ID
No. 2019-005

Type
Policy
Sector
Cross Sector
Status
Public comment closed
Date
Comment Due Date

FSRA is committed to ensuring that consumer input and perspectives inform our regulatory direction and decisions. We are creating a new Consumer Advisory Panel to advise FSRA (through the Consumer Office), and provide ongoing advice from a consumer perspective, on proposed FSRA policy changes. The Panel will play an important role in fulfilling this commitment and delivering on FSRA’s mandate to protect the public interest in financial services in Ontario.

Provide Your Feedback

The financial services sector is undergoing significant change and this heightens the need for regulators to understand and protect the public interest. Consumer expectations for choice and services are high, driving new technologies, business models, products and services.

FSRA is committed to ensuring that consumer input and perspectives inform our regulatory direction and decisions. The new Consumer Advisory Panel will play an important role in fulfilling this commitment and delivering on FSRA’s mandate under the Financial Services Regulatory Authority of Ontario Act, 2016, to protect the public interest in financial services in Ontario.

The Panel will advise FSRA’s Executive Vice President, Policy and Chief Consumer Officer and inform FSRA’s strategic approach and related activities, including consumer-based research, policy support and consumer outreach. It will help FSRA protect the rights and interests of consumers, and safeguard public confidence and trust in Ontario’s financial institutions.

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Sector Comment Date posted
Cross Sector
[No. 2019-005] Harold Geller - MBC Law Professional Corporation
1. Why is the CAP, unlike other FSRA consultative committees, reporting through the Consumer’s Office as opposed to directly to the Board? My preference is the model of the OSC’s IAP that reports to the board and works with the Office of the Investor. Personally, I think this layered approach sends the wrong message (i.e., the CAP is a lesser committee as compared to the other stakeholder committees)

2. Why does the CAP TOR not have the feel-good statement of “they are an important part of FSRA’s stakeholder engagement process?” This is a simple observation about the optics of this difference as compared to other stakeholder committees.

3. What does the phrase “provide external input” mean? Is this 3rd party empirical research or something else? See my comment below.

4. Should the CAP’s mandate include “providing feedback on the progress made by FSRA on its priorities from the previous annual business plan” to mirror the mandate of other committees?

5. Should the CAP have the same opportunity as is offered to industry to have “in camera sessions with the Board, at least annually,…”?

6. In addition, I believe that the mandate should include:
a. Consultation with Consumer Panels in other provinces and in securities regulation to coordinate the standards that protect consumers
b. Commissioning 3rd party empirical research to inform the development and workings of FSRA’s consumer protection mandate
c. Roundtables for the purpose of exploring and recommending solutions to consumer issues within FSRA’s mandate

In this regard, these are important parts of the workings of the OSC’s IAP and have proven to be a valuable resource for the OSC’s executive and board.
Cross Sector
[No. 2019-005] Neil Gross - Component Strategies
Regarding the FSRA Consumer Advisory Panel, you might find it will be more effective and useful if you make three changes:

• It should meet more frequently than proposed. Frankly, the current suggestion (2 to 4 times per year) undermines the credibility of the whole concept. (By comparison, the IAP meets monthly.)
• It should be more independent, so FSRA staff should play a support role only. You should appoint the chair but not be the chair.
• Members need to be compensated for the time they spend on Panel business."
[No. 2019-005] Caroline Hossein - York Univ
I believe it is important to focus on consumer needs. Members should be included who represent these communities and who can address bias and exclusion issues in marginalized areas. The membership on the panel should not only be diverse in terms of sectors but also race, class and gender. Ideally have members who are reflective of the society we live in and who can ensure there is equity and fairness in the system.
Cross Sector
[No. 2019-005] Harvey Naglie - Investor/consumer
I am pleased to see FSRA moving forward on implementing a Consumer Advisory Panel. I do have some comments on the proposed Terms of Reference that are summarized in the attached file that includes an annotated version of the Terms of Reference.

I thank you for this opportunity to provide my input.
No questions have been asked about this consultation yet.