THE STANDING SENATE COMMITTEE ON BANKING, COMMERCE AND THE ECONOMY
EVIDENCE
OTTAWA, Wednesday, December 10, 2025
The Standing Senate Committee on Banking, Commerce and the Economy met this day with videoconference at 4:18 p.m. [ET] to consider the subject matter of those elements contained in Divisions 4, 9, 10, 11, 12, 13, 14, 15, 16, 17, 22, 23, 37, 39, 43 and 45 of Part 5 of Bill C-15, An Act to implement certain provisions of the budget tabled in Parliament on November 4, 2025.
Senator Clément Gignac (Chair) in the chair.
[Translation]
The Chair: Honourable, senators, my name is Clément Gignac. I am a senator from Quebec and chair of the Standing Senate Committee on Banking, Commerce and the Economy. Welcome to our proceedings.
Before we begin, I would ask my colleagues to kindly introduce themselves.
[English]
Senator Varone: Toni Varone, Ontario.
Senator Yussuff: Senator Yussuff, Ontario.
[Translation]
Senator Ringuette: Pierrette Ringuette from New Brunswick.
[English]
Senator Fridhandler: Daryl Fridhandler, Alberta.
[Translation]
Senator Dalphond: Pierre Dalphond, De Lorimier Division, Quebec.
[English]
Senator Wallin: Pamela Wallin, Saskatchewan.
[Translation]
The Chair: Honourable senators, today we continue our prestudy of Bill C-15. We have a number of sections to analyze. Today’s meeting will be divided into two panels, beginning with the witnesses who are here in person and joining us by video conference. We will be discussing Division 9 in Part 5 of the bill.
From Fintechs Canada, we have Adriana Vega, Executive Director, who is here in person. Welcome, Ms. Vega. By video conference, we also have a representative of the Financial Data and Technology Association, Steve Boms, Executive Director. Finally, also by video conference, from Borrowell, we have Andrew Graham, Co-founder and Chief Executive Officer.
I understand you have some opening remarks. With that, I’ll turn it over to you, starting with Ms. Vega.
[English]
Adriana Vega, Executive Director, Fintechs Canada: Thank you, chair, and good afternoon, senators. I am the Executive Director of Fintechs Canada.
Fintechs Canada is the leading voice for Canada’s financial technology sector. Collectively, our more than 50 members serve millions of Canadians from coast to coast.
Thank you for the invitation to appear today to discuss Bill C-15. If passed and implemented, the financial sector reforms included in this budget bill will help make life more affordable for Canadians and our economy more productive. As we know, our financial sector is highly concentrated. Over time, this has had real impacts on Canadians’ ability to hold agency over their money, and it has also limited access to capital for both individuals and, critically, our small businesses.
Canada’s regulatory regime has not kept up with the rest of the world, depriving Canadians of access to broader choice and bespoke and affordable offerings. The reforms included in Bill C-15 — concretely those introducing Canada’s open banking regime — are hugely welcome and long overdue.
When in force, the new consumer-driven banking act will make the financial sector work better and harder for Canadians. Moreover, the stablecoin act, also in the budget implementation act, 2025, or BIA, is an ambitious piece of legislation. Fintechs Canada commends and supports the government’s swift response to industry calls to create this federal framework.
The road ahead is still long. Regulation still needs to be developed, and we now need to focus on striking the right balance that provides clarity and certainty for builders and that preserves the pro-competition spirit of the law.
Canada has a unique opportunity to leverage consumer-driven banking and transformative technologies like stablecoins to provide a long-overdue boost to our economy. Delays are not an option.
I thank you for your invitation and for your pre-study of this bill, and I look forward to your questions.
The Chair: Thank you, Ms. Vega.
Mr. Boms, do you have any opening remarks that you want to share with us?
Steve Boms, Executive Director, Financial Data and Technology Association: Yes, Mr. Chair. Thank you very much.
Thank you for the invitation to appear today on behalf of the Financial Data and Technology Association, or FDATA, the leading trade association advocating for consumer-permissioned access to financial data. We represent many of Canada’s most innovative financial technology companies and have been strong advocates of open finance in Canada for nearly a decade.
Division 9 of Bill C-15 represents a meaningful leap forward for open finance in Canada. Once implemented, it will enable Canada to not only catch up to its G7 counterparts, but to lead them.
The framework reflects broad industry feedback that will better enable consumers and small and medium-sized enterprises, or SMEs, to access more innovative financial products, tools and services in a competitive financial services marketplace.
I’d like to very briefly highlight four.
First, the scope is comprehensive. The legislation will confirm that Canada’s framework includes all financial accounts, not simply chequing, savings and credit card accounts.
Second, the governance is appropriate. Providing the Bank of Canada with oversight responsibility for consumer-driven finance builds on existing capacity and expertise and will allow financial technology firms already registered with the bank to more easily become open finance accredited.
Third, it empowers small businesses by explicitly incorporating business accounts into Canada’s open finance framework.
Fourth, the framework will evolve and expand. We welcome the commitment to introduce legislation by mid-2027 to facilitate “write access” to enable a more competitive, modernized payment system for Canadians.
In sum, this open finance framework would enable a more innovative, efficient, competitive and customer-centric financial system in Canada. It is essential that the government implement this framework according to the timeline it has committed to following.
I look forward to answering your questions.
The Chair: Thank you, Mr. Boms.
Mr. Graham, I understand you have some opening remarks. The floor is yours.
Andrew Graham, Co-founder & Chief Executive Officer, Borrowell: Thank you, Mr. Chair, and thank you to the committee for having me. I am co-founder and CEO of Borrowell.
Borrowell is one of Canada’s largest fintech companies. We have 4 million companies who have signed up with us to monitor and improve their finances. We are the first company in Canada to offer credit scores for free and the first company to allow Canadian renters to report rental payments to build their credit history. We are a proudly Canadian company employing over 100 people from coast to coast.
We see the challenges of delivering financial innovation in Canada. Take our experience launching Rent Advantage, which is our service to allow renters to build credit history. When a Canadian signs up for this service, we verify that they’ve made their rent payment every month by asking the customer to share their payment history with us. With the present system, where we don’t have consumer-driven banking, this doesn’t work. Connectivity is poor, and consumers often have to re-enable these connections every month.
Imagine if your favourite TV streaming service required you to re-enter your credit card information each month. It is more than a hassle; it really is a blocker.
This subpar experience can lead to customer cancellations, despite the service being beneficial for the customer’s credit history. Surely, a consumer should — if they wish to — be able to securely and easily share their payment history with a service like Equifax.
The reality is that in the absence of legislation, the present system makes it difficult for Canadians to share their financial information securely. Moving expeditiously to address this, which Bill C-15 will do, is crucial. Thank you.
The Chair: Thank you for your opening remarks.
Colleagues, we have probably 50 minutes left, so I propose that we could have at least five or six minutes each for the first round, and after that we will go for a second round.
[Translation]
Senator Henkel: Division 9 organizes the secure flow of data. However, it doesn’t say anything about the economic exploitation of that data. Without any explicit guardrails, how can we avoid a secondary or even a parallel market in which banks and accredited third parties could extract considerable value from the data consumers give up for free?
[English]
Ms. Vega: Thank you for your question, senator.
The framework will allow Canadians to hold greater agency over their data. In many ways, you could argue that open banking already exists in Canada, but there are gaps in the regulatory framework because we don’t have an open banking framework in effect as of now.
What that means is that Canadians are left to pick providers without the full certainty that they could be receiving in a robust, regulatory framework. Open banking will make the rules a lot clearer for all the players in the system. It will provide not only assurances for the government but also for consumers, and it will also provide a layer of safety for the providers themselves, for fintechs that are going to be participants in this market and for banks. For anybody who will be a part of this, they will have to undergo a whole suite of regulatory requirements, including a national security review, that they will safeguard this data and that they will all compete fairly for the business of Canadians.
When we have a fully functioning, open banking regime, and once these rules are implemented, the system will become more transparent for Canadians to make decisions over who gets to safeguard their data, and they will have the agency to do that.
The Chair: May I ask if the other witnesses want to add something?
Mr. Boms: I would be happy to. Yes, thank you very much, Mr. Chair.
Senator, the idea of all third parties having to be accredited is a very important improvement over the status quo today. Today, FDATA member companies provide roughly 8 million Canadians and Canadian small business owners with their services. They do that in the absence of any kind of accreditation, and they do that through screen scraping.
Open banking will mandate a transition to a more secure means of accessing that data — likely through application programming interfaces, or APIs, although a technical standard has not yet been chosen — and will require that the Bank of Canada accredit all of those third parties before that data is being accessed with the consumer’s permission.
It may not be perfect. I will acknowledge that we will have to iterate over time, but it is a marked improvement over the status quo.
The Chair: Mr. Graham, anything to add?
Mr. Graham: No, I’m happy to move on. Thank you.
[Translation]
Senator Henkel: Some critics fear that a data sharing framework will primarily benefit only established players: the big banks and the tech giants that have the resources to exploit this data on a large scale. How does Bill C-15 ensure that small fintechs and consumers in remote or low-income areas will be direct and meaningful beneficiaries and not just data providers?
[English]
Ms. Vega: Thank you for your question.
That is a core issue for us at Fintechs Canada. I mentioned in my opening remarks that the legislation is really the foundation; it is something that we need to do and it is a great first step in the direction of where we want to go as a country in terms of empowering consumers and incentivizing more competition.
However, when I refer to the road being still long, I mean that the developing of the regulations is going to have a big role to play in making sure the system actually works the way intended to empower consumers and make sure it reflects the pro-competition spirit of the law. A lot of the work remains to be developed, and I will say that we’ve had great engagement with officials at the Department of Finance. With the Bank of Canada becoming the regulator, it sets a great touch point for all the different actors to engage with the same regulator.
A lot will remain to be seen, though. We don’t want to get to a point where there are imbalances in the regulation. The regulation will need to be proportional and risk-based. That would be our core message for the agencies and government officials.
The Chair: Mr. Graham or Mr. Boms, do you have anything to add?
Mr. Graham: Sure, I’m happy to add.
I think it’s a great question. I can tell you, as someone who runs a fintech company for a living, that having the sort of consumer-driven banking system that is proposed in this bill will certainly — for my company and, I believe, for many more — increase our ability to compete. One of the biggest advantages that an incumbent has in the world of financial services is all the customer data they have. If a bank, for example, has had a relationship with a customer for many years and can see that customer’s payment history and inflow of regular employment into their accounts, that gives them an advantage when it comes to, perhaps, financing a mortgage for that customer, for instance.
Consumer-driven banking will allow that customer, if they choose, to share that history of regular payments coming into their bank account and on-time rent payments, for example, with another mortgage lender. That’s one of the ways how this will increase competition. For my own company, it will be a significant improvement.
Mr. Boms: To quickly add, one of our main requests of the Department of Finance over the last several years was to try to find a way to make sure that small Canadian companies are able to become accredited just as large Canadian companies are.
While I completely agree with Ms. Vega that there’s still a lot to be determined through regulation, I would highlight the very important movement of governance of this system to the Bank of Canada. That is, in our view, a nod toward that outcome. The overwhelming majority — nearly all of our members — are already registered with the Bank of Canada under the Retail Payment Activities Act, or RPAA. That basis becomes a stepping stone to become accredited here, which will enable smaller companies to be able to comply with that accreditation regime, if all goes well, much more easily than would have been the case if it had been a completely separate regime created from scratch.
Senator Wallin: I think you’ve answered my question, which is whether you are pleased about the relationship with the Bank of Canada.
Let’s just go to the process, because this happens all the time: We have legislation, and then it’s all going to get sorted out as they negotiate the regulations; “it will be resolved in the regs.”
What assurances do you have of that, and what is your relationship to that process?
Ms. Vega: We have undergone a recent process, actually, under the RPAA. It was a piece of legislation that is being implemented right now, and hundreds of payment service providers applied to be accredited under the Bank of Canada.
Obviously, during the rollout, things come up in the process, but I will say that we’ve had great engagement with the officials at the Bank of Canada.
Just to build on the point that my colleague Mr. Bom raised earlier, we think that connecting all of these participants and bringing them under the umbrella of the Bank of Canada is a positive, simply because the Bank of Canada will be able to have a holistic view of all of the players that participate in the economy, whether you are providing a payment service, issuing a stablecoin or are accredited to participate in the open banking regime.
While I think that a lot remains to be seen, and I do think that the Bank of Canada probably has a significant amount of work in terms of expanding their capabilities and learning through the process, I do think that our experience with the Retail Payment Activities Act sets a good basis for collaboration and a positive engagement for us as industry stakeholders.
Senator Wallin: I’ll just ask the gentlemen to comment on this, because regulations are still negotiated by government. I think there would just be recommendations from you through the Bank of Canada and then through to the Department of Finance. That could be a circuitous route.
Mr. Boms, do you want to go next to comment on that?
Mr. Boms: Senator, thank you for the question.
I’ll first knowledge acknowledge that there are no guarantees when it comes to the regulatory process. I don’t want to insinuate that we know what the outcome of these regulations will be. However, I would echo Ms. Vega’s comments about the Bank of Canada’s process and the RPAA. Their stakeholder engagement was exemplary. Their communication was ongoing and consistent throughout.
Regarding open banking, generally, I mentioned in my opening statement that FDATA has been working with the Department of Finance Canada for a period of about a decade now. It has been a highly consultative process. It has been a responsive process; I think we have spent more time consulting on this file than any other file —
Senator Wallin: To a fault, I think is your point.
Mr. Boms: Thank you for saying it.
All that to say that the lines of communication have been very much open. There is no guarantee that the outcomes will be what we’ve been asking for, but at least those consultative lines are there and have been very effective to date.
Senator Wallin: Your final comment, Mr. Graham?
Mr. Graham: Thank you, senator.
I would certainly agree with the comments of my two colleagues. I would also add this is intended to be a multi-step process. The government has signalled that step one will be read access, which is what is contemplated here; and step two would be “write access,” which would come later. We know there are going to be multiple steps here, which will hopefully afford everyone in the ecosystem an opportunity to provide additional feedback as the system understandably goes into practice and evolves.
Senator Wallin: In terms of the extensive consultation process that you described, do you think the government’s timelines are realistic as they’ve spelled them out?
Ms. Vega: We would like to see Bill C-15 approved so that we can continue engaging with government on the regulatory development. However, I will say those channels of communication, as Mr. Bom has already mentioned, have open, and we’ve been invited to provide comments. That engagement with the officials at the Department of Finance has been ongoing, and just because it’s an issue that’s been debated and analyzed at length, it’s ambitious but doable. What will be important for innovators will be to stick to the ambitious timeline that’s been set out.
Senator Wallin: Very quickly, one of the things we heard from the Office of the Superintendent of Financial Institutions, or OSFI, witnesses is that we really can’t anticipate the problems or try to solve them until they happen because they can’t think about them all.
Are you convinced that, if you see something, you’ll be able to intervene at that point?
Ms. Vega: I believe so. What I have been hearing from officials, agencies and elected officials is that expediency is of the essence. It is complicated, but there is goodwill both on the industry and government sides to get this done.
Senator Wallin: Mr. Boms, you had a quick word.
Mr. Boms: The benefit of Canada no longer being a fast follower on open finance but being a follower at this point is having learned from other jurisdictions. I know this committee has heard that message pretty consistently over the last few years.
Senator Varone: I’ve been embracing open banking, and I applaud the direction the government is taking on this. I applaud even further the kind of empowerment it will give the consumers.
Along the way, there are going to be some issues. This question is addressed to Mr. Graham, but others may chime in.
If I’m applying for a mortgage, a car loan or a credit card and I want the six banks to compete for it, how many times is my credit rating being pulled? Every time a credit rating is pulled, there’s an impingement on your credit.
At what point in time do you negotiate with TransUnion and Equifax to empower consumers in the same way you want them to be empowered through open baking? It seems that, unless they are onside, the information cannot flow from Equifax to the consumer and from the consumer to the bidding banks or the bidding institutions; it has to flow the other way, and every time it does, you end up with a note on your credit rating.
Mr. Graham: Thank you, senator, for the question. I’m certainly happy to address it. We’re one of the largest pullers of credit data in the country at this point.
The good news is, I think the credit bureaus in Canada have been very forward thinking in terms of allowing consumers to have greater agency over their credit data. For example, when someone signs up with us at Borrowell and we pull their credit score and report to give them access to it, that has no impact on the consumer’s credit.
Similarly, many companies are now doing what’s called a soft pull, which is the same kind of pull that we do, to assess ability to qualify before formally applying for a product. Again, that’s a soft pull.
Senator Varone: The point is, when you formally apply, you need an independent credit report from Equifax or TransUnion, and that’s where — and I’m a client of yours, so I know exactly what my credit is, but the banks won’t accept it from me.
Mr. Graham: That’s a great point. What we’re seeing in the market is that services like ours, we’re able to work with banks and other lenders, ingest their approval criteria, and we’re able to tell you, in many cases, if you will be approved without the bank having to then independently pull credit if you don’t actually want to apply.
I think there’s a lot of work under way to try to make that process easier. Helping consumers price shop without it impacting their credit is a very worthy objective, I agree with you. I think we’re making good steps as an industry toward that.
Thank you for being a client, I should say. Thank you very much.
Senator Ringuette: Thank you. Very interesting. Are you all Canadian companies, living, breathing and operating in Canada?
Mr. Graham: That’s correct. I have downtown Toronto behind me. We have well over 100 employees all in Canada, and our 4 million members — what we call our users — are all Canadian. We are a 100% Canadian company.
Senator Ringuette: That’s the first question. Ms. Vega?
Ms. Vega: In our membership, we have over 50 companies, and we represent many different verticals in the financial technology space. We have Canadian companies, but we also have international companies in our membership. We represent financial technology providers, digital first and challenger banks.
Senator Ringuette: Okay. Mr. Boms?
Mr. Boms: Yes. We similarly have Canadian companies as our members and international companies as well, some of whom do business in Canada, but not all of them do.
Senator Ringuette: Mr. Graham?
Mr. Graham: I’m trying to think what else I can tell you. Certainly, our employees are all here and we serve the Canadian market today exclusively.
Senator Ringuette: Thank you. My second question is for Ms. Vega and Mr. Boms.
What is the commitment for your members to reside and occupy a space in Canada? By extension, what is your members’ commitment with regard to safeguarding Canadian consumer financial data within Canada, which is supervised by the Information Commissioner of Canada? What is your commitment to that?
Ms. Vega: In our membership, we have financial technology companies, and it is a requirement that they operate in Canada. All of our members currently operate in Canada. Some are global companies establishing a presence there, and many have been waiting for the rules for open banking so they can fully deploy their suite of products.
Our companies abide by many different laws and regulations in this country, not just open banking. They already report to a multitude of other regulatory agencies with oversight over things like lending and consumer protection or, in this case, privacy. Our members are happy to engage with the regulators and comply with this law.
Within the scope of the open banking law, it doesn’t necessarily need to cover all the different verticals, but our members are currently already complying with the laws established by Canada on data protection.
Senator Ringuette: Data protection as of yet. We’re looking at establishing a new framework for your membership, and the data protection is not in there yet. The requirement for data to be kept within Canada is not there yet.
What you’re saying to me is that, no, as of yet, your membership has not committed to the Canadian consumer to do that?
Ms. Vega: Do you mean to keep data in Canada?
Senator Ringuette: Yes.
Ms. Vega: Well, I think the objective of data protection is to make sure that the Canadian government is satisfied that we have oversight and jurisdiction —
Senator Ringuette: That’s not my question. My question and concern is related to the fact that if your members — and we’ve been discussing open banking at this committee for over three years. If your members are not committed to our concern that I think express the concerns of Canadian consumers with regard to safeguarding that data within Canada —
Ms. Vega: I will say the companies are committed to complying with the law. This question is perhaps better addressed to the government. As long as the government is satisfied with the protections that are in place —
Senator Ringuette: So what you’re saying is if it’s not within the law, it won’t happen. Mr. Boms, what is your answer?
Mr. Boms: My answer, senator, is that there are some instances where a Canadian consumer would want their data available elsewhere. When a Canadian travels elsewhere and wants to access that data, they should have the ability to do so with their consent.
It needs to be spelled out in regulation what these requirements are, the instances where that data can be made available outside of Canada. It is our expectation that this will be made clear through regulation. And the commitment from all of our members, including those who don’t today do business in Canada but want to and are waiting for these regulations to come in, is that the regulations will spell those requirements out and they will comply as a condition of being accredited.
Senator Yussuff: I have two questions, and you could each have your own version of an answer in regard to it.
Does the framework generally allow for a small fintech company to have a fair chance to compete? Or does the legislation continue to favour the big financial institutions in the country?
Ms. Vega: The legislation, as I mentioned, is the legal foundation for companies to participate. Our aim is for small fintech companies to have equal opportunity to compete on a level playing field.
A lot of the regulatory developments will be the ultimate decider of whether that happens or not. It’s having this regime fully implemented, and we will participate in those consultative processes to make sure that our members, fintech companies, have the ability to participate.
Regulations, to my earlier point, should be balanced, and they should be risk-based to ensure we don’t unintentionally create the artificial barriers that are unnecessary and that ultimately only serve to deter access for smaller fintechs.
The Chair: Mr. Graham, anything to add?
Mr. Graham: Sure. Thank you, senator. I would certainly agree with what Ms. Vega just shared about the importance of regulation.
I would add that at a legislative level, creating a consumer-driven banking framework is very pro-competitive. Putting aside for a minute the details of what will be in the legislation, having a clear framework like this will allow for more competition and will be helpful for smaller companies. I say that as someone who has founded and is leading one of those companies.
The present state of affairs where it is very difficult for a consumer to share their financial information in a reliable and secure way is very detrimental to competition. This is a significant improvement. The details that will come in the regulations will, of course, matter, but directionally, this is a very pro-competition — I really think it’s actually beneficial for everybody, but including smaller companies.
Mr. Boms: Too soon to say for certain, senator, but this legislation is the most reasonable shot we have at accomplishing that outcome.
Senator Yussuff: My final question, ultimately we’re here to talk about consumers. That’s what it’s all about. From you and your own biases, whatever they might be, do you think this is going to actually lower costs for consumers, this opportunity for greater competition within this jurisdiction?
Ms. Vega: This sets us on the right path. Industry has advocated for these changes for a long time. As Mr. Graham was saying earlier, this is the right measure at the right time. It’s a very pro-competition measure that Canada should implement.
Mr. Graham: Part of what my company does is allow consumers to shop the market to compare different providers of credit cards or bank accounts, for example. What will make that even better for the consumer is being able to tailor those comparisons with their personal financial data, should they wish to. We do that today in a sense. Using the example I mentioned earlier, if a consumer could more seamlessly share their, for example, 10 years of consistent payment history on their mortgage when they’re shopping for their next mortgage, that is going to increase competition and ultimately lower costs. It will reward consumers with positive behaviours and lower costs for them. That’s why I believe this is a very pro-consumer and pro-small business piece of legislation.
Mr. Boms: Senator, the benefit of the years of consultation on this gives us the ability to look at other markets that have moved more quickly and say that’s not theoretical. It is actually what has happened in other markets that moved more quickly. You see things like lower cost of payment services and tools. Cash flow underwriting has come to market in other jurisdictions, which enables access to lower-cost credit, both for personal loans and business loans.
I think the answer is unequivocally yes, if we get this right.
The Chair: Thank you. Back to your previous question regarding the Bank of Canada and fintech, I would like to show my colleagues that the deputy governor of the Bank of Canada in early October mentioned that banking is an oligopoly and we need more competition. I think that would be an interesting discussion with you.
Senator Dalphond: All your comments are very positive about the bill and its content. You were consulted maybe for too long, but the thing is there.
What is missing? Based on your consultation process, what has the government forgot, if anything?
Ms. Vega: I can’t really speak to anything the government has forgotten. I think we’ve been very thorough. If anything, I would just say we need to do better on federal-provincial jurisdictional issues. We see very clearly on other issues, like stablecoins, for example, something that is coming up from scratch, we have an opportunity to build it. Even before it’s already implemented, before it’s a law, there are already issues around this friction between where does the federal jurisdiction end, where does provincial begin? And innovators are caught in the middle of having to interpret that I think both cover me, but then really the onus is on the innovator.
On open banking, we could potentially see some challenges like this when rollout is real. We’ll have to observe as things roll out, but I would flag that. Generally, I’m sure this is something you hear from other sectors, not just our own, but federal-provincial regulatory fragmentation is a real issue, especially for small companies.
Mr. Boms: Senator, we are at a stage now where the challenge for the government is no longer ideation; it’s execution. It’s a new phase of this process.
The Chair: Mr. Graham, anything to add?
Mr. Graham: Nothing to add. Thank you.
Senator Fridhandler: One of our witnesses mentioned that this data sharing might be beyond the territorial jurisdiction of the Canadian government. I was happy to hear today the announcement that Microsoft is going to domesticate a lot of their data storage. We have a concern, I’ve heard from many of my colleagues and with witnesses, about the integrity of data protection of Canadians, Canadian sovereignty. As soon as you move it extraterritorially, one of our government witnesses said, oh, we have great agreements and arrangements with everybody if something should go sideways. I don’t think that’s sufficient.
One thing I think is missing from the legislation is setting a boundary. Does open banking apply solely to exchange of information within Canada with Canadian participants or participants who operate within Canada? Do we need that framework or is it open globally, both to the participation and/or where the data is stored?
Ms. Vega: As I mentioned earlier, there are already rules governing safeguarding data for consumers. That applies not just in the banking space; it applies across all sorts of different data. The companies in our membership and beyond are in compliance with those laws and regulations.
Ultimately, the job for the government is to decide, are they satisfied with the jurisdiction that they have over whoever is having custodianship over that data? Do they have sufficient regulatory tools to govern what these providers are doing? That’s really a question more for the government. For companies what we need is clarity in the rules and predictability in how this regime will operate.
I also think there’s a reason why we have different verticals of legislation and regulation, whether it is prudential regulation, privacy or data protection. As long as the rules of engagement are clear for businesses and innovators, our companies will be happy to engage with government and comply with them.
Mr. Graham: I agree with all of that. I’m happy to add that if you compare what’s happening now, senator, where a consumer can share their data via screen scraping with really any entity in the world that they might wish to, that is a much scarier situation than where we will be after this bill is hopefully passed, where there’s going to be a very clear accreditation process. The details of that accreditation process are to be determined in the regulatory process, but having an accreditation process where a company has to go through and register effectively to be part of the consumer-driven banking regime is a marked improvement over where we are today.
Mr. Boms: I would completely agree with all of that.
Senator Fridhandler: Just to clarify, does your business case require that the boundaries of open banking stem beyond Canadian boundaries?
Mr. Graham: For my business, it does not. We’re working with Canadian consumers, and we’re helping them connect with financial institutions that serve and ultimately operate in the Canadian market. There’s no instance where we would refer them to a company outside of the Canadian market today.
Speaking for my own company, I would say my business case does not depend on that.
Mr. Boms: Senator, I would offer some other perspectives. This is all theoretical because today, it can’t happen; the system has not yet been built.
What we have seen in other markets is, for example, new Canadians or new arrivals to a specific country will not have a credit score or a credit file traditionally in that country, but if they can bring in data held about them for a chequing account or a savings account at a financial institution from their home country, they may qualify under cash flow underwriting for affordable credit or credit at all, where otherwise they might not have. That’s one situation where a policy-maker may determine that you should be able to bring in data from elsewhere in order to effectuate a better outcome for that consumer.
These are questions, to Ms. Vega’s point, that the regulations will have to contemplate. I think the commitment from our members certainly — and I believe all Canadian fintechs — is we are ready and willing to comply with whatever those requirements are to provide for the most competitive and secure system for all Canadians.
The Chair: Thank you. To complete this first round, last but not least, our colleague Senator Deacon is back from the Senate. You have the floor.
Senator C. Deacon: Thank you very much, chair. In this job, you’re often doing things that you have to do, and they take precedence over what you want to do. I wanted to be here, but I’m glad to be here now.
I want to ask about the API, the prospect of, for example, Financial Data Exchange, or FDX, being the chosen API in the exchange of data across our open banking or consumer-directed banking system. That’s a concern to me because it’s governed by American banks and it’s not a Canadian system.
I wanted to ask, just from your perspectives, Ms. Vega, Mr. Graham and Mr. Boms, what advice would you have to government in terms of moving forward?
It’s the choice of the minister about what API is chosen. The importance of having Canadian governance over that API and being able to iterate as we move forward in its use to learn how to improve and potentially — the Standing Senate Committee on Banking, Commerce and the Economy has been talking about this for seven years, so potentially moving forward in a way that really takes advantage of the opportunities for consumers on a forward-looking basis. In terms of the governance of the API, what are your thoughts?
Ms. Vega: Sure. Thank you. I think the answer is in your question. Thank you for that question. I hear you on your concerns.
I think, ultimately, it’s about the governance model. I think that’s what government needs to be thinking about. As they select the standard-setting body of choice, they will have to have pretty clear objectives when it comes to the governance and how they need to negotiate, perhaps, any changes that they would like to see on the governance front.
My advice for government would be let’s not have that be the reason why we delay implementation of this bill. I mentioned that earlier. Delays are really not an option anymore. I think we need to be able to do both things in tandem and not have one thing be beholden to the other.
FDX is here. It’s the system that is seen, perhaps, as the better fit for a standard-setting body. If it is, I think the issue really is for government to nail down the governance model rather than try to reinvent the wheel. That would be my only recommendation at this point.
Senator C. Deacon: Thank you. Mr. Graham?
Mr. Graham: Senator, thank you for the question. Let me thank you more broadly for all your work over the years advocating for a more competitive financial system and for consumer-driven banking more broadly.
I think I would echo Ms. Vega’s comments that probably the worst thing we can do at this point is to slow down. I think it would be unfortunate to pick a standard and embed that so deeply that it can never be changed or added to. Indeed, there may be a world where there are multiple standards available to be used. But I think at this point, my priority as a company certainly is let’s get moving with V1 and go from there.
Mr. Boms: First, senator, I would reiterate what Andrew just said. Thank you for your leadership over many years on this very important issue.
I won’t belabour the point other than to say the single-biggest technical blocker to companies beginning to build toward open banking is this decision of what the technical standard is going to be. Before cars drive on the highway, you have to build the foundational supports and the roads upon which they’re going to drive. We’ve heard the same concerns around governance. Many of our members are FDX members as well. Once the government has made its decision, that will enable the system to start being built, so we’re very hopeful that decision will be made relatively soon.
Senator C. Deacon: Thank you very much.
The Chair: I think my colleagues and myself want to echo congratulations to our colleague for his leadership.
Senator Ringuette: Thank you. I have a quick question for Mr. Boms. You were quite congratulatory in regard to the consultation you had with the Department of Finance in developing this framework. During those consultations, what was your position in regard to data sovereignty and data protection?
Mr. Boms: Thank you for the question, senator.
The consultations have taken place over a period of about a decade, so they’ve evolved over time. I am not recollecting at the moment any discussion during those consultations around data sovereignty other than the idea that the consumer should be empowered to control where their data is at all times. The consumer should be in control of their data. That has been the guiding principle behind all of the input that we’ve provided for almost a decade now.
Senator Ringuette: Thank you.
Senator C. Deacon: Thanks again to our witnesses.
I want to just touch on an issue that we’ve been speaking about a lot at this committee, and that’s fraud associated with our banking system. According to the Canadian Bankers Association, about half of the fraud is occurring specifically within the banks, and the other half is more within the ecosystem around the banks, including telcos.
I know there’s been efforts in other countries where fintechs have come along and been able to really help address this issue in a constructive way and provide consumers with options that reduce the risk of fraud quite substantially. I’m wondering if we can reverse the order and have Mr. Boms speak, then Mr. Graham and Ms. Vega to finish off. Please speak about the opportunities here that consumer-directed banking will open up for us.
Mr. Boms: Senator, thank you very much for the question.
It is the case in other markets that banks have looked at fraud in silos. They see only what’s happening within the bounds of their own bank. They don’t see what’s happening in the system.
In the consumer-driven banking ecosystem, there is this pan-system view where you can see fraudulent account takeover attempts happening across the board and pre-emptively alert financial institutions: We’re seeing trends here. Look at these IP addresses, or look at this activity and flag it pre-emptively before harm may befall a consumer. That is a very valuable benefit of consumer-driven banking. The framework that the government has put forward here would enable that outcome if we get this right and if execution follows the way we hope that it does.
Senator C. Deacon: Thank you. Mr. Graham?
Mr. Graham: Thank you, senator.
I would echo that theme for sure. To my mind, one of the key sets of use cases for consumer-driven banking is fraud prevention. It’s giving consumers the enhanced ability to prove who they say they are and prove who they’re interacting with in a way that’s much more difficult to do in our present system.
We hear day in and day out from both the banks we work with, from small fintechs and medium-sized fintech companies, that fraud is one of the real scourges of the banking system today. We need to get away from the world of screen scraping into one where we have a more secure system where fraud prevention is made easier through consumer-driven banking using modern APIs, et cetera.
Ms. Vega: I agree with what my colleagues have said. I would just add that trust is really the business of the financial sector. For a fintech, earning that trust and keeping it is arguably even harder and more important for a fintech to preserve than an established incumbent.
One of the added benefits of having more entrants in the system and more challenger organizations as part of the open banking regime means you have actors that have access to more modern technologies and are unconstrained by legacy systems that banks have to contend with. So that real-time response, the ability to detect fraud and to have a more holistic and more transparent view of the whole ecosystem, that will assist in fraud prevention, not the other way around.
Senator Loffreda: Thank you for being here. We were in chambers, so I’m sorry for being late. I’ve got a few questions, but one thing is Fintechs Canada has long advocated for a competitive, innovation-driven financial ecosystem. From your perspective, does Bill C-15 represent meaningful progress toward a truly open, competitive, consumer-driven finance framework or does it fall short in some key areas? We always talk about Canada’s lack of competition. Many feel there is a lack of competition in the financial industry, even though in many areas there isn’t, but we could all benefit from more competition. So what’s your impression and take on this bill? Where are the gaps that we can address, if any?
Ms. Vega: Well, the short answer is yes, it definitely leads to a more competitive financial services sector in many different areas. At least in our world, open banking is for sure the top layer that I would stack on that. The fact that it will give Canadian consumers and small businesses the agency for them to shop around for products, it will force incumbents and new entrants to just work harder for Canadians’ business.
As I mentioned in my opening remarks, access to capital has been a big issue in this country, both for individuals, but also for small companies that have a very small pool of lenders to go to and that really has knock-on effects on productivity, on company growth and scalability. Open banking will help play a part not only in opening the competition within the scope of the financial services industry, but also empower smaller businesses to have greater agency over how they shop around for capital to invest.
Yes, I do think that this bill sets us up for a significant step forward in terms of competition in our space.
Mr. Graham: I would echo that. The financial system, as you note, senator, would benefit from more competition. Open banking is a very powerful way to do that. It allows consumers to bring their data with them in a secure way and find new providers. It allows them to shop the market more effectively, finding the lowest rates so that they can save money. So for all those reasons, I’m very supportive of this bill. I think, certainly, a theme today has been that it’s been a long time coming and we hope get it across the line and get it implemented and get it working for Canadians.
The Chair: We want to thank you. It was very informative and at some point we are pretty happy with the development. At least it is Bank of Canada so for us it is something our committee has sought for a long time.
[Translation]
Honourable senators, we are continuing our prestudy of Bill C-15.
I’d like to welcome our last three panellists today. They are all in person with us in Ottawa. We want to thank you, because we know your schedules are very busy. We appreciate your being here.
I’d like to introduce Mark Maybank, Co-founder and Managing Partner at Maverix Private Equity; Jean Desgagné, Chair at Canada Stablecorp Inc.; and Eric Raymond, General Counsel and Head of Business Development at Shakepay.
I understand that you have some opening remarks. We’ll start with you, Mr. Maybank.
[English]
Mark Maybank, Managing Partner, Maverix Private Equity: Honourable senators, thank you for the opportunity to appear.
We are all aware of the threats to our defence and industrial capacity and to our Arctic sovereignty, but Canada’s financial system is under similar sovereign pressure. Recent global trends to expand China’s and the U.S.’s regional sphere of influences, through such initiatives as China’s project M-bridge, the U.S. GENIUS Act, the U.S.’s CLOUD Act and others, have introduced systemic financial risks that Canada cannot afford to ignore.
Our discussion today is not just about stablecoins; rather, it is also about a fundamentally new regionalized financial system.
It was the U.S. Securities and Exchange Commission’s Chair, Paul Atkins, who recently observed that the next step is coming with digital assets and digitization, maybe not even in 10 years, maybe even a lot less time, and I quote, “Maybe a couple of years from now.”
This rapid evolution is driven by digital assets, and already Canadian deposits are flowing into U.S. dollar-backed stablecoins. We estimate that over $10 billion in Canadian dollars has outflowed to date. If even 5% of our deposits migrate to foreign stablecoins, we risk a $675-billion contraction in domestic lending capacity, leading to increased volatility in the Canadian dollar, and diminished demand for Canadian government bonds. These are not theoretical risks; they are present and growing threats to our monetary policy and economic stability.
However, it is not all risks. There is a highly material upside case for Canada. Globally, trust is increasingly scarce, and Canada’s financial and governance systems remain trusted. There is an opportunity for Canada to export this trust and expand the share of global trade conducted in Canadian dollars, which presents a compelling upside for Canada’s economy.
However, to truly address sovereignty concerns in the medium to long term, Canada must build a sovereign Layer-1, or L1 blockchain a Canadian-controlled infrastructure for digital assets and payments. This L1, and any related digital asset legislation, including this proposed stablecoin act, must mandate Canadian domiciliation that all computer processing, transaction data and reserve asset custodianship be physically located in Canada.
Equally urgent is the need for regulatory clarity around tokenized deposits and other tokenized assets, and the role of banks in stablecoin issuance. Tokenized deposits offer efficiency and instant settlement but require clear rules on reserve management, consumer protection and prudential oversight.
In this new world order, there is a real opportunity for Canada to be proactive and export the high levels of trust in our banking and governance systems to a world that is increasing in need of trust.
Thank you.
[Translation]
Jean Desgagné, Chair, Canada Stablecorp Inc.: Mr. Chair, honourable senators, thank you for having me here today.
[English]
It is a pleasure to accept your invitation to appear in front of this committee to talk about the legislative framework on stablecoins.
Canada Stablecorp is the company responsible for QCAD, which is the first compliant stablecoin in Canada.
Stablecoins are a good thing for Canada. They support cheaper, faster payments and financial inclusion. They provide alternatives for the unbanked and the debanked. They support fintech innovation and put competitive pressure on big incumbents. They help protect our sovereignty and the relevance of our dollar, and power the continued digitization and tokenization of capital markets.
We applaud the government for proposing the “stablecoin act,” which we think will be an important driver of uniform national regulation.
Canada is significantly behind other players in this space, and we need to catch up. We urge the government to proceed with appropriate speed in passing this legislation while making sure that the legislation and related regulations are fit for purpose.
I would like to make five suggestions that would improve the effectiveness of this legislation. First, I think we need to address the risk of regulatory conflict and arbitrage that is likely to arise from the three-regulator regime that is evolving under this proposed act. Second, there is a need to ensure that one-to-one reserves are maintained for all stablecoins, regardless of who regulates the issuer. Third, we should consider the usefulness of relaxing the prohibition against stablecoins generating yields or similar types of rewards, as well as a potentially restrictive approach to permissible reserve assets. We, in fact, don’t know what those will be. Fourth, we need to make sure we can ensure competitiveness. The proposed act and the regulation should not be designed to impose more compliance burdens than are necessary, particularly given the three-regulator potential approach, ensuring a level playing field within Canada and with U.S. and other global issuers. Last, the proposed act should explicitly support and protect financial innovation within Canada. The proposed act does a very good job around prudential matters, consumer protection and national security. It isn’t as clear in the language of the proposed act how innovation will be supported in Canada.
I’m happy to take your questions. Thank you.
The Chair: Thank you, Mr. Desgagné.
We are going to Mr. Richmond now.
Eric Richmond, General Counsel and Head of Business Development, Shakepay: Good afternoon, chair and honourable senators. Thank you for the invitation to appear today as part of your examination of Bill C-15, specifically Division 45 of Part 5, which would enact the stablecoin act.
Shakepay is a Canadian crypto trading platform and fintech app based in Montreal founded in 2015. We offer a web and mobile app that allows Canadians to buy, earn and interact with bitcoin as well as a growing suite of financial products and services. Shakepay services over 1.5 million Canadian customers and is exclusive to Canada.
Shakepay takes a proactive approach to regulation. In addition to being licensed as a money-service business with FINTRAC, Shakepay is a member of the Canadian Investment Regulatory Organization, CIRO, and is registered as an investment dealer with the AMF and the securities regulatory authorities in all provinces and territories. We have applied to be registered as a payment service provider with the Bank of Canada under the Retail Payment Activities Act, and we are a member of Payments Canada.
Today, our customers can only transact in U.S.-dominated stablecoins. We would welcome the opportunity to offer Canadian-backed stablecoins to our customers, and to that end, we previously announced an investment in Tetra Digital Group’s stablecoin venture, along with other well-known financial institutions and fintechs. That’s why we are pleased that Bill C-15 advances a legislative framework for stablecoins in Canada. This is an important step to recognizing Canadian-backed stablecoins as payments, not as securities.
As we turn to implementation, Shakepay underscores the need to make sure the framework stays open, proportional and accessible. This will ensure fintechs can help build the next generation of trusted payment rails for Canadians. At Shakepay, we see strong demand from users for low-friction Canadian-dollar-backed stablecoins for everyday transaction. A Canadian stablecoin will offer a faster, cheaper and more efficient way to move money — one that reflects market demands, not outdated systems.
Once again, thank you for having me here today, and I look forward to your questions.
The Chair: It’s our last panel but certainly not the least. It will be a very interesting exchange with all the topics you have raised. We will begin questions, five minutes each.
Senator C. Deacon: Thank you all for being here.
This is a very exciting moment for Canada. We are slow, but we are not as slow as we were in open banking — not anywhere close. This is a good move.
We had Mr. Morrow and Ms. Butler here from the Bank of Canada earlier this afternoon, and they reflected the need for the system to allow for innovation — that we don’t know what payment system might be most effective and in what way.
If you had specific advice to us in terms of how we look at this — just going on your five suggestions, Mr. Desgagné, I would like to hear them, because the impression we got from the Bank of Canada is that they want to allow for innovation and to make sure the system is market focused and allows for safe, secure, rapid and frictionless secure payments.
Could you get specific on the two things I heard — the competitiveness and some of the prohibitions that you want to see relaxed?
Mr. Desgagné: Thank you for the question.
There are a number of spaces I would look at. The first is resolving the regulatory uncertainty that I think all three witnesses have raised. Our stablecoin was qualified under the CSA’s long-form prospectus rules. We don’t believe we’re a security under any stretch of the imagination, but that’s the only framework we have in Canada. To have a stablecoin qualified under that and then qualified under the rules of the proposed act and the regulations that will come is confusing, to say the least, because you’re not sure which regulator is on top. So if you want to promote innovation and risk-taking new products, I think innovators need to know who the regulator is and what set of rules they have to comply with. The worst outcome would be that they have to comply with two sets of rules that might not be consistent in the long term.
That would be my first item.
The second item is that it is important as we craft legislation and focus importantly on national security, consumer protection — those types of things, including prudential regulation — those are very important — but we also have to make sure that those don’t then stifle intelligent, responsible, contained risk taking in new types of products.
I have a long experience with payment systems. I ran the clearing house for Canada and worked in a series of banks. I know these things have to be very robust. There is a lot of stuff that flows through them, but there are ways to build things around the periphery that allow for more risk taking.
Many of our friends in Canada building fintech companies need to have payment-type technologies that are instant, digital and easily available to consumers. They would be more attractive if they offered yields.
Is my time up?
Senator C. Deacon: Yes, I would just love to hear from the other two witnesses, as well.
Mr. Maybank: Briefly, as it relates to innovation, I watched the Bank of Canada’s whole session. It was spot on with the need for innovation and agility of our financial system. The same way our Department of National Defence has been a little bit under-invested in at times, our financial system is similar. A little bit of complacency has set in.
The rate of change is driven by global conflict and preparation for war. The driver of this movement is war.
Keep in mind as we adopt this technology, it’s for war finance. The regional spheres of influence that the world is dividing into is to circumvent Western sanctions on certain other countries who may have certain extraterritorial or perceived extraterritorial ambitions. So we are moving into a world where our traditional anti-money laundering, or AML, in regulatory needs to be innovative to adapt to a world where the technology that’s being proposed was innovated to circumvent the AML and know your customer, or KYC, processes in the first place. We have an emerging of a bit of a Wild West coupled with a complacent tradition finance.
Innovation is spot on. Everyone is going to need to be adaptable and nimble. There is tremendous opportunity for on-ramps and off-ramps and I am going to come back to. We will need soon, ultimately, an L1, not a public blockchain, for us as a sovereign nation to have controls over those exact variables.
Senator C. Deacon: Mr. Richmond, at some point you’re going to have to explain L1 to us on the committee, but we’ll get to that I think.
Mr. Richmond: Two points I want to highlight. One, it is really important not to overregulate this thing. The inaction is actually causing more harm right now than — we’re moving quickly, but if we chose to overregulate and move slowly here, the inaction is causing more harm. Every Canadian dollar that goes into a U.S. dollar stablecoin is pulling basically $5 from the deposit pool in Canada. It is really important that we allow the innovation to happen and don’t overregulate to basically harm the innovation.
The other thing I will mention — Mr. Desgagné brought this up — is I don’t believe we have a jurisdictional issue here; it is more of a definitional issue. If I told you the stablecoins are payments, you would tell me jurisdictionally that obviously goes to the federal government. If the stablecoins are securities, then obviously it goes to the provincial government. So I think we have a definitional problem here. Let’s define what stablecoins are, what makes a fiat-backed stablecoin a fiat-backed stablecoin, and then define what makes a security. My proposal is something that looks more like a money market fund should be regulated by the securities regulators, but something that looks more like a stablecoin or a payment or a fiat-backed stablecoin should be regulated at the federal level.
The Chair: Thank you two for raising that because each time we ask the panel that we have had in the last few days, is it a security or not? Because that makes a difference.
Senator Loffreda: Thank you to our panellists for being here.
Mr. Richmond, you talked about overregulation, not to overregulate. Our financial sector is doing great. I always say it’s not how well we’re doing, it’s how well we could be doing. It comes down to four key elements I’m concerned with: Safety, innovation, global competitiveness and consumer protection.
My question: Does this proposed framework strike the right balance between the safety, innovation and global competitiveness or does it risk slowing down adoption, investment in Canada’s digital asset sector? If I question reserve management and transparency, does the act impose sufficiently clear and enforceable standards of reserve quality, segregation, disclosure and audit? And what is missing to ensure consumers understand the actual risks behind the Canadian-backed stablecoins? Because consumers don’t understand that. We sometimes need to educate consumers on key elements. I could go on with monthly attestations or real-time reporting requirements, would it be feasible for issuers or overly burdensome for future policy if we don’t have it in the current policy?
Last, you talked about the U.S. and for us to be competitive. Do you feel Bill C-15 will create a regulatory environment where small- and mid-sized Canadian fintechs can launch stablecoin-based products competitively or does it just favour incumbents and foreign players? It is difficult to compete with some of those players that have been there for already a long time now.
Mr. Richmond: Thank you for your question, senator. That is a long question so I will try to address most of those parts there.
On the disclosure point, I’ll highlight that point. Education, proper disclosure is incredibly important here. Going to the heart of your question, was this proper regulation, this is great and incredible to see that the government really moved quickly to get this legislative framework out. From really June and July of this year, we were able to get this out and move incredibly quickly.
Some of the things you highlighted around reserves, around capital adequacy, redemption rates, some of those things do need to be fleshed out in the regulations and it is important we do get that right. On balance, we did a fairly good job here.
Some of the areas that do need improvement are some of the things I previously mentioned, highlighting who has oversight here, ensuring we don’t have duplicative regulatory regimes overseeing this, ensuring the federal government and not the securities regulators and provincial governments have duplicative regulatory regimes over this. That’s one big thing.
Definitions, as I mentioned, properly defining what is a stablecoin, and what is not a stablecoin, under this act is incredibly important. The last thing — we mentioned this earlier — it is incredibly important that we remove the prohibition on yields. If we were to provide true value for Canadian dollar stablecoin, it’s the ability to provide yield. If at the end of the day, the assets that are backing the stablecoin are in high liquid reserve assets and that’s properly being overseen by the Bank of Canada, I don’t see why that yield should not be provided to Canadians. Really, the companies that then are reaping the benefits of it are just the stablecoin issuers, and I don’t see why that shouldn’t go to the Canadians who actually are using and holding the stablecoin.
Senator Loffreda: Thank you.
Senator Ringuette: Thank you for being here. Mr. Richmond, first question is for you. I went through all the definitions in section 35, and I don’t see any relation to security really. The only place that you find the security is in regard to government authority which includes the Royal Canadian Mounted Police, communications security establishment and the Canadian Security Intelligence Service. Where is the “no” zone in here that you keep referring to?
Mr. Richmond: The current framework in Canada — some of the other witnesses on the panel here can speak to that — is one that has been put forth by the Canadian securities administrators, where you basically need to file a prospectus to issue a stablecoin. That is the current framework, the way to get regulated as a stablecoin today. As a platform like Shakepay for us to list a stablecoin, we have to ensure that it meets those requirements in the staff notices that the securities regulators provided.
There are a few carve outs about securities from some of the federal acts in the proposed stablecoin act, which is great to see, but clarity needs to be provided in the act to ensure a fiat-backed stablecoin is governed at the federal level as a payment and something that looks more like a money market is regulated at the provincial level —
Senator Ringuette: Can you send us what should be the reading of the law according to you in regard to section 45?
Mr. Richmond: Yes.
Senator Ringuette: Okay. We’ve got a deal.
The second question is to Mr. Maybank. I’m quite intrigued by you introducing a kind of war measure in your presentation and your comments. Could you elaborate, please.
Mr. Maybank: When drafting and interpreting and reviewing legislation, it’s important to understand the macro drivers that are giving rise to the legislation. Stablecoins is not a new technology. It has been around for a dozen-plus years, so why now? Why did the PMO and the Ministry of Finance move in a couple short months to put this stablecoin act together? What are the pressures driving it and what are the underlying forces?
What I wanted to bring to the attention of the committee today was these forces so that it can assess this legislation in the context. There is a form of attack, nation/state-style attack through foreign entities on our monetary policy. Right now, almost the entire stablecoin market is U.S.-dollar denominated. That is on purpose — sorry, within our sphere of influence, it is almost entirely U.S.-dollar denominated. In another sphere of influence, it is all renminbi, or RMB, denominated. So let’s be clear.
You’re seeing increased dollarization. The last I saw was Türkiye at 58% U.S. dollar dollarization, heavy-driven stablecoin. Argentina is way up. Canada has a much tighter perimeter around it with a stronger dollar and a stronger economy, but it’s important that this legislation be viewed in that context of a form of attack or to undermine our system in the same way that other aspects of our sovereignty are also under challenge.
Senator Ringuette: You’re talking about financial/economic security?
Mr. Maybank: Yes, this is a form of cyberattack, a form of weaponization of financial systems. I would love for that lens to be used as this gets interpreted.
I have circulated materials, which I’m sure would have overwhelmed the translators. There are about 40 pages. In it I include a detailed comparison of regulatory frameworks from Switzerland, South Korea, Singapore, Japan, Hong Kong, the U.K., the European Union and the U.S. I’m sure the level of detail is high, and the interpreters will be spending time. If someone were to ask me to make sure that it was provided, I would make sure that it was provided.
Senator Ringuette: Thank you, sir.
The Chair: Thank you. We expect to receive — okay, thank you.
Senator Fridhandler: I agree that there’s an issue on this question of hybrid jurisdiction. I would also suggest that you acceded to the securities regulator, simply because there was a void, and you weren’t going to say, “You have no jurisdiction; we are going to sell stablecoin.” It’s a federal jurisdiction under banking.
I think we all have to stop using the old concept, because we have something new here. Stablecoin is stablecoin. It’s not necessarily a security, and it’s not necessarily a currency. It is stablecoin, and it will have its own legal properties at the end of the day.
I hope it’s federal and that we have a unitary system that makes it easier for everybody. Maybe I’ll let you comment on that.
Mr. Desgagné: Absolutely. You have my vote.
Mr. Maybank: Spot on.
Senator Ringuette: We’re unelected.
Senator Fridhandler: Secondly, Mr. Maybank, I want to go to a comment of yours about Canadianization of data sovereignty. I think it’s part of your war policy.
We’ve talked a lot about keeping data in Canada, because, otherwise, regulatorily, there is no control over it. The courts have no control over it. We as a country have no control over it if it’s placed someplace else.
Microsoft announced this morning a major project, apparently, that will Canadianize the ability for data. I agree with you on that. I don’t know what your colleagues think about where this data should reside.
Mr. Maybank: My colleagues and I believe strongly in what I’ll call this concept of Canadian domiciliation and Canadian residency, that all computer processing transaction data and reserve custodianship be physically located in Canada. That is one piece that should be put in this act that is not.
As it relates to Microsoft, I would just encourage everyone to read in detail the U.S. CLOUD Act as they read that announcement at the same time.
Senator Fridhandler: I have a last question on reserves. When I read the act, if people buy from the issuer — stablecoin for dollars in my naive understanding of this — then you have to place the dollars with the custodian, and you can’t do anything with it.
This can’t be placed with some deposit instrument? When you’re talking about yield, Mr. Desgagné, I don’t know if you’re talking yield on the reserves that you have or, ultimately, yield to the stablecoin holders. I think you were talking about stablecoin, but you had to generate something to get that yield. Yet the money is sitting inert in a reserve fund.
I don’t know what’s going to happen.
Mr. Desgagné: The act isn’t as explicit about what the components of the reserves can be. The GENIUS Act in the U.S., by comparison, is very explicit. It’s tiers of assets.
To the extent that the reserves are parked in cash, they’re not going to yield returns, but we expect the ability to invest in high-quality, short-term securities that wouldn’t generate price risk — things like Treasury Bills, or T-Bills.
The idea is that the reserves generate a return for the issuer, and what I’m talking about is that the owner of the stablecoin should also be able to participate in some form of yield or return. If I put a dollar in the bank in a savings account, they pay me some interest — not a lot — but they pay me some. If I hold a stablecoin, I should probably get some reward as well, and that will facilitate a lot of other fintech applications that depend on that kind of transformation.
Senator Fridhandler: What about creditor risk? There are a lot of concerns in here, and the act does address it, but I think that’s where there’s a jurisdiction issue. They can talk about the Bankruptcy and Insolvency Act, but they can’t really talk about provincial insolvencies on receivership. We have a bit of a hole there.
What are your thoughts on the insolvency issue around this?
Mr. Richmond: Yes, I think that’s right. I was listening yesterday to the Ontario Securities Commission, or OSC, on the panel. I agree.
From a provincial perspective, there’s a little bit of work to be done from a bankruptcy remote perspective ensuring these things aren’t bankruptcy remote, so it’s definitely great to think there’s some harmonization that is required, both at the federal level and provincial level on the bankruptcy side.
The Chair: Here we are. The provinces are back in the discussion.
Senator Wallin: Yes, we are back on that, because we’ve been having this discussion whether it’s the Bank of Canada or whether it’s the provincial securities regulators.
Mr. Richmond, you raised this. What is it?
Mr. Richmond: Where should this stay?
Senator Wallin: Where do you think it is? Which is the confusion? You talked about how it’s almost like filing a prospectus.
Mr. Richmond: I mean, it should not be filing a prospectus, to be clear.
Unfortunately, the Canadian Securities Administrators, or CSA, introduced an interim framework. That’s what they called it back in 2024, an interim framework for how we regulate stablecoins in Canada. I think at the time they called it value-referenced crypto assets.
With the proposed stablecoin act, it needs to be made clear that if something meets the definition of a stablecoin — and what, colloquially, we in this room are calling a stablecoin — it should be at the federal level. It should not be at the provincial and securities commission level, because it acts more as a payment.
Senator Wallin: You’re happy with the Bank of Canada being that —
Mr. Richmond: I think that makes sense. The Bank of Canada does have the expertise internally. They did a large project on the central bank digital currency, or CBDC, front as well, so I do think that’s the right place for that.
The one thing that I think is missing is that this does carve out the banks, and I think more guidance needs to be provided by the Office of the Superintendent of Financial Institutions, or OSFI, on how banks can issue stablecoins and how banks can also support stablecoins, because the guidance that the banks have received so far has been extremely prohibitive for them to, actually, be able to support some of these stablecoins.
I think some work is needed there.
Senator Wallin: Go ahead, Mr. Maybank.
Mr. Maybank: Senator, you’ve identified a gap in the legislation that’s important.
Just as I mentioned that the custody of the reserves needs to be in Canada, the act is insufficient in detailing the exact requirements of custody. On one hand, the act says caveat emptor, buyer’s risk, uninsured, all your problem, and at the same time, as my colleagues are promoting the Bank of Canada for regulatory oversight, there’s a gap in the disclosure.
The securities commissions were requiring disclosure of how those reserves are invested and where they are invested, so that Senator Fridhandler’s issue on counterparty risk can be addressed.
The act is insufficient in detailing the reserve needs. It should be Canadian. There should be a minimum counterparty or credit rating on the institution. It needs to be subject to certain levels of oversight. There needs to be minimum investments, not dissimilar to the way the U.S. GENIUS Act has. Only then can buyers, under caveat emptor, know what they’re actually buying.
In the shift from provincial to federal, we have a very large disclosure shift, a transparency risk that I would not want to see borne by consumers under the act’s current caveat emptor.
Senator Wallin: I want to hear from Mr. Desgagné as well, but just on the question of you want the reserves to be Canadian only, yet I think it was you that said there was $10 billion in outflows to the U.S., because people are looking for money and stability there.
Do we have enough to provide the backstop, to provide the willingness?
Mr. Maybank: Yes. There are a handful of things. One thing this act does not contemplate is blocking Canadian issuers from issuing foreign-backed stablecoins.
In the materials that are circulated out to everybody, you will see roughly half of our global peers and allies prohibit foreign stablecoins from being issued in their market, meaning that they’ve created a significant home market bias to their home currency, where this act does not contemplate that.
Senator Wallin: That’s very important.
Mr. Desgagné?
Mr. Desgagné: Just on the securities risk, we support the Bank of Canada as the regulator. We went down the path of least resistance, to your point, in terms of the securities regulators.
The other aspect here are the banks who have been carved out of this legislation completely and who may or may not be able to issue stablecoins. They may or may not look like these stablecoins. They can issue digital deposit receipts that don’t look like stablecoins, but consumers may be confused.
That matters from a consumer protection perspective. If you read my prospectus, there are 15 pages of risk factors. I don’t encourage you to read it. And our consumers won’t.
But on a very bad day in Canada — hopefully we don’t have one — a stablecoin that is backed by our reserves will still be worth a dollar. A stablecoin that is issued by a bank that is not fully reserved — and we don’t know if they can do that because OSFI hasn’t said — or is issued as a digital deposit receipt that a consumer thinks is actually like a stablecoin is only as good as the fractional reserves that the bank has to back that liability as well as all their other liabilities.
For those sorts of consumer protection and macroprudential reasons, we think it’s really important, to Mr. Richmond’s point, that we need to be very clear about the definition of a stablecoin, and having done that, then it should be regulated under this type of framework federally.
Senator Wallin: Thank you. These are really interesting points.
The Chair: Thank you for asking that question.
Senator Yussuff: Mr. Maybank, I’ll start with you because you were saying something so explicitly that it can’t be missed in regard to data sovereignty, and yet the legislation is so blatantly absent in recognizing that important point. Is it because we’ve been so lax in regard to data sovereignty so far as a nation, not just in this particular sphere but generally in other spheres within the country?
Mr. Maybank: An emphatic, yes.
Senator Yussuff: Now that there’s a heightened awareness given our experience with the Americans, I think it would be critical among your colleagues that this be submitted in writing to us. I appreciate your testimony here today because I think it will help us contextualize our evaluation of the legislation and what we may want to suggest to the minister for consideration in regard to what the House does with this bill.
The second point, you’re raising an issue about — which we’ve never been able to get in this federation we call Canada — the regulatory regime because we have this squabbling over what I call something that somebody thinks is important. Jim Flaherty, when he was alive and finance minister, did try to get to a national regulator system. Everybody and their brother were squabbling over what we shouldn’t do, and we didn’t do anything, and here we are again.
Do you think we can overcome this kind of paralysis we have in the country that on certain things, not only for Canadians, but for the greater good of investors and others that we need some foundation in this country that can give us some certainty? In the federal jurisdiction, the regulatory regime seems to make sense. By the way, we came out of a major financial crisis without major damage to our banking system. This says something about the regulator system, anyway.
Mr. Maybank: A multi-part answer, and thank you, senator, for the question. Firstly, you’re speaking to what I call the six-person problem. Canada is only ever this right six people away from being in a room and agreeing on it to have something advance. It is usually one person dissenting, but if you get the right six people, things can move fast.
Secondly, in the short term, Canada is learning how to be nimble. It’s using muscles in different government departments that it hasn’t used in decades. I do believe that Canadians are bound by a huge amount of what I’ll call latent patriotism. They’re hugely and fiercely patriotic. They want what’s best for the country, and that will surface in the medium term. I’m incredibly optimistic. I think the leadership from the PMO and the Privy Council Office on the proposed stablecoin act has been phenomenal. They’ve done it in a couple of months. I want this committee to understand that this should be viewed as the thin edge of the wedge, and there should be an entire financial system transformation behind it, the same way our defence and industrial capacity are under similar transformation.
Senator Yussuff: The larger challenge we face here is how to build consumer confidence. If they don’t necessarily have confidence in the system, they’re not going to. We are in infancy in terms of promoting this and getting buy-in across the country. How would you recommend to build that consumer confidence in the context that people will have confidence that if they’re investing in stablecoin, they don’t have to worry when they wake up tomorrow morning that the floor from whatever their savings might have disappeared and they’re going to be in a very different place? We’ve seen this in other jurisdictions, but I’m talking about here in Canada.
Mr. Maybank: Consumers right now have a very high level of confidence in the banking system. They don’t have the same pain points, let’s say, in Brazil with a 30-day settlement. Our overnight Automated Clearing Settlement System, or ACSS, and Brazil’s prior to Pix was 30 days. You had much lower confidence, so the adoption of digital created a massive delta. Our ACSS is very cheap and very reliable. It’s overnight. The Real-Time Rail, or RTR, will be launched next year. We can talk about an L1 and how it’s complementary if the committee chooses to go down that path.
But Canadians aren’t devoid of trust in their payment and financial systems today. You’re asking a question about how the market is going to evolve effectively, essentially is your question. I believe that the consumer adoption of stablecoin will be slow and limited. The material opportunity for stablecoin is in the higher-dollar B2B transactions as opposed to retail over time. That’s my personal view. It may differ from my fellow witnesses. But consumer confidence is not at a low.
Mr. Desgagné: I don’t disagree with those comments. I would add that one of the benefits of something like a stablecoin, particularly when married to fintech applications, is that it operates in the background. It really becomes an empowering tool to allow other things to happen. So you think about a retail version of foreign exchange transactions, where we are partnered with Circle, which is a large global provider, eight currencies. The idea that you could do foreign exchange, or FX, payments on your phone using stablecoins — you wouldn’t know you’re using them because they’re in the background. There are a whole bunch of applications like this that can power retail adoption, but it wouldn’t be people going out and saying, “I want to buy a stablecoin today.” I think it’s much more as a tool, a payments mechanism, to make other things possible.
Mr. Richmond: I would agree with that. I think B2B payments are the obvious first area where you will see the most drastic improvement. It will help alleviate a lot of the struggles that small- and medium-sized businesses have in terms of payment times and costs to transactions. Yes, we have the Real-Time Rails, but Real-Time Rails is still going to take some time to fully roll out. So I completely agree. I think retail will eventually probably come, but not initially.
Mr. Desgagné: There’s a tiny other business case around the unbanked. This provides an opportunity for them to make payments outside of this.
The Chair: Thank you. I just want to highlight the witnesses congratulated the PMO for moving fast on the stablecoin. The Senate is moving fast as well. We are already 13 hours, this committee, and ahead of us are Commons who have not studied in committee yet. So just to —
Mr. Maybank: I stand corrected, and I would like to redo my earlier comment to thank the Senate, the PMO and the Privy Council Office.
The Chair: Okay. Thank you. We have champions with Senator Colin Deacon around the table.
Senator Dalphond: You seem to say that because we’re talking about stablecoins, it should be federal, and with stablecoin, you need securities, but I look at the drafting of the bill, and I think the federal government doesn’t go as far as you’re going. With regard to its application, it says:
This Act applies only in respect of stablecoin that has or could reasonably be expected to have interprovincial or international applications.
So they attach it to the notion of interprovincial and international trade and commerce. They don’t attach it as payment or as money.
In part of the consultation, was that discussed? I know it’s very narrow.
Mr. Desgagné: There’s always a danger in asking an accountant a legal question. My understanding —
Senator Dalphond: I’m the only one that wrote an opinion on — same thing on the national security commission. I’m the only one in Canada who wrote it, so I understand your concern.
Mr. Desgagné: I think it would be incredible if it was very explicitly called a payment mechanism, whatever the right legal word is. My understanding is that language is to anchor this in the interprovincial trade part of the Constitution as opposed to the delegation of responsibilities around securities.
To use Mr. Richmond’s point, a very clear definition of what a stablecoin is tied to a payments mechanism would very clearly take it out of the securities realm. If this is a security, then so is my Canadian Tire money and my $50 Amazon gift card. That would be very helpful.
Mr. Richmond: If I could add one thing, I think it’s important that anything that falls under the stablecoin act is called a stablecoin. Anything that’s not under the stablecoin act is not called a stablecoin. That’s why I do think there needs to be harmonization —
Senator Dalphond: That’s not what it says now.
Mr. Richmond: I know it’s not what it says now. I think that’s really important, because it goes back to the education point we were talking about. If you start talking about, “This is a stablecoin, that’s a stablecoin,” people will get confused, and you’re going to end up having issues. I think that’s important.
Going back to when OSFI does come up with something around stablecoins for banks, it’s important that it’s uniform with what’s in the stablecoin act. And so they call a stablecoin a stablecoin, similar to what has been described in the act.
Senator Dalphond: Under the exception which is called — in respect of a closed-loop stablecoin. So that type of stablecoin will also be excluded?
Mr. Richmond: A closed-loop stablecoin is issued on a private blockchain. It’s usually internal to a business, so that is explicitly excluded. I don’t necessarily see a problem with that. I don’t know if the other witnesses feel differently.
Mr. Desgagné: An example of that would be a company with many subsidiaries that wants to move money around seamlessly internally outside of the banking system. They could do that with stablecoin.
The Chair: I think my challenge over the weekend will be to explain to my mother-in-law in plain English what a stablecoin is.
Senator C. Deacon: Again, thank you. The testimony has been fabulous.
L1 blockchain is going to be a transformation to the underpinnings of our financial system. In order for Canada to fulfill the vision that you’ve put forward — which I think is a really important vision — that we have a stablecoin that is a trusted leader and globally competitive, it doesn’t just aim to be the same level of usefulness as our currency. We’re sixth in the world with our fiscal fiat currency. We’ve really become a trusted provider. Right now, we’re sharing 0.1% of the global market in Canada. It’s some small number.
Mr. Maybank: Canadian dollar denominated trade is about 6% of global volume, and with a trusted dominant Canadian stablecoin, we can double that, representing about $575 billion of value if we use a 5:1 or a 6:1 ratio on that for underlying reserves. It implies about $100 billion of Canadian treasury purchase in assets.
Senator C. Deacon: It’s crucial to financing our future.
Mr. Maybank: Correct. It reduces volatility.
Senator C. Deacon: Achieving that end, we have to get rid of the prohibition on yield — these are the things we’ve heard — that we have Canadian jurisdiction or domicility in terms of the whole tech chain and OSFI to facilitate bank involvement and enable the markets to drive what is popular. We heard that from the Bank of Canada. We asked where Real-Time Rail fits into this, and they said: We’ll let the market decide. I think Real-Time Rail has been usurped entirely by this.
This is where I think we could get some very specific advice, maybe in writing, after the meeting in terms of the pieces you feel are central to Canada achieving that vision of not just having a stablecoin, but having a world-leading stablecoin as part of our monetary backbone.
Mr. Maybank: I’d love to take the first crack at that.
One, in the materials under translation, pages 10 through 12, I outline what a sovereign Layer-1 blockchain is versus a public blockchain, which is what today’s stablecoins would run on. It makes the case for why sovereignty is necessary. Quickly for the panel, our expert calls in with different members of Western Europe and NATO nations, and 100% of them are all considering their own sovereign L1.
Second, I would like to also say in those materials, I outline stablecoin versus tokenized deposits. I believe the Canadian market is configured much better for a tokenized deposit solution as opposed to stablecoin, certainly at the retail and consumer levels. That’s my personal view.
What does it take? Leadership, agility, 12 to 24 months and concerted focus at the regulatory level. I do believe that this intellectual property, once developed, can be sold or licensed to other nations who will buy it from Canada on a trusted basis. There is an export opportunity for Canadian leadership. I do think there is a NATO opportunity for leadership on this as well.
This is not a pure financial system. This has to be viewed within the confines of wiring our allies together. It is regional spheres of influence and financial systems that we’re evolving into. We have tremendous ties with our American friends, but there is also an element of needing to have a hedge. We need to be able to go both ways, and we can’t usurp our sovereignty in all regards.
I will point out that in the recent 2025 strategy document put out by the U.S., they do comment explicitly that they will be looking to export their technology and their standards into their allied group. Canada should expect pressure in that regard. If we move first, if we have an L1, if we are already on it and working on it, it’s way harder for someone to push something else into that white space. Enough said.
Senator Loffreda: As we know, Division 45 now proposes Canada’s first formal regulatory regime in this sector. The challenge is always striking the right balance between innovation and overregulation.
What is the single-greatest risk that over-regulation in Division 45 could pose to Canada’s fintech and crypto ecosystem? Conversely, what is the greatest risk of underregulation? Obviously, we want to get it perfect, but what are the risks of not striking the right balance? This is to any of our panellists.
Mr. Richmond: In terms of the over-regulation portion of your question, at the end of the day, we will lose our sovereignty. You’ve heard that on this panel. You’ve heard Mr. Maybank and his remarks on how important it is to get a Canadian stablecoin right. That is what will happen. We will lose deposits to the U.S.
There is currently $46 trillion in transactions on stablecoins in 2025. That’s three times the number of transactions compared to Visa. Now, a lot of that is crypto on chain, but the payment side of the equation is growing exponentially, but 99.9% of those transactions are in U.S.-dollar-denominated stablecoins.
These are Canadians who are holding U.S.-dollar stablecoins, which are essentially buying U.S. T-bills. So you’re losing a lot of that money from the Canadian deposit pool, and that number just continues to grow year over year.
The over-regulation ends up being you won’t see innovators innovating in this space, you won’t see Canadian dollar stablecoins coming out to market that meet a lot of the requirements we’ve been discussing here, and you’ll essentially lose a lot of your sovereignty.
In terms of underregulation, I think simply, you could have a bank run. If it’s not held in true liquid assets and there are people trying to claim back their assets, you could see a problem. That is obviously a balancing act that we need to consider.
Mr. Maybank: I would agree with that. There is one thing I would comment.
One risk of under-regulation is further enhancement of snow-washing. For those on the committee, that is money laundering through Canada, which I’m sure the committee is well aware of. Ultimately, under-regulation is a snow-washing and FATF risk.
Senator Loffreda: Thank you for that.
Senator Fridhandler: We’ve talked about the federal regulatory structure. We haven’t expressly mentioned it, but I think the Bank of Canada being the player here actually brings their goodwill and confidence into the system, not to say the securities regulators don’t have a good reputation and much improved these days compared to the Bre-X and the Wild West days we used to have.
I want to understand your business model. I saw some numbers on what you get per trade. How does anybody other than running something in their basement make a business out of this?
The other thing I’d point out, in section 53 of the act, it says the issuers will be assessed by the Bank of Canada and a portion of the total amount of expenses that the bank incurs in operating this system. Tell me how this all works to make a business case out of it.
Mr. Desgagné: Let me take a stab at that and maybe work backwards.
I’ve been regulated by the Bank of Canada and other businesses. Like many regulators, they charge the regulatees for the privilege of being regulated. If the Bank of Canada is going to incur the $10 million that’s being kicked around in the bill, they’re going to incur $10 million in charges, and they need to find a place to charge that. That becomes an expense for us. The stablecoin issuers earn the yield on the reserves that they’ve invested.
Senator Fridhandler: But you want to give it up.
Mr. Desgagné: We can give some of it up. They pay sponsors, exchanges, crypto asset trading platforms, or CTPs, that list them, et cetera. There are a whole bunch of expenses. At the end of the day, the trick is that the earnings you make on the reserves exceed the outlays. You try to do that while not taking price risk on the reserves and those types of things because you need to make sure that you have a dollar available when someone comes to get the dollar. That’s a different business model than the bank issuing a digital bank deposit that can incorporate the broader deposit regime and not having to worry about reserves and generating bigger yields on those reserves because the stablecoin standalone company has a different model.
That’s the business model. The large U.S. providers, who obviously have way more scale than we do, have demonstrated that it works. The hope is that as we grow in Canada, we demonstrate that it works here as well.
Mr. Maybank: There is an alternative business model and that is stablecoins in the on-ramps and off-ramps, and facilitate in all transactions around are still under patent in Canada until 2034-35. All existing players, including the globals, are offside on those Canadian patents. They may have rights in the U.S. or in other markets, but they do not own the rights in Canada. So every single player, probably including my co-witnesses here, would be offside on those patents. Those haven’t yet been brought to bear in terms of shaping this market, but there is a business model around there, to answer your question.
The Chair: I want to highlight to our witnesses that during the panel, the sponsor of the bill at the Senate has joined us, Honourable Senator Pupatello, former minister in Ontario with a different portfolio. Welcome. Thank you very much for joining us today despite the weather outside. I know you have a very busy agenda, but it was very informative and we appreciate your insight very much. So we will factor in your observations in our report.
Senators, with your permission, we will now adjourn and we will see you tomorrow at 10:30. Thank you.
(The committee adjourned.)