Declaration of Emergency committee  Also, I would add that financial institutions shouldn't have to be put in the position of determining whether a conduct is illegal.

Declaration of Emergency committee  One would be, of course, the guidance, so you're not left with all these questions and people know that it's limited and that it's targeted.

Declaration of Emergency committee  Our larger members, the six D-SIB banks, were given a heads-up it was coming. We learned when it was announced by the Prime Minister. But we all got the actual order at the same time. No one saw the details of that order until they were made public. So while they may have had a heads-up, the specific details of the order were all received at the same time.

Declaration of Emergency committee  What I would say is there was a gap between when it was announced and when the actual order came up. It was almost 30 hours, so what we did quickly was, based on what descriptions had been given both by the Prime Minister and Minister Freeland, start to generate a number of questions, because we were already wanting to understand what we would have to do from a compliance perspective.

Declaration of Emergency committee  Ours would be about 175. Our accounts in total were 180, so I'm ballparking here, but the vast majority.

Declaration of Emergency committee  My understanding is that there still are. Some have been paid into escrow, but others, I think, are still frozen. I can come back to you on that point, but the point is that there are still orders out there that are, in effect, impacting those funds.

Declaration of Emergency committee  Absolutely. I don't think that the financial institutions should be put in a situation where they have to take on an independent duty to determine it. It should only be relying on a list. That's what we conveyed to Finance. The appropriate way to do this to ensure consistency in how it should be applied would be to simply rely on a list that is provided, in this case, by the RCMP.

Declaration of Emergency committee  Not that I am aware of.

Declaration of Emergency committee  I would have to check that point. I can tell you that the cumulative amount from all of our banks was $8.3 million. It's definitely not any larger than that. It would be significantly smaller, but it was not small amounts, if that helps you. They tended to be larger accounts.

Declaration of Emergency committee  Yes. In the case of sanctions, we had the systems in place so that when we had a designated name, we had the ability to search against that name. We leveraged our sanctions compliance in that regard. What was missing and different from our usual approach with sanctions law was that there's usually clarity on exceptions.

Declaration of Emergency committee  Sure. I'll begin with the fact that the vast majority of accounts frozen were based solely on the list provided by the RCMP. For those ones that we were required to freeze because we had an independent duty to determine under the order, it wasn't like a blanket threshold or a dollar amount.

Declaration of Emergency committee  My understanding is that there were about four or five. Again, this was not a discretion. We had a duty to freeze if our systems noted something unusual and it matched the activities in Ottawa.

Declaration of Emergency committee  That is correct.

Declaration of Emergency committee  The only accounts still frozen would be those that are subject to ongoing orders. There was freezing that took place because of court orders that were put in place.

Declaration of Emergency committee  In their original list, they would describe at a high level some of the activities that the individuals were conducting that got them on the list, basically.