Consultation summary: Stakeholder engagement and consultation framework
In early 2015, the Financial Consumer Agency of Canada (FCAC) called for public comment on its proposed Stakeholder Engagement and Consultation Framework for Compliance Issues. The Agency received comments from a wide range of stakeholders, including financial institutions, industry groups and other interested parties. FCAC considered all of these comments and modified the framework, where appropriate.
The summary of submissions recaps the main submissions we received from stakeholders and provides our responses to these comments.
Overview of stakeholder comments
In general, stakeholders reacted positively to the approach set out in the framework. Stakeholders commented that the framework was comprehensive, open, transparent and conducive to informed decision making. They also felt that the types of consultations, interest groups and methods of consultation had been properly identified.
Several of the recommendations resulted in changes to the framework. For example, a recommendation was made by stakeholders to lengthen the submission period from 45 days to 60 days. They also requested a longer time frame to communicate and coordinate their responses internally, particularly when consultations take place over holiday seasons. As a result, stakeholders will be given a period of 60 calendar days to provide their submissions.
It was also suggested that other groups be added to the list of stakeholders. Examples included subject-matter experts, consultants and merchant groups. Consequently, we have expanded the list of interested parties to include the suggested groups and have clarified that the list is not exhaustive.
For stakeholder engagement sessions, stakeholders felt that face-to-face sessions would provide more useful information and a better environment for collaboration. They also suggested that we host these sessions in major cities in order to facilitate travel and encourage wider participation. The selection of host cities will depend on several factors, including the topic and the need to hold an engagement session.
We will also allow anonymous submissions by stakeholders, as proposed in some of the responses to our consultations. We must point out, however, that the process benefits when we can follow up with stakeholders when clarifications are required.
The final version of FCAC’s Stakeholder Engagement and Consultation Framework for Compliance Issues is available online. FCAC will review the framework from time to time, to ensure that it remains relevant and up to date.
The Agency would like to thank the contributors who submitted comments during this consultation. Stakeholder feedback is key to helping us improve our ability to deliver the Agency’s mandate.
Summary of submissions
- Comment: FCAC should be transparent about how it will treat confidential or sensitive information.
- Response: Information will be added to the framework about confidentiality and use of the information we receive.
List of stakeholders
- Comment: FCAC should publish the list of stakeholders invited to participate in a consultation.
- Response: Because of confidentiality issues, the list of stakeholders taking part in consultations will not be published.
- Comment: FCAC should expand the list of interest groups that it invites to participate in consultations.
- Response: The list of interest groups that may be invited to participate in consultations has been expanded; we would like to emphasize that the general public will continue to be eligible to participate in FCAC’s public consultations.
- Comment: FCAC should consider different consultation forums and methods.
- Response: The forum and method used for consultations depends on the topic and target interest group(s). We may, for example, communicate with Canadian consumers via social media. We will post notices of public consultations on the Government of Canada’s Consulting with Canadians website.
- Comment: FCAC should allow anonymous responses.
- Response: Anonymous comments will be permitted. However, we believe that the process benefits when we can follow up with stakeholders when clarifications are required.
Types of consultation
- Comment: FCAC should always consult with federally regulated financial entities (FRFEs) on all compliance and administrative changes.
- Response: FRFEs will be consulted on administrative changes that are likely to have a significant impact on them.
- Comment: FCAC’s relationship managers should maintain regular contact with FRFEs.
- Response: All FRFEs are assigned an FCAC relationship manager. Other stakeholders may contact FCAC’s Compliance Branch at firstname.lastname@example.org.
- Comment: FCAC should ensure that pre-consultations or informal consultations are followed by full consultation with industry stakeholders.
- Response: When appropriate, full consultations with industry stakeholders will be held.
- Comment: FCAC should begin consultations before drafting a Commissioner’s Guidance.
- Response: Pre-consultations on sensitive and/or complex subject matters will be held.
- Comment: FCAC should conduct a cost-benefit analysis or impact assessment for any guidance under consideration.
- Response: Impact assessments may be conducted, when appropriate, prior to considering guidance.
- Comment: FCAC should provide a period of at least 60 days for stakeholders to submit their submissions. More time should also be allocated for complex issues.
- Response: The period for submissions has been extended to 60 days. For complex compliance issues, we will consider a longer comment period.
- Comment: FCAC should allow more time when consultations take place over holiday seasons, at year-end, etc.
- Response: The response period for consultations will be extended when consultations take place during a holiday season.
- Comment: FCAC should allow for electronic submissions by email, rather than paper submissions.
- Response: Electronic submissions will be accepted.
- Comment: FCAC should provide a Web link and confirmation number for those who have contributed to consultations.
- Response: We will send confirmation emails upon receipt of submissions.
- Comment: FCAC should provide answers to frequently asked questions and its rationale for accepting or rejecting comments.
- Response: A brief summary of the responses and rationale for accepting or rejecting comments may be provided, based on the circumstances.
- Comment: FCAC should meet with stakeholders and provide feedback on submissions.
- Response: Stakeholders who want to discuss their submission may contact the Compliance Branch at email@example.com. All FRFEs are assigned an FCAC relationship manager and are encouraged to discuss their submissions with them.
- Comment: FCAC should highlight any amendments that are made to the document as a result of the consultations.
- Response: A brief summary of responses and the rationale for accepting or rejecting recommendations may be provided, based on the circumstances.
- Comment: FCAC should redact commercially sensitive submissions and anything that identifies the contributor.
- Response: Individual submissions will not be published. A confidentiality disclaimer will be added to framework.
- Comment: FCAC should publish draft consultation results only once stakeholders have had an opportunity to review them.
- Response: Draft consultation results may be published, when appropriate, once stakeholders have had an opportunity to review them.
- Comment: FCAC should meet with different interest groups.
- Response: We have expanded the list of interested parties to include the suggested groups (subject matter experts, consultants and merchant groups) and we have clarified that the list in the framework is not exhaustive.
- Comment: FCAC should endeavour to meet with stakeholders face-to-face.
- Response: Consultation locations will be selected based on the topic, location and objectives of the stakeholder engagement session.
- Comment: Stakeholders want to provide written submissions.
- Response: Stakeholders may provide written submissions.
- Comment: FCAC should engage with a cross-section of groups.
- Response: Different groups will be invited based on the topic, location and objectives of the stakeholder engagement session.
- Comment: FCAC should hold its engagement sessions in a variety of urban centres.
- Response: Stakeholder engagement sessions will be held across the country to ensure representative participation.
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