Karsten Wenzlaff, Advisor
August 26th, 2025
Aug 13, 2026

Artificial intelligence (AI) is rapidly becoming part of the day-to-day operations of Canadian financial advice firms. From automating administrative tasks and analyzing client portfolios to supporting investment research and improving client communications, AI has the potential to make advisors more efficient and help firms deliver a better client experience.
But as adoption accelerates, governance isn't always keeping pace.
Many firms are experimenting with AI tools before establishing clear policies around how those tools should be used, monitored, and supervised. That creates significant risk in an industry where investment advice is built on trust, accountability, and regulatory compliance.
Using AI without proper governance is a bit like prescribing medication without understanding the side effects or drug interactions. The technology may offer benefits, but without safeguards, oversight, and a clear understanding of the risks, unintended consequences can quickly outweigh the advantages.
For Canadian financial advisors, governance shouldn't be viewed as unnecessary bureaucracy. It's an essential part of responsible innovation.
Canada's financial regulatory environment already places significant responsibilities on advisors, and those obligations don't disappear simply because AI enters the picture. The Canadian Investment Regulatory Organization (CIRO), together with provincial securities regulators such as the Ontario Securities Commission (OSC) and the Canadian Securities Administrators (CSA), have made it clear that existing regulatory obligations continue to apply whenever technology influences regulated activities. Firms remain responsible for ensuring investor protection, fair dealing, appropriate supervision, cybersecurity, privacy, and sound governance, regardless of whether decisions are supported by artificial intelligence.
AI governance is no longer simply a future consideration. CIRO's 2026 Compliance Report identifies artificial intelligence and emerging technologies as areas of supervisory focus, signalling that firms should expect regulators to examine how AI systems are being used, what controls are in place, and whether appropriate oversight exists. The message is clear: firms remain accountable for the outcomes produced by the technology they choose to implement.
At its core, Canadian financial advisors continue to operate under well-established regulatory obligations. For most registered firms, this includes complying with Know Your Client (KYC), Know Your Product (KYP), and suitability requirements under the Client Focused Reforms. In certain advisory relationships, such as discretionary portfolio management, a fiduciary duty may also apply. Regardless of the business model, advisors are expected to understand the rationale behind every recommendation they provide and be able to explain why it is appropriate for each client. That expectation becomes much more challenging if an AI system produces recommendations that advisors cannot clearly explain, let alone defend or stress test.
Explainability is only one piece of the governance puzzle. Firms must also consider data privacy, cybersecurity, recordkeeping, model bias, third-party vendor oversight, and ongoing monitoring of AI systems. Regulators expect firms to demonstrate not only that technology delivers operational benefits, but also that associated risks are identified, documented, and actively managed.
History provides plenty of reasons for this scrutiny. AI systems used in other industries, such as HR, have produced biased hiring decisions, inaccurate healthcare recommendations, and flawed credit assessments due to inadequate oversight or unintended algorithmic behaviour. Financial advice firms cannot assume similar issues won't emerge within investment or wealth management applications.
Another emerging consideration is AI-generated investment commentary. Recent guidance from the CSA and CIRO reinforces that securities laws apply regardless of how investment recommendations are delivered. Whether commentary comes from a financial advisor, an online platform, or an AI-powered tool, firms remain responsible for ensuring communications comply with applicable registration, disclosure, and investor protection requirements. AI cannot be used to distance a firm from its regulatory responsibilities; introducing it does not reduce those responsibilities. If anything, it increases the need for governance.
Strong AI governance starts long before a new tool is deployed. Rather than allowing employees to independently adopt AI solutions across different departments, firms should first define exactly where AI will be used and where human expertise must remain central to the decision-making process. Administrative automation, document summarization, workflow management, and research support may represent lower-risk applications than suitability assessments, portfolio recommendations, or investment decisions that directly affect clients. Establishing clear use cases helps prevent AI from gradually expanding into areas where the risks may outweigh the benefits.
Governance also requires clear accountability. Every AI-enabled process should have an identified owner who is responsible for monitoring performance, addressing concerns, and escalating issues when necessary. Responsibility cannot rest with the software itself. Human accountability remains essential.
Transparency should be another guiding principle. Clients deserve to understand when AI contributes to services they receive, particularly if it influences recommendations, communications, or financial planning outputs. Transparency builds trust while helping clients better understand how technology supports, rather than replaces, professional judgment.
Bias testing is equally important because AI models learn from historical data, which can contain unintended biases. If left unchecked, algorithms may produce outcomes that disadvantage certain investor groups or reinforce patterns that conflict with principles of fairness and equal access. Regular testing allows firms to identify and correct these issues before they affect clients. The objective isn't simply to deploy AI; it's to deploy AI responsibly.
Creating governance policies is only the first step. Maintaining them requires ongoing operational discipline. There are some daily practices that could help firms in this aspect:
Proper documentation: Every meaningful AI-assisted recommendation or decision should be properly documented. Firms should be able to demonstrate how information was generated, how it was reviewed, and how the final recommendation was reached. Comprehensive documentation not only supports internal quality control but also prepares firms for future regulatory reviews.
Continuous monitoring: AI systems are not static. Performance can change over time as market conditions evolve, new data becomes available, or models begin exhibiting algorithmic drift. Regular reviews help ensure systems continue operating as intended while identifying unexpected behaviours before they become larger problems. Many firms may benefit from conducting quarterly governance reviews that assess model performance, review exceptions, evaluate client outcomes, and confirm compliance with internal policies.
Employee education: This should also remain a priority. Advisors need to understand both the strengths and limitations of AI. Training should focus not only on how to use new tools but also on recognizing situations where human judgment should override automated recommendations.
AI should not be treated as a set-and-go replacement for professional expertise. It should be used responsibly as a tool that enhances decision-making and quality investment advice while preserving the experience, judgment, and accountability that clients expect from trusted financial advisors.
AI will undoubtedly reshape financial advice in Canada, but technology alone won't determine which firms succeed. Governance will. Organizations should establish clear policies, maintain transparency, monitor performance, and preserve meaningful human oversight while using AI. Without adequate governance, firms may expose themselves to compliance failures, reputational damage, and increased regulatory scrutiny.
As AI capabilities continue to expand, firms should regularly ask themselves one important question: Could we clearly explain every AI-assisted recommendation to a client and, if necessary, to a regulator? If the answer is yes, governance is likely supporting innovation. If the answer is no, governance deserves attention before AI adoption moves any further.
Ultimately, responsible AI is not a roadblock to the adoption of innovation. It's about ensuring innovation strengthens the quality, integrity, and trust that define professional financial advice.
— — —

Nadeem Kassam, Marnoa Private Wealth Counsel
Nadeem Kassam, CFA®, MBA
Chief Investment Strategist, Chief Operating Officer & Portfolio Manager at Marnoa Private Wealth Counsel
Nadeem is a Chief Investment Strategist and Portfolio Manager with 20+ years' experience across major global banks, including senior-level roles at RBC, Raymond James, CIBC, Deutsche Bank, and Citigroup. At Marnoa, he leads investment strategy and portfolio management with a focus on North American equities and is a frequent commentator in the media, including regular appearances on BNN Bloomberg.
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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August 13, 2026 | NCFA Insight | Artificial Intelligence And Data, Competition And Market Structure, Public Sector Policy And Industrial Strategy

On August 10, 2026, Meta published The Future Is For Everyone, Mark Zuckerberg's wide sweeping proposal for how superintelligence should fit into society.
The central idea is personal empowerment. Zuckerberg argues that advanced AI should give individuals more ability to create, learn, build businesses, improve their health and pursue their own goals rather than placing most of that intelligence under the control of governments, large institutions or a handful of AI companies.
Meta's vision imagines personal agents working continuously on a user's behalf, small teams building companies that once required much larger organizations, personalized tutors, faster scientific discovery and powerful creative tools available to billions of people.
Meta wants AI capability spread widely, while the compute, models, release decisions and government relationships needed to provide it remain concentrated among a handful of organizations.
Mark Zuckerberg, Founder and CEO, Meta:
“The defining questions of our age are who will have access to superintelligence and what will we direct it towards.”
One of Zuckerberg's strongest economic arguments is that AI's biggest contribution could come from helping people invent things rather than simply automating today's jobs.
Meta expects individuals to become capable of doing work that currently requires larger teams, more capital or specialized expertise. Zuckerberg predicts more small businesses, more experimentation and potentially more employment as people use AI to create products, services and jobs that don't exist today.
That is a different vision from a future where AI mainly replaces knowledge work. Meta argues that if personal agents increase people's capabilities quickly enough, workers can adapt and new demand can grow alongside automation.
For founders, that could change the economics of starting a company. Product development, research, design, marketing and operations could require fewer people and less initial capital. Small firms could reach meaningful scale much earlier.
Financial services will feel the same pressure. Meta already has AI that can plan work, connect with email and calendars and continue tasks after the user leaves. As agents gain access to financial information and connected services, permissions and accountability become part of the operating model, especially when an agent can act rather than simply advise.
The more unusual part of Zuckerberg's argument is about safety.
He rejects the idea that one centrally controlled superintelligence can be aligned to a single set of values that works for everyone. People disagree about politics, economics, culture and what makes a good life.
Meta's answer is to distribute powerful AI widely enough that people, businesses, governments and competing AI systems check one another.
It is essentially a balance of power argument. One person with vastly better legal, financial or cybersecurity intelligence could gain an enormous advantage. If many people have access to comparable capabilities, Meta argues that power becomes harder to monopolize. (There’s some irony here. Zuckerberg built his fortune by controlling access to data, distribution and network effects that others couldn’t easily replicate.)
That philosophy also influences Meta's approach to alignment. Personal agents should primarily help users pursue their own goals within legal and safety boundaries rather than enforce one company's view of what those goals should be.
Meta says it plans to build a private mode where even Meta can't access a user's information, and it intends to resume releasing some open models. It is also giving its independent board authority to approve safety criteria for model releases rather than leaving those decisions entirely with Zuckerberg or management.
Meta's existing algorithmic products are already under legal scrutiny, including a federal trial involving 29 U.S. states over alleged harm to children. Meta denies the allegations. A company asking people to trust far more capable personal agents will have to show that user empowerment, privacy and safety work in practice. Algorithmic accountability is already moving into the courts as AI and automated systems take on a larger role in people's lives.
Zuckerberg's decentralization argument has limits.
He wants individuals to have broad access to powerful AI, but he also argues that the United States and its allies should retain leadership in advanced models, silicon and infrastructure. Meta supports continued restrictions on exports of leading chips to geopolitical rivals and wants U.S. policy to make it easier to build data centres and energy capacity.
He also proposes closer cooperation between frontier AI labs and government. Rather than waiting until an advanced model is finished, Meta wants labs to share intermediate model checkpoints and technical staff so governments can identify cybersecurity and other security risks earlier.
The result still leaves considerable power with governments, frontier labs and the companies that control advanced compute. Individuals would gain far more capability. Governments would receive earlier access for security purposes. Independent boards would get more authority over release standards. Frontier labs would still control development of the most capable models.
Meta's vision is therefore decentralized at the user level while retaining substantial institutional coordination at the frontier.
Meta expects capital spending of US$130 billion to US$145 billion in 2026 and spent US$31.08 billion in the second quarter alone. It is investing in models, data centres, energy, networking, its own chips and outside accelerators while trying to deliver AI across products already used by billions of people.
If personal superintelligence is going to be free or affordable at global scale, someone still has to pay for the compute..
Meta wants superintelligence broadly distributed, but scarce compute still has to be allocated. Its answer is a dynamic auction for additional capacity, which means the vision of AI for everyone could still produce tiers of access based partly on what users can afford. (conflict?)
The business model hasn't been proven. Meta's second quarter free cash flow fell to US$784 million as infrastructure spending accelerated, even while its core advertising business remained highly profitable.
Meta is making these commitments under real pressure. Its infrastructure spending has climbed rapidly, the company is still building the compute capacity and custom chips needed to compete at the frontier, and its existing platforms face growing legal scrutiny.
The scale of the investment also reinforces a central tension in Zuckerberg's vision. Meta wants personal AI to give individuals more power, but only a small number of companies can currently finance the systems needed to provide it.
Meta's vision has clear upside for Canada.
Canadian entrepreneurs, researchers and smaller businesses could gain access to capabilities they would never be able to finance themselves. If AI lowers the cost of creating companies, learning new skills and developing new products, a smaller economy can participate without matching U.S. frontier model spending dollar for dollar.
Canada is already debating how to keep more domestic intellectual property, capital and compute capacity while using global AI platforms. The country's AI sovereignty debate is partly about preserving enough domestic capability to avoid becoming only a customer of technology developed and controlled elsewhere.
A recent pro-human AI initiative backed by researchers, business and labour groups also argues for human agency, limits on concentrated power and accountability for AI companies. Zuckerberg reaches some similar principles from a very different starting point.
Canada needs enough choice, competition, data control and domestic capability for its companies and citizens to use increasingly powerful AI on their own terms.
Zuckerberg's bet is that superintelligence can give individuals more power to learn, invent, work and build. Meta has the reach and financial capacity to put that idea in front of billions of people. The cost of doing so is already putting heavy pressure on cash flow.Whether users ultimately gain more control will depend on who controls the models, data, compute and rules behind their personal AI.
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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August 13, 2026 | NCFA Resource | Risk Compliance And Regtech, Artificial Intelligence And Data, Regulation And Policy

On August 6, 2026, the UK Financial Conduct Authority launched the FCA Handbook API, giving firms, developers and RegTech providers direct access to structured Handbook data. The free service lets software retrieve current rules, guidance, technical standards and glossary content for use inside compliance and regulatory change systems.
The practical value is real. Firms no longer have to rely only on website searches, monthly downloads or manually maintained rule libraries when they want FCA source material inside their own systems. The API creates a direct route from the Handbook into software that tracks obligations, maps rules to business activities or supports AI assisted compliance work.
The API provides structured access to the FCA Handbook, Technical Standards and Glossary. Users need a free Handbook account, and the FCA says the data can be used in firms’ own applications or through third party technology providers.
The FCA identifies several practical uses:
AI can help retrieve, classify and compare regulatory information, but the quality of the output still depends on the source material it receives. A direct FCA data feed reduces one common problem which is compliance tools working from copied, stale or inconsistently maintained rule text.
NCFA has already identified this problem in AI powered regulatory reporting. The opportunity isn't simply to add AI to compliance work. Systems need reliable regulatory inputs, clear controls and a way to trace outputs back to the underlying rule or guidance.
The API can also reduce manual work around regulatory updates. Firms can connect Handbook content to internal rule inventories, product governance, control libraries or change management processes rather than repeatedly checking individual pages for updates.
There are some practical access conditions. Users cannot work with the API directly through the Handbook website. They need a compatible external application such as Postman or RapidAPI, or another system built to use the interface. Protected endpoints are also subject to rate limits.
The clearest users are compliance teams, legal teams, RegTech providers, financial institutions and fintechs that need FCA rules inside operational systems.
Large firms with internal technology teams can connect the data to their own compliance architecture and tailor how Handbook content is matched to business lines, products or controls.
Smaller firms may get more value indirectly through RegTech providers that use the API to improve rule monitoring, change alerts, obligation management or policy tools.
Developers and AI teams also gain a cleaner source for regulated workflows. For example, a compliance assistant could retrieve relevant Handbook content, compare current and future text, or help staff identify which internal policies may need review after a rule update.
That doesn't make the API a compliance decision engine. A system can retrieve the rule accurately and still reach a poor conclusion about how it applies to a particular firm, product or client situation. Human review, legal interpretation and internal accountability remain necessary.
The main strength is source quality. The API automatically draws from the latest Handbook rather than requiring firms or vendors to maintain their own copy of the rulebook. That can improve consistency and reduce the delay between a Handbook update and its appearance inside a compliance system.
It is also useful that the FCA has made the service available without a separate licence fee. Firms can choose whether to connect directly or use a technology provider, which lowers the barrier for developers and RegTech companies testing new compliance tools.
The API is not a complete regulatory archive. It does not provide historic Handbook versions. Requests for past dates return an error, although current and future versions are available through the API. Firms that need a full historical record will still need the Handbook website, archive tools or their own retained records.
The API also does not cover every piece of FCA information. The FCA Handbook contains rules, guidance and standards, while other FCA publications, supervisory communications, consultations, speeches and notices remain outside that core source. Compliance systems therefore still need broader regulatory monitoring.
Direct access to current regulatory text improves the input, but it does not guarantee accurate interpretation. Firms using AI for compliance should still test outputs, keep records, control permissions and make it clear when a person needs to review the result. The IOSCO AI Supervisory Toolkit provides useful additional guidance on governance, oversight, data quality and control expectations for AI in regulated financial environments.
The FCA Handbook API is most useful when treated as authoritative source infrastructure. It can make regulatory information easier for software to retrieve and keep current, while firms remain responsible for deciding what the rules mean for their own operations.
FCA Handbook API Launch (use cases for compliance, RegTech and AI)
FCA Handbook API FAQ (access, current data, limits and usage requirements)
FCA Handbook API (API access and developer entry point)
FCA Handbook (current rules, guidance and technical standards)
AI Powered Regulatory Reporting (regulatory data, automation and AI opportunity)
IOSCO AI Supervisory Toolkit For Capital Markets (AI governance, controls and oversight)
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](http://www.ncfacanada.org)
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August 10, 2026 | NCFA Companies On The Move | Digital Banking And BaaS, Competition And Market Structure

On August 10, 2026, Revolut secured a French banking licence from the ACPR and European Central Bank. France will become Revolut's second EU banking base alongside Lithuania, with Germany, Ireland, Italy, Portugal and Spain expected to follow.
Revolut enters this phase with more than 75 million customers and $6 billion of 2025 revenue. It is also building licensed banks in several major markets, which changes the competitive significance of its renewed interest in Canada.
Revolut's 2025 results show a business well beyond its original foreign-exchange and card proposition. Revenue rose 46% to $6.0 billion, profit before tax reached $2.3 billion and net profit was $1.7 billion. Customer balances reached $67.5 billion.
Eleven product lines generated more than £100 million each. Card payments produced $1.3 billion of revenue, wealth $876 million and foreign exchange $800 million. Revolut Business accounted for 16% of group income.
Credit is becoming substantial enough to change the risk profile. The loan book grew 120% to $2.9 billion across personal loans, credit cards and an early mortgage portfolio, while commercial real estate lending has extended the company into more specialized credit.
Private-market pricing has climbed with the operating results. Revolut completed a secondary transaction at a US$75 billion valuation in November 2025. A new secondary sale confirmed in July 2026 is reportedly pricing the company at US$115 billion. The current sale has not been announced as completed.
The French licence divides Revolut's European banking structure more deliberately. Lithuania remains the banking base for much of the European Economic Area, while the French entity will take responsibility for six Western European markets with roughly 30 million Revolut customers.
Revolut completed the next stage of its UK banking licence in March, launching the bank for a domestic customer base of 13 million after receiving the licence in 2024 and completing its mobilisation period.
Mexico began full banking operations in January, and Australia became its first licensed bank in Asia-Pacific in July.
Revolut moved toward a standalone U.S. banking licence in January and formally applied for a national bank charter in March.
Owning more of the banking infrastructure gives Revolut greater control over deposits, credit, payments and pricing. It also requires more local capital, compliance and operating capacity. In Western Europe, Revolut has committed more than €1 billion to the new regional structure and plans to build its headquarters in Paris.
Revolut's renewed Canada strategy follows an earlier attempt built around prepaid cards and foreign exchange. The company entered a limited Canadian beta in 2019 and withdrew in 2021 without establishing a domestic banking presence.
Jan Pilbauer was appointed to lead Revolut Canada in 2025 after senior roles at Payments Canada and the Bank of Canada. Revolut has described Canada as attractive but remains early in its evaluation. It hasn't announced a launch date, and there is no public evidence of a Canadian bank licence application.
The regulatory setting has changed too. OSFI's Streamlined Approvals Framework creates a clearer federal route for eligible innovative banking models, while consumer-driven banking could reduce data-access barriers once regulated sharing is operating.
Revolut would also be operating a different business. A payments and FX app would add another fintech option. A Canadian operation spanning deposits, credit, wealth and business banking would compete for much more of the customer relationship.
Italy offers a recent reminder that localization cuts both ways. In April, the country's competition authority fined Revolut entities more than €11 million over investment disclosures, account restrictions and information concerning Italian IBAN availability.
The Italian action touched the same customer-treatment and localization issues Revolut has to manage as more markets gain their own banking entities. Revolut disagreed with the findings and said it would appeal.
Revolut now has the customers, earnings and product breadth to compete much more directly with established banks. Its French licence shows how much regulatory infrastructure that ambition requires. A Canadian return would reveal whether Revolut is prepared to build the same depth here.
Nik Storonsky and Vlad Yatsenko launched Revolut in London around spending, transfers and foreign exchange.
Revolut
Mobile financial technology company
Launch
Initial consumer product
Early Venture
Outside funding follows early adoption
UK First
International spending and transfers
Consumers
Customers seeking cheaper international money use
Banks And FX
Digital alternative to bank foreign-exchange pricing
A narrow international-spending problem gave Revolut an entry point before it asked customers to use the app for more of their finances.
Information notice: Private-company estimates are identified and attributed. Information may change after the stated update date. This content is provided for informational purposes only and does not constitute investment, financial or legal advice.
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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