Declaration of Emergency committee  I am not aware.

Declaration of Emergency committee  These were extraordinary measures. I'm sorry.

Declaration of Emergency committee  When the order was announced, it was described what they were going to do, but we didn't have the actual order in our hands, so we started formulating a number of questions. Then, when saw the actual order, we continued to update those questions, because we wanted to understand a number of implementation issues.

Declaration of Emergency committee  No.

Declaration of Emergency committee  I'm happy to take that one.

Declaration of Emergency committee  Okay. The scope of the Emergencies Act was that it was designed for a state of emergency. One was declared by the government. Once that occurred, then the obligation became to enforce that law. We had obligations to fulfill. We were well aware that the Emergencies Act as it was created would have a post-act review that would assure whether or not any of those powers has been exercised—

Declaration of Emergency committee  Thank you. Good evening, and thank you for inviting the Canadian Bankers Association to appear today and participate in the committee's study of the invocation of the Emergencies Act and related measures. My name is Angelina Mason and I am the general counsel and vice-president of the CBA.

Finance committee  No. It would work the other way around. What we would do is provide intelligence to FINTRAC. First of all, as I mentioned, there is threshold reporting, so any international transactions over the 24-hour, $10,000 threshold would be reported to FINTRAC. If there were any unusual activity, we would report it to FINTRAC.

Finance committee  Great. I would say that it's basically what we've covered off, which is understanding the scope and the limited nature of this. Again, we were told that it was going to be temporary and very targeted, so we worked within that, but with regard to a proper assessment of the Emergencies Act itself and how it would be invoked, I think it's really not our position to comment on that.

Finance committee  Thank you.

Finance committee  Thank you for having us.

Finance committee  I can say that we, as an industry, went out with media messaging. We have the active messaging in place for all of our customers. At a certain point, Finance had made comments about clarifying the very targeted scope.

Finance committee  I would just say that obviously we weren't able to ask specific questions until we saw the regulations themselves. I give the government credit for moving quickly, but it was still very much in real time, whereas—and again I attribute it to the fact that this was an “emergencies act”—under the normal process, you would have an opportunity to do that before things were enforced.

Finance committee  You're talking about powers, so I just want to be clear. We had legal obligations, and for us it was more about understanding what the extent of those obligations was.

Finance committee  I see.