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Wendy Berman: Well, everyone, we have an ambitious agenda today and some incredible guests joining. So, I think we’re going to have a very rich discussion. So I’ll start off first of all by welcoming all of you for taking time to come and join us today and be part of this discussion. This really matters to Canada, and so I’m thankful to see a full room and a full online attendance. So hopefully we will not disappoint you in what we have to share.
So I’d like to acknowledge first that the land we are gathered on in Toronto is a traditional territory of many nations, including the Mississaugas of the Credit, the Anishinaabeg, the Chippewa, and the Haudenosaunee, and the Wendat people. We also acknowledge that Toronto is covered by Treaty 13 with the Mississaugas of the Credit. And in terms of my personal reflection on this, we all have much to learn from the many nations that call this land home. In my experience, we do so when we listen fully and we listen with an open heart and an open mind to encourage and promote those diversity of views. Our strength in Canada is our diversity. We are, and our willingness to approach Indigenous nations with respect, humility and openness informed by an understanding and an acknowledgement of our history is required for us to have that shared strength. So thank you, all.
So, as I said, we’ve gathered an incredible gang of speakers. I am very honoured to be included amongst these speakers. And I’m thankful that each of them have come today and given us their time and that they can share their insights with us as we go forward. So, I’m not going to introduce the panel. I’m leaving that to others, but you can see I’ll just say their title:
So, Peter Routledge, Superintendent of the Office of the Superintendent of Financial Institutions; Grant Vingoe, the CEO of the Ontario Securities Commission; Hugo Lacroix, the Superintendent of the AMF. I said AMF, because I don’t want to bastardize the French and embarrass myself as a Canadian. And then, of course, we have Lindsey Walton from PRI who is co-hosting this event. Thank you for joining.
And next, I would like to introduce—I’ll just make a few opening remarks and then introduce—Elizabeth Dove, who’s here to give us some remarks. So here at the CSSB, we recognize that we are at a critical time in Canada—a time of transition—which involves pain, risk, but also involves opportunity for our economy. We see sustainability disclosures as the table stakes for us to be able to move forward in that new transition towards a new economy—one where I think we’re going to emerge stronger and more resilient.
So, I would be remiss if I didn’t say we’re facing some pretty strong headwinds from emerging economic, geopolitical, social and regulatory shifts, which have made it more difficult for the adoption—broad adoption—of sustainability standards by corporate Canada. But I think we need to all rely on the fact that these headwinds do not change the fact that sustainability disclosures are driven by financial materiality. They’re not political or social agendas, and they are the foundation for us to be able to go forward and keep Canada competitive in the race for capital and in the race for revenue.
Transparency through high-quality sustainability disclosures fosters resilience and confidence. It’s when we boil it down, does a company have their arms around the sustainability matters that affect their business—for example, the physical risks of climate change or the transition risks and opportunities as we move towards a low-carbon economy.
And do they have a reasonable plan—not a perfect plan—but a reasonable plan that reflects those risks and opportunities? When they do, they inspire confidence across all of their interested and affected parties from lenders, capital allocators, employees; the ability to attract talent; the ability to participate in the global supply chain for increased revenue growth. And we see globally markets moving towards convergence around sustainability disclosures. And that has started with a loud, very loud cry from the investor or the capital allocators, but it has now been amplified by many others within that ecosystem.
So, we’re here now because those disclosures—we’ve heard how important those disclosures are for the growth of the Canadian economy. And at the CSSB, we are committed to ensuring that there is this credible, high-quality framework for disclosures that is globally aligned so we can pull ourselves out of that alphabet soup of disclosures, and we can reduce the cost for companies and for those who are the users of that information, because we’ll have that consistency and comparability across the globe.
So that’s my little spiel in the beginning to set the scene, and now I will turn and welcome Elizabeth Dove to the podium.
I’ll just give you a little bit about Elizabeth: So, Elizabeth is a globally recognized leader in sustainability matters and well known for her ability to drive meaningful collaboration, otherwise known as herding cats, to progress on the many projects she has tackled in her career. She is currently the Executive Director of the UN Global Company Network in Canada and has held numerous other leadership positions in sustainability for well over 20 years. She is recently… or she is the recipient of the Queen’s Diamond Jubilee Medal for her work on social impact, and she was named one of Canada’s top women leaders of Toronto in 2025 by the women we admire. Well, we admire you, Elizabeth. Thank you for coming. The podium is yours.
Elizabeth Dove: Thanks very much, Wendy, and thank you all for being here. Special thanks to the Canadian Sustainability Standards Board for allowing me to open things up today.
For those of you who don’t know us, the UN Global Compact Network Canada is the Canadian arm of the world’s largest sustainability initiative. Our core work is supporting businesses to align their strategies and their operations with the UN global compact 10 principles around labour, human rights, environment, and anti-corruption. And now with two hundred and twenty Canadian participants, we are the global standard for responsible Canadian business.
And I think my role today is really meant to be bringing the perspective of Canadian companies to this conversation and talking a little bit to them as well about why this conversation is so important. We’re gathered at a pivotal moment for sustainability in Canada. It’s full of complexity and uncertainty and also real possibility. Over the last few years, Canadian companies have stepped up. They’ve adopted climate action strategies. They’ve incorporated ESG into governance and risk. They’ve built systems to measure, disclose, and manage sustainability performance. But let’s be honest—it hasn’t been easy. This year in particular across Canada and particularly since February, I hear the same messages from many businesses: There are too many frameworks. There are too many standards. There’s too many changes. There’s too much uncertainty.
We are living in a time when businesses are expected to deliver credible climate strategies while the ground is shifting under their feet. Greenwashing laws in Canada have changed again, leaving many companies uncertain about how to communicate ambition without legal risk. Canada’s climate competitiveness strategy remains pretty vague for many industries on timelines and pathways. In Europe, Omnibus changes—it’s been a big month—may adjust timelines and requirements under CSRD. And in the U.S., we are seeing political friction and regulatory challenges that have created a visible chill on sustainability, climate action and DEI. All at the same time that our largest trading partner seems to have turned their back on us.
For Canadian companies, especially those operating globally, it can feel like trying to hit a moving target in a windstorm. And that is exactly why the work of the Canadian Sustainability Standards Board is so critical. Because in a fragmented global system, Canada now has an opportunity to offer clarity and consistency, not weakened ambitions but credible pathways to achieve them. The CSSB is not just presenting another framework through CSDS 1 and 2. It is building a stable Canadian foundation for sustainability disclosure aligned with global standards but grounded in Canadian realities, and this matters deeply to investors.
Sustainability and climate risk remain financially material both to your company and to investors. And the standards create a pathway. They help Canadian companies build confidence with capital markets by providing structured investor-grade sustainability data that can be integrated into financial analysis and capital allocation decisions. In a world of fragmented reporting and shifting policy agendas, that credibility is the competitive advantage.
Now, just to address the reality that many companies are feeling, there is real fatigue. And in the face of all the complexities I mentioned, some are asking: Should we slow down on our ESG plan? Should we kind of take a pause, make it a little quiet? Should we reduce our ambitions? But we cannot allow ambition to be the casualty of uncertainty. Climate change is not waiting for regulatory clarity. Nature loss is not paused while frameworks evolve. Markets, technology, and opportunities continue to move with or without your company.
And Canadian business is being relied on not to just disclose sustainability data but to drive the transition itself. You shape supply chains, influence technology adoption. You build infrastructure that lasts decades. If businesses do not lead a sustainable transition, no one else can deliver at that scale. The CSSB standards support that leadership. They are not just compliance tools. They help embed climate and sustainability into strategy, risk management, and investment decisions. They support the shift from narrative to measurable performance and from aspiration to accountability. Yes, the implementation will take effort. Yes, there is cost and learning curves, but there’s also opportunity. Global investors are increasingly directing capital towards credible transition strategies. Customers are demanding transparency, and talent wants to work for companies that are proving that they are building the future.
Sustainability long ago left us as a side issue. It is a competitiveness issue. It’s a resilience issue. It’s a value-creation issue. And while political winds may shift, the fundamentals do not. Carbon accumulates; risks compound. Companies, investors and countries that stay the course on sustainability will be the ones defining the next economy not the one that’s fading away. Canada has an opportunity to lead not by weakening our ambition but by strengthening our clarity, consistency and confidence.
So let me close with this: We cannot let uncertainty slow us down. We cannot let political volatility dilute our vision. And we cannot let complexity turn into paralysis. The low-carbon sustainable future we are working towards and that you all wish to live in will be built by organizations that seek to lead through the complexity and not retreat from it. And that is exactly what you are doing by being here today.
Thank you so much for your attention. Please enjoy the panel.
Lindsey Walton: All right. My name is Lindsey Walton. It’s really nice to see all of you. I’m just going to start with a quick introduction of the panel and of my background in the PRI and what sort of lens I’m bringing to the conversation as moderator, and then we’ll get started.
So, those of you who don’t know the PRI, we work with investors, policy makers and regulators and other key stakeholders to enable responsible investment and sustainable financial systems globally. We are the largest proponent for responsible investment with over five thousand signatories that represent 140 trillion—with a t—AUM. Our superpowers are, just to boil that down, our 20-year experience in responsible investment—so, our brand recognition; our … we’re trusted advisers in the industry; and then, of course, our size and our global influence. I say all of this, because it’s important that you understand how I’m bringing the international perspective. And I’ll tell you a little bit about what we’re hearing, and also my comms team will be happy with me.
So, I was in Mexico recently with, meeting with some of the AFOREs pensions, Mexican policy makers. I had the pleasure of attending our recent PR in person conference in Brazil. My colleagues went on to Belém. We heard a lot from all of LatAm there, and we were also able to speak with European investors, Asia-Pacific investors. And what they all had in common is that they are making incredible progress around sustainable finance.
So, taxonomies, disclosures, transition pathways—it’s really not a question of how fast but what have they completed for the most part and when will they have completed the rest. So, it’s not if; it’s how fast. And I don’t want to see us falling behind, but we are. Even our neighbours to the south showed up in huge numbers in Brazil. And they are using—yes, they’re using—a thesaurus to do a lot of find-replace term for terms like ESG that are triggering to some, but they are fiduciaries and they understand that they have to consider all material information. So the administration doesn’t necessarily speak for what investors need even south of the border.
So lastly, I’ll just note that we recently issued a call to action for global ISSB adoption backed by 120 leading investors and companies globally. So we do have the data to back up what’s converging internationally as that standard. So all that to say, we have to start showing up for the global competition for capital. And I know we can do it because we’ve punched far above our weight in sophisticated financial systems. We have renowned pension systems that are globally very respected and sought after, and we just need to get out of our own way a little bit. So maybe we’ll make some progress during this conversation.
All right. So now I will introduce my panel. Similar to what Wendy did, but I did practice my French, so I’m going to give that a shot. So, we do have Wendy Berman, Chair of the Canadian Sustainability Standards Board. Right here in the middle, we have Peter Routledge, Superintendent of Financial Institutions for the Office of the Superintendent of Financial Institutions. At the end, I’m going to say these out once, and then I’m going to go to the acronyms. We have Hugo Lacroix right here. He is a Superintendent, Securities and Distribution at Autorité des marchés financiers. Not bad, huh? And we have Grant Vingoe, CEO, Ontario Security Commission.
All right, I’m going to grab a seat now, and we will move to our first question. As noted, this year has brought significant change to our economic, geopolitical, legal and regulatory context. Wendy, given that you and Elizabeth did just share some insights, I think we’ll turn to our other panelists to start things off.
So, Peter, all the way at the end, we’ll start with you. A few days ago, OSFI released a report from its climate-related risk returns with insights on the state of climate-related data and its impact on financial stability from Canadian financial institutions. Can you share what you’re hearing nationally and internationally about sustainability disclosure data and the remaining resilience to climate risks?
Peter Routledge: Thank you, Wendy, and thank you to PRI for hosting this. Thank you, Lindsey, for being our moderator.
So yes, earlier this … or I guess it was late last week, we published some findings from the implementation of what we call our climate risk returns. And what is that? We now go to our internationally active financial institutions, and we ask them to disclose to us data on their exposure to the physical risk of climate change and data on their exposures to transition risks for climate change. And we’re doing that and not asking them to disclose publicly. And so the question is why. And the reason is—for the next few years, we’re asking institutions to do something they haven’t done before. And invariably, it’s going to take a few years to get the standards of their data collection up to the standards we’re used to with other forms of financial risk—for example, liquidity risk or credit risk, etc. But we’re off to a good start, and we’re able now to get a level set of where we have data quality strengths and where we have data quality weaknesses. And because it’s the first year, there’s more strengths than weaknesses. But we’re making very good progress on that.
On disclosure, our strategy is as over the next several years as we build … as the system builds capability to measure the financial risks that are a part of and inherent to climate change that there will be an opportunity then for public disclosure that we may mandate through our guideline on climate risk management, which we call Guideline B15. And our disclosure timeline is intentionally exactly aligned with the Canadian Sustainability Standard Board. That’s not extraordinary or unusual. Canada has always tied its regulatory data collection and disclosure to accepted accounting standards, and we are doing that exactly the same. We will not go a day earlier or a day later than what the accounting profession sets as a standard. So, I think I answered the question. I mean on the public discourse that’s going on around this issue, we consider ourselves at OSFI to be a little bit ahead of some of our regulatory peers. And sometimes that puts us in a bit of the crossfire, and we accept that as part of being out front on what we see as a long-term financial risk that is material and critical to addressing our mandate in a responsible way.
Lindsey Walton: Thank you so much. So, I’m hearing that even the large banks struggle with this new data collection and it takes some iterations to get it right, but it’s excellent that you’ve all started.
Next, I will move to Grant. Grant, can you share with us what you’re hearing from preparers? What are you hearing from preparers, investors and broadly other market participants in Ontario?
Grant Vingoe: Well, there’s still divided opinion. We see senior issuers embracing the need for utilizing the CSSB standards, using it as a tool for engagement with institutional investors—doing it relatively quietly, given the backlash. So it’s sort of a bit under the radar because most senior issuers are entwined with the U.S. capital market system. So it’s actually brought about more of a quiet effort to provide the necessary information. Probably from a slightly negative standpoint, it’s led to more candid discussions with institutional investors and not always put out into the public domain. And clearly as a securities regulator, I feel that the information should be out there in a uniform way, but the political environment in which they’re operating has made that somewhat difficult to do in present circumstances. I’d say the interest by institutional investors has remained consistent and strong and it’s frustrating to them that there isn’t a global baseline that would make engagement more efficient that would enable them to avoid using private sources of information that has less reliability. So, I think on the institutional side while there have been some cracks, there’s tremendous consistency and desire that we as capital markets regulators would move forward with more speed. I think everyone’s understanding the message that that we needed to pause, and I can get into that bit more later, but they’re sort of understanding of the difficult situation that we have collectively as a society found ourselves in relation to the United States in relation to challenging economic circumstances, the need to avoid a burden. So, I honestly feel that’s probably very Canadian that we as regulators have gotten a break for a period of time where people are kind of tolerating that we’re being a bit slower and more deliberate than our hopes were a few years ago. So, that’s part of it. Among smaller issuers, there’s still concern about how they fit into the system. They find compliance even on a voluntary basis and with limited operations to be challenging, and every dollar counts, and there’s continuing concern about the compliance burden of a full effort to align with the CSSB standards. So, I’m appreciative of the understanding we’ve received, and there continues to be slightly divided opinion, and the overall environment is making people very wary of candour.
Lindsey Walton: Thanks very much, Grant. Appreciate your candour there.
Hugo, can you please share with us what are you hearing in Quebec from preparers, investors, financial institutions, and other market participants?
Hugo Lacroix: Yes, for sure. Thank you. Is it working correctly? Yes, great! Thanks, thanks for the invitation, Wendy and Lindsey, to moderate our panel. And thanks … I’m amazed by the number of participants. I don’t know how many in line, but with all the beeps we’ve heard, I think we’re not alone. That’s good. Feels good.
What’s going on in Quebec? Mostly the same as in Ontario, I guess. I’ll start with … I must say investors and issuers, their core position remains steady. The tone has changed. The noise has changed, the context has changed, but their positions regarding disclosure is steady. Investor… Transparency for investor is non-negotiable and not more the case today than it was a year ago or that it will be a year from now. What they are struggling with is having comparable information, more detailed information. And regulatory fragmentation is quite frustrating for them, getting their job harder. The same for issuers. Market fragmentation doesn’t serve well issuers. Across listed issuers, it increases compliance costs and risk. For sure we heard and still are hearing from issuers that data, data quality, organizing data and detail disclosure are still quite a lot of work. And under current market conditions, the economic pressure is there, and I think they appreciate the extra time, they appreciate the pause.
Regarding financial institutions in Quebec, we’re quite pleased resilience is in their DNA—so resilience towards climate change. It’s not a hard stretch for them to grasp the importance of the concept. So, we see a true commitment to resilience and commitment to embark on disclosure from financial institutions. And I’ll speak maybe a bit later about what we see from smaller institutions and bigger institutions, because yes there’s a difference.
Lindsey Walton: Thanks very much. Appreciate that view from all of you, stakeholders.
Next, I’ll turn to you, Wendy. So, given everything we just heard, Canadian companies must address significant challenges but can also seize considerable opportunity in this transition to a low-carbon economy and in the competition for global capital. So, how is the CSSB helping Canadian companies and their investors address the market imperative for sustainability information without excessive administrative burden on either group, and how does this enhance Canada’s competitiveness?
Wendy Berman: So, I think the first thing that we did was take a look at the global baseline and add changes to reflect the uniqueness of the Canadian market. So, our standards have longer transition relief periods for the disclosures that were considered to be true pain points—so, Scope 3 GHG emissions and for scenario analysis. So we added that. What we also have is Canadian version of proportionality mechanisms. So with those two in place, what we’re saying to the market is it’s okay: Build capacity on these items and continue to do that so that you’re ready to enter the global market. And so I like to call our standards the ticket to play. That came to me yesterday during another conference, and I think it is. We are the ticket to play in the global market because we’re aligned with those unique aspects that reflect the Canadian market. I think that what we’re doing at the CSSB, and just to be a bit provocative, we’re not pausing—we’re pivoting.
And so recognizing the kind of political and regulatory environment that Canadian companies are facing, we’re embarking on a very aggressive enhanced outreach program so that we can open that two-way channel of listening: What are the real pain points and the real implementation hurdles for this? When we look at a large part of the disclosure, it’s all about communicating your governance structure: How did you get your arm around these sustainability matter (arms around)? What do you… How do you approach assessment of risks and opportunities? Disclose that. How do you manage? What’s your risk management strategy around those risks? And then I’ll leave metrics because that’s where we have a lot of discussion.
So, the proportionality mechanisms are very important because they say to companies: With your skills, resources and expertise, disclose. And I may have a very simplistic analysis or analogy, but if we look at what Canada did as a leader in resource and reserve estimates, we are an economy that is highly skewed towards extractive resources. But we had a period of time in which there was no trust around “what did you have in the ground and how are you going to get it out economically.” And we created a world-leading standard on that or at all of the evolution phases from exploration development to production: How do you disclose what you think looking forward is in the ground?
So, I kind of view sustainability disclosures the same way. We’re talking about short, medium and long-term exposures and opportunities for your company. You do not need to be perfect. You need to be rigorous, and if you communicate that rigour and you put sunlight around the main assumptions, which our standards tell you to, then that is what you’re communicating to the market. The concept of communicating to some and not others as Grant pointed out is really problematic for efficient capital flow, and so that’s what may happen as a result of the political headwinds that we’re facing. So we’re trying to make sure that doesn’t happen by having the conversations.
The other thing we’re doing is engaging with national standard-setters across the globe and learning from them. Some are ahead in their journeys. At one point, I thought Canada was ahead. Not so much. But others are ahead in their journey, and that is great because we can take a look at what did they do wrong. What failed, what succeeded may not work in our marketplace, but let’s take a look at it, and I have been very energized by the willingness of other regulators, financial regulators and standard-setters to share candidly. And so those conversations have been really rich, and it’s putting a lot of thoughts in our head about what’s next, what guidance do we need, what tools are out there, what can we harness in the industry itself so that our market, which is mostly small-medium enterprises, don’t take their foot off the pedal during this regulatory pause, that they continue to build capacity and they continue to get ready for these disclosures. And so can we take, for example, learnings from OSFI on the climate scenario analysis or their climate risk return data? Can we use those learnings and right-size them by industry or by the size of the company?
Something I’ve always been really proud of in Canada is our ability to innovate. And so let’s harness all that energy. There are lots of people that understand technology. I am not one of them. And we can use technology to our benefit so that we can make it easier for small and medium-sized companies to start to play in this field, attract revenue, be able to participate in global value chains because they have the minimum amount of disclosure necessary to play.
If we take a look at what’s happening, the ISSB (International Sustainability Standards Board) put out a report showing that approximately 40 countries are going to have mandatory ISSB-aligned disclosures. That’s a roughly 60% of the world’s GDP. That’s pretty impressive. So, that says: Yes! There is a ticket to play, and we need to be there. And we’re not going to be there tomorrow, and a lot of what Peter said and what Grant and what Hugo said is true. We aren’t going to be there tomorrow, but we cannot slow down. We have to continue to build capacity to gather the data, and we also have to recognize that we should not die on the altar of perfection. We are talking about looking forward 5, 10, 15 years. We’re really good at forward-looking information in the Canadian capital markets because we recognize it’s not perfect and because we recognize it’s your best guess right now. And as long as you put sunlight around the assumptions that went into and the rigour that you applied in getting to that view, then, I think, you’re more than three quarters of the way there. And that’s what we need right now. And as time evolves, methodologies, data availability—all of that will improve.
When I read the climate risk return, one of … maybe a handful of people that read it page to page. No, I’m just joking. Many people read it page to page. It showed such a good story about how far we’re coming in this journey to good quality data that helps us make smart decisions about what to do next with your organization and not in the hand-ringing way but in the look-at-the-opportunity way. So that’s what, I think, at the CSSB we’re doing.
And then the other voice that has traditionally not been around the table in Canada is the Indigenous voice. And so we are looking at ways to enhance and weave the Indigenous voices, rights and interests into everything we do at the CSSB, into all aspects of standard-setting activities because we recognize we have so much to learn and gain from adding that to what we do.
Lindsey Walton: Thanks so much, Wendy. I like the optimism there. I think everybody in this room is here because they live in optimism. So, thank you for that.
I’m going to throw you another easy question. Taxonomy. So, briefly, how would a Canadian sustainable investment taxonomy benefit from mandatory disclosure versus the status quo?
Wendy Berman: So the two are critical pillars of transition finance, and so one can’t exist without the other. It’s my view of it. And so I was very glad to see that the federal government supports developing a Canadian taxonomy. Was a little jealous when Australia took all the hard work that was done to create a framework for a Canadian-made taxonomy and ran with it and are ahead of us. But we can learn from them.
So, I think the taxonomy is a really pivotal part of this. So that … because in Canada the notion of transition finance and green finance—we have tons of opportunities and tons of risks around it. So, we need to get our arms around it. And the taxonomy just means that we’re calling everything the same thing and we’re recognizing what it is. But the taxonomy cannot operate without sustainability disclosures. It’s meaningless. You can’t get into the tag or the label without a company having the … complying with a framework like our CSDS 1 and 2. So, the two go hand in hand.
Lindsey Walton: Thanks very much, Wendy.
So, I’ll turn it back to you, Peter. With some Guideline B-15 climate disclosure and governance expectations coming into force this year for small and medium-sized deposit-taking institutions and other insurers, how is OSFI supporting organizations in meeting these expectations, and how are these expectations benefiting these institutions in the broader financial ecosystem within the context of the transition to a low-carbon economy?
Peter Routledge: Well, you’re right. And I’ll start the answer by saying we staggered the implementation of the requirements in B-15 in a proportional way. We asked the larger institutions with greater resources to go first. And then a year following, the smaller institutions will come into force. And so that’s sort of like the big picture way: You try and be proportional. And then, as we work with the smaller institutions on this—and typically we work through: On a day-to-day basis, our team works with senior management, but on an institution-to-institution basis, we work with boards of directors. So that’s sort of where I plug in. So, when we go talk to boards of directors of smaller institutions and they express concerns about: Gee, you’re asking a lot of us. We don’t have a lot of resources. We’re not a … We don’t have a trillion-dollar balance sheet. Are you going to make it too difficult for us to compete? Our first message is: No, that’s not our intent. Our intent is to try and get you along the adoption curve of measuring in this risk because we know: Once you measure it accurately, you and your shareholders will make really smart decisions about how to manage this as a financial risk. And so help us to help you help us understand where some of what we have written as a general principle in Guideline B-15 can be applied at your institution in a manner it doesn’t overburden you immediately, that serves as a catalyst for you and your organization to price this risk more.
And as we look at the financial risks of climate change, and that’s our job, we are not … Sometimes folks invite us into the public sphere, but we’re not participants in the public discourse around this issue. What we need to do is ensure that our financial system can deal with and absorb resiliently the financial risks associated with physical risk and of transition risk. And good news: Today, it’s not a financial stability risk. But the risk itself is growing in a nonlinear way, and that nonlinearity affects large institutions and small institutions. So, the next few years and implementing B-15 is a regular part of our supervisory engagement. We’re catalyzing early response, at least we’re on a relative basis early response, in the financial system. And then we’re working so that the response is manageable within the business models and strategies of the institutions that we supervise. And there’s a lot of friction. And some folks say we’re pushing too hard, and we’re trying to be empathetic on one side and principled about the risk on the other side. And we make trade-off decisions all the time, and we hope to get more of them right than wrong.
Lindsey Walton: Great! Thank you so much. Your B-15 work has been something we’ve shared at the PRI internally around the globe. So really appreciate that.
Over to you, Grant. So, while the CSA has paused work on climate-related and diversity-related rules in April, the announcement noted monitoring developments, and you’ve also been clear that the pause is not indefinite. So, have there been any developments that indicate it might be time to revisit these rule-makings? And then secondly, in lieu of rule-making, what is the OSC doing to ensure investors can access information about material sustainability risks and opportunities that preparers face?
Grant Vingoe: Well, on the timing of the pause: It was an indefinite pause. The marketplace needed certainty that it wouldn’t ratchet back in place in some very short time period. But it was not intended in any way as … It was intended to be temporary, and we are looking for the circumstances when it would be appropriate to bring back that discussion about incorporating CSSB standards into mandatory requirements. But we’re still in an environment … There’s been so much said about the headwinds, the integration of Canadian and U.S. securities markets. There’s talk about whether the U.S. will continue to fully recognize IFRS standards for foreign issuers because of the IFRS commitment to sustainability disclosure. So, there’s sort of an underlying narrative where it’s still very difficult for integrated markets, North American markets, to fully embrace the mandatory sustainability and climate-related disclosures.
There still has to be the case made too that, for Canadian companies, I think this supports our voluntary approach for the time being where they’re seeing new capital-raising opportunities and new pools of capital outside of North America that will help them justify the effort initially for voluntary and eventually mandatory compliance. It’s still somewhat unproven. The U.S. capital markets are so deep that everyone’s still considering, or many issuers are considering, that to be the primary driver what’s necessary to attract U.S. investors. So, I think that case still has to be made.
But in the same way that there’s such a strong commitment to diversifying trade opportunities and despite the depth of the U.S. markets, there is an effort underway by many to diversify capital-raising opportunities as well to Europe and Asia. If we’re going to do that, those jurisdictions are going to require that we comply with the global baseline to access those pools of capital.
So, in the meantime, we’re monitoring global developments—the elements I’ve just described. We do have existing pronouncements on material climate information, how it should be disclosed when it’s misleading. And so we do have existing disclosure requirements that relate to climate but take the form of guidance that are still drawn from the fundamental principles of materiality and require disclosure of risks and opportunities. And we are examining the disclosures made by the issuers that we’re responsible for with an eye to compliance with those standards of materiality, and we’re constantly alert to the risks associated with greenwashing and greenhushing. It’s the ultimate … One of the ultimate basis for a loss of trust is when people are making misleading disclosures about their commitments or incomplete disclosures that are half-truths about what they are saying about climate disclosure. So, we’re quite focused on that. We’re also, in the meantime during this pause, focused on how we can encourage companies to be more ambitious in their disclosures, and we’re considering—I’ve mentioned this before—whether we need specific safe harbours from extensive liability risk that in initial stages at least will encourage companies to make more forthright accurate but ambitious disclosure. So, we’re doing all of those things. And we are quite attuned to sort of picking our moment, based on developments worldwide in deciding when to move forward more definitively with disclosures.
Lindsey Walton: Thanks very much, Grant. Appreciate that answer.
Hugo, I’m going to turn to you with the same question. So, can you talk a little bit about how Quebec … In your view, have there have been any developments indicating it might be time to revisit that mandatory climate disclosure rules?
Hugo Lacroix: So, just to be clear, as an integrated regulator, we are both a credential and a market regulator. We have not paused our work and still are synchronized with our colleagues at OSFI for prudential harm. We did, as part of the CSA, pause for disclosure obligation our work for disclosure obligation for issuers.
A pause necessarily implies that you’re going to unpause at some point, that you’re going to resume. And when you resume, you resume where you left things, which were very near the finish line. And I must say that I’m pleased with what I saw last week in the last report from the firm Millani based in Montreal. I think the issuer community gets it. They understood why we pause, and they understood the concept of pause. And why I’m saying that is, and I think they heard your message, Wendy, three-quarters of the TSX, S&P/TSX Composite are having, are publishing disclosure regarding sustainability, which is the highest rate since 2022. And two-thirds refer to IFRS S1 and S2. So, they certainly understood that CSSB standards based on ISSB are the standards, are the ticket, and they—I’m pretty sure—they also are well aware of our public statement at the CSA that we’ve signalled the CSSB standards as the way to go as the standards you cannot be wrong with.
Offscreen voice: That’s our new tag.
[Laughter]
Hugo Lacroix: So why don’t we unpause? I think it’s premature. Why? Because the reasons why we pause, which is to provide issuers time to assess changes, provide predictability … You need a clearer sky. And changes—regulatory shift; political, geopolitical shifts—are still unfolding. We’re getting used to that, but they are still unfolding right at this time, this week, and certainly pretty sure for next week as well. So, it would be premature because it’s still ongoing. But you’ve heard Grant, and I’m fully at the same place as him. We are working to be ready as soon as possible to unpause.
Lindsey Walton: We will wait for the unpause. Thank you very much.
Okay. I’m going to go back to you, Peter, now. So, in September, the AMF and OSFI released insights from the standardized climate scenario exercise. Can you talk a little bit about where we are now and where you see we need to go to ensure institutions are addressing and preparing for climate risk?
Peter Routledge: Thanks. I look at my friend Hugo, and I say this: One of the proudest things, accomplishments that I have as Superintendent, and I think Yves Ouellet as CEO of the AMF would concur. It’s a great example of federal-provincial coordination and collaboration. And we have different jurisdictions, but we protect the same Canadians, and they expect us to work together in this way. And I’m very proud of what we accomplished on that.
The standardized climate scenario exercise was really a year-long effort that my friend here Stefane Tardif led at OSFI and working with the AMF to go out to the institutions we regulate and say: Here are some longer-term terrible scenarios with climate. And how ready are you to manage through them? And then here are some other less terrible scenarios.
And we’re not going to do it every year, but we’re going to make it a fairly regular discipline where we ask the institutions we supervise to open up their imaginations. And in doing that, we hope it elevates preparedness and crucially identifies weakness. And what we identified—one of the most important things, I think, we identified—is weaknesses are different across industries. So, the PNC industry is actually way out ahead in terms of understanding, in particular, physical risk. Three-quarters of them, of PNC firms, are already using geolocation coding in order to more precisely measure their physical risk from wildfires and floods. And correct me if I’m wrong, I think it’s about 12% of banks: 75% versus 12%—that’s a very, very significant gap. And I think the institutions that understood—for example, banks that understood: Well, PNC insurers who … they’re trying to make a profit for their shareholders just like us. Well, they’re really investing in this to protect or to manage their business risk. Well, I’ve got this collateral that’s sitting near a flood zone or sitting near a wildfire zone or in some parts of Canada, both. And I don’t understand well enough how significant that risk is for that particular piece of collateral or on our balance sheet more broadly.
And so that exercise is going to enable us to level up competence in measuring the risks of climate change as financial risks. And then when there’s deficiencies, we think boards of directors will be motivated to get their management teams to really drive forward and price this risk more effectively. And when we do that, when we level up the competency, we as a system will manage that risk more effectively. And guess what? As you measure the risk more effectively, boards of directors and senior management teams will make really smart decisions about how to invest to counteract that risk. That’s the beauty of market capitalism at work. That’s what we’re trying to enable with these exercises. It is not a regulatory burden for the sake of increasing costs in pursuit of some abstract virtue. That’s the last thing we’re interested in. What we’re interested in is creating management and risk measurement discipline to elevate and improve and sustain shareholder value. And when we do that, shareholders are happy. You know what? Creditors and policy holders and bond holders are happy. Interests are aligned, and that’s what we’re trying to do.
Lindsey Walton: Great! Thank you so much. And that’s an excellent report. So, I’m going to ask, Hugo, for your comments as well. Can you talk a bit about how Quebec institutions are addressing and preparing for climate risk?
Hugo Lacroix: Yes, for sure. And where we are aligned is the importance of collaboration. Thanks for your comment, Peter. I think it was over two hundred institutions who participated in the exercise? 250 who participated. A number of them were Quebec based. We’ve learned a lot, I think, us as regulator institutions as well. It was a very useful exercise. Certainly, I don’t think I’ll create a surprise saying like you said that some institutions are impressive by their capacity. They develop their readiness, and some of them really … it’s already integrated in their business model and how they price and how they manage risk. Others are … it was their first experience of a standardized scenario analysis, and so I think just realizing that is useful. Lessons from the regulators maybe for the community as well. When you are more granular with data, the qualities go with it, and it’s hard having a good set of quality data on wildfire and floods. But you know what? It’s still worthwhile. The exercise is still telling, and you progress by making those exercises, and then the quality will follow it. There’s a virtuous circle here. It’s just I don’t think I’ve heard no one saying: Oh, we should have waited for perfect data set. So that’s something. A lesson learned.
I think the industry certainly now have a better assessment of where they are in terms of physical and transitional risk where gaps remain. And as next steps for us, we’ll certainly use those data, those results in our supervision in a very proportionate way to increase readiness. I think that’s where we are in terms of objective as a follow-up.
Lindsey Walton: That’s great! Thank you. I’m hearing a real theme of “Just get started and you’ll figure it out along the way. Just go into the process with some rigour and be ready to iterate and work together, and you will figure it out and also come across information that you have never seen and are now glad to have seen like your geo distribution.”
So, good news! We’re now moving on to the opportunities side and away from the risk. Well, I’m a risk manager at heart, so bad news for me. I, sort of, like the risk side.
All right. So, opportunities. We hear a lot about sustainability risks, but Canada faces a pivotal moment. Our resource-rich economy affords us an opportunity to lead globally in the transition to a low-carbon economy. And I think everybody has seen this report—the International Energy Agency report in June. We all quote it that this year investment in clean technologies was 2.2 trillion. It is set to double that of investment of fossil fuels 1.1 trillion. So, I would like to hear from each of our panelists on this: At this crucial time, how is your organization helping Canada remain competitive to benefit from the global transition to a low-carbon economy? And how is your organization navigating external headwinds while staying focused on supporting organizations with what matters most—whether it be disclosures, a taxonomy, transition planning, or the holy trinity of all three? Wendy, I will start with you.
Wendy Berman: So, I think the main thing we’re doing is really working hard to shift the narrative to the opportunity side and also beyond this momentary headwind, because all these headwinds are momentary. So if you shift the narrative and you talk about the value and you approach it like any other business opportunity or risk that you need to look at as an organization without the social or justice agenda but just straight business, I think that that’s important. And then when you start to pull data, because we can see other countries that are ahead of us, what happens to your risk-adjusted cost of capital when you have transparency, when you inspire confidence that you have your eye on that ball and what it’s going to do to your company? We see … we’re starting to see some really strong evidence that the risk-adjusted cost of capital goes down. We’re starting to see capital inflows to countries even before they have the mandatory regime in place, but that it’s coming. So, what does that tell us? That tells us that capital allocators feel comfortable that those jurisdictions, the companies within those jurisdictions are looking at this and approaching it with rigour. So, I think that narrative is really important that we expand it. We also expand the lens. We need to look beyond our borders as others have talked about here. So, when we look at numbers like that for clean energy, when we look at countries, 8 of our 10 largest trading partners have or will have mandatory sustainability disclosure regimes in the near term. Eight out of 10. So, that’s a significant amount right there. When we look at … we used to think for a long time that this was a Europe-driven initiative. It is so not a Europe-driven initiative. Take a look at what’s happening in Asia. China will have mandatory climate disclosures shortly. Other countries: Japan, Hong Kong, Brazil. We start to see that convergence, and it makes it more clearer than ever that this is going to be the minimum you have to do to access capital or revenue from—and we focus on capital, but we should also focus on revenue, which is the economic growth driver. That’s going to be what you need to do. So, we are looking at engaging with shifting the narrative as we pivot, not pause. I’m really liking that “pivot, not pause.” And we can all disagree as to whether or not the pause is necessary. There’s a moment in time where we should lift the pause. But what I do want to say is on behalf … from my perspective at the CSSB as an independent standard-setter, we recognize that it ain’t an easy decision to whether or not now is the time, and we can disagree as to whether now is the time. But what I want to see going forward for Canada is that we continue to build capacity.
So, the other thing we’re doing is this is not a “one and one.” We are not done with S1 and S2. There will be other. There will be amendments to S2. In fact, we will be putting out an Exposure Draft shortly. And so we need to stay in touch with a business community, the capital markets, with regulators so that we can talk amongst ourselves and find the best Canadian solution for global changes to the existing standards. Then we’re going to have additional standards that come out of the ISSB. They have said by October of 2026 they will have a biodiversity disclosure standard and a human capital standard. So that’s coming down, and we need to make sure that Canadian companies are ready to address that as well. So, it’s ensuring that we have a loud punch above our weight, amplified punch above our population and the size of our capital markets, voice at that international table, and so that’s a big focus for us at the CSSB.
Lindsey Walton: Thank you, Wendy. Peter, any thoughts?
Peter Routledge: Our work on climate so far, it’s sort of sitting on four pillars: Guideline B-15 is regulatory principles for managing the risk; our regulatory return: data returns; the scenario exercises we’re doing; and then bilateral supervision, which is what we talked about. There’s something else we could do. Those four pillars are pretty much focused on the risk side. Well, with risk there’s return and opportunity. Opportunity here is in renewables. We would really love to have an accepted climate taxonomy that we could then use to price the opportunity that will emerge from climate change. And we are very open to considering how we think about capital might change if we had an accepted standard, which we, sort of, colloquially call a “green taxonomy”. That would be a huge advantage to us right now, and that would be pillar number five. That’s what we need.
Lindsey Walton: Green or a green and transition?
Peter Routledge: When I say green, I mean the green as well as the transition. So, I don’t mean to negate transition at all.
Lindsey Walton: Great! Just wanted the call to action to be clear. We need both. Thank you, everyone. Okay, I will move on to you, Grant.
Grant Vingoe: So, I think… Well, obviously Canada has a tremendous opportunity to demonstrate with its very strong mining and resource companies and other companies that do face risks and opportunities that Canada can do this differently and really demonstrate to the world that it’s committed to advancements in technology and managing these risks and bringing new offerings forward. There’s the intellectual capital in Canada to really be in the forefront of addressing these issues. And at the OSC, we’re really committed to having the expertise internally to work with those companies and help bring them forward to the marketplace. It’s a shift under our new strategic plan to really … Apart from being completely neutral regulator, there’s also in the present environment desire to make a contribution to building Canada. And in this particular dimension of activity, Canada can be distinct from the United States. It can find access to new sources of capital, and we are going to put the resources at the OSC into enabling Canadian companies to meet that opportunity through—and that’ll include—through high-quality disclosures, ambitious disclosures and eventual adherence to the global baseline. So, I do see kind of the beginnings of an opportunity to differentiate ourselves and to align ourselves with the many jurisdictions that have adopted the global baseline and are seizing this opportunity. I do think a green and transition taxonomy made in Canada will be of great assistance to Canadian companies globally that don’t fully appreciate the transition story in Canada. And we, in turn, along with the CSSB in terms of … can do much more on transition plans and disclosures related to how companies are going to adapt to new circumstances and meet net zero commitments. So, I think that’s going to be a very important avenue for us to consider additional disclosures in the future. So, while it may seem that we haven’t at the CSA fully adopted CSSB standards, I have to say that we’re great supporters of the CSSB and really do believe it’s integral, it is the ticket, and we want to build an infrastructure out from that to encourage Canadian companies in the space.
Lindsey Walton: Well, that’s great news! Thank you so much. And lastly, Hugo.
Hugo Lacroix: Yes. So the question is: What can we do? What can we do to help as regulator? Social policy? No. Environmental policy? No. That’s not that. Panel is not about that. Public policy? No. Regulation? Did we say we pause? We pause. We pivot. We certainly did not retreat. That’s important as well. But yes, there’s still things we can do. We can surveil; we can monitor. And that’s the plan. The plan is make sure, because we might pause regulation, but we did not retreat. The issuers did not retreat as well. So, there’s disclosure out there. There’s things to surveil, to monitor, make sure they are current between what’s mandatory and what’s voluntary. I think there’s a job for a market regulator to make sure all this is consistent and address and act on any greenwashing that can be going on out there. So that’s, I think, what we can do.
On the short term, pausing was helping competitiveness of our market. And I would say on a real short-term view. On the long term, I think that’s … What we can do … I’ve started with a couple of things we cannot do: It’s not in our mandate. But what we can do as regulator is creating trust and transparency. And that has proven quite a recipe for competitiveness of financial market as well. And right at this time, issuers, I think, have also a role to play, and boards have a role to play and reflect on what they decide. Do they decide to wait? Do they decide to be ready when we are on pause? Or do they decide to lead because they can certainly do that. They have a credible quality framework to Canada.
And one last thing regarding the taxonomy: I think we’re again on the same page. It would be absolutely aligned with other decision we took in Quebec to harmonize, to use Canadian independent, built, established standard by credible bodies, and that would be quite useful.
Lindsey Walton: Great! Thank you so much. So, we are running out of time as you do in these panel discussions. So, before we open the floor for questions, I’m just going to summarize some of what we heard, and then I’m going to give each panelist a 30-second rapid-fire opportunity to add anything that I may have missed.
So, what I’m hearing from all of you is here’s the status quo: There’s quite a bit of market fragmentation, which benefits nobody. The CSSB was built for Canada with proportionality considerations. And a lot of it is about communicating governance risk and strategy around climate that’s quite material. So, we may see some stakeholders get disclosures at this point and some which don’t, which is not very efficient for capital flow. From the international side, we have 40 countries—60% of the GDP globally—implementing ISSB, and 8 out of 10 of our largest trading partners have or will soon have mandatory disclosures. Lastly, we do have some announcements of the taxonomy that’s coming out, and that won’t work without the disclosure mandates. So what I’m also hearing in terms of the way forward from, I think, everybody is that you must get started and be rigorous but not perfect. So, there are some great examples of pilot implementations with larger institutions. Senior issuers embrace CSSB as well. So, most issuers are already disclosing on some climate standards. If you do have these pilots with larger issuers with some sort of safe harbour, that’s a potential way forward for everybody.
And now, I will give everyone a truly 30-second rapid fire opportunity to add. What did I miss? Peter, I’ll start with you.
Peter Routledge: I just think … The point I’d like to make is: Adapting to climate change is a big public policy issue to be debated in the public arena. For our purposes at OSFI, climate change is an immense challenge and opportunity to our financial system. And our job … We’ve used the metaphor of a pivot. I’m going to use a metaphor of “just keep driving forward day after day, step after step, mile after mile to progress the maturity by which we measure and understand climate risk”. That’s our job. Let the public arena and the participants there debate climate policy. We just want to move steadily forward step by step and be relentless on this. That’s our job.
Lindsey Walton: Thank you. Grant, 30 seconds.
[Laughter]
Grant Vingoe: Okay, just two quick comments. One is we don’t forget about retail investors. So, they might have a different risk opportunity calculus, but there’s a large number of, a whole demographic of, impact investors who deserve accurate non-misleading information. And we’ve published a number of behavioural insights papers about how their sentiments can be manipulated by star ratings, imperfect information regarding product labeling—in the fund industry, for example. So, I think, as securities regulators, and I think there’ll be spillover benefits for institutional investors too, that we need to also take in mind impact investors who want to have a positive impact on the environment. And their information has to be accurate as well. And then I just emphasize that we now, the last few years, have mandates to foster capital formation and foster competitive markets. And that’s a good entree into being able to foster areas where Canada has strength, including in innovative solutions to climate change.
Lindsey Walton: Great! Thank you. Wendy, 30-second comment.
[Laughter]
Wendy Berman: I think I’d echo Peter’s. I think, just keep marching forward. And to be clear, when I said the CSSB is pivoting, it’s because we didn’t think we were going to have to engage in such an outreach to encourage market adoption, which I like a lot better than voluntary adoption. So, we are pushing forward, and we want Canadian organizations to push forward because we think it’s in the public interest for all of Canada. And so last point is: Let’s not operate in silos. Let’s not put up barriers. Let’s work together. I think that’s one of the hugest strengths that Canada has. So even if we disagree across our patchwork financial ecosystem here in Canada, where we have multiple regulators and government entities, even if we disagree, we must keep talking, and we must all respect that we’re trying to act in the Canadian public interest.
Lindsey Walton: Great! And Hugo, last word before we have a few questions.
Hugo Lacroix: I will emphasize on the why we’re doing this. Grant, you refer to investors or refer also to consumers of financial products in Canada. I think they count on us, the regulator, to make sure they have a competitive financial market and financial institutions. And to be competitive, there’s going to be a shift, there’s going to be a transition, and we need that financial market to remain competitive in a low-carbon economy, and that’s the economy of tomorrow.
Lindsey Walton: Thank you so much for all of those last words. Those were very inspiring. I do have a couple of comments from online, and I think we’ll have time for at least one comment in the room if anybody has a hand.
From the online questions: A comment in the Q&A argues that the pause on mandatory climate disclosures runs contrary to the goal of protecting investors. The pause has left the investor public without crucial information about the financial risks created by climate change and a lack of mitigation efforts by issuers. Can you comment? Sorry.
[Laughter]
Grant Vingoe: I’ll comment. We have existing standards and guidance on making accurate climate and sustainability disclosures, and we’re examining for them. What’s lost is potentially a uniform baseline, but what’s not lost is our commitment to avoiding misleading disclosure and our ambition to encourage more forthright forward-looking disclosure. So, it’s not a black and white situation. Uniformity is lost, but we’re committed to accuracy.
Wendy Berman: I just want to add: I think today’s discussion was helpful for me. When we read, when we all read the news release about a pause, we were confused as to what it meant. So, I think it’s incumbent on our Canadian securities regulators to be clear as they are today about what it means so that organizations don’t think: “It’s not important right now; we can turn to something else.” They need to keep understanding: It remains important.
Lindsey Walton: Okay, great! Does anybody from the audience have a question, or if not I’ll go back to some online questions. No? Be brave. Oh, here we go.
Audience member: Thank you. I was wondering because there’s been a decent bit of talk about Australia and Asia adopting ISSB-aligned disclosures. I was wondering if you guys had any opinions on the States. I know there’s obviously headwinds or smoke coming from the south. But New York has passed the law that is ISSB-aligned; got paused. New York has one on the legislative agenda. So, I was just wondering how that, kind of, fits into your, guys’, thinking around these issues.
Wendy Berman: I think in the U.S. we’re seeing such a fragmented view towards sustainability or climate-related disclosures—with California standing out there as a leader. And so it would be a terrible thing if it went state by state as it is. And so we see municipalities in the U.S., being at the forefront, and we see certain states. We certainly don’t see a cohesive view across the United States. And that creates—and now I’m speaking as a securities regulator—but that creates a lot of confusion for Canadian companies that are dual-listed, which are the vast majority of companies in Canada that are dual-listed or dual-listed in the U.S., as to what they have to comply with.
Of course, I have an easy answer, which is adopt CSDS 1 and 2 and comply with that, and you’ll be where you need to be. So, I don’t think we’re going to have clarity out of the U.S. for some time.
Peter Routledge: I just add a little bit: Because we deal on the climate issue and the international for all the time, and I’ll quote our prime minister, or maybe I’ll steal a quote from him: We take note of what our international peers are doing. We don’t take direction. We’re going to do what’s right for Canada and Canada’s financial system.
Hugo Lacroix: And if I may. It’s certainly not information that is not important. It’s, I think, critical intelligence. It is not information that we have discarded in our decision process. I would say New York, California, but the dozens, I think, more 30 countries on their way to comply with the ISSB. But we, I think, like you said earlier, Grant, it’s a grey area, and that's why we end up to the decision that was taken, and that’s why we are saying with confidence that this is not a … this is a concept that will evolve.
Audience member: So, Andrea stepped out, so I stole the mic because it was coming by.
[Laughter]
And I guess my question goes back to something that was said much earlier about how institutional investors are getting more candid information in their meetings with companies, and we’re among those. But we have concerns about that. Sometimes we’re having to say: You can’t tell us because this is selective disclosure. And so my concern is that if you’re … is that … How are the securities regulators addressing this gap in standardization, which is in the risks around selective disclosure, or you’re not as concerned because you don’t believe it’s material information? I’m trying to understand which way.
Grant Vingoe: Well, it would have to … It would depend on the specific information that’s shared in terms of assessing its materiality. But I think there’s nothing in … I don’t think we’ve encouraged selective disclosure. It’s really the poll over making public disclosures that has arisen from liability concerns or reputational issues south of the border and elsewhere. From our point of view, material information must be disclosed publicly. So, as institutional investors, I’d encourage them, the issuers that you engage with, to take that element of information that is the core material information and disclose it publicly. So, I don’t think the deterrent is securities regulation. It’s the environmental factors and civil liability concerns rather than securities regulation. But our viewpoint is selective disclosure of material information isn’t appropriate.
Lindsey Walton: Thank you so much. Did you have something to add, Wendy?
Wendy Berman: Just that I have confidence in Canadian securities regulators that if it’s happening, they should be aware of it and they should act on it.
Lindsey Walton: Talk to Delaney.
[Laughter]
All right. Well, I am trying to be right on time. So, thank you so much to everybody. I want to really sincerely thank this panel for being here. This doesn’t happen everywhere in my experience. The transparency, the collaborative nature of the financial industry in Canada—it is truly unique. And just thank you so much for being here and for continuing to work with all of us. Very much appreciate it.