The January edition of our commentary on the new framework
outlined some of the changes likely to impact bank governance. The
focus of this installment is to examine Division 1 of Part XII.2 of
the legislation, which provides interpretative assistance, through
its definitions, in applying the provisions of other Divisions.
Of note, is the fact that the definitions, currently scattered
across the Bank Act ("the Act") and the regulations, have
been consolidated under one section (Division 1) of the Act, making
it more efficient and reducing the potential for inconsistency.
Some definitions make their appearance for the first time, while
others have undergone an expansion in scope. The definition of
"complaint" falls into the latter category.