From: Tarin Lewis Sent: February-26-14 11:18 AM To: Consumer Code / Code consommateur Subject: consumer protection framework - consultation paper Hi there, Thank you for the opportunity to provide input on Canada's Financial Consumer Protection Framework. Our organization is a not-for-profit organization that works with all members of our local community to help educate individuals and foster individual and community growth. We have recently received funding from TD financial/SEDI for a financial literacy project that involves mentorship within rural and small urban areas (Northumberland County and Peterborough/Peterborough County). We are also currently implementing outcomes from a Status of Women project with a focus on Economic Security for Women in Rural areas where approx. 200 forum participants gave input on topics related to economic security (employment and financial literacy needs). Based on our experiences, we understand the "vulnerable sector" to really include everyone that does not have a solid understanding/foundation of financial literacy which is almost everyone outside of the financial business sector. The following would be general comments that we would bring forward for the consultation paper: - Financial information regarding products and services of all kinds to all individuals have become so complicated as a result of innovation and the rate at which new services/products are introduced is extremely fast. A single framework would make access to information and understanding of principles easier to find. Simple language would increase the likelihood of understanding among all audiences and updates that relate to changes can be facilitated through an alert system and an availability of Q & A through website access or virtual "coach" system. - Vulnerability is based on lack of knowledge/information. Presently the onus is on an individual to take the initiative to learn about finances – how to manage, services, products, risks, etc. Introducing financial literacy at an early age through school curriculum would help younger generations grow up with financial awareness and a foundation to make good lifelong financial decisions and maybe less susceptible to advertising and quick, impulsive decisions. Currently, services and products are evolving at a rate so great, that individuals are always in a "catch up" mode to understand the product/service itself, much less the terms and risks associated with them. As a result of our aging population, often individuals are also struggling to learn the technology as well. - In addition to education within the school system, placing the responsibility of education as a requirement on businesses when introducing new services/products would be helpful. This education should not take on the form of advertising, but more of a workshop session to teach the value, limitations, risks, etc of a product/service in a proactive manner rather than have individuals trying to understand after the fact and they have misused a product/service. - Technology has allowed businesses to offer services differently, which includes making the online purchase or use of services more appealing than "in store". In other words, it is often cheaper to complete banking tasks online than in person at a bank for example – different rate of service charge. Individuals who are trying to be fiscally responsible would see the online option as cost-effective, but not necessarily understand the flip side of the risks. At a bank, a teller would ensure that a transfer/transaction only happened once, but online, it may be that an individual perceives the transfer/transaction did not go through so they repeatedly perform the same action which could place them in a precarious position (only one example). Individuals would be more inclined to go in person to a bank/business and ask pertinent questions to ensure understanding if the costs for in store service matched online service. - Rents are restricted by a percentage increase governed every year based on cost of living. Increase in any fees associated with financial services/products could perhaps have a similar limitation/restriction – for example ATM fees - A simple representation for disclosure would be helpful – perhaps as simple as a table that provides terms with coinciding product/service and risk – side by side instead of embedded in complicated multipage format with significant disconnect. Tarin Lewis Program Facilitator Community Training & Development Centre Box 662, 300 Alexandria Dr. Cobourg, ON K9A 4R5 905-372-9967 Tarin_lewis@kprdsb.ca