Episode 14: Opportunities and challenges for expanded access to Canada’s payments systems

Transcript of the recording

Cyrielle Chiron:
As Payments Canada that pushes forward on its payments modernization agenda, expanding membership to payment systems is a key component for payments innovation and competition in the global marketplace. I'm Cyrielle Chiron, your host of The PayPod, which talks about all aspects of Canada's ambitious payments modernization mission. And explores the topics that influence payments in Canada and around the world.

Cyrielle Chiron:
While it's important for payment system to remain fast, safe, and secure, ongoing regulatory work from the Canadian government and industry is needed to keep up with demand from both consumers and businesses. But what is being done to advance payments modernization and expand membership access to payment systems? Well, joining me today to discuss this topic is Anne Butler, chief legal officer and vice president of policy and research at Payments Canada. She plays a key role in advancing Payments Canada's modernization efforts. Also joining me today is Jason Young, head of legal and company secretary at PayPal Canada.

Cyrielle Chiron:
With 20 years of experience in law policy and government service, Jason oversees and advise on all legal regulatory and government relations matters for PayPal Canada. Thank you both for joining me today on The PayPod.

Jason Young:
Thank you. Glad to be here.

Anne Butler:
Really excited to be here, Cyri. Thanks.

Cyrielle Chiron:
Great. I'd like to start this off by talking about Payments Canada's vision for modern payments, which identifies eight needs of a modern payment system. So they are on Payments Canada's website, but I would just mention them again for our listeners, just to refresh everyone's memory. So we have faster payments options, data rich payments, transaction transparency, easier payments, cross-border convenience, activity-based oversight, platform innovation, it's long list. And last one, but not least. And this is topical for today, is open risk-based access to foster competition and innovation in the ecosystem.

Cyrielle Chiron:
Anne, I'd like to start with you. And maybe you can explain to us a little bit what is open risk-based access. So what does that mean? Because maybe it's just me, but I would not put open and risk-based in the same sentence together. So what is it, and why is it important? Why is it on that list?

Anne Butler:
Yeah. So thanks, Cyri. Yes, it is a bit of a funny thing to put those words together, being open and risk-based at the same time. So maybe I'll start with, what's the source of this? Why do we talk about open and risk-based access? And then hopefully get to the heart of your question, which is, how do you smash those two things together? So the source of open risk-based access really comes from international trends that have been adopted around the world, including Canada, from regulators of payment systems and other financial market infrastructures. That really say a national payment system or a market infrastructure has to have objective criteria that are risk-based. And that are publicly disclosed so that participants can understand the rules and understand how to play by the rules in a way that is fair and transparent and encourages competition.

Anne Butler:
So the way I think about it, to answer your question Cyri, is there's risk-based, so looking at what are the risks of a payments system, and what kind of skills, attributes and risk controls do you need to be able to participate safely? But as a payment system, especially a national payment system, you also have to have an openness in terms of information. An openness in terms of, what are the things a firm would need to do, or be able to do, to be able to participate in that system?

Anne Butler:
So competitors can build to those standards, they understand the rules of the game, and that they can participate. In my mind, the openness you have to think of as, are things like Payments Canada, where we have all of our bylaws and rules are publicly disclosed. The access criteria are publicly disclosed. And members need to understand how to comply with those in order to play fairly on the system. So that's how I see open and risk-based coming together.

Anne Butler:
So I guess, if you think about that criteria of risk-based is thinking about the systems that you have. So it's really a spectrum, and I think that's the other part of the international standards and the way that regulators approach it in Canada is, payment systems have different risks. And the participants in a payment system have different risks. And so when you look at what the criteria for access to those systems should be, they're going to be different depending on the nature of the system that you're working with. So the criteria around access should reflect the risk on the system. And at Payments Canada we're operating currently two systems, soon to be three. And the high value payment system, that has all the wire transactions in the country, the settlement of all the securities transactions in the country and all the wires between the banks to settle at the end of the day and with the Bank of Canada, big dollar values, right? Big, big dollar values that are really critical to the system.

Anne Butler:
And they have very robust risk controls around credit risk and liquidity risk management. And so that naturally the criteria for access to a system like that are going to be quite a bit more stringent than they're going to be for access to useful to what we spoke about earlier, real-time payments, retail payments, where the values are smaller, the participants are broader within the ecosystem. So you're really trying to tailor access criteria of an inherent risk in the system, and the natures of the risk that the participants bring to the system.

Cyrielle Chiron:
Yeah, no, definitely. And how does it look like in modernization initiatives? So you said, we know we can go from two system to three systems. So are we going to have different access for those different three systems?

Anne Butler:
Yeah, so we will. Because we're going to have three systems, the high value payment system we will have, we'll continue to have a retail batch system. And we'll have a standing up our new retail real-time rail system. And the high value system, and there's an area actually where you're going to see that openness is something that's going to be even more clear as we move forward. Because as part of this process, a big player in payment system is also the central bank. So all of our access criteria are currently disclosed for access to the systems. And of course, driven by membership in Payments Canada. You have to be a member first, and then if you meet the criteria to get access. But for participation in the systems as well, players have to have a settlement accounts with the Bank of Canada.

Anne Butler:
And so the bank is also working on, what are the criteria? Being more open about what the criteria will be going forward. So when we go to the high value payment system, that openness criteria will include not only, what are the requirements for you to participate on lengths, the high value system, but also what are the requirements for getting a settlement account with the Bank of Canada? And that will flow through to each of the systems. And it will be different depending on the system. And our retail batch system, a great example of one where we've already made some changes to the access criteria. Fingers crossed, because we are, as you know, a pretty heavily regulated entity. And the access criteria are actually regulations that have to go through the government drafting and approval process. And so they are drafted and ready to go, but waiting for them to actually be finalized through the government process.

Anne Butler:
But that is to open up access more broadly to our automated clearing and settlement system, which has currently volume requirements that limit direct participation. Unless you have sufficient volume of a certain amount to participate on the system. And one of the first things we did in our modernization initiative was to take the steps to remove that volume requirement. So that will no longer be a barrier to entry on our automated clearing and settlement system.

Anne Butler:
Then I think the most exciting one, Cyri, is with our new real-time real. It's really planning a much broader access to that system, which will be expected to be lower value payments. real-time payments that are pre-funded, and so the credit risk is much lower in the system relative to other systems. And we are expecting to see expansion of membership in Payments Canada include broader credit union membership and payment service provider membership options that would enable participation in that system going forward. Which is, I think, where you're going to really see the value of expanded access for the Canadian economy.

Cyrielle Chiron:
Yeah. Yeah, totally. I agree. Yeah, so definitely a big program, more transparency, more options, more innovation. So pretty big initiatives. Jason, I'd like your opinion on that, actually too. What are the opportunities and challenges do you see for this type of access?

Jason Young:
Yeah. Thanks Cyri. Anne gave a great intro piece there on all of the things that Payments Canada is working on. And it's a lot. From PayPal's perspective in Canada, we are focused on the real-time rail, which is the system that I am most familiar with. And its predecessor, the ACSS, or the analog, I guess. It's not entirely comparable, but similar. I'll just add to what Anne's already said, which is that those systems were designed for different priorities from a different era, that were primarily prudential. And a big problem has been that access has been limited to all but a very few large players. In fact, the largest players in Canada. And so I think from the opportunity side, moving to an open risk-based approach to access means that barriers to access will be lowered, including by creating greater certainty for new entrants to meet their obligations, to design their systems to meet those obligations. And setting out the regulatory expectations around what access looks like.

Jason Young:
And that's important, and factors into the innovation piece. Because it creates a fertile ground, if you will, for Canadians. And Canadian FinTechs, in particular, to compete on a global stage. I mean, we like to think of ourselves as a large country, and we are geographically, but from a market perspective we're quite small relative to the global stage. And so it's important for us as Canadians and as proponents of Canadian innovation and competition to think about how we can make it easier for Canadian entrepreneurs in the financial space to grow and then use Canada as a staging ground to enter that larger market. So on the risk side, I think... And I'll probably say this a couple times in this chat. But the devil is in the details, right? So we talk about principles and then we start to dig down into what those principles mean, how they are set out in regulations, how the systems will actually work.

Jason Young:
And a lot of that has yet to be ironed out, and it will take some time. And there are ways that we could do things from a principle space perspective that would be unhelpful to incenting competition and innovation. And there are ways that we could do things that borrow best practices from, for example, other markets where they're ahead of us. And we can learn those lessons and not adopt the same, or make the same mistakes that have been made in some other markets. And I think we should do that.

Jason Young:
And one of the reasons why we need to do that is because, as Anne already alluded to, a level playing field, it doesn't mean that everyone is subject to the same rules or degree of enforcement. It means that like risk is treated in a like manner. And that's tricky, because smaller players could represent qualitatively greater risk, even with smaller volumes. And larger players could represent qualitatively less risk with greater volumes, or vice versa. And so the rules have to reflect that there's going to be a lot of different models in play in the market, a lot of different technologies. And, how do you create a system that is safe, it's efficient, but also open, transparent and welcoming, and that it fosters that innovation that we're talking about today?

Cyrielle Chiron:
Yeah. I like the fact you mentioned fertile ground. I think this is exactly that. Just putting the infrastructure in place so that everyone can grow. And going back to the details, we're talking to people who are experts in regulations, so I don't expect anything other than all the details! Having said that, Anne, is there anything you'd like to add on this, looking at the opportunities and challenges?

Anne Butler:
Well, I think Jason's points were excellent. As we read work through our modernization initiative, we really have turned to look outside of Canada to say, what are the best practices? And frankly, outside and inside Canada to the players, like Jason's firm and others, and our members who are participating in multiple jurisdictions. So that we can think about how to build these in a way that they are learning from the other jurisdictions, and interoperable. And things like using common messaging standards like ISO 20022, and common rules frameworks at the approach.

Anne Butler:
So that if a participant's in one jurisdiction, as Jason said, what you don't want to have is to do business in Canada is so radically different than other jurisdictions that the cost benefits of playing in our country don't make sense. Or for seeding innovation in our country, you don't have to build to some model that doesn't help you to grow in other jurisdictions. And I think that's really, really important for us, because you can get lost in the regulatory weeds, right? You have to be thinking about the business here as we build this. And I think - Cyri's laughing because I think you're experiencing that, the regulatory weeds. I think it's really critical that we spend time, and we are trying very hard to spend a lot of time with the market players to understand how they intend to use the real-time rail. So what are their experiences in other jurisdictions? People like Jason volunteering their time and experience to helping us do the right thing.

Anne Butler:
I think that's critical. That's a huge missed opportunity if we do not have broad participation from a broader group of players on the real-time rail. Because that's the way we're going to compete, innovate and be competitive as a country. Having perspective on how we started and why we need to be so different today. Right? Remember in the 1980s, when this organization was created by statute, the Canadian Payments Association as it then was. We were in a primarily paper world, right? We were talking checks and government remittances.

Anne Butler:
Most of the economy was still being transmitted, or the money was being transmitted through a paper type world. And we're not in that world anymore. And if nothing else, COVID has shone a bright spotlight on that, the need to get digitized as fast as possible. Sure, we have a lot of our money moving now on digital rails, but we still have a lot of paper in the system. And so understanding that the value to us as a country, of being focused on getting this thing going and getting our economy truly into the digital world is really, really important. And I think the last four months have really underscored that for us.

Cyrielle Chiron:
Yeah, no, totally. I think you're absolutely right. We are in a new world, and we definitely need to make sure we adapt to this in order to keep up to date with the trends. Talking about keeping up to date with the transaction and adapting to a new world, and I'd like to stay with you. And I'd like to talk about the retail payments oversight framework. This big piece of work that has been undertaking at the national level. So I'd like to talk about this a little bit, because this is something that is key today, right? For all the work that is being done, and we are continue going to be done. Can you tell us a little bit, what is it? What is the work being done here on this piece of work? And what is the value for the payments ecosystem?

Anne Butler:
Yeah, so I'll get started. And I know Jason and I both sit on the Department of Finance's FinPay advisory committee that has done a lot of work on this. So I'll start and I'm sure he'll have things to add. The retail payments oversight framework is, in my view, is a very, very critical enabling piece of legislation for the payments ecosystem in Canada. We call it RPOF, or [RPOFers 00:18:22], people that are having intention to become payment service providers regulated under the retail payments oversight framework. This legislation is really designed to put regulatory arms around for a consistent and fair regulatory environment for the payment service provider space in Canada. Which has been regulated differently than financial institutions, for instance.

Anne Butler:
And it will provide a common framework for how they will be regulated to be able to participate in payment systems. And so if you think about it, there's really two critical pieces of legislation to enable a broader access, especially as we talked about real-time rail. The retail payments oversight framework, which will become a place for payment service providers to be registered and overseen by the Bank of Canada. And then once in that regime, you'll be eligible to apply to become a member of Payments Canada, and to have access to Payments Canada payment systems.

Anne Butler:
And so tied to the RPOF regime will be amendments to our Act, the Canadian Payments Act, to broaden membership to include not only payment service providers, but probably also broader credit union membership with one of the goals being to really enrich the participation in the real-time rail and other payment systems. So that, to me, is very critical. And it's a building block for the path forward for a broader and more competitive payments environment in Canada.

Cyrielle Chiron:
So that is what you were saying before, Jason. That's just fertile ground, right? So this is the thing, number one that's to be done. Yeah, that's pretty interesting. I'd like to followup on those question, but before that, I'd like to have you, Jason, also on RPOF. I'd like to have your thoughts on this. But also maybe from a consumer point of view, how do you see this benefiting Canadians?

Jason Young:
I think there's a couple of ways at least. Perhaps it's rare from a FinTech perspective, but certainly I think it's rare even from a person on main street to say that additional regulation might benefit the consumer. Sometimes that can be a challenge. But I think there are specific ways here that a regulatory framework or additional regulations could help. And RPOF is unique from a legislative perspective, I think, in Canada. In that it takes a functional approach as opposed to an entity approach. So if you are performing certain of five different payment functions, then you will be captured by the legislation and you will be required to do certain things, meet certain operational risk controls, protect end user funds, if you're holding them.

Jason Young:
And make certain disclosures, as yet unknown. But certain disclosures to consumers. And so I think from the consumer perspective, this should provide additional clarity on how, for example, consumers funds that are held by PSPs are safeguarded. That a PSP is meeting its obligations from an operational perspective, with respect to security. That consumers can avail themselves of a an established dispute mechanism if they aren't getting satisfaction from the payment service provider.

Jason Young:
And that the Bank of Canada, which has been designated as the regulator of this scheme, is ensuring that PSPs are following the rules. And so I think all of those things will be positive from the consumer perspective. I think it will be challenging to enforce the scheme and to oversee the scheme, particularly in the early years. Some of the estimates of the number of players that will be captured by this scheme have been bandied about. And I've heard that there are approximately 1,000 payment service providers operating in Canada today. And many of those providers, or at least some of those providers, won't have local operations. So they're providing services to Canadians from another jurisdiction. And many of those operators, even if they are here, are small. And so I think there's going to be an educational component that the Bank of Canada will have to undertake. And then there will be a compliance component that they'll have to undertake as well. And I think that's going to be a big chunk of work for them.

Cyrielle Chiron:
Yeah. To tell you, because the key question I would have, when Anne was talking, it's mainly about, you open access and then you give the criteria for entry. And how do you make sure that they have the criteria to enter, but do they have the criteria to deliver? Once they are in, how making sure that they can sustain everything that they said they're going to do. Especially for the small players you are talking about, compared to a big bank that has been doing that forever. So maybe some questions that they would have to access. And as you said, maybe educate the ecosystem to say that who is... I will not say who is digital who was not. But how do you make sure that you monitor those players?

Jason Young:
Right. And I think that's going to be a challenge. In part, because the way that the bank will impose or oversee the scheme is through a registration process. But if you're a FinTech, for example, operating outside of Canada and providing services into the country. Or if you're a small FinTech and you don't have legal and policy support, and you're just not aware of those obligations, and you haven't registered, defacto fall outside the scheme, and it will be difficult for consumers to necessarily assess. At some point I hope that a registration mark or a registration disclosure will give consumers confidence that a FinTech or a PSP, payment service provider, that they are doing business with is meeting those obligations. And so that could become almost like a trust mark or a-

Anne Butler:
Like in CVIC mark or something. Yeah.

Jason Young:
Exactly. Yeah.

Anne Butler:
Yeah.

Jason Young:
Exactly.

Anne Butler:
I agree, Jason, the challenges of that. And I think it also, Cyri, if I could highlight what it means, that's different too about the role that Payments Canada will play in this space. Because I think it's important to understand that to be under the retail payments oversight regime, as Jason said, it's are you doing these functions related to payments? If you are, the law applies to you, and you have to register. It's a registration regime. It doesn't mean you get to play in the payment systems. So Payments Canada will have to set... And going back to the original question you asked about what is open and risk-based? We will have to also declare, certainly the first tick box for a criteria to get access to the payment systems will be, are you a regulated financial entity?

Anne Butler:
Are you already an FI, that's a financial institution that's regulated prudentially in either federally or provincially? Or are you now a regulated payment service provider under the RPOF regime? Tick the box. But we will also have criteria that will be associated with your operational risk controls and so on. That will have to be built as part of our access criteria that will be publicly disclosed, and can be built to in order to come into the payment systems. Because it's one thing to be a startup payment service provider that registers to comply with the law. It's another thing to have the maturity to get into the system. And that's where being very clear on what the criteria will be for access around cyber security controls and operational risk management are going to be pretty critical.

Cyrielle Chiron:
Yeah, no, that's very interesting, Anne. And thanks for clarifying the role, the legislations, and also the role for Payments Canada. Because it's, as you said, it's not because you have the criteria that you're automatically going to be playing in our system. Both of you were saying that this piece of work, it's big. I don't know, it's big enough work. And it's taking time. So do you feel that there are any ways that the Canadian payments industry can help advance this legislative action in support of modernizing payments? So why don't we start with you, Anne, first?

Anne Butler:
Yeah. I think, you might be able to tell from my previous comments, I really believe that RPOF legislation is critical to our economy. That it has to get put in place. And it is ironic, right? As Jason said. That, how could a piece of regulatory legislation be so critical to advancing innovation in the country? But in my view, it is because it's the key building block for making changes to who's allowed into payment systems. And that we've got a lot of really exceptional talent, large and small businesses that are on ready, willing, and able to help us become more competitive nationally and internationally. And that this is really important. The COVID crisis has had an impact, obviously understandably on legislation that's actually ready to go. So for our colleagues inside the Department of Finance and Department of Justice, they've done the drafting work, but it's a matter of priorities in the times that we are in as to whether or not that's getting onto the legislative agenda.

Anne Butler:
And so in my view, it's one thing for Payments Canada to have a view that this is a really important building block for the payments ecosystem in Canada. That I think there's a real place for the voices of the businesses that will be able to thrive with this coming into force, to make sure that our lawmakers understand that this isn't a technical piece of legislation. This is a really important enabling step for our country. I think there's a real opportunity to make sure that the voices of our businesses are heard on that.

Cyrielle Chiron:
Yeah, that's a good point. And sort of now that you mention, this is ready, but COVID-19 affected a lot of work globally. And this is one of the piece of work that the pandemic has affected. And maybe the government shifted a little bit their priorities. Jason, maybe to build on that, and what on Anne say. What approach or next steps do you think the industry can take to continue to push this forward as they navigate in this new reality? Because this piece of work is important.

Jason Young:
I'm actually going to repeat a couple things that Anne has already said or alluded to. The first of which, is that consultation is really important. I strongly believe that. In part because the field of players, or potential players, who will be captured by RPOF. I say captured, and I don't mean that in a negative way, I just mean that they will have obligations under the framework. Is quite broad, right? And the business models and the technology used by those players will span the spectrum. And there will be lots of different flavors of services and products offered. And so there won't be one right way to do something. And when you're talking about principles, for example, protecting end user funds, it's fine to talk at that level and expect that everyone can agree to meeting that obligation.

Jason Young:
But then when you get down into, when you drill down into how that obligation will be met by those who are subject to this legislation, I think, again, going back to my earlier comment, the devil's in the details. It will be critical to have those conversations with the players, with the PSPs, to better understand what possible prescriptions we can adapt or adopt to meet those obligations. I think that will be critical. We want to build a system that is flexible and creates that fertile ground to allow a maximum level of innovation and efficiency in the system. The other point that I would make, again, repeating Anne, is that we are having conversations. There are a number of forums where that can happen. FinPay being one of them at the Department of Finance. Payments Canada's own stakeholder advisory committee.

Jason Young:
The Bank of Canada has set up a retail payments advisory committee, or an interim committee to, again, have those conversations. The challenge, I think, for the industry is that while PayPal and others like PayPal are at those tables because we have the size, the heft, the influence, there are many players who are not. And so, how does government reach out to and have conversations with those smaller players? Because they may have different interests than we do. And I think that's another potential challenge and one that both government and industry need to solve.

Anne Butler:
That's such an important point actually, Jason. I liked the way that you characterize that. And it's something that we certainly do a lot of thinking about, what will we need to play and help amplify those voices? So connecting, you referenced our stakeholder advisory council, which has a representation of different parts of the user's space in industry and in certain payment service providers. But that's not broad enough, right? In terms of our need to consult with industry and understand the marketplace of potential new participants of payment systems. And to help them understand the regime that we're working within. And I think if there's one thing I've learned in the last couple years is the importance of that consultation and engagement process for us as the payment operator.

Cyrielle Chiron:
Yeah. I think you're right, Anne. Like understanding the other's ecosystem. It's a new world, right? So making sure everybody understand each other, that will be very critical. And that's not going to happen overnight. I have one last question before we end, for the two of you. Kind of imagine, kind of asking this question about fast forward in the future. We are in a world where we have expanded more membership. It is all done, all up and access. Everything is working well. Now what? What's coming next?

Jason Young:
I've been saying this for years, and I'm saying it now for a different reason. But I believe that we're at an inflection point in payments. When I've said it in the past, I was referring to a critical mass of change in the industry. And COVID has done nothing but hasten that. I think it's demonstrated that Canadians are willing and indeed eager to change their behavior when it comes to commerce. I've heard many, and I'm sure we all have heard anecdotal stories of grandparents getting online and using PayPal or other payment mechanisms to order groceries to their homes, things like that. Behaviors like that, that you just wouldn't have imagined people doing voluntarily prior to COVID. But our payments infrastructure was built for the last century's economy, not this decade's.

Jason Young:
And so as we pivot back to how we can modernize the central clearing and settlement systems, central payment systems, I think we're at that inflection point, that critical juncture. We have, as a country, a tremendous number of advantages to succeed on the global stage. We have a very strong financial system. We have a highly educated and diverse workforce. And I underline the diverse piece because I think that is critical and often overlooked. We have a progressive immigration policy, particularly when contrasted with that of some of our neighbors. And we have a history, a strong history, and a long and proud history as a trading nation. So if we are able to do this right, to modernize our payments infrastructure, and to build that regulatory framework to incent innovation and increase competition, embrace transparency, underline and protect safety and efficiency in the system, we'll create that final necessary condition to allow Canadian FinTechs and Canadian consumers, frankly also, to benefit from and succeed both here and on the global stage. So I think it's a very exciting time to be in payments. And thanks for having me today.

Cyrielle Chiron:
No worries. Anne, is there anything you'd like to add?

Jason Young:
How do you followup after that? That was super inspiring.

Cyrielle Chiron:
I know.

Jason Young:
I mean, I can't improve upon that. That was just, I absolutely aligned with the statements that Jason has said. So maybe to end with an aspiration that reflects this long and painful journey we've been on, in terms of trying to transform not only technology, but a legal framework that was formed in the 1980s into one that the technology and legal frameworks that will support us into the future. And so my aspiration would be in addition to, Cyri, you gave us the fact assumption that we now have the regulatory environment, we have with the broader members. We assume we've created that platform for innovation. And for the reasons that Jason's also explained is, my aspiration is that we as a country find a better way to be nimble in how we develop regulatory frameworks for the future, so that we are not trapped in the 20th century way of doing it when we need the 21st century methodologies.

Jason Young:
And so for me, I spent a lot of time thinking about, how do we learn from this experience and think about the tools that we need for the future to be able, when there is innovation coming out of our ecosystem or internationally, that we can adapt quickly to enable that for Canada? And that's what I'm aspiring that we also are on that path at that point in time.

Cyrielle Chiron:
Yeah. And I know you spent some time looking at tools to make things better, so I can concur to that. Thank you both for your time. I think for me what's the key things here that I got, it's like building a secure, fertile ground. I think that was important in consultation. And this is just the beginning, right? It's pretty interesting time ahead that it's coming to us. I'd like to thank you both for your time. I think that was a pretty interesting conversation.

Jason Young:
Thank you, Cyri.

Anne Butler:
Thank you, Cyri. And thank you, Jason, it was great to chat with you for an hour and hear your voice.

Jason Young:
Thanks very much, Anne. Great to hear your voice as well.

Cyrielle Chiron:
As our guests have outlined, there are opportunities for expanding membership, but with opportunities come some challenges. And one of which is balancing the need to support innovation with safety and security. It's really an exciting time to be in payments these days. I'd like to once again thank Anne Butler and Jason Young for speaking with us today. As always, The PayPod is available for download on your favorite podcast app or payments.ca. Enjoy the conversation online using #modernpayments. And stay tuned as we continue to explore the changing world of things. See you next week.