Mr. Speaker, I thank the member for Rimouski-Neigette—Témiscouata—Les Basques. I really appreciate his question. I agree that the agreement between Canada and the United States is very complex.
However, I do want to say that, with that in mind, the banks have to start collecting this information as of July 1. That is when this due diligence process has to start.
As has been pointed out, these banks will have to make investments. They will have to make investments in information technology and other processes to collect this information, which they would have to do under FATCA and will have to do under the IGA. I would argue that they will probably have to spend less money under the IGA than they would under FATCA. At the same time, it is also important to understand that they need certainty with respect to getting this started because I believe it would be very difficult to try to go back and collect that information in 2015 or 2016.
I also want to reference a comment by the interim privacy commissioner. She said:
The risk to privacy here is therefore mainly related to over-collection, over-reporting....To avoid over-collection and over reporting, education and outreach to institutions affected by this new reporting requirement will be crucial.
I agree. It will be important for the CRA to ensure that it communicates well and gets these structures in place with the banks before they start.