Absolutely. To understand enforceability in relation to our guidelines, it would help if I take a moment to step back to situate it within the supervision framework that the FCAC has established and works within. Quite simply, the supervision framework is organized around three pillars of activity: promotion, monitoring and enforcement. Specific to the guideline, the guideline is a tool to promote compliance by way of establishing clear expectations from a regulatory perspective.
I'll stick with the example of the guideline. As it relates to monitoring, we actively engage on a regular basis to identify emerging issues with respect to implementation to either get out ahead of them or ensure that corrective actions are being planned and taken with respect to them. In the case of the guideline, there is the added requirement for reporting, so obviously the reporting allows us to monitor.
With respect to enforcement, we have a bit of a graduated model, which is to say that as issues surface and we assess them against risk, we increase the intensity of our oversight and supervision. The guideline does include some important provisions—those related to the offering of appropriate products and services. There are provisions in relation to disclosure and how that's provided so that it's clear and not misleading. There are also provisions with respect to express consent, which means receiving written confirmation of whatever you've agreed to.
When these provisions are found to be non-compliant, we undertake investigations, and when those investigations confirm the non-compliance, we will issue an enforcement action, of which we have more than one type depending on the nature of the non-compliance.