Fintechs Canada, the national not-for-profit association representing the country’s most innovative fiancial services companies, has filed its formal submission to Payments Canada’s consultation on the draft Real-Time Rail (RTR) By-law and Rules.
While welcoming the RTR’s promise of broadened access, resilience, and consumer protection, the association argues that two aspects of the draft framework risk slowing innovation and adding unnecessary operational burden:
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“Competitive Service” is too broadly defined to be useful. The current definition would sweep in virtually any brand label or ancillary feature and force each one through a 45-day registration window. Fintechs Canada warns this could create administrative drag, diffuse accountability, and slow down innovation for start-ups iterating rapidly. The submission recommends limiting the term to entities that actually originate, route, or hold funds, as well as waiving any registration fees to keep new services moving quickly.
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Incident reporting is unreasonable and counterproductive. Requiring participants to phone Payments Canada within five minutes of any Severity 2 type incident would distract first responders from restoring services for end-users and flood Payments Canada with false positives. Fintechs Canada urges aligning the rule with Bank of Canada expectations: report material Severity 2 incidents within 48 hours, and permit electronic channels for incident reporting in addition to phone.
“Canada needs an RTR that is both open and workable,” said Alex Vronces, Executive Director, Fintechs Canada. “These small fixes today will spare participants needless costs tomorrow and ensure consumers feel the benefits of real-time payments sooner.”
The full submission is available here.
