That was a report that was done after my departure from the OSB. I left for about three years.
Since my return, we've taken a close look at what we're calling the debt advisory marketplace. As I've mentioned, there are credit counsellors in Canada who are excellent. They are well trained and are really looking out for the best interests of debtors and helping them to find solutions, and they are often regulated by the provinces.
However, there's a subset that really falls into a no man's land. They're not regulated by my office and they're not regulated by the provinces. That's because they don't fit the definition of provincial legislation. What we have found is that in some cases, those players are playing an intermediary role between the debtor and the licensed insolvency trustee. They talk about being an advocate for the debtor, but their real business model is basically to bring the debtor to the licensed insolvency trustee to file a consumer proposal.
What we've observed is that this isn't always positive for any of the parties. As you've mentioned, the debtor doesn't always get the full information, and creditors sometimes get a lower return compared to other files.
It's something we're continuing to look at. It's a multipronged project. We're going to look closely at the LITs and make sure that they know their duties are set out in the act, that they need to abide by them, and that if they do not, there are consequences.
We also want to work with the provinces. That's a tough job, but we want to start that project to see if we can close the gaps in these legislative provisions.