The discussions took place over a very long period of time, about five years, and part of this reflected, I think, to some extent, the very changing character of the industry. These discussions took place as the industry is rapidly changing across the country. To be frank, some jurisdictions were very much more concerned about this problem than others, because they had a much larger problem, particularly in western Canada where the industry started out. They were the main interlocutors on this issue and the ones who were very keen on moving quickly on it.
Other provinces who had less experience of the phenomenon—particularly, say, in the eastern part of the country—were not so concerned about it. So it took a while for jurisdictions to come to a view about what would be the most appropriate set of protections to put in place, which we did over a series of studies, a number of studies that were carried out. As I mentioned in my remarks, we also did consultations with stakeholder groups, consumer protection experts, and the industry that's involved in payday lending, as well as credit counselling organizations, and others. The idea behind this was to get as broad an understanding both of the phenomenon as it was emerging and what the most appropriate and effective mechanisms would be for consumer protection.
What we ended up with in the end was, I think, a fairly good consensus across the country about what should be in a package of protection measures. I think the real question was the sense of urgency and how quickly the various jurisdictions wanted to move on the issue. So the structure of this proposal is designed in such a way that, for those provinces who do not feel that it's necessary to take action at this time, they can live with the Criminal Code provision if they wish. For those who feel that the problem has become a significant one in their jurisdictions, and as I said, there are many provinces in that situation now, there's a good opportunity for them to proceed with a regulatory structure both controlling rates and controlling—and I think this is equally important, to be frank—the business practices that are associated with this kind of lending.