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Finance committee  Other than wanting it to be legally consistent, I'm assuming that the English version, which I think was the version the sponsor authored it in, would be the version that people would want to reconcile it to. I don't know whether it's us, frankly, or the committee who could validate that.

May 30th, 2013Committee meeting

Brian McCauley

Finance committee  I don't know, to be honest. What I can do is to look into it and see if we can provide some information back to committee.

May 30th, 2013Committee meeting

Brian McCauley

Finance committee  The only reason I'm hesitating is that whenever you're looking at something that involves the courts, and the independence of the courts, I would want to be very careful that we weren't consulting on something that they would be offended by. Certainly we'll take it under advisement.

May 30th, 2013Committee meeting

Brian McCauley

Finance committee  To be honest, not particularly. Again, both in reality and in perception, we want to be seen to be quite open throughout the consultation process and not have landed, as it were, on what we think may or may not be exempt. Some people have observed to us that if the fee structure is designed in a certain way, the issue of who's exempt or not really becomes moot, because as you know, unless you're exceeding that cap, there's no requirement to report.

May 30th, 2013Committee meeting

Brian McCauley

Finance committee  What we will have to sort through is how do we appropriately value the product. If there are legitimate, as I think you're sort of intimating, cost considerations—labour in Toronto versus labour in another part of the country—I think certainly we would take that under consideration when we provided advice to the minister on the regulation, yes.

May 30th, 2013Committee meeting

Brian McCauley

Finance committee  Very briefly, the reason we suggested the amendment was that there was a possibility that, for example, the information provided on the disability certificate—where, if the bill passes, there would be an advisory, for example, to individuals about there being a maximum, so there would be consumer awareness, if you wish—and some of the other information that might be provided might not be available to us to use, to do some analysis, to see whether or not a firm would be exceeding the cap.

May 30th, 2013Committee meeting

Brian McCauley

Finance committee  I have absolutely no idea, because that's the purpose of the consultations. We do know that the bill is designed to ensure there's a viable marketplace. It recognizes there are many instances where these services are valuable and that it's important for people to be able to access the credit.

May 30th, 2013Committee meeting

Brian McCauley

Finance committee  I certainly haven't. I know we've been musing out loud about how you might approach it, and one of the things we were talking about even last night was how we can push the consultations should we have a straw model. Those are the kinds of things we'd probably think through with the industry during the consultation process so that is as open and transparent as possible.

May 30th, 2013Committee meeting

Brian McCauley

Finance committee  My understanding is that certainly there is no intention to rush consultations inasmuch as it is not an unimportant issue. I would expect we would want five to seven months for consultations. Again I'm being a bit speculative here. It's a big country, so knowing who wants to provide information, giving them a chance to do that, and then providing our information to the minister....

May 30th, 2013Committee meeting

Brian McCauley

Finance committee  There's no wrong door. So whether it's through the committee clerk, the parliamentary secretary, or an individual member, they can simply provide a name to the minister. Again, we haven't defined that, because it would have been inappropriate for us to assume the bill were going to pass, but the avenues will be very clear.

May 30th, 2013Committee meeting

Brian McCauley

Finance committee  Thank you, Mr. Chair. Actually, it's fairly straightforward. If the original wording of the bill had remained, it would have meant there were no consequences for the firm. Let's say a fee was established at $5,000 and they charged $5,500. The $500 would have been the penalty, but there's really nothing at risk for them, in as much as they would have paid that back.

May 30th, 2013Committee meeting

Brian McCauley

Finance committee  The legislation calls for consultation if and when the bill is passed. It would really not have been appropriate for us to consult while Parliament was considering the bill, so we haven't done so, other than paying attention to the briefs that have been submitted.

May 30th, 2013Committee meeting

Brian McCauley

May 7th, 2013Committee meeting

Brian McCauley

Finance committee  The form is readily available on the website and on paper. Probably the easiest test is to try it yourself, or ask others to try it. Again, as mentioned by Gail and others, we've made a number of revisions to it. If more can be done legally, including making it fillable, savable, things like that, certainly I'll take those suggestions on board, by all means.

May 7th, 2013Committee meeting

Brian McCauley

Finance committee  Yes. As I mentioned, there was a survey—I forget whether it was 2003 or 2007—with the CMA, whereby we surveyed about 12,000. There was a review a number of years ago. But, yes, and as I say, there will be an opportunity. The bill requires us to do consultations across the country, and I'm sure we'll take advantage of that to listen to individuals as well.

May 7th, 2013Committee meeting

Brian McCauley