MQCC responds to the "Canadian Mortgage Brokers Association" (CMBA) response to "The Advisory Committee to the Open Banking Review Financial Institutions Division; The Financial Sector Policy Branch; Department of Finance Canada"
Tue, Feb 19, 11:01 PM
Tue, Feb 19, 11:01 PM
Samantha Gale, LLB
CEO
Canadian Mortgage Brokers Association – British Columbia
101-1765 West 8th Ave | Vancouver, BC | V6J 5C6
o: 604-408-9989 | w: cmbabc.ca
Samantha,
Good evening;
Your letter was excellent: https://gallery.
You might not know this, but Canada's first functional "open banking system" was developed by yours sincerely and commercialized for global access on May 9, 2005 at www.privatelender.org; Canada's Private Lending Network. Built on seminal "principles of 'BlockChain'" first applied in commerce for development of a "peer-to-peer electronic finance system". The MQCC "open banking system" is Canada's ONLY "open banking system" that is continuously registered to Canada's National Standard for Quality Management Systems: ISO 9001:2015, continuously since May 9, 2008. According to Canada's Crown corporation, the Standards Council of Canada, MQCC's methods and products as "better, safer and more efficient"; for the scope of Mortgage Banking ("lending" in Canada) and Mortgage Brokerage Services.
Minister of Finance learned of MQCC's system in 2016; same with Jeremy Rudin, Superintendent of OSFI, so did MBRCC and host of others. You may want to read the latest letter from MQCC to Minister Morneau re: open banking here:
- your comment about the privacy issues; the MQCC Cyberlockchain™ would have helped the companies like Olympia Trust who were recently cyber attacked. See the blog article to Minister Morneau for an embedded brochure re: the MQCC Cyberlockchain™.
- RE: Regulatory Blurring with Regulated and Un-regulated Service Providers - MQCC developed a harmonized protocol BlockChain algorithm to address this.
- RE: Regulatory Blurring over Federal and Provincial Jurisdictions - the Mortgage Broker Context - MQCC developed a harmonized protocol BlockChain algorithm to address this.
• review the law around data ownership with a view to resolving its legal ambiguity, and more importantly ensure that consumers have the power to share data with service providers
- Yes. Registered to the National Standard of Canada since May 9, 2008, MQCC's system and technology address this concern.
• third party entities which hold financial data should have to meet security standards for data retention and be held accountable for breaches of such standards
- Correct. Registered to the National Standard of Canada since May 9, 2008, MQCC's system and technology address this concern.
• ensure that there is a consumer protection frame work in place which is guided by an understanding of federal and provincial jurisdictions governing financial services, and the consumer protection rationale behind that regulation.
- Correct. MQCC (and Bungay International Inc.) had to create private regulations to harmonize on pan-jurisdiction, pan-regulatory, inter-level (federal/provincial) basis.
• ensure that there is a consumer protection frame work in place to determine how unregulated third party service providers will be accountable when regulated financial service providers parse out bits and pieces of their services to them.
- Correct. The MQCC System and technology accounts for this requirement through a 'data artifact control algorithm'.
You are a lawyer so you will appreciate that MQCC's system is successfully litigation tested by members of the International Council of Legal Regulators.
PEMI® Private Equity Mortgage Institute
Also, now that you and I are on this subject; you might want to learn about the PEMI® program for Chartered Private Equity Mortgage (PEM®) Professionals. A little program yours sincerely started at least as early as 2014; bringing safety to private lending for Canadian and global consumers. PEMI® is the only industry in the world whose members operate in a decentralized manner, using consenus, proof-of-work systems and technology (ie: "principles of 'BlockChain'") the world was not ready for it, but now it might be. www.peminstitute.org.
On a fee-basis, MQCC provides consulting to lawyers (ie: you), governments, legislators, policy-makers, regulators and industry leaders on a peer-to-peer basis. If you are interested in learning more, let me know. It won't be cheap, but as you can imagine - it will be worth it. I have already provided training to lawyers employed by law enforcement agencies in Canada, and lawyers employed by members of the Canadian Securities Administrators.
PS: since you and I are both from UK; you should also look into my correspondence with the UK government; they are interested in learning more about the MQCC system.
MQCC responds and introduces itself to the UK Financial Conduct Authority (FCA) and International Members of the Global Financial Innovation Network GFIN
Best,
/s/
Anoop Bungay
If you have questions, please contact me at your convenience. In order to prevent errors and omissions, email is the preferred choice of communication.
Thank you for choosing MortgageQuote Canada Corp., 'Proud sponsor of the Canadian dream.'®
Sincerely yours,
MortgageQuote Canada Corp. (mortgagequote.ca)
Financial services for whom time is worth more than money.™
Alberta (AB) * British Columbia (BC) * Ontario (ON)
ON Brokerage License #12279
"Proud Sponsor of the Canadian Dream"®
An ISO 9001:2015 Registered Company
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