STANDING COMMITTEE ON FINANCE
COMITÉ PERMANENT DES FINANCES
[Recorded by Electronic Apparatus]
Thursday, March 1, 2001
The Chair (Mr. Maurizio Bevilacqua
(Vaughan—King—Aurora, Lib.)): I would like to call
the meeting to order and welcome everyone here. As
everyone knows, the order of the day is Bill C-8, an
act to establish the Financial Consumer Agency of
Canada and to amend certain acts in relation to
We have witnesses here from the Interac Association:
Ms. Judith Wolfson, president and chief executive
officer; Marc-André Lacombe, corporate secretary and
legal counsel; and Kirkland Morris, policy development.
Welcome. You've appeared before this committee before,
I gather, so you know how it works. Since we have two
hours, I will give you seven minutes to make your
presentation, and then we'll engage in a question and
answer session. Welcome.
Ms. Judith Wolfson (President and Chief Executive
Officer, Interac Association): Thank you, Mr.
Chairman. We do appreciate having the opportunity to
appear before you, Mr. Chairman and honourable members.
My name is Judith Wolfson, and I am the president and
CEO of Interac Association. On behalf of the
association, I thank you for allowing us to appear
today to offer our views on what is now Bill C-8. In
the fall we did appear before this committee to express
our general support for what was then Bill C-38 and to
discuss some very particular concerns with one small
section of the legislation, which is now clause 244
of Bill C-8, dealing
with the oversight of private payment systems.
Bill C-8 will establish a new regulatory framework for
Canada's private payment systems, Interac Association,
Visa, MasterCard, Mondex, and others. Under the new
framework, the Minister of Finance, if he believes that
it is in the public interest, will have the power to
designate and directly oversee the operation of any
payment system that operates on a national or
substantially national basis. We fully support the
government's stated goals of promoting efficiency and
competition, ensuring safety and soundness, and
protecting the interest of consumers.
It is our belief, however, that in aiming to achieve
these objectives, clause 244 does not reflect an
appropriate balance between benefits and costs. Last
fall we sought the committee's support for amendments
to, first, tighten the scope of the new oversight
framework so that it focuses only on issues of consumer
protection and avoids overlap with existing regulatory
processes governing payment systems, those in the
Competition Act and the Payment Clearing and Settlement
Act. The second aim was to increase transparency and
provide needed checks and balances in the exercise of
the powers created under the new framework.
In the time since our last appearance we have had the
opportunity to continue our dialogue with the
government on these issues. What we have heard is that
with respect to the first issue, that of narrowing
scope, the government wishes to maintain a high degree
of flexibility in the regulatory framework. This is in
light of the general uncertainty about the future
direction of the financial sector and an inability to
know today what tomorrow's issues might be. While we
believe this will result in regulatory duplication, we
understand the government's position in this regard.
However, we believe the impact of this duplication can
be minimized by ensuring that the new framework
contains clear processes for consultation and an
effective set of checks and balances. This brings us
to our second point about ensuring an appropriate
process and transparency.
We have some minor, yet very important, suggestions
for fine-tuning clause 244, which we believe will allow
the government to accomplish its goal of protecting the
public interest, while providing payment systems with
the predictability and transparency they need to
effectively manage their business. It is these process
changes for which we have heard continued support from
many sides of the debate, and today we're seeking the
committee's support for these amendments.
Interac Association, as you know, is a unique Canadian
success story. As a private not-for-profit association,
the now 90-plus members cooperate to build a network
that allows Canadians to access their funds at any
time and just about anywhere they happen to be.
As a result, Canadians enjoy a standard of banking
convenience that is matched in very few countries in
the world. We are concerned that an overly intrusive
and uncertain new regulatory framework for Interac
Association and others like us could jeopardize this
highly effective system. In this regard, let me be
specific. There are two primary concerns with clause
First, the bill gives the Minister of Finance the
power to designate individual payment systems to fall
under direct supervision of the government. For these
designated systems, we believe the oversight measures
proposed are more intrusive than they are necessary to
protect the public interests, potentially involving the
minister in day-to-day decision making.
For example, if the minister chose to designate
Interac Association under the new powers, all of the
technical rules and regulations we develop on a
day-to-day basis in managing our business would have to
be reviewed by the minister. Ours is a very complex
and rapidly evolving business. Involvement of the
minister in day-to-day rule making would create
significant costs for the industry, and indeed for the
government, without a clear benefit to the broader
Second, the proposed framework falls short in
providing appropriate checks and balances. Bill C-8
establishes virtually no rules, conditions, or
processes for designating a private payment system.
There are no defined triggers for designation. There
are no timelines established. Perhaps most
importantly, there is no provision that gives the
payment system the opportunity to fix a problem prior
to being designated. The bill simply does not establish
a clear and transparent framework for oversight.
To remedy these concerns, we are proposing some very
simple process amendments to Bill C-8, which we believe
will strike the right balance between maintaining the
government's ability to protect the public interest and
the industry's need for regulatory certainty and
First and foremost, Bill C-8 should contain a simple,
well defined, transparent process for designation,
should the minister feel it is necessary. There should
be three simple steps. One, the minister should
articulate a specific public interest concern with a
payment system and notify the system, in writing, of
that concern. Two, the system should be consulted and
given an opportunity to address the minister's concern
within a reasonable period of time. And three, if the
system fails to adequately address the minister's
concern, the government should have the power to
designate through an Order in Council. This would
maintain fully the government's ability to protect the
public interest. It would simply make designation a
last resort, rather than a first step in solving a
problem. It would also ensure the designation process
is transparent and fair.
Second, if and when a system is designated, the
Governor in Council, on recommendation from the
minister, should have the power to issue directives to
correct the problems identified. The government does
not need to review each and every rule and regulation
of a designated system.
Let me give you an example—and this is an absolutely
regular day-to-day example. We have on our books rules
that deal with how the Interac trademark can be used
and displayed, the format of transaction messages that
flow through the network, and the colour of the OK
button on the PIN pad. Those are our rules and our
regulations. Surely these are not issues in which the
government has a keen interest or that will have an
impact on the public interest at large. Requiring the
minister to review all of these day-to-day rules and
regulations would create a huge amount of work on both
sides. It would be costly, slow, and bureaucratic.
In summary, we support the government's goals of
promoting efficiency and competition, ensuring safety
and soundness, and protecting consumers. We are keen
to work with the government to ensure Canadians are
well served by Interac services, now and in the future.
The changes we are proposing to clause 244 are fine
tuning. They do not alter the government's intention.
They do not limit the government's ability to protect
the public interest. They simply put in place some due
process and transparency that would ensure the public
interest is protected in an efficient, cost-effective
manner that continues to provide flexibility and
promote innovation in a rapidly evolving industry.
Mr. Chairman, we have
provided to you specific language for these recommended
changes, and we would be happy to provide that to the
committee, if that would be helpful, and we thank you
for your time today.
The Chair: Thank you. Actually, I would
appreciate if those proposed changes could be tabled
with the committee also for our records.
We'll now move to the question and answer session.
We'll begin with Mr. Epp, a ten-minute round.
Mr. Ken Epp (Elk Island, Canadian Alliance): Thank
you very much, Mr. Chairman.
I appreciate your coming
here again and again and again. Eventually we'll
probably get this legislation through. On that topic,
I get the impression that the government is now ready
to move on this, and probably there will be some
movement on this, and maybe you can come to see us for
some reason other than this particular legislation.
I'd like to commend you for your insight into the role
of the government in your industry. The proper role of
government in something like this is to ensure that the
consumer's interests are protected. Do you feel that
the way it works now puts consumers at risk? I know
this is a silly question to ask you from your point of
view, but in terms of the legislation under which you
operate presently, are consumers' interests at risk,
and does Bill C-8 reduce the risk to consumers, does it
increase it—what's your perception of that?
Ms. Judith Wolfson: As you say, Mr. Epp, the
Interac Association is governed by a consent order,
pursuant to the competition tribunal, and in addition,
we are governed by and come under the rubric, if you
will, of the Competition Act and the Payment Clearing
and Settlement Act.
I don't think there are any areas in which consumers
are jeopardized at the present time—and that's
particularly what our interest was in trying to narrow
the scope of the legislation. I think the safety and
soundness is governed through the Bank of Canada, and
competition has been extremely effectively managed. The
Interac Association has grown from a number in the
twenties less than ten years ago up to 91 members. The
membership of the Interac Association is not just
financial institutions at this point, it's technology
companies, it is retail—Petro Canada, for instance, is
a member of Interac Association. So consumers'
interests are represented by the very broad membership
in the association and its governing structure.
Mr. Ken Epp: But when I, as a consumer, go to a
bank machine, I don't really get to choose which one I
go to—this is the one that's here and there I am. I
can't really choose which of the 91 member
organizations I'm dealing with—I'm dealing with
Interac at that stage, right?
Ms. Judith Wolfson: You choose your bank machine.
There are two services, of course, in Interac: one is
the shared cash dispensing, which are the ABMs, and the
second is Interac direct payment, which is the debit
card service. You're referring to the shared cash
dispensing service, which is the ABM.
Of course, you, as a consumer, have a vast array of
choices. You can go to your own financial
institution's bank machine, you can go to a bank
machine that is operated by another financial
institution—part of the shared cash dispensing—or you
can now go to the hugely increasing number of what are
called “white label machines”, and that availability
for consumers has grown enormously. Consumers truly
have access now to bank machines and their cash in a
way they never had before.
Mr. Ken Epp: Okay. How do you make your money?
Ms. Judith Wolfson: The Interac Association is a
not-for-profit association. The members pay fees to
cover the costs of the association, but that's all it
is, a not-for-profit association.
Mr. Ken Epp: Okay. One of the things you said was
that you feared the minister's becoming involved in
day-to-day operations, and you made, I think, a
facetious argument about whether he's going to become
involved in approving what colour the keys on the
machines are, and so on. Could you enlighten us as to
what regulations there should be concerning the powers
of the minister?
Ms. Judith Wolfson: Mr. Epp, I was not being
facetious. The problem with the legislation is that we
have hundreds of regulations, and we make them
constantly to make sure that the machines and the
services meet the needs of the marketplace. Under the
legislation, once a system is designated, it is so
broad that all regulations would have to go and be
lodged with the government, and that would be very
What we are suggesting is if there is a problem with
the public in terms of consumer protection, and the
government feels that the public interest is not being
addressed, then, from our perspective, the government
should say this is the problem—fix it. We should
have a consultation period, we should have an
opportunity to discuss it and then fix it, and if it's
not fixed to the extent the government thinks is
appropriate, then the government should regulate on
that issue. So should the government be interested in,
perhaps, a regulation on safety and security—believe
me, I think we'd be there before anybody else—and
should that not be fixed, then the government would
regulate on that issue. But it should not have this
blanket power to regulate on everything else.
Mr. Ken Epp: I think you're saying they would then
regulate on that issue if you didn't solve it before
that was necessary.
Ms. Judith Wolfson: Absolutely.
Mr. Ken Epp: Yes. Can you give us some idea of
how many consumer complaints we get per year in Canada?
Roughly, is it 20 per day, is it 100 per day?
Ms. Judith Wolfson: The difficulty, of course, is
that our members are the ones who would get the
complaints from consumers, and the bill addresses the
whole consumer issue with financial institutions by
setting up appropriate structures within the
Interac Association does not get significant numbers
of consumer complaints. I couldn't possibly speak to
what the members get themselves, financial institutions
or others. I am not privy to those specific numbers.
Mr. Ken Epp: If there were some problems, since
your name “Interac” is right on the machine, wouldn't
it make sense that the consumers then find out an
Ms. Judith Wolfson: Indeed.
Mr. Ken Epp: And contact you?
Ms. Judith Wolfson: That would certainly happen.
We do get concerns. We do facilitate those discussions
with the financial institution and ensure that transfer
I can tell you that most of our efforts have been in
reliability. This is an extraordinarily reliable
network—over 99% reliability—and there are, for
instance, regulations on sanctions policies if
reliability is not met. We have those in place so
consumers, if they do call.... We really don't see an
enormous amount of concern at all, but if we do, we
facilitate that with the financial institution or the
Mr. Ken Epp: Okay.
Mr. Marc-André Lacombe (Corporate Secretary and
Legal Counsel, Interac Association): If I may, I think
it's very important to understand that Interac
Association is not involved with the consumer in any
way. The services are really provided by the financial
institution to the cardholder. So you have an account
with one financial institution. The Interac services
are provided to you by the association. Our role is
simply to facilitate the transaction, to make sure that
when Bank of Montreal receives a card from CS CO-OP,
they know where to send the message so that CS CO-OP
can check that the money is in the account. We're not
involved in any way as part of this transaction. We
set the type of messages, and we make sure that the
service is uniform. Consumers will sometimes call the
office, and all we can do, since we can't help the
consumer, because we're not involved in the
transaction, is refer them to their financial
Mr. Ken Epp: You mentioned something about there
being huge costs. That's another thing I don't quite
understand. So there are more regulatory costs? So you
have to go to the minister? What is the source of
these huge costs that you're predicting both for your
association and for the government?
Ms. Judith Wolfson: From the government's
perspective first, reviewing a myriad of regulations
that don't have a specific interest in the concern at
hand is a costly bureaucratic process. From our
perspective, as I said, we sometimes deal with issues
very quickly. We certainly want to have the
flexibility to do that, should the marketplace need it.
To have to go through a process of consultation with
the government on a host of regulations that really
don't have any bearing on the issue at hand is a costly
process. It involves the discussions, the
consultation, the waiting periods—that's expensive.
Mr. Ken Epp: Would it be fair to say the summary
of this part is, you don't mind meeting certain
standards involved, but you don't want the government
involved in the details of how you achieve those
objectives? Would that be a fair summarization?
Ms. Judith Wolfson: Not quite. I think a fair
characterization would be, if the government has a
concern, and the government expresses what the concern
is and gives us an opportunity to remedy it, and then
feels it isn't appropriate and wishes to regulate it, I
don't have a difficulty. I hope we never get there,
but I would understand the government's wanting to have
involvement in scoping out those regulations and
understanding. It's in all the other areas where there
isn't an expressed concern that you have a carte
blanche, and it does not make sense to me. It's not
good, efficient, and effective regulation.
Mr. Ken Epp: Okay. One more quick one, Mr.
Chairman, if I may.
I'm curious with respect to the objections you have to
clause 244. I wonder whether you can give us an
indication of the effect this might have on other
businesses. Would there be an effect on businesses
other than your own members', and if so, what would
that effect be?
Ms. Judith Wolfson: It applies to other payment
systems as well. I really could not speak to an impact
on other businesses.
Mr. Ken Epp: Would there be an indirect cost, for
Ms. Judith Wolfson: There's an indirect cost, of
course, to all the membership, the membership of 91 and
growing, which are not—
Mr. Ken Epp: And passed on to businesses they
Ms. Judith Wolfson: Absolutely. There's no
question that the inefficiencies and the costs....
Switch fees are based on the costs of running a system,
so of course that would be translated into the broad
Mr. Ken Epp: Good. Thank you.
The Chair: Thank you, Mr. Epp.
Ms. Pauline Picard (Drummond, BQ): If I understood correctly,
the Interac Association in a networking association among the
various banking institutions. I have some trouble understanding how
you can ensure the protection of consumers while according to what
you said earlier, the Interac Association is an association of
financial institutions and not of card users. So, what is your
mandate with regard to card users?
Secondly, you also referred to regulatory duplication. You
talked about confusion among organizations, federal and provincial
institutions, and overlap, on several occasions. Can you give us
some examples of this type of duplication or confusion that might
arise if we did not amend clause 244 of the bill? I really don't
see what you mean when you say that you are only a networking
Ms. Judith Wolfson: Thank you for the question.
Let me deal with the second question first, if I was
It is not our position that there is overlap between
federal and provincial legislation. There is no effect
from provincial legislation at all. It is overlap
between the new protection under this proposed piece of
legislation and the Competition Act, which already
governs, and the Payment Clearing and Settlement Act,
which already governs. So safety and soundness are
taken care of in a present piece of legislation,
competition is taken care of in a present piece of
legislation—which has worked extremely well in this
regard—and it is just the area of consumer protection
that is not presently governed in legislation. So our
view was that we should limit the oversight of private
payment systems to consumer protection, since it isn't
governed by legislation.
I understand the government's interest in not
narrowing the scope. It is our view that if the
government doesn't wish to narrow the scope, there is
duplication, but at least we can make sure that the
processes then are clear and transparent, should the
government wish to designate. So that's that piece.
There isn't an overlap between provincial and federal
With regard to the first question on consumer
protection, we are the network that allows a
distributed architecture, if you will, that allows all
these organizations involved in shared cash dispensing,
the ABMs, or debit to talk to one another and make sure
those transactions go through. We're the hub, if you
The relationship for cardholders is between them and
their financial institution. That's where the
relationship to the consumer really belongs. We do
have a role in consumer protection. We have a very
significant role in security. What are the standards
for those machines? What should be the regulations in
regard to information and disclosure on the machines?
For instance, one of the regulations we have just
passed concerns what should be the language on the PIN
pads for surcharge disclosure. The size, the language,
making sure consumers understand and are clear, that's
our role. Or there is security, making sure we have
standards everyone has to comply with, telling the
world they are a secure and safe network.
We are, if you will, a clearing house, but the
relationship between the consumer and the financial
institution is theirs alone.
The Chair: Mr. Cullen, followed by Ms. Guarnieri,
then we'll go to Mr. Brison.
Mr. Roy Cullen (Etobicoke North, Lib.): Thank
you very much, Mr. Chairman.
Thank you, Ms. Wolfson, Mr. Lacombe, Mr. Morris. Good
to see you again.
I think you'd admit that while it may be burdensome
from time to time, the fact that you've been here has
resulted in some change between Bill C-38 and Bill C-8,
maybe not in exactly the way you would have asked for,
but it seems to me that in Bill C-8 now.... There was
some confusion—I don't know if it was from you—but
the oversight regime that could have applied under part
two has been clarified. I don't know if that was a
concern of yours, but the consultation with the
participants and the manager now has been incorporated
into Bill C-8. So it's not just one side of the coin,
and there's more consultation reflected, I think, in
Bill C-8 now. As you've said, it doesn't go as far as
you would like.
I'd like to step back a moment, and address the
payment system. I think you'd probably agree this is a
pretty important part of our whole financial structure
in Canada, and indeed internationally. I think you're
saying you'd like to see the minister involved only
with respect to consumer protection. But is there not
also a role the minister and the Government of Canada
would have with respect to prudential matters relating
to the payment system and efficiency issues? Or do you
see it strictly limited to consumer protection? And
what would your rationale be for limiting it to
Ms. Judith Wolfson: Thanks, Mr. Cullen. I'll try to
be as clear as I can.
I think it is very appropriate for the government to
be concerned about consumer protection, safety and
soundness, and competition—all three. Interac
Association is already governed in respect of its
safety and soundness and its competition by other
pieces of legislation. Consumer protection is not
presently governed, and that's why it was our position
that this piece of legislation should be narrowed in
We have had discussions with the government over the
past number of months. We understand it is the view of
the government that it should not be narrowed. It
doesn't make sense for us to have the duplication, but
we can live with it, as long as the processes for
designation and consultation are clear and transparent.
The difficulty is that this bill still doesn't achieve
that. It talks in very vague language about
consultation, in terms of involving the members as
well, but it puts absolutely no boundaries on the areas
of concern. It doesn't create the possibility of
saying, this is what we're worried about, go and fix
it. So you don't have an opportunity to remedy.
Do I think the government of the day is going to come
in, depending on someone's mood, and say, today we're
going to designate? Of course not; that doesn't make
sense. However, there should be in legislation
provision for clear, precise discussion in the
marketplace, so that there's certainty about this
sequence: if there's a problem, we'll tell you what the
problem is, go and fix it; if you don't, we'll
regulate—and then we'll regulate on that area. That's
the precision that I think makes good legislation and
allows the marketplace to operate with certainty and
Mr. Roy Cullen: One of the challenges, as I think
you'd probably appreciate, is that the payment systems
are evolving and changing so rapidly. We don't really
know exactly the shape or form all of them are going to
take. We have things like smart cards. We have a
whole host of other things. My understanding is, the
way the act has been clarified, if there were going to
be a designation, there would be consultation with both
the manager and the participants. So surely, if there
were some concerns, they'd be on the table. Are you
saying that this would be a big mystery to everybody?
Ms. Judith Wolfson: I'm saying there's no clear
statement in the legislation that the government has to
articulate a specific public interest concern, there is
no opportunity in the legislation to address that
concern, and there's no process that is transparent and
clear, a process for Governor in Council to regulate a
specific area. It's hugely unclear what that process
is. I think the clarity would be very helpful.
Mr. Roy Cullen: My understanding is that the
manager and the participants would be consulted, so
that there would be an opportunity for exchange of
views. I guess what you're pointing out is the need
for clarity in the guidelines as to what would
constitute a public interest concern. But as I say,
one of the challenges is not knowing exactly how
payment systems are going to evolve.
As to these rules and regulations, as I understand it,
the regulations or new rules would be submitted to the
minister within 10 days. A new rule comes into force
30 days after. The kinds of items you referred to—the
colour of the button, etc., etc.—I expect would
not be of concern to the minister unless they raised
other issues. They would go through normally.
So there's notice that in the
absence of word from the minister, they become rules.
What are the kinds of rule changes, then, you believe
the government might be concerned about? Are you
saying that the rule changes would all be in the kind
of category that you described? Or could you describe
other rules that would be more substantive and of
relevance in terms of public interest?
Ms. Judith Wolfson: Let me perhaps work backwards.
I do think having a system where you submit all rules
and regulations to the government, but do not know what
their real concern is, is not an efficient way of
running a business. If the government is concerned
about a specific public interest issue in the payment
system, they should tell us what it is and give us the
opportunity to address it. To have a response that
says, show us everything, and we'll decide at some
point if we're interested in it or not, isn't an
efficient way of running a business. Let me give you
an example of the kind of rules—
Mr. Roy Cullen: How would you filter what you send
to the government regarding rule changes and what you
Ms. Judith Wolfson: If the government is concerned
about a specific area, we suggest it should be speaking
to the private payment system as follows. We are
worried about tampering, security with machines and the
kind of regulations you might have in that regard.
We're going to designate and go through the
consultation process. We don't think you are properly
protecting consumers. You haven't convinced us. We're
going to regulate—I'm giving you the worse case
scenario; I don't think that would happen, but let's
assume. Then share with us all the rules and
regulations that have to do with this particular
Marc-André can help me. We have I don't know how many
regulations and rules that we change constantly. That
is, in my view, not the most efficient way for
government to run its business. First, if they're not
interested in it and it has nothing to do with them,
why is the government going to have a process to review
those rules? That doesn't make sense.
Mr. Roy Cullen: Given the evolving nature of the
payment system, given the changes going on, how would
the government know in advance that a rule change would
be inconsequential? Who's going to filter that?
Ms. Judith Wolfson: Right.
Mr. Roy Cullen: Initially, there's a learning
mechanism going on here.
Ms. Judith Wolfson: Sure. The government, from my
understanding, has no intention of running this
business. Even with the legislation as written, the
government has no intention of taking over and running
the private payment systems. They will have to assume
that the membership, the businesses, want this to
operate efficiently, effectively, and in the best
interest of the public. Otherwise, the public wouldn't
have the confidence it has.
So at the present time there has been no indication
from anybody that this system doesn't work in a
phenomenally excellent manner. It is the best in the
world. The government is saying they're worried about
having the power, should there be a consumer protection
issue—or safety and soundness, although that's already
taken care of. Let's just narrow it, for the sake of
discussion, to consumer protection. The government
wants the ability to come in. How are they going to do
that? They're going to do it the way they are going to
deal with everything else they're looking at in the
financial service sector. They're going to have
policy. They're going to look at that.
There's no way, no matter what the breadth of the
legislation, I can see the government looking at each
and every regulation. So define your area of concern,
and then allow for consultation in that area of
concern. That's all we're saying. That way, we will
all concentrate on what seems to be at risk, if
anything at all, rather than placing no onus at all on
government to say, this is what we're worried about.
It is extremely expensive and inefficient for
government legislation to have such gaps in
Let me, if I may, give one more example. The
association has just invested a lot of money, certainly
well over $10 million, in making the system more
robust, because we don't know how many transactions are
going to be there in the future. That's been a
significant investment. That kind of investment comes
with clarity, certainty.
We're not trying to say you should avoid placing a
consumer protection duty on the government—of course
the government has that obligation—but we're asking
that it be done in a way that tells people what you're
worried about and gives them open, clear, transparent
process. That's our point.
Mr. Roy Cullen: A point you've made before I found
more compelling, and that is, if you are looking at
forming strategic alliances with other payment systems
around the world, they would be looking for clarity.
You may understand the rules—
Ms. Judith Wolfson: Absolutely.
Mr. Roy Cullen: I find that a reasonably
compelling argument, except that everywhere in the
world countries are wrestling with the same kinds of
issues we have here. The payment system is evolving.
We have smart cards. We have debit cards. It's
changing so rapidly. We're in fact opening up the
payment system, as you know, to insurance companies,
Ms. Judith Wolfson: Absolutely.
Mr. Roy Cullen: So while a potential strategic
partner in Europe, for example, might like to
have more clarity in the rules, I expect in their own
countries they'd have similar lack of clarity, for want
of a better term. So world-wide, we're probably all
wrestling with similar kinds of issues. Are you saying
that in other countries, say in Europe or South America
or in the United States, the rules are clearer and that
a potential partner might say to you, “Here's it's as
clear as glass. Why isn't it clear up there?”
Ms. Judith Wolfson: I am not an expert on every
other payment system, although we have significant
experience with many. But there is no system I am aware
of where the management of the business is regulated to
that specific level by government.
I think what we need is an ability to change with the
marketplace. It is evolving enormously, and I
understand that balance between what we don't know and
what we need to know. Chip cards represent another
activity, smart cards—we're involved in this as we
speak. Provincial governments are involved in smart
card initiatives. Will you be able to piggyback for
efficiency, will consumers be able to have one card at
some point, not a myriad in the wallet? Every single
retailer you go into is giving you yet another card,
and loyalty goes with it.
We don't really know what the system will be. I think
for the marketplace it's really important to have the
ability to grow, not to be inhibited by rules that are
ineffective and costly, yet to have proper rules that
deal with safety and soundness, competition, and
consumer protection. That makes a lot of sense. Our
view is that you should address the issues that are
really there, not clutter it with issues that may not
be there, creating costs and, thereby, the reluctance
of the private sector to continue to invest in a system
that works and has to work very quickly.
I think the way we've structured the proposed
amendments deprives the government of no ability;
there's absolutely no obstacle to coming in if there's
a concern. Just tell us what it is, and if we can't
fix it, regulate it openly and transparently. That's
Mr. Marc-André Lacombe: I think it's also
important to realize that our concerns are not with the
regulation of the whole payment system, only with these
other payment networks. We know the bill contains a
lot of regulations regarding the Canadian Payments
Association, and when we talk about the payment system
and regulation, that's where it is regulated.
It's also important to note that we are not involved in
the settlement in any way, shape, or form. All of our
transactions are transactions that get settled through
the Canadian Payments Association.
So a lot of the concerns are already dealt with at the
payment system level. What we're talking about are
those payment systems that were deemed to not fall
within the scope of the CPA and were allowed to
develop outside of the CPA. Those are different.
The Chair: Ms. Guarnieri.
Ms. Albina Guarnieri (Mississauga East, Lib.):
I must confess that I'm certainly one of those
Canadians who uses her debit card excessively.
Ms. Judith Wolfson: And we're grateful.
Ms. Albina Guarnieri: I hope my husband doesn't
hear this testimony.
Certainly I think most Canadians will agree that it's
a big advantage, especially at grocery stores that
don't use credit cards.
Would I be correct in saying that Interac is
essentially a monopoly in the business of selling
access to their customer accounts? And just to give me
a clearer understanding of your business, could you
give me a breakdown of the costs associated with the
debit service of the retail outlet?
You mentioned earlier that you've just invested $10
million into your business. Who supplies the
equipment, the card swipe machines? What does the
retailer pay for the service, and what is the
retailer's cost for a transaction? Can you give me
some idea about what the consumer pays for a
Ms. Judith Wolfson: The answer is no, I can't, and
the reason I can't is that's not the business of
The investment I was referring to is in the—
Ms. Albina Guarnieri: The security aspects.
Ms. Judith Wolfson: —the inter-member network
software that allows the shared cash dispensing and the
shared Interac direct payment. That is our business.
The costs and the investment were to ensure that we
have the newest and the best software to make sure that
network is robust. The retailer costs and the fees are
absolutely not within our purview, nor do I know them.
They are the purview of the financial institution and
its customers—be they retailers or cardholders—and
that is an issue that is negotiated in the marketplace.
I think that's the best answer I can give you.
Ms. Albina Guarnieri: You can't give me a ballpark
figure of what you would charge for the business of
providing the service to a consumer?
Ms. Judith Wolfson: We don't charge a fee. What
we have are switch fees. The switch fees are based on
the total cost of the system, and they are then
attributed on a per-transaction basis to the members,
depending on how many transactions they have. We've
supplied you with a list of the membership, which is
only probably current to this week—I'm not sure about
next week. Some newer members may have fewer
transactions than others, so it's based on a switch fee
Ms. Albina Guarnieri: Are you essentially a
monopoly? Would that be a fair statement?
Ms. Judith Wolfson: No.
Marc-André, why don't you take that one?
Mr. Marc-André Lacombe: The fee
that the members pay us is a very small portion of the
cost of providing the service. The service includes
terminals at the merchant, it includes banking machines
all over Canada—we now have 32,000—and also it
includes systems at the vendors so that these
systems can process transactions and verify accounts.
Our system is a very tiny part in all of this. The
services are really services.... When you wanted your
debit card, you went to your financial institution and
they gave you a series of packages: you can pay so much
a month and you get that many transactions, or you pay
per transaction. There's a wide variety of fees at
various institutions, and it's the same thing on the
retailer side. I think we have fourteen different
members that provide the service directly to retailers,
and the services depend on the pricing policies of each
member. Because of the Competition Act, we are
prohibited by law from discussing any of these fees.
Ms. Albina Guarnieri: Do you supply the machines?
Ms. Judith Wolfson: No, the machines
are supplied by various members or folks who are in
relationships with them.
Ms. Albina Guarnieri: Where do you see competition
making sense, given the business structure that you
Ms. Judith Wolfson: I'm sorry, but I don't
understand the question.
Ms. Albina Guarnieri: Well, if you're a consumer
or you're a local retailer, let's say you didn't want
to use Interac. What would be the other alternative
that you would have?
Ms. Judith Wolfson: A retailer could provide a
number of ways of payment.
Ms. Albina Guarnieri: If you didn't want to go
through Interac to buy the service....
Ms. Judith Wolfson: For what service? For debit
Ms. Albina Guarnieri: Yes, for debit cards.
Ms. Judith Wolfson: In Canada, as I say, through
the consent order that was reached with the
Competition Bureau, the system that was set up
was, if you will, an infrastructure, a highway. It was
agreed that the highway would be a
On that highway, there are all kinds of
folks who have decided what kind of vehicle they will
use. We now have merchants who have decided to operate
their own vehicle on that highway, and more merchants
can, should they wish to do so.
We have financial institutions, we have third-party
processors, we have technology companies, we have
telecom. They can come in and say they want to use the
highway, and there is no differentiated cost. They can
use it on a cost-recovery basis and create their own
vehicle on that highway, depending on what the business
Ms. Albina Guarnieri: One last question: You
mentioned you're interested in obtaining the right
balance in the process for designation and consultation
with the government. You said you wanted simple,
well-defined steps, and you referred to the timeframe.
You requested a reasonable period of time, if I'm not
Ms. Judith Wolfson: Correct.
Ms. Albina Guarnieri: What would you consider to
be a reasonable timeframe?
Ms. Judith Wolfson: When we were meeting with the
secretary of state and I think he agreed that perhaps
it was a process that designated what was
reasonable—an open transparent process—he said, “All
right, you'll have seven days”. I think his tongue
was in his cheek at that point. I'm not sure exactly
what “reasonable” is. I think initial responses
depend on the complexity of the issue. It may well be
that a primary response is thirty days. We have all
kinds of timeframes and regulations.
I think you need to have flexibility, depending on the
complexity of the issue, so perhaps it would be an
initial response within thirty days, and then it would
be agreed upon depending on the complexity of the
issue. On certain issues it might be very simple, and
on others you may need to study it. So I think a hard
and fast rule is very difficult, but you need to have a
floor perhaps, and perhaps thirty days for an initial
response is an appropriate one.
Ms. Albina Guarnieri: Thank you.
The Chair: Thanks, Ms. Guarnieri.
We'll have two final questioners, Mr. Brison and Mr.
Mr. Scott Brison (Kings—Hants, PC): Thank you,
Mr. Chairman. I apologize for not having been here for
the whole presentation, but I had an industry committee
meeting at the same time.
The first question I have is relative to full
functionality of the Interac system. One of the MacKay
task force recommendations was in the interests of
creating a better environment for competition,
particularly in facilitating the entry of smaller
players in banking. It was also recommended that the
government investigate and move forward with a full
functionality of the Interac system.
I understand that with the technology, it's possible
now to effectively deposit to your branch through any
Interac machine, regardless of whether you're at
the same bank or your home bank's Interac machine. The
prohibition from doing it is a policy issue, as opposed
to a technological barrier. I would like your feedback
on why that's so, and on what the downside is to that,
and also from an upside perspective. It's clearer from
a competition perspective that it would be beneficial,
but what's the downside to moving to full functionality
of the Interac system?
Ms. Judith Wolfson: We have had extensive
discussion on that issue about our functionality.
There is no technical solution. It would have to be
created. Could one find a technical solution? I
believe one can generally find a technical solution to
anything, given enough time, enough resources, and the
need. There isn't one at this point in time.
The issues were what is the need and what is the cost.
We did extensive research and we shared that with the
government. There was not sufficient interest to make
a business case. The ones who were purportedly the
most interested were the ones where the cost would not
be borne primarily. Our continous consumer research
did not show a supportive business case where folks
were prepared to pay the costs and whatever fees would
be there in order to do the shared functionality. As a
matter of fact, consumer interest went down in the
recent research, and we shared that with the Department
of Finance. The business case was not there.
At present there isn't a technology fix, but
that isn't reasonably the barrier.
Mr. Scott Brison: I'd like to have your
information or your documentation on that. It would be
helpful. Intuitively it would make a significant
difference from a competitiveness perspective for
smaller players, if full functionality would be a big
step in that regard.
Your recommendations in terms of the transparent
process seem at first glance to be quite reasonable.
One of the difficulties with regulations, or public
policy in general, is often we develop these things
dealing with perceptions as opposed to realities. This
would at least ensure that if the government were
interested in providing a public good through some
regulatory mechanism, then it would at least be
defined. It makes sense. I suppose we'll be
discussing it further, but at first glance it seems to
One specific consumer protection issue is that
increasingly merchants seem to be—this is somewhat
anecdotal—taking the debit cards and swiping them, as
opposed to the consumer doing this directly. Is there a
policy or an initiative you're pursuing to address
some of that? It seems to me to be a bit of a security
issue that is evolving.
Ms. Judith Wolfson: It's a really interesting
issue and it is of increasing concern to us and is
something, as a matter of fact,
we have been dealing with
very currently. I'm sure you all read increasing media
reports, particularly in the gas station sector, where
there were skimming issues and consumers were concerned
about double swiping. You'll see that in many of the
gas stations, particularly in the GTO area, there are
consumer self-swipe devices.
It is something we're looking at. We're looking at
our rules to talk about the ability for a consumer to
swipe. How do you avoid double swiping? The issue, as
well, is what kind of certification of devices should
be in place. It's something, as a matter of fact, that
Kirkland is gainfully employed reviewing right at this
time. I think consumer confidence is important and
there are rules right now.
For instance, you aren't allowed to affix your PIN
pad. You can't have it where the consumer can't take
the PIN pad and ensure they can protect their PIN.
We have those kinds of rules, but
we're looking at it right now to make sure that in
particular sectors that's going to be affixed.
The other area, of course, is in mobile technology.
That's an increasing interest, where the PIN pads will
be far more mobile and use mobile technology, so in
pizza delivery or at your table in restaurants you will
be able to swipe your card yourself. That's happening.
Of course, the investment is significant when you
change those technologies, and we're actively looking
Mr. Scott Brison: Okay. The whole evolution of
wireless technology is going to have significant
impacts, and of course security issues are included.
For example, e-plicity is a Halifax-based company
that's doing work with the taxi companies in Montreal.
It's very interesting.
That's all I had, Mr. Chair, except for the ongoing
inequity we have all experienced at times with our
payment systems. I don't know whether there is a way
to address it, but it seems to me blatantly unfair that
the only people who can withdraw money from their
accounts using bank cards are those people with money
in those accounts. And if there's something that can
be done and if it's within your purview—
Ms. Judith Wolfson: Absolutely. I'll refer that
to the legislators.
Mr. Scott Brison: —it would make a huge
difference in the quality of life of all Canadians,
the people we represent in this place.
The Chair: I hope your amendment is adopted,
Mr. Scott Brison: Thanks.
The Chair: Thank you.
Ms. Judith Wolfson: Thank you.
The Chair: Just for the record, that was not
Mr. Ken Epp: That's right, Mr. Chairman. I've
often thought, even when I was speaking in the House,
that Hansard does not express the tone of sarcasm.
I have a couple of questions more. One concerns the
fact that you indicate you'd like more transparency.
Now, I can't imagine that you really want to have the
kind of transparency where, when a consumer out there
issued a complaint, it would instantly hit the wires.
That would undoubtedly tend to reduce the confidence in
your system, which I frankly think is very high right
now. As a member of Parliament, I have had very, very
few people come into my office to say that they have
concerns about their payment system. We've had some
complaints about the banks, some about the way they're
charging fees, and things like that. What do you mean,
therefore, when you say that you want this to be
Ms. Judith Wolfson: Very simply put, we want to
know from the government what a specific problem is. If
there's a problem, we want to have an opportunity to
rectify it. Then, if the government decides to
designate this a private payment system, we want it to
go through the Governor-in-Council process, so there's
an opportunity to look at the regulations and have good
debate prior to the industry being designated or
Mr. Ken Epp: In other words, when you use the word
“transparency”, you mean transparency for you, so you
don't have government officials sitting in a back room
somewhere concocting things and you don't really
understand what they're doing. You're not talking
about transparency for the public.
Ms. Judith Wolfson: No. I'm talking about a
transparent, open process of legislation.
Mr. Ken Epp: Okay. I have a second question
related to the same thing. The way I read your brief,
you're saying that when the minister becomes aware of
problems, the minister should only take action after
talking to you.
Ms. Judith Wolfson: Yes.
Mr. Ken Epp: Wouldn't your system make it too
late? Whenever I write a minister, it usually takes
about six months to get an answer. I would think that
you should rather be pressing for some sort of
requirement that, if the minister should learn of a
problem, he or she inform you of it within the hour so
you can start working on it.
Ms. Judith Wolfson: Mr. Epp, this business has
become as successful as it has because for all the
participants and the members, this is their livelihood.
The only way they can survive and grow is with consumer
Mr. Ken Epp: And if they do it right.
Ms. Judith Wolfson: The minute there isn't
consumer confidence, you won't have a system that
works. We're not waiting for anybody in government to
tell us what the issues are. We are constantly,
constantly vigilant, and believe me, the media would
keep us constantly vigilant even if we weren't inclined
to be so.
What we are saying is that the government, within
its legislative responsibility, shouldn't use a shotgun
approach, hitting and regulating segments of the
industry haphazardly. Tell us what the problems are,
and we'll fix them. If we don't because there's a
concern or a legitimate disagreement and the
government feels a certain action is in the public
interest, it's the job of government to protect the
Mr. Ken Epp: Is it your evaluation that if there
were a problem, you would be aware of it before it got
to the minister?
Ms. Judith Wolfson: I would be shocked if there
were a problem that came to the government before we
knew about it.
Mr. Ken Epp: Yes, that would be my impression as
Ms. Judith Wolfson: We wouldn't be in business
very long if that happened.
Mr. Ken Epp: Okay. I have one last question, Mr.
Chairman, and that is whether in your view this
legislation adequately anticipates changes in payment
systems. Right now you have these cash-dispensing
machines. I really do expect that within a very short
time—I'm not ready to predict a timeline, whether it's
five years, ten, or whatever—they will be obsolete. In
five to ten years or thereabouts we will no longer have
wallets full of folding money, full of Canadian
Ms. Judith Wolfson: Sure.
Mr. Ken Epp: Rather, we will have some sort of
smart card, and we will be transferring money to a
little smart card instead of transferring paper into
Are you anticipating this as an industry? Have you
given any study as to whether Bill C-8 anticipates
this, or is everything already covered?
Ms. Judith Wolfson: Firstly, I absolutely agree
with you. I think that the role of cash in our society
is changing enormously quickly. As a matter of fact,
our newest research, which was in the press not two
months ago, talked about the fact that in the
perception of Canadians their cash has now been
superseded by plastic. The use of cash and paper is
rapidly declining, so what you say is absolutely true.
What do I see? We all would like to be able to look
into crystal balls. There is no question that we will
look at other payment mechanisms. Payment on the web
is also going to be an extremely interesting new
development. As to cross-border exchanges, the web is
not restricted to operating within the borders of
Canada. Purchasing doesn't stay within Canada. We are
looking at the kinds of issues that will happen in a
web-based economy. Does this bill address that? I'm
just not familiar enough with all aspects, but I think
that in terms of this particular part and our role,
this gives flexibility to the government to be able to
involve itself where necessary.
Mr. Ken Epp: What I'm driving at here is—
The Chair: What is your definition of “final
Some hon. members: Oh, oh.
Mr. Ken Epp: I guess it's whenever the chairman
finally interrupts me and tells me I'm done.
The Chair: I'm sorry about that, but—
Mr. Ken Epp: But I'm still on the same question.
The Chair: Oh, are you? Okay.
Mr. Ken Epp: You see, if I lose my wallet, whoever
finds it has access to $25 cash. They do not have
access to my bank account with its thousands of dollars
Ms. Judith Wolfson: That's right.
Mr. Ken Epp: They're limited. Now, if I have a
cash card, I do not want that cash card to be connected
to my bank account. I want to be able to transfer $50
to that card. If I lose that card, whoever picks it up
can spend $50 and they're done, that's it.
Ms. Judith Wolfson: And that's what you have when
you have that card because you're protected by a PIN.
Mr. Ken Epp: Okay, but are you anticipating this
new technology, and are you doing research into it?
Specifically, should there be anything in this bill on
that issue, or do you think that's for another time?
Ms. Judith Wolfson: Yes. Firstly, I don't think
that in this piece of legislation we should be
addressing any specifics that we don't know enough
about. In terms of what we are doing about it, there
is nothing we can conceive of that would not allow for
protection, at least in terms of what we have at this
time. Future chip technology will add more protection,
not less. I absolutely agree with you. The only card
that might have the same lack of protection that cash
has would be a stored-value card like a Bell telephone
card, where you can put in a certain amount, say
$10, or like a card for vending machines. You might
not have that same kind of protection. I see nothing
in the future that wouldn't allow you at least the kind
of protection we have today.
Mr. Ken Epp: Mr. Chair, that's my final question.
The Chair: I won't take that as a draft.
Mr. Ken Epp: Oh yes, you're next.
The Chair: Ms. Bennett, do you want to follow up
on Mr. Brison's point?
Ms. Carolyn Bennett (St. Paul's, Lib.): Thank you,
I do want to follow up on Mr. Brison's point. In
fact, I've been stewing about this since the last time
Ms. Wolfson came before our committee.
You have a
bunch of members. Do you have a board?
Ms. Judith Wolfson: Sure.
Ms. Carolyn Bennett: Who is on the board?
Ms. Judith Wolfson: The board is set up pursuant
to the consent order. The board is made up of a number
of direct connectors, financial institutions, small
players, white label players—
Ms. Carolyn Bennett: Being able to make deposits
at all of the machines is something seniors and the
more vulnerable population have been very concerned
about. They say, “They closed the branch next to me,
there's a machine here, but the next machine is a
long way away from my institution. How come I can't
deposit my cheque into the machine that's right next to
me?” When I asked Mr. Brison's question the last time you
appeared, you said it wasn't in the business
plan. You also forecasted that there maybe wouldn't be
cash or cheques one day. But I wasn't sure we
could actually go there, in that these people are still
worried about this.
If I have my money in a credit union or all of that
and I would like my clients to be able to deposit at
the Royal Bank, how do we make sure it isn't the big
institutions that are making these decisions rather
than the small institutions in terms of protecting the
This comes to your point of in so many aspects of
government we are stuck with a complaint basis. In
terms of you wanting this scoped down more narrowly on
a needs-to-know basis with regard to your regulations and all of
that.... If there were people in the Department of
Finance who could read your regulations and go, eureka,
I don't think this is good for consumers, can you...?
It's very difficult if you are asking government to
wait until there's a problem to then request the set of
regulations from your company based on that problem, as
opposed to looking at all the changes and maybe being
able to pre-empt something that isn't in the best
interests of Canadians.
Those are my concerns based on your
suggested amendment. We want to
know how decisions are made in your organization to
make sure that smaller companies and
consumers.... I'm worried it's just a bottom-line
kind of decision.
Ms. Judith Wolfson: Let me address it absolutely
directly, Dr. Bennett.
Firstly, just off the top,
nothing prevents the Department of Finance from talking
to us at any time about any concerns, and you don't
need a regulation in order to do that. Having been a
deputy minister in the Government of Ontario for many
years, we didn't wait for regulations in order to go
and deal with the industry in many areas and talk about
what was happening and consumer interests. It is
in the interests of this organization that it respond
to consumer interests, or it wouldn't be in business.
Let me address how decisions are made. It is set
up pursuant to a consent order with the Competition
Tribunal. As a matter of fact, if I'm correct—and
Marc-André, who's our corporate secretary and legal
counsel, will correct me if I'm wrong—the major large
financial institutions are no longer the majority on
the board. We have, in addition to the Bank of
Montreal, CIBC; Laurentian Bank of Canada; Royal
Bank; Scotiabank; TD Bank, including Canada Trust;
caisses populaires; and Credit Union Central of
Canada. There are equal votes, by the way, on
the board for everyone. BCE Emergis Inc. is on the board.
CGI, which is a technology company that provides a lot of
the white label machines and does a lot of technology,
is on the board.
TCS (Canada) Ltd. is our newest board member. Its
president is a man called George Oliver. They are now
the third largest deployer of ABMs in the country. Is
Mr. Marc-André Lacombe: They're the largest.
Ms. Judith Wolfson: That's not one of the
largest financial institutions. This is a white
label.... It's a third of the ABMs, if I'm correct.
No, I'm not right. I don't know the number. Anyway,
he's our newest member on the board.
There is absolutely an opportunity for consumers who
are using different kinds of payment mechanisms,
technology companies, credit unions, the Caisse
Desjardins in Quebec, and the financial institutions
to be on the board. That's the structure.
Ms. Carolyn Bennett: So the smaller
institutions, and I mean deposit-taking organizations,
have an ability to outvote the big guys.
Ms. Judith Wolfson: I forgot to mention Sun Life
Financial Trust Inc.
There are certain resolutions that require a
two-thirds majority—that's all in the consent
order—and some that require a simple majority.
But the reality is that this is a very business-like
organization that looks at how we can grow this business
for the population of Canada. You wouldn't get the kind
of strength and robustness in the marketplace if you
didn't take those issues into account.
The Chair: Thank you, Dr. Bennett.
On behalf of the committee, I want to thank you very
much. I'm glad you've subscribed to season tickets to
the finance committee. Of course we'll look at the
points of view expressed as we head toward
clause-by-clause consideration sometime in the near
future. Thank you.
Ms. Judith Wolfson: Thank you.
We will make sure we lodge with you the specific
The Chair: Madame Picard.
Ms. Pauline Picard: This does not concern the witnesses. I
simply want to express an opinion on our notices of meeting.
Yesterday we received three, four or five notices of meeting with
different times. Some said nine o'clock and then others said eleven
o'clock. I have noticed this type of change a few times since last
week. It's very difficult for us; we have tight schedules and we
must sit on other committees, and it is difficult to make
appointments around the meetings of our own committees. I don't
know if the situation can be solved easily, but I find it very
awkward that a hearing is confirmed and then cancelled. I hope you
will be able to make the necessary change. I have not consulted my
colleagues, but everyone is somewhat disturbed by this way of doing
The Chair: I want to address that issue. We had a
striking meeting during which we elected the chair and
vice-chairs, and I gave out a timetable, which
everybody who was present actually agreed upon. Then
we proceeded to ask witnesses when they would like to
appear. Interac was the only one that wanted to appear
this week. We allocated two weeks for initial
hearings, anyway. Most of the people wanted to appear
the week after the parliamentary break. Days were
allotted to hear witnesses, but the only one that said
yes for this week was Interac.
I hope that clarifies
your situation. It's a situation that not only you
have to go through but I have to go through as
Mr. Ken Epp: Mr. Chairman, you might want to
dismiss our witnesses, since we're no longer dealing
I have a question with regard to
Madame Picard's comments.
The Chair: Sure. Thank you.
Mr. Ken Epp: Are we going to have a planning
The Chair: Yes, we are.
Mr. Ken Epp: We haven't struck that yet.
The Chair: Actually, we have,
but we don't have a date for the first meeting.
Mr. Ken Epp: When did that happen?
The Chair: That happened on the first—
Mr. Ken Epp: When I was sleeping. I seem to have
missed a lot that day.
The Chair: We do have a steering committee. We
dealt with that the day we—
Mr. Ken Epp: Has that steering committee
The Chair: No, it has not met.
Mr. Ken Epp: So we're just going ahead on
the basis of straight, practical.... I have no objection
The Chair: Yes. What we would have to deal with
as a steering committee would be future business, but
because we already had done some preliminary work on
scheduling, we had the entire committee agree to the
schedule. So de facto they were the steering
Mr. Ken Epp: Okay. Just for my interest, who is
on the subcommittee?
The Chair: Myself, and there's a representative
from every party, obviously.
Mr. Ken Epp: There is?
The Chair: Yes.
The Clerk of the Committee: Mr. Chair,
it's in the motion. It
includes the chair, the two vice-chairs, a
representative from every other party, and one of the
The Chair: Yes, one of the parliamentary
secretaries, because we have two parliamentary
Mr. Ken Epp: So do you know who it is for our
The Clerk: It's whoever comes. No one is named.
You have to arrange it among yourselves.
Mr. Ken Epp: Okay.
The Chair: Okay? Great.
The meeting is adjourned. Thank you.