You don't have to be a Competition Bureau technocrat to look at the landscape and see that there isn't.... It's obviously not a monopolistic or duopolistic marketplace, but there are a very few, very large integrated competitors that we all know. That, ironically, has been reinforced by technology at one level, because there are increasing economies to scale in electronic networks, and this has benefited the banks enormously in terms of being able to continue their dominant role.
What we've heard from consumers and what we know from the work we've done is that there's an enormous appetite for more innovative structures, payment mechanisms and financial instruments out there. People understand that what they're being offered is a very limited menu.
The problem is—and this is a difficult thing to manage—when you're talking about moving your money around, you're necessarily somewhat conservative and cautious. The lack of familiarity with many of these new technologies that the vast majority of consumers have is definitely an issue here, too.
The other is, frankly, as I hinted at earlier, if we want consumers to be very confident and engage in new technologies, new payment providers and new systems because we know they can bring efficiencies and reduce costs for consumers, we also have to pay an equal amount of attention to the protection frameworks that are going to be in place.
This is new territory, so there are two sets of issues here. What kind of new protections are necessary given the nature and change in the technologies involved and the procedures that will be changed as a consequence as well? What risks therefore have to be mitigated from the consumer point of view? That's prudential, as well as just increasing the risks I may have of fraud. We also want all these new providers to be financially stable.
The problem right now is that too much of what we have is too limited and too siloed. We need an approach to consumer protection in this area that's integrated, holistic and flexible enough to address unanticipated problems in the future as the technology mutates, because if we don't do that, we're at grave risk of deterring people from engaging in new technologies—if we don't have a robust protection regime in place that's forward looking—but we also run the risk of too many bad stories because the protections aren't there and we didn't do a good job of anticipating the risks from the consumer point of view.
There's no better way to kill innovation than to have a lot of damaged consumers playing in new mechanisms that they aren't properly protected in. I would suggest it's important not only to make sure these new firms and new technologies can enter the market and compete, and have the right rules to encourage that, but, at the same time, to have the right safety nets and protections in place for consumers so they can enthusiastically and confidently engage in these new methods of moving their money around and banking effectively.