Yes. Certainly from the smaller institutions' perspective, I guess the first thing I would say is that FINTRAC is not a very direct regulator. For years and years, FINTRAC deferred to the Office of the Superintendent of Financial Institutions for the supervision of banks and other financial institutions on its behalf. They seem to have come to some better understanding about who is responsible for what, but I think that from the institutions' perspective, it's still very unclear who their primary regulator is. They've ended up in a world where they're really subject to two regulators.
OSFI continues to play a role. They take the position that compliance with anti-money laundering laws is a prudential matter and that institutions are subject to reputational risk and therefore that OSFI should continue to play a role. FINTRAC has begun to do its own examinations, which are separate and distinct from the OSFI examinations, on the basis that they are the actual statutorily empowered regulator.
For the small institution, I think they are left in a confused situation as to which regulator is really responsible for oversight. I think that continues to evolve, but from the small institution's perspective, it's not precisely clear who is responsible for what.