The Canadian Bankers Association has published its response to the Department of Finance’s National Anti-Fraud Strategy discussion paper, supporting an initial multi-sector framework spanning financial services, telecommunications providers and digital platforms. It argues that a central regulator should coordinate baseline cross-sector expectations, supervisory alignment and oversight of external dispute resolution, while existing sector regulators continue to supervise and enforce sector-specific rules. The submission also backs baseline anti-fraud controls across sectors, including risk-based onboarding and identity verification, authentication, customer reporting channels, fraud monitoring, temporary intervention powers and consumer education. It says bank-only measures are insufficient because much fraud now originates through telecoms and online platforms before funds move through the financial system. The CBA says the initial scope should extend within financial services to credit unions, payment service providers, fintech firms, money services businesses, crypto asset service providers and payment networks, and within digital platforms to online marketplaces, dating platforms and internet infrastructure providers. It calls for clearer legal permissions and protections for intelligence sharing among regulators, law enforcement and private-sector firms, supported by common data standards, sharing agreements and centralized or federated data capabilities, and suggests a regulatory sandbox if uncertainty persists. On complaints and liability, it favors a commercial reasonableness standard, proportionate enforcement focused on systemic non-compliance, and a single escalation pathway for cross-party disputes. It also says the Canadian Anti-Fraud Centre should remain the national fraud reporting and intelligence hub, and that the proposed Financial Crimes Agency’s mandate should be clearly defined to avoid overlap. The association says it wants continued engagement with the Department of Finance as the strategy and framework are refined and implemented.