Finance committee  Any clarity that prevents complaints is a good thing.

Finance committee  I think all of these create clarity for both the firm, in terms of their expectations in the marketplace, and what consumers can expect in the marketplace. As a non-advocate, it would be inappropriate for me to provide opinions on each of them. But I will say that the clarity provided by these is, in the long term, going to be helpful to our work.

Finance committee  First of all, to clarify, an ombudsman is not a regulator, but if a complaint were to arise with a Canadian consumer's problem with a bank in Panama, it would be outside of our jurisdiction and I would have to look to a counterpart, if one existed, in Panama to resolve that specific complaint.

Finance committee  That is current for 2011. That's the most recent statistic for 2011—87% of the cases in 2011.

Finance committee  I will have it sent to your office right away.

Finance committee  Not necessarily.... I think a statement from this committee as to the preferable structure of dispute resolution in the sector would go a long way to sending the appropriate signal, not just to what government policy should be, but also conduct within the marketplace right now. We have four major banks that have stuck it out with us because they think this is the right structure, notwithstanding the other actions.

Finance committee  I would agree that when they left each was, in turn, the largest participating firm in our service, yes.

Finance committee  In 2008, when RBC left, they were the largest source of our banking complaints. In 2011, when TD left, they were, in turn, the largest source of our banking complaints.

Finance committee  I'll be as quick as I can be. It's the articulation of the complaint, which is not something a firm-focused provider will be interested in doing. It's the ability to do the investigation, not simply accept the paper file submitted by the firm to the dispute resolver. It's the ability to have someone who is actually motivated to do what is fair and independent and impartial between both parties, without being potentially conflicted by where the rent cheque and the payroll are going to come from next.

Finance committee  The eight issues were many.

Finance committee  Oh, it ranged from getting into statutory investigations to timeliness of complaint handling, the increase in the budget, the non-responsiveness to their specific concerns regardless of whether they were shared by the rest of the industry, and things of that nature.

Finance committee  The target set by our board is 80% within 180 days. The vast majority of the straightforward complaints are actually done in less than 60 days. The area in which we're having some challenges is actually not in the banking sector at all; it's on the investment side. On the banking side, about 87% of our investigations are concluded within the 180-day target, and many within less than 60 days.

Finance committee  I think the challenge is that standards are only part of it. If there are multiple players, how do you avoid a race to the bottom if the choice of who the provider will be is actually the firms? In the current environment, what you have is one body playing that public policy role, with good, strong relationships with government at both the federal and provincial levels.

Finance committee  Absolutely. I think it's about the independence of the function, to not have to be beholden to a firm that hires you on an annual or contractual basis. I think the fact that the funding comes from the industry is no different from what you'd see at CDIC, OSFI, or other regulatory-type bodies.

Finance committee  I think the difference between our structure and the statutory one is primarily around flexibility. If you're a regulator, your job is to apply statute in regulation. We are asked to take on a mandate of finding fairness in the circumstances, which as you can appreciate is very specific to individual fact situations.