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Industry committee No. Again, the only reason why we provided comment on that specific item.... I don't want to overkill it, if you will, because the banks will comply with whatever will be the intention of the legislator. The comment is really in relation to the complexity of the system. Sometimes it takes longer than you would expect to make the change and to make it right, avoiding as much as possible any errors.
September 30th, 2009Committee meeting
Nathalie Clark
Industry committee It's regular days.
September 30th, 2009Committee meeting
Nathalie Clark
Industry committee No, they're regulated by provincial legislation.
September 30th, 2009Committee meeting
Nathalie Clark
Industry committee As you said, the banks have very sophisticated systems in place. That's why we are concerned that the 10 days would not allow the banks to proceed efficiently with the unsubscription. We feel that a bit more time would help to avoid errors, delays, and non-compliance. Banks have some of the most sophisticated IT systems in this country.
September 30th, 2009Committee meeting
Nathalie Clark
Industry committee Yes, that's always been the practice.
September 30th, 2009Committee meeting
Nathalie Clark
Industry committee I can tell you that in the past, banks consistently indemnified their clients who have suffered losses as a result of identity theft, and it's been the practice.
September 30th, 2009Committee meeting
Nathalie Clark
Industry committee We are recommending that the bill be amended to allow the bank, which has an existing business relationship with its customer, to share information with some of its affiliates, in order to take a more holistic approach, so to speak, with customers. Quite often, the bank's goal is to provide the best possible service to its customers, and consequently, to provide more comprehensive services or financial advice.
September 30th, 2009Committee meeting
Nathalie Clark
Industry committee I think your question is in relation to online banking.
September 30th, 2009Committee meeting
Nathalie Clark
Industry committee Online banking is done at a bank website that customers such as you access proactively to take care of their personal finances. These online banking portals were developed to respond to a customer need, to customers who wanted to use electronic means to do their personal finances.
September 30th, 2009Committee meeting
Nathalie Clark
Industry committee I will let my colleague answer this question.
September 30th, 2009Committee meeting
Nathalie Clark
Industry committee I'm talking about efforts to attract new or prospective customers.
September 30th, 2009Committee meeting
Nathalie Clark
Industry committee We did not consider that point. I would first like to reiterate that we support this bill. However, we believe that a number of simple amendments could address some of our concerns about legitimate commercial activities. Clearly, it is important for us to be able to make that initial contact with a prospective customer.
September 30th, 2009Committee meeting
Nathalie Clark
Industry committee Yes, it is true that we would like to be able to contact a prospective customer or consumer initially to request his or consent at that time. Obviously, we are not suggesting that strict parameters be put in place to govern the initial contact, but rather that some provision be made for this contact in the legislation.
September 30th, 2009Committee meeting
Nathalie Clark
Industry committee As I said in my opening remarks, we believe that a private right of action in this context is inappropriate. We believe there is a risk of facing increased private actions that would put a lot of pressure and costs on our industry. There's always a risk of class action when there's a civil right of action.
September 30th, 2009Committee meeting
Nathalie Clark
Industry committee I guess I would answer that question by saying that what really concerns the industry is that built into that private right of action is a possibility to have damages granted without a real proof of loss. That is really the issue we have with this regime. We think it's inappropriate to be able to grant damages when no real loss has been proven.
September 30th, 2009Committee meeting
Nathalie Clark