First, I would mention that the regulations already include some measures to encourage compliance, such as fines or AMPs. Also, recently specific obligations were introduced to basically require brokers and agents to document every step of the way. They're called “reasonable measure” records.
There are, then, some things in place. I think, however, that you can streamline some areas in cases in which the obligations imposed don't really make sense. For example, we have a policy interpretation from FINTRAC that says you have an obligation to know who your client is, and if you do repeat business with them you have an obligation to make sure that, say, their occupation hasn't changed.
However, what if you're doing two transactions concurrently? Basically, what FINTRAC has told us is that if you ask someone what their job is—let's suppose they say they're a plumber—and you're doing another transaction, you have to ask them again: “Remember that a minute ago I asked whether you were a plumber? We want to know whether you are still a plumber.” This makes no sense.
If we had a policy interpretation that recognized the way real estate actually is being conducted, which is that people often buy and sell homes at the same time or in a very short period and there is no need necessarily to ask the exact same question, such as, “Did your date of birth change?” or “Did your occupation change?”, it would be a way for FINTRAC to have more credibility. Then we could tell that what they're really saying is that they want to make sure you know whom you're dealing with.
We don't have an issue with that. We know we have a role, but it has to make sense.