Canadian Lenders Association Statement on British Columbia’s Consumer Protection Amendments

FOR IMMEDIATE RELEASE
Toronto, ON – October 13, 2025

The Canadian Lenders Association (CLA) acknowledges British Columbia’s initiative to modernize consumer protection law, including measures that would provide consumers with free monthly access to their credit report and score, and introduce both security alerts and credit freezes administered by consumer reporting agencies. These objectives, as described by the Province, aim to strengthen protections against credit-related fraud and improve transparency for consumers.

As the national voice for Canada’s lending and fintech community, representing over 300 companies across the country, the CLA supports measures that improve consumer confidence while maintaining access to responsible credit.

The Association is concerned, however, with the bill’s proposed security-alert framework. In addition to requiring recipients of a report containing a security alert to undertake heightened identity-confirmation steps and to keep records of those efforts, the bill would impose a new obligation on consumer reporting agencies to notify the consumer in writing or another prescribed manner of the alert’s end date shortly after the alert is created and again at least thirty days before the alert ends, where the alert is subject to a prescribed expiry period. This dual bureau-to-consumer expiry-notice obligation is novel in Canada and is not found in the Ontario or Québec frameworks, which address alerts and freezes without imposing advance expiry-notice duties on the agencies themselves.

Introducing a province-specific consumer-notification duty on security alerts risks fragmenting compliance requirements and undermining the stated objective of interprovincial harmonization. It also creates practical delivery risks because consumer reporting agencies do not maintain ongoing verified communications channels with most individuals, increasing the likelihood of missed notices and consumer confusion regarding the status of protections. These concerns are amplified by the bill’s record-keeping obligations placed on report recipients when an alert is present.

The Association recommends that British Columbia amend the security-alert provisions to align with prevailing Canadian practice. In particular, the expiry-notice requirement should be removed or adapted to a flexible model that relies on verified, consumer-authorized channels, while preserving the recipient identity-confirmation steps when an alert is present. A measured implementation period remains important to permit coordinated operational changes by consumer reporting agencies and lenders so that consumers receive the intended protections without avoidable disruption.

“The goal of empowering consumers with effective tools is shared,” said Gary Schwartz, President of the Canadian Lenders Association. “That goal is best achieved through a harmonized framework that protects against fraud, preserves access to credit, and can be implemented reliably by all market participants.”

“The proposed credit-freeze regime can deliver benefits if essential servicing access is preserved and timelines are realistic,” said Dean Velentzas, Head of Policy at the Canadian Lenders Association. “The security-alert expiry-notice obligation, as drafted, is a deviation from Canadian practice and should be amended to support a Team Canada approach.”

The Canadian Lenders Association stands ready to work with the Government of British Columbia, consumer reporting agencies, and stakeholders to finalize amendments that protect consumers, reduce fragmentation, and support a stable and efficient credit marketplace.

5 Main points

  • Support for modernization and consumer empowerment
    The CLA commends British Columbia for updating its consumer protection laws to enhance fraud prevention and transparency, including measures like free monthly access to credit reports and scores, and the introduction of security alerts and credit freezes.

  • Concern over the proposed security-alert expiry-notice requirement
    The CLA highlights that BC’s proposed rule—requiring consumer reporting agencies to send dual expiry notices (at creation and 30 days before expiry)—is unique in Canada and not found in Ontario or Québec. It warns that this could complicate compliance and fragment national standards.

  • Risk of consumer confusion and operational burdens
    Because credit bureaus often lack verified communication channels with consumers, the proposed expiry-notice process could result in missed notifications and confusion about protection status. Additional record-keeping requirements for lenders could also create unnecessary administrative burdens.

  • Recommendation for harmonization and flexibility
    The CLA urges BC to align its security-alert provisions with existing Canadian practice, suggesting a flexible model that uses verified, consumer-authorized channels for notifications and a phased implementation period to ensure smooth coordination among lenders and credit bureaus.

  • Commitment to collaboration and a “Team Canada” approach
    The Association reaffirms its readiness to work with the BC government, consumer reporting agencies, and other stakeholders to ensure reforms that protect consumers, maintain credit access, and reduce regulatory fragmentation across provinces.

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