Karsten Wenzlaff, Advisor
August 26th, 2025
Dec 17, 2025 | NCFA Fintech Market Activity | Scale and Partnerships
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On December 11 2025, CapIntel announced a formal collaboration with KPMG Canada to support wealth management firms rolling out digital advisor and client tools, according to the company’s announcement. CapIntel says more than 20,000 wealth professionals across North America currently use its platform.
Buying technology rarely causes problems. Adoption does. Most of the friction shows up after procurement, when integration work begins and compliance teams step in. Tools that function well on their own often slow down once they enter legacy environments with uneven advisor workflows and strict oversight requirements.
Talking Point
CapIntel is pairing its advisor platform with delivery support to reduce adoption risk inside large wealth firms, while KPMG Canada continues to lean further into execution and integration work for digital wealth initiatives. Will this collaboration shorten rollout timelines enough to influence how enterprise wealth firms evaluate advisor technology vendors?
That pressure has been building inside large wealth management firms. Digital modernization still sits high on the agenda, but tolerance for long pilots and stalled rollouts has dropped. Senior teams want tools in daily use, not just sitting between approval and deployment. In enterprise and hybrid advisor models, inconsistent adoption creates operational and regulatory risk firms don’t want to carry.
Both organizations have been active elsewhere in fintech and wealth technology over the past year. CapIntel has continued to expand partnerships and publish advisor focused research tied to client communication and trust, while KPMG Canada has emphasized its role in digital modernization and implementation support for wealth firms navigating complex operating environments.
This collaboration brings delivery into the commercial discussion instead of leaving it for later. CapIntel is pairing its platform with implementation and change management support rather than assuming firms will solve execution internally. That matters when advisor tools touch regulated client communications and firm wide processes.
James Rockwood, Chief Executive Officer, CapIntel:
“Joining forces with KPMG strengthens our ability to deliver at scale for the enterprise wealth market. By combining KPMG’s integration and transformation capabilities with our platform’s powerful advisor tools, we’re helping clients realize the full value of their digital strategy faster.”
As wealth technology matures, differentiation increasingly shows up in execution rather than interface design. Feature sets tend to converge. Integration effort, advisor training, and governance alignment don’t. For large firms, disruption risk often outweighs incremental product improvements.
The real test is practical. Firms will be watching for named deployments, clear rollout timelines, and repeatable implementation results across advisor teams. If those surface, the collaboration will carry weight inside buying committees. If they don’t, it’s likely to stay a partnership on paper.
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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Nov 7, 2026 | Last Updated Nov 13, 2026 | NCFA Fintech Whisperer | Artificial Intelligence And Data, Capital Markets Infrastructure And Funding, Competition And Market Structure, Cross Border Payments And FX, Cybersecurity Fraud And Financial Crime, Digital Assets Blockchain And Tokenization, Digital Banking And BaaS, Embedded Finance, Insurance And Insurtech, Lending Consumer Credit And BNPL, Open Banking Open Finance And Data Sharing, Payments Infrastructure And Money Movement, Regulation And Policy, Risk Compliance And Regtech, SME Finance And Business Banking, Sustainable Finance ESG And Financial Inclusion, Treasury Liquidity And Cash Management, Wealthtech Investing And Trading

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NCFA Fintech Whisperer is a live weekly market intelligence page tracking financial technology and financial innovation developments that change how markets operate. Coverage spans NCFA's full financial innovation taxonomy, with Canada first and global developments included when they materially affect rules, market access, competition, capital, technology adoption, distribution, risk or execution. We focus on changes that founders, investors, financial institutions, regulators and operators may need to act on, not simply what's making headlines. This page is updated throughout the week as material developments emerge, then closed and archived before the next weekly window begins.
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This is useful operating evidence because the bank measured the agent inside a real onboarding workflow. The value isn't a chatbot interface. It is fewer days spent cleaning institutional data before a client can use the service. Banks testing similar agents should track production accuracy, exception rates, analyst time and how quickly bad outputs are caught before they reach client records.
DTCC is extending a live depository service rather than building a separate token market. That gives banks and asset managers another network choice while the underlying security remains tied to DTC infrastructure. The commercial test will be whether another public chain improves collateral use, liquidity or distribution enough to justify the added custody, wallet and integration work.
The acquisition gives smartTrade more of the trading stack, from pricing and workflow through direct listed market execution. That can simplify vendor architecture for banks and trading firms, but it also concentrates more critical trading functions with one supplier. Buyers should compare latency, venue coverage, risk controls and migration cost before consolidating production systems.
OKXICE is testing whether investors will use digital stock markets outside conventional exchange hours under the SEC tokenized stock exemption while retaining shareholder rights. Brokers should examine custody, wallet eligibility and how liquidity works when the underlying stock market is closed. A launch date is not evidence of trading demand.
This is an operating distribution network, not another proposal for digital shares. Investors can reach familiar European companies through wallets and supported venues, although holding a token is not identical to direct share registration. Custody rights, corporate actions and reliable prices when primary markets are closed will decide how far this reaches.
Private credit managers cannot rely on a headline yield while investors struggle to see where fees go or how loans are valued. Canadian fund managers should test their own disclosures against these findings, particularly related party arrangements and distressed loans. Distribution may be growing faster than investor transparency.
Institutions can reach crypto liquidity through a familiar bank counterparty instead of adding a separate exchange credit relationship. That changes how treasury and trading desks assess risk, collateral and settlement. The real commercial test is whether the arrangement brings lower financing costs and dependable liquidity during volatile markets.
tZERO now controls more of the regulated derivatives workflow instead of relying only on outside venue or clearing capacity. That can improve product economics and launch flexibility, but licences don't create liquidity. Investors and counterparties should watch which contracts list first, which brokers connect and whether trading volume follows the regulatory buildout.
Securitize wants to earn revenue from financing assets, not just issuing their tokens. Lenders could eventually use the same infrastructure for collateral records, borrowing and funding, but the acquisition has to close first. The legal and operating structure of tokenized assets remains central to whether this works at scale.
Formation is building a different route from the planned NYSE platform, using Solana trading pools rather than a conventional exchange model. Issuer consent, investor access and lawful settlement all need to work together. A notice opens the preparation stage; it doesn’t establish live trading or sustained liquidity.
This is a consequential infrastructure choice, not a live tokenized stock exchange. Banks, brokers and custodians now have a more concrete system to evaluate for settlement finality, interoperability and collateral use. The next test is regulatory clearance and real trading activity, alongside the NYSE shareholder governance infrastructure announced last week.
Interoperability has become a commercial barrier to tokenized finance. Banks and infrastructure firms that help write common standards may avoid expensive custom connections later. The group builds on Europe’s tokenized finance settlement roadmap. This is a standards development process, not a new binding rule. The practical issue is whether competing ledgers and settlement systems can work together without new silos.
As private companies stay private longer, shareholders need better records and a practical route to liquidity. Morgan Stanley wants more of that work inside one client relationship, from employee equity through public listings. Transfer agency also gives it an important control point if tokenized securities gain institutional distribution.
A regulator’s conditions can change the economics of a deal even after most approvals are secured. Here the disagreement reaches beyond closing timing into Western Union’s agent model and strategy. Investors should treat the acquisition as disputed, not completed or cleanly cancelled, until the companies resolve their contractual fight.
If the banks combine, scale could lower operating costs but also alter competition for Italian deposits, lending and payments. Smaller banks and fintech partners would face a larger distributor with more bargaining power. The claimed savings deserve scrutiny alongside potential integration costs and the effect on customer choice.
Treasury teams want new payment options without rebuilding their control systems. Bottomline has shown USDC can operate inside its existing software, but commercial adoption still needs proof. The cost of converting funds, bank receipt and compliance will decide whether stablecoin payments become regular treasury infrastructure.
The missing link in many stablecoin payment proposals is getting funds into ordinary corporate bank accounts. PNC is testing that connection with its existing treasury clients. Banks and PSPs will be looking at conversion reliability, compliance and actual settlement costs. For Canadian firms, stablecoin issuance and payment rules remain important when designing a comparable service.
Fraud models work better when they reflect the attacks a business actually sees. Fingerprint is packaging that custom training without asking every customer to maintain its own machine learning stack. Buyers should test lift against their current controls, false positives and the quality of the fraud labels feeding the model.
Banks cannot set useful rules for AI agents if they cannot tell whether a customer session is controlled by a person or software. AiRE gives risk teams another input for that decision. The real test is whether it separates authorized assistants from attackers without blocking legitimate customers.
Crypto trading firms, banks and payment providers need to check their sanctions screening against the official updated designations. The exposure can sit with counterparties or payment routes, not just direct customers. Do not rely on press headlines to identify restricted parties when transaction screening requires exact legal names.
Fraud intelligence creates more value when banks, telecommunications providers and platforms can act on it quickly. These results give Canada measurable evidence of cross industry disruption. Firms should compare how rapidly reports lead to blocked payment routes and recovered funds, not just how many alerts are generated.
Digital asset firms still need dependable bank accounts and settlement access before institutional trading can scale. MidChains now has that connection through a global bank. The commercial value sits in moving client money safely between traditional and digital markets, not in adding another trading venue.
This gives Ethereum compatible applications a more direct route into regulated asset infrastructure without dropping issuer controls. Custodians and platforms can integrate familiar smart contract tooling while compliance remains attached to the asset. The next test is whether that easier access produces more live issuance and secondary activity.
Bank custody gives asset managers another established counterparty to evaluate for digital holdings. That can lower the need to manage keys internally, but clients still need to compare segregation, withdrawal controls and responsibility for losses. The bank has crossed from a planned offering to paying customers. This launch is Reuters verified and not independently confirmed through a new November 11 bank release.
DriveWealth can now package regulated crypto access beside the brokerage infrastructure banks and fintechs already use. That lowers one barrier for partners that don't want separate securities and crypto vendors. The next proof is product availability, custody design, partner adoption and whether the combined model lowers compliance and integration cost in practice.
A banking licence can give Revolut a stronger base for local deposits and services than a cross border app alone. But the commercial race begins only after it satisfies the conditions and opens accounts. Prospective customers and competitors should watch what products the new bank is actually allowed to offer.
An individual IBAN can reduce manual payment matching and give business customers a clearer way to receive funds. This is especially relevant as European banks verify recipient names against account details. Fintech buyers should compare the total cost of integration and account servicing, not just API availability.
Digital banks still compete for people who handle cash. Chase can offer nationwide deposit access without building branches, while PayPoint gains another banking distribution partner. For challengers, the question is whether a third party cash network costs less than the customers it helps attract and retain.
Business customers increasingly want bank services inside their ERP and finance software. Prolific offers banks an integration route without giving every client unrestricted payment access. The selling point is self service development under bank controls. Banks should test how quickly client APIs can be certified and put into production.
Core replacement is expensive for specialist banks that still need product flexibility. Monument is selling managed infrastructure rather than requiring AlRayan to build and maintain every component. Canada has its own production example in Tangerine’s new banking core. The agreement is commercially significant, but clients should distinguish a selected platform from completed migration and measurable service improvements.
Sage already sits inside the daily financial workflow of small businesses. Adding accounts and cards could keep more payments, cash data and reconciliation inside the same software. The opportunity is large, but the proof will come from launch timing, customer adoption and whether integrated finance saves businesses real administrative work.
The insurance product now sits beside daily property management work. Automated checks can reduce manual certificate chasing and give landlords a current view of coverage across properties. Distribution is established; the test is whether the expanded service cuts administration costs and produces measurable insurance adoption.
Canadian brokers still lose time maintaining separate connections to insurers. Common data fields can reduce that work and make it easier to launch quote and policy services. The value now depends on how many carriers and brokers adopt the certified interfaces in everyday transactions.
Existing terminals give Tabby a distribution route without asking merchants to install another device. AFS can add a credit option to its acquiring relationship while keeping checkout familiar. Merchants should compare fees, approval rates and basket lift against the added complexity of offering instalments at the counter.
Affirm is buying an established European payment provider rather than starting distribution from zero. That could lower its entry cost and put more merchants within reach. Existing Ratepay partners should watch pricing, underwriting and continuity of service before the ownership change becomes effective.
The credit union controls the customer relationship while equipifi supplies installment technology. That gives traditional lenders a way to compete with checkout lenders without sending members to another app. Pricing, underwriting, repayment performance and repeat use will determine whether embedded BNPL strengthens member economics.
Income increasingly lands outside traditional payroll accounts. Plaid is making that platform held income easier to use across the financial system. Lenders and personal finance apps gain a richer view of cash flow, while DoorDash makes Crimson more useful without building every downstream financial service itself.
Visa is adding another regulated settlement asset rather than asking merchants to change how they accept cards. For issuers and acquirers, the decision comes down to treasury economics, liquidity, custody and when stablecoin settlement is cheaper or faster than existing bank routes. Network support creates an option, not proof that partners will use it at scale.
Merchant acquiring is becoming a feature inside business banking rather than a separate purchase. HSBC can give smaller firms a faster route to card acceptance while Stripe gets distribution through a major bank. The competitive question is whether convenience and pricing are strong enough to keep merchants inside that banking relationship.
Local payment methods matter because customers often choose the option they already trust. A direct connection can reduce technical layers and give Ecommpay more control over service quality and economics. Merchants should judge it on conversion, settlement and total cost rather than the number of payment logos at checkout.
AI agents are getting payment instruments, not just permission to recommend purchases. That makes spending limits, evidence of consent and the ability to stop an agent commercially important. The same AI agent access controls are already being tested by Canadian banks. Firms should test what happens when an agent selects the wrong merchant or amount before giving it broad payment authority.
Another chain gives Visa partners a choice over settlement cost and technical integration. That does not mean merchants receive stablecoins or that funds are already flowing through Monad. Banks should check custody support, liquidity and the actual economics before selecting an additional network.
Every legitimate purchase lost at checkout costs a merchant revenue. Better data may help issuers approve more of those payments without turning off fraud controls. Canadian merchants and PSPs should test actual approval lift, added fees and dispute rates before assuming the integration improves margins.
Direct acquiring gives Omise more control over settlement, merchant economics and the payment services it can offer. It also puts more responsibility for uptime and risk on the company. Merchants will care about approval rates, costs and funding times, not which party owns the connection.
The rail is live, but access is not universal. PSPs and banks still need certification, operating arrangements and settlement readiness. The first commercial opportunities lie in faster supplier payments, payroll, collections and instant reconciliation. Firms planning a connection can use the approved RTR access and operating rules to map their responsibilities.
Crypto firms selling in New York now need marketing controls that look more like regulated financial product governance than ordinary growth marketing. Product, compliance and legal teams will need one evidence trail for fees, performance claims, testimonials and regulatory status. That also raises the cost of using influencers or affiliates without tight review and recordkeeping.
Removing some performance fees from the cap could make private market funds easier for workplace pensions to buy. That creates a larger distribution opportunity for private capital managers, but fees and valuations will face more scrutiny. Providers should model whether expected returns still justify the added cost after liquidity limits, valuation risk and member outcomes are included.
This is an operating change in who supervises a major stablecoin, not another consultation. Circle now answers to both European and French authorities across different parts of the same product. Stablecoin issuers entering Europe should expect scale to bring additional supervision, reserve scrutiny and recovery planning.
Russia is bringing crypto trading inside conventional exchange supervision rather than leaving it only to specialist platforms. Existing exchanges may gain a new product line, but approval of each venue's rules remains a practical gate. Brokers and infrastructure providers should watch which exchanges clear that gate first and what liquidity actually migrates onshore.
Screening teams need to incorporate the latest named entities, aliases and transaction restrictions into payment and customer controls. The compliance work extends beyond checking a bank name. Counterparty ownership and transaction routes matter too, particularly for firms already managing Iran related MSB and sanctions exposure.
Canadian issuers and platforms now have more detail on how securities regulators are approaching tokenized products. Firms with real transaction designs should prepare evidence on custody, investor rights, settlement and operating controls. The report gives a policy direction, not permission to launch a regulated product.
Canada now has two distinct milestones, a working payments rail and formal oversight of its resilience. Participants will need to test continuity, incident response and operational dependencies against a higher standard. Settlement speed is only useful when the rail stays dependable through disruptions.
The proposed treatment could give issuers a common legal route instead of seeking individual relief. Canadian policymakers should pay attention to the reserve, redemption and disclosure conditions, which determine whether users can trust payment tokens when a provider gets into trouble.
Reporting is becoming a scale business because firms must manage more jurisdictions without multiplying manual workflows. DTCC can now sell a broader reporting stack through one access point. Banks and brokers should compare data quality, exception handling and implementation cost against existing vendors before consolidating regulatory reporting with one provider.
A smaller reporting template should reduce the work of extracting and reconciling bank data. But climate risk adds a new testing requirement. European banks and regtech suppliers can plan changes now, then compare the cost savings against the data and model work needed for the new module.
Yoco can now fund more of its merchant lending from a dedicated institutional facility. That gives it more control over price and credit risk while offering merchants financing where they already manage sales. The key questions are repayment costs, merchant outcomes and how the loan book performs if sales fall.
Projects often struggle to raise financing before they have reliable data, commercial partners and an investable structure. SPIRE Asia tackles those problems together. Investors should look for the first funded transactions and whether public or philanthropic capital attracts private lenders on terms that projects can afford.
Corporate treasury platforms compete on access and control as much as investment yield. If this connection launches as planned, clients can choose another custody and investment route without rebuilding their primary investment workflow. The commercial test will be fund coverage, execution costs and account servicing across jurisdictions.
Businesses still spend time collecting balances from different bank portals before they can decide what cash is available. Citizens is putting that work inside an existing bank relationship. Banks offering treasury tools will need to compete on the quality of connected data, forecast accuracy and implementation effort, not just their deposit products.
Opening IPO requests in a retail app can give companies another distribution route while giving individual investors access before an initial trading spike. The question is whether customers receive meaningful allocations and understand the risk of buying at the offering price.
This week narrowed the gap between fintech experiments and working financial infrastructure. Canada’s RTR went live, Visa expanded stablecoin settlement, DTCC added another tokenization route, and regulated firms added custody, reporting and trading capacity. Regulators also tightened access requirements, while AI entered real production workflows. More infrastructure is now live, regulated and commercially usable. The next decisions are practical ones around customer adoption, cost, controls, integration and scale. Firms that cannot make the economics work in day to day operations will struggle to turn technical capability into durable business.
NCFA offers various curated resources to help founders and investors stay current on developments that impact fintech markets. Get the weekly Whisperer and related market intelligence through NCFA's newsletter, view the latest fintech news and insights, industry research, or launch into emerging financial innovation opportunities.
The National Crowdfunding & Fintech Association (NCFA Canada) is a financial innovation ecosystem that provides education, market intelligence, industry stewardship, networking and funding opportunities and services to thousands of community members and works closely with industry, government, partners and affiliates to create a vibrant and innovative fintech and funding industry in Canada. Decentralized and distributed, NCFA is engaged with global stakeholders and helps incubate projects and investment in fintech, alternative finance, crowdfunding, peer to peer finance, payments, digital assets and tokens, artificial intelligence, blockchain, cryptocurrency, regtech, and insurtech sectors. Join Canada's Fintech & Funding Community today FREE! Or become a contributing member and get perks. For more information, please visit www.ncfacanada.org
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Regulation | December 15, 2025

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On December 11, 2025, the Canadian Securities Administrators (CSA) and the Canadian Investment Regulatory Organization (CIRO) released new guidance for finfluencers, investment firms, and issuers on how securities laws apply to online investing activity (Download CSA and CIRO Staff Notice 31-369 13 page PDF). Social media now plays a real role in how Canadians make investment decisions, and regulators expect existing securities law to apply when online influence impacts behaviour. The guidance clarifies when creators must register, how disclosure must work in short-form content, what counts as advice or trading activity, and where firms and issuers remain responsible when they work with finfluencers. Keep reading to learn about the practical implications, including some use case examples covered in the report.
Regulators are responding to what they see in the market today. Social media is no longer a side channel for financial education. It is where many investors first encounter investment ideas, products, and promotions, often without realizing when education turns into influence.
As NCFA previously reported, based on the CSA's 2024 Investor Index, 53% of Canadian investors now use social media as a source of investment information. Among younger investors aged 18 to 24, reliance on social platforms is even higher. Those investors face materially higher risk.
The OSC also tests causation, not just correlation. In a controlled experiment involving 1,465 Canadians managing a simulated $10,000 portfolio, 38% of participants exposed to finfluencer style promotional posts purchased the promoted asset, compared with 8% in the control group. Exposure alone drives different investment choices, even without personalized advice.
Canadian securities regulators examined 87 finfluencers and 9 issuers and repeatedly found undisclosed compensation, promotional framing that functions as recommendations, and content drifting into advising or trading activity without registration.
The CSA and CIRO aren't introducing new rules. They are making it clear how existing securities law already applies when online content influences investment decisions. There's a clear message that Finfluencers should take seriously:
Labels and intent matter less than impact. What counts is how a reasonable investor experiences the content, not how the creator describes it.
Finfluencers need to register when they provide investment advice or help facilitate securities trading for a business purpose, unless a specific exemption applies.
A business purpose doesn't require a formal firm, a full-time role, or a registered brand. Regulators look at how the activity actually operates. Repetition, promotion, compensation, solicitation, and continuity over time all matter. Paid courses, subscription communities, affiliate arrangements, and recurring sponsored content often meet this threshold.
The guidance is explicit that finfluencers cannot avoid registration by saying their content is not advice. Disclaimers do not change how regulators assess the activity.
Investment advice includes opinions about the merits of investing in a specific business or security, as well as recommendations to buy or sell. The guidance notes that even promotional language or emojis that imply opportunity can be interpreted as recommendations.
Trading activity is defined broadly. It includes not only executing trades, but any act done in furtherance of a trade. The guidance specifically points to copycat trading enablement, such as linking followers who pay a subscription fee to replicate trades in a self-directed account. These lines are crossed more often than many creators realize.
Some finfluencers rely on the general advice exemption when providing broad and non-personalized commentary, however the regulator's guidance makes clear that this exemption is narrow and conditional.
If a finfluencer relies on it, they must clearly disclose any financial or other interest in the securities discussed. Financial or other interest is interpreted broadly and includes indirect incentives, compensation arrangements, and related party interests.
The exemption does not apply to trading activity. This distinction becomes critical when education is paired with transaction pathways.
Disclosure needs to be clear, prominent, and specific enough for an audience to understand the security involved, the incentive, who paid it, and who received it.
The guidance is direct about what fails. Statements like “I may have a financial interest” are not enough. Disclosure also fails when it is buried at the end of a video, hidden behind extra clicks, or written in a way viewers are unlikely to notice.
A simple acid test applies. If a viewer has to look for the disclosure, it likely does not meet expectations.
The example scenarios below highlight when creators drift into regulated activity without intending to. These aren't rare cases but common growth paths.
In one example, a creator starts with general investing education. That activity stays outside registration. When the creator adds buy and sell signals in a paid course, the activity becomes advising. When the creator begins answering personalized questions through comments and direct messages, charges fees, and scales tailored advice, registration becomes necessary or the activity needs to stop.
In a second example, a crypto-focused creator promotes a token without compensation. When that creator later joins an airdrop program tied to promotional tasks, the activity becomes compensated promotion. Disclosure obligations arise immediately and need to stay current. Linking to trading platforms and receiving payments from followers or platforms can also push the activity into trading facilitation.
In a third example, a creator promotes issuer securities for payment but hides the sponsorship because disclosure reduces engagement. Disclosure is buried behind “show more” links. Regulators treat this as a breach and move to enforcement. Not knowing the rules does not change the outcome.
Registered firms that work with finfluencers are expected to govern those relationships. That includes due diligence, written agreements, training, ongoing monitoring, and corrective action when content becomes misleading or non-compliant.
Order-execution-only dealers face added sensitivity. Because they cannot provide advice, regulators caution against indirectly enabling recommendations or registerable activity through referral arrangements, hosted content, outbound links, or copycat trading features.
For fintech platforms, this brings compliance into product design. Referral flows, creator landing pages, and trading enablement features all carry regulatory weight.
When issuers work with finfluencers, social media content counts as public disclosure. Issuers remain responsible for statements made on their behalf.
Regulators expect issuers to ensure content stays factual, balanced, consistent with filed disclosure, and clear about paid relationships. Issuers need to provide guidance and controls rather than leaving disclosure discipline to third parties.
Promotional shortcuts can surface later during diligence and capital raising.
Securities law applies regardless of whether content is created by a human, a digital avatar, or an AI system. Anyone deploying AI to generate investment related content remains responsible for that content as if they created it themselves.
For platforms experimenting with automated education or AI powered engagement, note that technology does not reduce accountability.
Finfluencer activity now sits firmly inside the regulatory perimeter. Data shows that influence impacts behaviour, and behaviour drives investment decisions. This new guidance gives founders, platforms, creators and issuers clarity. Teams that design content, monetization, referral flows, and product features with these expectations in mind can move faster with fewer surprises.
Teams that treat finfluencer activity as casual marketing often discover where the line sits only after they cross it. That is the practical message regulators are sending, and it is one the market needs to take seriously now.
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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Compliance | December 11, 2025

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On December 10 2025 the CSA and CIRO released new findings from their second national review of Client Focused Reforms based on 105 firms. The update arrives in a year marked by a CSA record year of 1,011 investor alerts and outreach that reached more than 4.5 million Canadians.
With the imminent arrival of Canada's commercialization of open banking, and the country's work on faster payments and new digital asset rules, fintechs now face a more demanding compliance environment, and firms must focus on fixing gaps to prepare for what comes next.
Client Focused Reforms arrived in two stages across 2021. Conflicts of interest rules took effect in June 2021 and enhanced rules for know your client, know your product and suitability took effect at the end of 2021.
Regulators did a first sweep in 2022 to confirm whether firms built the foundation. They looked at updated forms, processes and governance. The first sweep focused on whether firms completed the initial implementation work required by the reforms rather than on how well those changes worked in daily practice.
The second sweep tests practical use. Firms have lived with these rules for more than three years. Regulators expected complete records, strong reasoning and evidence of care in client decisions.
Regulators found that some digital onboarding flows move too quickly for the level of detail the rules require.
They saw cases where firms collected risk tolerance but did not collect risk capacity.
They found broad financial ranges that did not support detailed decisions.
They found missing updates when clients changed jobs, retired or faced major life events.
They also saw records that did not show meaningful conversations with clients.
👉 Regulators want firms to gather clear and complete financial information and to treat risk tolerance and risk capacity as separate concepts. They expect client data to guide decisions, not follow them. They expect fintechs to show that a digital experience still produces real understanding.
Fintechs often use a select list of products, model portfolios or automated recommendations. Regulators looked closely at these choices and found cases where product review notes were thin or unclear.
They found approvals without evidence of analysis.
They found firms relying on affiliates even though each firm must complete its own review.
👉 Regulators want product evaluations that show how a firm reviewed the structure, features, risks and costs of a product before deciding to offer it to clients. This work guides what a firm chooses to place on its platform and how it ensures the product suits the clients who may use it. They want clear records that show why a product fits the platform and how the firm reached that decision. They expect firms to understand their products in a practical way and to document that understanding with simple and direct notes.
Suitability is where digital advice models face the most pressure. Regulators found decisions marked as suitable with little or no explanation.
They found missing concentration checks and liquidity checks.
They found limited cost comparison even when firms offered lower cost fund series.
They saw suitability records that did not update after product changes or after changes to the representative responsible for the account.
👉Regulators want suitability work that explains how the firm connected the client’s information to the recommendation. They want firms to consider exposure levels, liquidity needs, cost differences and alternatives. They want reasoning that shows why a recommendation or a model portfolio fits the client.
Fintechs can improve compliance by treating data, product analysis and suitability logic as design elements. Design and process can impact onboarding flows that gather clear information without slowing clients down.
Fintechs strengthen compliance when they update client profiles after major life events and use product files that link directly to real due diligence notes.
Clear concentration and liquidity checks inside the recommendation engine supports more reliable decisions.
Cost comparison helps firms show why a recommendation fits the client.
Investor education tools help clients understand their choices with more confidence.
Thoughtful use of AI can improve accuracy and consistency when firms understand which processes benefit most from automation.
Strong design choices make it easier to show good judgment and better care for clients.
The new CFR review arrives as Canada prepares for major changes in the financial system. Open banking will introduce structured data sharing and clearer expectations for permission and accuracy. Payments modernization will accelerate how money moves, supported by Canada’s payments innovation push toward faster rails. Digital asset rules will mature as Canada moves forward with the first draft of the national stablecoin framework.
These developments point in the same direction. Regulators expect firms to show strong reasoning, accurate information and clear documentation of decisions. Fintechs that build these strengths now will be able to handle the coming changes with confidence instead of surprise.
Good CFR practices support competitiveness and growth. Partners and investors look for firms that manage risk with care and clarity. Clients choose platforms they trust.
The CSA year in review reports 54 permanent bans imposed during the reporting period and 24 enforcement actions tied to crypto assets. This is why strong governance matters at a time when financial infrastructure is evolving.
Fintechs that build accurate data, consistent processes and quality supervision strengthen their position and gain credibility across the market.
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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