It is thorough, I'll tell you that. It is thorough and it has a lot of points in it. At different points, the Minister of Finance has tried to address it, but it's multi-point, two-page, bullet-point, rather like the way my motion is here, on what are the instructions to the Minister of Finance and what he is supposed to be doing.
You'll forgive me for saying this, but when I looked at it initially, I couldn't find open banking in here. It just seems to be an extra thing that was layered on top after the fact. However, some of these things here have not been done yet, as far as I can tell. They haven't been looked at. Some of them are to co-operate with another minister; some of it is about the clean technology fund; some of it has to do with working with the minister of indigenous and northern affairs to establish a new fiscal relationship; and some of it has to do with EI.
Again, when I went through it, I did not find open banking, which then leads me to openly question why the Government of Canada has this advisory group that has this consultation, whereas now this committee is going to look at open banking. I would be the first to say that we shouldn't be looking at the minister's mandate letter for us to consider whether a study is a good idea or a bad idea.
I have gone through many ministerial mandate letters for inspiration, and in here I simply do not see open banking. Open banking would actually impact some of these points and how some of these things work, and it goes back to my point about how government bodies collect private information.
My last point, my last bullet, is about the principle of financial transparency in open banking and how it could be applied to things such as the CCB, how it could be applied to things such as EI. Perhaps it would be a good idea if the same idea about open banking could be practised by the EI fund, where a Canadian could go and consent to a sharing of information with other financial institutions and could maybe access that information, such as “How much have I paid into EI since I started working?” I'm sure there are a lot of people out there who would be curious. I'd be curious. I'm sure there are other members who would be curious. How much have you paid into CPP?
Perhaps it would be a way for you to share your CPP information, just by the click of a button, with your financial adviser or planner, which you have agreed to ahead of time, to share information with them so they can do better financial planning for you. Instead of providing you with an estimate, they could provide, perhaps down to the penny, exactly how much you can expect when you retire at age 55, 60, 65, 70, or 75, and it gives you a better idea of what's out there. However, I just don't see that in the original motion, which is why I am proposing to do it here.
Looking at the mandate letter, I just see a lot of opportunities for, again, these government bodies to be more directed in the type of work they do, the open banking principle, which is transparency. If the consumer is the main focus here, and I think it is, and I totally believe the government caucus when they say that consumer protection is the first thing mentioned, that the consumer comes first and open banking is to maximize the benefit for the consumer, but if that is the way, then why don't we practise that same principle for taxpayers when it comes to the Government of Canada's services and programs and the amount of money we give to them?
The principle should be the same, so that whatever we decide on open banking, could we then also say that for government bodies, you will produce information in a way that makes it simplified for open government, and not just put it in the government's open data website—opendata.gc.ca—where they just drop in a whole bunch of Excel spreadsheets, which are really hard to use and some of them are not all that useful? Give people some more control, at least so they know, as I said, on CPP, on EI, or on registered disability savings plans, so maybe they don't need to go and talk to a financial adviser. Through the click of a button, there could be a Government of Canada app that tells your current balance with all these institutions, so then you know.
Again, I don't see it here in the mandate letter, so I'm just a bit concerned that we're not following what the government is doing, outside of following what this advisory committee has started to do.
If you look at the mandate letter, if you wanted to, you could do a study just assessing whether the minister has met all the points in the mandate letter. I've actually gone through it and colour-coded it for myself, and some of them have not been done at all.
The minister has already taken on an extra task, this open banking, that is not in his mandate letter. I look at the mandate letter and I have seven things that they have done, and there are quite a bit of red and quite a bit of yellow things that are supposedly in progress or not being met. The deadlines are all very quick, because they're obviously before the next election. Mandate letters expire at some point.
I think, on the point here, that if we're going to do this open banking study, we should make it as detailed as possible. When we make it as detailed as possible, we can report detailed findings to the government. I don't think that's a bad point. I don't think it's negative; I think it's perfectly reasonable.
Again, on point (j), financial transparency should be practised by government institutions. We could discover how.
Then, on the point about prioritizing open banking by this current government, I'm just wondering why that didn't make it into the original mandate letter if it were so important. It's also 2019 already, so we're at the tail end of this current government's mandate to do its review. I'm just a little concerned here that we're going to be undertaking a study while making it as specific as possible, and the minister's mandate letter is very specific, like I mentioned. This is the depth here of the minister's mandate letter. It went detail by detail into what they are doing and the different points in it. Like I said, I think it's incumbent on us to have as complete a motion as possible. It wouldn't hurt the study we're undertaking. It would just make it more specific.
I want to move on to my next point, here, which is point (i):
what the appropriate level of government regulation over Canadian financial service providers ought to be, considering the history of the Canadian context as well as that of other jurisdictions around the world
That goes back to the point I made about how much time we spend legislating what Canadians can do. We don't spend enough time legislating what government departments and regulators can do, and that's really important to me. I've included it here, because if we're going to consider consumer protection, privacy, cybersecurity and financial stability, we have to look at it from the point of view of what government bodies and government regulators are doing now and what kind of rules we can set onto them to empower the consumer and to empower the financial institution to serve the consumer.
Open banking cannot be about making it easier for government to collect data. It just can't be. That will lead to a lack of transparency. There are a lot of Canadians who already feel that way. There's just simply a lack of transparency. Government is so big that it's difficult to keep track of all the things it's engaged in and all the things it's doing. This has to be about putting the consumer first, and, in my mind, the consumer in open banking is not the financial institution. The financial institution is there to serve them.
The previous Auditor General, before he passed away, blasted the government for refusing to provide him with key financial information. He said at the time that the lack of transparency prevented him from completing an audit on the elimination of fossil fuel subsidies. That's the way he termed it. That's from a Globe and Mail article by Daniel Leblanc, parliamentary affairs reporter, dated May 16, 2017.
There's a lot of information held by the government already that would be helpful to consumers, but there is no government rules setting out how they're supposed to make it public. My experience has been, with access to information requests and with OPQs—Order Paper questions—that the government is not forthcoming with information. It provides me with very generic answers or tells me to go to a government website to obtain information. That's not good enough. If in open banking we're talking about that same user experience they have with the government being superimposed onto financial institutions, then that really should not be the way we do this.
In this article, it went on at length to talk about the transparency and openness failings of the Government of Canada in the services it provides and information it shares with officers of Parliament, including the Privacy Commissioner, which has happened before. That's been an issue of previous governments, too. I'm not going to lay blame just on the current Liberal government. It has been the experience of past governments as well. That's been the experience with the RCMP, with Canada Border Services Agency and with a whole bunch of these institutions.
In this open banking, again, I think that adding in a point about the appropriateness of government regulation and about making sure Canadian financial service providers.... We should look at the broader context here, the landscape, what types of rules are being imposed on financial institutions and if any rules are to be imposed on consumers. How much are we expecting consumers to know and be aware of and how much are we wanting them to be involved in their daily financial information and information sharing?
So I would hope that in any study such as this, we don't just leave it to the four broad points we have in here, and we have in here too what steps, if any, the government should take to implement an open banking system.
