Article
Introduction
The CBA appreciates the opportunity to contribute to the government’s upcoming budget. Representing more than 60 domestic and foreign banks operating in Canada, the CBA advocates for policies that promote a sound, secure, and competitive banking.
Banks play a significant role in B.C.’s economy. In 2025, banks:
- Contributed approximately $9.4 billion to provincial GDP
- Paid nearly $500 million in provincial and municipal taxes
- Employed approximately 23,000 people
- Provided over $310 billion in residential mortgages and more than $248 billion in authorized business credit, including $44 billion to SMEs in B.C.
For more information, please visit cba.ca.
Recommendation 1 Explanation: Combatting frauds and scams
Financial crimes, including scams, identity theft, and account takeovers, pose a growing threat to Canadians. In 2025, reported fraud losses exceeded $704 million nationally ($90 million in B.C.), although actual losses are estimated to surpass $13 billion due to significant underreporting. Beyond the harm to victims, financial crime creates substantial economic costs and erodes trust in the financial system and digital economy. Fraud prevention and enforcement are investments in both public safety and economic resilience.
The CBA is collaborating with approximately 50 public and private sector partners through the Canadian Anti‑Scam Coalition (CASC), including regulators, financial institutions, telecommunications providers, law‑enforcement, and digital platforms, to advance coordinated education, awareness, and prevention initiatives. While these efforts are essential, effective enforcement and prosecution are equally critical to deter criminal activity by holding offenders accountable under the Criminal Code of Canada; preventing further victimization.
An effective strategy should centralize financial crimes reporting flows between the Canadian Anti‑Fraud Centre (CAFC) and law enforcement, strengthening intelligence‑sharing to support investigations. It should also balance personal information protections with organizations’ ability to detect and prevent financial crime, including through appropriate confidentiality safeguards for cross‑sector information sharing that support investigations.
To further support the fight against financial crimes, including anti‑money laundering and anti‑terrorist financing efforts, we urge continued collaboration with the federal government to strengthen Canada’s commitment to the corporate beneficial ownership transparency. Further, we encourage ongoing investments in B.C.’s enforcement and prosecution capacity, support the Financial Crimes Agency (FCA), to help strengthen Canada’s response to increasingly sophisticated criminal networks. A coordinated national approach will ensure effectiveness, reduce regulatory duplication, and minimize opportunities for legislative arbitrage across jurisdictions.
Fraud has evolved into a global, organized, and technologically enabled criminal economy that no single jurisdiction, sector, or stakeholder can address alone. Stronger global cooperation is increasingly necessary to combat fraud.
Recommendation 1: Combatting frauds and scams
- Centralize reporting between CAFC and law enforcement
- Support specialized career streams/resources to strengthen financial crimes expertise and complement FCA
- Coordinate multi‑sector efforts involving financial institutions, telecommunications, digital platforms
- Support federal anti‑fraud initiatives, public‑private information sharing, international coordination against sophisticated financial crimes
- Introduce a beneficial ownership registry aligned with federal rules/guidelines
Recommendation 2 Explanation: Reduce internal trade barriers for financial services
The CBA is encouraged by Canada’s momentum to reduce internal trade barriers, which the International Monetary Fund estimates are equivalent to an average annual tariff of nine per cent and largely concentrated in the services sector; undermining productivity, competitiveness, and economic resilience.
Fragmented regulatory regimes can also create inconsistent product offerings and reduce operational efficiencies for entities operating nationwide. In our view, the challenge is not a lack of competition, but rather a regulatory architecture that stifles scaling and innovation. The policy focus should therefore shift to modernizing regulatory frameworks through greater coordination across Canada.
To support this objective, and consistent with the Canada Free Trade Agreement, we recommend:
- Advancing federal‑provincial alignment on privacy definitions and requirements to ensure consistent obligations and rights nationwide; streamlined compliance; greater consumer access to innovative products and services (e.g., consumer‑driven banking, AI)
- Supporting the adoption of a federal framework for payment services providers engaged in bank‑like activities to ensure consistent compliance obligations and consumer protections
- Coordinating provincial approaches to over‑the‑counter (OTC) derivatives participation fees to prevent duplicative charges by multiple provincial securities regulators for the same transactions, preserve market liquidity, and maintain international competitiveness
- Collaborate with the federal government by having the B.C. Securities Commission coordinate with self‑regulatory organizations such as CIRO to advance a harmonized framework for account transfers, including modernized infrastructure and standardized transfer procedures and timelines across all institutions offering investment and registered accounts
- Update legislation to support amalgamations and asset purchase transactions between federal and provincial credit unions to enable economies of scale and risk diversification. Additionally, increase the financial transparency in the provincial credit union system
Recommendation 2: Reduce internal trade barriers for financial services
Reduce interprovincial regulatory frictions by:
- Harmonizing privacy requirements across the country
- Ensuring consistent consumer market conduct protections
- Coordinating OTC derivatives participation fees
- Harmonizing frameworks for account transfers
- Supporting credit union amalgamations and asset purchases as well as increasing financial transparency
Recommendation 3 Explanation: Restricted insurance agency regime
Banks are committed to meeting their customers’ needs by providing access to authorized insurance products in a manner that serves customers’ interests. Authorized insurance products are those prescribed under section 416 of the Bank Act in the Insurance Business (Banks and Bank Holding Companies) Regulations, including:
- Creditors’ disability insurance
- Creditors’ life insurance
- Creditors’ loss of employment insurance
- Creditors’ vehicle inventory insurance
- Export credit insurance
- Travel insurance
These optional insurance products are selected by consumers based on their individual needs and financial circumstances and can be especially beneficial for vulnerable consumers who may otherwise have limited access to more costly insurance options.
The Insurance Council of B.C.’s (Council) proposed requirements on training accreditations are overly prescriptive on distribution and may create unintended consequences to the distribution of these products. This could reduce consumer access to important protection products for vulnerable customers who may benefit most while increasing regulatory burden and compliance costs.
The CBA and its members strongly encourage the Council and B.C. Ministry of Finance to reconsider its approach and instead develop a principles‑based RIA proposal that is better aligned with existing regimes in Manitoba, Saskatchewan, Alberta, and New Brunswick. This would reduce unnecessary regulatory burden and cost while maintaining the Council’s strong consumer protection objectives.
Recommendation 3: Restricted insurance agency regime
Amend the current approach to the Restricted Insurance Agency (RIA) regime in order to develop a principles‑based, harmonized approach. Current proposals are overly prescriptive, increase regulatory compliance burden, allow insufficient timelines for training accreditation and implementation, and create uncertainty regarding banks’ continued ability to offer travel insurance.