The CSA’s ‘Collaboratory’ stated aims of supporting data portability and open banking to help investors reduce costs and promote competition are admirable. Its desire to understand incoming technology and its operational impacts is understandable. The IIAC’s reply:

• Recommends preserving regulatory resources and maximizing efficiency by skipping further consultation and proceeding directly to the proposed sandbox approach for interested firms. Regulatory efficiency can also be maximized by avoiding duplication of efforts addressed through privacy commissions, FINTRAC, and related privacy and anti-money laundering laws.

• Underscores that investors have had rights of access to their personal information for many years. Those rights have become more widely known and accessible through technology and legislative initiatives such as open banking.

• Highlights that among the simplest, most basic, and common means of data portability for investors are account transfers. Seamless, quick transfers enabled through electronic means serve investors – and avoid negative headlines.