Good afternoon. We would like to thank the Committee for inviting the Canadian Bankers Association to participate in the Committee’s review of Bill C-86. The CBA works on behalf of over 60 domestic banks, foreign bank subsidiaries and foreign bank branches operating in Canada and their 280,000 employees.

Building and maintaining strong client relationships remains of fundamental importance for Canada’s banks and banks continue to be an essential part of the daily life of Canadians. Ninety-nine per cent of Canadians have an account with a financial institution, so millions of Canadians turn to banks every day for products, services, and financial advice. Banks help Canadians safeguard their money, finance a home, manage their savings, plan their investments, and prepare for retirement.

Banks in Canada take very seriously their role in the lives of individual Canadians. And Canadians trust their banks and value the products and services they provide. Banks have worked hard to make banking more convenient – extending branch hours, introducing mobile banking and payments, and enhancing online banking – enabling banking literally around the clock and around the world.

Financial Consumer Protection Framework

Bill C-86 consolidates the consumer protection provisions that exist in federal legislation as they have evolved over many years, as well as new measures, into a single, comprehensive, Financial Consumer Protection Framework within one Part of the Bank Act. Consolidating the federal consumer protection framework helps to ensure that Canadian consumers continue to benefit from consistent, safe and high-quality banking products and services.

We support the Financial Consumer Agency of Canada having continued oversight of the consumer protection provisions under the Bank Act. The FCAC was created in 2001 to strengthen oversight of consumer regulation and expand consumer education. The industry has a longstanding and strong working relationship with the FCAC. In fact, the CBA and its member banks often partner with the FCAC on consumer initiatives, particularly in the area of financial literacy.

The CBA and its members have long supported a strong federal regulatory framework for consumers. Although Canadian consumers already benefit from a strong consumer protection regime for financial services, the federal framework proposed in Bill C-86 is a step to further provide a consolidated and comprehensive regime.

More clarity about the implementation of the Federal Consumer Protection Framework will be provided through the development of subsequent regulations. We look forward to engaging in that process with the government to achieve a workable, efficient and flexible approach for the benefit of Canadian consumers.

Protection of Legally Privileged Information

Bill C-86 also includes provisions that protect legally privileged information provided by federally regulated financial institutions to the Office of the Superintendent of Financial Institutions, including clarifying that providing this information to OSFI does not waive privilege. The banking industry supports these amendments. Privilege is recognized as a quasi-constitutional right that is fundamental to the proper functioning of our legal system. These amendments balance the need for protection of this information while supporting the continuation of a transparent and cooperative relationship between banks and OSFI as a prudential regulator.

Thank you again for inviting us to be here today and we look forward to your questions.