# TRAMÉ LOOM — Canadian regulatory dossier **Purpose.** Every commercial claim on the LOOM site traces to a line in this file. If a claim is not here with a source, it does not go on the site. **Status.** Compiled 7 August 2026 from public sources. Dates, thresholds and penalty ceilings change. **Nothing here is legal advice.** Confirm with Canadian counsel before relying on any of it commercially, and re-verify before every material release. --- ## 1. The "2030 accessibility act" — what it actually is There is no single Canadian statute called the "2030 Accessibility Act." The 2030 date belongs to **Nova Scotia**, and it sits inside a stack of four separate regimes that a Canadian advisory firm can be caught by simultaneously. | Regime | Who it binds | The date that matters | |---|---|---| | **Nova Scotia *Accessibility Act*** (Bill 59, 2017) | Nova Scotia public sector and, progressively, the private sector | Goal of an **accessible province by 2030**; standards phased in by area. Built-environment standard enforcement began **1 April 2026**. | | **Accessible Canada Act** (2019) | Federally regulated organisations — banks, telecom/broadcasting, federal transport — plus federal bodies | **Barrier-free Canada by 2040.** Digital conformity: **5 Dec 2027** (federal government + mandatory training), **5 Dec 2028** (federally regulated private sector, incl. large entities of 500+ employees). | | **AODA** (Ontario, 2005) | Ontario public sector any size; private/non-profit with **50+ employees** for web obligations | Web accessibility (**WCAG 2.0 Level AA**) deadline **passed 1 Jan 2021** — already binding. Next Accessibility Compliance Report for private/non-profit orgs with **20+ employees** due **31 Dec 2026**. | | Provincial acts elsewhere | Manitoba, BC (*Accessible BC Act*), Saskatchewan, Newfoundland and Labrador | Varying standards and timelines — scope per client. | **Standard development in Nova Scotia** covers six areas: education, employment, goods and services, information and communication, public transportation, and the built environment. *Information and communication* and *goods and services* are the two that reach a financial advisory firm's client portal, statements and correspondence. ### Penalty exposure - **AODA:** up to **$100,000 per day** for a corporation; up to **$50,000 per day** for individuals, unincorporated organisations, or directors and officers. Fines accrue until the violation is resolved. - **Accessible Canada Act:** enforcement via the Accessibility Commissioner, the CTA and the CRTC, with penalties up to **$250,000 per violation**. ### Obligations beyond "make the website work" Covered organisations must **publish a three-year accessibility plan**, **consult people with disabilities**, **run a feedback process**, and **publish annual progress reports**. Organisations with fewer than 10 employees are exempt from the planning and reporting requirements under the ACA. > **Product consequence.** The plan, the feedback intake, the progress report and the conformance evidence are *recurring artefacts*, not a one-time audit. That is why SELVEDGE is a module with an SLA and a queue rather than a checkbox — and it is why it is defensible revenue. ### Sources - [Access by Design 2030 — Government of Nova Scotia](https://novascotia.ca/accessibility/access-by-design/) - [Nova Scotia Accessibility Act — Nova Scotia Legislature (Bill 59)](https://nslegislature.ca/legc/bills/62nd_3rd/3rd_read/b059.htm) - [Accessibility Act Compliance — Government of Nova Scotia](https://novascotia.ca/accessibility/compliance/) - [The Accessible Canada Act: deadlines are closer than you think — Deque](https://www.deque.com/blog/the-accessible-canada-act-deadlines-are-closer-than-you-think/) - [ACA compliance overview — Allyant](https://allyant.com/compliance/aca-compliance-the-accessible-canada-act/) - [AODA penalties and fines — Recite Me](https://reciteme.com/us/news/aoda-compliance-fines/) - [AODA website accessibility requirements — Accessibility.Works](https://www.accessibility.works/aoda-website-accessibility-requirements/) --- ## 2. Total Cost Reporting — the reporting wedge The **CSA** and **CCIR** published enhancements to total cost reporting for investment funds and individual segregated fund contracts. - **Effective 1 January 2026** (subject to ministerial approvals). - **Clients receive the first enhanced annual reports for the year ending 31 December 2026** — i.e. delivered in early 2027. - Scope: investment funds (excluding private funds and LSIFs), plus new cost and performance reporting for individual variable insurance contracts. Reporting obligations touch **dealers, advisers and investment fund managers**. - Purpose: surface **ongoing embedded costs** — management fees, trading expenses — to investors and policyholders. - Related: CIRO has published enhanced cost reporting rule amendments. > **Product consequence.** A firm whose fee ledger and statement engine are separate systems has a reconciliation project in Q1 2027. A firm on LOOM has a render. This is the single cleanest "why now" in the pitch, and it expires — which is why the sales motion is dated. ### Sources - [CSA — Canadian financial regulators enhance cost reporting requirements](https://www.securities-administrators.ca/news/canadian-financial-regulators-enhance-cost-reporting-requirements-for-investment-funds-and-individual-segregated-fund-contracts/) - [OSC — same notice](https://www.osc.ca/en/news-events/news/canadian-financial-regulators-enhance-cost-reporting-requirements-investment-funds-and-individual) - [Stikeman Elliott — Enhanced Total Cost Reporting coming in 2026](https://stikeman.com/en-ca/kh/canadian-securities-law/enhanced-total-cost-reporting-for-investment-funds-and-segregated-funds-coming-in-2026) - [CIRO — Enhanced Cost Reporting](https://www.ciro.ca/newsroom/publications/enhanced-cost-reporting) --- ## 3. Payments — the billing rails ### Pre-authorized debits (Payments Canada **Rule H1**) - A **PAD agreement** between payor and payee is required **before the first withdrawal**; it must contain the mandatory provisions under Rule H1. It may be written, electronic or verbal. - **For variable-amount PADs, the payor must be notified at least 10 days before the debit occurs.** - The current Rule H1 took effect **3 October 2022**; payees had until **31 December 2023** to comply with the revised rule. > **Product consequence — the sharpest feature in the product.** An advisory fee charged on AUM is *variable by definition*. Every quarter, every household, a compliant firm owes a 10-day notice. Doing that by hand across a 1,000-household book is where firms quietly fall out of compliance. LOOM issues it on schedule, versions the agreement, and keeps the evidence. ### Real-Time Rail (RTR) - RTR **by-law and rules approved**, coming **into force 24 August 2026**. - **Launch targeted for Q4 2026** following ministerial approval of the legal framework. - The Interac-provided exchange component was completed in June 2023. - History: originally promised for 2019, repeatedly delayed. **Do not build a plan that requires the launch date to hold.** LOOM's position is rail-agnostic — ISO 20022 messaging modelled up front so adoption is configuration, not migration. ### Sources - [Payments Canada — Rule H1, Pre-Authorized Debits (PDF)](https://www.payments.ca/sites/default/files/h1eng.pdf) - [Payments Canada — Amendments to Rule H1](https://www.payments.ca/amendments-rule-h1-facilitate-pre-authorized-debit-pad-user-experience) - [Payments Canada — Critical milestone: by-law and rules approved for the RTR](https://www.payments.ca/critical-milestone-achieved-law-and-rules-approved-canadas-real-time-rail) - [Payments Canada — Real-Time Rail payment system](https://www.payments.ca/systems-services/payment-systems/real-time-rail-payment-system) - [BetaKit — Canada's RTR will launch this year](https://betakit.com/canadas-real-time-rail-system-will-launch-this-year-after-achieving-critical-milestone/) --- ## 4. Market sizing anchor - **CIRO** sets and enforces rules for **262 Canadian investment and mutual fund firms and approximately 108,000 representatives**. *(Figure appears to date from 2024 — re-verify against CIRO's current published number before using it in a deck.)* - That is the addressable seat count for a per-advisor product, before counting portfolio managers registered directly with provincial commissions and the exempt-market and insurance channels. **Source:** [CIRO](https://www.ciro.ca/) --- ## 5. Competitive reference — Investipal Benchmarked 7 August 2026 from [investipal.co](https://www.investipal.co/). | | Investipal | TRAMÉ LOOM | |---|---|---| | Headline | AI for financial advisors streamlining **proposals** | AI for financial advisors streamlining **billing & payments** | | Modules | Statement scanner, proposal generation, IPS, onboarding, AI-driven engagement, AI assistant (Alpha), billing & payments | Same seven surfaces, reordered around billing — plus **accessibility conformance** as a first-class module | | Pricing | Sales-led; pricing page routes to a contact form | **Published list price in CAD**, with the usage line shown | | Proof | Named client testimonials, 16 partner logos, T3 9.67/10, Wealth Professional 5-Star 2026, SOC 2 Type II | **None claimed** — pre-launch, and the site says so | | Canadian specificity | Serves Canadian firms; US-shaped product | PAD Rule H1 notices, TCR-shaped statements, RTR-ready, EN/FR, Canadian data residency | **Honest read on the competitive position.** Investipal has customers, certifications and awards; LOOM has none of those and must not imply otherwise. What LOOM has is a **narrower, dated, Canadian obligation set** that is expensive for a US-shaped product to retrofit and cheap for us to make native — plus a cost base that lets us publish a price they route to a form. **Where the moat is thin:** any competitor can add PAD notices in a quarter if a customer demands it. The durable part is the *accessibility conformance artefact pipeline* — audit, ACR/VPAT per release, tagged-document generation, remediation SLA — because that is an ongoing programme with recurring cost, not a feature ticket. Fund it or the differentiation evaporates. --- ## 6. Standing constraints on all LOOM material 1. **Tramé Tech is a software vendor.** It is not registered as a dealer, adviser or investment fund manager in any Canadian jurisdiction. No LOOM surface — copy, demo, AI output — may recommend a security or a course of action, or read as advice. 2. **No unearned proof.** No testimonials, logos, awards or certifications until they exist. SOC 2 is described as *in progress with a scheduled observation window*, never as held. 3. **Every regulatory number carries its source and its date**, and is hedged as subject to change. 4. **Accessibility claims are demonstrated, not asserted.** If the marketing site itself fails WCAG 2.2 AA, the claim is a lie and the legal exposure is ours, not the customer's. 5. **Illustrative figures are labelled illustrative.** The fee-run panel on the site says so; the ROI calculator states every assumption inline.