On June 22, 2023, Parliament passed Bill C-47, the Budget Implementation Act, expanding the mandate and powers of the Office of the Superintendent of Financial Institutions (OSFI) to include supervising federally regulated financial institutions (FRFIs) to determine whether they have adequate policies and procedures to protect themselves against threats to their integrity or security, including foreign interference. These changes intend to enhance the OSFI’s oversight of FRFIs to support and maintain a stable Canadian financial system.

FRFIs must establish and adhere to such policies and procedures by January 1, 2024. To effect these changes, OSFI released the Integrity and Security Draft Guideline(Draft Guideline) on October 13, 2023, to set expectations for FRFIs.

Request for Feedback:

On an industry call on October 13, 2023, OSFI stated that the Draft Guideline was drafted in a short timeframe to meet their January 2024 turnaround target, and thus, we have a six-week consultation period which ends on November 24, 2023; this Draft Guideline version should be viewed as a starting point to ensure equal application of the principles within a year.

Note: The Draft Guideline Appendix shows the summary of expectations and overlap in expectations with OSFI’s existing/other guidelines

Please send your feedback to Gavin Karaiskos by November 3, 2023, using the feedback document with tracked changes enabled.