting, servicing and broker economics. NORTHGUARD has acquired an operating base rather than starting with software alone. Founders and capital partners should watch how quickly it expands beyond Quebec, how it funds mortgages and whether faster decisions translate into stronger loan performance.
Ramp is seeking direct control over regulated investment and custody capabilities rather than relying entirely on external providers. Following its recent funding and expansion, the charter application adds another route for the company to broaden its financial services business. The key tests are OCC approval, which capabilities Ramp brings in-house, and how the new entity would work alongside existing bank partners.
SoFi is testing whether customers will keep digital dollar balances at a bank until they need to transact. The split between an insured deposit and a transferable stablecoin is commercially important because the legal protections change at conversion. Banks and fintechs should compare yield, redemption terms and access rather than treating both tokens as the same product.
Banks are starting to offer controlled data access where customers already work with AI, rather than forcing every question back into a banking app. Finom’s read-only design keeps the risk boundary relatively clear. The test is whether business owners use it routinely and whether future payment permissions can be added without sacrificing that control.
A bank can now test whether AI cuts investigation costs without losing control of the decision trail. Starling’s approach also raises the bar for vendors that sit outside the banking core. But speed isn’t enough. Compliance teams still need to know when a decision should be challenged, who owns an error and whether the economics hold across higher risk cases.
AI risk is moving from broad supervisory concern into bank level remediation work. The practical question is no longer whether banks recognize the threat. It's whether they can show the ECB who owns the risk, what systems need investment and how quickly controls can change as models become more capable. NCFA first tracked the supervisory direction in ESRB Warns Frontier AI Models Could Strain Cyber Resilience. The October action plans turn that warning into an execution deadline.
The FCA has made current obligations easier to test against real deployment patterns without creating a separate AI rulebook. Firms can compare their controls with concrete supervisory examples before weak ownership, monitoring or vendor dependence becomes an operating problem. NCFA has been tracking the same AI governance and compliance costs as financial institutions move from experiments into live workflows.
This expands the market infrastructure available for event driven securities products before the products themselves reach investors. The commercial test is whether Cboe and Robinhood can turn the new clearing authority into meaningful trading volume while keeping the risk, margin and settlement controls expected of regulated securities markets.
Private credit is becoming too large for market data firms to treat as a side business. LSEG is paying for proprietary information, workflow and distribution in a market it estimates at US$3.5 trillion. Investors should watch whether the deal improves pricing and risk visibility in less liquid credit or simply concentrates more valuable data inside one platform. The commercial upside depends on cross selling without weakening the specialist product customers already pay for.
Fund managers have a new capital application window, but founders still need to meet the investment criteria of the funds receiving public commitments. The capital won’t necessarily reach businesses outside the venture model. The immediate tests are which managers apply, how they attract pension and private capital, and whether founders beyond established funding hubs gain access.
This separates collateral custody from the funding used on a derivatives platform. Traders can keep crypto exposure while obtaining dollar margin, but the convenience comes with another lender, security interest and liquidation process. Custodians and brokers should watch collateral valuation, loan terms and who can act when markets gap outside banking hours.
French managers seeking US advisory access have a clearer supervisory cooperation arrangement behind their applications. The practical question is how registration processing, compliance preparation and ongoing examination responsibilities operate under the memorandum. Asset managers expanding internationally should distinguish the renewed application pathway from permission to begin serving clients without SEC registration.
Malaysia has moved tokenized fixed income into core market infrastructure rather than leaving it in a pilot. That matters because issuance, ownership records and settlement now sit inside infrastructure controlled by the central bank. NCFA previously tracked the earlier groundwork in Bank Negara Malaysia Onboards Ringgit Stablecoin And Tokenized Deposit Pilots. The next test is issuance volume and whether banks, governments and corporate borrowers start using the new rails regularly.
Mobile wallet providers and fintechs could gain more control over how contactless services reach iPhone users. Fees, available technical methods and contractual access are the practical questions. Firms considering wallet or account-based payment products should examine the consultation now, rather than planning around terms that have not yet been finalized.
Western Union already has customer distribution and cash access. The harder work is fitting a stablecoin rail into local payout rules, liquidity and customer support. Noah gains an important infrastructure role, but both firms still need to show where customers can actually use the service and whether fees fall without making redemption harder.
Cross border card programs become expensive when every new country needs another bank relationship and operating stack. Newline is using Fifth Third's balance sheet and Visa's network to give fintechs one route into more than 40 markets. The opportunity is meaningful for software platforms serving global employers and businesses. The real test is whether local authorization and issuing reduce fees and failed transactions enough to justify the added compliance work.
Fiserv is selling fewer integrations as a cross border growth advantage. Large merchants can add local payment methods without rebuilding settlement, reporting and operational controls market by market. The commercial test is whether that consolidation lowers total payment costs and speeds expansion enough to outweigh the value of using specialized providers in individual countries.
Cross-border digital money won’t scale if every bank has to negotiate a different settlement and compliance arrangement in every market. BLOOM puts three central banks at the table with the providers building those connections. Operators should follow the actual commercial agreements, supported assets and settlement rules, not just the growing participant list.
Stablecoin payments are being fitted into existing institutional fraud and compliance operations rather than treated as a separate risk channel. Banks and payment providers will need to test whether the combined intelligence improves decisions across conversion, transfer and payout stages, and how responsibility is divided between partners when a suspicious transaction is held or rejected.
Agent-driven commerce needs a way to recognize authorized software without giving fraudsters a free pass. Identity signals that enter the merchant’s existing risk engine offer one practical approach. The next test is whether checkout performance holds across more merchants, higher transaction volumes and contested payments, where evidence of the human mandate matters as much as recognizing the agent.
Loan participation payments are still full of reconciliation work after the money arrives. Moving the payment and loan records together attacks that operating cost directly. Banks should care less about the token label than whether the process shortens settlement, reduces exceptions and keeps every participant on the same loan balance. Repeat volume across more institutions would turn this from a useful transaction into infrastructure.
Institutional settlement now has another bank deposit option on a public blockchain where tokenized assets already trade. Treasury and digital asset teams can compare the legal claim, eligible counterparties, network access and liquidity against stablecoin-based settlement. The commercial test is whether institutions use the additional network for regular transactions, not simply as another technical connection.
Revolut now has another regulated entity it can use to expand crypto services without relying on one licensing base for every market. The value will come from where the Gibraltar permission actually opens distribution, custody and staking at scale. Investors should watch which markets are added, how quickly customers migrate to the new entity and whether regulatory expansion improves revenue without adding disproportionate compliance cost.
Switzerland already had deep crypto infrastructure, but retail fund approval changes distribution. Wealth platforms and advisers can now offer Bitcoin through a supervised investment product instead of pushing every customer toward direct ownership. The advantage is easier custody and familiar fund controls. The risk doesn't disappear, and competing providers will still have to win on fees, liquidity and investor trust.
Failed cross border payments are expensive because the bank or fintech still absorbs investigation, repair and customer service costs. Connecting verification across bank accounts and wallets gives institutions a chance to catch bad recipient data before funds leave. The value will show up in lower exception rates and fewer fraud losses. Adoption will depend on how much coverage Liink participants can use without adding another slow step to the payment flow.
Payment providers can’t afford a different wallet authentication arrangement for every country or partner. A common set of rules could lower integration costs and clarify liability. The industry now has time to shape those rules, but firms shouldn’t treat a published development plan as a completed authentication standard.
Financial identity checks are extending beyond onboarding into agent interactions, remote approvals and sensitive communications. Firms considering these tools need to test exactly which facts a proof establishes, what data must be retained and who accepts liability if a verified participant still gives fraudulent instructions. Design-partner use is an early distribution step, not proof of broad institutional adoption.
AI assistants are moving from advice into execution inside everyday business software. Stripe gives Claude access to payment and commerce tools while keeping the owner at the approval point. For founders, that can cut routine admin without handing an agent open ended spending authority. The commercial question is whether customers trust the controls enough to move real purchasing and finance work into the interface.
Stablecoin adoption is moving into a bank's existing retail distribution rather than asking customers to adopt a new crypto wallet. That cuts a major onboarding barrier. The numbers to watch now are wallet activation, payment frequency and merchant usage. If customers use RedCoin for ordinary transactions, regulated stablecoins start competing as payment products rather than mainly trading and settlement tools.
Payment margins can depend on who controls the local acquiring relationship. Nuvei can now bring more of that work inside its own network instead of paying intermediaries. Merchants should compare actual approval rates and processing costs after implementation. For Canadian payment firms, the licence shows how regulated local access can strengthen international distribution.
Agents that buy software services need spending limits that survive across multiple suppliers. Mastercard is testing a way to approve a budget once without granting open access to company funds. The commercial question is whether developers and merchants adopt one shared payment method instead of creating another patchwork of wallets, credits and billing accounts.
Euronet wants a larger share of the merchant relationship than payment processing alone. Connecting checkout, reconciliation and business software can improve retention and open new service revenue. Merchants will judge the platform on integration costs and daily usefulness. Competing payment providers should watch whether the Greece rollout turns Euronet’s distribution into a durable advantage.
Business payment automation is crossing a practical barrier: recognized agents can finish authorized transactions inside supplier portals without a person manually completing every step. Finance teams will need to define mandate limits, approval evidence and exception handling before using this model more widely. Successful pilot transactions are a useful milestone, but broad interoperability and dispute processes remain to be proven.
Card networks are designing agent payment protocols, but local bank account and wallet schemes can’t simply assume those rules fit. The council gives payment providers a place to settle the hard questions around mandates, identity and refunds before agents become another checkout channel. Its value depends on usable technical specifications and adoption by real payment schemes.
More official repo capacity gives market makers another liquidity buffer as Hong Kong builds deeper offshore RMB markets. The increase itself is modest, but the control point is important. Banks competing for RMB flows now have stronger public liquidity support behind market making, while exchanges, payment firms and treasury platforms get a deeper funding base for products built around offshore RMB.
Corporate treasurers leave cash idle when fund cut off times don't match when money becomes available. This transaction shows how tokenized bank money can connect that cash directly to an investment product without rebuilding the treasury stack around a stablecoin. The opportunity is better use of working cash. The business case will depend on redemption speed, fund access and whether the model scales beyond bespoke transactions.
The important shift isn't that an AI can read a balance. It can now carry out approved treasury work inside the financial account. Founders gain leverage if routine transfers and invoice payments move out of the admin queue without weakening controls. Banks and fintechs will need equally clear permission models because the competitive question is moving from who has an AI assistant to who safely lets it touch money.
AI and tokenization are no longer sitting outside the routine examination cycle. Firms using either in regulated workflows should expect questions about governance, supervision, records, controls and investor outcomes. For infrastructure providers, the combination of Treasury clearing and tokenization also puts implementation risk closer to the examiner's desk, not just the product roadmap.
Regulatory competitiveness now has explicit federal policy requirements, but better outcomes aren't automatic. Fintechs and investors should watch whether impact assessments, burden offsets and regulatory reviews actually reduce entry costs and approval friction. The same questions around OSFI's approach to growth and competition extend across federal regulation: will the new requirements make it easier for credible entrants to launch, scale and compete?
The final rule gives stablecoin issuers a clearer operating framework, but rewards remain a competitive fault line between banks and crypto platforms. Exchanges may still have room to pay customers when the reward isn't simply interest for holding a stablecoin, yet there is no blanket approval. Issuers and partners now need structures they can defend under OCC review. For banks, the deposit competition debate isn't settled just because the rule is final.
Crypto firms need to establish which activities require authorization and which qualify for exclusions before committing to licensing and operating structures. The distinction is particularly important for stablecoin payments, decentralized protocol interfaces and technical service providers. Firms affected by uncertainty over arranging permissions should engage with the FCA during the application window rather than assume that forbearance extends the application deadline.
Canada's existing restrictions can complicate fintech investments when a business combines financial services with other commercial activities. The proposed fintech investment reforms would give banks and insurers more room to invest, acquire and build technology businesses while retaining limits on their exposure. Fintech founders could gain access to strategic capital and established distribution networks. The commercial test is whether institutions use that flexibility to expand products and partnerships, rather than simply absorb promising competitors.
Hiring senior leaders can take months when every role requires an external approval. The UK is proposing to put more of that decision back on regulated firms without removing accountability. Boards and compliance teams should compare the proposed savings with the additional burden of documenting their own assessments before changing staffing or control plans.
Retail brokers now have a dated supervisory benchmark for scam controls rather than a general warning about fraud exposure. Firms should review the full guidelines and FAQs against their customer protection, escalation and operational processes, identify changes requiring development or vendor support, and budget the work ahead of June 2027.
A global crypto brand still needs effective controls inside its locally regulated payments entity. Reliance on a parent company doesn’t transfer accountability for safeguarding customer funds. Payment firms expanding into Europe should verify daily reconciliations, board visibility and the resources available to challenge a group service provider when problems appear.
Financial crime controls built around yesterday’s payment and customer patterns can miss risks introduced by agents, crypto products and new vendors. Firms should test whether their transaction evidence, staff escalation and sanctions processes still work across those channels. The consultation offers a chance to challenge unclear expectations before the final guide is issued.
A shared classification method could give issuers and capital providers a more consistent basis for assessing transition-finance claims. But the real allocation decisions will turn on sector thresholds, supporting evidence and independent review. Investors and borrowers should not treat today’s methodology as a certification of individual projects or assume that unsettled greenwashing and disclosure risks have disappeared.
Financial data partnerships now carry clearer accountability beyond the initial customer consent. Banks and fintech aggregators need to map every downstream recipient, inspect contract rights and test whether their oversight works when data are reused. Access to the rail is valuable, but it won’t excuse weak controls at the next company in the chain.
Canada put C$1.75 billion in venture and growth capital on the table and introduced new rules to make federal regulation more competitive. Internationally, banks and fintechs advanced tokenized deposits, cross-border settlement and AI-controlled financial transactions. These are becoming practical business decisions about who controls customer access, payment infrastructure and compliance costs. The opportunity for Canadian fintechs is to compete on execution, building products customers trust, securing distribution and turning regulatory change into commercial advantage.
NCFA offers various curated resources to help founders and investors stay current on developments that impact fintech markets. Get the weekly Whisperer and related market intelligence through NCFA's newsletter, view the latest fintech news and insights, industry research, or launch into emerging financial innovation opportunities.
The National Crowdfunding & Fintech Association (NCFA Canada) is a financial innovation ecosystem that provides education, market intelligence, industry stewardship, networking and funding opportunities and services to thousands of community members and works closely with industry, government, partners and affiliates to create a vibrant and innovative fintech and funding industry in Canada. Decentralized and distributed, NCFA is engaged with global stakeholders and helps incubate projects and investment in fintech, alternative finance, crowdfunding, peer to peer finance, payments, digital assets and tokens, artificial intelligence, blockchain, cryptocurrency, regtech, and insurtech sectors. Join Canada's Fintech & Funding Community today FREE! Or become a contributing member and get perks. For more information, please visit www.ncfacanada.org
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October 21, 2026 | NCFA Insight | Regulation And Policy, Digital Assets Blockchain And Tokenization, Competition And Market Structure

On October 21, 2026, the U.S. Office of the Comptroller of the Currency OCC finalized rules under the GENIUS Act for payment stablecoin issuers under its supervision. The rules take effect January 18, 2027 and cover reserves, redemption, capital, governance, custody and regulatory approval. The United States now has a clearer path for regulated stablecoin issuance, but a licence alone won't make a viable issuer. Companies also need capital, liquid reserves, banking relationships, operating systems and customers.
Existing issuers may have an early advantage. Qualifying firms already issuing stablecoins in the United States can request temporary relief while the OCC reviews their applications. New entrants generally need approval before launching. Federal approval can also reduce the need for separate state issuer licences, giving successful applicants a simpler route to national expansion.
The GENIUS Act created the federal framework in July 2025. The OCC's final stablecoin rule now spells out how regulated issuers must operate. It covers eligible bank subsidiaries, federally approved nonbank issuers and certain state supervised firms. Foreign issuers follow a separate registration path. Wallets, exchanges, payment companies and custodians don't become stablecoin issuers simply because they handle someone else's coin.
Issuers must hold enough qualifying reserves to cover every stablecoin they have outstanding. At least 5% must stay immediately available, eligible Treasury securities generally can have no more than 93 days remaining maturity, and many exposures to a single counterparty are capped at 40%. That money is there to repay customers, not fund salaries, product development or marketing.
Managing those reserves is now part of the business. Issuers need enough cash and liquid assets to meet redemptions while spreading risk across banks, custodians and investments. Higher yielding assets may generate more income, but the rules limit how far an issuer can stretch for return.
Valid redemptions generally must be processed and payment initiated within two business days. The money may take longer to reach an outside account. If redemption requests exceed 10% of a stablecoin brand's outstanding value within 24 hours, the issuer must notify the OCC and needs approval for more time.
The OCC tightened that rule from its February proposal by removing an automatic seven day extension after the 10% threshold was reached. An issuer facing a rush for cash can't simply slow redemptions until markets calm down. It needs enough liquidity and dependable banking and custody relationships before stress hits.
Reserves aren't the only money tied up in the business. Issuers covered by the OCC capital framework generally need at least US$5 million in regulatory capital, with higher amounts possible depending on risk and licensing conditions. They also need a separate backstop equal to 12 months of operating expenses. Up to half of that backstop can come from qualifying subordinated debt instead of equity.
The three pools serve different jobs. Reserves repay customers. Capital absorbs losses. The backstop keeps the company operating during a serious disruption or an orderly wind down. A founder can't use the same dollars freely for all three.
Growth can make those requirements more expensive. More staff, technology and compliance spending can increase the required backstop, while higher risk can lead the OCC to demand more capital. An issuer that remains below its required levels can face limits on new issuance. Continued shortfalls can ultimately force it to liquidate reserves and redeem outstanding coins.
Issuers also need governance, financial controls, custody arrangements, audits and systems that keep outstanding coins, reserve assets and redemptions in sync. They can hire outside custodians and compliance providers, but responsibility stays with the issuer. Bank affiliated issuers may be able to use existing parent company risk systems, giving them an operating advantage over firms building everything from scratch.
The licence also has boundaries. Stablecoin issuers can issue and redeem coins, manage reserves, provide permitted custody services and carry out activities that support those functions. They can charge disclosed purchase or redemption fees, but GENIUS Act approval doesn't give them permission to offer every financial product.
The GENIUS Act says stablecoin issuers can't pay interest or yield simply because someone holds or uses their coin. The OCC's February proposal went further by targeting some payments made through affiliates or other closely connected companies. In the final rule, the OCC dropped that approach after deciding it could catch legitimate business payments and make the line even less clear.
That gives exchanges, wallets and other platforms more room to offer rewards funded through their own businesses, but it doesn't give them a free pass. An issuer still can't pay someone else to pass prohibited yield on to customers, and the OCC can step in if a rewards program is really just issuer interest in another form. Platforms may therefore have more room than issuers to compete for stablecoin customers with rewards. NCFA has tracked that fight in Stablecoin Interest and Rewards A Regulatory Fault Line and Stablecoin Rewards Keep Pressure On US Crypto Bill.
The January 18 deadline creates a timing problem for companies already issuing stablecoins. A firm can submit its application and still be waiting for OCC approval when the new rules take effect. If it keeps issuing without the required approval, it can face serious consequences.
The OCC's application and waiver guidance gives some existing issuers a temporary bridge. A company with a substantially complete application pending by January 18 can ask for relief. The OCC says it generally expects to approve that relief for covered issuers already operating in the United States unless there is a strong reason not to.
The waiver isn't automatic and can last no more than 12 months from January 18. New issuers shouldn't expect the same treatment and generally need approval before launching. An insured bank itself can't use this waiver, although an eligible subsidiary may qualify.
That gives established issuers a head start. They may keep serving customers while their applications are reviewed. A startup can be paying staff, lawyers, compliance teams and technology costs before it earns revenue from a single coin.
Applications weren't open when the OCC issued its final rules on October 21. The agency is waiting for Office of Management and Budget approval before it can begin accepting them. Once applications open, the OCC has 30 days to decide whether a filing is substantially complete. After that, the application is deemed approved after 120 days unless the OCC denies it first.
Federal approval can also make national expansion easier. A federally qualified stablecoin issuer generally doesn't need a separate state issuer licence for the same business. State consumer protection and other laws still apply, but the company can avoid building a separate licensing strategy for every state.
The state route remains open. A state supervised nonbank issuer that grows beyond US$10 billion in outstanding issuance generally has 360 days to move into the federal framework or stop increasing net issuance. It can ask to stay under state supervision, and some established state regimes receive favourable treatment under the rule.
So, the market has more than one route to scale. Some state issuers can keep their existing regulator, while smaller OCC issuers may face less frequent examinations. But size still helps. Audits, treasury operations, technology and supervision are easier to absorb when an issuer already has meaningful volume.
Distribution may be an even bigger barrier than regulation. Existing issuers can already be listed on exchanges, integrated into wallets and accepted by merchants. A new entrant still has to convince the market to use another stablecoin after paying to build the regulated business behind it.
The OCC also published revised weekly and quarterly reporting forms. Proposed first reporting dates are January 25 and March 31, 2027. The forms are still going through approval, so the individual fields aren't final yet.
Those requirements also create opportunities for companies that don't issue stablecoins. Banks can provide settlement accounts, custodians can hold reserves, and technology firms can handle reporting, reconciliation, redemptions and compliance. For some fintech founders, building the infrastructure around stablecoins may be a better use of capital than issuing one themselves.
Canada enacted its Stablecoin Act on March 26, 2026, but its main operating provisions haven't come into force. The framework will put covered nonbank issuers under Bank of Canada oversight through registration, with requirements for reserves, redemption, governance and reporting once implementation is complete.
NCFA's Canadian stablecoin regulations guide examines the enacted framework and the rules still needed before it operates. The Canadian and U.S. systems aren't interchangeable. Canadian registration won't authorize issuance in the United States, and U.S. approval won't replace Canadian requirements.
A Canadian issuer seeking U.S. customers faces additional conditions. Foreign issuers need an eligible home regulatory framework, OCC registration and ongoing U.S. supervision. They must also make required records available in the United States and maintain arrangements that support redemption obligations to U.S. holders.
That makes issuing a U.S. dollar stablecoin in America a significant commitment for a Canadian fintech. The company needs more than a Canadian registration and strong technology. It needs capital, reserve management, U.S. regulatory access, distribution and enough customers to justify the fixed cost of operating the product.
Canadian banks are approach approaching the market differently. In September 2026, TD and Scotiabank joined a 21 institution stablecoin initiative targeting a U.S. dollar product in 2027. The product isn't live, but the participating banks already have capital, compliance teams, payment relationships and institutional customers.
Fintechs don't have to compete by issuing another coin. A Canadian payments company can integrate a regulated stablecoin from an approved issuer. Others can build merchant settlement, wallets, reserve systems, compliance technology or redemption tools. Those businesses can participate in stablecoin growth without carrying the obligation to back and redeem every coin themselves.
Issuance offers more control over economics and distribution, but the OCC rule shows the cost of that control. Infrastructure businesses give some of it up, yet they can focus their capital on a narrower customer problem and potentially sell to several issuers.
The market may therefore split in two. Stablecoin issuance could concentrate among firms with strong balance sheets, banking relationships and distribution, while payments and infrastructure attract a broader group of fintechs. For Canadian founders and investors, choosing which layer to compete in may matter more than simply deciding whether stablecoins will grow.
The GENIUS Act removes much of the uncertainty around regulated stablecoin issuance, but it doesn't make issuance a lightweight fintech business. Existing issuers have a transition route and federal approval can simplify national expansion, while newcomers must finance the business before they build meaningful volume. Will the new rules support a wider group of viable issuers, or will the better opportunity for new entrants be the payments, custody and compliance infrastructure built around them?
The National Crowdfunding & Fintech Association (NCFA Canada) is a financial innovation ecosystem that provides education, market intelligence, industry stewardship, networking and funding opportunities and services to thousands of community members and works closely with industry, government, partners and affiliates to create a vibrant and innovative fintech and funding industry in Canada. Decentralized and distributed, NCFA is engaged with global stakeholders and helps incubate projects and investment in fintech, alternative finance, crowdfunding, peer-to-peer finance, payments, digital assets and tokens, artificial intelligence, blockchain, cryptocurrency, regtech, and insurtech sectors. Join Canada's Fintech & Funding Community today FREE! Or become a contributing member and get perks. For more information, please visit: www.ncfacanada.org
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October 21, 2026 | Insight | Capital Markets Infrastructure And Funding, Digital Assets Blockchain And Tokenization, Wealthtech Investing And Trading

On October 20, 2026, the U.S. Securities and Exchange Commission published guidance on tokenized stock trading, clarifying how certain U.S. public shares can trade on blockchain platforms without a company's affirmative approval. The guidance follows the SEC's September 17 Innovation Exemption, which allows limited trading of eligible public stocks through new digital venues. Sixteen companies, including Microsoft, Alphabet and Goldman Sachs, have reportedly objected to having their shares traded on the proposed OKXICE platform.
The exemption doesn't cover every public stock, and companies can block certain trading arrangements. Venues also face limits on which securities they can offer and how much trading they can handle. For investors and market operators, the questions are which stocks qualify, what ownership rights come with the tokens and whether these new platforms can compete with traditional exchanges. The October 20 guidance further explains how the existing exemption works without introducing new regulations.
The SEC allows qualifying venues to trade tokenized National Market System stocks, which generally include eligible shares listed on major U.S. exchanges and certain exchange traded products. The exemption covers qualifying securities tokenized by their issuers and arrangements involving independent third parties. It excludes rights, warrants and tokens that merely track a stock's price without providing the same ownership rights as the underlying security.
The SEC separates eligible stocks into two groups. Tier 1 includes shares in the S&P 500 and Russell 1000, along with certain qualifying exchange traded products. Major companies such as Apple, Microsoft, Alphabet and Nvidia fall within those indexes, although that doesn't automatically make their shares available on a tokenized venue. Tier 2 includes other eligible listed securities outside Tier 1, giving smaller public companies a potential route into these markets.
The limits are strict. A qualifying venue can offer up to 75 Tier 1 symbols, with trading in each capped at 0.25% of the stock's average daily share volume during the previous month. Tier 2 allows up to 250 symbols, with a 2.5% volume cap. Related venues must combine their trading activity when calculating these limits.
Consider a Tier 1 stock averaging 10 million shares traded daily. A qualifying venue and its affiliates could trade up to 25,000 tokenized shares per day. A Tier 2 stock with the same volume would have a limit of 250,000 shares. A first breach of a stock's volume limit doesn't automatically require suspension, but subsequent breaches require a three month trading pause for that security.
Investors must receive the same rights and privileges as holders of equivalent conventional shares. That includes applicable dividends and voting rights. The arrangements supporting those rights must be verified, and venues must meet requirements for trading halts, transaction records and technology safeguards. A token offering only synthetic exposure to a share price doesn't qualify under this exemption.
OKXICE is one of the first proposed venues testing the SEC's approach. It's a joint venture owned equally by Intercontinental Exchange, parent of the New York Stock Exchange, and OKC USA Holding, part of the OKX group. Its public trading notices describe a platform where approved investors could trade tokenized U.S. stocks against stablecoins using automated liquidity pools instead of a conventional stock exchange order book.
OKXICE plans to use Uniswap v4 technology on the X Layer blockchain to let approved investors trade tokenized stocks through pools of shares and stablecoins. Investors would need to verify their identities and use approved digital wallets. OKXICE says it won't hold customer assets or sell newly issued shares. Publishing its plans doesn't mean the SEC has approved the platform or that trading has started.
OKXICE initially proposed 63 stock symbols from 62 companies. Nine companies had objected by October 15, including Broadcom, Verizon, UnitedHealth, CoreWeave and AppLovin. Reporting on October 19 identified seven more, bringing the total to 16 companies, including Microsoft, Alphabet, Goldman Sachs, Qualcomm, Caterpillar, McDonald's and Western Digital.
One of the 16 objectors, Cerebras Systems, wasn't on the original proposed list. That means 15 of the original 62 companies had objected, leaving 47 without a reported objection at that point. Silence doesn't mean approval. It only means the company hasn't exercised its right to block that particular trading arrangement.
Applied Optoelectronics explained its concerns to The Wall Street Journal. The company questioned whether tokenized trading would benefit shareholders and worried about possible effects on its share price, trading activity and volatility. It also didn't want investors to mistake an independent tokenized offering for one supported by the company.
Under the SEC exemption, companies have 30 calendar days after receiving notice to object. If they object in time, that venue can't offer their tokenized shares under the exemption. The objection doesn't automatically prevent every other form of stock tokenization.
Trading platforms face a separate 30 day requirement. They must publish their operating plans at least 30 calendar days before trading begins. The SEC's October 20 guidance confirms that venues can publish proposed stock lists while companies are still deciding whether to object. They must disclose which decisions remain pending and update their lists as objections arrive or the periods expire.
Andrew Cuomo, co-chair of OKXICE, described the issuer objections as a "natural response". He said the venture expected some companies to wait before participating. Whether that resistance eases will depend partly on how the first venues operate and what benefits they can demonstrate to investors and issuers.
The potential appeal is clear. Investors could trade familiar U.S. shares outside regular exchange hours, hold them through approved digital wallets and use blockchain systems to complete transactions. But being able to trade at any hour doesn't guarantee liquidity or a competitive price. New venues still need enough investors and market makers to support reliable trading.
OKXICE proposes using automated market makers instead of matching every buyer and seller through a traditional order book. Liquidity providers would supply tokenized shares and stablecoins to trading pools, earning fees while taking market risk. If those pools don't attract enough capital, investors could face wider spreads or prices that differ from the conventional stock market.
Nasdaq has proposed a different model. In September 2025, Nasdaq sought SEC approval for tokenized stock trading within its existing exchange system. Investors could choose traditional or tokenized settlement, with the Depository Trust Company handling the process. The same trading rules, security identifiers and shareholder rights would apply.
Chuck Mack, Nasdaq's Senior Vice President of North American Markets, explained the company's approach.
"Past market failures teach us that it is imperative to ensure governance, resilience, and investor protection are embedded from the outset."
The two companies are taking different approaches. OKXICE plans to build a new blockchain trading platform, while Nasdaq wants to add tokenized stocks to its existing exchange system. Nasdaq's proposal follows a separate regulatory process and predates the October 2026 objections. For investors, the real focus is which approach offers better prices, reliable trading and strong shareholder protections.
Tokenized shares still need to give investors the same ownership rights as regular stocks. That means making sure dividends reach the right people, shareholders can vote and stock splits or mergers are recorded correctly. Investors who control their own digital wallets also need to protect their access keys. Losing them could mean losing access to their investments.
Investor protections can also differ. OKXICE isn't registered as a traditional stock exchange for trading under this exemption, so some rules that apply to established exchanges don't apply in the same way. The SEC exemption is temporary and lasts five years. That gives regulators time to assess how these markets operate before deciding whether to introduce permanent rules.
For Canadian fintech founders, the business opportunities go beyond operating a trading platform. These markets need companies that can protect assets, maintain accurate ownership records, verify compliance and supply trading liquidity. Brokers and transfer agents may also need new technology to connect blockchain transactions with existing securities systems. Demand for those services will depend on whether investors actually use the new markets.
Canada is also looking at how tokenized securities could trade under its own rules. In March 2026, the Canadian Securities Administrators launched Project Tokenization to explore trading, custody and settlement of digital securities. The initiative has since engaged more than 240 organizations, as reviewed in NCFA's capital markets innovation analysis. Unlike the SEC, Canada hasn't introduced a comparable exemption for tokenized public stock trading. For Canadian exchanges and fintech founders, the U.S. experiment offers an early look at which business models work and where existing securities rules may need to adapt.
If tokenized stocks attract buyers and sellers, keep trading costs competitive and preserve shareholder rights, they could become a useful alternative. If not, investors may have little reason to move away from traditional stock markets.
The National Crowdfunding & Fintech Association (NCFA Canada) is a financial innovation ecosystem that provides education, market intelligence, industry stewardship, networking and funding opportunities and services to thousands of community members and works closely with industry, government, partners and affiliates to create a vibrant and innovative fintech and funding industry in Canada. Decentralized and distributed, NCFA is engaged with global stakeholders and helps incubate projects and investment in fintech, alternative finance, crowdfunding, peer-to-peer finance, payments, digital assets and tokens, artificial intelligence, blockchain, cryptocurrency, regtech, and insurtech sectors. Join Canada's Fintech & Funding Community today FREE! Or become a contributing member and get perks. For more information, please visit: www.ncfacanada.org
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On October 17, 2026, Finance Canada published proposed fintech investment and technology regulations for powers Parliament approved in June 2018 and never brought into force. The package reaches more than 400 federally regulated financial institutions.
Finance now says the older rules can “prevent or complicate” fintech investment, limit capital flowing into innovative sectors and impede productivity growth. Eight years after Parliament acted, the operating rules are still only proposed.
The delay wasn’t one long consultation. Finance’s own record shows six concrete problems. Officials had to draw the regulatory perimeter between finance and technology, preserve the barrier against unrelated commerce, set revenue and regulatory capital limits, stop the rules from squeezing smaller institutions, and cut reporting requirements industry said were too heavy. Then Parliament had to repair defects in the 2018 statute in 2024. Six problems turned one reform into eight years of rulemaking.
This wasn’t a ban on fintech investment. Banks and insurers could still buy businesses that fit the existing rules. The trouble started when a fintech mixed finance with commercial software or expanded after an institution had invested. Banks had already warned that some domestic technology approvals took three to four months. The 2026 proposal would finally give qualifying mixed businesses a new route when at least 60% of their activity is financial, subject to separate limits on the investor.
Finance opened the review in 2016. It held 32 meetings and received 63 written submissions, then received 300 submissions in 2017, with 25 focused on fintech. Finance later acknowledged that incumbent institutions and industry associations were better represented than independent fintechs and venture investors.
Bankers came with a practical complaint. The Canadian Bankers Association’s 2017 submission said some domestic technology approvals could take three to four months and covered only the activities named in the application. That’s a poor fit for a fintech that can add a product, market or subsidiary in the time it takes a large institution to finish an approval process.
Founders weren’t building tidy regulatory categories. Payments were moving into merchant software, identity tools could serve banks and law offices, and data companies were becoming financial infrastructure while selling into other industries. The old rules drew cleaner lines than the market did.
Investors wanted a wider lane too. Finance said collaboration could pair fintech speed with the balance sheets and customer relationships of established institutions. Portag3 Ventures, then backing Canadian companies including Wealthsimple, Borrowell and KOHO, supported broader investment flexibility and argued that bank financing and collaboration were important to the fintech ecosystem. Capital and distribution were already part of the policy problem.
Under the Bank Act route described by the CBA, a substantial investment generally had to stay inside permitted activities. If even one ancillary activity or a downstream subsidiary moved outside that list, the bank could face another approval, a different investment classification or divestment. The CBA called the restriction a “significant impediment” with the potential to restrict Canadian innovation.
Insurers ran into the same boundary from another direction. The life insurance industry’s 2017 submission said an insurer could use identity or anti money laundering technology inside finance but couldn’t freely sell the same capability to law offices, real estate firms, other businesses or government. Useful technology could have a broader market, while the ownership and commercialization rules stayed narrow.
A growing fintech can create a problem for the shareholder that helped fund it. Add inventory software, merchant analytics or a commercial subsidiary because customers want them, and the business may no longer fit the permission that supported the original bank investment. The CBA warned that this could discourage fintechs from working with banks.
Insurers faced a similar commercial choice. A tool built for regulated finance might have customers far beyond finance, yet the legal route could narrow who could own the business or where the product could be sold. That can influence which investor a founder takes, how the company is structured and which markets it enters next.
A founder weighing a new product couldn’t look only at customer demand. If the activity fell outside a bank investor’s permitted business, expansion could trigger another approval, a different investment classification or a divestment decision. The investor that helped finance growth could become a constraint on the next stage of growth.
No named transaction has been documented as abandoned for this reason. That doesn’t erase the mechanism recorded in the 2017 submission, because a weak legal fit can kill an idea before anyone files an application. Venture investors weren’t subject to the same federal financial institution business powers.
Parliament responded on June 21, 2018. The 2018 Budget Implementation Act broadened permitted technology activities, removed prior ministerial approval for the expanded nonfinancial activities, widened referral powers and created a new investment category for companies whose businesses were mostly financial services. The law clearly moved toward more flexibility.
But Parliament didn’t define how much of a company had to be financial to qualify as a majority financial services entity. It also left the revenue, capital, reporting and transaction conditions to regulation. Without those operating rules, institutions couldn’t use the new powers and stayed under the older framework.
Parliament gave banks and insurers broader ownership powers in June 2018. Finance still had to define the majority test, exposure limits and safeguards before anyone could use them. The authority existed. The investment route didn’t.
That left financial institutions making real investment decisions under the old framework while fintech business models kept widening. A company could fit the rules when a bank first invested and create a new legal problem later simply by adding a commercial activity customers wanted.
The amendments expanded the information and technology activities federally regulated financial institutions could conduct. They also widened referral and agency powers, removed ministerial approval from the new permitted nonfinancial activities and created a majority financial services investment category. The direction was broader participation, not unrestricted commercial ownership.
The new category was meant for businesses that were primarily financial but also did other commercial work. Parliament supplied the authority but not the operating definition of majority or the limits around its use. Finance still had to turn the statute into rules a transaction team could actually use.
After Royal Assent, Finance worked with the CBA, the Canadian Life and Health Insurance Association and OSFI. The first problem was the regulatory perimeter. Finance called separating new technology activities from core financial services a “serious technical challenge”, especially when the same staff, assets and systems served both. Officials also had to preserve existing investment prohibitions and keep visibility into the new business.
Then came the operating limits. In 2019, officials worked through revenue caps, regulatory capital exposure, annual reports and transaction conditions. A 2020 technical review exposed two more problems. Uniform rules could box out smaller institutions, while the proposed reporting package could impose a significant burden. Finance later revised both.
The delay didn’t come from one unresolved issue. It came from six. Finance had to separate finance from technology, preserve limits on unrelated commerce, set revenue and capital exposure caps, give smaller institutions enough room to compete, and reduce reporting requirements industry said were too burdensome. Those were the five regulatory design problems documented through the consultation record.
The sixth problem sat in the law itself. Bill C-59 received Royal Assent in June 2024 and made technical corrections to the 2018 law. It fixed discrepancies between the English and French provisions and clarified that the expanded technology powers were limited to information technology. By then, Finance had already consulted in 2019, reviewed a draft in 2020, consulted again in 2021 and returned with another draft in 2024.
Every revision created another round of legal or regulatory work. Caps changed. Reporting changed. Parliament repaired the statute six years after passage. The first public regulations still didn’t reach Canada Gazette Part I until October 2026, even though stakeholders were asking by 2024 for the powers to come into force “as soon as feasible.”
Finance began implementation work after Royal Assent in 2018. By early 2019, discussions had expanded to revenue and capital limits, reporting and transaction conditions. The initiative entered Finance Canada’s fintech regulatory implementation plan in July 2020, followed by further consultations on regulatory parameters in summer 2021.
The 2020 technical review found problems with the treatment of smaller institutions and the reporting burden. Finance revised the caps and streamlined reporting before consulting again in 2024. Parliament enacted the technical statutory corrections that June. Canada Gazette Part I finally published the regulatory draft on October 17, 2026.
The market didn’t wait for the rulebook. By 2019, one industry study counted roughly 1,000 Canadian fintech companies, more than 30,000 employees and about C$30.5 billion in startup value. Founders, banks and investors kept building around the permissions they actually had.
National Bank took control of Flinks in 2021. Its disclosed transaction included C$73 million for voting preferred shares followed by another C$30 million investment. The bank’s interest rose to 85.9%.
RBC bought WayPay in 2019 to expand automated business payments and account reconciliation. Canada Life acquired ClaimSecure in 2021, adding 1.25 million plan members and technology handling more than C$1.2 billion in annual claims payments. Canada Life and ClaimSecure later launched a combined benefits product.
Those deals matter because they rule out the easy story. Canada didn’t ban institutional fintech investment, and banks and insurers kept buying businesses that fit the existing framework. The squeeze showed up at the edges, where finance blended with commercial activity or a company later expanded beyond the legal fit that supported the original investment.
By October 2026, Flinks had moved beyond financial data connectivity into banking development, payment integrations, account switching and managed services. That’s exactly the kind of expansion a strategic shareholder may want to keep backing. Under the older framework, a different commercial move could force the shareholder to stop and ask whether it could legally stay invested.
National Bank’s 2021 results disclosed the Flinks transaction. RBC described its WayPay acquisition as part of expanding digital capabilities for commercial clients. These deals establish what the old framework could accommodate.
Canada Life’s ClaimSecure acquisition added 1.25 million plan members, while the later SecurePak launch combined ClaimSecure technology with Canada Life products. None of these transactions has been established as a special exemption connected to the dormant 2018 amendments. They’re examples of what was possible, not proof that the restrictions never bit elsewhere.
The CBA warned that the legal fit could affect a deal before anyone applied for approval. If a fintech needed capital quickly, a bank bid carrying a regulatory condition could lose to cleaner, faster money. A later business change could also force the bank back into approval or divestment. A lost opportunity can disappear before Ottawa ever sees a file.
Finance expects more activity once the new route is usable. Over the past decade, roughly one institution per year sought the relevant ministerial approvals. Finance now assumes large banks will average two qualifying investments annually and large insurers one. The figures aren’t directly comparable, but Finance itself expects more activity because the process should be faster, less costly and more certain.
Government data can count approvals. It can’t count the bank bid that was never made, the expansion pushed into another company or the investor a founder never approached because the legal fit was poor. It can’t count technology an insurer decided not to sell outside finance either. Those decisions rarely leave a public record.
The economic toll starts before an approval file exists. A bank offer with conditions can lose to faster capital. A founder can split a product, delay a commercial move or avoid an investor whose ownership may become a future constraint. None of those choices needs a rejection letter to change the company’s path.
The businesses under the most pressure were the ones mixing finance with something else. Embedded finance can combine payments or lending with merchant software. Identity, fraud and compliance tools can sell to banks, retailers, law offices and governments. AI and data companies can support financial decisions while building a much wider enterprise market.
Research published in 2019 linked Canada’s financial services productivity gap to restrictive regulation that weakened competition, capital formation and fintech scaling. It also noted that the investment reforms already passed still lacked clarity and an effective date. The report didn’t isolate the dormant 2018 amendments as a standalone productivity cost, but the implementation gap was visible years before the 2026 proposal.
The October proposal finally puts a number on majority. A target can qualify when at least 60% of its business consists of qualifying financial activity, measured using whichever produces the highest result among revenue, operating expenses or assets. That gives younger or differently structured companies more than one way to clear the test.
The investor has separate limits. Institutions with more than C$12 billion in equity would face a 10% nonfinancial revenue ceiling and a 10% regulatory capital exposure limit. Small and medium institutions with C$12 billion or less in equity would get 15% revenue headroom while keeping the same 10% capital limit.
Take a payments company that also sells merchant software. Under the older activity based route, one impermissible commercial activity could knock the company out of that investment permission. Under the proposal, a business with 70% qualifying financial activity and 30% other commercial activity could potentially qualify. The 70 and 30 split is illustrative, but the business consequence is straightforward. The founder may no longer have to strip out every useful commercial feature just to keep a bank investor eligible.
The percentages don’t describe the same limit. The historical 5% exemption covered certain bank technology investments without approval and required the investee to stay within prescribed activities. The new 60% test applies to the target company’s business mix. The 10% and 15% limits apply to the investing institution’s aggregate nonfinancial business. There isn’t a simple old cap and new cap comparison.
The examples below put the rule into business terms. They’re illustrations of how an investment decision could change, not transactions proven to have been blocked. Securities, digital assets, privacy, lending, payments and insurance rules still apply on top of the new investment permissions.
| Fintech investment example | Existing framework | Proposed permissions |
|---|---|---|
| Payments and merchant software | A bank can own permitted payments or technology activities, but a fintech adding inventory management or merchant retail operations outside those permissions may become harder to acquire or retain. | A bank could potentially invest in the combined payments and merchant software company when the target meets the 60% financial activity test and the bank stays within its own limits. |
| Lending, embedded finance and SME platforms | A platform mixing lending or payments with booking, loyalty or other commercial software can fall outside an existing investment route when an impermissible activity sits in the target or a subsidiary. | The mixed business route could make a qualifying embedded finance platform eligible without stripping out every commercial feature. Lending and consumer protection rules would still apply. |
| Digital identity, fraud and RegTech | An insurer can use or license some compliance technology within finance, while its 2017 industry submission identified limits on selling the same technology to law offices, real estate firms and other nonfinancial customers. | Broader technology permissions could support identity verification, fraud checks and compliance software used across industries, subject to the statutory boundaries and applicable approvals. |
| Insurance and health benefits technology | An insurer can already acquire eligible insurance businesses, as Canada Life did with ClaimSecure. Commercial activity beyond the permitted business can still change what an insurer may own or sell. | A mixed insurance technology company could be easier to acquire if its qualifying financial activity clears the majority test. Commercial activity would still count toward the institution's limits. |
| AI and financial data tools | Banks can develop and buy permitted financial analytics. A fintech expanding into general retail or enterprise AI may cross the investor's activity permissions or require another legal structure. | Expanded technology permissions or the majority financial services route could support a wider product mix. Privacy, AI and sector rules would remain separate. |
| Wealth technology and investing platforms | A digital wealth platform may fit an existing financial investment route, while broader enterprise analytics or commercial software can complicate that route if the activities move outside permitted business. | A qualifying wealth platform could combine investment services with a larger adjacent technology offering if it clears the majority test and the investor stays within its limits. Securities registration would remain separate. |
| Blockchain and tokenized asset infrastructure | The insurance industry cited distributed ledger software for asset managers as a financial technology example in 2017. That did not make every blockchain or token business an eligible investment. | A bank or insurer may have more flexibility to invest in financial ledger software, asset servicing or a mixed technology provider when its actual activities qualify. Securities and custody rules remain separate. |
| Tokenized deposits and settlement | Banks can already develop permitted deposit and settlement products. Canada's major banks are exploring tokenized deposits, so the dormant 2018 amendments were not a proven block to those projects. | Broader investment powers could support qualifying software providers, service companies and partnerships around tokenized banking infrastructure without changing the legal treatment of deposits. |
| Crypto platforms and stablecoin services | An exchange, custody business or stablecoin issuer does not become an eligible bank investment simply because it uses software or blockchain. Securities, prudential and other restrictions still matter. | The proposal creates no blanket crypto permission. A specific business model would still need to satisfy the investment test and every other applicable regulatory requirement. |
| Crowdfunding and private capital markets | A financing platform may qualify as a financial business, but unrelated marketplace or software activity can complicate a financial institution investment under the existing activity tests. | A platform combining qualifying financial activity with commercial software could potentially fit the new category. Crowdfunding exemptions and securities rules would still apply. |
| Customer referrals and SME software | Existing bank referral powers are principally framed around financial service providers, limiting some referrals into broader commercial platforms. | Expanded referral powers could let a bank connect customers with eligible funding, invoicing and business software providers. Referral permission remains distinct from acquisition permission. |
The insurance industry’s 2017 submission specifically cited distributed ledger software for asset managers. That supports a blockchain infrastructure example, not a claim that every crypto business suddenly becomes investable. Canadian banks are already exploring Canadian dollar tokenized deposits under existing powers, while distributed ledger businesses still face securities law where it applies.
If an institution breaches either aggregate limit, affected holdings can become temporary investments, generally giving it two years to return to compliance or move the holding into another permitted category. The route is wider, but it isn’t a licence for banks or insurers to own any commercial business they want.
More eligible bank and insurer investors can improve financing choices, distribution and negotiating leverage for an independent fintech. A strategic buyer can get a product in front of customers much faster. It can also end up owning technology several competing institutions rely on. More capital and more competition aren’t automatically the same outcome.
Finance is trying to keep sight of that risk. Certain large acquirers would have to report material supply arrangements between a target and the acquirer’s competitors. Smaller and medium institutions get more revenue headroom and no new reports, because identical limits would leave them with much less room to compete.
A wider buyer pool can help founders raise money, get distribution and negotiate exits. It can also put an important supplier or emerging challenger inside a major incumbent. That’s where the reform shifts from a capital question to a competition question.
The Competition Bureau’s fintech study supported removing unnecessary barriers to entry and collaboration while keeping scrutiny where incumbent relationships could weaken competition. Finance’s new supply reporting reflects the same concern. The useful outcome isn’t simply more acquisitions. It’s more capital reaching strong companies without draining independent competitive pressure from the market.
Finance initially considered common limits, then found that a 10% revenue cap would leave smaller institutions with far less absolute capacity than the largest banks and insurers. Institutions with C$12 billion or less in equity therefore get a 15% revenue allowance, while everyone keeps the 10% regulatory capital limit. The extra room is meant to keep the reform from becoming a tool only the biggest institutions can use.
Small and medium institutions are also exempt from the new transaction and annual reports. That cuts a burden Finance itself concluded would fall harder on them. Whether the design works will show up in what smaller banks, trusts and insurers actually back once the powers are active.
Finance estimates the proposed rules will add C$267,518 in annualized administrative and compliance costs, or about C$1.88 million in present value over 10 years. Those figures cover the new reporting burden. They don’t count the savings from removing some ministerial approvals, and they certainly don’t capture eight years of slower, narrower business choices under the old framework.
The regulations are proposed, not in force. Canada Gazette Part I opened a 30 day consultation on October 17, 2026, with comments due November 16. The government still has to finalize the regulations and use a separate Order in Council to activate the dormant 2018 amendments.
The last round now turns on execution. The 60% definition has to work for current fintech business models, smaller institutions need enough room to compete, and Finance needs visibility into new risks without rebuilding the reporting burden industry spent years pushing back on. Get those choices wrong and the reform can still underdeliver even after eight years.
Canada has already spent eight years designing conditions around powers Parliament approved in 2018. The next step is simpler to describe and harder to deliver. Put the rules into force, give good businesses a workable path to institutional capital, and keep enough independent competition in the market that customers actually benefit.
The 60% definition decides which mixed businesses can qualify. Revenue and capital caps decide how much room an institution has to use the powers. Subsidiary treatment, reporting exemptions and supply relationships will affect how easily deals can be structured and how closely Finance can watch competition risk.
The proposal doesn’t erase the basic policy choice behind Canada’s banking system. Banks and insurers still have to remain primarily financial businesses. What changes is the hard edge around mixed companies. Some commercial activity around finance would no longer automatically push a promising fintech outside the investment route.
Canada’s eight year delay carried a real economic toll. Banks faced approval processes that could take three to four months. Mixed fintechs could lose access to some bank or insurer investors as they expanded. Insurers had less room to sell useful technology outside financial services. Finance now says the old framework can prevent or complicate investment, limit capital and impede productivity. We can’t put a credible dollar figure on every deal, product or expansion that went another way, but the commercial cost isn’t abstract. It lands in who funds a company, what it builds next and how quickly it gets to market.
Canada has good reasons to keep banks and insurers out of unrelated commerce. Those guardrails protect stability and stop financial institutions from controlling too much of the wider economy. But a safeguard carries a cost when rules written for older business models keep constraining newer ones after Parliament has already approved change. The Competition Bureau’s fintech progress review has warned that regulatory barriers can weaken competition too. Capital won’t wait eight years for rulemaking to catch up.
Founders didn’t stop building while Ottawa worked through the rules. Banks and insurers still found ways to invest where the old framework allowed it, as Flinks, WayPay and ClaimSecure show. The 2026 proposal can widen those paths without turning strategic investment into another route to incumbent control. Eight years are gone. The better outcome now is a market where good Canadian fintechs have more ways to finance growth, commercialize useful technology and challenge the status quo.
The National Crowdfunding & Fintech Association (NCFA Canada) is a financial innovation ecosystem that provides education, market intelligence, industry stewardship, networking and funding opportunities and services to thousands of community members and works closely with industry, government, partners and affiliates to create a vibrant and innovative fintech and funding industry in Canada. Decentralized and distributed, NCFA is engaged with global stakeholders and helps incubate projects and investment in fintech, alternative finance, crowdfunding, peer-to-peer finance, payments, digital assets and tokens, artificial intelligence, blockchain, cryptocurrency, regtech, and insurtech sectors. Join Canada's Fintech & Funding Community today FREE! Or become a contributing member and get perks. For more information, please visit: www.ncfacanada.org
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Oct 10, 2026 | Last Updated: Oct 28, 2026 | NCFA Fintech Whisperer | Artificial Intelligence And Data, Capital Markets Infrastructure And Funding, Cross Border Payments And FX, Cybersecurity Fraud And Financial Crime, Digital Assets Blockchain And Tokenization, Digital Banking And BaaS, Payments Infrastructure And Money Movement, Regulation And Policy, Wealthtech Investing And Trading, Risk Compliance And Regtech, Sustainable Finance ESG And Financial Inclusion

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This live weekly NCFA intelligence page tracks financial technology developments that significantly affect how fintechs build, sell, raise capital, and operate under scrutiny. Coverage prioritizes Canada and includes global events that directly influence competitive conditions, market access, and execution realities across fintech sectors. This page will be updated throughout the week with market movers in a live format and then each week we'll close the prior week's contents in prep for the upcoming week, and continue on a rolling basis. (Missed prior week's Fintech Whisperer? (December 6-12, 2025, December 13-19, 2025, January 1-9, 2026, January 10-16, 2026, January 17-23, 2026, January 24-30, 2026, January 31-February 6, 2026, February 7-13, 2026, February 14-20, 2026, February 21-27, 2026, February 28-March 6, 2026, March 7-March 13, 2026, March 14-March 20, 2026, March 21-March 27, 2026, March 28-April 3, 2026, April 4-10, 2026, April 11-17, 2026, April 18-24, 2026, April 25-May 1, 2026, May 2-8, 2026, May 9-15, 2026, May 16-22, 2026, May 23-29, 2026, May 30-June 5, 2026, June 6-12, 2026, June 13-June 19, 2026, June 20-June 26, 2026, June 27-July 3, 2026, July 4-July 10, 2026, July 11-July 17, 2026, July 18-July 24, 2026, July 25-July 31, 2026, August 1-August 7, 2026, August 8-August 14, 2026, August 15-August 21, 2026, August 22-August 28, 2026, August 29-September 4, 2026, September 5-September 11, 2026, September 12-September 18, 2026, September 19-September 25, 2026, September 26-October 2, 2026, October 3-October 9, 2026).
Anthropic's lease gives EverWind a committed customer for its first development phase, strengthening the commercial case for a major Canadian infrastructure investment. But financing AI compute infrastructure depends on more than tenant demand. Power availability, construction costs and grid approvals determine when that demand becomes revenue. For investors, the distinction is between securing a customer today and delivering profitable computing capacity on schedule.
Hong Kong banks now have updated supervisory guidance for deploying AI, while future rules for autonomous agents remain under discussion. Banks investing in these systems need clear ownership of decisions, reliable input data and controls that allow staff to intervene. Canadian financial institutions face many of the same questions as they expand AI into lending, compliance and customer service. The operating advantage will depend on speed and cost savings that hold up under supervisory review.
TD is using AI to clear document checks at more stages of the mortgage process, freeing staff to handle exceptions and borrower decisions. The reported time savings are substantial, but lenders still need to measure end-to-end completion times, error rates and rework. The investment pays off when faster reviews translate into funded mortgages without weaker controls.
The first deadline arrives well before the settlement switch. Brokers, custodians and asset managers now need to reconcile message formats, client instructions and exception handling across counterparties. Canadian firms trading European securities face the same operational handoffs. A short settlement cycle leaves less room to repair missing allocations overnight.
Loan syndication involves years of servicing, amendments and lender coordination after the initial funding. Handling those events on a shared record could reduce duplicate reconciliations and disputes over loan status. The same operating question sits behind shared bank blockchain infrastructure: can participants keep one reliable record without adding new integration costs? Lenders will want evidence of repeat transactions before committing more capital.
Paid investor communities can create recurring revenue for crowdfunding platforms, but the fee can't become a barrier to understanding what investors are buying. Operators need to show enough deal information before collecting membership payments and explain exactly what those fees purchase. The bigger commercial issue is trust. Platforms that sell access before demonstrating investment value risk higher acquisition costs, complaints and regulatory scrutiny. A subscription model can work, but it still has to earn investors' money.
Longer trading hours change the conditions under which orders meet available liquidity. Marketplaces and brokers need controls that work when fewer orders are on the book and prices can travel farther on small trades. The consultation gives Canadian trading firms a chance to address threshold design before extended hours become a larger operational commitment.
BNY has demonstrated that tokenized market infrastructure can support real overnight financing, not just digital settlement. For dealers, the advantage could be faster access to collateral and lower funding friction. The economics depend on custody fees, connections to other counterparties and how often the process can be repeated at scale. One completed repo proves the workflow; regular volume would prove the business case.
The partnership tackles a central obstacle for tokenized funds: reaching investors through regulated broker dealer workflows they already use. Federated Hermes brings investment products; Prometheum would provide custody, clearing and brokerage connections. Managers and intermediaries will judge the offer by distribution costs, settlement performance and investor demand, not the use of tokens alone. The first fund remains planned for 2027.
Origin gives TXSE a publicly traded bank issuer and a practical chance to compete for U.S. listings. But a listing win is only the beginning. Brokers and investors will judge the exchange by trading depth, spreads, execution quality and reliable access to market data. Those measures will determine whether other issuers see a commercial reason to follow.
Evernorth offers stock market investors exposure to a company holding a large XRP treasury without requiring them to buy XRP directly. Its shares may trade at a premium or discount to the underlying assets. Investors should weigh treasury management, operating costs and future capital decisions against the simpler alternative of owning the asset itself.
Institutions can now manage traditional market exposure through a crypto trading venue when stock and futures exchanges are closed. That's a meaningful opening for firms that trade across time zones, but 24 hour access doesn't guarantee deep liquidity or better prices. Prime brokers and market makers will compare margin efficiency, weekend spreads and counterparty risk with established derivatives markets before moving significant volumes.
RPAA registration gives payment providers a defined route to serve Canadian businesses, along with continuing safeguarding and reporting duties. Payoneer can use that standing in discussions with customers and banking partners. For competing providers, the relevant costs extend beyond registration to the controls needed to maintain it.
The restrictions change how banks price rupee hedges and how companies manage currency exposure. Dealers face cash reserve costs and tighter checks on the transactions they can accept. Corporate treasury teams may need to reassess hedging across multiple banks, especially when a cancelled contract can no longer be rebooked. The immediate commercial impact is on liquidity and flexibility, not just compliance paperwork.
Payment infrastructure is now being treated as critical digital infrastructure with direct cyber obligations attached. For operators, this moves resilience from good practice into a formal compliance responsibility. Boards and technology teams need to know which systems are designated, who owns incident decisions and whether reporting can happen fast enough when a critical payment service fails.
Frontier AI is raising the standard of evidence supervisors expect when reviewing financial institutions' cyber resilience. Boards need visibility into where AI changes their threat exposure, which vendors create concentrated dependencies and whether recovery plans still work against faster attacks. The immediate operating priorities are vulnerability management, supplier assurance, incident testing and clear accountability before failures expose gaps.
FIS is taking an AI investigation tool from development into commercial banking operations. The potential savings are substantial because analysts spend considerable time gathering records before judging an alert. But banks still own the compliance decisions. Buyers should examine audit trails, false positives and completed case volumes before relying on projected productivity gains. For Canadian providers, the competitive pressure is on evidence quality and operating cost, not merely the number of alerts an AI system can review.
Fraud intelligence is becoming shared infrastructure rather than a control each institution builds alone. TrustGraph takes a different technical route from Canada's CSAFE fraud exchange, using cryptographic matching instead of pooling customer records. The commercial advantage grows with participation: more institutions create more opportunities to identify repeat attacks before fraud reaches another account.
Fraud often crosses the boundary between a mobile account and a bank account. CSAFE gives participating firms confirmed intelligence from both sides, helping them recognize repeat attacks sooner. The financial value will come from fewer losses and investigations without blocking legitimate customers. That depends on timely, accurate contributions and disciplined privacy controls.
The penalties show how failures in alert handling, correspondent banking controls and sanctions screening can become major financial liabilities. For banking executives, the response requires more than a larger compliance budget: investigations must be timely, findings must reach decision makers and remediation must work across business lines. Investors should track the cost and effectiveness of those repairs.
USDC's designation brings a major stablecoin under closer EU oversight of capital, reserves and redemption. Circle must now manage a split supervisory relationship, while banks and payment providers gain a clearer view of which authority oversees critical financial safeguards. For Canadian stablecoin operators, the decision shows how growing scale can change supervisory obligations even after a token enters the regulated market. Compliance costs and the confidence of institutional counterparties will matter together.
Authorization gives the bank consortium an important legal foundation for issuing a euro stablecoin. It does not yet provide a token that customers can use. Banks, exchanges and payment providers will evaluate redemption certainty, liquidity and integration costs once issuance begins. Broad institutional backing could support distribution, but demand still has to be earned.
Stablecoin operators increasingly need both digital asset and payment permissions when products cross from trading into money movement. Flowdesk can now combine MiCA services with PSD2 payment capabilities inside one European regulatory structure. For firms comparing international models with Canada's stablecoin framework, the operating question is how quickly multiple regulatory permissions can translate into custody, transfers and institutional volume.
Institutional stablecoin use depends on custody, transfer permissions and access to trading venues. Standard Chartered now offers a regulated custody option for RLUSD. Its proposed LMAX integration could let clients use collateral without moving it to an exchange. The commercial benefit will depend on funding efficiency, safeguards and the costs of operating across several counterparties.
A bank issuing digital money needs to know which tokens are still valid before paying holders back. Episode Six puts that check inside the bank's ledger at the point of redemption, where an error could turn into a direct loss. The commercial question is whether this control reduces reconciliation work and fraud without slowing payment flows. Banks still have to prove the reserves exist; software checks aren't a substitute for that obligation.
Buying Saldo could give Payward direct control over more European deposit and lending services instead of relying on bank partners for every product. The agreement is not ownership yet, and regulated banking brings capital and supervision costs. Once the deal closes, investors should watch customer uptake, funding costs and whether the combined businesses improve margins.
IKB would give Crédit Agricole an established German business lending franchise and relationships it would otherwise have to build customer by customer. That creates opportunities to offer existing borrowers more services and fund loans through a larger banking group. Returns will depend on credit quality, customer retention and integration expenses after closing.
Banks need reliable customer records to lend and open accounts across borders, but moving those records creates cost and privacy concerns. This platform lets participating institutions verify information without receiving the underlying files. That could shorten onboarding and credit checks for businesses operating in both markets. The next test is how many banks integrate it, what it costs per verification and whether customers see faster decisions.
Direct payment access could change the economics of launching a fintech in South Africa. Providers would have a route to clearing and settlement without depending on a sponsoring bank for every transaction. That could reduce intermediary costs and give new entrants more control over their services. The commercial opportunity now depends on licensing requirements, connection fees and how quickly the new infrastructure can support real transaction volume.
Stablecoin funding can help payment companies keep less idle cash in multiple accounts while supporting payouts outside traditional banking hours. Visa and Inyo now have a production service, but the financial gain depends on conversion costs, liquidity and the actual timing of settlement. Banks and payment fintechs should compare those economics with their existing prefunding arrangements before assuming round the clock access will improve margins.
Payment fintechs spend time and money negotiating access to the systems that move customer funds. A simpler rulebook could reduce duplicated compliance work and make access terms easier to challenge when incumbents impose costly conditions. But consolidation alone won't guarantee better access. Founders need to examine connection charges, technical requirements and the rights available when an operator refuses entry. Those details will determine whether the reform lowers the cost of competing or mainly reduces paperwork.
Mastercard is turning its BVNK acquisition into a distribution channel for businesses that need to hold, convert and pay in both bank money and stablecoins. A single integration may lower development and reconciliation costs for fintechs. But buyers will still compare pricing, available corridors and responsibility for funds across the service. The competitive question is whether bundled infrastructure delivers better working capital management than separate providers.
Local acceptance capacity gives merchants more than another foreign payment option. It can improve authorization routing and reconciliation where domestic rules differ. Nuvei already connects payment acceptance with enterprise invoice workflows; South African access extends the territory where that infrastructure can be sold. Merchant uptake and transaction performance will decide the return.
Owning licensed payment capacity changes Polygon’s role from infrastructure supplier toward a provider that can connect digital asset transfers to conventional money. It also adds a regulated distribution component to the stablecoin payment infrastructure opportunity. Customers will judge the combined platform by supported payment routes, settlement reliability and total cost, rather than token throughput alone.
Visa has gained a formal route toward operating in China’s domestic card market, but it cannot clear local transactions yet. The next milestones are the remaining approvals and connections with issuing banks, acquirers and merchants. Market share will depend on those relationships and the cost and quality of competing with established networks.
Payment providers could face an independent route for customer complaints, beyond their internal case handling. If adopted, membership would add costs for records, escalation and disputed transactions. Canada’s proposed open banking complaint requirements address related responsibilities for participants, although they are a separate regime. Firms selling payment and stablecoin services across borders need to cost customer redress into their operating model.
Listed companies need decisions about delayed disclosure to withstand scrutiny after information becomes public. The revised grounds offer more clarity, but they do not remove the obligation to assess confidentiality and investor impact in each case. Boards and legal teams should update decision records and approval procedures rather than treating the five additions as blanket exemptions.
Public companies must align earnings presentations, investor materials and financial statement notes before the reporting change. The CSA amendments apply to issuer disclosures, while separate IFRS 18 reporting changes affect federally regulated insurers. Finance teams should reconcile definitions across published measures and underlying accounts before disclosures reach investors.
The consultation puts detailed custody, settlement and capital proposals behind ASIC’s earlier digital asset licensing roadmap. Platform operators can now compare existing controls against draft requirements and price the cost of entering Australia. Firms must distinguish their responsibility for holding customer assets from their role in executing and settling trades.
Regulatory modernization could affect how quickly new financial products reach customers and how much compliance costs smaller entrants. The consultation gives fintechs and industry associations a chance to identify rules that impose costs without improving outcomes. The real test will be whether future supervisory reforms shorten approval timelines, reduce duplication and preserve financial safeguards.
Customer screening is now subject to closer scrutiny over why banks accept or decline legitimate businesses. Institutions need documented distinctions between lawful customer activity, financial crime risk and reputational judgments. For Canadian banks with US operations, policy review and audit evidence are practical priorities. Access decisions that cannot be defended consistently can carry supervisory and commercial costs.
The new safeguards require financial product distributors to prepare for tighter supervision of public sales activity. Firms should update staff training, customer consent records and controls over where representatives approach people. The transition period creates time to make those changes before MAS applies the revised guidelines.
GIFT IFSC is putting a clear accountability line around automated trading. A firm can use more advanced models, but it can't outsource responsibility to the software or its vendor. Brokers, trading firms and technology providers now have a concrete checklist for approval, testing, surveillance and shutdown controls before they scale automated strategies.
ASIC’s loss figures put pressure on brokers that rely on frequent, highly leveraged retail trading. The proposal could affect product terms, customer acquisition and dealing revenue if adopted. Platforms should assess those consequences now, while regulators consider whether the existing protections still address the products offered to retail investors.
European asset managers need to distinguish between holding companies with strong environmental credentials and demonstrating how investor capital contributes to measurable improvements. The supervisory examples also clarify how future transition promises should be explained and monitored. Canada's recent green taxonomy and investor trust debate addresses the complementary question of which activities qualify for sustainable financing in the first place.
The FSB has given financial institutions a common reference for assessing AI controls across business lines and technology providers. Banks and fintechs can compare their existing governance, vendor contracts, model inventories and monitoring against the final practices. The commercial challenge is keeping controls proportionate as AI adoption expands without making every deployment slower or more expensive.
Retail brokers cannot treat surveillance as a technology purchase and assume compliance is handled. Alert thresholds, investigation judgments and management review determine whether suspicious trading is escalated. NCFA’s market abuse risk research also covers more complex automated trading behavior. Brokers need case files and decision trails that stand up to supervisory examination.
This week brought production stablecoin payment services, a live €150 million blockchain loan and new rules for securities settlement and financial disclosures. Canadian firms also gained overseas payment access while domestic regulators advanced trading controls and reporting requirements. For founders, the opportunity lies in replacing costly operational steps with services customers will use repeatedly. Investors should look beyond launches to actual volumes, integration costs and the obligations that follow when a product becomes financial infrastructure.
NCFA offers various curated resources to help founders and investors stay current on developments that impact fintech markets. Get the weekly Whisperer and related market intelligence through NCFA's newsletter, view the latest fintech insights, industry research, or launch into emerging financial innovation opportunities.
The National Crowdfunding & Fintech Association (NCFA Canada) is a financial innovation ecosystem that provides education, market intelligence, industry stewardship, networking and funding opportunities and services to thousands of community members and works closely with industry, government, partners and affiliates to create a vibrant and innovative fintech and funding industry in Canada. Decentralized and distributed, NCFA is engaged with global stakeholders and helps incubate projects and investment in fintech, alternative finance, crowdfunding, peer to peer finance, payments, digital assets and tokens, artificial intelligence, blockchain, cryptocurrency, regtech, and insurtech sectors. Join Canada's Fintech & Funding Community today FREE! Or become a contributing member and get perks. For more information, please visit www.ncfacanada.org
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NCFA Canada
Craig Asano
CEO and Executive Director
casano@ncfacanada.org
ncfacanada.org








