Karsten Wenzlaff, Advisor
August 26th, 2025
Karsten Wenzlaff is a Crowdfunding and Fintech Expert from Germany. He is Secretary-General of Digit[...]
Category Archives: Fintech Opinions
Imminent Litigation Challenges of the Metaverse
Blakes | Karine Russell and Christopher DiMatteo | Nov 23, 2022
Image: Unsplash/Javier Peñas
While a virtual-reality parallel universe is likely several years away, entirely new areas of law have developed to address the online world. Cyberattack or data breach class actions have become common.
- Privacy litigation: If the metaverse develops as anticipated, it will involve the collection of an unprecedented amount of data about users. Platforms could (as they do now) collect data about what users buy in the metaverse, what they look at, and their conversations with other users. However, because a user’s access to the metaverse would be through a headset, much more data could be collected – for example, relating to user movements, physiological responses and perhaps even brainwaves – that will give platforms a deeper understanding of their users’ thought patterns and behaviours.
- Tort of intrusion upon seclusion where a defendant intentionally intrudes into the plaintiff’s private affairs in a manner that would be highly offensive to a reasonable person. In addition to a data breach scenario, it is possible to envision other metaverse cases of intrusion upon seclusion. If it is possible to buy virtual real estate in the metaverse, for example, a defendant could be liable for snooping in a plaintiff’s virtual home.
- Could a metaverse operator be liable for negligently failing to prevent a cyberattack that resulted in the compromise of user data?
- If a metaverse user breaches the privacy of another user, could the platform be liable for failing to prevent the breach?
See: Proof of Humanity: Aftermath Islands Metaverse Launches Blockchain-based Facial Recognition
- Product liability: The metaverse is projected to result in a vast market for virtual and physical products available for purchase and use by customers. Accordingly, developers, manufacturers, licensors, vendors and others in the industry may be at risk of metaverse-related product liability claims brought by metaverse participants and users of these products.
- claims could result from scenarios where individuals sustain personal injuries while immersed in the virtual or augmented reality of the metaverse world
- property damage or economic loss claims could arise where participation in the metaverse or use of related hardware gives rise to an incident that destroys property. Metaverse users may also be sued by other users for their conduct in the metaverse as it relates to another person or avatar.
Continue to the full article --> here
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, 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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Canada’s Open Banking Journey: Interview with Steve Boms, Executive Director Financial Data and Technology Association – North America “FDATA”
NCFA Canada | Mahi Sall | Dec 5, 2022
Thought Leadership Series of Expert interviews and insights related to a made-in-Canada open banking regime
The National Crowdfunding & Fintech Association of Canada (NCFA), true to its mission of providing education, industry stewardship, networking, growth, and funding opportunities for innovative financial technologies and related sectors, is pleased to launch a brand new thought leadership series on Open Banking led by Berlin-based NCFA ambassador and independent expert in Fintech-Bank Partnerships Mahi Sall.
NCFA is proudly contributing this thought leadership series to help shape a system that will bring profound changes in how financial services will be created, distributed, and consumed in Canada over decades to come. Our hope is that Canada’s Open Banking system will improve economic outcomes, improve market efficiencies and competitiveness, and enable consumers to access new and innovative financial services in a way that is secure, efficient, and consumer-centric.
The series is called ‘Canada’s Open Banking Journey’ and aims to aggregate international and domestic perspectives of Open Banking/Finance expert practitioners from around the globe to advance dialogues, key considerations, and explore potential solutions for the development of a made in Canada open banking regime with the following timeline:
- Sep 2018: Canada’s Open Banking journey officially began when the government established a multi-stakeholder Advisory Committee tasked to conduct a review into the merits of Open Banking
- Apr 2021: Advisory committee publishes final recommendations
- Mar 2022: Government appoints Abraham Tachjian – PwC Canada as Canada’s Open Banking lead responsible for convening industry, government and consumers in designing the foundation of the system of Open Banking for a launch in 2023.
- Oct 2023: Phase 1 implementation expected
NCFA Canada's Open Banking Journey Series:
Interview Begins
”As the government advances critically important initiatives to modernize Canada’s financial services market, including open banking and payment modernization, the voices of consumers and small businesses must be at the center of the conversation”.
-- Steve Boms, Executive Director Financial Data and Technology Association - North America “FDATA”
Mahi Sall: Please tell us about yourself and FDATA North America
Steve Boms: Steve Boms, Executive Director FDATA North America, Founder & President of Allon Advocacy LLC.
FDATA North America was founded in early 2018 by several financial firms whose technology-based products and services allow consumers and small and medium enterprises (“SMEs”) to improve their financial wellbeing.
We are a regional chapter of FDATA Global, which was the driving force for Open Banking in the United Kingdom, and which continues to provide technical expertise to policymakers and to regulatory bodies internationally that are contemplating, designing, and implementing open finance frameworks. With chapters in North America, Europe, Australasia, Latin America, and India, FDATA Global has established itself as an expert in the design, implementation, and governance of open finance standards and frameworks globally since its inception in 2013.
We count innovative leaders such as the Alliance for Innovative Regulation, APImetrics, Basis Theory, Betterment, BillGO, Codat, Direct ID, Equitable Bank, Envestnet Yodlee, Experian, Finansytech, Fiserv, Flinks, Hank Payments, Interac, Intuit, Inverite, Kabbage, Mogo, Morningstar, M Science, MX, Petal, Plaid, Questrade, SaltEdge, Trustly, ValidiFi, Vaultree, VoPay, Wealthica, and Xero, among others, as our members.
Mahi Sall: Chief among the factors affecting the take-off of Open Banking is low adoption by consumers. What could Canada do differently than other jurisdictions in order to pre-empt this risk?
Steve Boms: I would respectfully disagree with the premise of this question. Millions of Canadians are already using open finance tools today offered by dozens of FDATA North America member companies. At last count, in excess of five million Canadians were utilizing open finance tools offered by just our members in Canada. Moreover, open finance is not itself the product; it is the rails upon which products and services are offered to consumers. Said another way: Canadians are already benefiting from open finance. The implementation of a formalized open finance regime is a means of providing ubiquitous access to open finance tools regardless of the financial institution with whom one banks.
Mahi Sall: Speak about Open Banking limitations and the most common misconceptions people have about it?
Steve Boms: Open finance’s ability to spur innovation and competition is almost entirely limited by how policymakers design, implement, and ultimately govern their open finance systems. The technological barriers to consumer control of data are minimal and decreasing by the day, particularly as APIs and other modern data communication systems are rolled out across various sectors of the economy. That’s basically why FDATA exists- to be a strong, vigilant advocate for open finance’s potential to the very policymakers who will determine its form and function.
Perhaps the most common misconception of open finance is that it will inherently present a cybersecurity risk to banks and data holders. However, we have stressed since our inception that this risk has so far been entirely speculative, and there are no examples of data breaches in open finance frameworks – formalized or otherwise – due to a third-party data sharing relationship with a fintech. To further address this concern, we have also repeatedly advocated, mostly through comment letters to regulatory agencies, that third party fintech providers should be entirely responsible for all elements of cybersecurity, due diligence, regulatory compliance and consumer protection- and are perfectly capable of doing so. In fact, we are opposed to the idea of banks and data holders retaining responsibility or liability for such damages, since this provides them the pretext to arbitrarily limit data access, and cut it off in some extreme cases. The details of how third party providers must go about ensuring privacy, data, and cybersecurity will be properly developed through an accreditation process. Once such process is devised, any accredited third party financial provider should have continuous access to customer-permissioned data from any and all Canadian banks that participate in the open finance system.
Mahi Sall: In the early days of Open Banking some European banks provided in addition to APIs a Modified Customer Interface (MCI) as alternative means for third party providers (TPPs) to get access to customer data. Would you foresee the need for Canadian banks to deploy fallback options? If so, what could be some of the alternatives?
Steve Boms: Yes. Any realistic view of open finance in Canada must consider the need for fallback options. The vast, overwhelming majority of customer-permissioned financial data sharing in Canada currently occurs via credential-based screen scraping. While all stakeholders in the market would prefer to transition to token-based APIs, it is unrealistic to imagine that 100% of data access will quickly transition to this data access method. Accordingly, fallback options will need to remain.
The harsh reality is that Canada’s financial system is not yet ready to eliminate existing technological methods of accessing customer data without massive detriments to consumer financial health. This is a lesson clearly learned from other, more advanced markets like the United Kingdom, which retain screen scraping as a connectivity method either as a fallback option or for data not available through APIs. In the absence of a fully developed, robust API environment, screen scraping is a necessary tool to enable universal consumer and SME data access.
“ Regulatory certainty and clarity will be key to ensuring that this new open finance marketplace develops to its maximum potential.”
Mahi Sall: What must be thought of and accounted for at this early stage of Open Banking in Canada in order to ensure compatibility and interoperability at regional/international level?
Steve Boms: Regulatory certainty and clarity will be key to ensuring that this new open finance marketplace develops to its maximum potential. We have been working with Canada’s independent banking regulator the Office of the Superintendent of Financial Institutions (OSFI) to ensure that their efforts to modernize third-party risk management do not interfere with open finance development. Since the open finance accreditation standards in Canada will almost certainly include cybersecurity requirements for third-party providers, harmonization of efforts between the Department of Finance’s open finance work and OSFI’s approach to third-party cybersecurity risk will therefore be essential. We’ve also urged OSFI to clearly distinguish between what it considers to be bank third party providers under its supervisory guidelines from what will soon be accredited open finance participants to avoid any confusion.
“Half of Canadians feel stress when interacting with Canada’s financial services sector.”
Mahi Sall: Any final thoughts?
Steve Boms: We recently commissioned a landmark survey of Canadian consumers along with Paytechs of Canada to measure attitudes toward the existing financial services marketplace and open banking. It found that more than half of Canadians feel stress when interacting with Canada’s financial services sector and believe they would benefit from increased competition and transparency in the financial services market. The findings indicate this is especially true among women, young people, and new Canadians. Among the biggest sources of dissatisfaction are high fees and a lack of choice.
As the government advances critically important initiatives to modernize Canada’s financial services market, including open banking and payment modernization, the voices of consumers and small businesses must be at the center of the conversation. These first-of-their-kind surveys clearly demonstrate Canadians’ hunger for a more competitive, transparent, and innovative Canadian financial system.
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Links you may be interested in:
Mahi Sall is an Ambassador of the National Crowdfunding & Fintech Association of Canada “NCFA”, and an Expert on Fintech-Bank Partnerships. He is based in Berlin, Germany.
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, 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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Fintech Leaders Say Regulatory Challenges No. 1 Concern
BankingDive | Gabrielle Saulsbery | Nov 28, 2022
Image source: Gartner, Peer to peer 2022 Fintech survey
Private firms are adopting a more defensive posture, delaying new funding rounds, planning for modest growth and addressing regulatory risks, according to a report.
- Regulatory challenges have doubled in importance to fintech leaders from 2021 to 2022, according to the results of a survey of 100 industry leaders released Monday. Now, nearly half (47%) of respondents dubbed regulatory challenges their No. 1 concern.
See: EY Handbook: Key Priorities for Fintechs to Sustainably Grow from Start-up to Scale-up
- Could see it coming: Survey data was collected Aug. 2 to Oct, 22, after several U.S. senators first put big-bank-owned fintech Zelle under a microscope due to fraud concerns. Shortly before the report came out, the Treasury Department declared a need for more oversight of the fintech sector and bank-fintech partnerships.
- Private fintech companies have been made obvious by double-digit percentage-point workforce layoffs at places like Brex, Chime and Stripe.
- Public fintech companies have seen their share prices cut at the knees — SoFi is down from $15.05 on Jan. 3 to $4.98 as of Nov. 23, and PayPal is down from $194.94 to $80.28 for the same period
- Hiring: Despite the recent layoffs, however, leaders of private fintechs are optimistic about the second half of 2022, with only 3% of companies expecting to reduce headcount. Most (81%) of respondents expect to increase their workforce at least somewhat in the second half of this year.
- H2 plan: Fintech companies instead plan to spend the second half of this year focusing on core priorities such as product development (49%), profitability (35%) and developing partnerships (30%). And they continue to focus on the same markets as last year, with 40% primarily targeting millennials and 37% primarily targeting low-income consumers.
See:
CB Insights Report: The State Of Fintech: Q3 2022
EmFi Fueled by Cloud-based Infrastructure | KPMG Fintech Pulse H1 2022
Alloy General Manager Charley Ma:
Before this year, “regulators were sort of viewed as, they move really slowly, and they’re more interested in regulating large banks and [financial institutions].” Regulators have moved a lot faster this year, for example, with crypto, and anything within crypto will touch fintech. Noting the “spectacular failures in the stablecoin space, like Luna and Terra,” fintech and crypto both have a “big, flashing red light for regulators to look at. It’s clear that private firms in particular have adopted a more defensive posture for the time being — delaying new funding rounds, planning for modest (rather than explosive) growth, and addressing regulatory risks
Continue to the full article --> here
Download the PDF report --> here
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, 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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Newfoundland’s AI Unicorn Helps Predict AIs Near-term Business Opportunity
Image: Pixabay
Five years ago, artificial intelligence (AI) experts would have guessed that the first AI “unicorn” startup (a venture valued at more than $1 billion) in Canada would be from Toronto, Montreal, or Edmonton. But the experts were wrong.
- We thought the first AI unicorn would be where the cutting-edge research took place. Better technology would be all it took. Instead, Canada’s first unicorn AI startup hailed from St John’s, Newfoundland, far from where Canada’s research leaders were developing cutting-edge AI. Verafin gave financial institutions the tools to weed out money laundering and fraud. In 2020, NASDAQ bought it for $2.75 billion (U.S.).
- What did we all get so wrong? We were focused on the location of AI expertise rather than where AI could be most easily implemented.
- AI prediction machine: Verafin was already in the prediction business and already parsed financial transactions to find fraud. When AI’s latest wave of progress arose 10 years ago, Verafin took those inventions and improved its product with AI at the centre. Its banking customers wanted prediction; AI supplied it.
See: Why Artificial Intelligence Will Solve All Our Money Problems
- Chastened by our own predictive failure, we started to look closely at where AI was really being used — not by the tech stars, but by businesses. Only about 11 per cent of businesses use AI somewhere in their operations. But most large businesses had spent meaningful investment dollars attempting to use AI. Why were they coming up short?
- Example: When Air Canada developed an AI system to forecast freight demand and dramatically reduce the likelihood of empty cargo holds, it found that to put it in place, it had to train workers to pack the planes differently. In other words, it couldn’t simply adopt the enhanced prediction capability; it had to adapt the system in which it was embedded.
- Verafin gave us a clue. For them, adopting AI was easy. They were supplying predictions to their customers, who knew what to do with them. But in many other businesses, AI could supply predictions — say, about demand or supply-chain issues — but many businesses were not equipped to use it.
This is par for the course for radical technologies. AI is coming. It will transform many industries. To take the current, modest uptake as a forecast that dramatic disruptive change isn’t coming would be a big mistake.
Continue to the full article --> here
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, 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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Canada’s Open Banking Journey: Interview with Stephane Nouy, Co-Founder Moneythor (HQ: Singapore)
NCFA Canada | Mahi Sall | Nov 28, 2022
Thought Leadership Series of Expert interviews and insights related to a made-in-Canada open banking regime
The National Crowdfunding & Fintech Association of Canada (NCFA), true to its mission of providing education, industry stewardship, networking, growth, and funding opportunities for innovative financial technologies and related sectors, is pleased to launch a brand new thought leadership series on Open Banking led by Berlin-based NCFA ambassador and independent expert in Fintech-Bank Partnerships Mahi Sall.
NCFA is proudly contributing this thought leadership series to help shape a system that will bring profound changes in how financial services will be created, distributed, and consumed in Canada over decades to come. Our hope is that Canada’s Open Banking system will improve economic outcomes, improve market efficiencies and competitiveness, and enable consumers to access new and innovative financial services in a way that is secure, efficient, and consumer-centric.
The series is called ‘Canada’s Open Banking Journey’ and aims to aggregate international and domestic perspectives of Open Banking/Finance expert practitioners from around the globe to advance dialogues, key considerations, and explore potential solutions for the development of a made in Canada open banking regime with the following timeline:
- Sep 2018: Canada’s Open Banking journey officially began when the government established a multi-stakeholder Advisory Committee tasked to conduct a review into the merits of Open Banking
- Apr 2021: Advisory committee publishes final recommendations
- Mar 2022: Government appoints Abraham Tachjian – PwC Canada as Canada’s Open Banking lead responsible for convening industry, government and consumers in designing the foundation of the system of Open Banking for a launch in 2023.
- Oct 2023: Phase 1 implementation expected
NCFA Canada's Open Banking Journey Series:
Interview Begins
“It is important to help banks understand the benefits and use cases that they can build on top of Open Banking.”
-- Stephane Nouy, Co-Founder Moneythor (HQ: Singapore)
Mahi Sall: Please tell us a bit about yourself?
Stephane Nouy: Stephane Nouy, co-founder of Moneythor, Chief Client Delivery Officer and Managing Director Europe.
Moneythor powers Open Banking use cases in several countries and across various regimes such as Europe (PSD2), Australia (CDR) and Singapore (SGFinDex) enabling banks and fintech firms to offer improved functionality and experience to their retail & business customers through their digital banking services.
The Moneythor solution has been deployed globally by large banks such as ANZ, CIMB, DBS and Standard Chartered among others, fintech firms such as Raiz as well as digital banks such as Orange Banque. It supports Open Banking natively.
Powered by real-time data analytics and behavioural science techniques, the prime focus of the Moneythor solution is in the delivery of data-driven personalized, contextual and actionable recommendations, insights and nudges to end-users, preconfigured or uniquely crafted by the financial institutions. Examples of these include money management features, budgets, goals, automated savings alerts, predictive forecasts, financial literacy material, relevant offers and more.
Mahi Sall: Common Rules represent a key component of Open Banking System Design, with the premise that they create a level playing field which eliminates the need for bilateral arrangements between Open Banking participants.
Speak about situations that would call for bilateral arrangements in an open banking environment that thrives on common rules.
Stephane Nouy: More than bilateral arrangements, what we often see is a situation whereby the Open Banking common rules do not cover the full spectrum of banking data (ex: PSD2 not including all types of accounts), forcing aggregators and Open Banking data consumers to continue using scraping techniques. This should encourage the Open Banking regulation to include a broader set of financial data.
Mahi Sall: Another key component of Open Banking System Design is the Accreditation Process. Canada’s Advisory Committee on Open Banking recommended to exempt federally regulated banks from the accreditation process, and similar consideration for provincially regulated financial institutions to be discussed.
What major frustration points relative to the accreditation process can be anticipated and how to address them?
Stephane Nouy: If some banks are exempted from the mandatory opening of their data through standard-based Open Banking APIs, the aggregation process will be tempted to continue relying on scraping techniques.
Compliance with Open Banking is still too often seen by banks as a regulatory effort more than a commercial opportunity, adding to their technical roadmap with no clear return on investment. It is important to help banks understand the benefits and use cases that they can build on top of Open Banking, and thus transform this regulatory requirement into a business opportunity.
Mahi Sall: The third key component of Open Banking System Design are Technical Specifications & Standards with two approaches currently dominating the landscape: single standard approach (e.g. UK, Australia) and multiple standards (e.g. US, EU). Canada’s Advisory Committee left both approaches open for exploration. Can you speak to the advantages and shortcomings of these approaches?
Stephane Nouy: Although the EU allows multiple technical standards, they all comply with the same rules and functional coverage. This doesn’t impact the services built on top of Open Banking, it instead offers more technical flexibility allowing the banks to select and work with their preferred technical partner.
Mahi Sall: What are some of the lessons you’ve learned in terms of Open Banking test designs and implementation.
Stephane Nouy: The experience in the EU clearly shows that the banks were late in complying with the PSD2 Open Banking directive, and that Third Party Providers (TPPs) therefore struggled to perform their tests and roll out their solutions. TPPs also faced multiple bugs and issues when attempting to consume the banks’ APIs, and they suffered from this. They are however instrumental in the success of any Open Banking ecosystem, and their work should be facilitated more than we’ve seen with the PSD2 roll-out in Europe. For instance, building a sandbox with a set of automated tests that the banks should connect to and that would guarantee the correct deployment of their APIs would be an interesting step to minimize the issues encountered by TPPS in their implementations.
Mahi Sall: As in other jurisdictions, financial inclusion is high on Canada’s Open Banking agenda. Please share examples where Open Banking failed to deliver on this metric.
What are some of the key lessons learned that Canada could benefit from?
Stephane Nouy: Financial inclusion has not always been a primary objective of Open Banking, with the initial services developed on top of Open Banking clearly targeting digital savvy and multi-banked consumers. An initial use case of Open Banking has often been around credit assessment and scoring, for example to support the seamless approval of a loan or BNPL proposition, again not particularly focused on financial inclusion, although easier access to credit is a useful feature within this segment too.
You may want to check the “Cresus – BGV (Budget Grande Vitesse)” initiative in France, promoting financial inclusion and financial education. It helps connect banks, identify recurring income and expenses easily, manage budgets, track the available balance and the end of month projection, and calculate the social aids being available.
Mahi Sall: Chief among the factors affecting the take-off of Open Banking is low adoption by consumers. What could Canada do differently than other jurisdictions in order to pre-empt this risk?
Stephane Nouy: Multiple factors can explain the low adoption (non-exhaustive list):
- Banks are usually lobbying for increased security, which can lead to a slower or limited adoption. E.g.: if the user needs to update their credentials or provide their consent too often, she may be tempted to abandon the service.
- Users may be afraid of sharing their credentials with a TPP. More public communication and explanation could be provided by the authorities on the service and the certified participants.
Mahi Sall: Drawing upon your observations, what are some of the quick wins in terms of Open Banking use cases that banks and fintechs should prioritize rolling out?
Stephane Nouy: Digital banks are usually not the primary bank of their clients, this limits the level of services and personalization that they can provide. Through Open Banking, they can access all their customers’ transactions and therefore provide them with insights, recommendations and nudges relevant to them.
Credit scoring (based on Open Banking data analysis) is also one of the top use cases deployed.
Money transfer across banks through Open Banking is also a use case that we see more and more, allowing fintechs to propose advanced solutions without the bottleneck and limitation of a complex fund transfer process through the existing (complex and expensive) payment flows and channels.
Cashback services and/or personalized merchant offers are also another use case developed on top of Open Banking data, offering good incentives for the customers to share their data.
Mahi Sall: What role does talent play in developing a thriving Open Banking system?
Stephane Nouy: Talent is critical to invent and develop the best use cases and boost the Open Banking adoption. We believe that the regulator should provide strong support to the fintech ecosystem (e.g.: strong guidance for the TPP enablement process, so that fintech can stay focused on their specific functional use cases).
Mahi Sall: Speak about Open Banking limitations and the most common misconceptions people have about it?
Stephane Nouy: As mentioned previously, the security restrictions imposed by the banks (eg: changing credentials or providing consent too often) can really kill the fluidity of the use cases invented by TPPs and thus the Open Banking adoption.
Limitations will happen whenever data is missing in the Open Banking specifications (eg: not all accounts, MCC codes for the transactions).
“ It’s undeniable that Open Banking is a game changer in the way financial services are offered to consumers and businesses.”
Mahi Sall: What does Open Banking mean to banks and fintechs, and how does it affect the relationship between the two?
Stephane Nouy: Traditional banks clearly see Open Banking as a threat of being disintermediated, while this is a great opportunity for fintechs. This leads to a conflictual relationship (except when the fintech sells its services to help the bank innovate).
Please note that:
- Digital banks would also see an opportunity in Open Banking.
- Credit scoring (based on Open Banking) use cases is something that traditional banks may find useful for their consumer credit activities.
- We have seen lots of consolidation scenarios, where the banks would invest in the top TPPs.
Mahi Sall: How could banks and TPPs best prepare for Open Banking and extract the most value out of it?
Stephane Nouy: Rather than a defensive attitude, banks should embrace Open Banking, and try to lead the game by providing value-added services to their customer base e.g. personalization based on the 360 degree analysis of the customers’ spendings, etc.
As noted previously, we have seen lots of consolidation scenarios, where the banks would invest in the top TPPs.
Mahi Sall: Given the very tight schedule of Canada’s Open Banking roadmap, where do you think the balance must be struck to meet deadlines without significant trade-offs?
Stephane Nouy: A strong follow-up of the banks’ progress should be performed, the rest of the Open Banking stakeholders (TPPs and fintechs) is indeed dependent on this.
A strong lobbying from the different actors should be anticipated, we recommend carefully listening to TPPs, they are not only instrumental for the Open Banking deployment, but also the experts who will immediately identify the bottlenecks and technical problems.
See: NCFA Open Banking Implementation Risks with Senator Colin Deacon and Mahi Sall
Mahi Sall: In order to ensure compatibility and interoperability at regional/international level, what must be thought of and accounted for at this early stage of Open Banking in Canada?
Stephane Nouy: Interoperability is today only seen in specific zones (eg: EU), and hardly between different Open Banking jurisdictions. Some thoughts:
- Problematic of the schema compatibility : by anticipation Canada should build upon the existing Open Banking deployment and have a compatible schema.
- Data residency: this can be a limitation for international interoperability.
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Links you may be interested in:
Mahi Sall is an Ambassador of the National Crowdfunding & Fintech Association of Canada “NCFA”, and an Expert on Fintech-Bank Partnerships. He is based in Berlin, Germany.
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, 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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Canada’s Open Banking Journey: Interview with Brenton Charnley, CEO and Founder of Open Finance Advisors, Australia (Ex-TrueLayer ANZ CEO)
NCFA Canada | Mahi Sall | Nov 23, 2022
Thought Leadership Series of Expert interviews and insights related to a made-in-Canada open banking regime
The National Crowdfunding & Fintech Association of Canada (NCFA), true to its mission of providing education, industry stewardship, networking, growth, and funding opportunities for innovative financial technologies and related sectors, is pleased to launch a brand new thought leadership series on Open Banking led by Berlin-based NCFA ambassador and independent expert in Fintech-Bank Partnerships Mahi Sall.
NCFA is proudly contributing this thought leadership series to help shape a system that will bring profound changes in how financial services will be created, distributed, and consumed in Canada over decades to come. Our hope is that Canada’s Open Banking system will improve economic outcomes, improve market efficiencies and competitiveness, and enable consumers to access new and innovative financial services in a way that is secure, efficient, and consumer-centric.
The series is called ‘Canada’s Open Banking Journey’ and aims to aggregate international and domestic perspectives of Open Banking/Finance expert practitioners from around the globe to advance dialogues, key considerations, and explore potential solutions for the development of a made in Canada open banking regime with the following timeline:
- Sep 2018: Canada’s Open Banking journey officially began when the government established a multi-stakeholder Advisory Committee tasked to conduct a review into the merits of Open Banking
- Apr 2021: Advisory committee publishes final recommendations
- Mar 2022: Government appoints Abraham Tachjian – PwC Canada as Canada’s Open Banking lead responsible for convening industry, government and consumers in designing the foundation of the system of Open Banking for a launch in 2023.
- Oct 2023: Phase 1 implementation expected
NCFA Canada's Open Banking Journey Series:
Interview Begins
To make Open Banking successful it must be done through mandated regulation first for innovation to happen.
-- Brenton Charnley, CEO and Founder of Open Finance Advisors, Australia (Ex-TrueLayer ANZ CEO)
Mahi Sall: Please tell us a bit about yourself.
Brenton Charnley: Brenton Charnley is the CEO and Founder of Open Finance Advisors, an Australian based consultancy specialising in the Consumer Data Right, Open finance and Open banking in Australia. Brenton is also the Founder of Open Finance ANZ the leading community of innovators furthering open finance in Australia and ex-CEO of TrueLayer ANZ.
Mahi Sall: The premise behind common rules is that they create a level playing field which eliminates the need for bilateral arrangements between Open Banking participants. On the other hand, bilateral arrangements are said to be a catalyst for more innovation.
What are your thoughts in terms of striking the balance between fostering innovation and creating a level playing field in financial services through Open Banking?
Brenton Charnley: Having experience working on both sides of the ‘innovation fence’ that is inside a large regulated financial services organization and on the outside working for innovators in fintech and insurtechs, I have lived and breathed the opportunities on both sides. The reality is, if you already have a large core (and regulated) business, you and your shareholders will do what they can to protect it. I therefore believe to make Open Banking successful it must be done through mandated regulation first for innovation to happen. For if nothing needs to change, then why change? We have seen this play out first hand in Australia with the Consumer Data Right. Even with mandated regulations, it has taken over 4 years to get to a stage of ‘good’ coverage of regulated data access. Compare this to New Zealand which has bi-lateral agreements, and sadly there isn’t enough coverage to justify it as a success just yet.
Mahi Sall: Canada’s Advisory Committee on Open Banking recommended to exempt federally regulated banks from the accreditation process, and similar consideration for provincially regulated financial institutions to be discussed, while all third-party providers (TPPs) will be subject to accreditation.
What major frustration points relative to an Open Banking Accreditation Process can be anticipated and how to address them?
Brenton Charnley: The fundamental challenge that Australia has experienced with the Consumer Data Right is the balance required between regulated data access and the need for information security to protect the consumers data and the privacy laws which define who can access and what can be done with the data. The data is ultimately leaving a highly regulated and secure environment and therefore it should go to a comparatively secure environment, correct? Well it really isn’t that simple. To hold early adopters and innovators to the same or similar technology and information security standards as highly profitable, large and regulated banks creates unnecessary barriers to entry for market participants.
In addition to these challenges, the access models under the Consumer Data Right were not fit for purpose at launch and needed to be amended to extend for different use cases and participants. This has caused a lot of complexity and a “wait and see” approach over the last two years meaning that participation has been low.
To address these challenges, I’d recommend learning from the experiences of both the PSD2 environment and CDR. Then, look to identify simple use cases and accreditation pathways to get started with regulated data sharing. Further, it is necessary to divorce the Privacy Standards from the Open Banking Standards to ensure that the regulations, and therefore accreditation, is not overly restrictive. In addition, having a principles based approach would help get moving instead of having an overly prescriptive compliance framework.
Mahi Sall: Two approaches to technical specification development currently dominate the open banking landscape: single standard approach (e.g. UK, Australia) and multiple standards (e.g. US, EU). Canada’s Advisory Committee left both approaches open for exploration given a lack of consensus by stakeholders.
Speak to the advantages and shortcomings of the approach you are most familiar with.
Brenton Charnley: Having experience only with the Consumer Data Right I can only advocate for a single standard approach. That being said, in our experience even with a single standard adherence to those standards varied greatly. Therefore, I would recommend against multiple standards.
Mahi Sall: Low adoption by customers is often cited as a key limiting factor to the take-off of Open Banking.
What could Canada do differently than other jurisdictions in order to pre-empt this risk?
Brenton Charnley: This is correct. From Australia’s experience two years in, we have seen limited consumer adoption. I’d recommend accelerating the participation of intermediaries and early adopters to get use cases into market. It should not be left to the banks to add ancillary data sharing services to their existing products. The UK had a successful innovation competition to help incentivise participation, this could also be done.
I’d also recommend absolute transparency on the consumer participation numbers (e.g. number of completed consents). As an industry the north star metrics must be the number of consumers using it, else it can’t be seen as a success.
Mahi Sall: Drawing upon observations in your and other jurisdictions, what are some of the quick wins in terms of Open Banking use cases that banks and fintechs in Canada should prioritize rolling out?
Brenton Charnley: The top three would be personal finance management, account verification especially for payments and loan applications.
Mahi Sall: What role does talent play in developing a thriving Open Banking system?
Brenton Charnley: Open banking will thrive on an already working fintech, payments and financial services community. If the talent is strong here, then you should see innovators in these sectors look to adopt open banking as ancillary innovation.
No one says I want to “do open banking”, they just want it to be easier.
Mahi Sall: Speak about Open Banking limitations and the most common misconceptions people have about it?
Brenton Charnley: I used to laugh about this and the typical “bbq chat” where people ask what you do. Having to explain what open banking and APIs are, often resulted in some blank faces. But the reality is, consumers don’t care as open banking is not the “job to be done”. The job to be done is make consumer experiences easier and embedding open data in those experiences to make it seamless. No one says I want to “do open banking” they just want it to be easier.
Mahi Sall: What does Open Banking mean to banks and fintechs, and how does it affect the relationship between the two?
Brenton Charnley: There is clearly a tension between the two. However, there is a clear interdependency here. Fintechs can’t facilitate access to open banking without compliance from the banks to the data regulations.
Mahi Sall: How could banks and TPPs best prepare for Open Banking and extract the most value out of it?
Brenton Charnley: To get the most value out of open banking both parties need to identify consumer use cases that deliver better experiences. Therefore I’d recommend both to undertake use case discovery and identify the pain points their customers have and where open data can best relieve those pain points.
Mahi Sall: Given the very tight schedule of Canada’s Open Banking roadmap, where do you think the balance must be struck to meet deadlines without significant trade-offs?
Brenton Charnley: Learning from Australia the trade-offs need to be starting small on the use cases, broader access to enable participation and to deal with non-compliance on a case by case basis over time.
See: So what is financial exclusion in the era of Open Finance?
Mahi Sall: In order to ensure compatibility and interoperability at regional/international level, what must be thought of and accounted for at this early stage of Open Banking in Canada?
Brenton Charnley: Having worked across both PSD2 and the CDR interoperability was not possible. Open banking needs to be successful at home first so I’d recommend starting there.
Mahi Sall: Banks deploy significant upfront investments in order to become Open Banking ready/compliant, which begs the question of return on investment (ROI).
What is your experience in terms of how banks have been reconciling the need for a substantial, fast return on that investment vs providing affordable, secure and innovative solutions to consumers & SMEs?
Brenton Charnley: As mentioned earlier, banks have been regulated in Australia to share data and therefore I suspect it wasn’t an ROI decision, but that of compliance. That being said, given the investment made, banks should be turning their eye to how to turn this into value. We haven’t seen a large number of banks do this just yet however.
Mahi Sall: Fraud is a major concern in financial services. Does Open Banking bring new types of financial and non-financial risk?
Brenton Charnley: I don’t think so. Continuing with the existing non-regulated data sharing models is of higher risk.
Mahi Sall: Taking a long-term view on Open Banking Governance, what are some of the key lessons learned in Australia and abroad that you’d recommend Canada to consider?
Brenton Charnley: Think I have covered a lot of these above!
Interview: Senator Colin Deacon on Open Finance in Canada: Governance
Mahi Sall: Any final thoughts?
Brenton Charnley: Please check out the last TrueLayer report on Australia and what needs to be done to improve. This is a good insight on what Canada can learn from, including ensuring there is an implementation entity!
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Links you may be interested in:
Mahi Sall is an Ambassador of the National Crowdfunding & Fintech Association of Canada “NCFA”, and an Expert on Fintech-Bank Partnerships. He is based in Berlin, Germany.
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, 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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Will Global Regulation See Bitcoin Surge in 2023?
November 21, 2022
Regarding the price of Bitcoin and most cryptocurrencies in general, 2022 has been a rough year, especially compared to the phenomenal price performances of 2020 and 2021. Naturally, millions of people are keen to see what 2024 will bring, especially for BTC.
Among various market experts' crypto circles, there is increasing talk of a Bitcoin price surge coming. Its foundations are predicted to come from a rather unlikely source, increased global regulations.
Previously, increasing government regulation spelt bad news for cryptocurrency. But now, it could have the complete opposite effect. As cryptocurrency regulation grows worldwide, many expect that new governmental frameworks could play a huge role in increasing the credibility of Bitcoin and other cryptos and dramatically increase their value.
Out of all cryptocurrencies, Bitcoin is the one almost everyone has their eye firmly on. The first cryptocurrency in the world, it has a staggering market cap of $390 billion, is worth more than triple that of Ethereum and trumps every altcoin out there. Naturally, it is often the most recognisable name and the go-to choice for crypto newcomers.
But 2022 has not been kind to Bitcoin. Between 2020 and 2021, the price surged from $5,000 per coin to more than $60,000. Making many people richer than they ever could have imagined practically overnight.
But this year, In the wake of the pandemic, war in Europe, and increased global volatility, the price has fallen dramatically, losing over 70% of its value and thus characterising the volatility of crypto.
Of course, the precarious state of the world has also seen some of the most stable blue-chip stocks plummet too. But unlike these, BTC doesn’t have the same level of credibility amongst the mainstream investment audience. But 2023 could see a dramatic change in this area.
To be accepted by a mainstream investment audience, it’s widely said that there are six main expectations that cryptocurrencies need to meet:
- Durable ✔️
- Portable ✔️
- Divisible ✔️
- Fungible ✔️
- Scarce ✔️
- Widely accepted as a form of payment ❌
When it comes to Bitcoin, the original cryptocurrency largely ticks the boxes on the initial five necessities. However, its stumbling block is becoming a globally accepted form of payment.
However, 2023 could see that box finally ticked.
Almost every form of investment, be it fiat currency, properties, commodities, etc., is regulated in some form. Bitcoin has largely avoided it so far, but this may end soon. But fear not; this may not be a bad thing at all.
In fact, it could be the final push needed for Bitcoin to finally achieve widespread use and adoption.
A change that will likely make its price surge higher than ever before. Now, let’s look at some of the most promising regulations in the crypto pipeline from global governments from the UK to Saudi Arabia and what it means for Bitcoin and crypto as a whole!
Bitcoin Regulations In The United Kingdom
From one of the shortest reigns of any prime minister to the loss of value in the Great British Pound, the political scene in the United Kingdom has been a rollercoaster in recent months and not a very fun one.
Britain’s latest prime minister, Rishi Sunak, is a former banker from Goldman Sachs. So if there’s one thing he knows well, it’s economics. Due to various political scandals and mishaps, public opinion is divided over Sunak’s ability to lead the country.
However, when it comes to crypto in the UK, things are looking bright. Rishi Sunak has revealed his ambitious aims for post-Brexit Britain to become a hub of crypto-related business similar to that of the Baltic states.
So much so that a recent UK government voted to add digital cryptocurrencies to the scope of activities to be regulated via the newly proposed Financial Services and Markets Bill.
In an additional boost for crypto, the Financial Conduct Authority has recently updated its advice and advises that crypto should be limited to 10% of a diversified portfolio. Previously, they advised avoiding it altogether due to its volatility.
Where Should You Invest In Bitcoin In 2023?
Naturally, reading this article and realising the promising future that lies ahead for the likes of Bitcoin and other cryptocurrencies, you’re no doubt wondering how to invest in Bitcoin for the future. Well, as we come to the end of this article, allow us to share some advice with you.
Worldwide, there are several ways to invest in cryptocurrency, but not all of them are equal. Surrounding an elite group of exchanges and trading platforms is a minefield of scam platforms and illicit exchanges, which you should avoid at all costs.
Instead, opt for a popular and varied platform that is well-suited to beginners, such as eToro, Kraken, or Bitcoin Loophole. These platforms also come with a range of useful trading tools that you can use to streamline your crypto portfolio and build an investment for the future.
The Securities or Equities Question in The United States
The United States is home to a huge community of cryptocurrency investors. Around 22% of the US adult population (46 million people) own some Bitcoin. In fact, recent statistics have shown that most millennials surveyed believed that Bitcoin is superior to gold as a safe-haven asset.
Naturally, crypto regulation is becoming an increasing topic of discussion in the US Senate. Gary Gensler, the Chair of the Securities and Exchange Commission, has said that those who invest in cryptocurrencies should be granted the same protections as those who invest in mainstream equity.
Gensler has also made his opinion clear regarding a crypto market that offers protection to those who invest in it. By doing so, the market will produce more confidence, draw more investors, and become stronger overall.
The US Government is currently debating how to classify Bitcoin and other crypto assets. The question is whether they should be treated as equity-like securities or gold-like commodities akin to gold.
It’s a difficult question indeed, as various cryptocurrencies share the characteristics of both investment forms. Many have argued that the classification should determine whether a particular crypto asset uses a proof-of-work or proof-of-stake protocol.
Once this question is answered and the issue is settled, retail investors will undoubtedly feel much safer and more confident about investing in crypto. In turn, we could see a huge wave of investment towards Bitcoin and other crypto assets that will undoubtedly skyrocket.
The European Union’s New Licencing Regime
Another major player in the future of Bitcoin and the wider world of crypto is the European Union. A vast collection of 27 countries, whatever decisions toward crypto regulation made at the top of the EU have a huge effect on the wider world of cryptocurrency.
Recently, the EU agreed to establish a cooperative licensing authority regulating various cryptocurrency exchanges such as Binance, Kraken and Coinbase.
The general plan is for all cryptocurrency exchanges to have the ability to seamlessly operate across the borders of countries that make up the EU within an agreed Crypto Regulation Framework.
Anti-Crypto Asia Is Changing Its Mind
From China to India, quite a few governments in countries across Asia have demonstrated an inherently anti-crypto stance. However, the progress of technology and widespread adoption is hard to fight, and many countries are beginning to change their minds.
Take India, for example. In recent years, the Central Bank of India has blatantly branded cryptocurrency as nothing more than a Ponzi Scheme. More recently, the Indian Directorate of Enforcement decided to freeze both WRX and Tether underneath India’s Prevention of Money Laundering Act. Despite this, it’s believed that more than 7% of the enormous Indian population of 1.4 billion own some form of crypto. That’s almost 10 million people!
And then there’s China. When one of the biggest countries on earth imposed a full-on crypto ban, it sent shockwaves across the cryptocurrency industry. But in the iconic investment hub of Hong Kong, things are looking promising.
Elizabeth Wong is the chief of fintech at the Securities and Futures Commission and recently informed investors that the government is contemplating authorising people to invest directly in digital assets.
It’s believed that this is some form of reconciliation that is aimed at attracting fintech investors back to Hong Kong in the wake of mainland China’s violent crackdown on Hong Kong protestors.
Saudi Arabia is Bringing Change to Crypto Investing in The Middle East
Across the predominantly Islamic countries of the Middle East, religion often plays a significant role in the governance of money and finance. To stay in line with Islamic law, many countries across the Middle East have been naturally cautious about cryptocurrencies due to the question of whether they’re Halal or not.
However, one country, in particular, is at the forefront of changing this. Interestingly, it’s one of the most surprising countries one could think of due to its notoriously hardline religious society: Saudi Arabia.
Officially, the government in Saudi Arabia banned the country's bank from processing any form of crypto transactions. But, as with anything, there are numerous ways to get around it, and many Saudis take full advantage of them. By the Spring of 2022, surveys showed that 14 per cent of the adult Saudi population (3 million people) either currently owned crypto or had at least actively traded in the last six months.
There’s increasing talk of the neighbouring United Arab Emirates making steps to become the main hub of cryptocurrency in the Middle East. Not wanting to be outdone by their neighbour, many believe that regulations will be loosened in Saudi to allow cryptocurrency activity to flourish. Binance has already got its foot in the door in anticipation of this news and has increased its number of Saudi-based staff.
Even more promising for the region is an increasing number of religious leaders declaring that cryptocurrency is permitted under Islamic law. Plus, the Kingdom of Saudi Arabia is also making plans to form a multi-regional CBDC under the name ABR.
International Monetary Fund (IMF)
And last but by no means least is another financial powerhouse that is predicted to play a huge role in the global acceptance of Bitcoin and other crypto assets: The International Monetary Fund (IMF).
Recently, the IMF released their World Economic Outlook Update Report that was largely encouraging to the crypto sector and stated that, despite the enormous sell-off across the cryptocurrency market in the wake of price dips, there had been limited fallout on the wider financial system overall.
In contrast, there was more negative attention directed towards stablecoins. Tobias Adrian, IMF director of monetary and capital markets, stated that stablecoins like USDT threaten investors due to their characteristic nature of not being backed one to one.
Overall, rather than focusing on cryptocurrencies like Bitcoin to further regulate them, Adrian predicted that regulators will place their focus on crypto exchanges and those who provide digital wallets.
In Conclusion, Regulation Could Mean a Bright Future For Bitcoin!
Previously, the lack of government regulation was a huge selling point for BTC and was a huge help to draw more investors to the asset and increase its value. Now, it’s widely accepted that Bitcoin needs to advance into the future and become a globally accepted form of currency.
But to achieve this, governmental regulations are inevitable, and it’s happening as we speak. Some may say it’s a bad thing that goes against the very principles of cryptocurrency. But, overall, crypto needs to advance.
Plus, as the range of crypto regulation advances worldwide and the use cases, credibility and acceptability of the likes of Bitcoin grow in sync, we could naturally see its price surge in 2023 and beyond.
See: MiCAR: EU Crypto Regulation in the Making
But of course, only time will tell, and nobody can truly tell what the future has in store for Bitcoin and other cryptocurrencies. This means that you shouldn’t take this article as a form of financial advice.
If investing in cryptocurrency for the first time, always conduct deep research into the market, consult with a financial expert and never, I repeat never, invest more than you can afford to lose.
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, 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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