CPA Payments Strategy Vision 2020
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CPA Payments Strategy
Vision 2020
Canadian Payments Association 2 Executive Summary 12 Glossary of Terms
Association canadienne des paiements 3 CPA Payments Strategy 13 Glossary of Acronyms
February 2010 Vision 2020 Overview 14 Contributors
4 I The Payments Landscape
in 2020
5 II Developing the Strategy
6 III CPA Strategy
CPA Mandate
CPA Vision
CPA Payments Strategy Objectives
CPA Payments Strategy:
Vision 2020Executive 02
Summary
While the payments landscape in Canada has
evolved rapidly over the past ten years, due to
expansive growth in electronic payments and the
increase of payment service providers and new
market entrants, research indicates that the next
ten years will yield a period of even faster changes.
The Canadian Payments Association (CPA) expects Canadian institutions, stakeholders, and international counterparts and a
payments to quickly mature into highly automated and interactive comprehensive consultation program that validated the needs
payments, subject to global trends towards enhanced regulation of the payments industry. Vision 2020 sets a course for the CPA
and oversight that will present challenges to participants, the during a period of dynamic change for Canadian payments that
clearing and settlement processes and systems. is a reflection of the Board of Director’s strategic priorities and
is anchored in five important areas.
Recognizing the trends, in 2008, the CPA embarked on a compre-
hensive exercise to develop a long term strategy for CPA clearing
and settlement systems, that would ensure the CPA framework
for clearing and settlement continues to serve the needs of all
participants and the Canadian public. The development of the
CPA Payments Strategy: Vision 2020 (Vision 2020) was
driven in large part by a research program that engaged memberCPA Payments Strategy 03
Vision 2020 Overview
The CPA will strengthen its ability to best serve
members and stakeholders in delivering its statutory
mandate by focusing on:
1
5 2
4 3
1 Support the Growth of Promoting modern, innovative, safe and sound frameworks that
support the introduction and usage of electronic payments;
Electronic Payments
2 Drive Efficiencies in Driving efficiency for the CPA clearing and settlement systems, CPA
members and payments users by identifying the opportunities to
Payments improve interoperability & straight through processing (STP) capa-
bilities for CPA clearing & settlement systems, and reducing costs;
3 Modernize CPA Legal Modernizing the CPA legal framework (Act, bylaws, and rules)
to reflect and better accommodate new clearing arrangements,
Framework business models, and emerging market participants and payment
products;
4 Enhance CPA Exchange, Enhancing the robustness and resiliency of CPA technology,
networks and applications for clearing and settlement, by devel-
Clearing and Settlement oping and implementing a multi-year technology strategy that
Technology improves clearing and settlement arrangements and accommo-
dates evolving electronic payments;
5 Expand Value-added Enhancing services which promote knowledge and information
sharing to better meet the needs of CPA clearing and settlement
Services system participants and users.I—The Payments 04
Landscape in 2020
Payments experts believe that in the period between 1999 and 2010
global payment volume increased to around 330 billion transactions
per year, with growth spread unevenly across payment types.1 The
highest growth was in electronic payments, which grew globally to
about 85% of all non-cash payments—with consumer use of payment
cards representing the highest increase.
At the same time, cheque volumes decreased by At the same time, the global economy will further
approximately 70% globally. From 1999 through
2
drive efficiencies in both domestic and international
2010, Canadian payment card activity is estimated payments systems. International trade expansion
to have doubled to about 67%, electronic payments and globalization are growing the demands for
are approximately 85% of all non-cash payments international payments and will increase pressure
and cheque volumes are about 37% lower. The3
on traditional international payments models. In
Netherlands have already mandated the virtual response many countries are moving towards the
elimination of cheques, while the United Kingdom adoption of international standards and technol-
(UK) plans to do so in 2018, and countries like ogy to become more integrated and to permit more
Australia have outlined a broad strategy to manage efficient cross-border payments.
this decline.
Further, payments users are expecting develop-
As 2010 begins, the next ten years promise to deliver ments in payments processing to be much more
a rapidly changing payments landscape as increas- responsive to their requirements and demands,
ing standardization and competition is expected particularly for payment messages to carry robust
to advance the commoditization of payments. and standardized remittance information. It is
Payment service providers will continue to grow and expected that end-users and corporate clients will
further develop niche markets within the payments wield increasing levels of market power with finan-
value chain; offering new and innovative payments cial institutions and payment service providers, in 1. TowerGroup, Global
services and solutions. International credit card satisfying their payment needs. Payments: Trends,
Opportunities, and Impact
companies will enter non-credit retail payment mar-
on the Canadian Payments
kets creating payment competition across the full The CPA expects the Canadian payments landscape Industry, February 2008.
spectrum of retail payments. 4 Emerging payments, to evolve over the next ten years towards highly 2. Payments Industry
Environmental Scan 2007—
such as mobile payments are set to grow and could automated payments subject to global trends in
CPA, June 2007.
replace payment cards as the next dominant con- regulation and oversight that will challenge partici- 3. Global Payments: Trends,
sumer payment. Many countries around the world pants, the clearing and settlement arrangements Opportunities and Impact
are addressing the emerging trends with a variety of and the underlying technology. The framework that on the Canadian Payments
Industry—TowerGroup,
oversight responses including government regulation underpins the CPA clearing and settlement systems
February 2008.
and law modernization, standardization of rules to and the CPA as an entity, need to be carefully 4. CPA Competitive Landscape
apply to payment service providers and new market reviewed to ensure each is well positioned to adapt. and Relevancy Position Paper
entrants, and greater consideration given to payment Part I Market Research—CPA,
November 2009.
stakeholders and users.II—Developing the Strategy 05
In 2008 the CPA embarked on a comprehensive
exercise to develop a strategy to ensure that its
framework for clearing and settlement continues
to serve the needs of all participants and the
Canadian public. CPA’s
International
Counterparts
In this regard, benchmarking surveys were conducted the CPA substantiate large segments of the draft
with the CPA’s international counterparts, including version content, determine areas where further Benchmarking surveys were
conducted with the CPA’s
payment organizations in Australia, Ireland, Japan, work is needed, and shape a recalibrated CPA
international counterparts,
Netherlands, South Africa, the United Kingdom (UK), Payments Strategy—Vision 2020. including payment organiza-
and the United States (US). In addition, a needs tions in Australia, Ireland,
Japan, Netherlands, South
assessment survey was conducted with CPA mem- The result is a document that sets out a strategic
Africa, the United Kingdom
bers and strategic planning sessions and committee vision for the CPA, provides a framework for innova- (UK), and the United States
meetings were held with members and stakeholders. tion, and will be responsive to the dynamic payments (US) to develop a strategy
These combined findings served as the basis for landscape and payments industry needs. The CPA’s to serve the needs of all
participants.
defining the CPA’s future direction in its Draft Long strategic vision is to play a leadership role in provid-
Term CPA Payments Strategy—Vision 2020. ing safe and efficient CPA clearing and settlement
systems that meet the current and future payments
Following the public release of the Vision 2020 draft, needs of Canadians. The CPA payments strategy 5. A list of contributing CPA
an extensive consultation program was completed builds on the CPA’s vision and mandate and provides members and organizations
may be found on page 14.
to engage a wide variety of stakeholders and a direction for the progression of payments cleared
validate the CPA’s strategic direction. The consulta- and settled through the Association’s systems.
tion period extended over 100 days and consisted of The CPA payments strategy also aims to reflect the
webinars, written feedback, and town-hall meetings demands of the payments industry and will seek
held across Canada. The consultation was attended to respond to changing industry needs. As such,
by over 240 individuals representing more than 100 the activities planned in pursuit of the overarching
organizations. 5 The CPA received well-informed strategy for the CPA are intended to evolve over time,
feedback that reflected a rich understanding of reflect changing market realities, and will follow the
payments and international practices. Much of the appropriate CPA project methodology.
feedback acknowledged the challenges facing the
payments industry and the CPA, and sought to pro-
vide suggestions and answers. Taken together, the
consultation program was instrumental in helpingIII—CPA Strategy 06
CPA Mandate CPA Payments Strategy Objectives
Pursuant to the Canadian Payments Act, the The CPA continues to play a vital role in the evolution
mandate of the Association is: of the payments industry and its payments strategy
• To establish and operate national systems for the will establish and articulate a dynamic plan that
clearing and settlement of payments and other aims to:
arrangements for the making or exchange of • Maintain an efficient, modern and accommodating
payments; CPA clearing and settlement system;
• To facilitate the interaction of its clearing and • Promote flexibility, innovation, and growth for CPA
settlement systems and related arrangements payments; and
with other systems or arrangements involved in • Provide CPA clearing and settlement systems that
the exchange, clearing or settlement of payments; enable reliable, secure, safe and sound payments.
• To facilitate the development of new payment
methods and technologies. CPA Payments Strategy: Vision 2020
The CPA will continue its focus on the collaborative
In pursuing its mandate, the Association will development of rules and standards and a national
promote the efficiency, safety and soundness of its approach for safe, sound and efficient clearing and
clearing and settlement systems and will take into settlement systems that best serve CPA members
account the interests of users. and that take into consideration stakeholders’
interests. Relying on the CPA, efficiencies can be
CPA Vision achieved through the coordination and implementa-
The CPA plays a leadership role in providing a safe tion of common standards and processing rules,
and efficient clearing and settlement system to meet leading to system interoperability. In the down-
the current and future payment needs of Canadians. stream markets, payments providers will continue to
aggressively compete for payment users.
The CPA’s payments strategy objectives are
anchored in five key strategic pillars, each
reflective of specific goals and work initiatives.
The execution of the initiatives identified under
each of the following pillars will serve to enhance
the CPA clearing and settlement systems and
the relevance of the CPA.Support the Growth of 07
1 Electronic Payments
The CPA will enable the migration of paper added benefits to users and participants of the CPA
payments to electronic payments in its systems clearing and settlement systems. As such, the CPA
by researching viable payment alternatives, will seek to study unmet payment needs and facili-
exploring opportunities to leverage investments tate the progression of electronic payments. Efforts
in imaging, enhancing the existing electronic will commence with a review to identify barriers to
payments framework, and facilitating new and increasing the use of electronic payments. The CPA
emerging electronic payment instruments in its will seek to adapt the rules and develop supporting
framework. communications aimed at promoting electronic pay-
ments acceptance and usage in Canada.
The migration toward electronic payments presents
a significant opportunity to reduce cost, improve Given the increasing complexities of this industry
processing speed, and enhance payment-related and the emergence of non-traditional players in the
services like fraud detection. This move does, electronic payments space, open collaboration and
however, introduce challenges that must similarly information sharing between financial service provid-
be considered and addressed, such as increasing ers, scheme operators, financial institutions and the
complexities and risks, and the varying needs of CPA will also become an imperative part of the CPA’s
different business segments. However, on balance, facilitation of electronic payments.
the adoption of electronic payments will introduce
ELECTRONIC PAYMENTS SOLUTION PATH
DESCRIPTION
Paper to Electronic Enhancing CPA Facilitation of
Migration Electronic Payments Emerging Payments
Framework
STRATEGIES/ • Undertake a review of barriers to • Develop and implement policy • Develop, as required, the standards
INITIATIVE
increased electronic payment usage frameworks to support the changing and rules framework to support the
and identify opportunities needs related to: clearing and settlement of emerging
• Develop proactive rule frameworks • Point-of-Sale (POS) transactions and innovative payment solutions—
that facilitate electronic payments in face-to-face and remote e.g., mobile payments and EMV Chip
• Identify opportunities that leverage environments card applications
image technology investments of • Electronic Bill Payments
CPA and members Framework
• Research & identify new potential
uses for AFT and EDI paymentsDrive Efficiencies 08
2 in Payments
In conjunction with members and stakeholders, The CPA Member Needs Assessment Survey demon-
the CPA will identify the opportunities to improve strates that STP and interoperability are key industry
straight through processing (STP) capabilities
6
priorities. Stakeholders indicated that their interna-
for CPA clearing and settlement systems, and tional payments needs are not currently being met,
reduce clearing and settlement costs. The CPA as there is considerable complexity, uncertainty, and 6. Provide a framework to
will also monitor international standards, facili- lack of transparency. Members and stakeholders facilitate the capture of
payment and remittance
tate knowledge sharing with its members, and agreed that developing STP could be an important
details to enable members
seek domestic applications where applicable. part of a cheque reduction strategy. to offer more complete
automated processing of
payments reducing the need
Standards for payments messages are significant Similarly, opportunities exist within the CPA to
for processing, keying and/
enablers of innovation, global interoperability,7 enhance and promote the efficiencies of internal or formatting data.
competition, efficiency, processing speed and cost processes and CPA clearing and settlement systems, 7. Provide a common founda-
reduction. As such, the CPA and its members will to contain cost, operational risk and transactional tion of standards to facilitate
efficient sending and receiv-
monitor international efforts and facilitate knowl- inefficiencies. In conjunction with Pillar 4 Enhance
ing of payments.
edge sharing with one another, and where applicable Exchange, Clearing and Settlement Information
stakeholders, to promote the development and align- Technology Systems, an IT system health check will
ment of domestic payments standards with existing be completed and recommendations implemented
international standards. Where a business case is to enhance internal system delivery to members.
realized for domestic applications, the CPA will seek
to facilitate global and domestic interoperability for
its clearing and settlement systems. Standards will
enable improved CPA member interoperability which
may contribute to future interoperable payment
options for end users.
EFFICIENCIES SOLUTION PATH
DESCRIPTION
Explore Efficiencies Integrate With Global
Standards
STRATEGIES/INITIATIVE • Examine the opportunities resulting from the • Map Domestic Standards to Global standards
establishment of enhanced Remittance Data (i.e. CPA standards to ISO 20022, EPN 820)
standards • In partnership with members, participate in
• Identify the opportunities and costs associated international forums to facilitate development
with improving STP capabilities for retail and of standards for international interoperability—
wholesale payments e.g., International Standards Organization (ISO),
• Based on international best practices, identify SWIFT, Global Payments Forum (GPF)
near and long-term opportunities to reduce
clearing and settlement costs and increase pay-
ment velocity—e.g., review ACSS model against
other models (to determine continued relevancy
and effectiveness)Modernize CPA Legal 09
3 Framework
The robustness and flexibility of the with a focus on ensuring the efficiency, select research efforts designed to under-
CPA legal framework 8 and consultative safety, and soundness of CPA clearing and stand and assess the issues of payments
processes will be enhanced in order to settlement systems. Any framework modi- users and alternative oversight models for
address the dynamic payments land- fications will be aligned with all applicable CPA activities. In particular the CPA will
scape and the needs of its users. global and domestic payment regulations leverage research in the areas of regulatory
[e.g. Anti-Money Laundering (AML) and requirements, in order to highlight the regu-
The International Benchmarking research Know Your Customer (KYC) provisions]. latory gaps within the Canadian payments
showed a trend towards increased flexibility landscape; oversight and regulatory models
in clearing arrangements for direct and Stakeholder consultations revealed a employed internationally of comparable
indirect clearers, as well as inclusion of new strong consensus that the rapidly evolv- organizations to the CPA; and stakeholders
market players in rules, regulations, and in ing payments landscape—new players and CPA members to better understand
clearing and settlement systems. For stake- and payment types, emerging technology their evolving needs.
holders, modernizing the CPA’s framework and system functionality and capabilities,
may mean more flexibility in payment pro- increased competition, and a growing Given the Minister of Finance’s review of
cessing arrangements & enhanced trans- number of payments that operate outside Federal Financial Legislation generally
parency in payment processing practices. the CPA’s regulatory framework—requires occurs every five years, the next being
the CPA to investigate ways in which it may 2012, the CPA may seek to identify and
The CPA will modernize its legal frame- make better and more efficient use of its present to the Minister recommendations
work—through the review of its legislation, statutory mandate. In this regard, the CPA for legislative amendments to the Canadian
by-laws and rules—to reflect new clearing will seek to improve its rules development Payments Act—respecting key policy issues,
arrangements and business models, inno- and consultation process. that may include the governance, member-
vative payment products, and to consider ship, and funding of the CPA.
new market participants (e.g. Payment Building on the work already done to date
Service Providers and money service in the development of strategic payments 8. The CPA regulatory
providers). These issues will be reviewed policy, the CPA proposes to undertake framework comprises its
governing Act, by-laws, as
well as rules, guidelines
and standards.
CPA LEGAL FRAMEWORK SOLUTION PATH
DESCRIPTION
Modernize CPA
Legal Framework
STRATEGIES/INITIATIVE • Enhance the risk management framework for • Assess the benefits of implementing more
CPA clearing and settlement systems—review principle-based rules to the CPA, members and
and update current member default model/rules stakeholders
• Update the By-law framework to reflect industry • Enhance business model to accelerate rule
practices and meet member needs— e.g., credit development “speed to market”
union framework • Review and make recommendations on the cur-
• Assess models for participation in the retail rent membership criteria, governance model,
payments clearing system that improve upon compliance framework, and association dues/
its objectivity and transparency—e.g., Direct funding approach under current mandate
Clearer Criteria, Tiering structure
• Identify options to enhance the effectiveness of
CPA public consultative processEnhance Exchange, Clearing 10
4 and Settlement Information
Technology (IT) Systems
The CPA will enhance its current IT systems Based on a comprehensive assessment of the
by developing and implementing a multi-year current CPA exchange, clearing and settlement
technology Strategy that will improve clearing IT systems, the CPA will develop a multi-year
and settlement arrangements and accommodate Technology Strategy, reflecting leading technology
evolving electronic payments. practices, and addressing key issues of CPA IT
systems performance, availability, costs, security,
The CPA IT systems clear and settle on average risks, and reliability. This technology program will be
$173 billion every day and plays a vital role in supported by a clear funding plan to ensure required
Canada’s financial services industry. The CPA will investments are identified, prioritized and moni-
continue to provide secure, highly available and tored. In this regard, investments will be guided by
cost-effective exchange, clearing and settlement IT the strategic priorities of Vision 2020, particularly
systems. Continual and rapid technology advance- in regard to supporting electronic payments and
ments, heightened member and stakeholder expecta- improved processing efficiency.
tions and emerging payment schemes/services are
primary change drivers requiring the CPA to invest in
its critical IT infrastructure. In this dynamic environ-
ment, it is imperative that the CPA IT systems not
only meet existing needs but also have the ability to
appropriately respond to future developments.
EXCHANGE, CLEARING AND SETTLEMENT IT SYSTEMS SOLUTION PATH
DESCRIPTION
Enhancing the CPA’s Exchange, Clearing and
Settlement IT Systems and Applications
STRATEGIES/ • Based on an IT System Health Check, develop • Enhance CPA IT systems safety through the
INITIATIVE
and implement long-term CPA Technology advancement of the information security
Strategy and Plan, including long-term management program
funding plan
• Initiate high-priority IT system projects to meet
changing payments industry needs and busi-
ness requirementsExpand Value-Added 11
5 Services
Given the increasing complexity of payments Similarly, there have been calls to bring together
processes and arrangements and the resulting CPA clearing and settlement system participants to
risk, the CPA will more formally share its openly discuss CPA payments, clearing and settle-
knowledge and expertise with members and ment issues. It is generally recognized by members
stakeholders, and facilitate discussion to and stakeholders that there is not an appropriate
enhance the understanding of CPA clearing forum established to facilitate this dialogue. The CPA
and settlement systems and payments. will seek to develop a leadership role in the industry
and leverage its relationships with financial institu-
There exists an opportunity to enhance the tions, stakeholders, regulators and international
knowledge of market participants and as a result, counterparts to address these unsatisfied needs.
the efficiency of the CPA clearing and settlement
systems. In responding to the needs of the market
and pursuant to its mandate and value proposition,
the CPA will examine the opportunities to facilitate
training and educational forums with member
institutions and stakeholders.
VALUE-ADDED SERVICES SOLUTION PATH
DESCRIPTION
Advance Industry Payments Education/
Dialogue & Debate Training
STRATEGIES/ • CPA will identify issues of common interest to • The CPA will leverage internal expertise and
INITIATIVE
payments system participants and effective competencies to enhance members and
means to broker a constructive industry dia- stakeholder knowledge of CPA payments,
logue— e.g., explore partnerships with stake- rules, clearing and settlement systems
holder groups and payments forums on specific
issues affecting the CPA or its membersGlossary of Terms 12
CPA Legal Framework electronic data interchange (EDI) X12 Retail Payments
Comprises the CPA’s legal objects, 820 standards commonly used for For the purposes of this document,
including its governing Act (the payment files within the U.S. retail payments are mainly consumer
Canadian Payments Act), by-laws, payments or non-urgent payments
rules, guidelines and standards. Financial Legislative Review that are of a relatively low value.
Every five years the Government These payments are not generally
CPA Clearing & of Canada embarks on a review made through the CPA’s Large Value 9. Bank of International
Settlement Systems of financial legislation that has an Transfer System (LVTS). Settlement (BIS), Core
Describes the end to end process of explicit sunset clause. Principles for Systemically
exchange, clearing, and settlement Risk Management Important Payment
Systems, p.9
at the CPA, which includes the Legal Global Interoperability A systematic process that involves
10. Canadian Standards
Framework, IT systems, accompany- Describes a situation in which pay- identifying and assessing risks, evalu-
Association, Risk
ing rules and standards, and any other ment instruments belonging to a given ating risks against the organization’s
Management: Guidelines for
aspects that facilitate or enable CPA payment scheme may be used in other stated risk tolerance, communicating
Decision-Makers—A National
clearing and settlement of payments countries and in systems operated in those risks and developing strategies Standard of Canada (CAN/
for CPA members. separate schemes. Interoperability to prevent any negative event from CSA–Q850–97), 2002;
requires technical compatibility occurring and contain or minimize IRGC, An Introduction to
CPA Exchange, Clearing and between the systems, but can only potential harm, while providing the IRGC Risk Governance
Settlement IT Systems take effect where commercial agree- reasonable assurance regarding the Framework, 2008;
Refers generally to the technology, ments have been concluded between achievement of the CPA’s objectives. 10 Presidential/Congressional
networks and applications that the schemes concerned. Commission on Risk
Assessment and Risk
enable the exchange, clearing and Schemes
Management, 1997;
settlement of payments to be carried Governance A payment scheme is defined as a
Treasury Board of Canada
out as described in the CPA Rules. Payment System Governance payment mechanism that has its own
Secretariat, Integrated
This includes the IT systems of the arrangements may be defined as distinct:
Risk Management
Automated Clearing and Settlement the set of relationships which exist 1) rules, standards, and guidelines Framework, 2001;
System (ACSS), the Large Value between a payment system’s owners, (policies); Committee of Sponsoring
Transfer System (LVTS), and the U.S. governing body, management and 2) requirements for storage and com- Organizations of the
Bulk Exchange (USBE). At members’ other payment system stakeholders. munication of data between partici- Treadway Commission
request, the CPA also supports These arrangements provide the pants (data flow). (COSO), Enterprise Risk
related IT infrastructure for the structure through which a payment Management—Integrated
CPA Services Network (CSN), the system’s overall objectives are set Strategic Framework, 2004; KPMG
LLP, Best Practices in
Financial Institution File (FIF), and and achieved, risk is monitored and The formal pro-active consideration
Risk Management: Private
the Corporate Creditor Identification assessed and how performance is of an organization’s future course or
and Public Sectors
Number (CCIN). optimized. 9 direction.
Internationally, 1999.
EPN STP 820 ISO 20022 Wholesale Payments
This standard was developed by the This is an eXtensible Markup Payments, generally of large
Electronic Payments Network (EPN), Language (XML) schema for the amounts, which are primarily
one of two Automated Clearing House development of financial messages. exchanged between banks or
(ACH) processors in the United The schema is driven by payments financial institutions that require
States. The objective is to standardize industry bodies including SWIFT and urgent and timely settlement.
the use of ten remittance fields the Treasury Workstation Interface
to ease payment file integration. Standards Team (TWIST). ISO 20022
is being adopted as the framework
EPN STP 820 for payments messaging under Single
This standard is approved by the European Payments Area (SEPA) rules
American National Standards Institute throughout Europe, and for the new
(ANSI), and is a derivation of the SWIFT MX message category.Glossary 13
of Acronyms
ACSS Automated Clearing and Settlement System
AFT Automated Funds Transfer
AML Anti-Money Laundering
CPA Canadian Payments Association
EDI Electronic Data Interchange
EMV Europay-Mastercard-Visa
EPN Electronic Payments Network
GPF Global Payments Forum
ISO International Standards Organisation
IT Information Technology
KYC Know-Your-Customer
LVTS Large Value Transfer System
POS Point-of-Sale
STP Straight-Through Processing
SWIFT Society for Worldwide Interbank
Financial Telecommunication
UK United Kingdom
US United StatesContributors 14 The Association is grateful for the participation and submissions it received in developing the CPA Payments Strategy: Vision 2020. The CPA would like to formally acknowledge the contributions of CPA members and stakeholder representatives from 107 organizations. ABN AMRO Bank, N.V., Fédération des Caisses Retail Council of Canada Canada Branch Desjardins du Québec Rogers Wireless ACT Canada Financial Consumer Association Royal Bank of Canada ADP Canada of Canada Safeguard Business Systems Inc. AOC Consulting First Calgary Savings Credit Union Scotia iTRADE ATB Financial Gaz Metro Shaw Finance Bank of America National Global Thermoelectric Inc. Smart Strategies Association, Canada Branch Great West Life Assurance Company Software AG Bank of Canada Groupe Promutuel Fédération State Street Canada Bank of Montreal GWL Realty Advisors Inc. SWIFT Bank of Nova Scotia Hedge Rho Management Inc. Symcor Inc. Bell Canada HSBC Bank Canada TD Bank BNP Paribas (Canada) Hydro Quebec TelPay Inc. Bridgewater Bank ICICI Bank Canada Telus CGA Canada Imperial Oil Ltd. Union Gas Caisse centrale Desjardins Industrielle Alliance UseMyBank Services, Inc. Canadian Bankers Association Industry Canada Van Leeuwen Engineering Limited Canadian Council of ING Direct Canada Vancity Business Banking Grocery Distributors Intact Financial Corporation Ville de Longueuil Canadian Imperial Bank of Commerce Interac Association Visa Canada Canadian Tire Bank Intria Items Inc. VisionCraft Development Corp. Capital One Canada Investors Group Inc. Wawanesa Mutual Central 1 Credit Union Jameson Bank Insurance Company Ceridian Canada Ltd. Laurentian Bank Westminister Savings Credit Union CGI Manulife Bank of Canada Westoba Credit Union Chambre des notaires du Québec Meridian Credit Union York University Chase Paymentech Ministère des Finances du Québec Citibank Canada National Bank of Canada City of Grande Prairie NetSecure Technologies Ltd. City of Surrey Ombudsman for Banking CLHIA Services and Investments Community Natural Foods Ontario Financing Authority Consumers Council of Canada Optimal Payments Credit Union Central of Canada Option consommateurs Credit Union Central of Manitoba Payment Solutions Marketing Cryptolex Trust Systems Peace Hills Trust Company CUPS Payment Services Penn West Energy Davis + Henderson Pitney Bowes Business Insight Department of Finance Canada Planet Payment Duncan Consulting Polish Credit Union EnCana Corporation Province of Manitoba Everlink Payment Services Inc. Public Interest Advocacy Council EWA Canada Public Interest Advocacy Centre Expertus ResMor Trust Company
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