From:	XXXX
Sent:	December-03-13 6:47 PM
To:	Consumer Code / Code consommateur
Subject:	Canada's Financial Consumer Protection Framework: Consultation Paper


As an independent accounting professional one concern I see through government 
policy is the future requirement by Canada Revenue Agency to require any tax filer to 
provide a recognized bank in Canada for any payment or benefit, and non-paper filing 
in 2014 (e-file or net-file only). In one sense I believe this is a good move to drive 
efficiency and taxpayer transparency. However, there are two issues that will affect 
marginalized consumers/taxpayers that will have a true dollar impact via banking 
services.

1.	Not all consumers have bank accounts today. The above CRA requirements 
may drive some consumers/taxpayers to either higher priced Retail Tax 
Preparation services that will charge them for the net-file preparation of their 
return and then offer an immediate refund through a pre-paid charge card (with 
associated fees). Many consumers file their taxes to ensure continuation or claim 
of benefits – UCCB, CCTB, WITB, HST etc… Regulating these fees can help, but it 
could cost a taxpayer with a small value return to incur costs exceeding that to 
comply. Should it cost money to access universal programs provided by the 
Federal Government?
2.	Banks and credit unions require service fees or minimum bank balances to 
service accounts – which we can agree is a business necessity. Unfortunately, 
even nominal monthly service fees have an impact on continuing erosion of 
disposal income for marginalized consumers/taxpayers and fixed income seniors. 
They are discouraged from establishing accounts due to the costs and 
complexity of setting up.

The rise and popularity of "Cashmarts" and "Payday" loan type stores for cheque 
cashing, advances etc… indicates that they are servicing a neglected need amongst 
a segment of the population. Unfortunately this is a segment that in most instances can 
least afford those services. Can banks, and very basic services be made more broadly 
available for little or no cost for those with a demonstrated need?

There is a lot of investment in new and exciting payment technologies through smart 
phones, Pin Cards etc… but are these accessible to everyone? My mother (80+) has no 
capability to use internet based services – she still needs a teller at a bank, and I would 
imagine that one day every aging senior Canadian will ultimately grow weary of self-
serve internet based services as they grow old with failing memories and obsolete 
computer skills and technologies (if they are even available).

My final thought is to suggest that banks and credit unions, as responsible corporate 
citizens, be required to always provide a means for opening and servicing basic 
account needs for those that fall behind through income and age. Government policy 
should not be imposing additional costs on consumers that do not benefit from 
additional protections. 

Thank you.

XXX