The framework is optional, but if credit co‑operatives want to compete with the banks and participate in the open banking system, they will have to comply with the framework, which is under federal jurisdiction.
That means that rather than simply ensuring that a common technical standard is adopted for all financial institutions, the framework will duplicate what already exists in the provinces, in terms of the protections and regulation of relationships between consumers and financial services providers.
During testimony at the Senate committee, we understood that the laws of Quebec and the provinces could continue to apply. However, there then would be duplication. Rather than have a harmonized common standard, as was done in the case of securities, an institution under provincial jurisdiction will have to comply with the province's standards, such as consumer protection standards, and also the federal standards.
For provincial financial institutions, this will double their responsibilities, and that will undermine their competitiveness vis-à-vis the federal financial institutions. Do you agree with that reading?