Payments Canada has released its latest discussion paper, De-Tiering Large Value Payment Systems: The Case of the Canadian LVTS. Many large value payment systems are characterized by a ‘tiered’ structure, whereby a small number of banks are direct members of the system (also called ‘first tier’) and the majority of banks are indirect members (‘second tier’). The smaller the number of direct banks over the total sector, the higher the level of tiering. Although the causes of high tiering can vary across countries and jurisdictions, the general consensus in the current principles for financial market infrastructures are to encourage direct participation, i.e. ‘de-tiering’ the system. However, it is not clear what impact de-tiering would have on the topology of payment flows. This is mainly due to the lack of complete information about the originator and final receiver of each payment that is usually mandated by FMIs. This paper estimates the payment flows between initial payers and final payee banks. Those flows would correspond to the equivalent fully de-tiered payment system that is consistent with the observed payment structure of the tiered system. It then defines metrics to assess any risks from tiering or arising from de-tiering the payment system.