Enhanced Data Collection (EDC)

Through its Enhanced Data Collection (EDC) initiative, FSRA is modernizing the way it collects data from Credit Unions. It will improve the utility of the data for supervisory assessment as well as other applications such as stress testing and scenario analysis in assessing the impact of tariffs on credit unions, the adequacy of the DIRF, and strategic purposes in support of Principles Based Regulation (PBR) and Risk Based Supervision (RBS).

EDC will bring about two primary changes for credit unions:

The collection of instrument-level data, such as loans and deposits data.
The migration of all existing and new data collection, including instrument-level data, into one channel.

An overview of the EDC initiative can be found at the following link: EDC initiative

Some benefits of EDC:

Single channel for Credit Union management, board, and regulatory reporting
Available data and reporting to be used for sector benchmarking
Enhanced regulatory efficiency and data transparency to promote the sector’s long-term viability
Reduced manual burden for Credit Unions through automated data collection
Improved Deposit Insurance Reserve Fund (DIRF) adequacy assessment
Less focus and intensity by FSRA on lower risk Credit Unions using FSRA’s data-informed, risk-based supervisory approach
The potential for reduced capital requirements (for certain verifiably lower risk assets, beyond the current capital risk weightings)
Provide insights to Credit Union senior management and boards and promote better business decision making and strategic planning

FSRA is working with Credit Unions one-on-one for the implementation of EDC. FSRA has been actively engaging with all Credit Unions through a process known as Data Mapping and Technical Development (Data Mapping). This provides a dedicated forum for FSRA and Credit Unions to share information and track EDC readiness.

Regulatory and Risk Data Standard (RRDS)

The Regulatory and Risk Data Standard (RRDS) defines all data requirements for EDC in a standardized format. It contains information on the data points and how to report the data under EDC. This is a living document that will be updated periodically. The current version of the RRDS will have no modifications or updates for the duration of the onboarding phase so Credit Unions have a stable version to work with. The current version of the RRDS can be found here and is updated as of March 2025: RRDS Enhanced Dataset V5.1.7 [XLSX].

The data standard is a dictionary of data points that will ultimately improve data quality and make collecting, reporting, and using the data more efficient for both FSRA and Credit Unions.

FSRA consulted with the Technical Advisory Committee (TAC) for Credit Union Data Strategy and Digital Transformation on EDC and the development of the Regulatory and Risk Data Standard. More information on the TAC process can be found here: Technical Advisory Committee (TAC) for Credit Union Data Strategy and Digital Transformation.

In May 2025, FSRA held a Webinar outlining updates to the RRDS prior to onboarding Credit Unions to the EDC platform. These changes were implemented to incorporate feedback from the sector and other stakeholders. It included elements to reduce inconsistencies and improve system efficiency and data reporting accuracy. During the webinar, Credit Unions were informed of the updated onboarding plan and process, from a ‘Big Bang’, all-at-once approach to a gradual phased onboarding approach that is tailored to guide and support each Credit Union through the transition.

Onboarding

Through a one-on-one process, FSRA has onboarded Credit Unions across a variety of asset size and complexity onto the EDC platform.

Phase I onboarding requires Credit Unions to submit the first six schedules in RRDS which represent the instrument level data.

Phase II onboarding incorporates the remaining schedules listed in the RRDS. Credit Unions will supply both the instrument level data, and the aggregated financial metrics and financial reports. In instances where a Schedule does not apply to the business activities of an institution (such as, for example, Commercial Lending or Securitization), FSRA will provide a ‘nil return’ template to the Credit Union with which to file that Schedule.

To further support the onboarding process, FSRA has created a list of helpful instructions for institutions to assist in file generation and submission.

Monthly eblasts are provided to the sector to stay up to date on EDC developments
Frequently Asked Questions and a Helpful Hints Guide are contained in eblast #5

What is FSRA’s approach to EDC?

The Risk Data is nothing less than the business data that Credit Unions use to run their own business.

What type of data will be collected?

The data requirements are defined in the Regulatory and Risk Data Standard (RRDS). The RRDS consolidates all existing data reporting (Regulatory Data) and adds Risk Data templates. The Risk Data is nothing else but the business data that credit unions use to run their own business.

Regulatory Data is all information that is currently reported by Credit Unions such as the MIR, AIR and financial template data (such as, for example, LCR). Going forward these will be filed through the EDC system and Credit Unions will be required to start reporting this data through EDC from the time of onboarding.

Instrument-Level Data pertains to a specific instrument, such as the Date of Origination and the Outstanding Amount of a loan. Credit Unions will initially provide the instrument-level data as available at the time of onboarding, including data with missing attributes. In time, Credit Unions are expected to progressively enhance their data quality.

How frequently?

Will the MIR/AIR system be discontinued?

Yes, the EDC system will replace the MIR/AIR and other forms of data collection once the data is of acceptable quality and completeness.

Once Phase II onboarding is complete, Credit Unions will file concurrently through both EDC and legacy channels and will collaborate with FSRA on cross-channel validation. FSRA is expecting a minimum number of consecutive filings to be aligned between the two systems to be able to confirm the data integrity provided by the Credit Unions. The data filed through the EDC system must be of sufficient quality and integrity to allow for a Credit Union to stop filing on the legacy system. Once the last Credit Union has been successfully transitioned to EDC, the legacy portals will be decommissioned.

Do other regulators or related organizations collect instrument-level data?

Yes, in Canada these are some of the organizations that collect instrument-level data:

British Columbia Financial Services Authority (BCFSA) currently collects instrument-level data. The FSRA instrument-level data templates are based on the BCFSA’s.
Under the Canada Deposit Insurance Corporation’s (CDIC) Data and System Requirements, member institutions are required to identify, capture, organize and produce account-level deposit liability data.
Canada Mortgage and Housing Corporation (CMHC) collects instrument-level data on mortgages.
The Office of the Superintend for Financial Institutions (OSFI) collects instrument-level data on mortgages.

There is a general recognition among regulators around the world of the risk of weak and fragmented data and the need for enhanced data in the digital age. In 2013, The Basel Committee on Banking Supervision (BCBS) issued the Principles for Effective Risk Data Aggregation and Risk Reporting (RDARR) which sets expectations regarding management and reporting of risk data.

Various central banks and financial regulators around the world have initiatives to improve the effectiveness and efficiency of data collection.

The above is not a complete list, and many other regulators collect this information through internal or ad hoc requirements.

Can FSRA collect this data from Credit Unions under the Credit Union and Caisses Populaires Act 2020 (CUCPA)?

Will the data that FSRA proposes to collect be personal information under the Freedom of Information and Protection of Privacy Act (FIPPA)?

Would collection of the data under CUCPA sections 198 and 199 be authorized by FIPPA?

Yes, FSRA’s collection of the data is permitted under FIPPA. The data is necessary for assessing Credit Union risk profiles and the effective implementation of Principles Based Regulation and Risk Based Supervision. Section 38(2) of FIPPA permits the collection of information “necessary to the proper administration of a lawfully authorized activity”.

If someone were to make a freedom of information request to FSRA under FIPPA for the data FSRA proposes to collect from Credit Unions, what would the likely outcome of that be?