Finance committee  I just wanted to comment, as Alex has mentioned, that CMHC is going in the right direction right now. They're providing more data publicly, and they're engaging with more stakeholders. We're being pulled into a lot of the discussions and we're grateful for that. It would be unfortunate if somehow that got waylaid because there was a shift in where it was going to reside in government.

Finance committee  Yes, and that's precisely our experience. That's what we're seeing in the market.

Finance committee  High-ratio volumes, we estimate, would be down near about 35% from the last changes. Of course we're not into the spring-time house buying yet, so it's hard to measure, but these are our estimates. That varies across the country: high of course in the Lower Mainland and in Toronto, and in Alberta between about 13% to 46%, depending on the credit union decline in volumes.

Finance committee  I just have one more thing to follow up on in terms of risk sharing. With the risk-sharing model, credit unions or small lenders will become a counterparty to the insurers. Given that we are basically local, concentrated in particular markets, my guess is that they'll start tying premiums to what they consider to be their counterparty risk in those regions, which will have to be passed on through higher rates to our members in, say, rural or remote Canada.

Finance committee  There are a number of things in there. I just wanted to comment on the risk sharing. I think one thing you're going to find is that the risk-based pricing that institutions will pursue will become much more finely granulated. As you said, we may be in Cape Breton where the market is more liquid, and places like Gimli, Manitoba, or wherever, and people like Genworth and CMHC will be looking at us and saying, “Well, you have some housing market risk there because it's a liquid market and there might be a downturn in the economy.

Finance committee  I will say that in some markets it will be harder for us to compete. It means they probably will be dealing with the banks more.

Finance committee  As we said, it certainly surprised the market. It surprised us. To the extent that the system is involved in securitization, yes, it puts us on a back foot. We have probably about north of 40 issuers in the country. We have about 283 credit unions overall. It's predominantly some of the big ones that have had to deal with this, that are involved.

Finance committee  Right. As co-operative institutions we basically take deposits, fund off deposits, and loan off deposits and retained earnings. The mortgage securitization process was another conduit to fund a small bit of what we're doing, but it still was an important conduit. Banks have other ways of issuing paper, as you said, but also they have the covered bond tool that the government has come up with.

Finance committee  I have just one follow-up on that. We are aware that CMHC is actually trying to expand the data it's going to make public and also what it collects. The credit union, as a system, is beginning work with them to be able to provide a conduit for expanded data in the future. I think they're doing it with other institutions also.

Finance committee  I can take up that one. What CMHC...and I think the finance officials call them sandbox measures. They tend not to consult when they implement them, and they usually play with the parameters around eligibility and things that are already in place. When they do move to actually change the structure of the regulatory regime, whether it's through OSFI or..., then they tend to consult on their guidelines and there's time there.

Finance committee  I can speak to a bit of it. We don't have the exact numbers, but we did some estimates based on 2016 approvals. We modelled what the impact of the October 2016 changes would have been on our books and the decline in it by about 37% nationally in the number of approved high-ratio mortgages.

Government Operations committee  They're not in the deposit-taking business, so they have a limited suite of products. But there are other equally viable models to partner with, credit unions or other institutions, too, not necessarily postal banks. We already provide a lot of, say, agricultural products and services for our members, for example, AgriInvest accounts.

Government Operations committee  I can't add much more to that, but the other thing we've done is we've tried to extend our ATM network. We are part of what's called the Exchange network, which includes credit unions and some banks that have committed to a surcharge-free exchange network. You can actually go and make deposits and do some beyond basic transactions at ATMs.

Government Operations committee  Yes, and some of our credit unions, usually in very remote areas, have moved to some shorter-hour models to make them viable. Of course, these decisions have to be made at the credit union level. It has to do with their business model and what's going on in their other branches.

Government Operations committee  I think the key thing is whether these services align well with the skill set, with the labour complement they have, and with the technologies they have in place. I think we've said that making the jump into financial services is going to require large investments. There's going to be training, security issues.