I looked at the same thing. Quite honestly the two reports put together provide the minister with a full picture of what is happening. They both highlighted that enhancements in reporting had happened in all sectors, and that is true.
As Mr. MacKillop has said, we changed the way we were doing audits. In 2017 we moved to an assessment model. You will see a difference. The way we were doing audits before, we would go into a bank and we might find a minor deficiency. For example, perhaps an address was not entered completely. That still allows us to do the work we need to do, but it's a minor deficiency.
A reporting entity such as a bank has millions, even billions, of transactions. If a bank had that deficiency occur a number of times, the number of issues in that one field would result in a major deficiency. The current definition of major deficiency can be clarified a bit further, because a lot of minor doesn't always mean it's major. The banks can fix that quite quickly, through a system fix, for example. As Mr. MacKillop said, the more we do audits, every single time we look at a file, if it's the exact same issue that we have found, we will add it every time. The number, because it's so big, turns the issue into a major deficiency.
As we move to an assessment model, we are actually looking more at the impact, which is a more outcomes-based approach, looking more at what is the impact of not having this information. If it is severe, it will be very significant. If it is a field that is missing that still allows us to do the job, it won't be identified as very significant. We're in the process of making those definitions a bit more clear and transparent in terms of what they really mean.
We are pleased that our reporting entities are improving. We're getting more suspicious transaction reporting in all of our sectors. We've actually received more. The quality is improving. Can we do better? Absolutely. Will we do better? Absolutely. We are moving in the right direction.
Also, a number of new obligations were introduced last year. Always, with new obligations, as they are preparing their systems, there could be deficiencies that are found.