Fractional AI Product Manager · Toronto, ON
Toronto fintech companies selling AI features into TD, Scotiabank, or Manulife encounter OSFI's model documentation requirements during vendor procurement. Shopify app developers building AI for merchants need specs that account for merchant usability, not just engineering feasibility. Canadian AI products need PIPEDA data use analysis before the feature ships, not after a privacy complaint.
A fractional AI PM writes the product spec and the regulatory documentation in the same document, before engineering starts. That combination saves the three to six weeks most Toronto AI teams spend retrofitting compliance documentation after a procurement team asks for it.
Fixed engagement, scope agreed before work starts.
Tell us about your Toronto AI product challenge.
Canadian AI compliance is not the same as US compliance, and the gap matters most for companies selling into the financial sector. OSFI Guideline E-23 applies to any model used by a federally regulated financial institution. A Toronto fintech selling an AI-powered credit scoring tool to Scotiabank is selling a model that the bank's model risk team will evaluate against E-23 before deployment.
The E-23 documentation requirements include a model development memo, independent validation evidence, and a monitoring plan. These are product PM responsibilities, not engineering responsibilities. The AI PM writes the model development memo. Engineering implements the monitoring. The spec defines both.
PIPEDA's purpose limitation principle adds a data use analysis to every AI spec where personal information is used as input. For a fintech using transaction data to train or operate a fraud model, the analysis determines whether that use falls within the original collection purpose. The analysis is short but required. Building it into the spec means legal reviews the analysis before development, not after a complaint.
The forthcoming AIDA creates prospective documentation obligations for high-impact AI systems. For Toronto companies building AI that makes consequential decisions about individuals, the spec documents the intended use and known risks now, so AIDA compliance is faster when the final regulation is in force.
Procurement teams at TD, Scotiabank, Sun Life, and Manulife evaluate vendor AI products with these specific questions.
A written description of how the model was built: the training data, the methodology, and the known limitations. OSFI E-23 requires this for any model an institution relies on. The fintech provides it; the institution reviews it.
Where model inference runs, whether Canadian data residency is maintained, and which third-party model providers the product uses. Canadian financial institutions ask about subprocessors for data privacy and regulatory reasons.
A written assessment of whether the AI feature's use of personal information is consistent with the original collection purpose under PIPEDA. One to two paragraphs, reviewed by legal, included in the vendor documentation package.
How model performance is monitored post-deployment, what signals indicate model drift, and what the response process is when performance degrades below the defined threshold. Part of the product spec, not a post-launch addition.
Shopify app developers face a different set of product spec requirements than fintech companies do. The user is a merchant, not a compliance officer.
The spec defines the maximum setup steps before the AI feature produces a useful output. A merchant cannot justify 30 minutes of configuration. The constraint is written in the spec and engineering builds to it.
When the AI feature makes a recommendation (restock, pricing, promotion), the spec defines the explanation format in terms that map to the merchant's business decisions, not model outputs.
The spec defines how a merchant corrects a wrong AI recommendation and how that correction improves future outputs. A feedback loop built into the spec is more valuable to merchants than a more accurate initial model.
Discovery call (1 hour)
We map the AI feature, the target buyer or user, and the Canadian compliance questions that apply: PIPEDA, OSFI, data residency. Fixed price quoted at the end of the call.
Spec and compliance drafting (weeks 1--4)
We interview product, engineering, and legal or compliance as needed. We write the product spec and the compliance documentation in the same document. Draft sent for review.
Review and handoff (weeks 5--8)
We incorporate feedback and finalize everything. The spec and all supporting documents are yours. No retainer, no ongoing obligation.
Describe your Canadian AI product challenge.
Tell us whether you are building for the financial sector, the Shopify ecosystem, or another market. We reply within one business day with a rough scope and price range.