For a credit union, the membership list is also the credit union's customer list. The provision in Bill C-9 dealing with membership lists could therefore provide a competitor of a federal credit union with the means of obtaining access to a list of all the credit union's customers. This could be a major impediment to take-up of the federal credit union option.
Fortunately, there is a simple solution, namely to change the rules to correspond to the rules for federal insurance companies, whereby par policyholders and shareholders are not permitted to obtain the list of par policyholders. This is appropriate for policy reasons and also to prevent a competitor from buying shares and using the entitlement to obtain a full list of par policyholders.