FSRA’s EDC webinar for Ontario credit unions

0:05

Hello everyone and welcome to today's webinar, FSRA's Enhanced Data Collection webinar.

0:12

Before we get started, I would like to go over a few items so you know how to participate in today's event.

0:17

You have the opportunity to submit text questions to today's presenters by typing your questions into the questions pane of the control panel.

0:26

You may send in your questions at any time during the presentation.

0:30

We will collect these and address them during the Q &A session the end of each of today's presentations.

0:37

I would now like to introduce David Maxwell, Head Integrated Credit Union Supervision. Maxwell? I'm sorry, Mr.

0:45

Maxwell. Thanks Wendy and thanks everyone for joining us today.

0:52

I'm not surprised that this is a popular topic but it's still gratifying to see so many of you taking time out of your day to speak with us on this topic.

1:01

Before we get To start, I'd like to acknowledge that the land we are on is the traditional territory of many nations, including the Mississaugas of the Credit, the Anishinaabeg, the Chippewa, and the Haudenosaunee, and the Wendat peoples, and is now home to many diverse First Nations, Inuit, and Métis peoples.

1:19

We acknowledge that Toronto is covered by Treaty 13 with the Mississaugas of the Credit, and the Williams Treaties signed with multiple Mississaugas and Chippewa bands.

1:30

And with that, we can move on.

1:33

So we're going to cover a couple of different topics today.

1:37

I think the list is here.

1:40

Ultimately, I think we do want to take as much time as possible to answer your questions, knowing that there will likely be many.

1:47

I want to reiterate that you can submit questions at any time during the presentation in writing.

1:53

We will address as many of them as we can at the end of the session.

1:58

To the extent that there are multiple questions on the same topic, I will try and aggregate them for the team that will be answering questions, but we will try and get to everything possible.

2:09

I would ask that if your question is of a particularly technical nature or specific to your credit union circumstances, feel free to submit the question, but we may not address it as part of this webinar.

2:24

We will ultimately, though, be taking all of those questions back and circulating something to all attendees with written answers to some of those more technical questions.

2:34

The other thing I'd like to note before we get started is that this presentation and the recording of the webinar will be shared within about a week of this webinar with everyone who's attending here.

2:46

So we typically get questions on that, wanted to address it right off the bat.

2:52

And we can move on to the next.

2:55

So today you'll be hearing from Flavia, who you can see on screen, who's our Director of Macro Surveillance and Analytics, as well as Dan Oprescu, who's lurking in the background, but will be joining us on screen to answer questions at the end.

3:10

My name's David.

3:11

I'm head of Integrated Credit Union Supervision.

3:13

I will be your cruise director for today, as well as talking through a few of the initial slides.

3:20

Next, please.

3:23

So, wanted to take some time at the outset, first of all, to acknowledge the amount of work that has gone into this initiative by yourselves, by your teams, by the credit union sector.

3:37

This is a big change, change is hard.

3:41

We acknowledge that and we are truly grateful for the efforts that have been put in.

3:46

And we can see over the course of this journey the extent to which those efforts have borne fruit for the credit unions.

3:55

And, ultimately, notwithstanding all of your efforts, the Go Live has been delayed and that announcement went out about a month and a half ago.

4:05

This is a very complex initiative.

4:08

We're not striving for absolute perfection.

4:10

We've had that feedback from the sector, don't let perfect be the enemy of good, but ultimately we need to make sure that it's good enough, given the fundamental nature of this activity to our supervision, as well as the fact that we're dealing in your data and your members' data.

4:26

And we're very conscious of that and are making sure that everything is working as intended before going live.

4:34

And we'll have updates on timelines very shortly.

4:38

Ultimately, prior to that delay, we determined that there were some performance issues, primarily from the upload perspective from a performance perspective on our side, which was the reason for the delay.

4:53

We're also taking this time to address some feedback that we've received from the sector to make sure that the transition and onboarding is ultimately as easy as possible for you.

5:04

So with that in mind, there are updates to the RRDS, which Flavia will be discussing in more detail as part of this webinar.

5:14

We are committing to no further changes to the RRDS until all CEUs are onboarded.

5:19

And we are taking a phased approach to onboarding.

5:22

This is something that members of the sector felt strongly about as a means to sort of ease the transition process for them.

5:31

And I'll get more into that in just a moment.

5:33

But ultimately, this brief pause gave us the opportunity to incorporate more of the sector's feedback and I think ultimately will be beneficial to both sides as we go across the finish line together.

5:49

Next slide, please.

5:53

So, I mentioned two phases and this is ultimately what it's going to look like.

5:59

Two phases because there are ultimately two components to this.

6:02

There is the raw data that we're asking for, and again, this is your risk management information.

6:10

And so this is the granular and ad hoc data that we've periodically requested in the past.

6:16

Submission will now be automated.

6:18

This is an important first step for us, and it made sense, I think, for us and for the sector to separate this out from the Phase 2 component, which is the equivalent of essentially of the monthly information returns that are already being submitted.

6:32

So that mirror type data will be onboarded with you in a second phase, starting in the fall of 2025.

6:42

But if I was to say the headline here is that as of June 30th, we will be onboarding a group of pilot credit unions.

6:51

And we've already had initial discussions with a group of credit unions who have volunteered for that pilot period.

6:58

Thank you to those of you who will be undertaking that with us.

7:01

Um and then the rest of the credit unions will be on boarded um at a um I will say a relatively uh slow pace over the course of the summer um just to make sure that we're able to provide you the support um as you go through this process um and make sure that both sides are able to achieve a level of comfort before we move on to phase two which will start in the fall of 2025 likely in same order that we go through phase one and so we will be onboarding you as we and you both agree that you are ready to be onboarded that will determine the order we will be structuring or sorry organizing one-on-one conversations with you with your teams to make sure that we're on the same page in terms of operational readiness with the goal being that all CU's will be onboarded through both phase one and phase two by this time next year.

8:02

There are still some lingering components that will be addressed over time, primarily data quality and integrity.

8:11

We do note that there's a range across the sector of data availability and the integrity of the data that's being submitted.

8:20

That's something that will be an ongoing conversation with the supervision team.

8:25

So with myself, with the directors, with your relationship manager charting a path towards ultimately what we hope to be full completeness over time.

8:38

So some of that will happen in advance of onboarding but this is an ongoing journey as we move forward. Next slide please.

8:49

So I did want to sort of take the time given the effort that's been expended to talk a little bit more about why we're ultimately undertaking this work.

9:01

And I think, you know, ultimately, eliminating manual work is a big part of this.

9:08

We have gone out to the sector for data when we undertake thematic reviews like our deposit taking and residential mortgage lending reviews.

9:17

Some of you had a similar request for our commercial real estate thematic review.

9:22

And we have gone out more recently and will be again in the summer looking for data with respect to your exposure to tariffs.

9:33

The purpose of this exercise is to eliminate that manual work so that we have the data at our fingertips when we get requests from our board, from the ministry, from our other stakeholders and are able to provide insights into the sector on a timely basis.

9:49

So, the important thing here is, and certainly in my conversations with you over the last few months, I've heard questions like, based on our membership, we have little to no exposure to tariffs.

10:03

Why are you coming out to me with the same information request?

10:07

The reason for that is that as we provide assurances to our stakeholders, including the board, including the ministry, that we're focusing both our human and financial resources in the right areas.

10:19

We need to be able to provide that holistic view of the sector and point to the CUs that are not affected and say we have evidence to say that they're not affected.

10:29

We can leave them alone for now and focus our attention where it's required.

10:33

So that eliminates manual work for you in the sort of through these ad hoc data calls but also allows us to be more in the way that we report, both back to you and to our other stakeholders on the way that we're conducting our work.

10:52

The single source of data, I think, is important.

10:54

We talk about principles-based regulation and the need to sort of foster trust and transparency.

11:00

This is a way to ensure that we're working from the same data set.

11:04

We're talking about the same things, we're seeing the same things, and so I think it will lead to much better and productive, and for some of you, as we'll talk about in a bit, less frequent conversations with your regulator about what it is that we're both seeing, both in the environment and in the risk data that you are providing.

11:26

It also will allow us the opportunity to feed this information back to the sector in a much more timely manner. We piloted this a bit with our previous thematic reviews.

11:40

Ultimately, because of the complications with collecting that data manually, we aren't able to come back to the sector with timely information in the way that we would hope.

11:50

And so what you should see coming out of this is much more frequent and timely feeding back of insights that we're getting from this data to the sector so that you're able to benefit from that as well.

12:03

And so that's something that we committed about a year ago to doing more frequently and with more utility.

12:11

And once we have everyone onboarded, I think you'll really start to see the benefits from that.

12:17

There's also the potential to reduce capital requirements.

12:20

And this is something that will play out in more detail through the consultation as we amend the capital rule.

12:27

But ultimately, we think that there are real pockets of lower risk and lower credit unions in the sector that should benefit from our availability of more granular data.

12:41

Sorry, my brain is getting ahead of my mouth as it often does.

12:45

But ultimately, we want credit unions to be able to grow.

12:49

We want credit unions to be able to thrive.

12:52

We want to recognize the lower risk elements of your portfolios and allow you to reallocate capital so that you can invest in better technology and new products and in ways to better serve your members.

13:05

Next, please.

13:12

So this is where, I mean, I think I alluded to it before, but ultimately this is, I will say, perhaps not the final step, but a truly important step in us being really risk-based in our approach.

13:27

It will reduce the number and duration of supervisory assessments because we have this data at our fingertips.

13:33

It will reduce the number of recommendations coming out of those assessments as we're able to sort of address these issues in real time with you through our monitoring process.

13:45

And ultimately it gives us a comfort level that you have the data at your fingertips.

13:52

Better reporting leads to more informed decision making and that will allow us develop a strong comfort level around the governance and management of your credit unions.

14:02

And again, let us focus our attention where it needs to be and let well-run credit unions largely go about their business.

14:11

And we talk about sort of overall risk rating being evergreen and our understanding of the credit unions being evergreen.

14:19

This will allow us to also be more dynamic in the way that we address the overall risk rating.

14:24

And as we see changes in your credit union, adequately reflect those so that you can have confidence that our view of your credit union matches up with your own.

14:37

It also promotes resilience, which is a key aspect of our framework, both on an individual credit union level as well as at the sector level.

14:48

These are key parts of our mandate.

14:50

We have statutory objects that drive us to focus on those two aspects as well as the treatment of your members.

15:01

And this is a way again to foster transparency, foster trust, have us reading from the same materials as we have these discussions and ultimately, as I said, lead to better decision making both as we look at individual credit unions and at the broader sector. Next please.

15:28

Just a few more benefits here and I will say we're taking up three slides on this but I legitimately believe that the benefits are there for the sector.

15:37

There are huge benefits for FSRA in terms of its approach but ultimately I think that this is a big step for the sector and will lead to real benefits for you once everyone is boarded.

15:51

So ultimately we are focused on governance, we are focused on risk management as we have to be and so ultimately looking through that lens at the CU sector, being able to foster market confidence, being able to ensure that this sector that we're all very much invested in continues to be viable in the long term, continues to be able to adapt to what are I will say trying and times is a real priority for us.

16:23

Regulatory efficiency will also make sure that we're able to, again, focus our attention where it's needed, but also recognize the financial strain on the sector.

16:35

Do our work more efficiently and you should see real benefits from that going forward.

16:42

And it will also allow you to demonstrate lower risk profile where those things exist that ultimately feeds the overall risk rating will allow you to reduce deposit insurance premiums it has an impact on fees as well so the effort and investment that has gone into this at this point there will also be financial benefits for you going forward as we're able to develop a mutual level of comfort around your data, around your exposures, and around the quality of your controls and your oversight functions.

17:20

So we'll move to the next, please, at which point it is time for me to turn it over to Flavia Popa, who will talk to you about the regulatory and risk data standard changes and the implications for yourself as well as those for FISRA. Flavia?

17:36

Thank you, David. Good afternoon, everyone.

17:41

I will be walking you through the more technical part of this presentation.

17:47

We will be going into details of the changes that we have done to the RDS 5.1.7 Amendment Number 3.

17:58

I know that many of you are working directly to building these schedules so I will try to make sure that I am addressing all the technical questions and if there's anything additional.

18:13

As David mentioned, we will either address it during the question portion of our webinar or afterwards through our usual channel of the EDC inbox.

18:26

So if we can please go to the next slide.

18:30

Okay, so many of you have received about a month and a half ago a new RDS mentioning about a thousand changes.

18:41

For one, I wanted to make sure that I am addressing that the number of changes that we are asking you to do is much lower than a thousand.

18:51

We want to make sure that we are transparent and we are you informed of all of the alignments that we are doing based on your feedback as well as on the user acceptance testing that we have performed in the last few months.

19:08

And just to bring down a little bit the concerns, there are about 200 of them that do require your attention and additionally there's no data mapping changes to the schedules that you are providing or that you have been working with us to create in the last couple of years.

19:30

That being said, once we did the user acceptance testing as well as received your feedback throughout the last year, we noticed that there were some data alignment issues, some formula logic that needed to be revised, as well as we made sure that the business definitions and business validation rules are aligned throughout all of the 24 schedules.

19:59

And once we did that, we reduced the inconsistency as well as created more efficiency from a platform perspective, which will enable you to be able to onboard smoother.

20:15

The transition should be easier and as well ensure that there's no issues when you will be onboarded on phase number two.

20:29

As David was mentioning earlier, there will be a phase one and phase two.

20:34

These RDS changes are basically, they will be impacting your onboarding for phase two, which will start the fall. If we can please go to the next slide.

20:53

Okay, so the changes have been broken down into two categories. One is able to file and one is unable to file.

21:02

Unable to file is referring to the 206 changes that will require your attention.

21:10

And we are asking you to make sure that the ones are highlighted in yellow in the RDS that we have shared with you, the last RDS, you will pay attention and you will make the changes according to what is highlighted in the document.

21:30

If you are unable to make those changes, you will receive an error from on the platform and it will block your submission.

21:39

So if we can please go to the next slide as we go through the detail of these Here we have broken it down into a more detailed category.

21:52

We have about 98 changes that will require your attention immediately prior to onboarding to Phase 2.

22:02

You will start onboarding with the monthly schedules.

22:05

Afterwards, based on the timing of your onboarding, after two or three months, you will have to submit your quarterly changes and then you will have to address the 75.

22:17

And then annually, it's 33 changes.

22:21

Additionally, for all these changes, we will be providing appendices where you can see more detailed by schedule exactly where you will have to change and how to consolidate that you have addressed every single one of these changes, which are critical blocks to your submission.

22:45

Once you do that, the onboarding should be smooth, and it will align to the reporting accuracy and submission schedules that you are used to up to this point.

23:02

If we can, please go to the next slide.

23:07

In this slide, we have broken it down slightly to a little bit more just to explain the complexity so that you can see that majority of these changes have a minor impact.

23:23

One example can be for a minor change, which is out of the 98 for the monthly schedule, only 79, can be that prior it used to be a data point greater than zero, now we have changed it to greater than or equal to zero.

23:41

That means that it is very minimal.

23:45

It's logical and it doesn't affect much from a business perspective, but it will affect it from platform and type of error that you will receiving.

24:04

If the following 18 changes for the monthly will be more complex and we are here to support you in case you have any questions so to please reach out when you are making these changes. If we can please go to the next slide.

24:23

Okay so the able to change are basically informative changes that we have done and for transparency purposes, we have made sure to allocate color blue in the RDS version 3 that was circulated about a month and a half ago.

24:42

To give you a bit of background, what you will be seeing in the moment you are submitting these files, if you choose to not make any changes or revisions, you will receive a caution, notice, or warning. These are the three categories.

25:00

There's no approval needed, but they will inform you that there is a discrepancy between data points within the different schedules or within the same schedule.

25:13

So if we can please go further into detail on the ABLE to file.

25:19

This is the same table as shown in the previous slide, only that we will be focusing on the ABLE to file.

25:26

The majority of the changes here are on the monthly schedules, followed by the quarterly and annually.

25:37

This can be a description on the business definition rules or, for example, it can be a formula removal where you will be informed that we have made that change when you are it to the previous RTS which was circulated last year in August, but there is no action required on your end. If we can please go to the next slide.

26:13

Okay, so we are going into a bit more detail in terms of the 887 changes.

26:21

These are categorized in two groups.

26:23

Some of them are non-formula changes, others are changes and we have a section where we have added a formula that being said it's coded and embedded into the system but previously there was no formula now we are adding one so you will be informed of that specific change additionally here I would like to highlight if you take a look at the quarterly formula change, majority of the changes are in the quarter submission in the NCCF schedule. So, the remaining of the schedules have minor changes.

27:09

Most of them are concentrated there and you can review that specific schedule for more detailed information.

27:18

If we can please Go to the next slide.

27:24

So what are some non-formula changes that we have done?

27:28

Some of them can be label, others can be definition.

27:33

Some of them are user interface input.

27:37

For example, one of the user interface cases can be the name of the credit union, the charter number.

27:47

it will be imported from the mirror information that we already have for your specific credit union, but that is a change that we have added to the RDS in schedule seven, so you will be able to see it over there.

28:05

One change for the non-formula that I would like you to pay close attention to is the formula removal.

28:13

Meaning currently, previously there was a formula, currently we have removed it, which means it turns from a formula data field to an input data field, and you will have to put in that specific number for that cell.

28:34

If we can please go to the next slide.

28:37

All right, I won't be spending too much time the next two slides as they are just examples of the different types of changes that we have done.

28:49

But as you can see in business validation one is yellow one is blue.

28:54

Yellow means it requires your attention and you need to make a change to be able to file while the blue one it's mostly informative.

29:06

As I was if you take a look at the D12 it used to be greater caution if greater than 25 percent right now we are just stating that that caution will be appearing in the moment that it is greater than 25 as 25 percent as this field has to be less than or equal to 25.

29:35

For the technical validation rules, previously we used to have yes or no.

29:42

Now you can take a look that we are referring to the specific cell when we are checking in the user interface, and we are stating if that specific data point is equal to yes or no, then it is OK to pass.

29:57

If not, then you will be receiving caution or notification. If we can please go to the next slide.

30:07

So in terms of format change you will see only one single format change and it's from string to date. It will make sense.

30:18

It is aligned to the fact that it is a fiscal year and it should be a date format.

30:24

With regards to formula updates you will that if the calculation rule was empty and now it's populated, it means that now it is calculated by the platform.

30:40

If it used to have a formula and it's removed, then it is an input. I believe that's all on this slide.

30:48

If we can please go to the next.

30:52

Okay, so what can you expect from us in terms of communication going forward.

30:59

As David was mentioning, we will be engaging with you more often when it comes to EDC as we are transitioning to a phased approach to onboarding.

31:13

The first party will be receiving from us eBlas on a monthly basis starting June.

31:21

We will also be having ongoing communication and support with credit to make sure that we are scheduling you based on your data completeness and data readiness.

31:37

After scheduling each credit union, you will be receiving training session, onboarding material, support documentation, and frequently asked questions.

31:49

As well, you will be receiving support when it comes to the first filings.

31:54

we understand that it's a new process and most likely you will have a lot of questions and need our support. So we are always here to provide you that guidance through this transition.

32:09

Additionally, we want to hear back from you with this experience.

32:14

So there will be different surveys that we're going to be sending out. One of them will be after the webinar.

32:21

Just to get your input, if this was useful, if you would like more of these types of communications or something more personalized would fit your needs better, as well as after three months of the onboarding to phase two, we plan on sending out another survey to understand your customer experience.

32:46

If you find this platform useful, what can we improve and how we can keep that open communication to receive your feedback.

32:57

Additional to that, you always have the EDC inbox where you can write us and we will get back to you as soon as we can.

33:06

And if there are specific questions that you prefer to have a meeting with us, as David mentioned, you can reach out to your relationship manager and we can support with any additional information that you require when it comes to EDC.

33:27

If we can please go to the next slide. I'll pass it on to David now for next steps.

33:38

Thank you. I think this one might actually still be yours, Flavia. Okay, sorry.

33:44

Okay. So next steps.

33:48

What we are requesting from you is to, as I mentioned, review the 206 that are in yellow and make sure that you are changing it where needed.

34:01

Align it to the definitions that we have for business and validation rules.

34:07

If not, you will be receiving an error message and phase two filing submissions.

34:15

When it comes to the remaining, you have the 272 formula updates.

34:22

That's another one that I would suggest reviewing in more detail and pay a little bit more close attention to it as you might have an automated process in the background that might be aligned to a previous schedule and that could cause errors, but I'm hoping that that would not be the case.

34:50

And then the remaining, it will be for your information.

34:55

I would suggest reviewing just to avoid misreporting, but number two and three, it will not generate an error in submitting your files, but it is good to be aware of what is happening in the backend.

35:15

Okay, if we can go to the next slide, and I think now I'm passing it off to David.

35:20

Now it's my turn.

35:23

So yeah, as I said at the outset, we are going to be meeting with you individually on this.

35:29

And I think we wanna make sure again and then we have the same views as to your readiness, and we order the onboarding accordingly.

35:40

But ultimately, and I think Dan is gonna be joining us on screen shortly as he would say, we're gonna be holding hands as we cross the finish line here, and expect a lot of interaction over the coming months to make sure that we get to where we need to be by the end of the summer.

35:59

The other thing that I mentioned previously is that, again, data quality, completeness, this will be an ongoing focus and something that we will be looking to enhance on a continuous basis.

36:16

We will talk as part of those sort of initial meetings about what sort of, from a completeness integrity perspective, what will be possible at onboarding, and then working with you to chart a path towards, again, continuous improvement in those areas, so that ultimately we end up with a data set that allows us to fulfill the many promises I made to you at the outset of this webinar.

36:46

And we can move to the next, which is the opportunity for you to ask questions.

36:53

I see that some questions have already been trickling in.

36:56

I look forward to getting to those.

36:58

My initial suggestion for this was that we provide 10 minutes for questions and do the webinar at the end of a Friday when everyone was a little sluggish and looking to get on with their weekend.

37:08

I was voted down, and instead, you have 53 minutes to ask questions at peak intellectual capacity on a Thursday afternoon.

37:19

So possibly a mistake on our part, but we're going to roll with it.

37:23

I'm going to ask Dan Aprescu to emerge from the shadows and join us.

37:33

Thank you, David.

37:35

And as I mentioned, we've already had some questions come in.

37:39

Please continue to submit your questions.

37:44

We will get to as many of them as we can.

37:47

Dan, given that you've just joined us, I'm going to start with you.

37:51

And this is a question, I guess, related to the notice that went out recently about the data call in the summer.

37:58

Is the data call for summer 2025 related to the changes here?

38:05

Yes, but loosely in the sense that the enhanced data collection project needs to proceed the normal way, arrive at a successful conclusion.

38:18

But because of the volatile environment in which credit unions operate, and in fact, we all live nowadays, we need to analyze a variety of scenarios, adverse scenarios, perform stress testing, and for that we need data.

38:41

And the two needs, the project need and the scenario analysis need converge on the same time frame, which is the summer. This is the connection between the two.

38:57

So one is not a cause of the other, but the two initiatives are converging in the summer time frame.

39:10

Good. Thanks for that, Dan. Question from the audience again.

39:18

I believe Flavia mentioned an EDC inbox. Is this an email to ask questions or perhaps on the FISRA website?

39:28

Yes, we have an EDC inbox specific for any questions that you might have.

39:35

May it be in technical matter, IT questions, business questions, any sort of questions and concerns that you might be having about EDC, please feel free to contact us, we are here to support.

39:51

I believe the EDC inbox is also on one of the slides of the deck and the deck will be circulated.

39:58

So you can use that as well.

40:03

Great, thank you for that.

40:06

So another question here, and I think we've already mentioned that in the course of onboarding, we'll not be making any more changes to the RRDS.

40:15

This question asks, will the RRDS be updated in the near future? If so, will updates follow a quarterly or annual cycle of some sort?

40:27

That is something that is still in development.

40:31

There will be no RDS changes until we complete the onboarding.

40:38

Once that is complete, we will be working towards standardizing the RDS changes as well, creating a pipeline in which we will ensure that they are informed of the future changes and when those changes will happen as well as the timeline for those changes.

41:01

So that's in discussion at the moment.

41:05

Yeah, and I think, yeah, I certainly understand that some things still need to be sort of Notwithstanding our efforts to lock this down The environment is evolving credit unions are evolving and ultimately We may need to make further changes to the RRDS to reflect all of that Question for Dan will there be a parallel filing period during which the EDC and mirror systems are active If so, how long will this dual filing period last?

41:44

Yes, there will be a parallel run in order to assess the integrity of the reporting.

41:53

The length of time will depend on the degree of comfort that we get, and it's institution specific.

42:04

We are not envisaging an overly extended parallel run, like a year, but it is possible that will get comfort earlier than say six months or whatever the average expected parallel run would be. Great, thank you.

42:33

So question in the chat again and this one maybe I can start with and then I'll open it up to Dan and Flavia for when I inevitably get it wrong.

42:45

When will we receive more information on this data call? And the answer to that is that it is imminent.

42:54

Dan mentioned sort of the purpose of this data call.

42:57

We are prioritizing certain data fields as a result and so we have finalized that list.

43:10

We will set be sending it out as of a communication to the broader sector very shortly.

43:15

And then as part of these one-on-one conversations that we're setting up, we look forward to a discussion around these priority fields, their availability for your credit union, and what we can do to perhaps make progress from a completeness perspective as we move towards this data call.

43:36

Dan, Flavia, anything to to add on that front? Good. It was perfect. Good.

43:48

Question for you, perhaps, Flavia. Why are blanks no longer accepted if a field does not apply to us?

43:57

If a field does not apply to a credit union, they do not need to provide it.

44:04

So I believe that this referring to the formula removal.

44:09

So if they do not have that product or that data point, this would have all been discussed in their data mapping communication that they had with FISRA.

44:21

They do not need to make any changes, so they would have to go into the RDS and make sure that those 19 data points that was referring to, they are connected to what they have previously mapped and they relate to that credit union. What I was highlighting is the maximum number of changes that can happen.

44:49

Great. So I'm going to hit you again, Flavia, because we've got a lot of RRDS questions here.

45:00

What do items highlighted in red mean in the RRDS doc? I don't have an answer for this.

45:14

Yeah, unless you want to provide a clarification, whoever asked the question, maybe a bit more detail in the question.

45:27

That doesn't sound like one that we're able to answer at this time, apologies for that.

45:37

Question for Dan now.

45:39

As part of the pilot, I've provided a lot of feedback about data integrity for commercial personal lending, knowing the landscape comprises complex and different systems and processes.

45:50

Have you considered a template approach for both like you have with investment?

45:59

I believe we have. There is a given template for commercial and personal lending.

46:08

And within that template there is a variety of options of product types that may be characterized as commercial lending or as personal lending.

46:25

And there is also other data elements that could characterize each line on the lending file appropriately for a risk assessment, which is the purpose of this.

46:44

Now, that's my understanding of the question so far.

46:52

Template approach for both like you have, yeah, so they are all subject to templates.

46:57

These are the first six schedules of our RDS.

47:05

But if that's not clarifying it, please ask, just write to us.

47:14

I think this comes from Steve. Steve, please write to us and we'll clarify further.

47:24

Great. And I would encourage you again to submit questions if you have them.

47:30

Again, this is far from the only forum you will have to ask questions.

47:35

but we do have the time now and you have the three of us in the firing line so feel free to to take advantage and I see someone has already said they will clarify their question with an email so great thanks for that Steve thanks to you another question here that I will take a against my better judgment take a first stab at as well and then turn it over to the others will you hold off on tariff data call until the U.S. Court of International Trade's ruling appeal is finalized.

48:10

Thank you for the question. I certainly understand the rationale for the question.

48:17

For better or for worse, we need to be forward-looking in our assessments.

48:23

And so we, in a time of great uncertainty, are unfortunately not in a position to wait for certainty given the I will say volatile nature of the decision-making process that can have significant impacts.

48:42

We won't be able to hold off on the data call because we need to look forward and understand not just what the impact of the current tariffs are but get a view as to the future landscape should again the situation swing wildly as it has several times in the past.

49:02

So we understand the work that's associated with these data calls.

49:07

Again, the purpose of EDC is to mitigate the need for these type of ad hoc data calls and allow us to be more proactive in our approach.

49:17

But as much, I think, as we would all like some additional security, security, there's my brain working again, some additional certainty in this respect.

49:30

We need to be forward-looking, we need to be as proactive as possible, and the prioritized data fields will allow us to look at a spectrum of potential possible outcomes with respect to the geopolitical situation and provide, again, our stakeholders with some comfort that again we're focusing our human resources, our financial resources in the right area.

49:56

And I say financial resources because this will be a key determinant in allowing us to use the DERF, use our line of credit to provide short-term support where it's necessary.

50:10

And again, we have stakeholders that need to be provided with a level of comfort.

50:15

We have a provincial government that's decidedly empirically minded these days and wants to see the evidence, and so this will allow us to move more effectively from preparing the sector for a crisis into, as needed, supporting the sector through a crisis.

50:34

Dan, Flavia, anything to add on that front?

50:37

Yeah, I would like to add something.

50:39

David, thank you very much.

50:40

David Anderson, thank you for the question.

50:45

It links with the previous answer, has the Tariff Data Call anything to do with EDC?

50:53

Both of them happen to be in the same timeframe, but if there was no tariff threat, if there was no volatility, we would still proceed with enhanced data collection.

51:05

We are trying to be efficient at every step, and therefore, we would not, It's called a data call, but it's a little bit misleading in the sense that, as David and Ravia previously indicated, the onboarding of credit unions for the first six schedules, the granular data, the gradual process is a wave by wave, if you want.

51:34

So we are building this data structure gradually.

51:38

the data structure that can be used for stress testing to assess tariff impact, but also for other applications.

51:48

So the data onboarding that will happen over the summer is not contingent on anything happening, anything to do with tariffs or US or anything like that.

52:08

If there's a lesson here, It's just that I should let Dan answer the questions first.

52:15

Another question here.

52:16

I'm going to ask this one to Flavia first.

52:19

For the formula change, for example, NCCF, would that change the methodology or results if we change all the fields highlighted in yellow?

52:29

No.

52:30

No, it would not.

52:33

As we were going through UAT and as we further detailed analysis on the formulas especially for business and validation rules in the back end meaning on the platform we have noticed that there was an error so we have corrected it and that that is what the NCCF formula change means and that is why I stated that most likely there's no action required from the credit union side, but it is something that we needed to fix on the platform to make sure that we are aligned with the current data standards.

53:22

One for Dan here, and this is related to the data call, but also relevant to EDC onboarding.

53:30

The prioritized fields that were mentioned, will they be on the entire lending portfolio or a subset of products?

53:37

How does this data support decisions on older line of credit products where the borrower may have changed industries since origination?" So thanks for the question Mark.

53:50

It's a very good question because it allows me to talk about the timeliness of data.

53:59

First of all, in direct answer to your question, prioritized fields do refer to the entire lending portfolio but only where applicable.

54:12

So because as I was saying earlier, within a lending portfolio there is different product types.

54:20

Each product type, each line in the portfolio, each loan will have a number of relevant data fields and those data fields don't match the next loan and the loan and the next one so because of this it's a the answer is a yes the column exists there for every loan but it only need to be populated where applicable and with regard to the example you gave on lines of credit that have been going on for a while the industry of the borrower may have changed yes that is since origination the industry of the borrower will have changed.

55:04

The question to the credit union would be, are you managing that particular loan ignoring the potential change of industry since origination?

55:18

And if the answer is yes, you know what we would say.

55:23

And if the answer is no, we have an updated view of the would say okay well put that in with the latest industry rather than the origination industry at origination because this information is used for risk assessment and there's no point in taking history of five years ago if is not no longer applicable if it is of course but if it isn't the business the credit union, and we, the regulators, only need the latest information.

56:00

Whether that is yesterday's or a year ago, the latest is better than five years ago.

56:07

Yeah, I think the other thing that I want to stress on this is that, you know, we look at these things from a portfolio perspective first, and so certainly want understand the nuance in the data, but we're never going to make judgments on your portfolio or on your data without a conversation.

56:32

We understand that you know your members, we understand that you know your portfolio in aggregate.

56:39

This will be the start of a conversation rather than the start of an angry sounding letter from your regulator.

56:46

So just know that the intent here is to foster effective rather than pass judgments based on the raw data.

56:58

There's a question here noting that they still have some questions about inconsistencies in the latest version of the RRDS and will there be opportunities if they submit their analysis for any final tweaks before we put a lock on the RRDS going forward?

57:20

Flavia, I see you nodding. Maybe you can start.

57:24

Yes. So there are various parts to this question.

57:29

One, we are fully aware that there are still inconsistencies to the RDS version 3.

57:37

What we try to do in this version is to make sure that we keep the data mapping, which is something that I have mentioned in my first slide, to make sure that we don't put too much burden on the credit unions asking them to change their data mapping right before we go live.

57:59

So any changes to the data mapping that would impact either changes to the data fields or adding new data fields which can be considered inconsistencies, We are parking those for after go live as we are trying to be considerate of everyone's time Resources and efforts that are being put in to make this initiative happen, so Yes, we are aware that it's not perfect at the moment and we are currently assessing and strategizing on when we will be getting to that perfect stage that we are all hoping to get to.

58:43

That being said, before onboarding it is locked in, as it not only impacts changes that we would need to coordinate with every single credit union, but also it would be changes that need to be coordinated with our technology team, and that takes time, and we don't want to push further the onboarding stage due to these inconsistencies, but that are not a showstopper when it comes to what we need for the submission.

59:25

I hope that answers the question, if you want to.

59:28

I think that's great, Flavia, and I would say because there was an offer to submit that credit unions analysis, please go ahead and do so.

59:37

I think, you know, as Flavia said, we need to balance certain things and not let perfect be the enemy of good, but I think would be very interested to see any analysis that you've done and distinguish the known inconsistencies from the unknown inconsistencies from the the show stoppers as Flavia said and so thank you for the offer and we will absolutely take you up on it. Definitely thank you.

1:00:09

This time we have run out of questions or at least out of EDC and data call questions.

1:00:18

I see a question here about whether Dan and I emailed to match our outfits for the webinar this morning.

1:00:25

The answer is yes.

1:00:28

We aim for consistency wherever possible in your regulatory experience.

1:00:38

Not gonna close things off just yet, but I wanna thank you for the quality of the dialogue today.

1:00:46

I think that we really appreciate your questions.

1:00:50

We are being as transparent as we can about our own processes as we always do, but we don't always know what you don't know or what it is that you're curious about.

1:01:06

These interactions are really valuable on a collective level, but again, this will be far from your last interaction with us in this regard.

1:01:15

We'll be reaching out very shortly, first of all, with details on the prioritized fields for the summer data call.

1:01:22

And second of all, to have a conversation with you about your readiness, about where you would like to sit in the order of onboarding.

1:01:31

And then, of course, starts the process of what I can promise will be white glove service provided by Flavia, Dan, maybe even myself, but certainly their teams.

1:01:43

as we as I said hold hold hands crossing the finish line.

1:01:49

I am glancing to my right and we'll give it one more minute there's only so much I can stall here you're really sort of taxing my capabilities but thank you again for taking the time for us today.

1:02:04

Thank you as I said at the outset for the tremendous effort that you've put into EDC over the last few years.

1:02:12

Thank you in advance for the effort that you will be putting in over the summer through Phase 1 and then through Phase 2.

1:02:20

And I look forward very much to our interactions on this subject over the course of the next year and to what should ultimately be a very much improved regulatory experience on both sides once everybody is onboarded and we're all able to reap the benefits of this system.

1:02:43

seeing no more questions other than some very nice comments thank you for that I will bid you all a great rest of the day a great rest of the week and we'll be in touch very soon on next steps thank you thank you