Yes, 100%.
I'll answer the interoperability bit first.
The way the system is set up right now, you have to go through Interac. When you go through there, they are very particular about what you can use, when you can use it and how you can use it, even if it is inefficient and does not yield the result you need in order to deliver on the promise you have made to consumers and that makes you successful elsewhere.
As I mentioned in my note, the forcing of the technology itself is extremely limiting, and the technology in and of itself, the access that the APIs grant you, is not on par with what's available elsewhere in the world. This is where innovation is required in the system itself, and if not, in offering something—a replacement or a parallel rail—in that sense.
On the fees, absolutely, the fees are opaque, and the fee structures are opaque. We know from talking to business owners and the present public that the fees they pay are not the same as what larger institutions pay. Definitely, as Mr. Kholodenko mentioned earlier, this hinders even somebody who wants to enter. If they don't know the cost somebody else is paying, how do they know if they are as competitive as somebody else and whether they can bring forward something that's more competitive?
My answer is absolutely yes to both questions.