Thank you, Mr. Chair, and thank you, committee members.
I'm here with my colleague, Rob Martin, representing Canada's credit unions.
Credit unions, as you know, are member-owned, full-service banking institutions that serve over 5.6 million Canadians. We contribute $6.5 billion to our country's GDP and help create over 58,000 jobs. We support small and medium-sized business with 11.5% market share, and that market share is close to 50% in some markets out west. In a recent CFIB study, credit unions are far ahead of the banks when it comes to serving small and medium-sized business in Canada.
This year, for the 12th year in a row, we ranked first in customer service, well ahead of the banks. We do this from what is largely a traditional banking model: taking deposits, making loans. However, the current environment is challenging for us, with low interest rates, federal tax changes, increased regulatory burden, and new mortgage lending rules, which are all making it more difficult to serve our markets, mostly middle-class Canadians.
My remarks today will focus on two key priorities: allowing for a regulatory pause to assess the full impact of recent mortgage change rules before any new risk-sharing measures are considered, and implementation of a risk-based approach to the common reporting standard.
Our first and most pressing recommendation is that the government implement a regulatory pause to assess the impact of recent mortgage rule changes before proceeding with new risk-based measures. As you know, the government recently announced two changes to mortgage insurance parameters. The first change implements a stress test for high-ratio insured mortgages. These borrowers have less than a 20% down payment. The second change will implement, as of November 30, new qualifying requirements to obtain low-ratio mortgage insurance. This is when a borrower has 20% or more as a down payment.
In our view, and the view of others, the recent measures will dampen mortgage markets across Canada and will make it more difficult for those aspiring to the middle-class goal of home ownership. To elaborate, in the October monetary policy report, the Bank of Canada recognized the impact that these measures will have, and projected a slowdown in the housing market through 2016 and 2017. In fact, the bank projects that in 2017, rather than being a net contributor to GDP growth, the housing sector will become a drag on the Canadian economy.
The bank also projects a significant dampening of resale activity across Canada. According to Genworth Financial, a little over one-third of insured mortgages, predominantly for first-time homebuyers, will have difficulty qualifying for mortgage insurance. Genworth has also estimated that approximately 50% to 55% of its total portfolio of new insurance written would no longer be eligible for mortgage insurance under the new low-ratio mortgage insurance requirements. Preliminary credit union analysis suggests that, in some instances, up to half of low-ratio mortgages would no longer qualify for low-ratio insurance. This could have a significant impact on funding opportunities for credit unions and our ability to raise capital, and would increase prices for members and our customers.
On top of these measures, the government released a consultation paper on mortgage insurance risk sharing just last week. Two of the proposed models would require lenders to accept more losses if loans default. A third model would establish premiums that lenders would pay that would be based on loan losses in a specific period. In our view, implementation of any of these proposed models during a period before other mortgage measures have taken hold would be unwise. Mortgage activity would face a further slowdown, credit costs would rise, resale activities would decline, and mortgage credit would be harder to come by.
As the market tightens, aspiring homeowners across Canada would find it more difficult to obtain a first mortgage or get home financing in economically challenged regions. It is especially concerning, because many of these regions have not experienced the housing sector upswings, as in the Toronto and Vancouver markets. Credit unions are particularly concerned about the impact these measures would have on the 380 small communities where they are the sole bricks-and-mortar financial institution.
Once again, I'd like to emphasize the need for a regulatory pause before the government moves toward implementation of a new risk-sharing framework.
Our second recommendation is to incorporate a risk-based approach to the common reporting standard. As you know, in Bill C-29, the government included an amendment that will bring a common reporting standard into force in Canada. The standard is intended to help curb cross-border tax evasion by facilitating the automatic exchange of financial account information between tax jurisdictions, except, of course, the U.S.
Bill C-29 does not propose a risk-based approach to compliance. Instead, the standard is being implemented on a one-size-fits-all basis to require all financial institutions, even those that are at low risk for being used for this type of tax evasion, to begin reporting on all accounts held by non-residents, this despite the fact that the CCUA survey found that the median number of non-U.S. non-residents served by Canada's credit unions is three—just three. This means that every credit union will have to dedicate additional resources for account screening, review, analysis, monitoring, reporting, and record-keeping. Banking system changes will need to be made and additional staff training undertaken, all to report to CRA annually on a handful of foreign-held accounts.
In our view, regulatory compliance based on risk assessments makes more sense. To this end, CCUA urges the federal government to apply a risk-based approach wherein institutions qualifying under an annually applied test would be exempt from CRS obligations. This is similar to the approach that we applied under FATCA, the current bilateral tax agreement with the U.S., and it makes sense to apply it for the common reporting standard.
Thank you for the opportunity to speak today. We look forward to your questions.