FSRA Credit Union Stakeholder Advisory Committee (SAC)
meeting with FSRA Board of Directors
Summary of the May 8, 2023 meeting
Via Zoom
Stakeholder Advisory Committee members present:
William Boucher – Desjardins Ontario Credit Union
Pierre Dorval – Caisse Alliance
Geri James – The Police Credit Union
Brigitte Goulard – Torys LLP
Marycatharine Kusch – Libro Credit Union
Sunny Sodhi – Meridian Credit Union
Richard Adam – Northern Credit Union
José Gallant – Alterna Savings
Jeff Guthrie – Canadian Credit Union Association
FSRA board members present:
Joanne De Laurentiis – Chair of the Board
Larry Ritchie – Director
Joseph Iannicelli – Director
Brent Zorgdrager – Director
Kathy Bouey – Director
Dexter John – Director
Management members present:
Mark White – Chief Executive Officer
Paul Reid – Chief Financial Officer
Judy Pfeifer – Chief Public Affairs Officer
Heather Greenberg – Corporate Secretary and Deputy General Counsel
Mehrdad Rastan – Executive Vice President, Credit Unions & Insurance Prudential
Glen Padassery – Executive Vice President, Policy & Chief Consumer Officer
Jordan Solway – Executive Vice President, Legal and Enforcement
Huston Loke – Executive Vice President, Market Conduct
Antoinette Leung – Head, Financial Institutions and Mortgage Brokerage Conduct, Market Conduct
Dan Oprescu – Head, Prudential Supervision, Credit Union and Insurance Prudential
Dan Padro – Director, Policy, Credit Unions and Pensions, Policy
Bradley Hodgins – Director, Regulatory Initiatives and Knowledge Management
Steve Kokaliaris – Director, Approvals and Insurance Prudential Practices
Amber McNair – Senior Manager, Credit Union Policy
General comments
The Chair of the Board welcomed the Committee and introduced the Board. The Chair provided introductory remarks about the importance of sector engagement.
A Committee member commented that they are committed to working with FSRA to build a strong partnership to help improve the sector. In that regard, these meetings are important to building a dialogue that will help everyone better understand the issues facing the sector and coming up with solutions to address them.
The meeting discussion centred around the following main themes: data requests, technology, amalgamation, attracting new members and talent acquisition. Comments were also made about recovery and resolution plans, emergency lending and deposit insurance.
Data requests/Enhanced Data Collection
One Committee member noted that the sector has been navigating challenges relating to FSRA’s Enhanced Data Collection (EDC) initiative, but many of these concerns have been addressed through collaborative work with FSRA. Credit unions (CUs) understand that FSRA does have the authority to request data as part of its regulatory mandate, but FSRA should invoke its legal authority to do so.
It was noted that some smaller CUs may have difficulties complying with the frequency and scope of FSRA data requests, including implementation of EDC, given the associated costs. However, some members acknowledged that over the long-term, EDC will improve efficiency and reduce the data burden and cost to members. It was suggested that FSRA should communicate the future efficiencies that will result from EDC next steps for the initiative more broadly to the sector.
FSRA responded that the EDC Roadmap will set out timelines and expectations and although currently best efforts is acceptable, as data maturity improves, CUs will submit better and more complete data in the future.
Technology
Another Committee member noted new requirements that Fintech’s will soon be facing (e.g., registration via Retail Payment Activities Act, federal Open Banking framework, new requirements through Bank Act, new rules on real time payments). As a result, FinTech’s will place more demands on the CUs that they are partnering with. The sector will need to think about how advancing technologically will impact them operationally; this is both a challenge and an opportunity.
The Committee noted that CUs should be involved as the federal government advances the new Open Banking framework and that FSRA should not duplicate requirements.
FSRA noted current and future priorities to prepare the sector for open banking (e.g., EDC, Operational Risk Management and Resilience Guidance, IT Risk Management Guidance) and address any potential supervisory gaps. FSRA confirmed that it does not intend on duplicating requirements that will be set at the federal level.
New member acquisition
The Chair of the Board noted that they understand that attracting new members has been and continues to be an issue for the sector.
The Committee noted steps that the sector has taken to attract new members (e.g., a 2021 campaign to increase impressions within key demographics and building awareness of CUs among younger Canadians). The Committee acknowledged more should be done in this respect and, in particular, to attract new Canadians.
Amalgamation
The Board asked about the pace of consolidation in the sector. Consolidation continues to be a trend in Ontario.
A Committee member noted that smaller CUs have fewer resources to service local members and respond to requests by the regulator. This has led to smaller CUs amalgamating with larger ones, sometimes resulting in erosion of region-specific values and branch access for members.
One Committee member commented that amendments should be made to the regulatory/legislative regime to prevent conflicts of interest at the board level when CUs amalgamate, in order to help maintain the character and values of CUs.
Talent acquisition
The Committee noted that attracting talent continues to be a big focus area for the sector given upcoming digital changes (need for specialized talent). Consideration could be given to pooling of resources in the sector.
Other comments
A Committee member commended FSRA for accommodating sector requests relating to implementation timelines, given new regulatory requirements and guidance coming into force.
Emergency liquidity for the sector was noted as an important area of focus and FSRA was encouraged by the Committee to continue to prioritize work in this area. The Committee also noted that the deposit insurance limits provided by the Deposit Insurance Reserve Fund (DIRF) continues to be an important issue, and CUs in jurisdictions with higher coverage limits present a competitive disadvantage for Ontario CUs.