Due diligence checklist, Canada

Consumer-Driven Banking Act: what to ask a vendor

Consumer-Driven Banking Act. FCAC. Participants are accredited and share data under the framework's technical and security standards.

A starting point, not legal advice. The regulator's own page: FCAC.

What it is

Participants are accredited and share data under the framework's technical and security standards.

Who it applies to

Applies to every financial institution in Canada, when procuring open banking and cdr, digital banking, payments.

What to ask a vendor, and the evidence to request

#Ask the vendor forEvidence to request
1Accreditation under the framework where the vendor receives shared dataThe accreditation record or sponsor arrangement, with its scope and date, or a written statement that none is held.
2Conformance with the framework's technical standard and security requirementsConformance test results or a written statement of conformance against the standard, with the version supported.

In every case

  • A named contact at the vendor responsible for this regime, and how the vendor tracks changes to it.
  • Which named customers the vendor already serves under this regime, as references you may call.

This checklist is a starting point for a procurement team, not legal advice. Read it with the regulator's own page, your institution's policies and your legal and risk teams; the regime may have changed since the date on this document.

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