These four targeted actions could improve the resilience of Canadian households.
First, we believe that stronger federal-provincial alignment is needed to improve consumer protection. Rules on issues such as statute-barred debts, collection practices, credit reporting and consumer remedies vary widely across provinces, creating confusion for consumers and regulatory gaps.
Second, stronger protections are needed against false and misleading advertising of debt solutions, along with clearer direction to trusted sources of advice. For example, Google offers a useful model whereby, in Canada, only federally regulated, licensed insolvency trustees may advertise debt services on its platform. We believe that similar standards should apply across other digital and social media platforms.
Third, CAIRP supports having responsible lending guardrails that preserve access to credit while reducing harm. Possible measures could include limits on auto loans where there is negative equity, clearer disclosure for high-cost and digital lending and, of course, more consistent oversight across all types of lenders.
Lastly, financial literacy efforts should continue to be strengthened. Licensed insolvency trustees contribute to financial literacy through the mandatory counselling we provide in bankruptcies and consumer proposals, but we believe that more could be done. CAIRP remains committed to working with the OSB and the FCAC to help Canadians access reliable and timely debt advice.
We look forward to answering the committee’s questions.
Thank you.