There are a number of ways we could work better with FINTRAC, or FINTRAC could work better with us, in order to get to where everyone wants to go, which is fighting money laundering.
You are correct. We recognize that there is money laundering in the real estate sector in Canada, and our members play a role, but there is a lot that they can do. They can give us tools in order to get where they want to go. One example would be more meaningful outreach.
We do meet with them on occasion, but not regularly. It can be a struggle sometimes to meet with them. When we do meet with them, we ask for policy interpretations. Sometimes we email them policy interpretations. It's great that we can do that, but when we get a response, which sometimes can take many months, which is not helpful, the policy interpretations we get can be vague or require further confirmation from them of what they exactly mean. They might just quote us the legislation again. They might not use the language that real estate brokers and salespersons use, which is really important. A one-size-fits-all approach and the use of generic language is not a helpful policy interpretation. That is something else that we could get.
Also, there may be instances where clear and specific regulation and guidance tailored to the real estate industry might be necessary. We're seeing this on the guidance side. Right now, FINTRAC is looking at updating their suspicious transaction reporting guide. What we're looking at right now is core guidance that is applicable to all sectors, but if you look at the language, a high percentage is geared towards financial institutions.
There are lots of ways that we think we can benefit.