Just quickly, with respect to the committee that's been created, we would like that to have a specific name. Its duties should include establishing policies, not only procedures, and ensuring that it reviews the implementation and compliance by the bank with the policies and procedures.
With respect to complaint handling, we recommend that the banks should have to report total complaints received, not simply the number and nature of complaints that reach the most senior person, so that a fulsome understanding of the number of complaints that banks are receiving is made public and understood.
We think that there should not be multiple steps that a bank makes a customer go through internally in order to address their complaint. There should be one process, not two. This has been the way that reforms have occurred in other leading jurisdictions. Time periods for internally handling complaints and for external bodies to handle complaints need to be clear, transparent and objective.
With respect to disclosure, we recommend that information about all charges or fees for a product or service be in dollars and cents. We recommend that interest or returns be disclosed on an annual basis.
With respect to the whistle-blower provisions, which we see as a positive development, we strongly recommend that one office be created in order to receive and address whistle-blower complaints and tips, not several bodies or organizations or entities as set out in the bill.
We understand and agree that confidentiality is a critical component, and this should be extended to all individuals who come forward in good faith with information regarding possible wrongdoing. Other authorities or agencies should be subject to the same confidentiality provisions as those binding the office we believe should be created, and assurances of confidentiality should be obtained prior to sharing the confidential information, to protect the identity of the whistle-blower.
Individuals should be able to come forward on an anonymous basis through legal counsel. With respect to protection from reprisal, the office should have the ability and the legislative authority to bring an enforcement proceeding against a bank that retaliates against a whistle-blower. It shouldn't just be that the whistle-blower himself or herself, having lost their job, has a right to pursue litigation against a bank, given the economic power disparity between an individual and the bank. We recommend that there be a statutory right of action and that there be the ability of the office to bring a proceeding, in order to deter retaliatory actions.
Finally, we recommend that agreements that limit an individual's right to report wrongdoing, whether an employment contract, non-disclosure agreement or otherwise, should be deemed unlawful so that individuals have the right to report wrongdoing, and so that they know they have that right and that it's not limited through contract.
Thank you very much for the opportunity to present our views here today.