On October 3rd, 2025, CCUA responded to the Competition Bureau's (the “Bureau”) consultation on its proposed terms of reference (TOR) for an upcoming market study examining competition for financing to small and medium-sized enterprises (SMEs). The focus of the market study is to evaluate the state of competition in the SME financing sector by examining three key topics: competitive dynamics, barriers to entry or expansion in providing financing to SMEs, and barriers to switching lenders. 

The Bureau utilizes market studies to help assess a sector from a competition perspective and identify laws, regulations, policies, and other factors that may affect competition. Through market studies, the Bureau makes findings and provides evidence-based recommendations on enhancing competition in a particular sector.  
In our response to the consultation, CCUA supported the market study and provided the following recommendations to the proposed TOR:

• that the Bureau engage credit union stakeholders, such as CCUA, who can provide sector-wide information, and engage with credit unions and their SME members directly, specifically underserved SMEs;
• that the scope of products be broadened to reflect a more accurate landscape to achieve the objectives of the market study, as SMEs often use a mix of financing products;
• that the Bureau consider the role of provincial regulation in shaping credit unions’ lending capacity in its geographical focus, and the existence and impact of Crown lenders and government financing programs; and
• that the Bureau consider the government’s financial modernization initiatives and industry-led digital technology trends in its market study.  

See here for the complete submission.

The Bureau anticipates officially launching the study with the final TOR in October/November 2025, engaging with stakeholders, undertaking research from fall 2025/winter 2026, and publishing the report in fall 2026. 

If you have any questions, please contact Sabena Sandhu.