Ontario Modernizes Credit Disclosure:
A Win for Consumers and the Lending Industry

Abstract: Ontario’s introduction of Bill 46 marks a meaningful modernization of credit reporting rules, eliminating the outdated requirement for credit bureaus to display generic creditor email addresses on consumer disclosures. Backed by the Canadian Lenders Association (CLA), this targeted amendment streamlines communication for consumers—who now receive support through secure, real channels—and reduces unnecessary compliance burdens for lenders. The change preserves all core consumer rights while improving system efficiency and aligning regulation with the realities of today’s digital financial services. It exemplifies smart, responsive governance that balances protection with practicality.

Ontario took an important step toward smarter regulation with the introduction of Bill 46, the Protecting Ontario by Reducing Red Tape Act, 2025. Among its many schedules is a targeted amendment to the Consumer Reporting Act, removing the requirement that credit reporting agencies display a general creditor email address in the tradelines and inquiry sections of a consumer’s credit disclosure.

While this may seem like a minor technical change, it delivers tangible benefits for both consumers and the lending ecosystem. The Canadian Lenders Association (CLA) supported the amendment and commends the Government of Ontario for responding to industry input and acting decisively.

This is regulation as it ought to be: targeted, pragmatic, and aligned with how the system operates in practice. Here’s why it matters:

1. Streamlined Consumer Communication
   Borrowers today expect clear and efficient communication channels, typically through secure online portals or telephone support provided by their financial institutions. The previous requirement for a general creditor email address on credit reports often resulted in confusion, as these addresses were usually generic, unmonitored inboxes that rarely provided meaningful assistance. By removing this outdated requirement, consumers are more likely to be directed to the right support channels, improving their experience and ensuring their concerns are addressed promptly and securely.
2. Modernization & Efficiency for Lenders
   Eliminating this vestigial requirement saves lenders countless staff hours spent confirming and updating contact details. It frees resources to be reinvested into consumer support, fraud prevention, and product innovation, areas that directly benefit Ontarians.
3. Balanced Protection Without Burden
   Importantly, this amendment does not roll back consumer rights. Credit bureaus are still required to provide meaningful disclosure, and consumers retain their rights to dispute information and request corrections. The change simply removes a redundant disclosure requirement that made sense in a paper-based era but no longer aligns with how financial services are delivered today.
4. An Industry‑Government Win‑Win
   The CLA applauds Ontario for pursuing meaningful red‑tape reduction. We’re grateful for the ministry’s responsiveness and willingness to listen to industry feedback. This sets a standard that fosters competitiveness and encourages investment in the province’s vibrant lending sector.

For Consumers: Clarity and Real Support

On its face, requiring credit bureaus to post email contact information for every creditor may have seemed consumer-friendly. But in reality, these emails were typically generic, unmonitored inboxes, often auto-responded or redirected. They created confusion-not clarity-for borrowers who were trying to resolve issues, ask questions, or understand their credit histories.

Today, the vast majority of lenders-banks and non-bank institutions alike-offer dedicated customer service portals, secure messaging systems, and phone support to handle sensitive account information. These are the channels through which real support happens.

This amendment ensures that consumers are directed to the right support path, not a dead-end inbox. It modernizes disclosure in line with how customer service is actually delivered in 2025.

For the Industry: Reduced Compliance Friction

For lenders, especially smaller financial institutions and specialty credit providers, this outdated requirement created operational and legal challenges. Maintaining general-purpose email addresses solely for credit bureau compliance was inefficient and risk-prone, particularly given the data privacy concerns associated with unverified email contact.

The CLA has long advocated for this change because it streamlines compliance while preserving full consumer rights to contact lenders, dispute tradelines, and access credit information. It allows our members to focus on real issues-like customer care, fraud mitigation, and credit accessibility-rather than maintaining inboxes no one uses meaningfully.

Moreover, keeping email records current across multiple bureaus and regulatory filings added administrative overhead with little benefit. This amendment frees up time and resources to be reinvested into service delivery and innovation.

A Shared Vision: Smarter, Modern Regulation

Importantly, this change leaves core consumer protections untouched. Borrowers continue to have the right to dispute information and request corrections. What has been removed is a symbolic measure that no longer aligns with operational realities.

The CLA’s advocacy on this issue was part of its broader participation in the Ministry of Public and Business Service Delivery and Procurement’s consultation process. In addition to urging this disclosure reform, the CLA recommended that the government clarify other elements of the proposed Consumer Reporting Act regulations, including: limiting the duration of security freeze suspensions to avoid operational uncertainty for lenders, and providing clearer guidance on which credit reporting agencies fall under the Act’s scope, especially for smaller agencies facing compliance ambiguity

Bill 46 reflects a broader vision of regulatory modernization, one that adapts sensibly to the pace of financial innovation. The CLA commends the Government of Ontario for taking this step, and looks forward to continued collaboration to advance consumer protection while ensuring Ontario’s lending sector remains competitive, efficient, and responsive.

Here are 10 key insights from this article:

1. Bill 46 eliminates a redundant requirement: Credit bureaus are no longer required to display generic creditor email addresses on consumer disclosures, reducing confusion and inefficiency.

2. Improves consumer experience: Consumers will now be directed to secure, responsive channels like customer portals and phone support, rather than outdated, unmonitored email inboxes.

3. Preserves core consumer protections: Borrowers still retain full rights to dispute tradelines, request corrections, and access accurate credit information.

4. Reduces operational burden for lenders: Lenders no longer need to maintain generic email addresses for compliance purposes, freeing up resources for fraud prevention and customer support.

5. Supports privacy and data security: Removing unverified, publicly posted email addresses mitigates risks related to data misuse and unauthorized communications.

6. Reflects modern service delivery: The amendment aligns credit disclosure requirements with how financial institutions actually interact with customers in 2025.

7. Fosters innovation and competitiveness: By cutting red tape, the regulation allows lenders—especially smaller institutions—to focus on value-added services rather than administrative overhead.

8. Promotes regulatory clarity: The CLA has advocated for clearer, more practical credit reporting rules, including guidance on security freezes and the scope of the Act.

9. Result of public-private collaboration: The amendment reflects the Ministry’s responsiveness to industry consultation and shows how stakeholder engagement leads to better regulatory outcomes.

10. Sets a standard for smarter regulation: Bill 46 demonstrates that government can modernize consumer protection in a way that benefits both individuals and the financial ecosystem as a whole.

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