Draft from the article outline in the copy deck. Full text of 1,200 to 1,800 words to follow after owner review and counsel review [LEGAL].
Scope note
Your counsel decides whether you must register. This article covers the operational work each model involves. This is preparation, not legal advice. Registrations, filings and legal opinions are handled by your counsel. [LEGAL]
What the Bank of Canada requires of registered PSPs
Registration, a risk-management and incident-response framework, safeguarding of end-user funds, and an annual report by 31 March. [Bank of Canada links]
What changes under a partner model
Who holds the funds, whose framework applies, and what the partner will ask of you in due diligence and ongoing reporting.
Interac e-Transfer access
Since September 2025, PSPs registered under both the RPAA and with FINTRAC can apply for access to Interac e-Transfer. [Interac link]
Bank access
The documents banks request: end-to-end flow diagrams and a description of safeguarding and reconciliation arrangements. [CBG-A link]
A two-column checklist
Registered PSP compared with operating under a partner, item by item. [OWNER: checklist table; counsel review before publishing]
Sources
[Sources list with links and Last checked dates to be added before publishing]
Related engagement: Regulatory preparation.
Munro Banting advises, designs and builds. Client funds are held and moved only by licensed partners. Munro Banting does not hold, transmit or exchange client funds.
This is preparation, not legal advice. Registrations, filings and legal opinions are handled by your counsel. [LEGAL]