Special Committee on Cooperatives committee  The brief was submitted to your clerk approximately two days ago, so I imagine it's just in the translation process right now.

Special Committee on Cooperatives committee  That's correct. In the 2010 numbers I have, I believe it's around 4% of pre-tax earnings of credit unions nationally that is given to the community as compared to 1% for traditional banks.

Special Committee on Cooperatives committee  Our national trade association, the Credit Union Central of Canada, was consulted throughout the process. I was also involved on a committee that dealt with it throughout the two or three years that the development of that legislation, or regulations, was under way. I was disappointed, personally, and taken a bit by surprise, that the decision had already been made that it was going to go under the Bank Act as opposed to the Cooperative Credit Associations Act, which is the legislation we're under.

Special Committee on Cooperatives committee  Yes. Most of the transactions we do are set up that way so that the ultimate client doesn't see our involvement in it, and the agreements and the relationship are between us and the credit union and sometimes other credit unions. There might be a consortium of various credit unions that are involved in the lending.

Special Committee on Cooperatives committee  We don't consult with the members on the various specific transactions that we do. It's more on the overall strategy—what strategy and how we position ourselves in the credit union system—that the members consult with us on, through our board. The board is structured such that there is representation from the various regions across Canada, and that's how you bring that in.

Special Committee on Cooperatives committee  Sure. For example, have restructured our social responsibility platform at Concentra over the last year and a half, and we set aside a certain amount of money each year and then allow credit unions from across Canada to submit submissions for particular initiatives that they are interested in helping their community with.

Special Committee on Cooperatives committee  Thank you, Mr. Chair. We don't do direct lending to cooperatives so much. We have provided lines of credit to cooperatives, and have been involved in social housing projects in Toronto to a great extent, because we partner with the credit unions on that. So I can't really speak to the credit unions' credit risk policy, but we do partner with them.

Special Committee on Cooperatives committee  Yes, they can. We do have the federal power—

Special Committee on Cooperatives committee  —servicing credit unions in particular. But certainly, a lot of our trust work is still directly with members or directly with people.

Special Committee on Cooperatives committee  From reading the information that's gone around, I believe that some of the regulators involved with the federal trust legislation may have been speaking in British Columbia, though I could be wrong. I think I've heard on a couple of occasions the question posed to credit unions, what are you doing to mitigate your risk and diversify when all of the mortgages you provide, for example, are all in one particular city or area, which could get hit particularly hard?

Special Committee on Cooperatives committee  We can submit that to you.

Special Committee on Cooperatives committee  That's right. We have the federal power to do anything. Now, initially, we were doing a lot more work directly with consumers, and what we've done in the last couple of years, at the request of credit unions in the system, is moved away from that and become more of an financial intermediary—

Special Committee on Cooperatives committee  I wouldn't suggest that we fit within a hierarchy. Basically, most of what we do at Concentra is to act as an intermediary or a wholesale provider. So we are the intermediary between the credit union and the credit union's members. So if a credit union member comes forward and needs, say, a large commercial loan exceeding the capacity of that credit union or its regulatory capacity, then they can come to Concentra and we can help fund that through a participation or a syndication.

Special Committee on Cooperatives committee  Certainly. Thank you for the question. The main difference between credit unions and traditional banks or other financial institutions is in their governance model itself. Credit unions, generally speaking, have a membership within a certain region or area. Because of that, the people who work in the credit unions generally know their clients much better than they would in a banking system.

Special Committee on Cooperatives committee  I certainly applaud the government's initiatives with regard to financial literacy. I would like to see more consultation with the credit union system. On the first go-round, there wasn't the opportunity for credit unions to be consulted on financial literacy models. Yet that is certainly an initiative we've seen specific credit unions across Canada take an interest in.