I guess I should begin by reminding you that regulating the banks is a job for OSFI, and that's not me passing the buck at all. As for what OSFI has said to the banks and publicly, it has not told them they can't pay dividends, but it has asked them not to increase their dividends, which is something that historically they've tended to do, and to stop using their capital for buybacks.
One of the reasons OSFI has taken that position is that it had imposed what we call a dynamic stability buffer, an extra capital buffer on top of its regular capital requirements, in advance during what we call the good times of roughly two percentage points. I think it was going to be 2.25% by now. What happens, then? Saying to them that it's okay to reduce the buffer now has the same effect on the economy as if we were in a different economy without a buffer and they said let's not have any dividends. What it does is keeps capital in the bank and allows it then to be used to expand lending if that is the demand.
As I described before, we had a tremendous amount of drawdowns from companies drawing their credit lines in the early days of this period, so this move by OSFI helped that situation quite a lot because the banks can satisfy the requirements at a slightly lower level. We have at least been operating in the same way; it's just that we had an additional tool there, not a tool that the Bank of Canada manages but OSFI's tool. You'll recall, perhaps, the day that the superintendent and I appeared with the minister to describe the basket of changes that happened all at once.
As for the other items you raised, I'm not going to be the defence for the banks. I'll just say that the banks have been important conduits for the policies that have been enacted. Additional lending policies have been put in place, and the banks are running those programs on behalf, essentially, of the government because they're the ones connected with the clients. They have a lot of risk already, of course, in existing loan books. We shouldn't forget this. In crises, there will be strains in the credit in their books. This is also something to take into account.
As for mortgage deferrals and the reduction of credit card rates, that is somebody else's province. I'm glad to see the flexibility they have put out there, because I think that in this deepest downturn of the economy, that's an important buffering mechanism.