Executive Summary

Background and Research objectives

The Office of the Superintendent of Financial Institutions (OSFI) is the primary regulator of federally regulated financial institutions and federally administered pension plans. To help assess how well it is achieving its mandate, OSFI undertakes consultations with senior executives within the financial community for their perceptions of OSFI's performance.

A key element of OSFI's stakeholder consultations program is a biennial survey of CEOs of all federally regulated financial institutions, including banks and other deposit-taking institutions, and life and property and casualty insurance companies.

The research objective of the 2014-15 Financial Institutions Survey (FIS) is to provide a high level assessment of the Office of the Superintendent of Financial Institution's (OSFI) overall performance on a series of core measures, including:

• Overall impressions;
• Impressions of OSFI's guidance, approvals process and supervisory activities; and,
• Assessments of emerging key issues.

This research will be used to help meet OSFI's performance reporting requirements and to help identify areas of improvement for OSFI going forward. Where relevant, the 2014-15 results are compared to three previous research waves to understand how perceptions of OSFI's performance have changed over time.

Methodology

A list of active financial institutions (246) was provided by OSFI to Environics, all of whom were invited to participate in this research. These institutions comprise all active deposit-taking institutions and insurance companies supervised by OSFI meaning that the survey represents an attempted census of these financial institutions.

The research consisted of an online survey with 106 senior executives of active deposit-taking institutions (DTIs) and insurance companies supervised by OSFI, between September 23 and October 22, 2014. This represents a response rate of 43%.

Since the entire population of active financial institutions was invited to participate in this study there is no margin of sampling error to be estimated or reported. The moderately good response rate and the similarity of responding institutions to the entire population on key characteristics (industry sector, asset size) indicates that the results are likely to be representative of financial institutions regulated by OSFI.

A more detailed description of the methodol­ogy used to conduct this study is included in the final report, along with a copy of the questionnaire. The cost of this research was $33,219.46 (HST included).

Key findings

• Overall satisfaction with OSFI remains high (86%), but the proportion who are most positive ("very satisfied") has slowly declined over the past few waves of the survey.
  
• Views of OSFI's performance on most other measures remain strong and stable since 2012-13.
  • The only statistically significant change since 2012-13 is an increase in positive ratings for OSFI's performance in "consulting with the industry when developing guidance" (39% very good, up from 22%).
  • There have also been small (but not statistically significant) improvements in ratings for OSFI's performance on "responding to market changes or industry suggestions" (77% overall good, up from 69%) and "striking an appropriate balance between prudential considerations and industry's need for competitiveness" (60% overall good, up from 53%).
    
• Small and mid-sized (SMS) DTIs and insurance companies hold moderately positive views about the extent to which OSFI scales its supervision (63% very good or good) and applies guidance (54%) taking into account the nature, size and complexity of their institutions. Ratings of how good a job OSFI does at conveying the scalability of its guidance are lower (43%).
  • While these are new questions and thus trend data is not available, it is notable that these ratings are lower (relatively speaking), suggesting room for improvement.
• The overall pattern of results suggests more positive momentum among insurance companies than among DTIs. Insurance companies are largely responsible for the improved ratings for OSFI and also tend to rate OSFI more positively on SMS-related issues, which may reflect that the insurance sector (which includes Life and P&C together) has fewer SMS-related issues to consider.
  
• OSFI receives stronger ratings for its efforts to gather input from small and mid-sized institutions than for communicating back how that input was taken into account in the final decisions.
  • Small and mid-sized institutions give OSFI more positive ratings for "providing the opportunity to comment on revised or proposed guidance" (45% very good) than on the "transparency of the consultation process" (25% very good) or "communicating its response once feedback has been provided" (21% very good).
    
• There is moderate awareness among small and mid-sized DTIs (63%) of the creation of a "Small and Mid-Sized Advisor" role, and a majority (63%) of those aware of it say the objectives of the role have been well-communicated.
  
• There are no statistically significant differences in views between institutions with assets of $1 billion or less versus more than $1 billion, and this holds true for all survey results.

Political neutrality statement

I hereby certify as a Senior Officer of Environics Research Group that the deliverables fully comply with the Government of Canada political neutrality requirements outlined in the Communications Policy of the Government of Canada and Procedures for Planning and Contracting Public Opinion Research. Specifically, the deliverables do not contain any reference to electoral voting intentions, political party preferences, standings with the electorate, or ratings of the performance of a political party or its leader.

Sarah Roberton
Senior Associate, Public Affairs
Environics Research Group
sarah.roberton@environics.ca
(613) 230-5089 ext. 224