Thank you for the opportunity to speak to this briefly.
That is our understanding of what's happening. When we think about competition—and the test is always whether competition is sufficient to protect the best interests of users—it's clearly not working right now because consumers are taking on layer upon layer of debt. The bureau has the power to study it. I think the question is, are they studying it? I'd love an answer to that question.
To counter some of the Canadian Bankers Association data, I'm going to quote from an Ivey Business School report from earlier this year. This is Ivey, with a foreword by former Bank of Canada governor Stephen Poloz. These aren't his words but the report's words:
Amid national economic headwinds, recent reports suggest that consumer debt and credit card spending is at an all-time high. One report—
This is from the CEIC, which does macroeconomic data around the world.
—suggests that over half of Canadians were $200 (or less) away from being insolvent, despite Canada's distinction of having some of the most financially literate consumers in the world.
That brings out the issue of literacy and disclosure. You can have many pieces of paper attached to a credit card loan, but if you're a University of Ottawa student walking through campus, where credit card companies are loading students up with debt—which, by the way, is going to be illegal in the U.S.—it is piling on. There is a revolving door of going from one credit product to the next to try to pay off one with the other. There's no real “know your client” rule being enforced to make sure that a student at the University of Ottawa can actually handle the debt and that it's not one of four different instruments this poor student is taking on.