The FCAC, in its consumer protection measures, has service standards for the transfer of registered investment accounts that actually apply to both federally regulated and provincially regulated entities. The obligation is to “strive” to make these transfers in a timely fashion. To “strive” is, I would say, insufficient in our experience, given, for example, the five-month delay in 10% of our transfers.
When it comes to the NSF fee cap, we don't charge NSF fees. There was a long delay between the announcement of that consumer protection measure and its actual implementation. Our strong encouragement to the government is that while Canadians have applauded the commitment to ban those account transfer fees, the ban should be implemented without delay, because it is difficult to understand why it's taking so long to implement.