Note: This is the second in a series of monthly articles
intended to parse the new federal financial consumer protection
framework1 (the
"Framework").
As we wait for the new Framework to come into force, we thought
we would spend some time going through its sections, sequentially,
and discussing their potential impact on banks. However,
before we start unpacking Division 1 of Part XII.2, we consider
some of the amendments to the Bank Act that aim to
strengthen governance.
Governance
Currently, banks are required to designate a committee of the
board of directors to monitor the procedures they must establish to
provide the disclosure required under the Bank Act and for
dealing with complaints (paragraphs 157(2)(e) & (f)).
While the new paragraph (157(2)(e)) maintains the requirement for a
committee, it increases the committee's responsibilities in
that it must now: