Good morning, Mr. Chair.

Thank you, dear committee members, for this opportunity to speak with you today.

My name is Bernard Brun and I'm the head of government relations at the Desjardins Group.

With assets of over $420 billion, Desjardins is the largest co‑operative financial group in North America and the seventh-largest financial institution in Canada. To meet the diverse needs of our 7.7 million members and clients, our activities cover every aspect of the financial sector, including services to individuals, business services, wealth management, personal insurance and general insurance.

Desjardins supports initiatives that would enable it to provide enhanced financial services to its members and to Canadian citizens. The objectives of the consumer-driven banking framework, commonly known as the open banking framework, would appear to do just that. We therefore support the ultimate objective, which is the implementation of a framework to allow consumers to control the sharing of their data.

Unfortunately, the proposed framework has a major structural flaw. Our current concern stems from the fact that the proposed framework would do more than introduce a common technical standard for all of the country's financial institutions; it would also establish a separate mandatory framework for federal financial institutions, to which provincial institutions could adhere.

As this government admits, the field covered is one of shared or joint jurisdiction. Concretely, it would lead to a dual overlapping framework for the jurisdictions, which would certainly put provincial financial institutions, like caisses populaires and credit unions, at a disadvantage. Although adherence to the framework is theoretically voluntary, financial institutions would end up being required to adhere in order to remain competitive and provide proper services to members and citizens, and also because of risk management considerations.

As I was saying, the current bill has a structural flaw that would have a major impact. It needs to be corrected as soon as possible. The government must avoid a false start in terms of consumer-driven banking services to ensure that it covers the entire financial sector and all consumers.

As a systemically important financial institution nearly all of whose activities are subject to provincial regulation, we believe that the inevitable overlap between the federal framework being proposed and the existing provincial framework is counterproductive. It's a barrier to competitiveness.

The adoption of the bill in its current form would undermine consumer and user confidence, when this confidence is crucial to the concept underpinning the idea of open financial services.

A two-tier system would place consumers at a disadvantage and, more to the point, make a consistent consumer experience impossible, while ultimately reducing credibility and innovation.

The Desjardins Group is in favour of introducing a framework that would enable consumers to control how their data is shared. In order to do so, corrective action is immediately needed in terms of governance and structure, if we are to continue to benefit from current favourable conditions and avoid future delays.

Under the circumstances, dear committee members, we asked the government to remove division 16 of part 4 of Bill C‑69 and to make it a separate bill so that the proposed framework could be reviewed in depth to allow all of the entities affected and the public sectors, including provincial authorities and governments, to have the same view and understanding of the future system.

Thank you for listening. I'd be more than happy to answer your questions.