06/16/2026
Open banking just stopped being theoretical in Canada.
On June 9, FirstOntario Credit Union went live on open banking under the Consumer-Driven Banking Act. One of the first credit unions in Canada to activate consent-based financial data sharing in production on Day 1 of the framework.
Three things in that announcement that matter for every Canadian lending executive:
1. FirstOntario picked its open banking partners eighteen months before the rule required it. The lenders who treated 2024 and 2025 as a building window are live now; those still waiting for "final clarity" are watching from the sidelines.
2. FirstOntario did not rip-and-replace its core to get there. The capability runs on top of existing systems through FIS Everlink and Flinks Outbound, which already has 300+ fintechs connected. Extending the stack, not rebuilding it, is the model that scales.
3. The infrastructure clock is real. Bill C-15 received Royal Assent in March. Technical standards are coming in the next few months. OSFI Guideline E-21 comes into full effect on September 1. Every open banking partner becomes a third-party relationship to inventory under B-10. The institutions that were built early are also documented early.
For underwriting, the strategic question is what runs on top of the new inputs. Consent-based data feeds compress document collection; the decisioning layer is where the competitive advantage lives.
The model is not the moat. Foundation models give everyone the same reading and reasoning capability. What separates good underwriting from generic underwriting is whether the AI is trained on this lender's policy and corrected by this lender's underwriters. That specializing signal is the moat, and it sits with the lender, not the vendor.
FundMore deploys as an agent within a lender's existing LOS. No rip-and-replace. No 12-month IT project. Pure infrastructure that never originates, funds, or brokers a loan, which means it does not compete with its customers for borrowers.
FirstOntario showed what early looks like. The lenders building on top of open banking infrastructure now, with policy-trained AI applied to the cleaner inputs it creates, will define the underwriting standard for the decade.
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