Yes. It was a good move on OSFI's part to come up with those guidelines. Of course, they could go further. As you highlighted, the commissioner of the environment and sustainable development did a report on this and said that the approach in B-15 remains “short of incentivizing the transition to a net-zero emissions economy.” We understand that OSFI thinks its mandate in that regard is limited. Other regulators elsewhere have a different view of their mandates, even without legal changes. I definitely invite OSFI to have a broader interpretation.
That's something your report could recommend—that OSFI have a broader interpretation of their mandate.
What the climate-aligned finance act would do, on top of what OSFI is already doing, is mandate OSFI to look at impacts and at reducing impacts. It would anchor everything in a 1.5°C framework. It would provide a lot of details. That two-pager “climate test”, as we used to call it, provides a level of detail that is missing in the guidelines. It mentions transition plans. It doesn't go into any level of detail there. The measure most bankers absolutely hate is increased capital requirements for microprudential and macroprudential risks that investments in fossil fuels bring forward.