On July 27, 2026, the Canadian Forum for Financial Markets responded to the federal government’s proposed Regulations Amending the Financial Consumer Protection Framework Regulations (the “Proposed Regulations”). The Proposed Regulations are designed to operationalize amendments to the Bank Act that were introduced through the Budget Implementation Act, 2025 No. 1. Collectively, these amendments form the first phase of the Canada’s National Anti-Fraud Strategy and, as such, the Proposed Regulations must be assessed within the context of the government’s larger policy agenda.

The CFFiM generally supports the government’s objective of addressing consumer-targeted fraud in Canada. However, it is important to emphasize that the Proposed Regulations, Bank Act amendments, and the National Anti-Fraud Strategy are being proposed in the absence of any confirmed data on the occurrence and characteristics of consumer-tarted fraud in Canada. The government’s speculative data suggests that Canadian’s are falling victim to fraud at a scale that would suggest that a national and international response is needed with a focus on law enforcement.

In the interim, the Proposed Regulations should be amended to properly distinguish between unauthorized fraud and authorized fraud that is caused by coercion or dishonesty. Unauthorized fraud is an operational risk that can raise prudential/systemic risk concerns as addressed by the Office of the Superintendent of Financial Institutions, whose mandate was expanded in June 2023 to assess whether federally regulated institutions have adequate policies and procedures to protect themselves against threats to their integrity and security, including fraud.

Fraud is a criminal offence, and fraudsters should be prosecuted where possible. The proposed Regulations should more clearly emphasize that the primary response to fraud remains investigation and prosecution.

The proposed Regulations should also specify that the supervisory focus is on the quality of fraud prevention controls.

The fraud reporting structure detailed in the Proposed Regulations ought to be revised to allow for direct reporting to the Minister of Finance and to promote information sharing with law enforcement. A whole-of-government approach to consumer-targeted fraud requires that law enforcement and related government departments be provided with the same information that will be provided to the Minister of Finance under this scheme.