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I call this meeting to order.
Good afternoon, everyone.
Happy Halloween.
Welcome to meeting number 143 of the House of Commons Standing Committee on Industry and Technology.
Before we begin, I would like to invite all participants here in Ottawa to review the guidelines for best practices for earpieces and microphones to prevent audio feedback incidents. The purpose of these directives is to protect the health and safety of everyone, but especially of our interpreters, whom we thank for their work.
Pursuant to the motion adopted on Thursday, September 19, 2024, the committee is resuming its study of credit card practises and regulations in Canada.
Today, we are pleased to welcome our witnesses.
From Agri-Food Analytics Lab, we have Sylvain Charlebois, senior director, who is here in person. He's also a professor at Dalhousie University. Mr. Charlebois is accompanied by Samantha Taylor, senior instructor of accountancy and information sciences at Dalhousie University. Thank you for joining us.
From the Office of the Superintendent of Bankruptcy, we have Superintendent Elisabeth Lang joining us by video conference. I would also like to thank her for being with us so early on this Thursday morning.
You each have five minutes for your opening remarks.
Without further ado, I give the floor to Mr. Charlebois.
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Thank you very much for inviting us this morning.
I am accompanied by my colleague, Samantha Taylor, who is an expert in accounting, which is not my area of expertise. I haven't done a whole lot of research on credit cards in my career, so I thought that Ms. Taylor's presence would be appropriate for this testimony.
The expansion of buy now, pay later options in Canada, notably through platforms like Apple Pay and providers such as Klarna, has implications for consumers who may already be facing financial strain. Though current regulations don't address BNPL for essential items like food, I would recommend restricting BNPL credit options specifically for grocery and food purchases either directly at the point of sale or indirectly through digital payment intermediaries. Such a measure could help prevent Canadians from incurring additional debt on essential items.
While I have reviewed key government resources, including the code of conduct for the payment card industry in Canada and the Financial Consumer Agency of Canada Act, there appear to be no existing restrictions on using BNPL for groceries or restaurant purchases, underscoring the need for action in this area.
In addition, social media's influence on consumer perceptions cannot be underestimated. generation Z and millennials increasingly rely on social media for news consumption, diverging from older generations who prefer traditional media like print and radio. That really affects their behaviour.
Of concern, we've seen campaigns promoting grocery boycotts and even social encouragement for shoplifting. To address the potential influence of bots and coordinated misinformation, which may disproportionately affect younger Canadians, I recommend considering requiring social media platforms to implement a verification system for users on online platforms to prevent manipulation of Canadian consumers by automated accounts.
Additionally, agencies like the Financial Consumer Agency of Canada can use social media to share credible, engaging content such as short videos, boosting financial literacy where younger Canadians are most active. I do want to underscore the fact that financial literacy is a big issue in Canada right now.
At this point, I'd like to pass it to my colleague, Samantha Taylor, for the remainder of our opening remarks.
Thank you, Chair and distinguished committee members. I am Samantha Taylor, and I am here to offer insights about financial technology, social influence and food security.
Buy now, pay later, or BNPL, is becoming increasingly popular in Canada, offered through platforms like Apple Pay and Klarna. It appears that current regulations do not prevent consumers from using such mechanisms to purchase food. With these additional credit offerings, Canadians may be inadvertently increasing their consumer debt.
To address this, I recommend introducing regulations to prevent the use of BNPL for food items and, possibly, restaurant purchases either directly or indirectly through third-party platforms.
Next, I'd like to discuss social media influencers and their effect on consumer behaviour and perception of food security.
Campaigns by influencers, even with positive intent, can lead to price volatility or encourage illegal activities like shoplifting.
Further, generation Z and millennials are more likely to consume news online, especially via social media, as compared to older generations. Notably, generation Z is just as likely to trust news from social media and professional journalists versus older generations who prefer professional journalism. To counteract this, I propose exploring user verification measures for social media platforms operating in Canada. This could prevent autonomous accounts, or bots, which can drive misinformation campaigns.
Additionally, I recommend that agencies like the Financial Consumer Agency of Canada consider mobilizing their content via social media to meet younger Canadians where they are.
Lastly, a greater number of Canadian consumers are ordering and paying for groceries online. I recommend considering the introduction of restrictions against online grocers saving consumer credit card information to protect them from data breaches.
By proactively addressing these technological and financial risks, we can better support Canadian consumers in managing their finances and ensuring stable access to food.
I look forward to discussing these recommendations in detail.
Thank you.
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Chair and honourable members, thank you for the invitation to appear as a witness today.
I will deliver my remarks in English in order to avoid any technical difficulties.
Today, I will provide a brief overview of the insolvency system in Canada and I'll touch on some information and data that I thought might be of interest to you in relation to the current study. Then I will be happy to answer any questions you have, in the language of your choice.
Before I begin, I'd like to share an important perspective regarding policy challenges and insolvency.
Policy challenges generally don't originate in insolvency laws. They have a light shone on them via an insolvency, but the problems almost always lie elsewhere and should be addressed at their root. Trying to fix problems in insolvency is ineffective for the core problem and can upset the delicate balance that is necessary for an effective insolvency system and/or can negatively impact credit in general. Trying to fix problems in insolvency is like trying to save a plant by addressing the flowers only. If you do that, both the flowers and the plant will die.
Turning briefly to an overview of the insolvency system and my office, for context purposes, a well functioning insolvency system is a key pillar of the economy. It helps promote investment and creditor confidence in the Canadian marketplace and allows honest but unfortunate debtors a fresh financial start.
As superintendent, which is a Governor in Council appointee, I have statutory duties and authorities that I carry out at arm's length to the government, which help to ensure that the Canadian insolvency system continues to operate as intended. My office is responsible for overseeing all aspects of the Bankruptcy and Insolvency Act, as well as certain aspects of the Companies' Creditors Arrangement Act. I license and regulate the insolvency profession, ensure an efficient and effective regulatory framework, supervise stakeholder compliance, and maintain public records and statistics.
I also have directive-making power that enables me to provide additional direction on the legal requirements of the BIA. My office has the lead on regulatory changes, while the Minister of Industry has responsibility for insolvency legislation. We work closely with the department to try ensure that operational realities are considered in any policy changes.
The OSB, as a vote net organization, is almost entirely funded by stakeholders, whereby levies and fees cover almost all of our direct and indirect costs, with only a small appropriation. In addition to the OSB, key players in the insolvency system include licensed insolvency trustees, debtors, creditors and provincial courts. Stakeholders in the insolvency system have rights and responsibilities and can be subject to consequences if they fail to fulfill their duties.
I want to note that there has been a lot of attention paid to insolvency trends and the increased number of filings of late. To put that in context, we have not yet seen consumer insolvency filings reach the number we saw prior to the pandemic. In 2019, there were just over 137,000 consumer insolvency filings. The numbers dropped significantly during the pandemic lockdowns and have only more recently been rising. In 2023, for example, there were just over 123,000 consumer insolvency filings.
It is worth noting that we saw the highest number of filings in 2009 during the recession, when we saw over 151,000 consumer insolvency filings, with a note that Canada's population has grown since then.
It is also worth mentioning that in 2023, almost 79% of those filings were consumer proposals, which is an option that allows debtors to retain their assets and pay an amount agreed upon by their creditors, usually over a period of time. Consumer bankruptcies are only occurring in about 21% of the cases and are more likely to be an option for debtors who have little or no ability to repay the amounts owing.
On the business insolvency side, we have seen filings increase steadily since the lows in 2021 and 2022. In 2023, there were 4,810 business filings, which is the highest number since 2011, but it's still not as high as the filing numbers seen in 2008, 2009 and 2010, following the recession.
My office's role with respect to credit card practices and regulations is limited, as an insolvency occurs at the end of the lending cycle and only a small fraction of credit card holders in Canada file an insolvency each year. However, we do collect insolvency data and I thought I could share a few relevant data points.
Debtors have to report all liabilities on their statement of affairs at the start of any insolvency, including any credit card debt. In 2023, 87% of insolvent consumers reported at least one credit card in their liability, with an average amount owing of just under $18,000. This is pretty comparable to 2019, prior to the pandemic, when we saw 89% with one credit card, with debt averaging close to $20,000.
On the reasons for financial difficulty, this is an open text field, so it's not perfect for providing data, but what we can see is that in 2023, around 0.79% of those filing bankruptcies and proposals self-reported that credit cards were the reason for their financial difficulties, which is about the same as in 2019, when it was 0.95%.
On bankruptcies, we also collect the licensed insolvency trustees' perspective on the cause of bankruptcy at the end of the bankruptcy. In that case, overextension of credit was reported as a cause of bankruptcy in 11.68% of consumer bankruptcies.
On demographics, consumers aged 35 to 49 made up 37.5% of insolvency filings in 2023, which is about the same as in 2019. This is the largest percentage share of all age groups.
I'll conclude by highlighting two last things.
First, consumer debtors in Canada are required to participate in two insolvency counselling sessions in accordance with standards established by my office. These sessions are supported by an online curriculum and are designed to promote debtor rehabilitation in support of a fresh financial start. One of the modules deals with the responsible use of credit and covers topics like borrowing and managing the use of credit and debt.
Finally, my office has been working hard in collaboration with partners to provide helpful information to debtors so that they can make the best choices to deal with their debt. We publish an online “Consumed by debt?” brochure in 13 languages. We have an online debt solutions portal and an AI-empowered debt questionnaire. We have issued consumer alerts and we have been undertaking multiple social media campaigns to get the word out to consumers.
This concludes my opening remarks. Thank you once again for the invitation to be here today.
Thank you, witnesses.
In particular, it's always great to see a fellow Nova Scotian here before a parliamentary committee. Professor Charlebois, thank you for coming and for coming in person.
Maybe I can start with you. Professor, we know we have record food bank usage in Canada. Over 2 million people a month are using food banks, which is a level we haven't seen in decades. We also know that credit card debt in Canada has increased about $30 billion since 2015, which is a per capita increase of credit card debt of about 20% since then. In any given month, we know that roughly half of Canadians don't pay off their credit card debt. That's according to the Bank of Canada.
A recent poll by Harris done this year, in 2024, found that the reason people have changed their credit card habits as debt has increased is that the prices of goods and services have gone higher. In essence, people are using credit cards to pay for everyday purchases, according to this, like food and things you would normally not use credit for.
I know we've talked about the cost of living as having an impact on the issue of rising credit card debt, with food being a part of that as people are using credit cards to buy food. The basket of food that Canadians purchased for $100 in April 2021 now costs about $121. That is why people are feeling the pinch.
I'd like you to comment, if you could, a bit about about how much the carbon tax is impacting that increasing food pricing, which is increasing the use of credit cards to purchase food and, therefore, credit card debt.
Ms. Lang, your testimony is actually an eye-opener for me. I was not aware of a lot of things that you mentioned in your opening remarks. Please do send us the trend in insolvencies and bankruptcies for the period of the last five to 10 years if you can, so that we can appreciate.... You brought up a lot of numbers. Reading it will be much easier to comprehend than listening to it.
One think I should say is that I really like the funding model of your agency. Usually, whenever witnesses come from various agencies, the first thing they say is that they need more funds, so I'm glad to see that you are meeting your requirements through your own sources, which is a good thing. I have a couple of questions for you, if time permits, but I will come back to you later.
Professor Charlebois and Ms. Taylor, on this buy now, pay later, you mentioned that it incurs additional debt for consumers. How many consumers, and what percentage of consumers do you think are incurring unreasonable amounts of additional debt due to this BNPL?
I'd like to thank all our guests for being here, both in person and remotely. We are grateful to them, despite the technical problems.
I'm going to follow up on my Liberal colleague's question about buying now and paying later.
The purpose of our study is to examine the behaviour of credit card companies, to assess whether consumers fully understand the ins and outs of the financial products they use, and so on. The committee has, of course, heard from representatives of the banks and a number of companies. Clearly, there are vulnerable consumers in this market. Personally, I don't doubt that. However, I admit being surprised to hear the testimony about the “buy now, pay later” model.
I sometimes see that on offer when I go to a furniture store—the possibility of paying in 36 instalments. The same holds true for ceramic tiles and a central vacuum cleaner, but let's stick to your area of expertise. Let's talk about the possibility of eating now and paying later.
When I do my groceries at the IGA in Saint-Janvier, on Curé-Labelle Boulevard in my riding, I use the automated checkout. The system has never offered me the option of paying later. You have to choose between about 42 options—you're asked whether you have premium cards, whether you have this or that, or whether you want to make a donation.
However, I've never been offered the option of paying for my can of beans in 36 instalments.
Can you tell us what grocery chains do offer that option in Canada?
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The answer is interesting, because we heard from a Fintechs Canada representative, who told us that the problem stems from credit card issuers. He was basically saying that they themselves were simply customer service manufacturers. When we draft the committee's report, I think we'll have to look at the issue of fintechs offering these payment options, particularly for food.
I will now turn to Superintendent Lang, from the Office of the Superintendent of Bankruptcy, since time is short.
When credit cards are used as a financial tool to borrow over the longer term, they strike me as toxic credit tools.
The Office de la protection du consommateur au Québec, or OPC, considers a 35% interest rate to be usurious. As a result, to exceed the 23% or 24% rates on some credit cards, you almost have to do business with organized crime. That means that we really find ourselves at the top of the rate range.
For my part, I note that banks advertise credit cards far more than all the other products that could better suit clients, including personal loans at a preferential rate, plus 1%, lines of credit at lower interest rates, and so on. That's not a scientific observation; it's just an observation.
Here is my question.
For certain toxic substances, such as alcohol, lotteries and cigarettes, there are mandatory education programs to accompany these products.
Shouldn't we have strong warnings about credit card offers? Shouldn't we also, in a way, require banks and issuers to offer other less expensive products to their customers, if these are tools used to borrow over the longer term?
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Thank you for your question.
If I may, I will answer you in English, to ensure that I provide an accurate, complete and comprehensive answer with all the necessary nuances.
[English]
That's a bit outside of my wheelhouse, to speak to what banks should offer.
What I can tell you from our experience and the complaints we receive, high-interest creditors can be very aggressive, both in their marketing and collection behaviour, including ignoring the stay of proceedings that happens when you file an insolvency. In some cases, they are so aggressive that people have been fired from their jobs, because they've received calls every minute from these collectors. In some cases, these people are outside of Canada, mind you.
However, my opinion, personally, going outside of my wheelhouse, would be that there is a need for access to low-cost borrowing for some of these Canadians. If people need to buy now and pay later for food, that might tell you something about their ability to buy food, right? To me, that's a bigger policy question.
Thank you for the good questions, Mr. Garon.
It's interesting. We talk about labelling on cigarettes and other things, but my credit card has an inducement to use it more for getting points. There is advertising on my credit card to do that. One of the recommendations I am thinking about is a warning label on credit cards that reminds us about debt, or something like that—some message you can pull out for financial literacy, because, really, it has shifted to trying to induce us. I really appreciated Mr. Garon's questioning. I'm interested in that Australian study, too.
Ms. Lang, maybe it's because I'm left-handed—so I see things differently and have to operate in this world differently than most people do—but it seems—
Mr. Badawey is making fun of me, which is fine.
Voices: Oh, oh!
Mr. Brian Masse: There's a notion about credit cards causing bankruptcy. When I talk to small retailers and other people, they don't view the credit card as having caused the bankruptcy. However, it's part of their bankruptcy. They got into debt, their business model wasn't working, they extended themselves too much or, sadly, like you noted, they got sick or lost a job. They don't view the credit card as the reason why they're in debt. However, you mentioned these are 87% to 89% of bankruptcy costs.
What do you think about that perspective, in the sense that it may not be the thing that triggers it, but it's the cumulative part later on that is noted as part of the bankruptcy? That seems like a high number. If everybody going bankrupt has a credit card, it seems to me that's part of the problem. It's not the solution to the equation for the person.
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It's often referred to as the snack tax.
When you walk into a grocery store, there are about 4,600 products that are taxable. Most Canadians actually don't realize that.
There's one province in the country that is looking into making sure that people are aware of what's taxable when they visit a grocery store, and that would be Quebec with Bill 72. I testified in Quebec a few weeks ago about this bill, and I was very supportive of what they were trying to do. It's transparency in the aisles, telling consumers what is taxable and what is not. Most people don't look at their receipts.
The biggest issue with taxation, as far as I'm concerned, with CRA rules, is that there is an increasing number of products that are now taxable that weren't before. Granola bars is a good example. If you have six bars in a box, that's not taxable, but if there are five bars, it becomes taxable.
I will continue with you, Superintendent, because you spoke earlier about examples from abroad. You talked about what is happening in Australia.
There’s another country that interests me a great deal, and that is Quebec, where legislative changes are still ongoing and will soon be implemented. Under these changes, the Consumer Protection Act will impose a duty of assessment on banks and financial services co‑operatives. When a person signs a new credit contract, the bank produces a report on the financial capacity to repay it. It includes fixed charges for people applying for credit, rent and so on, as well as all the interest and payments on existing loans.
When it comes to what we call high-cost credit contracts, or when dealing with alternative lenders, the lender must provide this report to the person making the request. That’s the case in Quebec. It seems to me that this legislative change must have been made in response to a real problem with the quality of the information provided to credit applicants when they sign a contract.
How is it that the federal government still doesn’t have a policy like this? In your opinion, when it comes to consumer protection—particularly when it comes to credit contracts—how is it that Quebec is always one step ahead? Finally, do you think that such a policy over in Quebec is likely to mean that fewer personal insolvency cases will end up on your desk?
To our other witnesses here—and then I'll get a quick one in for Ms. Lang another time—from just looking at Statistics Canada data, 90% of Canadians do have a credit card, so it's kind of consistent even to consumer insolvency.
Looking at their debt, a vehicle lease or loan is a significant part of average debt, but that loan can be anywhere from 0% to 6% or 7% financing, depending on the vehicle they have. Outstanding credit balance is anywhere from 5% minimum—I think I've seen the lowest at 5.5% on a credit card—to 20% or 30%.
Personal lines of credit are often used to help consolidate credit card debt for people. That's usually a couple points above prime, depending on your relationship with your bank.
Student loan is the other one, where that's in the smaller range of digits. I actually believe we shouldn't have any interest on student loans, but that's just a personal opinion.
Mortgage on secondary residence is often usually lower than the interest rate range as well. Even though it went up most recently, it's still been historically low. Last is personal loan or other debt liability, which usually is, again, consolidation of debt to a smaller interest rate than the credit card.
I guess my question to you is, if we don't get the buy now, pay late under some type of change, as you've noted, with the increases of GST, shrinkage and so forth, wouldn't it seem that we're maybe setting Canadians up for failure?
If you don't pay with cash, you're going to pay some of the highest interest rates on food and other services from the only payment process you get because you can't use your car loan or your mortgage to get your groceries. We're only giving them the one option, which is the credit card or buy now, pay later.
Mr. Charlebois, I want to ask you some questions.
I note that I was on the agri-food standing committee, and you appeared quite a number of times, so it's great to have you here at INDU.
The Governor of the Bank of Canada has recently said that climate change continues to be the main driver of food price volatility, which is interesting because you also indicated today as well to some degree that global commodity price volatility is caused by climate change. You've estimated that companies would be forced, in a way, to review their cost structure, and you anticipate another wave of shrinkflation in the future.
In the work that you do at the agri-food lab, have you done a study? Has your organization done a study on what is well regarded by some experts, including you, I think here today, that food price volatility is being led by or caused by climate change? Have you done a study on that?
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I know that when I shop, I shop around the perimeter. Just in saying that, I'm understanding of the nutritional density, and preparing your own food is certainly how I choose to eat, but every Canadian has their own choices to make.
I'm sort of interested in the fact that you've made comments fairly regularly about carbon pricing, and I disagree with you strongly, but I want to just tease out some of the things I've heard in connecting these things together and then put a question to you.
In February of this year, the Bank of Canada governor stated at another committee that at $15 per tonne annual increases in carbon pricing raise the average economy-wide price level by 0.1 percentage points. I would argue that this is a relatively small amount. It's not insignificant, but it's pretty small. Would it even show up in the CPI calculations? I'm not sure.
Trevor Tombe, who I think you probably know of, an economist at the University of Calgary, has said that the current cost of carbon pricing would be about 0.15%. That's 15¢ on a hundred-dollar spend at the grocery store. He then traced it through the supply chain and said that it might be as much as about 30¢ on a hundred-dollar spend. That's relatively small. When I hear the Conservatives wailing and screaming about this, it sounds like it's the end of the world, like it's $50 on a hundred-dollar grocery bill, to be honest, the way they make it sound. To me, I'm a fact-based person here. I'm trying to understand what is the real impact.
The other thing I want to say is that the European Central Bank did a study. They said that “higher temperatures alone will” push “up worldwide food prices by between 0.9 and 3.2 per cent every” year. That's way higher, so what I'm trying to say is, isn't the cost of climate change, the impact it has on our food prices, significantly higher—like 20 to 30 times higher by my really gross calculation—than the carbon price?
It's over to you.
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We know that you’re generous with others, but not with me. It doesn’t work, Mr. Chair. I’m the one who is Généreux.
Mr. Charlebois, after reading your article in La Presse this morning, I decided not to use a lot of propane next summer to cook steaks. The effect of the cost of food in the country is unbelievable. And yet, Canada is a significant beef producer. Based on what I understood from your article, decreased meat production means that demand is higher than supply. That is very interesting.
Ms. Lang, with the help of my friend ChatGPT, I went to look up some data relevant to you. In fact, it comes from you. I was surprised to see that if there are fewer bankruptcies, conversely, users work out many more proposals or agreements with credit card issuers or banks.
Is the increase in the number of these agreements a significant trend? Is there not a risk that people will go so far into debt that, in the end, they have to come to an agreement with their creditor, especially a bank, to only pay 10% or 20% of their debts? It could be an endless cycle.
Do you see a problem there, or has that been the norm over the last two years?
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Thank you, Mr. Chairman.
I've been in the food business for over 40 years. That's pretty well my entire life. I recognized quickly as a 10, 12, 15, 25, 30 and a 40-year-old that what impacts food prices most is weather. Climate change is a big part of that. Mind you, for added-value foods, whether they're prepared, or for any food, for that matter, which has any value added to it, the margins are much higher. Frankly, that's where your increases come from, period.
Therefore, as Mr. Turnbull alluded to earlier, we have to buy smart. I see a lot of consumers starting to do that now and the costs of the foods that they're buying are starting to level off because of the smart buying.
I want to go back to what we're actually studying here and that's credit cards. Primarily, today's meeting, with Ms. Lang here, is about credit card debt.
Ms. Lang, I really want to concentrate on you with respect to trying to mitigate some of the challenges that our residents are going through right now, taking more of a proactive approach.
My first question for you is, what role does your office play in pre-emptively assisting Canadians who may face financial difficulties in the future, especially related to credit card debt?
Do you have any proactive approaches or outreach that you would embark on or any awareness campaigns that your organization would actually embark on to be proactive, so folks don't get into credit card debt in the first place?
Rest assured, Mr. Chair, I was being completely altruistic and sympathetic.
I'd now like to turn to Mr. Charlebois.
In a comment you made earlier, you mentioned price increase dynamics among food retailers in Canada. You said margins were a little higher in the U.S., so when wholesale input prices fluctuate, grocers and Walmart don’t necessarily need to increase their prices immediately just to maintain their margins. Here in Canada, margins are lower, so major fluctuations are immediately passed on to consumers.
I find that interesting. To tie it back to our study on credit cards and interchange fees, I wonder whether a drop in interchange fees would be pocketed by merchants or passed on to consumers. According to some critics, grocers would benefit from the lower interchange rates we’re proposing. That said, I wonder whether slightly larger margins on the cost that interchange fees represent could mean grocery stores might not need to raise prices as much. I'm talking about input price fluctuations over the next two, three or four years, in this two or three-year horizon.
How can we criticize grocery stores for not immediately lowering or adjusting prices as soon as interchange fees come down, if it means they'd have the leeway not to have to raise prices later?
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Thank you, Mr. Chair. It was a fascinating discussion of cap and trade and the carbon tax, which we now have because of the Conservatives in Ontario, thanks to a $2-billion bill with it.
However, that's not what I want to get on about as we finish this part. I want to rightly bring it back to the fact that, again, food and purchasing is now going on with buy now, and pay later payment systems and what this means for the future and so forth. One thing that's changing in the grocery store sector—and I hope you can highlight whether there has been much study on this—is that they're offering to do their own shopping for customers now, and in there, their advertising hasn't been consistent with regard to food pricing. Also, some of them have fees or deposits that are required to be part of that. Then, what I noticed—and I don't know if there are some good stats on this or maybe it's too early yet—is that it seems that seniors and people with disabilities and so forth might use those services more, and if that's an increased cost.... Almost all of those you don't pay cash for. They're all delivery services that go onto, again....
What accountability or measures are there in that system? If the retailers are now encouraging more practices to move that.... If it has different pricing and costs for doing it, and then you're using the systems that put you into the higher bracket of borrowing again, should there be more truth in advertising to this? Should there be a service for just the regular cost of doing business that's rolled into the whole model, especially if seniors and people with disabilities are a primary target for that?
I think some of this is also a response to those other independents, like Uber Eats and the other ones, that are getting into that market too. I can understand why they're creating a system there. Third parties are using access to their system, so why not have their own system? Again, I've run into issues, and I think there hasn't been the most overt transparency with regard to the cost of using that service.