By now, you have likely heard of the Retail Payment Activities Act (RPAA) and associated incoming requirements, which includes the requirement to register with the Bank of Canada (BOC). To help make this a bit easier, Outlier has put together a spreadsheet that will help if you are an organization that needs to register. The RPAA (including registration) generally applies to PSPs that perform any of the following five payment functions:
- the provision or maintenance of a payment account;
- the holding of end-user funds until withdrawn by the end user or transferred to another individual or entity;
- the initiation of a payment at the request of an end user;
- the authorization of an electronic funds transfer, transmission, reception, or facilitation of a payment message; or
- clearing or settlement.
The requirements apply to businesses with payment activities with a place of business in Canada, or those that provide services to end users in Canada. This includes activities that many Money Services Businesses (MSBs) provide. The BOC has provided a tool to determine if an organization must register with the BOC. For organizations that do register, the registration provisions of the RPAA will take place between November 1, 2024 to November 15, 2024. It should be noted that this is different from your MSB registration under AML requirements.
The registration application itself consists of 18 sections and comprises over 200 questions. While a substantial amount of information and data is needed, the majority of information relates to business and corporate information. This includes:
- Ownership structure and financial information;
- Information related to your product services and flow of funds;
- Information related users;
- Value/volumes related to transactions;
- Geographic perimeter; and
- Information related to 3rd party vendors.
It is not a requirement to provide your operational risk management and incident response framework (policy and procedures) as part of the application process.
To help aid in the registration process, we have put together a spreadsheet that will allow you to keep needed data and information organized. It will also allow you to determine if you need assistance with sections of the registration, or understanding what these changes mean to your business. The spreadsheet is a tool to assist with registration and not meant to replace the registration guidance the BOC has published.
Note: requirements that introduce prescribed operational risk management standards under this new regime come into force at a later date on September 8, 2025.
Outlier is here to help, so please get in touch.