Finance Committee on April 19th, 2007

[The Chair, Conservative, Brian Pallister]

Good morning to all.

I am here today to welcome you, witnesses. Thank you very much for coming in. And thank you also for your previously submitted written material, which I'm sure was of interest to committee members.

I'll ask the cameras to vacate now. Thank you very much.

Pursuant to standing order 108(2), this is a briefing on automated teller machine fees and electronic payments.

We have two hours this morning. You've all been instructed that you have five minutes to cover a very important topic. We recognize the brevity of that time. I will give you an indication when you have a minute remaining. I will have to cut you off at five minutes to allow for time for exchange with our committee members.

Thank you again. We appreciate your being here.

We'll begin with CIBC, Sonia Baxendale.

[Sonia Baxendale, Senior Executive Vice-President, Retail Markets, Canadian Imperial Bank of Commerce]

Thank you very much, and good morning.

I am pleased to have the opportunity to provide CIBC's comments on the issues of choice and competition with respect to banking services in Canada.

Let me begin by giving you a brief overview of CIBC's approach to enhancing services for our clients and ensuring continued competitiveness. CIBC has made, and continues to make, significant investments in all of our distribution channels to improve accessibility and the range of services we offer our clients. As a result of these investments, today we operate one of the largest branch, ABM, telephone banking, and online banking networks across Canada. We have been upgrading our network to adapt to changing market conditions. CIBC has approximately 1,050 branches across Canada. To that end we are in the process of opening, relocating, or expanding another 70 branches, to be completed over the next five years.

Our telephone banking and online banking services hold leading positions in the marketplace. In fact CIBC's client website was just ranked number one among Canadian banks by an independent market research firm.

We have built the country's second largest bank-operated network of ABMs, with more than 3,800 bank machines, representing 23% of ABMs operated by Canadian banks. Earlier this month we announced the completion of a multi-year $90 million upgrade of our ABM network, offering improved access for persons with disabilities, enhanced security, and new transaction features. For example, we have doubled the number of CIBC access for all ABMs, from 610 in 2004, to almost 1,200 today. These machines are installed at wheelchair-accessible height, and include headphone jacks for audio access, grab bars, and improved lighting.

We have also provided clients with the opportunity to complete withdrawals more quickly, and we have added a calculator to help them total multiple deposits. We have developed new ABM features to deter card-skimming devices and keep our clients' accounts secure. In addition to ABM locations at our branches, clients can access CIBC bank machines at convenience stores, universities, colleges, and hospitals, as well as Loblaws grocery stores through our President's Choice Financial machines.

By investing in and maintaining such a large network, we are providing our clients with very broad access, convenience, and choice. We are also providing them with the opportunity to avoid ABM surcharge fees by using our network versus those of other banks or white label bank machines. In fact almost 90% of all ABM transactions undertaken by CIBC clients are done at our CIBC machines, meaning our clients pay no additional fees. These investments in our ABM network, as well as in our branches, telephone banking, and online banking, are how CIBC is responding to the competitive financial services market in Canada.

We have taken steps to address the specific needs of students, seniors, and those with disabilities. For example, through our CIBC Advantage account, our clients aged 60 or older have access to an unlimited number of free transactions through the CIBC channel of their choice, as well as free bank drafts and money orders. CIBC remains committed to providing our clients with the most convenient, accessible, and affordable financial solutions.

Thank you. I look forward to your questions and comments.

[The Chair, Conservative, Brian Pallister]

Thank you very much for your presentation.

We will continue now with the representative from the Competition Bureau. Mr. Richard Taylor is with us. Welcome, sir. You have five minutes.

[Richard Taylor, Deputy Commissioner, Civil Matters Branch, Competition Bureau]

Thank you, Mr. Chair and members of the committee. The Competition Bureau welcomes the opportunity to take part in the committee's study of ABM fees and electronic payments. My comments today will focus on the 1996 Competition Tribunal order concerning Interac. However, I would first like to briefly describe the mandate and the role of the Competition Bureau.

The Commissioner of Competition is responsible for the administration and enforcement of the Competition Act. The purpose of the act is to maintain and encourage competition in Canada in order to promote the efficiency and adaptability of the Canadian economy and to provide consumers with competitive prices and product choices.

As you will appreciate, the bureau routinely receives complaints from consumers saying that they believe prices are too high or that competitors charge similar prices or have increased their prices in unison. Other complaints frequently allege profits or price gouging.

It is important to understand that high prices and profits in and of themselves are not contrary to any of the provisions of the Competition Act. However, when high prices are the result of anti-competitive conduct circumscribed by the Competition Act, the bureau will deal with those situations expeditiously.

Agreements among competitors to fix or raise prices are subject to the severe criminal conspiracy provisions of the act, the penalties for which include heavy fines and jail terms.

In addition, the act deals with potentially anti-competitive conduct that has prevented or lessened or is likely to prevent or lessen competition, whether it be anti-competitive mergers or abuses of a dominant position aimed at eliminating or excluding competitors from the market.

One of the major investigations under the abuse provisions in the 1990s involved the Interac Association which operates the network that allows customers to make withdrawals from ABMs not belonging to their own bank. Originally, Interac was dominated by a small number of large deposit-taking institutions. Rules imposed by these few members restricted access to the network, impeded innovation, and limited competition in providing banking service to merchants and consumers.

The bureau's investigation of Interac focused on practices that limited competition in the supply of network services to both businesses and consumers. The practices included the following: limiting membership to deposit-taking institutions; charging prohibitively high initiation fees for new members who weren't among the nine members at the time; having restrictions that impeded the introduction of new services or innovative products; and prohibiting charges for ABM use, which discouraged the placement of ABMs and deprived consumers of the benefits of widespread ABM deployment determined by market forces and not by the association.

In June 1996, the Competition Tribunal issued a consent order against Interac that not only prohibited these anti-competitive acts but also put in place changes necessary to restore competition in the affected markets. The order required Interac to open its network to potential participants; collect fees based solely on a user or transaction basis; broaden the governance of the association; make the network available for additional types of accounts and new services; and remove the prohibition on surcharges, which are now known as convenience fees.

The order did not in any way mandate or regulate the imposition of surcharges. However, allowing surcharges permitted operators of ABMs to determine and charge a competitive price for ABM services based on their costs, consumer demand and other relevant market factors.

Consequently, consumers have benefited from the placement of ABMs in all parts of Canada in accordance with market forces. Following the 1996 order, the number of ABMs increased from 12,800 in 1995 to 55,000 in 2006. In fact, Canada has the highest number of ABMs per capita, and we are among the heaviest users of ABMs.

To reiterate, the order does not regulate the convenience fees that ABM operators charge consumers, nor does it require that they charge any fee at all. Furthermore, the order does not deal with network access fees, so-called Interac fees, or any other account-related fees connected with cash withdrawals or debit transactions.

I would be pleased to answer any questions you may have.

[The Chair, Conservative, Brian Pallister]

Thank you very much, Mr. Taylor.

We continue with Michel Tremblay from the National Bank of Canada. Five minutes, sir.

[Michel Tremblay, Senior Vice-President, Personal Banking and Wealth Management, National Bank of Canada]

Thank you, Mr. Chairman.

Honourable members, thank you for this opportunity to speak with you today. The main focus of my comments will be ABM convenience fees within the specific context of Quebec.

While National Bank is Quebec's leading bank, we have a more limited reach elsewhere in Canada, where we operate 105 branches and as many ABMs. As we are concerned with providing our clients outside Quebec with the best possible service, the bank has become a member of the Exchange network.

I wish to point out that we did not join the network as a way to offer our clients the possibility of withdrawing funds without paying convenience fees. That was not our goal. We did it mainly to enable them to make deposits or transfer funds between accounts, which is what makes the Exchange network ABMs a remote service counter in the real sense of the term.

I also want to remind you that 46% of ABMs that are accessible through the Exchange network belong to banks. As such, this network cannot be regarded as belonging to cooperatives, especially given that Desjardins, the largest cooperative in the country, is not a member.

Our core market, Quebec, has some particular features that I would like to hone in on. Of the ABMs located in the province, 53% are operated by independent suppliers that frequently charge a convenience fee of $3 per transaction.

In addition, more than half of the ABMs operated by financial institutions belong to a deposit-taking institution that is not a bank and therefore not regulated by the federal government. That financial institution, the Desjardins Group, charges a convenience fee of $2 per transaction.

That means that the National Bank's convenience fee is lower than those charged at around 75% of ABMs in Quebec. It also means that our clients have to pay a $2-dollar convenience fee each time they use a Desjardins ABM, while Desjardins clients pay 50¢ less per transaction to use our ABMs.

In such an environment, we feel that imposing regulatory limits on such fees would be highly discriminatory and unfair for our clients. How could we explain to them that they have to pay $2 each time they use the ABMs of a competitor that operates four times as many banking machines and whose clients can, unlike them, withdraw cash from our machines or those of another chartered bank for free?

Moreover, our clients have dramatically altered their financial payment habits over the past 20 years, and they have benefited from a payment system that has continually evolved towards greater efficiency and reliability. The system is built on the user-pays principle, the only one that enables the deployment of new technologies and encourages economically rational choices. The arrival of the digital wallet will mark yet another step in that evolution and could very well make the topic of today's meeting irrelevant. One of the results of this adjustment process is that third-party use of our ABMs has declined 20% in the last few years.

However, since we only operate a handful of ABMs outside Quebec and only 6% of all ABMs located in Quebec, we are constantly analyzing market developments and client needs so we can offer our clients, through highly attractive banking packages, ready access to the various transaction methods at a competitive price, be it through banking machines or other means.

I'll be available for questions, in both languages.

[The Chair, Conservative, Brian Pallister]

Thank you, Mr. Tremblay.

We'll continue with Ms. Heather Black from the Privacy Commissioner of Canada's office. Welcome, and five minutes to you.

[Heather Black, Assistant Commissioner (PIPEDA), Office of the Privacy Commissioner of Canada]

Thank you, Mr. Chair. I don't believe I will need five minutes.

Not surprisingly, our office has no views on the whole issue of fees for automatic teller machines or anything like it.

[The Chair, Conservative, Brian Pallister]

You would keep those private.

[Some hon. members]

Oh, oh!

[Heather Black]

Exactly.

We are, however, greatly concerned about the rising incidence of electronic data theft, which leads increasingly to credit card, debit card, and bank account transfer fraud. The numbers are going up on incidents of that nature. Consumers are increasingly unable to recoup the cost of setting some of these things straight. There are weaknesses all along the chain in some of these cases, and probably the weakest end of the chain is in the retail sector, which is more vulnerable to hacking than the banks.

I'll be pleased to answer questions--unfortunately in only one official language.

[The Chair, Conservative, Brian Pallister]

Thank you very much, Madam Black.

We'll continue with Jim Westlake from the Royal Bank of Canada.

Welcome, sir. You have five minutes.

[Jim Westlake, Group Head, Canadian Banking, Royal Bank of Canada]

Thank you, Mr. Chairman.

Thank you to the members of the committee for the opportunity to speak with you today.

I'd like to start by saying that Canada has one of the best, most affordable, and most efficient banking systems in the world. The price of retail banking services, including ATM access, is low relative to other countries and is driven by intense competition. Canada has more ATMs per capita than any other country. Our pricing is fair and transparent, based on a pay-per-use principle.

At RBC, our clients benefit from access to Canada's largest distribution network, including more than 1,200 branches and business banking centres, telephone and Internet channels, almost 2,000 mobile bankers, and of course almost 4,000 ATMs, which are available to our clients at no direct charge. In fact, 80% of our clients do not pay for using our ATMs. Our network of ATMs is the most extensive in Canada and we are expanding, with plans to deploy more than 400 new machines in the next three years. All of these are RBC machines. We do not own any white label ATMs.

Students benefit from our extensive network. We have 67 ATMs now, or planned, on 35 college and university campuses, and 446 ATMs within one kilometre of the 229 university and college campuses in Canada.

Seniors and people with disabilities also benefit. We were the first bank to offer audio-enabled machines, which are serving as a prototype around the world. Today our clients have access to 425 of these talking ATMs in Canada, and more than 550 machines have been designed so that people in wheelchairs have easier access.

A fundamental part of RBC's philosophy is that we are located in and contribute to communities all across Canada, because where our communities succeed we all succeed. Our 60,000 employees work hard every day to provide our 12 million clients with financial products, services, and advice at competitive prices. Competition is working and Canadians are being well served by a stable, efficient banking system that provides maximum choice and convenience.

Any attempts to reduce competition, including additional regulation, will only lead to fewer options for consumers. This point has been recognized by many, including members of this committee. Without the flexibility to charge and price on a competitive user-pay basis, our clients and shareholders would effectively be subsidizing access to our ATM network for clients of our competitors. It's unlikely that we would be able to continue to maintain a network of 4,000-plus ATMs; innovation and access would suffer and costs to consumers would undoubtedly rise. Increase regulation and you'll be reducing choice for students, seniors, people with disabilities, and all Canadians.

Thank you. I'll be pleased to answer any questions.

[The Chair, Conservative, Brian Pallister]

We will continue with Tim Hockey from the Toronto Dominion Bank.

Welcome, Tim.

[Tim Hockey, Co-Chair, TD Canada Trust, Toronto Dominion Bank]

Thank you, Mr. Chair.

Mr. Chair, honourable members, thank you for the opportunity to appear before you today.

TD employs about 58,000 people and has over 14 million customers around the world, over 10 million here in Canada. At TD we place a premium on customer service, a fact recognized by external surveys that place us first in customer service. We ask more than 400,000 customers each year how we are doing and what we can do better to ensure we offer the service they want and deserve. This is reflected in the wide array of accounts, products, and services we have designed to suit the needs of our customers, including low-cost accounts and special accounts for students and seniors.

Our customers also choose how they want to bank with us. If they prefer dealing with the branch, we have an expanding network across the country and the longest branch hours in the industry. In the past three years, TD Canada Trust has opened 63 new branches, the highest number of all the banks, and we plan on opening another 30 this year.

If customers choose to bank online, TD offers EasyWeb, an award-winning, full-service online banking experience. We also offer telephone banking through EasyLine, and of course we are expanding our network of automatic banking machines. We offer ABM services exclusively through our network of conveniently located Green Machines. TD does not own or operate so-called white label machines.

Our bank is very proud to have invested over $250 million installing more than 2,500 brand new Green Machines across the country, all of which feature the latest in security and assisted technology for disabled customers.

Recently we announced that we would install a TD Green Machine on or within walking distance of large university and college campuses in Canada to help make sure more TD customers have convenient access to their money. We did this because we recognized that we did not have a presence on all campuses and wanted to ensure that students, particularly TD Canada Trust customers, had access to our ABMs. We have now written to the identified schools and look forward to moving forward with this plan.

TD owns and operates its ABM network to maximize the service we offer to our TD clients. TD customers pay very low or no monthly charges to access their funds via our Green Machines. Eighty-one percent of all TD Canada Trust accounts do not pay any transaction fees when using TD Green Machines. Seniors who belong to the Plan 60 account do not pay any fees at all.

TD ABMs are linked to a wider network that allows non-TD customers to access their money through our machines, and as you know, there is a transactional fee associated with this service. This system is very transparent. TD and the banking industry have worked very hard to ensure Canadians understand the fee system, and over 75% of ABM withdrawals in this country are made by Canadians using their own bank's ABMs. In terms of the TD experience, over 80% of TD Green Machine transactions are made by TD customers.

On the issue of electronic payments, I would be happy to answer any questions about TD's role in the bill payment process. I would like to make the point, however, that all bills our customers pay online get processed by us that day, but it can sometimes take two business days for the payment to get processed by the billing company. It's worth noting, though, that 95% of TD's billers recognize the transaction date as the payment date, thereby minimizing the customer impact. Information advising customers of processing times has always been available on our EasyLine and EasyWeb online service.

As my time is short, I would just conclude by saying that TD has always encouraged customers who have questions or concerns about any aspect of their banking experience to talk to us about the account options that best suit their needs.

Thank you. I'm happy to answer your questions.

[The Chair, Conservative, Brian Pallister]

Thank you very much, sir.

From the Bank of Nova Scotia, we have Christopher Hodgson with us. Welcome to you, sir, and five minutes is yours.

[Christopher Hodgson, Executive Vice-President and Head of Domestic Personal Banking, Senior Executive Office - Domestic Personal Banking, Bank of Nova Scotia]

Good morning, Mr. Chair and members of the committee. Thank you for the opportunity to speak with you today.

First of all, let me tell you a bit about our bank. Scotiabank is Canada's most international bank, anchored by a strong franchise here at home. We have just under 1,000 branches here in Canada and 2,800 ABMs. Our bank is 175 years old this year, and we're very proud of that. We've seen a lot of changes in such areas as electronic banking, but we fully recognize that new channels are additional options for our customers rather than replacements for branches.

I am going to focus my remarks in the next few minutes on ABM fees, although I will be pleased to answer any questions you may have.

I would first like to state that I appreciate the concerns expressed by the members of this committee and by Minister Flaherty. We strongly agree with the minister and the Department of Finance officials that the best way to protect the consumer interest and make the marketplace effective is through competition and choice.

We face stiff competition for clients. The number of different account packages and features that exist is a good example of the degree of competition driving these differences. We are constantly reviewing our account packages to ensure that they remain competitive and effective in meeting the needs of our customers. We're also interested in finding solutions to address access issues for customers most impacted by the fees that result from the use of our competitors' ABMs.

More than 75% of our customers never pay an ABM convenience fee, as they choose to use Scotiabank machines. Furthermore, we're adding branches and ABMs across the country so our customers can find a Scotiabank when they need one. In addition, customers can access Internet and telephone banking at their convenience.

Finally, we're seeing an increasing trend by customers to use point of sale as an opportunity to take cash back and minimize fees.

Consumers benefit from the range of options they have to access their accounts, including a coast-to-coast ABM network that ranks Canada first in the world in terms of access as defined by ABMs per capita. Canada's major banks control one-third of the ABMs in Canada. Two-thirds of the ABMs are controlled by other providers.

I know the committee has been interested in ABM fees in the U.K. market. While this model may seem attractive on the surface, it provides significantly less access, it relies on a lower standard of disclosure of fees, and it results in higher costs to consumers through hidden charges. This model is sound from neither the consumer's perspective nor in the interest of competition. It is very important to consider the total cost of banking, and on this metric Canada is one of the best in the world.

In summary, we offer our clients very competitive service packages. We also welcome input not only from our customers but from the government on an ongoing basis as we review and upgrade our service offerings.

Mr. Chair and members of the committee, I'd like to thank you very much for the opportunity to speak with you today.

[The Chair, Conservative, Brian Pallister]

Thank you very much.

We continue with Maurice Hudon from the BMO. Welcome to you, sir. You have five minutes.

[Maurice Hudon, Senior Executive Vice-President, Personal and Commercial Banking Canada, BMO Bank of Montreal]

Thank you, Mr. Chairman.

We are pleased to have the opportunity to appear before you to discuss our approach to automated banking machines.

BMO has invested heavily in our network of Instabank banking machines. We currently have nearly 2,000 machines across the country. In the past couple of years we have replaced every one of them. Our new generation of machines makes banking from an ABM more accessible, faster and simpler. In short they make it easier for our customers to do their business with us.

We have been strategic about locating our ABMs in locations that provide convenient access to our customers, allowing them to avoid hassles and fees, especially those charged by the higher-priced, white label ABMs. For example, we have more than 200 ABMs within one kilometre of university campuses across Canada and an additional 300 within two kilometres.

Our customers' behaviour tells us we must be doing something right when we decide where to locate our machines because, at last count, about 85% of our customers' transactions were completed at BMO machines, compared with 75% industry-wide.

That said, we do take seriously the concerns raised by the Minister of Finance and your committee. We recognize that you are approaching this issue not only as responsible public policy-makers, but as consumers of banking services, in your own right.

So, we are conscious of your concerns about the cost of banking for seniors and students, which is why we provide no fee banking plans for both these groups.

Seniors in the know know that BMO's banking plan for seniors is free and that it is the only free seniors plan that offers them one free monthly Interac transaction at another financial institution's ABM.That's a market response and it's a competitive decision.

Students in the know have known for some time that BMO has the best student banking plan, a free banking plan, with the added flexibility of one free e-mail money transfer per month. When compared to most of our competitors before you today, our free monthly plan saves students anywhere from $1.25 to $3.45 per month. That adds up over the course of a year. That's a market response and that also is a competitive decision. Yesterday we reaffirmed our commitment to seniors and students by extending the fee waiver on our performance plan for seniors and our plus plan for students for three more years.

What does this all mean, Mr. Chairman, in practical terms? It means that in 2006 we provided free banking services to 390,000 students, as well as to 866,000 customers aged 60 or over.

Let me cite another example of a competitive solution to the issue of ABM access. HSBC and BMO entered into an agreement under which HSBC decided to buy access to our Instabank network instead of making a large capital expenditure of their own. Under this arrangement BMO does not charge a fee to HSBC customers who use our machines. Nor does HSBC, but then, neither did they incur the cost of building the network. HSBC customers can even make deposits to their accounts through a BMO machine, and as you know, Mr. Chairman, your committee has discussed this issue of full functionality in the past.

The point is that there is nothing stopping individual financial institutions from using these kinds of creative arrangements to gain competitive advantage, and we have. That is a market response and, again, a competitive decision.

Mr. Chairman, I thank you and your colleagues for giving us a chance to exchange views on the subject, and of course I'd be happy to answer your questions.

[The Chair, Conservative, Brian Pallister]

Thank you, sir.

We'll conclude our witness presentations with David Phillips. Welcome back to the committee, sir.

Mr. Phillips is from the Credit Union Central of Canada.

Over to you.

[David Phillips, President and Chief Executive Officer, Credit Union Central of Canada]

Thank you very much, Mr. Chairman and committee members. I want to thank you for this opportunity to appear before the committee as part of your study on ATM fees.

My name is David Phillips, and I'm president and CEO of Credit Union Central of Canada, commonly known as Canadian Central.

Canadian Central primarily represents the nine provincial credit union central organizations in Canada, and through them 498 credit unions. I should point out that these credit unions are situated in all provinces of Canada except Quebec. We do not represent the caisses populaires of Quebec.

I would like to limit my opening remarks to three specific points. Two of these are points of contrast with the banking industry, and the third I suspect is a point of similarity. The first point of contrast is the existence of surcharge-free, inter-credit-union networks in the credit union system. Unlike the large commercial banks, individual credit unions, being community-owned financial institutions, typically do not have large and extensive branch and ATM networks. For this reason, and for competitive reasons, credit unions participate in ATM networks that provide their members with surcharge-free access to cash withdrawal services on a national basis. One of these networks is known as Acculink. Acculink is a credit union only network. It is comprised of 435 credit unions and provides access to approximately 1,700 ATMs on a surcharge-free basis across Canada.

You heard about a second surcharge-free network this past Tuesday, and you've heard about it earlier today, known as the Exchange network. Many credit unions participate in this network, along with a few banks. Through participation in one or both of these networks, and depending on the credit union of which you are a member, credit union members will have surcharge-free access to between approximately 1,700 and 2,700 ATMs on a national basis. This is an important service to members, which enables credit unions to maintain competitiveness with the ATM networks of the large banks.

A second point of contrast between credit unions and the banks is the manner in which credit unions set service fees for the financial services obtained by their member customers, including ATM access fees. Unlike the large commercial banks, which typically design and offer fee packages on a national basis, the credit union system is comprised, as I've said, of 498 credit unions, each of which design and provide their own fee packages separately and independently in the communities they serve. Since the array of packages is so vast, it is not possible to generalize about the nature and level of service fees that credit unions might charge their member customers for ATM access.

However, it is worth noting that the customers of credit unions are also the members and the owners of their credit unions. They annually elect the boards of directors of their credit unions. So if credit union members have views about the fees charged by their credit unions--favourable or unfavourable--they have a very direct way in which to assert these views at the level of the board of directors and senior management of the credit union.

I believe my third point is a point of similarity with the banking industry on the subject of efficacy of government regulation in this area. Currently the ATM surcharge, where it exists, is a fee that is both transparent and it is usually avoidable. In our view, regulation aimed at limiting surcharging is likely to undermine these aspects of the fee and would probably reduce the availability of ATM services to the Canadian public. We are not persuaded that the regulation of ATM fees would achieve positive results.

This concludes my remarks, Mr. Chairman. I'll be happy to answer any questions on this subject.

[The Chair, Conservative, Brian Pallister]

Thank you very much for your presentations. It is highly unusual that you would all keep within that five minutes. I do appreciate it, and I know the committee appreciates it. It will allow more time for exchange with the members.

We'll begin with Mr. McKay now, seven minutes.

[John McKay, Liberal, Scarborough—Guildwood, ON]

Thank you, Mr. Chair.

Thank you to each one of you for coming. You're almost as popular as the RCMP today.

I want to first of all ask Mr. Taylor about the law of unintended consequences. Prior to the consent order, am I to understand that those members of Interac didn't charge fees? And then after the consent order, which accessed further financial entities, then fees were charged. Is that correct?

[Richard Taylor]

I'm not able to answer that right away. I don't have first-hand knowledge of the period before 1996. They did always charge what they called the network access fee. Whether they charged a convenience fee, I can't answer. I can find that out for you, or maybe somebody from one of the banks could answer that.

[John McKay, Liberal, Scarborough—Guildwood, ON]

Possibly somebody from one of the banks could answer that then.

Mr. Westlake, do you know?