With the creation of the agency we've developed a rather innovative compliance framework. One of the tools we use is mystery shopping. The first time we'll go out to a sizeable portion of branches across the country in various urban centres and in some rural areas, to see what the retail experience is for the consumer with respect to compliance with the legislation.
Our first mystery shop was carried out in 2003 and we focused on how the banks met their disclosure requirements in branch. The results were not positive in all the areas.
We then have in our act two processes. First of all, let me clarify the word “prosecution”. Prosecution is a completely separate action that would be taken through the criminal act, and that's not a key tool for the agency. The agency can progress through what we refer to as a “notice of violation” and then a violation that receives an administrative monetary penalty.
So that's the difference between prosecution and our administrative monetary penalty. That's just a point of reference there.