Summary of CCRC Recommendations  and Position Papers

Set out below is a brief summary of the CCRC's recommended changes to financial institution legislation in Canada, as detailed in the Position Papers produced by the CCRC since September 1997.  For more details about any of the recommendations, please view the CCRC Position Papers in full (or the summaries of many of the Position Papers) listed further below on this page.

In addition, go to the updated summary of the CCRC's Priority Changes Needed to Federal Financial Institution Laws -- Closing Key Gaps in Accountability and Consumer Protection (February 2007):

• as detailed in the CCRC's third, fifth and ninth Position Papers, enact legislation based upon the U.S. Community Reinvestment Act (CRA) which will: require banks and other financial institutions to disclose detailed information (on a branch-by-branch basis) about their lending, investment and service records; establish an annual government review and grading of each institution's performance in these areas, and; set out incentives and sanctions to encourage institutions to improve their performance if they received poor or failing grades in any area (To see details about the Community Reinvestment Act (CRA), click here -- To see details about the $4.2 trillion in reinvestments that have resulted from the CRA since 1977 (in a PDF-format document), click here);
• as detailed in the CCRC's sixth Position Paper, place a moratorium on bank mergers and takeovers of other financial institutions (and expansions of bank powers) until two years after the promised changes to foreign-bank entry laws have been made and a CRA-like law is enacted in Canada (this time period is needed to determine whether foreign banks will provide significant competition to Canada's big banks, and whether our big banks serve all Canadians fairly and well);
• as detailed in the CCRC's sixth, seventh and tenth Position Papers, never remove the 10% bank ownership rule, and enact in law the federal government's review process for bank mergers and expansions of bank powers (in addition to the process just recently finalized by the Competition Bureau) and include in the process consideration of the results of a CRA-like assessment (including a realistic assessment of customer choice in financial services), likely job losses, likely negative impacts from withdrawal of service and consolidation of services branch by branch, and a requirement that all reports produced through the review be made public;
• as detailed in the CCRC's fourth Position Paper, require banks and other financial institutions to enclose a one-page flyer in their customer mailouts inviting people to join a consumer-directed Financial Consumer Organization (FCO), as supported by a majority of Canadians according to a national survey;
• as detailed in the CCRC's second and eighth Position Papers, require banks and other financial institutions to provide fairly-priced services to any person who can prove residency in Canada, and to clear cheques and deposits within a specific time period, and set up an independent, effective monitoring system to ensure they comply;
• as detailed in the CCRC's second Position Paper, require banks and other financial institutions to conduct a public review of any proposed branch closures, including disclosure of the branch's profit/loss and net income record for a few years before the proposed closing date;
• as detailed in the CCRC's first Position Paper, establish a truly independent financial services ombudsman with the power to make binding rulings;
• in addition, prohibit financial institutions from practising tied selling; and
• prohibit financial institutions from disclosing personal information gathered from a customer to other subsidiaries of the institution or other institutions or individuals without the explicit permission of the customer.

1. Banking Ombudsmen: Why They Must Be Independent (September 1997) [Document][Summary]
2. Access to Basic Banking Service: Ensuring a Right to This Essential Service (October 1997) [Document][Summary]
3. Disclosure by Banks of Business Lending Statistics: How to Correct the Flaws in the Current System (November 1997) [Document][Summary]
4. A Financial Consumer Organization for Canada: Balancing the Financial Services Marketplace (December 1997) [Document][Summary]
5. An Accountability System for Financial Institutions in Canada: How to Ensure They Meet a High Standard of Performance (December 1997) [Document][Summary]
6. Ending Power Without Accountability: Making Banks in Canada Better Before They Get Bigger (May 1998) [Document][Summary]
7. Bank Rhetoric or Customer Reality? Key Questions About the Competition Bureau's Analysis of the Proposed Bank Mergers (November 1998) [Document]
8. Access Denied: The Failure of Voluntary Measures to Improve Banking Services (1999 National Survey Report) (June 1999) [Document]
9. More Money Down: The Case for a Community Reinvestment Act to Ensure Financial Institutions Help Solve Canada's Affordable Housing Crisis (November 1999) [Document]
10. An Unjustifiable Takeover: A Performance Evaluation of Toronto-Dominion Bank and Canada Trust Based on the U.S. Community Reinvestment Act Process (March 2000) [Document]
11. CCRC Recommendations vs. 1998 Task Force on the Future of the Canadian Financial Services Sector Recommendations (September 1998)
12. Comparison of CCRC Recommendations and Bill C-8 (February 2001) (NOTE: Bill C-8 became federal law in Canada in June 2001, although all of its related regulations were not in effect until October 2003)
13. Priority Changes Needed to Federal Financial Institution Laws -- Closing Key Gaps in Accountability and Consumer Protection (February 2007)