After undertaking what it referred to as a “significant strategic planning exercise in 2020”, the  Financial Consumer Agency of Canada (“FCAC” or “the Agency”) recently posted its 5-year Strategic Goals along with its 2021-22 Business Plan.

5-year Strategic Goals

Over the next 5 years, FCAC will turn its attention to four strategic goals:

• Be the national leader in financial consumer protection.
• Strengthen the financial literacy of Canadians for an increasingly digital world.
• Be the authoritative source for Canadian financial consumer information.
• Enable the future of work.

While the 2021-22 Business Plan indicates that the FCAC 2021-2026 Strategic Plan would be published in the first quarter of 2021, no Plan was published as at the date the article was published.  We will update the article once that information becomes available.    

To achieve its four strategic goals, the FCAC has established strategic priorities and related activities for each of its strategic goals.

Strategic Priorities
 

1. Strengthen the risk-based, outcome-driven supervisory program

Activities

• FCAC plans to complete Market Conduct Profiles for an initial set of regulated entities and then move to develop them for the next tier of entities. It states that this project will span a number of years.
• It also intends to oversee the mandatory reviews of external complaints bodies (5-year review) and of payment network operators (3-year review). It also plans on supporting the Department of Finance’s work on strengthening the external complaints framework and reviewing the Code of Conduct for the Credit and Debit Cards Industry.
• FCAC is also expected to start establishing a dedicated team focused on thematic reviews, which it estimates will be fully functional sometime in 2022–2023. The team will be responsible for conducting reviews, making recommendations, and monitoring strategies to address deficiencies uncovered by reviews.
   

2. Implement the Financial Consumer Protection Framework

Activities 

• FCAC will consult with industry on the publication of guidance related to legislative and regulatory amendments.
• It also anticipates testing the functionality of its case management system through a pilot with certain regulated entities.
   

3. Provide expertise to contribute to policy development
    

Activities

• FCAC will continue its participation in the Department of Finance’s policy development activities related to open banking.
• It will also conduct research and develop recommendations on issues related to consumer access to banking products and services, including novel credit and deposit products.
• FCAC will co-lead with the Department of Finance the Consumer Data Protection Working Group, which is responsible for reviewing current data protection practices by regulated entities. The working group will identify gaps and research international best practices on strengthening financial consumer data protection. See our two-part webinar series and blogposts on Canada’s Privacy Overhaul.
   

4. Renew the National Strategy for Financial Literacy

Activities

• FCAC will finalize the development of the renewed National Strategy for Financial Literacy. An  implementation roadmap will be created that will articulate how to achieve the objectives and goals outlined in the National Strategy for Financial Literacy.
   

5. Provide innovative tools and resources for better financial decision-making

Activities

• FCAC will develop new educational content on topics that include open banking, Fintech, new payment methods and update some of its educational material.
• It will also redesign the Financial Literacy Database to offer a more user-friendly
• FCAC plans to investigate the feasibility of educational tools that support financial decision-making with just-in-time, targeted information.
   

6. Engage constructively with stakeholders and foster strategic partnerships

Activities

• The Agency will develop a stakeholder engagement and outreach plan with a focus on engagement opportunities, consumer-centric outreach activities and strategic partnerships.
• It will also organize events and activities to engage with stakeholders and profile FCAC’s activities.
• FCAC will engage and coordinate with other regulatory authorities, committees, and governments—in Canada and internationally—and actively collaborate to support its consumer protection mandate.
   

7. Leverage research to increase evidence-based decision-making

Activities 

• The Agency plans to explore options for a platform that facilitates knowledge-sharing between FCAC and its research partners.
• It also plans to extend the monthly COVID-19 Financial Well-Being Survey to December 2021 and publish its results, and will start fielding the Canadian Financial Capability Survey annually rather than every 5 years.
• In addition, FCAC will leverage insights from data and behavioural science research to deploy direct-to-consumer tools and interventions with a specific focus on vulnerable populations.
   

8. Raise awareness of FCAC and promote financial literacy tools and resources

Activities

• FCAC will develop marketing strategies and partner with federal government organizations, stakeholders and strategic partners on joint promotional campaigns.
• The Agency will improve the online experience of its website users.
• It will also launch a targeted advertising campaign to raise awareness of its existence and the tools and resources it offers.
   

9. Strengthen and support the workforce

Activities
 

• The Agency will continue to address the results of the Public Service Employee Survey and update its policies and processes to reflect the January 2021 amendments to the Canada Labour Code that aim to prevent and address harassment and violence at work.
• FCAC will also implement plans on employment equity and official languages and will advance the Clerk of the Privy Council’s call to action on anti-racism, equity and inclusion in the federal public service. It will also adopt a hybrid model of in-office and remote work for all of its employees.
• It will also develop a strategic human resources plan that advances its People Management Framework.
   

10. Modernize the workplace 

Activities 

• FCAC will enhance its data governance and create a business glossary and data structure model.
• It will implement an enterprise digital strategy, which includes mobile and platform integrations and enterprise service management
• It will also transition all information management/information technology (IM/IT) tools and technologies to cloud technologies so that employees can more effectively work remotely.
• The Agency will modernize the Ottawa office and set up a Toronto office.
   

11.  Improve enabling processes

Activities

• The Agency will undertake a formal assessment of its cyber-security policies, standards, infrastructure and training program.
• It will also informally review its processes related to its Consumer Service Centre, Access to Information and Privacy.
   

Planned Financial and Human Resources

Planned spending for 2021–2022 is forecasted at $45.9 million, which is an increase of $7.5 million over the 2020–2021 approved budget of $38.4 million. The estimated increase is a result of:

• normal economic increases
• adding 4 full-time equivalent employees[1]
• developing and implementing a modern, flexible and comprehensive IT case management system
• implementing a workplace modernization project that will support a hybrid model for remote and in-office work, provide for greater collaboration among employees and ensure efficient use of the office space
• opening an office in Toronto and
• investing in information technology

The $7.5 million increase represents an additional $1 million for Supervision and Enforcement, and additional $0.7 million for Financial Literacy and an additional $5.8 million being allocated to Internal Services.  In 2022-23 & 2023-24, the Agency forecasts its planned expenditures to continue increasing by $1.4 million in Supervision & Enforcement and by $0.8 million in Financial Literacy.  However, its expects its Internal Services expenditures to decrease by $0.4 million over fiscal year 2021-22 by the end of that period.

The 2021-22 Plan also sets out the FCAC 5 year evaluation plan, which includes evaluations in the areas of cyber security (2021-22), business continuity and physical security (2022-23), access to information and privacy (2022-23), strategic policy (2023-24), project management (2023-24), information management (2023-24), IT services management (2024-25), performance and recognition (2024-25) and risk assessment/market conduct profiles (2025-26).

[1] The Agency plans to add another 6 FTEs in Supervision and Enforcement in 2021-22 over its approved 2020-21 budget and another 5 FTEs in 2022-23.  It does not anticipate adding FTEs in 2023-24.  It will reduce its Financial Literacy FTEs by 1 FTE in 2021-22 over its 2020-21 approved budget but will add 3 FTEs in 2022-23 and another 1 FTE in 2023-24.  It will reduce its Internal Services FTEs by 1 in 2021-22 over its 2020-21 approved budget and keep the number unchanged for fiscal years 2022-23 and 2023-24.