Okay, so as a consumer, when I buy my financial services, I have zero choice as to what company I get with my bank account that does that. To me, that looks like market dominance, especially when Interac is probably 90% to almost 100% of everything that happens. It's pretty clear it's well above your 30% threshold for Interac.
This will be part of your competition, but we've had evidence that “Membership has its privileges”, so to speak, to quote a former American Express credit card marketing firm. The membership here is the four banks and Desjardins that own Interac; they are the board that governs it and they get preferential rates. If you're not there and if you're trying to come in as a credit union or as somebody who's not part of the membership or the club of Interac, as a financial institution, you seem to get charged seven, eight, nine or 10 times the rate for the fees.
If you have 100% market dominance, if the financial services customers have no choice in what service comes with their bank account and if the fees charged for those who aren't part of the Interac club are 10 times what they are for those who are in, that sure looks like a monopoly power that needs to be broken up.