Thank you for these excellent questions. That's a very good summary of my comments, you've put it better than I could have done myself.
I would say yes, we need to look at what the Americans are doing, but not only because they are our largest partner. It's also because we have a lot in common, including our political structures, even though they're not identical. In terms of competition, we have always tried to align what we do with what they are doing, particularly with respect to things like mergers, even though we remain separate for reasons of efficiency.
I would nevertheless say that the Americans recognize that there are things that need to be added to their legislation. There are in fact six bills before the U.S. Congress on this subject. President Biden has decided to use his political advantage to make progress in this area. I'm not certain that they will be adopted, but it shows that the Americans are aware of this need.
I would nevertheless add that the Americans have not yet succeeded in adopting legislation to provide a framework for some aspects of digital, not because they don't want to, but because it's impossible for them to do so. So I think we could learn a lesson from the Europeans here. It's worth thinking ahead and having a better organized structure, broad principles and rules, to provide a framework for the right to privacy and all other matters of this kind, like interoperability and intellectual property.
It's therefore important for us to draw upon what the United States is doing and to try and adapt to it, without necessarily reproducing every one of their weaknesses. What we need most of all are framework laws. Our Competition Act is already much more detailed than theirs. I don't know if you have read the Sherman Act, but it's extremely short and vague. An act like that would never pass here, owing to constitutional constraints. We need to know that we will have to have more legislative structures, but I tend to believe that we're going to have to do more than that.
The glitch, I believe, is that our competition agency, the Competition Bureau Canada, has neither the weight nor the funding required to achieve the broad objectives we are aiming at. If we are serious, we truly need to review the bureau's funding and assign it certain powers, including the ability to carry out market studies in addition to investigations. They can't do that at the moment. It would be very useful if it could study digital phenomena. There's a digital sandbox, but it's not big enough to force the market participants to give it the information or data to know what's going on concretely, rather than simply speculation. Right now, we don't necessarily know everything that's happening, and I'd be the first to acknowledge that.
So it would be very important to give the bureau the resources and powers it needs to carry out a mandate analogous to what the FTC, the Federal Trade Commission, or the DOJ, the American Department of Justice, do. They have completely different resources, and we shouldn't have overly high expectations, in my view.