Mémoire prébudgétaire de la Nouvelle‑Écosse – Miser sur les atouts pour un avenir prospère

The CBA appreciates the opportunity to help shape Nova Scotia’s future by contributing to the Department of Finance and Treasury Board’s consultation for the upcoming Budget. Representing more than 60 domestic and foreign banks, we advocate for public policies that support a sound and secure banking system, while fostering economic growth and prosperity for all Canadians. We are pleased to provide these recommendations on behalf of our members.

Recommendation 1: Support the federal government’s electoral commitment to conduct a comprehensive review of the corporate tax system. The review should aim to improve Canada’s productivity, job creation, and economy by:

• Ensuring the tax system is anchored on the principles of tax efficiency, neutrality, certainty, and competitiveness
• Removing the province’s Corporate Capital Tax on financial institutions to promote economic growth, and encouraging the federal government to end sector-specific tax measures by reinstating the Dividend Received Deduction for financial institutions and phasing out the Financial Institutions Tax
• Prohibiting the use of retroactive taxation that creates uncertainty for businesses and investors
• Publicly support lowering Canada’s statutory and effective corporate tax rates, and the combined rate for investors, to rank within the lowest third in the OECD by 2030 and annually track progress against that objective to encourage international and domestic investment

Recommendation 2: Support the creation of a national financial regulation framework for un- or under‑regulated payments service providers (such as e‑commerce platforms and similar entities) rooted in the strong system that presently governs banks. We encourage the Government of Nova Scotia to work with the federal and other provincial governments to establish a nationwide market conduct framework that provides consistent protections to all Canadians regardless of location.

Recommendation 3: Ensure the National Anti‑Fraud Strategy addresses key requirements to combat financial crimes provincially and federally, including adequate resources to hold criminals accountable under the Criminal Code of Canada. Specifically, the CBA supports the following measures:

• Centralizing financial crimes reporting flows between the Canadian Anti‑Fraud Centre (CAFC) and Nova Scotia police agencies to better provide line of sight to authorities to track and mitigate these crimes
• Ensuring sufficient training, funding, and dedicated resources for law enforcement and prosecutors to respond to the rising volume and sophistication of financial crime
• Expanding public education initiatives to equip Canadians with the knowledge and tools they need to protect themselves against financial crime and scams
• Taking a multi‑sector approach to combatting scams, including coordinating with telecommunications and online platforms
• Replicating successful models such as Ontario's Serious Fraud Office in Nova Scotia to improve coordination and enforcement

Recommendation 4: Collaborate with the federal government to strengthen commitment to beneficial ownership transparency, in addition to investment in relevant authorities to support money laundering (ML) and terrorist financing (TF) investigations. In particular, we urge investments in Nova Scotia’s enforcement and prosecution capacity and harmonize its existing tools with federal measures. A harmonized approach will ensure effectiveness by avoiding legislative arbitrage and reduce compliance duplication across jurisdictions.

Recommendation 5: Provide policy and regulatory support to help both provincially regulated credit unions that choose to transition to the federal credit union framework as well as amalgamations and asset transactions between federal and provincial credit unions, and increase financial transparency in the provincial credit union system.

Recommendation 6: Strengthen public safety and community well‑being by:

• Introducing legislation or industry regulations to phase out the use of universal master keys in heavy construction equipment and implementing a regular PIN management regiment
• Facilitating information sharing of construction site locations with various stakeholders to allow ATM operators to implement risk‑based security measures
• Implementing innovative and comprehensive solutions that address public safety challenges, while improving community vitality and economic growth
• Urgently increasing funding for community vibrancy projects, addiction recovery services, and expanded police and crisis teams
• Enhancing community services for unhoused individuals, recognizing that this continues to be a significant challenge
• Launching local coalition efforts to revitalize heavily impacted cities and regions
• Providing a comprehensive listing of all mental health mobile crisis teams (MHMCTs) operating across the province

Recommendation 7: Strengthen wireless networks in underserved communities across Nova Scotia to enhance public safety and enable all Nova Scotians to participate in the digital economy.

Introduction

Beyond serving as a cornerstone of Canada’s strong and stable financial system, banks actively partner with Canadians to help them achieve their goals, whether purchasing a home, starting a business, saving for the future, or navigating periods of uncertainty.

Banks played a vital role in the Nova Scotia’s prosperity by:¹

• Contributing approximately $1.3 billion (about 3.0%) of GDP to Nova Scotia’s economy
• Paying close to $200 million in taxes to municipal and provincial government in Nova Scotia and generating more than $29 billion in dividend income for Canadian seniors, families, pensions, charities, and endowments
• Employing more than 6,400 people in Nova Scotia in an inclusive and equitable workforce, with women representing about 58% and self-identified visible minorities comprising about 26%

Banks helped Nova Scotians:

• Purchase homes, with more than $28 billion in residential mortgages outstanding²
• Start and grow businesses, with approximately $17 billion in credit authorized for small and medium‑sized enterprises and authorized close to $61 billion in total business credit³
• Facilitate access to financing, approving 9 in 10 small business debt financing requests annually since 2010⁴

An increasingly competitive and evolving financial services landscape

Nova Scotia’s financial services sector is highly competitive. Six domestic systemically important banks (DSIBs) compete with 72 domestic and foreign small- and medium-sized banks (SMSBs) and federal credit unions that are regulated federally with most of them able to collect deposits across Nova Scotia. This competition is further intensified by 15 provincially-regulated credit unions.⁵ Financial institutions recognize the vital role physical branch locations play in ensuring access to essential and specialized banking services, building relationships, and supporting local economies. Collectively, they operate over 215 branches across the province, with banks operating over 75 percent and credit unions the remainder.⁶

Competition is equally strong in the mortgage market. Nearly 30 banks compete with more than 45 non-bank financial institutions (including provincial credit unions, mortgage finance companies, trust companies, and insurance companies) approved under the National Housing Act (NHA).⁷ Private lenders further expand the competitor landscape in the uninsured mortgage market.

Furthermore, the financial sector is evolving, as new technology and service providers enter the competitive landscape. Examples of these new entrants include large technology platforms with growing access to consumer data and fintech payment services providers, buy-now-pay-later companies, digital currency exchanges, and robo-advisors. More broadly, close to 5,100 fintechs and technological giants are offering or embedding financial services into their platforms further fragmenting the financial marketplace.⁸ Adoption of digital-first banking is widespread with 84 percent of financial transactions and 95 per cent of retail spending occurring digitally.⁹ These new rivals leverage telecommunications network and payments systems to compete without a physical presence, and many consumers have become comfortable with digital-only financial solutions.

In response, Canada’s major banks have invested approximately $120 billion in technology over the past decade to enhance consumer experience, reduce costs, and maintain competitiveness.¹⁰ These strategic investments have contributed to labour productivity growth in the Finance and Insurance sector of 2.4 percent annually since 2007, the second fastest rate among all Canadian industries.¹¹ Regulators are also advancing initiatives such as consumer-driven banking and real-time rail payments to further encourage innovation and consumer choice.

Canadians are benefiting from the increased competition and innovation in the financial sector. Average credit card interchange fees for retailers fell from 1.7 percent in 2014 to 1.4 percent in 2020, saving merchants an estimated $2.5 billion. Small business interchange fees fell even further, reaching 0.95 percent in 2024. Investment costs have also decreased: mutual fund management expense ratios (MERs) declined to 1.47 percent in 2023 from 2.06 percent in 2013. With the emergence of ultra-low-cost exchange-traded funds, the average MER declined further to 1.28 percent.¹²

The financial sector is also influenced by regulatory initiatives that focus on consumer protection and market stability (e.g., AML, privacy rules, cybersecurity). Canadian banks have been complying with these public policy initiatives while providing competitive services and maintaining some of the highest levels of consumer trust among developed countries (Graph 1).

Recommendation 1: Reform the tax system to work for Canadians

Canadians’ standard of living, as measured by real GDP per person, was lower in 2024 than in 2014. Canada risks continued deterioration in living standards without improvement to its low labour productivity, ultimately resulting in wage stagnation, constraints to governments’ public services, increased production costs, and reduced competitiveness globally.

Canada’s productivity has declined significantly over time, falling from sixth place among Organisation for Economic Co-operation and Development (OECD) countries in 1970 to 18th in 2022 and ranks second last among G7 countries.¹³ In relation to our largest trading partner, productivity in Canada is approximately 30 percent lower than in the U.S., comparable to levels seen in lower‑income states rather than in innovation leaders like California or New York.¹⁴

Furthermore, since the last comprehensive review nearly 60 years ago, Canada’s tax system has evolved without a consistent focus on foundational tax policy principles that underpin domestic and foreign investment, economic growth, and innovation. The International Monetary Fund (IMF), the OECD, and others have urged Canada to implement growth‑oriented tax policies. This is unsurprising given Canada’s loss of its business tax advantage internationally: it now ranks 27th out of 38 OECD countries in corporate tax rates and has the third highest combined corporate and personal tax rates in the OECD.

Targeted taxes on the financial services sector have further undermined economic growth and productivity by limiting banks’ capital available for Canadian businesses, reducing Canadians’ ability to save and invest, and dampening foreign investment. Other countries recognize the negative effects of sector‑specific taxes with Australia’s Government Productivity Commission concluding that industry levies must be avoided to establish or maintain sound foundations for productivity growth.¹⁵

Canada’s targeted taxes include:

• Capital taxes imposed by Nova Scotia and five other provinces reduce banks’ retained earnings and penalizes prudential capital buffers
• Removal of the Dividend Received Deduction, impacting over 3 million Canadians holding market‑linked GICs and notes, often middle‑class households close to retirement who seek stable returns and downside protection
• The 2022 Financial Institutions Tax and the Canada Recovery Dividend curtailed credit capacity to businesses and consumers as every dollar reduction in retained earnings translates into over $7.50 of foregone new credit capacity. These taxes also led to a divestment of $11.6 billion in Canadian bank equity by foreign investors in 2023
• Retroactive sales taxes on payment clearing services undermine the tax system’s principles of predictability, certainty, fairness, and investor confidence

Canada’s persistent productivity challenges, combined with heightened uncertainty arising from trade and tax policies in the U.S., underscore the need for comprehensive corporate tax reform more than ever. Strengthening Canada’s resilience to external economic shocks will require a tax system that is modern, efficient, and competitive. We were encouraged by the Prime Minister’s campaign promise, which included a commitment to review Canada’s corporate tax system, guided by the principles of fairness, transparency, simplicity, sustainability, and competitiveness and encourage provinces to support such a review.

Recommendation: Support the federal government’s electoral commitment to conduct a comprehensive review of the corporate tax system. The review should aim to improve Canada’s productivity, job creation, and economy by:

• Ensuring the tax system is anchored on the principles of tax efficiency, neutrality, certainty, and competitiveness
• Removing the province’s Corporate Capital Tax on financial institutions to promote economic growth, and encouraging the federal government to end sector-specific tax measures by reinstating the Dividend Received Deduction for financial institutions and phasing out the Financial Institutions Tax
• Prohibiting the use of retroactive taxation to provide certainty to businesses and investors
• Avoiding any increase to tax structures that deters investment in Nova Scotia, making it more difficult for firms to scale (e.g., capital gains inclusion rate)
• Publicly support lowering Canada’s statutory and effective corporate tax rates, and the combined rate for investors, to rank within the lowest third in the OECD by 2030 and annually track progress against that objective to encourage international and domestic investment

Recommendation 2: Make financial regulation more efficient and consistent across Canada

Canadians continue to adopt new payment methods offered by non-traditional payment service providers (PSPs), including Big Tech. However, these PSPs are largely un- or under‑regulated. Moreover, new payment forms such as stablecoins are emerging with a new draft legislative framework at the federal level.

Globally, G20 member countries and the OECD have recognized the risks associated with entities that engage in bank‑like activities without bank-like regulation. Failure to address the risks associated with these entities could create stability concerns and erode trust in the financial system. Financial services and products raise public policy issues that must be addressed by governments.

As an example, while the Retail Payment Activities Act establishes a federal framework for PSPs to address certain financial and security risks, it does not impose the full range of protections for consumers that are applied to banks and, in particular, is silent on market conduct. Given the Bank of Canada’s recent mandated oversight of nearly 3,000 PSPs, consumer usage is likely to increase and the absence of market conduct regulation is a significant gap in ensuring fair outcomes and protection for Canadians.¹⁶

Nova Scotians should benefit from a secure, reliable, and consistent financial system regardless of the nature of the financial payments provider or geographical residence. Therefore, it is important that un- or under‑regulated players do not introduce risk into the financial system. The financial services regulatory framework, including market conduct, should adopt the principle of "same activity, same risk, same regulation" and should continue to evolve to reflect changes in technology.

Recommendation: Support the creation of a national financial regulation framework for un- or under‑regulated payments service providers (such as e‑commerce platforms and similar entities) rooted in the strong system that presently governs banks. We encourage the Government of Nova Scotia to work with the federal and other provincial governments to establish a nationwide market conduct framework that provides consistent protections to all Canadians regardless of location.

Recommendation 3: A need for a coordinated approach to combat financial crimes

Financial crimes, such as scams, identity theft, and account takeovers, continue to threaten Canadians, with some schemes being linked to organized criminal networks beyond Canada’s borders. Reported fraud incidents have doubled over the past decade and cost Canadians more than $645 million in 2024 alone. Given that financial crimes are significantly underreported, total annual losses are estimated to exceed $12 billion.¹⁷ In Nova Scotia alone, based on 830 reports, financial crimes resulted in reported losses over $8.8 million but actual losses are expected to be multiples of reported losses due to underreporting by victims.¹⁸

In response, the CBA is collaborating with some 50 organizations across public and private sectors (government regulators, financial institutions, telecommunications companies, law enforcement and digital platforms) in a Canadian Anti-Scam Coalition (CASC). CASC is dedicated to protecting Canadians through coordinated education, awareness, and prevention initiatives that address scams in all their forms. And, while prevention and education are essential, effective enforcement and prosecution are equally critical to ensure criminals are held accountable under the Criminal Code of Canada, preventing further victimization.

Protecting Canadians against financial crimes requires a coordinated and proactive strategy that spans the fraud lifecycle, from prevention and detection to enforcement and prosecution. This is why we support the federal government’s Budget 2025 announcement of the government’s intention to develop a whole‑of‑government National Anti‑Fraud Strategy. This strategy will build off the work of the CASC and bring together financial institutions, technology, and telecommunication companies to develop a cross‑sectoral approach to protect Canadians from evolving and highly complex fraud schemes. An effective National Anti‑Fraud Strategy should integrate public‑private collaboration, reinforce enforcement and prosecution capacity, and empower Nova Scotians through education.

Recommendation: Ensure the National Anti‑Fraud Strategy addresses key requirements to combat financial crimes provincially and federally, including adequate resources to hold criminals accountable under the Criminal Code of Canada. Specifically, the CBA supports the following measures:

• Centralizing financial crimes reporting flows between the Canadian Anti-Fraud Centre (CAFC) and Nova Scotia police agencies to better provide line of sight to authorities to track and mitigate these crimes
• Ensuring sufficient training, funding, and dedicated resources for law enforcement and prosecutors to respond to the rising volume and sophistication of financial crime
• Expanding public education initiatives to equip Canadians with the knowledge and tools they need to protect themselves against financial crime and scams
• Taking a multi‑sector approach to combatting scams, including coordinating with telecommunications and online platforms
• Replicating successful models such as Ontario's Serious Fraud Office in Nova Scotia to improve coordination and enforcement

Recommendation 4: Need for a harmonized anti‑money laundering and anti‑terrorist financing regime

The Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) must continue to serve as the cornerstone in Canada’s fight against money laundering (ML) and terrorist financing (TF). While the CBA may support certain changes to the PCMLTFA, we caution against introducing new provincial requirements, reporting or otherwise, on federally regulated entities. Any fragmentation of the national regime could inadvertently:

• Empower bad actors by creating pockets of legislative arbitrage if federal and provincial requirements are misaligned
• Undermine the federal government’s ongoing and important national policy efforts
• Complicate coordination among expanding set of authorities as ML and TF risks evolve, and
• Potentially exacerbate concerns with high‑volume, low impact reporting

Rather than adding new layers of regulations to an already comprehensive federal framework, the CBA urges the Government of Nova Scotia to support existing anti-money laundering (AML)/anti‑terrorist financing (ATF) tools and invest in law enforcement to strengthen the fight against ML and TF by:

• Working with the federal government to continue to expand the transparency of beneficial ownership in Canada through a one‑stop‑shop, publicly accessible beneficial ownership registry that reflects, through aligned data points, the beneficial ownership information of corporations and other entities (e.g., partnerships, trusts, and associations) from across Canada
• Investing in law enforcement to support its investigation and prosecution of ML and TF cases and enhance coordination with relevant federal authorities

Recommendation: Collaborate with the federal government to strengthen commitment to beneficial ownership transparency, in addition to investment in relevant authorities to support ML and TF investigations. In particular, we urge investments in Nova Scotia’s enforcement and prosecution capacity and harmonize its existing tools with federal measures. A harmonized approach will ensure effectiveness by avoiding legislative arbitrage and reduce compliance duplication across jurisdictions.

Recommendation 5: Enabling federal options for credit unions

In addition to over 70 banks, three federal credit unions are currently licensed under the federal Bank Act to operate across Canada, affording them the ability to compete by scaling and making necessary investments in technology, talent, and risk management. However, most credit unions operate under provincial oversight - in Nova Scotia, 15 credit unions service over 120,000 customers, hold nearly $4.7 billion in assets and over $4 billion in deposits.¹⁹ Migrating to a federal license enables credit unions to carry on business outside or to merge with (or purchase assets from) credit unions outside their home province, which enables economies of scale and diversifies risks across markets.

While policymakers acknowledge that scale enhances resilience, builds internal capacity (technical, operational, and strategic), and improves risk management, the process for federal credit union mergers or amalgamations with provincially‑regulated entities is long and cumbersome.²⁰ Mergers involving federal and provincial credit unions require approval from the Minister of Finance, OSFI, the provincial regulator, deposit insurers, and the Competition Bureau.²¹ In Budget 2025, the federal government has acknowledged the need for support for federal credit unions’ growth, via amalgamation or asset acquisitions, and to make it easier for credit unions to enter the federal framework.

Most provincial legislation is silent on a credit union’s continuance under the Bank Act, an option for credit unions to operate under the national standard or amalgamate with an existing federal credit union.²² The limited number of transitions to date highlights persistent internal regulatory barriers and greater transition flexibility is needed to allow credit unions to scale and compete across provinces. Therefore, the province should ensure a smooth and efficient process for provincial credit unions to transition to the federal level as stand‑alone or amalgamated entities and ensuring requirements (including approvals) be proportionate to the transaction, and provide guidance that facilitates credit unions’ continuance under the federal Bank Act following an amalgamation or asset transaction between federal and provincial credit unions.

One of the benefits of the federal regulatory framework is transparency: federally regulated institutions must publish monthly and quarterly financial disclosures that are published on the Office of the Superintendent of Financial Institutions (OSFI) website. Most provincial credit unions currently post annual financial statements on their individual sites. More frequent, standardized disclosures through a centralized portal would strengthen transparency of the credit union system’s financial state, helping inform depositors and borrowers when making financial decisions. Such transparency will improve visibility and understanding of key risks, promote public confidence and stability in Nova Scotia’s provincial credit union system.

Recommendation: Provide policy and regulatory support to help both provincially regulated credit unions that choose to transition to the federal credit union framework as well as amalgamations and asset transactions between federal and provincial credit unions, and increase financial transparency in the provincial credit union system.

Recommendation 6: Strengthening public safety and community well‑being

Across Canada, ATM attacks involving construction equipment are rising sharply: from one incident in 2023 to six incidents in 2024 to 7 in 2025 year‑to‑date. As of 2025, such attacks account for 24 per cent of all ATM attacks.²³ This trend is highly concerning due to the scale of losses and broader impact on local businesses and communities. Beyond the direct financial impact and the costs of repair and replacement of damaged ATMs, temporary or prolonged branch closures reduce access to essential banking services. These disruptions are especially harmful in rural or underserved areas, where alternative banking options are limited.

A contributing factor to such attacks is the use of universal keys in many types of construction machinery. These keys are easily obtainable and interchangeable across brands and models, creating a substantial security vulnerability.²⁴ Bad actors, including organized criminal networks, are becoming increasingly sophisticated, often conducting reconnaissance and likely obtaining master keys in advance. To mitigate these risks, manufacturers and contractors should adopt unique, machine-specific access systems to ensure that only authorized personnel can operate equipment. Some heavy construction equipment is also equipped with ignition kill switches or immobilizers that require a personal identification number (PIN) for bypass. To reduce the risk of PIN compromise and subsequent circumvention of these security controls, we recommend increasing the frequency of the PIN lifecycle management, including the issuance, updating, and retirement of PINs.

Additionally, notices of approved construction site locations would enable ATM operators to apply risk-based security measures to mitigate the opportunities of theft with heavy construction equipment. Information sharing between stakeholders, including governments, CBA and private sector stakeholders would assist in the implementation of risk‑based security measures.

Nova Scotia’s provincial crime rate and severity are slightly above the national average. In 2024, the crime rate per 100,000 was almost 8 per cent higher than the national average, rising 2.6 per cent from 2023.²⁵ In many parts of Canada, rising crime and violence continue to affect communities, creating heightened safety concerns for commuters to workplaces, forcing business closures, reducing family‑supporting jobs, and increasing pressure on mental health and social support programs.²⁶ Although Nova Scotia has not experienced the most severe forms of these events, vigilant and proactive action is essential.

A comprehensive, cross-jurisdictional approach is needed to address the interconnected challenges of mental health, addiction, homelessness, and public safety that impact banks and surrounding communities. Temporary measures such as removing unhoused individuals from ATM vestibules or businesses (by security guard services or law enforcement) displaces the individuals from one location to another, is not sustainable long‑term, and fails to address root causes. To that end, loitering remains a high concern for banks, accounting for approximately 75 per cent of all annual physical security incidents. Strengthening mental‑health and addiction supports, expanding crisis‑response teams like mental health mobile crisis teams (MHMCT) and investing in permanent housing and economic‑stability initiatives are also essential to reducing disruptive behaviour, enhancing staff and customer safety, and supporting healthier, more resilient communities. These MHMCT teams consist of health care professionals working alongside specially trained police officers, help and de‑escalate volatile situations, and connect individuals to follow‑up care and community programs.

The CBA is active in finding solutions to these challenges across the country. For example, the Downtown Halifax Business Commission (DHBC) is a not-for-profit organization that works to pursue a more prosperous and vibrant Downtown. The DHBC also runs a Navigator Outreach Program that offers direct support to the unhoused and street‑involved individuals. Such organizations and initiatives are crucial to the revitalization of city cores.²⁷

We request that the Government of Nova Scotia provide a comprehensive listing of all MHMCTs operating across the province. Centralizing this information would significantly reduce the administrative burden currently placed on financial institutions, which are otherwise required to compile this data independently across jurisdictions.

Recommendation: Strengthen public safety and community well‑being by:

• Introducing legislation or industry regulations to phase out the use of universal master keys in heavy construction equipment and implementing a regular PIN management regiment
• Facilitating information sharing of construction site locations with various stakeholders to allow ATM operators to implement risk‑based security measures
• Implementing innovative and comprehensive solutions that address public safety challenges, while improving community vitality and economic growth
• Urgently increasing funding for community vibrancy projects, addiction recovery services, and expanded Police and Crisis Teams
• Enhancing community services for unhoused individuals, recognizing that this continues to be a significant challenge
• Launching local coalition efforts to revitalize heavily impacted cities and regions
• Providing a comprehensive listing of all mental health mobile crisis teams (MHMCTs) operating across the province

Recommendation 7: Expand wireless access in underserved areas

Persistent broadband and wireless coverage gaps in rural and coastal areas limit economic participation and compromise public safety. Reliable connectivity is essential for secure online banking and digital payments, enabling seniors, remote communities, small businesses, and low‑income households to participate fully in the digital economy.

Strong wireless networks also support emergency preparedness by enabling real-time alerts and first responder coordination during hurricanes, wildfires, and winter storms. Coverage along evacuation routes and storm‑prone areas is critical to protecting lives and property.

We request that the province expand last‑mile connectivity in underserved regions such as the Eastern Shore, Cape Breton, and the Southwest Shore. This should include streamlined permitting for new towers and infrastructure and ensure emergency hubs are equipped with backup power and climate‑resilient systems.

Strengthened connectivity across Nova Scotia will enhance public safety, modernize digital infrastructure, and support inclusive economic growth.

Recommendation: Strengthen wireless networks in underserved communities across Nova Scotia to enhance public safety and enable all Nova Scotians to participate fully in the digital economy.

Conclusion

The CBA appreciates the opportunity to contribute to the province’s upcoming Budget. Our recommendations are designed to help shape Canada’s, and Nova Scotia’s, future by fostering investment and innovation, strengthening communities across the province, and enhancing the resilience of our country’s economy. Critically, we seek to ensure that Nova Scotians, indeed all Canadians, have the opportunity to thrive. We welcome the opportunity to discuss our recommendations in greater detail and to explore efforts to collaboratively deliver benefits for Nova Scotians.

¹ 2024 banking contributions provided by CBA, workforce composition based on 2023 data, Statscan.
² Mortgage lending statistics provided by Bank of Canada
³ Lending statistics provided by CBA
⁴ ISED, Credit Conditions Survey, 2010 to 2024.
⁵ Credit Union Deposit Insurance Corporation (CUDIC) of Nova Scotia, December 2025
⁶ OSFI financial data, annual financial disclosures from financial institutions, and Canadian Credit Union Association (CCUA).
⁷ CMHC National Housing Act Approved Lenders.
⁸ Tracxn, as of October 8, 2025
⁹ Calculated from Payments Canada, Payment Methods and Trends Report 2024. Includes debit card, credit card and prepaid card, by value.
¹⁰ Calculated by CBA.
¹¹ CBA calculations and Bennett Jones, Economic Outlook 2025, Safeguarding a Vital Relationship and Investing in a More Productive Economy. While the Finance and Insurance produced $93 in real GDP per hour worked, banking and other depository credit intermediation produced $113.40 in real GDP per hour worked.
¹² Conference Board of Canada, Funding the Future: The Economic Impact of Canada’s Investment Funds Industry, September 2024, Blended MER including ETF calculated using market share data on p. 5.
¹³ OECD, OECD Compendium of productivity indicators 2023, February 2023.
¹⁴ RBC Thought Leadership, Canada’s growth challenge: Why the economy is stuck in neutral, June 2024.
¹⁵ Australian Government Productivity Commission, Towards Levyathan? Industry levies in Australia Research paper, December 2023.
¹⁶ Bank of Canada, Laying bare the evolution of payments in Canada, May 2024
¹⁷ Competition Bureau of Canada, Fraud Prevention Month to focus on impersonation fraud, one of the fastest growing forms of fraud, February 2025
¹⁸ CAFC 2024 Annual Statistical Report
¹⁹ Canadian Credit Union Association (CCUA), Third Quarter 2024 National Sector Results, Revised January 2025
²⁰ BCFSA, Cooperative Finance at a crossroads: Strengthening system design for what’s ahead, July 2025
²¹ CCUA, Stronger Together, Sooner: A Roadmap for Faster and Fairer Credit Union Merger, Reviews, August 2025
²² While Nova Scotia credit union legislation provides for continuance of a credit union in other jurisdictions, it does not explicitly mention federal continuance. Currently, Alberta and New Brunswick have legislation that explicitly contemplates the amalgamation of a provincially regulated credit union with a federally regulated credit union under federal continuance.
²³ Figures are provided for a calendar year, January to December. 2025 YTD includes figures from January to October
²⁴ CBC, Easy to get heavy equipment keys, says operator after back‑to‑back robberies, January 2019
²⁵ Statistics Canada, Incident-based crime statistics, by detailed violations, Canada, provinces, territories, Census Metropolitan Areas and Canadian Forces Military Police, September 2025.
²⁶ Saskatoon credit union branch to close due to 'increased threat' to safety, CTV News Saskatoon, November 2023.
²⁷ DHBC, About DHBC, accessed November 2025