The short answer is yes. I would start from the fact that agreements between states to avoid tax evasion are obviously desirable and necessary. A certain amount of information will have to be shared between states to prevent tax evasion. However, the type of information, the clarity of the criteria for sharing of information, the measures that should be taken to guard against privacy breaches—all of these are the privacy conditions under which what is a reasonable agreement in principle would properly balance tax information purposes and privacy purposes.
Here, the threshold is presumably an accommodation that Canada was able to negotiate with the U.S. government in terms of exemptions to reporting, so the threshold of $50,000 exists. However, point one is that it's not clear how it's applied. There seems to be a discrepancy, in that the IGA, according to our reading, appears to say accounts under $50,000 need not be transferred, while the Canadian federal Income Tax Act seems to require that all accounts be provided except as determined by the reporting institutions.
Therefore, how firm the $50,000 threshold is and how it's applied is not clear. That leads to ambiguity and the risk of over-reporting of information.