For any of our participants who are using RTR or a third party exchange that clears through the RTR's clearing and settlement, it is mandatory. There are the four services that I described. The network-level risk score will be consumed by them. It's available to them. It needs to go into their adjudication process on whether to proceed with a payment. There is a requirement in our rules to report fraud, account-to-account fraud with a common national taxonomy. There is an obligation under specification to contribute to the risk list. There is a requirement to use the confirmation of payee to identify a valid account.
That includes all new participants coming into the RTR directly as well as the first third-party exchange, which is Interac's e-transfer. All are mandatory.
