Finance committee  I don't know the specific answer to your question. What I would say is that the institutions usually want to comply. Having a regulator that is helpful and of assistance in providing direction to the institutions is more useful. I think right now the institutions— Another sour

Finance committee  It's a very good question and one that we confront all the time. As I mentioned, we do provide compliance risk management software to some 15 or 20 banks right now. The difficulty we have is that, while the law is sort of common, each bank operates in a distinct way, particularly

Finance committee  Before coming here today I wrote a small list of the things in the discussion paper that would be quite helpful for the small institutions. In fact, two of the things that were proposed on the list would give FINTRAC more authority to deal with the institutions and provide inform

Finance committee  Yes. Certainly from the smaller institutions' perspective, I guess the first thing I would say is that FINTRAC is not a very direct regulator. For years and years, FINTRAC deferred to the Office of the Superintendent of Financial Institutions for the supervision of banks and othe

Finance committee  The small bank community is fully regulated. We comply or are subject to the exact same rules the largest of banks are subject to. The only issue for us is really when the law becomes too prescriptive, when it says you must do something, particularly when it's constructed in such

Finance committee  Yes, I definitely think that doing some benchmarking so that they understand how much effort is involved, by institution, would be helpful because, as I say, it's the one-size-fits-all problem. They look at what the large institutions do, convince themselves that this is the leve

Finance committee  Well, I have to say that I'm a regulatory lawyer, and a lot of that law emanates from litigators who are obviously concerned about solicitor-client privilege, which quite frankly rarely arises in what I do. Typically, I'm not giving people legal advice about potential litigation.

Finance committee  Yes, and sorry, just to correct you: schedule I now refers to any domestically owned bank, so it includes everything from the largest of large to the newest incorporation on the block, as long as it's domestically owned.

Finance committee  Well, it's a couple of things, but I think it's a distinction. The smaller institutions tend to be what I call “momma lines”, so they'll be uniquely mortgage lenders, or uniquely credit card banks. What sometimes happens is that when you drop the entire regime—which was designed

Finance committee  Thank you, Mr. Chair. It's important given the comments Mr. Tassé made that I immediately distance myself from being a lawyer. In addition to my role at Cassels Brock, I also lead a company called the Canadian Compliance Group. Together with our software partner, Resolver Inc.,