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Opening remarks
Good evening. My name is Eric Prud’homme and I am the Director, Quebec and Atlantic Government Relations at the Canadian Bankers Association (CBA). I am joined by my colleague Christian Petit‑Frère – Senior Legal Counsel at the CBA. We appreciate the opportunity to appear again before this Committee today to discuss the draft regulations on the use of French in federally regulated private businesses (draft regulations).
The CBA is the voice of more than 60 domestic and foreign banks operating in Canada and their nearly 300,000 employees and it continues to provide governments and others with a centralized contact to all banks on matters relating to banking in Canada. The CBA advocates for public policies that contribute to a sound, thriving banking system to ensure Canadians can succeed in their financial goals. Consumers benefit from the high degree of competition and choice in the Canadian financial services marketplace. Of the more than 80 domestic and foreign banks operating in Canada, more than 40 offer financial products and services to retail customers, including bank accounts, credit cards, loans, and investments.
I would like to quickly mention that yesterday evening the CBA appeared before the Standing Senate Committee on Official Languages with similar considerations. You may note my opening remarks are similar, and that is because this is a topic of importance for the CBA and its members. We are glad to see this matter being studied extensively by both the House of Commons Committee and the Senate Committee.
We were pleased to see the tabling of the draft regulations in Parliament by the Minister of Canadian Identity and Culture and Minister responsible for Official Languages.
The CBA would like to reiterate that banks value the fundamental importance of Canada’s two official languages, working diligently to offer services to their customers across the country in their language of choice. Banks also recognize how vital it is that French speaking employees be able to work in French in workplaces located in predominantly francophone regions in Canada.
Banks’ ability to offer services in French in Quebec and in regions with strong francophone presence
Banks have a long‑standing commitment to meeting the language preferences of their customers. Canada’s largest banks already offer personalized customer service in French in and outside of Quebec where there is a demand for services in French, including in New Brunswick, and Eastern Ontario. Customers across Canada have access to customer service in French through telebanking centers and on banks’ online and web‑based platforms. Thanks to significant investments banks have made in technology, more than ever before, bank customers, including French speaking customers, have more choice and convenience when it comes to accessing financial products and services. These investments have greatly improved the way banks connect to and interact with their customers and how they operate internally. For instance, no matter where French‑speaking customers are located, they have access to certain bank documents in French.
Research shows that a majority of Canadians are using digital banking and banking apps and those technology advancements allow customers to bank regardless of where they are located in Canada. At the same time, traditional bank branches remain essential to Canada’s banking network, with a strong presence throughout rural and all kinds of communities, big and small.
Potential challenges with some of the requirements in the draft regulations
Although the banking sector has a strong record in offering products and services and employment in French both in Quebec and other regions throughout Canada, it is critical that organizations such as banks be given the flexibility to comply with the language requirements based on the nature, size and complexity of their business, distribution channels, and products and services. Small and medium‑sized banks may not have the resources that bigger banks may be able to deploy to meet certain requirements.
The banking sector understands the importance of creating well‑paying, high‑quality jobs in francophone communities, but the pool of skilled candidates needs to be available for organizations to hire them. Further, we note that some very small areas in some provinces were designated as regions with strong francophone presence, it may be even more challenging to find skilled candidates to fill roles in some areas. Consideration should be given as to whether in future reviews of the legislation, the threshold should be higher in designating a region as a region of strong francophone presence.
With regards to human resources, our members have taken note of the provisions regarding acquired rights in the enabling legislation and welcome this approach, while recommending that the concept of supervising a Francophone employee in a region with a strong Francophone presence be applied flexibly and in accordance with the specific circumstances of each situation. It is also critical that a considerable implementation period be given to adjust systems, provide training, hire additional staff, before the requirements come into force.
Thank you for the opportunity to deliver our remarks. The CBA looks forward to participating in the consultation regarding the draft regulations. We will be pleased to answer your questions.