Reporting of retail payment activity metrics at registration

Publication date: February 14, 2024

This supervisory policy outlines the retail payment activity metrics that payment service providers must report at registration.

Introduction

Under the Retail Payment Activities Act (RPAA), payment service providers (PSPs) are required to report quantitative metrics of their retail payment activities—first at registration and then as part of annual reporting. The metrics that must be reported at registration are detailed in section 24 of the Retail Payment Activities Regulations (RPAR) and in section 29 of the RPAA.

This policy helps applicants understand the reporting requirements of Section 9 and 10 of the registration application. It offers guidance on each required metric. Applicants should take all reasonable steps to report in line with this policy given their circumstances, including the information they have available and any steps taken to obtain it. As a reminder, providing false or misleading information is a designated violation under the RPAA.

These reportable metrics capture information on a PSP’s ubiquity and interconnectedness, as demonstrated by the:

• value of end-user funds it holds
• number and value of electronic fund transfers (EFTs)
• number of end users
• number of other PSPs it provides services to

More specifically, the reportable metrics may be used, among other things to:

• supervise PSPs using a risk-based approach
• take proportionate enforcement actions, including issuance of administrative monetary penalties
• monitor trends and issues

1.0 Reporting retail payment activities

This section provides general guidance applicable to all metrics listed in section 2.0 Reporting required metrics that an applicant must report at registration.

1.1 Scope of Reporting

Applicants must report all retail payment activities performed that are within the scope of the RPAA.1 Reporting should not include retail payment activities that are excluded from the RPAA.2

1.2 Reporting for applicants in and outside of Canada

Applicants that have a place of business in Canada3 must provide details of all retail payment activities within the scope of the RPAA:

• all end users (both in and outside of Canada),
• end users in Canada only (reported separately)

Applicants that do not have a place of business in Canada4 must provide information for retail payment activities performed within the scope of the RPAA for end users in Canada only.

1.3 Agents and mandataries

Any retail payment activities performed by an agent or mandatary on behalf of the applicant (i.e., the legal entity that is registering with the Bank) should be included in the applicant’s reporting.5^,6

1.4 Affiliates

Retail payment activities performed by entities affiliated with the applicant (i.e., the legal entity that is registering with the Bank) should not be included in the applicant’s reporting.7

1.5 Canadian-dollar-equivalent calculations

Applicants are required to express certain metrics in Canadian dollars (CAD). To do so, the applicant should calculate the Canadian-dollar equivalent by either using the current monthly exchange rates published by the Bank or the exchange rates it uses during the normal course of business.

2.0 Reporting required metrics

This section provides general guidance on individual metrics that must be reported by the applicant as part of the registration application. Related questions from the registration application are noted for each topic below.

Specific guidance is outlined under each metric for applicants that:

• have a place of business in Canada
• do not have a place of business in Canada
• have not yet started operations

2.1 Value of end-user funds held

2.1.1 Average value of end-user funds held

2.1.1 Average value of end-user funds held8

(Registration application questions 9.2, 9.3, 9.6 and 9.7)

Applicants must report every month’s average daily value of all end-user funds held at the end of the day. This must be reported for each of the previous 12 months.

• Note that “previous 12 months” refers to the most recent 12-month period for which data are available. For example, if an applicant registers on November 1, 2024, and data are available for October 2024, the previous 12-month period is November 2023 to October 2024.
• If the applicant was not in operation for the full reporting period required for each particular metric, they should provide the information for the time they were in operation.

End-user funds held refers to the total amount of funds that an applicant holds on behalf of its end users.

For each of the previous 12 months, the average daily value of end-user funds that the applicant held at the end of each day:

• should be calculated by taking the total value of end-user funds held at the end of each day in the month and dividing by the number of days in the month
• must be expressed in Canadian dollars (see section 1.5 Canadian-dollar-equivalent calculations).

Applicants with a place of business in Canada must report separately the value of end-user funds held for end users in Canada and for all end users (in total).

Applicants without a place of business in Canada must report only the value of end-user funds held for end users in Canada.

Applicants that have not performed any retail payment activities in the previous year should provide the projected monthly average value of end-user funds to be held at the end of each day for their first year performing retail payment activities.

2.1.2 Currency composition of end-user funds held

2.1.2 Currency composition of end-user funds held9

(Registration application questions 9.2.1, 9.3.1, 9.6.3, 9.6.4, 9.7.2 and 9.7.3)

These questions are relevant for PSPs that currently hold, or held during the reporting period or plan to hold end-user funds in currencies other than Canadian dollars.

For applicants with a place of business in Canada:

• Using the drop-down list in the registration application form, applicants must report all currencies in which they held end-user funds for all end users over the previous 12 months.
• For each currency, applicants must also report the approximate percentage share of total end-user funds held for all end users in that currency over the previous 12 months.
• Applicants that have not performed any retail payment activities in the previous 12 months must provide projections for their first year performing retail payment activities.

For applicants who do not have a place of business in Canada:

• Using the drop-down list in the registration application form, applicants must report all currencies in which they held end-user funds for end users in Canada over the previous 12 months.
• For each currency, applicants must also report the approximate percentage share of total end-user funds they held for end users in Canada in that currency over the previous 12 months.
• Applicants that have not performed any retail payment activities in the previous 12 months must provide projections for their first year performing retail payment activities.

If the applicant was not in operation for the full reporting period required for each particular metric, it should provide the information based on the time it was in operation.

2.2 Number and value of electronic funds transfers

2.2.1 Total number and total value of electronic funds transfers (EFTs) for which the applicant performed a retail payment activity

2.2.1 Total number and total value of electronic funds transfers (EFTs) for which the applicant performed a retail payment activity10

(Registration application questions 9.4, 9.5, 9.8 and 9.9)

Applicants must report the total number and total value of EFTs for the previous 12 months.11

• If the applicant was not in operation for the full reporting period required for each particular metric, it should provide the information based on the time it was in operation.

The total value of EFTs must be expressed in Canadian dollars. See section 1.5 Canadian-dollar-equivalent calculations.

For applicants with a place of business in Canada, the total number and total value of EFTs for end users in Canada and for all end users are reported separately.

Applicants without a place of business in Canada must report the total number and total value of EFTs for end users in Canada only.

Applicants that have not performed any retail payment activities in the previous year must provide projections of their total number and value of EFTs expressed in Canadian dollars for their first year performing retail payment activities.

If the applicant has a place of business in Canada, reporting should include all EFTs for which the applicant performed a retail payment activity, regardless of whether the applicant is interacting directly with the end user or with another PSP.

If the applicant does not have a place of business in Canada, reporting should include all EFTs for which the applicant performed a retail payment activity on behalf of an end user in Canada, regardless of whether the applicant is interacting directly with the end user in Canada or with another PSP.

• If the applicant does not know an end user’s location, it should provide an estimate based on best efforts and available information.

Applicants are not required to report EFTs associated with activities that are excluded from the RPAA. These include:

• payment functions performed in relation to an EFT made with an instrument issued by a merchant or group of merchants, such as shopping mall gift cards, coffee cards or transit cards (section 6(a) of the RPAA)
• payment functions performed in relation to an EFT made for the purpose of giving effect to an eligible financial contract or to prescribed transactions in relation to securities (section 6(b) of the RPAA)
• payment functions performed in relation to an EFT made for the purpose of a cash withdrawal at an automated teller machine (section 6(c) of the RPAA)
• payment functions performed in relation to an EFT using a system designated under the Payment Clearing and Settlement Act (PCSA-designated system) (section 7 of the RPAA), subject to the following:
• Participating in or merely using a designated system does not exclude a PSP from having to report. As noted in the Bank’s registration criteria, an individual or entity is subject to the RPAA if it performs any payment function outside of a designated system. The Bank expects that likely only an operator of a designated system could perform all of its payment functions entirely within a designated system. Accordingly, the Bank expects that all payment functions performed in relation to a single EFT would have to be performed by the system operator using a designated system (e.g., Interac e-Transfer^®) for that EFT to be excluded from the reporting obligation. If one payment function for an EFT is performed outside of a designated system (e.g., on a PSP’s web interface), that EFT would be reportable by the PSP.
• internal transactions among affiliated entities (section 8 of the RPAA)
• orders by the Governor of the Bank of Canada under section 11 of the RPAA
• payment functions that are incidental to another non-payment service or business activity (section 3 of the RPAR)

The Bank expects the applicant to consider the following items when reporting on the number and value of EFTs:

• The number and value of EFTs can generally be determined by how many retail payment transactions a PSP facilitates (i.e., for which it performs one or more payment functions, regardless of whether they are interacting directly with end users or with another PSP).
• Section 2 of the RPAA defines an EFT as “a placement, transfer or withdrawal of funds by electronic means that is initiated by or on behalf of an individual or entity.”12 In simpler terms, an EFT is a way of moving money between a payer and a payee through any electronic means—in other words, not in cash. Some common examples include debit, credit or prepaid card transactions made online or at the point of sale (POS), direct deposits, bill payments, payment disbursements, electronic peer-to-peer payments and various types of money transfers into or out of customer’s accounts. The Bank considers any of these transactions to be a single reportable transaction regardless of the number of steps or intermediary flows that take place to allow for the ultimate settlement of the funds.
• The number of EFTs to be reported consists of the number of the retail transactions described above involving an EFT between a payer and a payee for which a PSP performs at least one payment function of the RPAA. The value of EFTs to be reported consists of the total dollar value of those transactions.
• Do not count one transaction multiple times; only report a transaction once. We do recognize that in one single transaction, it is possible that you perform multiple RPAA functions (e.g., authorization and settlement), provide multiple services, handle multiple instructions, handle multiple steps in the payment chain, or handle both sides the transaction (e.g., send–receive, credit–debit, inflows–outflows, push–pull, purchase–settle).
• Please note that multiple PSPs involved in the payment chain of a single transaction will likely be reporting the same transaction.
• For batch transactions (when multiple transactions are handled at once), include the total number and value of underlying transactions included in the batch.
• Only completed transactions should be included in the applicant’s reporting.
• For example, if a transaction was first authorized for an amount that was different from the final amount, an applicant does not need to report this transaction twice and should only report the final amount that was paid by the payer.
• Applicants should report the dollar value of those completed transactions not including transaction fees.
• Where relevant to an applicant’s operations, transactions for refund purposes and unclaimed transactions should also be included in reporting.

Some illustrative reporting examples:

• PSP A receives $100 from a payer to send to a payee via a transfer that involves an EFT. It should report would one EFT for its number and $100 for the total value of the EFT.
• PSP B helped process (i.e., performed payment functions) 10 electronic peer-to-peer funds transfers between various payers and payees that added up to a total value of $500. It should report would 10 EFTs for its number of EFTs and $500 for the total value of those EFTs.
• PSP C helped process (i.e., performed payment functions) eight credit card transactions between various payers and payees that added up to a total value of $1,000. Even if those transactions were cleared and settled in one batch payment for a netted amount of $50, PSP C should report would eight EFTs for a total EFT value of $1,000. This is because reporting needs to be based on the number and total value of retail transactions between the payers and payees that involve an electronic movement of funds.
• PSP D helped process (i.e., performed payment functions) one credit card transaction. Being a payment at a gas station, PSP D sought an authorization for a total amount of $100 but only $55 worth of gas was ultimately purchased. PSP D should report would one EFT and an EFT value of $55, because that is the amount that was exchanged between the payer and the payee in that specific transaction.
• PSP E helped process (i.e., performed payment functions) three debit card payments for a combined amount of $100. It also helped process five payroll transactions between an employer and its employees for a combined total of $6,000. As a result, it should report would eight EFTs for the number of EFTs and $6,100 for the total value of those EFTs.

2.3 Number of end users

2.3.1 The number of end users for whom the applicant performs retail payment activities

2.3.1 The number of end users for whom the applicant performs retail payment activities13

(Registration application questions 10.2, 10.3, 10.4 and 10.5)

Applicants must indicate the number of end users for which they performed a retail payment activity over the previous one-year period.

• If the applicant was not in operation for the full reporting period, it should provide the information based on the time it was in operation.

The applicant should include the number of all its end users or the estimated number of all its end users.

• The number of end users could be estimated based on available information, such as the number of accounts, merchant identification numbers, etc.
• The applicant should not distinguish between end users who are payers and payees when reporting this metric. When the applicant provides services to payers and payees, both are considered end-users and should be included in the total number reported for the year.
• Applicants should report the total number of distinct end users to whom services were provided during the reporting year. For example, if the applicant conducted multiple retail payment activities for a single end user multiple times in a year, this should be counted as only one end user during the reporting year.
• If the applicant does not have information regarding how many payers and payees they are servicing because they do not interact directly with them (i.e., they indirectly provide services to those end users because they only interact with other PSPs), it should report zero for this metric.
• The number of PSPs to which services are provided should be reported for that specific metric, per the guidance in section 2.4 Names of other payment service providers that services are provided to.

For an applicant with a place of business in Canada, the total number of end users, both in and outside of Canada, must be included in reporting.

For an applicant without a place of business in Canada, only the total number of end users in Canada must be included in reporting.

Applicants that have not conducted retail payment activities over the past 12 months, must report the projected number of end users for their first one year performing retail payment activities.

2.4 Names of other payment service providers that services are provided to

2.4.1 Names of any other PSPs for which the applicant performed retail payment activities

2.4.1 Names of any other PSPs for which the applicant performed retail payment activities14

(Registration application questions 10.6, 10.7, 10.8 and 10.9)

Applicants must report the names of PSPs for which they performed a retail payment activity over the previous two-year period and for which they plan to perform retail payment activities in the next two years (e.g., the applicant has entered into an agreement or arrangement with a PSP to perform retail payment activities for that PSP next year).

• For example, if the applicant clears and settles transactions for a certain PSP, the name of that PSP should be indicated in the report.
• Reporting of this metric should not capture PSPs to which services are provided only as an end user (i.e., where those PSPs are accessing services as a payer or a payee).
• Applicants should report the names of other PSPs for which they provided services regardless of whether the RPAA applies to those other PSPs, including:
• a bank
• an authorized foreign bank, as defined in section 2 of the Bank Act in terms of its business in Canada
• a cooperative credit society, savings and credit union, caisse populaire or central cooperative credit society that is regulated by a provincial act, or an association regulated by the Cooperative Credit Associations Act
• His Majesty in right of a province or an agent or mandatary of His Majesty in right of a province that accepts deposits transferable by order
• a company to which the Insurance Companies Act applies or an insurance company regulated by a provincial act
• a company to which the Trust and Loan Companies Act applies
• a trust company that is regulated by a provincial act
• a loan company that accepts deposits transferable by order and is regulated by a provincial act
• the Canadian Payments Association (Payments Canada)
• the Bank of Canada
• a prescribed individual or entity
• the SWIFT (Society for Worldwide Interbank Financial Telecommunication) messaging network

An applicant with a place of business in Canada must report the names of other PSPs with and without a place of business in Canada for which it performed retail payment activities during the previous two years and for which it plans to perform retail payment activities in the next two years.

An applicant without a place of business in Canada must report the names of other PSPs with a place of business in Canada for which it performed retail payment activities during the previous two years and for which it plans to perform retail payment activities in the next two years.

Endnotes