Finance committee  The guideline is intended to address exactly the issue you raise, which is the risk of inconsistency across institutions. Within institutions is, I suppose, also a possibility. One of the main drivers for us to issue it was to make it clear to the industry what the expectations w

Finance committee  We are very comfortable that institutions are observing the guideline and will observe the guideline. Of course, the guideline isn't law. It is our communication to industry about how we will apply the law, so in that sense, it is absolutely enforceable.

Finance committee  Thank you very much for that question. I'm very happy to address it. I read that news story. I found the news story accurate, but the headline was not. We have a centre where consumers can make complaints, but we are not a complaint-resolving entity. We have a system for comp

Finance committee  No, I don't, because I think it's just a different mechanism. If you're on a fixed-rate mortgage and you skip a payment, you add the interest. It is akin to negative amortization, just a different mechanism, so no, I don't think there's an unfairness there.

Finance committee  It's a very serious issue. It is a concern, and it is a concern about the product. We share the superintendent's concern about the variable-rate fixed payment, because it's a complex product and it has risks that are being realized and that may not have been fully appreciated. W

Finance committee  I'm not sure I understand the question exactly. There is no difference in the guidance about tailored relief measures and types of relief measures—depending on what type of mortgage you have—regarding the fairness in how banks treat any consumer, regardless of the type of mortga

Finance committee  We certainly do anticipate, as everyone does—and by that I mean our colleagues in the federal oversight system—that in the coming months and over the next two years, as consumers hit renewal rates or hit trigger points, there will be increased recognition and realization of chall

Finance committee  Yes. I'd be happy to turn to Frank, who has more detail on the preliminary reporting we've received to date.

Finance committee  Thank you for that question. If I understand correctly, you're asking if we have a picture of the number of mortgage holders who are currently in a negative amortization. It's a serious issue, and we have great concerns about that. We do have some numbers, again on a prelimina

Finance committee  There's quite a lot in there. I accept your concern around pricing and whether pricing in one area is cross-subsidizing another. I think that's why pricing is a challenging issue. There are provisions to protect consumers from unfair treatment. We put a provision specifically in

Finance committee  The relief measures do speak to whether it is insured or uninsured. There's no difference in the guideline between the relief measures that are expected and the behaviour that's expected towards insured or uninsured.

Finance committee  Yes, that is part of their obligation. Under the guideline, the expectation is that banks must first proactively identify the customers who are at risk and then proactively reach out to discuss options with them. They're essentially trying to get ahead of problems. The earlier th

Finance committee  The stress test is a prudential tool, so it's not my area of expertise. It is a macroprudential tool principally, but of course it does have a microprudential impact, which is that there are likely some borrowers who were saved from overextending.

Finance committee  No. There is no contradiction or daylight. I believe we sent a letter to that effect in which we tried to explain that. The purposes and targets are different. Our mortgage guideline is intended to address temporary measures to allow consumers who are at risk of default to make

Finance committee  We don't specifically define “temporary”, but the expectation is quite clear in the guideline. The OSFI guideline, which they can explain better than I can, of course, is for new contracts or permanent changes.