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Ron Matthews October 24, 2012 The Payments Landscape 2012 - ???? AFPC - Calgary.

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Presentation on theme: "Ron Matthews October 24, 2012 The Payments Landscape 2012 - ???? AFPC - Calgary."— Presentation transcript:

1 Ron Matthews October 24, 2012 The Payments Landscape ???? AFPC - Calgary

2 Agenda A bit of background Stakeholder Advisory Council SAC priorities The changing environment Questions / discussion A bit of History & Reference Material Banking in Canada Department of Finance Bank of Canada Canadian Payments Association Task Force for the Payments System Review Finance Canada Payments Consultative Committee PWGSC announcement Best Practice for the uniform treatment of wires Code of Conduct for the credit & debit card industry

3 A bit of my background & a correction The correction first: on the web site I was referred to as the Chairman of the Canadian Payments Association – I’m NOT - that position is held by Janet Cosier – but I was the Chair of Stakeholder Advisory Council And now the background: I started in the cash management game in 1974 in Montreal I was the 1st program committee chair of the Toronto Cash Management Society in the late 1970’s I was one of the founding members of TMAC Member of AFP since 1986 Member of the Stakeholder Advisory Council (SAC) to the Canadian Payments Association (CPA) since its inception in 1996 Actively participated on the Task Force for the Payments System Review Acted as Chair of SAC from 1999 until October of this year I retired in June this year BUT I’m still …… AFP’s representative on the SAC until 2014 Ministerial Appointee to the Board of Directors of the CPA – 2001 – 2014 Independent member of Finance Canada Payments Consultative Committee (FinPay)

4 Stakeholder Advisory Council (SAC) The Stakeholder Advisory Council (SAC) was established by the Canadian Payments Association (CPA) in 1996 on a voluntary basis and formalized in the Canadian Payments Act in The SAC provides advice to the CPA Board of Directors on payment, clearing, and settlement matters, and contributes input on proposed initiatives, including by-laws, policy statements, and rules that affect third parties. It also identifies issues that might concern payment system users and third-party service providers, and suggests how they could be addressed. The SAC meets at least three times a year. In addition, SAC representatives serve on the Advisory Committee on CPA Policy and Regulatory Matters and the Conference Program Advisory Committee. Composition The SAC has a maximum of 20 members and is broadly representative of users of the payment system and service providers to it. The General By-law stipulates that a minimum of 12 members represent payments system users, including at least: two representatives of consumers; one representative of the retail sector; two representatives of governments; and one representative of the treasury and cash management sector. A minimum of one member represents service providers to the payments system. Two positions are allocated to CPA Board members to facilitate the exchange of ideas between stakeholders and the Board. The remaining seats are open to either payments system users or service providers.

5 SAC Priorities – 2011/2012/2013 Promotion of Mobile and Digital Payments in Canada EFT Payments Remittance Data Consistent Treatment of Similar Types of Payments Reduction of Cheques in the Payments System in Canada Supporting and promoting financial literacy on payment issues to Canadians In 2012 we replaced this with “promoting financial literacy” In many countries where "chip and PIN" and mobile devices are an integral part of the "payments system" a lead organization is working with government agencies to ensure that security issues are addressed in an effective manner. In Canada we need to evolve a lead organization that works with government agencies to collaboratively identify security requirements and ensures an appropriate standards and certification infrastructure is in place. The CPA is ideally suited to investigate possible implementation options out of scope but ……..

6 Where do we stand Promotion of Mobile and Digital Payments in Canada Discussion has started on the process for rule creation for Mobile ? EFT Payments Remittance Data Projects on Standard 5 & ISO – 2012 / ?? Consistent Treatment of Similar Types of Payments On-us payments – CBA public commitment Reduction of Cheques in the Payments System in Canada Re-write of PAD rules – Sept 2008 / Feb 2010 PWGSC announcement – 2012 / 2016 Supporting and promoting financial literacy on payment issues to Canadians Financial Consumer Agency of Canada (FCAC)

7 The changing environment March 2010 – Budget commitment to review the payments system June the Task Force for the Payments System Review fulfills a Budget 2010 commitment to review the payments system is established Mandate of task force was to review: the safety, soundness and efficiency of the payments system whether there is sufficient innovation in the payments system the competitive landscape whether businesses and consumers are being well served by the payments system, and whether the current payments system oversight remains appropriate August Code of Conduct for the Credit and Debit Card Industry in Canada December the Task Force presented its Final Report, Moving Canada into the Digital Age to the Minister of Finance March the Finance Minister released the final report of the Task Force for the Payments System Review, Moving Canada into the Digital Age The main recommendations of Moving Canada into the Digital Age are that the federal government should lead the following actions: Implement electronic invoicing and payments (EIP) for all government suppliers and benefit recipients. Partner with the private sector to create a mobile ecosystem. Propel the build of a digital identification and authentication (DIA) regime to underpin a modernized payments system and protect Canadians’ privacy. Additionally, the Task Force also calls on the Government of Canada to “overhaul the governance structure of Canada’s payments system”. The Task Force’s recommendations concern both the broader payments system and the CPA.

8 The changing environment (continued) April 11, 2012 – the Government of Canada will increase the use of direct deposit by slowly phasing out federal government cheques by April 2016 June Finance Canada Payments Consultative Committee, or FinPay. Led by the Department of Finance, FinPay will be made up of stakeholders from across the payments industry and user community. Specifically, the Minister announced that: the Government will “review the governance framework for the payments sector, including the Canadian Payments Association, to ensure the continued safety and soundness of the payments system, spur innovation and promote the consideration of user interests.” the creation of “a senior-level advisory committee made up of public and private sector stakeholders. This group will meet regularly with Department of Finance officials to discuss emerging payments system issues.” No details are available on the Minister’s initiative at this time. the Minister also indicated in his press release that the “Department of Finance officials will review, in close consultation with stakeholders, the application of the Code of Conduct for the Credit and Debit Card Industry in Canada to emerging mobile payment products.” September 2012 – Harper Government announces Code of Conduct expansion to cover mobile payments October 9, 2012 – Following collaboration with business and corporate stakeholders, Canada’s financial institutions, led by the Canadian Payments Association (CPA) and the Canadian Bankers Association (CBA), have endorsed a best practice for the treatment of wire payments for their customers.best practice for the treatment of wire payments for their customers. October 16, 2012 – first meeting of FinPay – more to come

9 The changing environment (continued) 2013 and beyond – patience will be a virtue to deal with the issues and costs associated with these recommendations Recommendations regarding the broader payments system are that the government: 1. Define a discrete payments industry and require payments service providers to become members. 2. Create a new public oversight body for the payments industry that will: a) Protect the public interest as broadly defined through a principles-based approach; b) Monitor the implementation of changes to the payments system, ensure that it continues to meet the public interest and propose adjustments where necessary; c) Provide redress, where necessary, when industry behaviour no long inspires trust, or enables access, competition or innovation. 3. Encourage industry to create a broad-based, collaborative, self-governance organization including both providers and users to develop and implement strategy and standards for the payments industry. This entity would be recognized by the public oversight body as a self- governing organization. the safety, soundness and efficiency of the payments system whether there is sufficient innovation in the payments system the competitive landscape whether businesses and consumers are being well served by the payments system, and whether the current payments system oversight remains appropriate

10 Questions ????????? Thank-you!!

11 Banking in Canada Canada is widely considered one of the most efficient and safest banking systems in the world, ranking as the number one soundest banking system for the past three years according to reports by the World Economic Forum. The bank regulator is the Office of the Superintendent of Financial Institutions (OSFI), whose authority stems from the Bank Act. The financial groups are also governed by regulatory bodies (bank regulators, securities regulators, insurance regulators, etc) in each country they operate in. The banking industry includes 22 domestic banks, 26 foreign bank subsidiaries and 23 full-service foreign bank branches and six foreign bank lending branches operating in Canada. In total, these institutions manage close to $3.1 trillion in assets (Source: Office of the Superintendent of Financial Institutions as of December 31, 2010). Schedule I banks are domestic banks and are authorized under the Bank Act to accept deposits, which may be eligible for deposit insurance provided by the Canadian Deposit Insurance Corporation (e.g. The big five plus some smaller entities). There are currently 88 members of CDIC which includes other deposit taking institutions which are not banks. Further co-operatives (i.e. credit unions) accept deposits and are generally insured by provincial deposit insurance schemes. Schedule II banks are foreign bank subsidiaries authorized under the Bank Act to accept deposits, which may be eligible for deposit insurance provided by the Canada Deposit and Insurance Corporation. Foreign bank subsidiaries are controlled by eligible foreign institutions. Schedule III banks are foreign bank branches of foreign institutions that have been authorized under the Bank Act to do banking business in Canada. These branches have certain restrictions.

12 Department of Finance The Department of Finance (Finance Canada) develops policies and provides advice to the Government with the goal of creating a healthy economy for all Canadians. Examples of mandate: Plans and prepares the federal government’s budget Analyzes and designs tax policies Develops regulations for Canada’s banks and other financial institutions Administers the transfer of federal funds to the provinces and territories Develops policies on international finance and helps design our country’s tariff policies Monitors economic and financial developments in Canada and provides policy advice on a wide range of economic issues Source:

13 Bank of Canada The Bank of Canada is Canada’s central bank. They are not a commercial bank and do not offer banking services to the public. They have responsibilities for Canada's monetary policy, bank notes, financial system, and funds management. Their principal role, as defined in the Bank of Canada Act, is "to promote the economic and financial welfare of Canada." Originally founded in 1934 as a privately owned corporation, Bank of Canada became a Crown corporation belonging to the federal government in Since that time, the Minister of Finance has held the entire share capital issued by the Bank. Bank of Canada has an oversight role for the LVTS as a systemically important payment system. The Bank is not a government department and conducts its activities with considerable independence compared with most other federal institutions. For example: The Governor and Senior Deputy Governor are appointed by the Bank's Board of Directors (with the approval of Cabinet), not by the federal government The Deputy Minister of Finance sits on the Board of Directors but has no vote. Bank employees are regulated by the Bank itself, not by federal public service agencies. The Bank's books are audited by external auditors appointed by Cabinet on the recommendation of the Minister of Finance, not by the Auditor General of Canada. Source:

14 Canadian Payments Association (CPA) The Canadian Payments Association (CPA) is a not-for-profit organization that was created by the Canadian Payments Act (CP Act) in The mandate of the CPA is to establish, operate, and maintain systems for the clearing and settlement of payments among member financial institutions on behalf of their clients— individuals, businesses, and governments.. The CPA’s governance framework is set out in the Act. The Minister of Finance makes three appointments to the Board of Directors and the Bank of Canada appoints the chair, while members elect the remaining 12 directors. A 20-person Stakeholder Advisory Council provides advice and input to represent the diverse interests of users of the payment systems. The Bank of Canada and all chartered banks operating in Canada are required to be members of the CPA. Trust and loan companies, credit union centrals, and other deposit-taking institutions have been eligible for membership since the CPA’s inception. Life insurance companies, securities dealers, and qualified corporations on behalf of money market mutual funds have been eligible since Source: 94f2-http://www.cdnpay.ca/imis15/eng/About/eng/About.aspx?hkey=1ef7ae22-a f- 94f2-

15 CPA (con’t) The CPA operates two primary clearing and settlement systems: Automated Clearing Settlement System (ACSS), is mainly for domestic consumer payments of lower value and urgency; (although there is a limit for cheques, there is no stated limit for other transactions other than system limitations); and the Large Value Transfer System (LVTS), is generally for very large or time sensitive payments that cannot be reversed. (Note – there is no minimum amount on LVTS and system is used for both large and low value transactions) In addition, the US Bulk Exchange (USBE) system, a system parallel to the ACSS, is used for clearing payments in US dollars. Settlement of USBE balances is done through banks in New York. The CPA also develops, implements, and updates the rules and standards that govern the clearing and settlement of payments between its members. These rules and the related processes are central to the CPA’s role in promoting the efficiency, safety, and soundness of the clearing and settlement systems. Clearing is the process through which CPA member financial institutions exchange and reconcile payment items made by clients, and includes the calculation of net balances due to or from members prior to settlement. Settlement is the process through which CPA members fulfill their net clearing obligations to other members by transferring funds between accounts held at the Bank of Canada, based on amounts owed to each other as calculated in the clearing process.

16 Task Force for the Payments System Review Federal Government Payments Systems Review Task Force created in June 2010 Mandate of task force was to review: the safety, soundness and efficiency of the payments system whether there is sufficient innovation in the payments system the competitive landscape whether businesses and consumers are being well served by the payments system, and whether the current payments system oversight remains appropriate Task Force recommendations to be submitted at the end of 2011 Changes from recommendations to be determined. The main recommendations of Moving Canada into the Digital Age are that the federal government should lead the following actions: Implement electronic invoicing and payments (EIP) for all government suppliers and benefit recipients. Partner with the private sector to create a mobile ecosystem. Propel the build of a digital identification and authentication (DIA) regime to underpin a modernized payments system and protect Canadians’ privacy. Additionally, the Task Force also calls on the Government of Canada to “overhaul the governance structure of Canada’s payments system”. The Task Force’s recommendations concern both the broader payments system and the CPA.

17 Finance Canada Payments Consultative Committee (FinPay) On March 23, 2102 the Finance Minister released the final report of the Task Force for the Payments System Review, Moving Canada into the Digital Age Specifically, the Minister announced that: the Government will “review the governance framework for the payments sector, including the Canadian Payments Association, to ensure the continued safety and soundness of the payments system, spur innovation and promote the consideration of user interests.” the creation of “a senior-level advisory committee made up of public and private sector stakeholders. This group will meet regularly with Department of Finance officials to discuss emerging payments system issues.” No details are available on the Minister’s initiative at this time. the Minister also indicated in his press release that the “Department of Finance officials will review, in close consultation with stakeholders, the application of the Code of Conduct for the Credit and Debit Card Industry in Canada to emerging mobile payment products.” The main recommendations of Moving Canada into the Digital Age are that the federal government should lead the following actions: Implement electronic invoicing and payments (EIP) for all government suppliers and benefit recipients. Partner with the private sector to create a mobile ecosystem. Propel the build of a digital identification and authentication (DIA) regime to underpin a modernized payments system and protect Canadians’ privacy. Additionally, the Task Force also calls on the Government of Canada to “overhaul the governance structure of Canada’s payments system”. The Task Force’s recommendations concern both the broader payments system and the CPA.

18 Finance Canada Payments Consultative Committee (FinPay) Continued Recommendations regarding the broader payments system are that the government: 1. Define a discrete payments industry and require payments service providers to become members. 2. Create a new public oversight body for the payments industry that will: a) Protect the public interest as broadly defined through a principles-based approach; b) Monitor the implementation of changes to the payments system, ensure that it continues to meet the public interest and propose adjustments where necessary; c) Provide redress, where necessary, when industry behaviour no long inspires trust, or enables access, competition or innovation. 3. Encourage industry to create a broad-based, collaborative, self-governance organization including both providers and users to develop and implement strategy and standards for the payments industry. This entity would be recognized by the public oversight body as a self- governing organization. the safety, soundness and efficiency of the payments system whether there is sufficient innovation in the payments system the competitive landscape whether businesses and consumers are being well served by the payments system, and whether the current payments system oversight remains appropriate The committee is composed of the broad spectrum of users and service providers to payment processing, including but not limited to consumers, small, medium & large businesses, financial institutions The Task Force also calls on the Government of Canada to “overhaul the governance structure of Canada’s payments system”. The Task Force’s recommendations concern both the broader payments system and the CPA.

19 PWGSC “announcement” Government of Canada Increasing the use of Direct Deposit: Security, Reliability and Efficiency GATINEAU, Quebec, April 11, 2012 – The Government of Canada will increase the use of direct deposit by slowly phasing out federal government cheques by April Direct deposit is a secure, reliable and cost efficient way to deliver payments to Canadians. This initiative is expected to save the Canadian government approximately $17.4M per year starting in The cost to produce a cheque is approximately 82¢ while a direct deposit payment costs about 13¢. Cheques will only be issued under exceptional circumstances, for example when Canadians do not have access to a financial institution because they live in a remote location. "Increasing the use of direct deposit will contribute significant savings through the reduction in the use of paper and related cheque-printing and delivery costs." The Receiver General issues over 300 million payments annually, of which close to 77% are already made by direct deposit. Citizens and businesses currently receiving Government of Canada cheques have the next four years to register to receive payments by direct deposit. Enrolment forms can be obtained from the Receiver General web site, or from federal departments responsible for the payment to be received by direct deposit. For any new payment, the first payment method offered will be direct deposit. This government is modernizing the way we do business and saving taxpayer dollars. For more information about the Receiver General and to enroll for direct deposit, please visit:

20 To provide clarity around the treatment of on-us wire payments and address customer expectations, endorsing financial institutions voluntarily agree to treat on-us wire payments in the same manner as LVTS payments. Specifically, the assurances outlined in Canadian Payments Association (CPA) By-law No. 7 – Respecting the Large Value Transfer System regarding timing, finality and errors (subject to anti-money laundering and fraud policies) will be similarly applied by endorsing financial institutions to on-us wire payments. In this regard, similar to LVTS payments, endorsing financial institutions will treat on-us wire transactions as having the following characteristics: Payment irrevocability and finality (once funds have been posted to the payee’s account); Same day credit (on value date indicated and in accordance with the endorsing financial institution’s daily cut-off schedules); and Notice to the beneficiary by its financial institution about funds availability (this could be accomplished by posting to the beneficiary’s account). In addition, endorsing financial institutions will work towards including provisions in their client agreements that are created following endorsement of this best practice confirming the institution’s assurance to treat on-us wire payments in the same manner as LVTS payments, for the elements outlined above. Scope of Best Practice This best practice applies to all domestic, Canadian dollar business and consumer on-us wire payments. Endorsing Financial Institutions Bank of Montreal Bank of Nova Scotia National Bank of Canada CIBC Royal Bank of Canada Toronto Dominion Bank HSBC Citibank Canada Canadian Western Bank Laurentian Bank of Canada President’s Choice Bank Royal Bank of Scotland Mega International Commercial Bank (Canada) JPMorgan Chase Bank, N.A. Bank West Mizuho Corporate Bank, Ltd., Canada Branch State Street Bank and Trust Company – Canada Branch La Caisse central Desjardins du Quebec Best Practice for the Uniform Treatment of Wire Payments

21 Purpose The purpose of the Code is to demonstrate the industry’s commitment to:  Ensuring that merchants are fully aware of the costs associated with accepting credit and debit card payments thereby allowing merchants to reasonably forecast their monthly costs related to accepting such payments.  Providing merchants with increased pricing flexibility to encourage consumers to choose the lowest-cost payment option.  Allowing merchants to freely choose which payment options they will accept. Scope The Code applies to credit and debit card networks, (referred to herein as payment card networks), and their participants (e.g. card issuers and acquirers1). The payment card networks that choose to adopt the Code will abide by the policies outlined below and ensure compliance by their participants. The Code of Conduct will be incorporated, in its entirety, into the payment card networks’ contracts, governing rules and regulations. The Code will apply within 90 days of being adopted by the card networks and their participants. Networks and acquirers will have up to nine months to implement Element 1. Issuers will have up to one year to re-issue cards already in circulation that contravene Element 6 or 7. Requirements for Payment Card Networks By adopting the Code, payment card networks agree to provide any requested information regarding actions taken by themselves or participants to the Financial Consumer Agency of Canada, for the purpose of monitoring compliance with the Code. In addition, payment card networks agree to pay for the fees associated with monitoring compliance with the Code, as determined by the Financial Consumer Agency of Canada. Policy Elements 1. Increased Transparency and Disclosure by Payment Card Networks and Acquirers to Merchants The payment card networks and their participants will work with merchants, either directly or through merchant associations, to ensure that merchant – acquirer agreements and monthly statements include a sufficient level of detail and are easy to understand. Payment card networks will make all applicable interchange rates easily available on their websites. In addition, payment card networks will post any upcoming changes to these fees once they have been provided to acquirers. Payment card network rules will ensure that merchant statements include the following information:  Effective merchant discount rate2 for each type of payment card from a payment card network;  Interchange rates and, if applicable, all other rates charged to the merchants by the acquirer;  The number and volume of transactions for each type of payment transaction;  The total amount of fees applicable to each rate; and,  Details of each fee and to which payment card network they relate. This information must be presented in a manner that is clear, simple and not misleading. 2. Payment card network rules will ensure that merchants will receive a minimum of 90 days notice of any fee increases or the introduction of a new fee related to any credit or debit card transactions. Payment card networks will provide at least 90 days notice to acquirers for rate and / or fee changes and at least 180 days notice for structural changes3. Notification is not required for fee changes made in accordance with pre-determined fee schedules, such as those based on merchant sales volume, provided that the schedules are included in the merchant’s contract. 3. Payment card network rules will ensure that following notification of a fee increase or the introduction of a new fee, merchants will be allowed to cancel their contracts without penalty. By signing a contract with an acquirer, a merchant will have the right to cost certainty over the course of their contract. As a result, in the event of a fee increase or the introduction of a new fee, merchants will be allowed to opt out of their contracts, without facing any form of penalty, within 90 days of receiving notice of the fee increase or the introduction of a new fee. Merchants may not cancel their contracts in relation to fee increases made in accordance with pre-determined fee schedules, such as those based on merchant sales volume, provided that the schedules are included in the merchant’s contract. 4. Payment card network rules will ensure that merchants who accept credit card payments from a particular network will not be obligated to accept debit card payments from that same payment card network, and vice versa. Payment card networks will not require merchants to accept both credit and debit payments from their payment card network. A merchant can choose to accept only credit or debit payments from a network without having to accept both. 5. Payment card network rules will ensure that merchants will be allowed to provide discounts for different methods of payment (e.g. cash, debit card, credit card). Merchants will also be allowed to provide differential discounts among different payment card networks. Discounts will be allowed for any payment method. As well, differential discounting will be permitted between payment card networks. Any discounts must be clearly marked at the point-of-sale. 6. Competing domestic applications from different networks shall not be offered on the same debit card. However, non-competing complementary domestic applications from different networks may exist on the same debit card. A debit card may contain multiple applications, such as PIN-based and contactless. A card may not have applications from more than one network to process each type of domestic transaction, such as point-of-sale, Internet, telephone, etc. This limitation does not apply to ABM or international transactions. 7. Payment card networks will ensure that co-badged debit cards are equally branded. Payment card network rules shall ensure that the payment networks available on payment cards will be clearly indicated. Payment card networks will not include rules that require that issuers give preferential branding to their brand over others. To ensure equal branding, brand logos must be the same size, located on the same side of the card and both brand logos must be either in colour or black and white. 8. Payment card network rules will ensure that debit and credit card functions shall not co-reside on the same payment card. Debit and credit cards have very distinct characteristics, such as providing access to a deposit account or a credit card account. These accounts have specific provisions and fees attached to them. Given the specific features associated with 2 debit and credit cards, and their corresponding accounts, such cards shall be issued as separate payment cards. Consumer confusion would be minimized by not allowing debit and credit card functions to co-reside on the same payment card. 9. Payment card network rules will require that premium credit and debit cards may only be given to consumers who apply for or consent to such cards. In addition, premium payment cards shall only be given to a well-defined class of cardholders based on individual spending and/or income thresholds and not on the average of an issuer’s portfolio. Premium payment cards have a higher than average interchange rate. They must be targeted at individuals who meet specific spending and/or income levels. 10. Payment card network rules will ensure that negative option acceptance is not allowed. If payment card networks introduce new products or services, merchants shall not be obligated to accept those new products or services. Merchants must provide their express consent to accept the new products or services. 1 “Acquirers” are entities that enable merchants to accept payments by credit or debit card, by providing merchants with access to a payment card network for the transmission or processing of payments. 2 The effective merchant discount rate is calculated as the total fees paid by the merchant to an acquirer, related to the processing of a specific type of payment card from a payment card network, divided by the total sales volume for that type of payment card. 3 Structural changes are significant changes to the fee structure for a payment card network. This includes the introduction of new types of interchange or other fees, a change to the interchange rate structure or the introduction of a new type of credit or debit card. Code of Conduct for the Credit & Debit Card Industry in Canada

22 Sold Out: October 24th: Payments in Canada: The Perfect Storm: The entire global payments landscape is going through a period of unprecedented upheaval, with new technologies, new players – and even new forms of money competing for market share. With one of the world’s most advanced financial systems, Canada has found itself in the eye of the storm – uniquely positioned to establish global standards and set an example for other countries that are struggling to adapt. Join us on October 24th, as Ron Matthews, Chairman of the Canadian Payments Association ** not of the CPA but of the Stakeholder Advisory Council discusses the strategic vision that Canada is establishing, and outlines the changes that are expected to impact consumers, businesses and financial institutions. Mr. Matthews is considered one of Canada’s primary experts on payments and cash processing, and will facilitate an interactive discussion on the fundamental trends and regulatory standardization developments that are transforming online and mobile payments – and the CPA’s recommendations to the Federal Government on compliance and risk management processes that are needed in this new environment.


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