I really can't answer that, being from a chartered bank. I can appreciate perhaps some of their frustration. I mentioned in my earlier testimony that there is a significant cost to compliance. We're not just looking at the Canadian regulations. We also have to look at other international regimes where we do business. When you layer that on top of Canadian requirements, it is fairly onerous.
A point that we wanted to make, though, quite frankly, is that Global Affairs Canada in the last few years hasn't made it much easier. Going back to 2010—no, I won't go that far back. I'll go back to 2013, when I first assumed my role. It was at a time when Global Affairs, DFAIT at the time, was much more collaborative. When there was an introduction, say, of a new sanctions regime, or a new country was added, they would host a conference call, and they would invite industry. They would do separate calls for banking, and I believe they did a separate call for credit unions at the time. They would answer questions fairly openly and would provide some much-needed guidance, because you won't see anything published, as you're aware. At Global Affairs, they don't publish frequently asked questions, as OFAC does in the U.S.
We found it frustrating, because since 2015 it's almost been radio silence. Earlier I could pick up the phone and speak to a lawyer in the economic law division and be able to get at least an indication if that sounded like something we'd need a permit for or if we were on the right track in our interpretation. Now, since 2015, there's nothing. They don't even provide that limited guidance. They'll say to submit an email or submit a permit application.
Well, we'd send an email without any real guidance. Basically their response would be, “You need to seek independent legal advice.” We've heard from lawyers in the industry; it's circular. They don't have the advice. They need to go back to Global Affairs.
Ultimately it comes back to a permit process. You submit something, you ask for general advice, and they say, “No, we can't give you a general answer. It has to be specific.” We wait for a transaction, a live transaction. We have clients waiting. They want to do a letter of credit, and you have to submit an application.
We've been waiting 16 months.