Well, it's a couple of things, but I think it's a distinction. The smaller institutions tend to be what I call “momma lines”, so they'll be uniquely mortgage lenders, or uniquely credit card banks. What sometimes happens is that when you drop the entire regime—which was designed for a large, full-service bank—on the small bank, the small bank is forced to put in place a lot of compliance processes that may not be relevant or necessary to their business model. If we had more of a principles-based approach, the individual institution could be a little more flexible in the processes it adopts. In fact, according to the discussion paper that came out, for example, Canada has always adhered to mandatory identification requirements. You must get these types of identification and nothing else will suffice. In other places, it's more of a principles-based approach, which means taking reasonable measures to properly identify your customer. That allows the individual institution to be a little more flexible in the processes they adopt.
On April 16th, 2018. See this statement in context.