From: Brian J Doyle Sent: January 16, 2019 2:18 PM To: OBBO (FIN) Subject: Feed back on Open Banking Committee Team, Wonderful news that Canada's Department of Fianance is considering adopting Open Banking! Aside from the inpetus this would provide to the technology sector in general and specifically the growth of the Fintech idustry here in Canada, it is quite simply the right thing to do in a country such as ours where the Banking sector is so highly concentrated. I am sometime envious of my start-up competitors located in the UK, in Australia or in Singapore who have all adopted Open Banking. We already work with groups like the World Counsel of Credit Unions (WOCCU) and we support initiative such as CGAP's open api https://www.cgap.org/blog/what-apis-are-digital- financial-services-providers-opening and Sovirin's Self Sovereign Identity (SSI) https://sovrin.org/ innovations which like Open Banking are proving themselves beneficial in providing better more affordable more innovative financial services in so many countries. The concept of Open api https://www.openapis.org/membership/members is not new, pushing financial institutions to adopt it may be and one should distance themselves from financial institutions who may advise your committee that inherent risks are to great to protect their monoploy and profits. When banks are forced to share their api they will also be adding security and stability to the entire Fintech sector. Removing some regulatory risk by adopting Open Banking will help small companies raise venture funding and will essentially force the Banks to partner with start-up where ideas are often the best of breed and most innovative. The result will be not only a healthier Fintech industry but also a stronger more innovative banking sector which will benefit all Canadian and our economy. Precisely because the Canadian banks are so strong and profitable they need a "gentle push" by Federal regulators to force them to explore partnerships and licensing or joint development of financial innovations without which a decade from now we will have totally lost our edge and Canadian consumers and businesses will be using and paying for foreign financial technology services. Products such as Alipay are already encroaching on our shores and the big five and interac with whom we have entered into mutual NDA and shared ideas with are sleeping at the switch. In short an opportunity lost without being internationally competitive by adopting Open Banking. YodoPay, a fourth sector entity which is 50% owned and majority controlled by Ayodo Foundation www.ayodo.org , a Canadian registered not-for-proft which is currently applying for charitable status has in fact been offering a merchant centric mobile payments and money transfer process, which we believe is fully compliant under Canada's most recent PCMLTFA because our service is Account Balance and Velocity of Money limited. That is to say we do not allow more than USD500 or foreign currency equivalent balances on any account nor do we allow more than USD 500 in transactions on any single client account in any 24 hour period. The PCMLTFA stipulates prepaid products are not to exceed CAD 1,000 nor see a velocity greater than CAD 1,000 in a 24 hour period , but we operate an global service to coincide with Ayodo Foundation's mandate to alleviate poverty by enhancing financial inclusion, so use USD criteria. We are targeting and beginning to work with, through the assistance of export Canada, in prime markets where mobile cell penetration is high but bank accounts, credit cards and financial inclusion are all in the low double digits such as India and Myanmar. For struggling start-ups such as our OPEN BANKING would be most welcome and provide wind to our sails. Thanks, One critical area to consider is deregulation of the Cash-in and Cash-out agents. This is essenitally the concept and the principle upon which YodoPay has been built. A prepaid or gift card on a phone where cash is tendered and merchant assume custody of the prepaid cash which then defacto becomes "cloud" money to be routed and used anywhere in the world. CGAP originally assumed that financial inclusion could be enhanced by setting up agents or mini- correspondent banking agents to practice what they were then calling branchless banking. In a decade of service they have learnt that regulations still apply and diminish the worth of such small agents and are crying out for the type of deregulated yet secure and trusted agencies Yodo implements through ther Merchant centric mobile payment system. https://www.cgap.org/blog/its-time-deregulate-agent-cash-incash-out https://www.blakesbusinessclass.com/good-bad-ugly-revised-regulations-pcmltfa/ Brian Doyle, Managing Director Yodo Inc. M: 1-250-634-2059