Every decision is made by deterministic rules that are unit tested. The same file always gets the same answer, and every answer is explained in plain language. AI never sets a limit, a price or an approval.
Reading cash flow
Berry reads twelve months of synthetic transactions in an FDX-inspired format. Transfers between the applicant's own accounts are set aside, and a bounced payment cancels against its reversal so it isn't counted twice; the bank's fee stays as a real cost. From that it measures:
average and median monthly income, spending and cash left over;
how much income varies month to month (coefficient of variation) and its recent trend;
days of spending the balance covers, bounced payments in 90 days and 12 months, and existing loan payments;
debt service coverage: cash available for all debt payments divided by those payments, including the new one.
Income is classed as salaried, pension, gig, seasonal (the best three consecutive months bring at least 50% of a year's income), invoice-based (mostly direct client payments, a few a month), steady business, or irregular. Revolving credit is assessed at 3% of the limit per month (a setting in each lender's policy) Illustrative.
How each lender decides
Each lender is a thin rule layer over the same measurements. Its limits, rates and thresholds live in configuration, shown here exactly as the engine uses them. Every value is Illustrative: chosen to make three lending styles visible, not taken from any real institution.
Northgate Credit Union
Weighs membership (tenure, products held and deposits). Reads seasonal income over a whole year and sizes a seasonal line so peak-season surplus repays it. Gives thin-file members with steady pay a starter limit. Strong members can be approved slightly below the standard coverage minimum; that approval moves up one authority tier. Every approval names who signs off.
Minimum debt service coverage
1.20x
Coverage minimum for strong members
1.10x
Relationship score counted as strong
0.6 of 1
Years of membership for full tenure credit
5
Peak-season surplus must cover a seasonal line
1.25x
…for strong members
1.15x
Most bounced payments allowed in 90 days
2
With recent bounces, limit capped at months of net cash flow
4
Highest card utilization allowed
90%
Unsecured revolving limit for non-members
$2,000
Starter limit for thin-file members
$2,000
Credit history under this many months is a thin file
12 months
Revolving credit assessed at this share of the limit each month
3%
Limits under $10,000 round down to steps of
$500
Limits under $50,000 round down to steps of
$1,000
Larger limits round down to steps of
$5,000
Relationship score: weight on years of membership
50%
Relationship score: weight on products held
30%
Relationship score: weight on deposits
20%
Products held for full product credit
3
Seasonal operating line term
12 months
Who signs off
Member Service Representative: up to $10,000
Lending officer: up to $50,000
Branch Manager: up to $250,000
Credit Committee: above that
Policy version 1, effective 2026-10-01
Kite
Cash flow only: no relationship factors. Sizes limits on the median month, so a few big months can't inflate them. Hard cut-offs on recent bounced payments and on months where more goes out than comes in. Doesn't structure around seasons, so a seasonal request gets a standard line instead.
Minimum months of account history
3
Most bounced payments allowed in 90 days
1
Highest card utilization allowed
90%
Minimum coverage, measured on the median month
1.30x
Personal revolving limit, in median months of net cash flow
4.5x
Business revolving limit, in median months of net cash flow
2x
Assessed payment may use at most this share of the median month
50%
Starter cap for thin files without a foreign report
$1,000
Credit history under this many months is a thin file
12 months
Revolving credit assessed at this share of the limit each month
3%
Limits under $10,000 round down to steps of
$500
Limits under $50,000 round down to steps of
$1,000
Larger limits round down to steps of
$5,000
Policy version 1, effective 2026-10-01
Aspen Bank
Fixed thresholds checked in order, and a decline lists every one that failed. Approvals come with a documentation checklist and standard conditions. Gig and invoice-based income is referred for two years of tax returns.
Minimum months of account history
12
Minimum months of Canadian credit history
24
Highest income variability (CV) allowed
0.35
Minimum debt service coverage
1.25x
Most bounced payments allowed in 12 months
1
Highest card utilization allowed
90%
Revolving credit assessed at this share of the limit each month
3%
Limits under $10,000 round down to steps of
$500
Limits under $50,000 round down to steps of
$1,000
Larger limits round down to steps of
$5,000
Policy version 1, effective 2026-10-01
Results on 37 planted test cases are published under Test results.
What it deliberately ignores
No decision uses any of these. They are kept out of the engine's input entirely:
Name
Age and date of birth
Gender
Nationality and immigration status
Postal code and province
One input can track nationality: a foreign credit report. Programs cover only some countries, so whether a report exists depends on where someone has lived. Berry uses only the report's rating (good or better counts as credit history), never the country.
A test hands the engine every applicant with these fields shuffled and checks that no decision changes; it was checked by planting a bias and watching the test fail. A large cash deposit is flagged for FINTRAC review but is never a credit factor, and a test proves the decision is the same with or without the flag.
Verification and the friction trade-off
Identity and business checks are simulated on synthetic data, against a fictional watch list and registry. Of 14 applicants, 12 clear automatically in seconds and 2 go to a person: one for a near-match on the watch list and one for an overdue annual filing. A manual review takes hours, which is why the goal is to send people only the cases that need judgment.
Money movement
Every approved loan is serviced in a simulation that runs from funding to the end of December 2027. Money is kept in a double-entry ledger in whole cents: every entry's debits equal its credits, entries are never edited, and corrections are reversing entries. Funding goes by AFT (next business day), Interac e-Transfer, or the Real-Time Rail, which is simulated in Berry (it launches in phases from Q4 2026); instant rails need a simulated account check first.
Repayments are pre-authorized debits. When one is returned unpaid, Berry follows a playbook based on the Payments Canada return reason (Standard 007, checked October 12, 2026): an NSF return is retried once, on the borrower's next payday where possible, and never inside the 2-business-day window in which their bank could charge another NSF fee; an account problem means asking for new banking details instead. Repeated returns bring a hardship offer, and a loan still unpaid 120 days after a missed payment is charged off (configurable) Illustrative.
A seasonal operating line is a limit, not a lump sum. The borrower spends its own cash first, and the line is drawn only to keep one month's average spending in the account Illustrative, sized from the borrower's own past year. Interest is charged only on what's drawn, and the line is repaid from peak-season sales. In the base scenario Hollis Family Farm draws about half its limit at peak; the rest is headroom for a poor harvest or a price drop.
Berry's lenders charge no fee of their own for a returned payment; the simulation shows what the borrower's bank charges. The NSF fee rules in force since March 12, 2026 (a $10 cap, one fee per 2 business days, none when overdrawn by less than $10) apply to personal accounts at federally regulated banks, so Berry applies them only there. Provincially regulated credit unions set their own fees: for borrowers who bank at one, Berry uses an illustrative fee, labelled “provincially regulated — fee illustrative”.
Foreign credit reports and the credit-building path
Some newcomers can bring credit history with them: foreign credit report programs import history from a limited set of countries (for example, India was first in Equifax Canada's program). This planted applicant has a thin Canadian file but history from a covered country. Switch the report off to see how much each lender's answer depends on it.
Newcomer with credit history from a country covered by foreign credit report programs, and a thin Canadian file. Asking for a credit card of $3,000, with 4 months of Canadian credit history.
Northgate Credit Union
Approved
$2,000
For new customers we start unsecured credit at up to $2,000.
Kite
Approved
$3,000
After your current bills, you'd have about 17.32x what the new payment needs.
Aspen Bank
Approved
$3,000
After your current bills, you'd have about 20.82x what the new payment needs.
Many newcomers come from countries no program covers yet. For them, Berry's credit-building path fills the gap foreign credit reports don't cover: a starter limit sized on steady cash flow, and milestones (six on-time payments for a limit review; twelve months for an unsecured line) shown on the applicant's file. Daniel's file shows it.
Known limitations, and what would change in production
All applicants, institutions, accounts, watch lists and registries are synthetic or fictional. No real bank, bureau or identity service is connected.
Rates, limits, thresholds and authority tiers are illustrative. A real lender would calibrate them on its own loss history and risk appetite.
The accuracy score shows the engine applies its stated policies; expectations and engine share an author, so it says nothing about real credit performance.
The AFT file is ASCII, not EBCDIC, and isn't for submission; payment type codes from Standard 007 were not checked.
Business days skip weekends and nine federal holidays the clearing systems are commonly published as closing on; Payments Canada's own calendar for 2026–2027 could not be read, so the holiday calendar is illustrative.
Servicing is simulated: settlement and return timing, retry policy by return reason, interest accrual and the credit union NSF fee are illustrative.
Three provinces' credit union deposit insurance limits could not be read from the official sites and are shown as Illustrative.
In production: real consented data, after accreditation under the consumer-driven banking framework, bureau data alongside cash flow, model monitoring, adverse-action notices reviewed by compliance, and human review of referrals and exceptions.
111 of 111 planted decisions match the expected outcome (100%), across 37 cases and three lenders. The expectations and the engine share the same author, so this shows the rules are applied as written, not that they're good lending. Outcomes and approvers are scored; limits aren't scored, because the cases were written to expect an outcome, not an amount. Each actual limit is shown below.
What the score means
The engine reproduces the outcomes its rules were designed for. It does not mean the rules are the right ones, or that these loans would be repaid.
Each planted case is a synthetic applicant built to test one policy: clean approvals, clear declines, and edge cases just either side of each lender's thresholds. The expected outcome for every case was written from the case design and each lender's stated policy before the engine was run on it, and the engine never reads those expectations. A match shows the engine applies its stated policies correctly. It does not show the policies are good lending: the expectations and the engine were written by the same author, and real credit performance can only be measured on real outcomes.
Two cases where the answer is debatable
Both match their expected outcome, so they count as correct above. A reasonable lender could still decide differently. The engine's answers are unchanged; here is the case for each side.
A small business paid by client invoices, with steady months
Planted case B07 · Aspen Bank
The engine's answer
Aspen Bank refers it: when income comes from invoices, its policy asks for two years of Notices of Assessment before deciding. Northgate Credit Union approves $15,000; Kite approves $10,000.
The strongest argument for a different answer
The bank data already answers the question the tax returns are meant to answer. Over 12 months, income varied by 9% from month to month, there were no returned payments, and the business keeps about 70 days of spending in the bank. At Northgate Credit Union's proposed payment, cash flow covers it 10.45x over. Asking for two years of returns adds days and work for a file the bank data already shows is strong.
What a lender would need to see to change it
Either the two years of Notices of Assessment the policy asks for, or a policy change that accepts at least 12 months of verified account income for invoice earners whose income varies less than a set amount. That's a change Aspen Bank would make in the Policy tab, with its impact on other cases shown first.
A long-standing member asking for a personal loan, with coverage just under the standard minimum
Planted case P19 · Northgate Credit Union
The engine's answer
Northgate Credit Union approves $10,000 as a relationship exception: coverage is 1.18x, under the standard 1.20x but above the 1.10x allowed for a strong relationship (16 years, 4 products). Because it's an exception, sign-off moves up one authority tier (Lending officer). Kite approves $3,500; Aspen Bank approves $9,000.
The strongest argument for a different answer
The 1.18x is an average, lifted by a few stronger months. In a typical month the cash left over ($174.25) covers the $317.96 payment only 0.55x, which is why Kite, looking at the typical month, offers $3,500. A membership of 16 years shows commitment, not spare cash: a smaller loan would leave more room in an ordinary month.
What a lender would need to see to change it
For a standard approval with no exception: coverage of 1.20x, either from slightly stronger average cash flow or a smaller loan of about $9,800. For a smaller offer or a decline: returned payments, a weaker relationship, or a typical month that can't carry the payment once other debts are counted.
By lender
Northgate Credit Union
100%
37 of 37 cases
Kite
100%
37 of 37 cases
Aspen Bank
100%
37 of 37 cases
FINTRAC large cash checks: 3 of 3 planted cash cases flagged as expected.
Misses
No open misses. Every planted decision currently matches its expected outcome.
Found and fixed during development
B07 · Aspen Bank: expected refer, engine gave approve (2026-10-11)
Cause. The engine classified invoice-based income by how much it varied, so even invoice income looked like a steady business and skipped Aspen's tax-return referral. Invoice-based describes how income arrives (a few direct client payments a month), not how variable it is.
Fix. Income is now classed as invoice-based when most of it is direct client payments arriving a few times a month. Card-processor settlements got their own transaction category so weekly card batches are not mistaken for invoices. Expectation unchanged.
Every case
Expected and actual outcome for every planted case and lender, with the actual limit
Case
Northgate Credit Union
Kite
Aspen Bank
Expected
Actual
Expected
Actual
Expected
Actual
B01Steady business, clean, asking for exactly the Lending officer tier limit.
approve
approve $50,000
approve
approve $50,000
approve
approve $50,000
B02Steady business, clean, just above the Lending officer tier limit.
approve
approve $55,000
approve
approve $55,000
approve
approve $55,000
B03Seasonal business; the off-season still breaks even.
approve
approve $40,000
approve
approve $10,000
decline
decline
B04Strongly seasonal; most months lose money outside the peak.
approve
approve $40,000
decline
decline
decline
decline
B05Seasonal business asking for a line larger than its peak season can repay.
approve
approve $65,000
approve
approve $6,500
decline
decline
B06Invoice-based business with very uneven months.
approve
approve $15,000
approve
approve $12,000
decline
decline
B07Invoice-based business with fairly even months.
approve
approve $15,000
approve
approve $10,000
refer
refer
B08Steady business with two bounced payments in the last 90 days.
approve with conditions
approve with conditions $17,000
decline
decline
decline
decline
B09Steady business with three bounced payments in the last 90 days.
decline
decline
decline
decline
decline
decline
B10Business spending more than it brings in.
decline
decline
decline
decline
decline
decline
B11Large, strong practice financing $400,000 of equipment.
approve
approve $400,000
approve
approve $150,000
approve
approve $400,000
B12Cash business with one single cash deposit of $12,000.
approve
approve $20,000
approve
approve $20,000
approve
approve $20,000
B13Cash business with two deposits totalling $10,500 within 24 hours, across midnight.
approve
approve $20,000
approve
approve $20,000
approve
approve $20,000
B14Cash business whose largest day is a $9,900 deposit: just under the reporting threshold.
approve
approve $20,000
approve
approve $20,000
approve
approve $20,000
B15New business with nine months of history, otherwise healthy.
approve
approve $25,000
approve
approve $25,000
decline
decline
B16Growing business whose existing debt leaves little room for a new loan.
approve
approve $85,000
approve
approve $46,000
approve
approve $65,000
P01Clean salaried member with plenty left over each month.
approve
approve $10,000
approve
approve $10,000
approve
approve $10,000
P02Clean salaried non-member, small loan.
approve
approve $5,000
approve
approve $5,000
approve
approve $5,000
P03Three bounced payments in the last 90 days.
decline
decline
decline
decline
decline
decline
P04One bounced payment in the last 90 days, otherwise clean.
approve with conditions
approve with conditions $5,500
approve
approve $6,000
approve
approve $6,000
P05Two bounced payments in the last 90 days.
approve with conditions
approve with conditions $5,500
decline
decline
decline
decline
P06Two bounced payments seven to nine months ago, none since.
P08Thin credit file (5 months), steady pay, not a member.
decline
decline
approve
approve $1,000
decline
decline
P09Thin Canadian file, but an imported foreign credit report is available.
approve
approve $2,000
approve
approve $3,000
approve
approve $3,000
P10Only seven months of account history, long credit file.
approve
approve $5,000
approve
approve $5,000
decline
decline
P11Steady gig income from daily payouts.
approve
approve $2,000
approve
approve $3,000
refer
refer
P12Gig income with two bounced payments in the last 90 days.
approve with conditions
approve with conditions $3,000
decline
decline
decline
decline
P13Retiree on a workplace pension, long-time member.
approve
approve $10,000
approve
approve $7,000
approve
approve $10,000
P14Credit cards at 95% of their limits and climbing.
decline
decline
decline
decline
decline
decline
P15Credit cards at about 85% of their limits, stable.
approve
approve $5,000
approve
approve $5,000
approve
approve $5,000
P16Stable pay, but only about $250 a month left over.
approve
approve $7,000
approve
approve $2,000
approve
approve $6,500
P17Spends more than they earn every month.
decline
decline
decline
decline
decline
decline
P18Existing loan payments take almost everything left over.
decline
decline
decline
decline
decline
decline
P19Long-time member whose coverage sits just under the standard minimum.
approve
approve $10,000
approve
approve $3,500
approve
approve $9,000
P20High earner asking for more than any lender's personal loan maximum.
approve
approve $50,000
approve
approve $20,000
approve
approve $50,000
P21Newcomer with credit history from a country covered by foreign credit report programs, and a thin Canadian file.
approve
approve $2,000
approve
approve $3,000
approve
approve $3,000
Engine 0.1.0 · policy versions Northgate Credit Union v1, Kite v1, Aspen Bank v1 · synthetic data as of 2026-09-30
Regulatory status
Status as of October 12, 2026. Each row links to its source and shows when it was last checked. Sources that aren't a regulator, government body or Payments Canada are marked as such. Live means in force; Enacted, not in force means passed into law but not yet in effect; In draft means proposed; Launching means announced and rolling out; Illustrative means Berry could not confirm it from an official source.
NSF fee rules (personal accounts at federally regulated banks)
Live
For personal deposit accounts at federally regulated banks: NSF fees capped at $10; at most one NSF fee per account in a period of 2 business days; no NSF fee when the account would be overdrawn by less than $10. Provincially regulated credit unions set their own fees.
In force March 12, 2026
In Berry (applied):When a simulated debit is returned NSF, Berry shows the borrower's own bank fee: these rules for personal accounts at banks; for credit union accounts an illustrative fee, labelled 'provincially regulated — fee illustrative'. Retries are never scheduled inside the 2-business-day window. Business days skip weekends and federal holidays (an illustrative calendar).
Rules for pre-authorized debit (PAD) agreements: mandatory agreement elements (Appendix II), confirmation at least 10 calendar days before the first debit, 10 days' pre-notification of changes and variable amounts, prominent waiver clauses, cancellation, and recourse of 90 calendar days (personal) or 10 business days (business).
Amendment 13 effective July 27, 2026
In Berry (applied):Repayment schedules follow the confirmation and pre-notification timing; the agreement checklist shows every Appendix II mandatory element and the verbatim recourse statement.
Note: Appendix IV (confirmation wording) was only skimmed; Berry does not reproduce it.
Fixed-width file format for automated funds transfer, encoded in EBCDIC, with record types including header (A), credit (C), debit (D) and trailer (Z) records of 1,464 characters. The standard defines others that Berry doesn’t use.
Amendment 23 effective July 22, 2024
In Berry (simulated):Berry generates a sample disbursement file in the A, C and Z layouts from the standard, in ASCII rather than EBCDIC. Illustrative: not for submission.
Note: Amounts in cents and the mandatory flag on some credit-record fields are inferred from the standard's sample and tables, not stated outright.
Three-digit codes on returned AFT and PAD items, e.g. 901 NSF (Debit Only), 903 Payment Stopped/Recalled, 905 Account Closed, 907 No Debit Allowed, 914 Incorrect Payor/Payee Name. The standard applies to both AFT and ISO AFT transactions.
Standard 007, amendment effective July 3, 2026
In Berry (simulated):Simulated returned debits use these codes with their official labels. Which returns Berry retries (only 901 and 908) and which come back before settlement is Berry's own illustrative policy.
Note: The standards don't say which return reasons may be re-presented, so Berry's retry policy by reason is illustrative.
Reporting entities report receiving $10,000 or more in cash in one transaction, or in two or more amounts within a consecutive 24-hour window by or for the same person or entity; reports are due within 15 calendar days.
In Berry (simulated):Cash deposits are checked for candidates and routed to a review queue. A compliance flag only, never a credit factor; Berry's report summary is illustrative, not a filing.
Eligible deposits at CDIC members are insured up to $100,000 per eligible category, per member institution. Members include banks and federally regulated credit unions; provincially regulated credit unions are not members.
In Berry (context only):Shown as context for deposit protection at Aspen Bank.
Deposits at provincially regulated credit unions are protected by the deposit insurer of the credit union’s province, not CDIC. Coverage differs by province: confirmed limits range from $250,000 (per category, or per member in Prince Edward Island) to unlimited.
In Berry (context only):Northgate is described as a provincially regulated credit union whose coverage depends on its province; a per-province table shows only confirmed limits, with the rest marked Illustrative.
Note: BC, Ontario and Quebec limits could not be read from the official sites (access blocked) and are marked Illustrative in the table.
The legal framework for consumer-driven (open) banking. Most provisions, including consent, are not yet in force; regulations are required to bring the Act into force.
Royal assent March 26, 2026 (S.C. 2026, c. 3, s. 224); most provisions not yet in force
In Berry (simulated):Berry's consent screen and dashboard are built around the framework's consent principles. Berry is not accredited and connects to no real institution.
Express consent may be valid for no more than 12 months after it is obtained (Act s. 86), with renewal within seven days (s. 87); draft regulations add triggers for earlier renewal (s. 44).
Act s. 86, not yet in force
In Berry (applied):Berry's simulated consents expire within 12 months and the consent screen says so.
Proposed regulations: accreditation first, then read-only data sharing starting with deposit and payment accounts, then lending accounts, then registered and non-registered accounts. Write access (payment initiation) is left for a later phase; the screen-scraping prohibition will not come into force until further consultation.
Published for comment June 27, 2026 (Canada Gazette, Part I); comments closed after 60 days
In Berry (simulated):Data requests are limited to what a decision needs, and the screen shows what was not requested.
Payments Canada's new real-time payment system, launching in Q4 2026 with the first direct participants; two sequential phases will then migrate Interac e-Transfer volumes.
Initial launch Q4 2026
In Berry (simulated):Funding by Real-Time Rail is simulated. Lenders cannot fund on it today.
Press reports expect every participant to have access to the Real-Time Rail some time in 2027. Payments Canada has not published dates for the phases after the Q4 2026 launch.
In Berry (context only):Mentioned as a press report only; no Berry feature depends on it.
Note: Press-reported, not from Payments Canada. Earlier versions of this row cited a 2027 Interac e-Transfer migration and Q3 2027 full capacity; no source we could read confirms either, so they were removed.
Foreign credit history in a bank newcomer program (example)
Live
One large Canadian bank's newcomer program can use credit history from a listed set of countries, through a foreign credit data provider; the list is subject to change.
In Berry (context only):Context for why Berry's credit-building path fills the gap foreign reports don't cover.