One thing I must point out is that writing these types of submissions takes time.
I needed to review the previous independent reviews of the ombudsman, the previous independent reviews of the insurance ombudsman, the OBSI board views and actions on the many recommendations of the last independent review (board meeting notes which have since stopped, annual reports etc), related and relevant CSA proposals and regulation and industry submissions on such. I also wanted to review related regulation and content for international ombudsman as well as their regulatory and government relationships + a lot of other incidental research.
Just flipping off a submission is not sufficient to deal with all the points that need to be confronted and that need to be pushed into the public domain. Canada has a woeful record for encouraging, developing and supporting consumer involvement in regulation of the financial services industry. It also has a woeful record of government interest and involvement in the public interest in this sphere.
Sometimes I feel that the powers that be consider this market place to be no more than a low grade meat packing industry with the consumers as the cows. The international scene is different, and if I find this very difficult to stomach. Of the funded bodies that do exist to frame the consumer viewpoint, the OSC’s Investor Advisory Panel (on a 50k a year budget) is clearly insufficiently funded and under resourced and FAIR Canada, which is reasonably well funded, is overly dependent on its regulatory benefactors when it comes to renegotiating its funding every few years. Neither body has a guarantee over its existence or its funding. Precarious and unjust comes to mind.
This is all deeply ethically wrong! Is this the way to treat human beings?