That's a great question.
We have a few provincially regulated entities in our membership who have raised similar questions. Our answer to any question like that is, to the extent possible, let's not create duplicative requirements where there is an equivalent level of protection administered by a provincial regulator. Let's recognize that as equivalent, so we don't need to make these regulated entities jump through unnecessary hoops.
My understanding of the open banking framework is that it is voluntary, so no one is going to force any requirements onto any entity that doesn't want to abide by them. I know that policy-makers at the Department of Finance have been in lengthy conversations with policy-makers at the provincial level to work out where the requirements are net new and they do need to be administered and where there is equivalence so they can recognize it.
That said, I can't speak to any outcomes of those discussions. I just know that they're happening.