Finance committee  We don't believe that there should be any exemptions. In fact, there was a consultation recently about making bond loans an exemption, and we believe that even bond loans equivalent to less than $1,500 shouldn't be an exemption because bond loans are also equally predatory. Regarding the payday loan specifically, there was a specific exemption carved out for payday loans, and that's when the whole regulation of payday loans moved to the provinces.

Finance committee  We've maintained a fixed rate more than keeping it variable. Obviously, a lower rate is better than a higher rate of 35%. We are encouraged by the fact that the federal government is moving toward lowering it. We did see further consultation to further lower the criminal interest rate from 35%—once it is 35%—to whatever level.

Finance committee  Should I go ahead?

Finance committee  Thank you. Definitely there's a lot that one can do in the instalment lending space, for sure, particularly because we know there's no complaint mechanism at the federal level in case a person wants to prosecute, ask any questions, take these lenders to court or even file a complaint.

Finance committee  I don't think it would cover payday lenders—

Finance committee  I do believe it should be a different space for predatory lenders because the way it works is different.

Finance committee  Thank you. I'm sorry. I'm not sure if I understood the question correctly, but as far as I understood, I think you were specifically speaking to the enforcement piece, which is the ability of borrowers to prosecute lenders. We believe that enforcement needs to go hand in hand. We know that with the way it is at this point in the Criminal Code of Canada it's very hard to prosecute these lenders because one needs an actuarial certificate.

Finance committee  Sure. Thank you. During the pandemic we tried understanding whether there had been an uptake in accessing high-cost credit, and obviously there was an increase. Like we've been saying, it's quite easy. That's their tag line—fast credit, convenient. These lenders were actually deemed essential during the pandemic.

Finance committee  We completely agree with Elizabeth. They're making huge profits. Making just a little less profit will not harm this industry at all. In our survey that we did last year, which actually focused on fair credit alternatives, we saw that a lot of credit unions are providing payday loan alternatives.

Finance committee  It's totally false, as we've seen not just in study after study but in the U.S., where it has already been lowered for instalment loans. People are turning to better alternatives. There is an increasing number of better alternatives coming up. People are able to resort to different means and not go to, as the Canadian Lenders Association is claiming, payday loans.

Finance committee  Could you please repeat your last sentence, MP Baker, if you don't mind?

Finance committee  Exactly. That's exactly the point. We know that they're making a huge profit out of this business. Lowering from 48% APR to 35% APR will still allow them to make enough profit—a decent profit. You quoted from Easy Financial's annual report. They're saying that they're already lowering the interest rate for some clients from the highest to 33% or 35%, although we haven't seen that happening among ACORN members who have experience with Easy Financial.

Finance committee  That's right, yes.

Finance committee  ACORN has been pushing for 30% and lower—

Finance committee  Can I go ahead and answer the question?