PIAC’s submission pointed to the underlying gaps that should be considered to have a more comprehensive national anti-fraud policy. PIAC also submitted that the measures being presently considered do not go far enough in terms of raising consumer awareness, as well as protecting against fraud. Consumer losses and liability are key issues that should be a central part of any anti-fraud strategy.

Importantly, PIAC noted that we need practical steps planned and executed to make any changes work, just peripheral discussion on these issues does not and cannot do much. Consumers have been suffering from fraud, particularly vulnerable consumers, including seniors with limited to no redress. Consumers in these cases are often left with considerable liabilities and/or losses that could in some cases jeopardize their entire life savings. It is about time for some clear and concrete action.

Last year in December 2025, PIAC appeared before the Standing Senate Committee on Banking, Commerce and the Economy (BANC Committee) to discuss its views and concerns regarding Bill C-15, Division 16 (Bank Act, Consumer-targeted Fraud). The written brief submitted to the BANC Committee was sent with these comments.

See here for PIAC’s comments to the National Anti-Fraud Strategy consultation.

For PIAC’s Comments to the BANC Committee on Bill C-15, Division 16 (Bank Act, Consumer-targeted Fraud), see here.

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We presented our major concerns and proposed some pragmatic measures to protect competition and consumer interests in this digital age. Specifically, we suggested retaining protection of consumer interests in the purpose clause of the Competition Act and proposed additional safeguards to clarify the scope of consumer protection under the Act, and standards for applying competition law and policy. We strongly opposed any attempt to remove consumer protection from this framework. We commented on measures to consider concerning abuse of dominance by digital platforms. We also recommended the removal of the problematic efficiencies defence. See our submission for more details.

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In our comments, PIAC supported the FCAC’s inclusion of expectations regarding systemic issues and redress and reimbursement policies not found in CG-12, the existing guidance for Federally Regulated Financial Institutions (FRFIs) including banks. However, PIAC recommended the FCAC use stronger language to describe these new expectations and include more explicit references to the above noted FCPF consumer protections.

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