I would say that older Canadians can be vulnerable consumers, and strictly relying on disclosure and consent as a way to protect those consumers would not, given the complexity of a lot of financial products, be adequate. Therefore, the appropriate standard is a step in the right direction. I would also add that banks can play a very important role in recognizing loss of capacity and potential elder financial abuse issues. FAIR Canada has co-authored a report with the Canadian Centre for Elder Law on vulnerable investors. We made six practical recommendations including amending the privacy legislation federally to permit workers, employees and different staff at banks to play a positive role in dealing with that problem.
On November 8th, 2018. See this statement in context.