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2022 UPDATE | Canada

2022 UPDATE | Canada

by Starling Insights

Starling Insights Editorial Board

May 15, 2022



While Canada has not suffered misconduct scandals to the same degree as many other financial markets, it has not entirely avoided such concerns. Among a global push to hold auditors to account for the quality of their audits and for their frequent failure to identify seemingly obvious fraud, for instance, in February 2022 PwC Canada was fined more than $900,000 by Canadian and US accounting regulators over exam cheating that involved some 1,100 of its auditors.1


In July 2021, Peter Routledge took the helm at the Office of the Superintendent of Financial Institutions (OSFI), when Superintendent Jeremy Rudin, who had held the position for the previous seven year term, retired.2

Routledge had served previously as chief executive officer of the Canada Deposit Insurance Corporation (CDIC). While at CDIC, Routledge led a successful transformation of its culture, strategy, and technology. Earlier, he held a variety of leadership roles in the financial services industry, both in Canada and abroad. “He has distinguished himself in both the public and private sectors and I know his leadership and eye for innovation will be of immense value,” Finance Minister Chrystia Freeland said in a statement, “particularly as we navigate the end of the COVID crisis and Canada’s economic recovery.”3  (See also our Interview with Superintendent Routledge)

Diversity and Inclusion

OSFI has sought to be more intentional in establishing an organizational culture, internally, that supports its work in regulating and supervising the financial sector. This explicitly includes priorities regarding its diversity. Superintendent Peter Routledge stated that OSFI would work “obsessively” on improving the regulator’s diversity, in a September 2021 speech.4

“Having a diverse workforce is a valid policy end, in and of itself,” Routledge wrote. “It reflects Canadian reality, the Canadian mosaic, and it is the right thing to do. And we pursue diversity for another very important reason,” he added. “Diversity enables OSFI to leverage varied perspectives on the risks we face. We will be better prepared for whatever lands on our doorstep if we have an organization with diverse skills and mindsets drawn in full proportion from the Canadian mosaic.”

Culture and Compliance Supervision

In a speech entitled, “Clear Expectations: OSFI’s Priorities and Agenda,” Routledge laid out the regulator’s views on the importance of culture as a driver of sound decision-making and operational resilience:

Whether you are a regulated entity or the regulator, ensuring you have a responsible and forward-thinking organizational culture in place will not just help mitigate the impact of any future “black swan” events — and rest assured, COVID-19 will not be the last of these — it will also blunt any criticism that due consideration has not been given to acting responsibly and prudently.5

In a December 2021 letter to Federally Regulated Financial Institutions, OSFI announced intent to issue a consultative document regarding culture and reputational risk in early 2022.6 With this, OSFI proposes to issue draft guidance to consult on culture risk management by year end.

The letter, which was published in April 2022, laid out plans to issue a principles-based, outcomes-focused culture risk management guideline for consultation in late 2022, also seeking comments on proposed outcomes of effective culture risk management and on how culture risks can affect federally regulated pension plans.7

As part of its future guidance, OSFI will expect Federally Regulated Financial Institutions (FRFIs) to establish and maintain a robust approach to managing and overseeing culture risks. The approach includes attention to: Leadership; Compensation, People Management & Incentives; Accountability & Ownership; Risk Mindsets & Behaviors; Group Dynamics & Decision-Making; and, taken together, a firm’s Resilience.


In October 2020, the Ontario Securities Commission (OSC) published the Charter for its new Office of Economic Growth & Innovation, with the stated goal of “supporting economic growth and innovation in Ontario’s capital markets.”8

In a May 2021 Linkedin post, Office director Pat Chaukos wrote that, in addition to supporting fintech businesses through its launchpad program, the Office would aim to expand its reach.9

“What’s changed is that we’re striving to support the whole financial innovation ecosystem — not just individual businesses,” she wrote. “We aim to build new ties with incubators, accelerators, and innovation centres, as well as VCs. We’re also working on ways to help connect service providers with eligible businesses for advice that falls outside our specialty.”

Other Articles in the 2022 Compendium of Regulatory Priorities Series

Introduction to the 2022 Compendium of Regulatory Priorities

United States


United Kingdom









Hong Kong


United Arab Emirates


New Zealand

South Africa

Global Regulators

  1. Michael O’Dwyer, “PWC Fined Over Exam Cheating Involving 1,100 of Its Auditors,” Financial Times, Feb. 25, 2022.
  2. Stefanie Marotta, “Peter Routledge to Become Next Head of Canada’s National Banking Regulator,” Financial Post, June 24, 2021.
  3. Department of Finance Canada, “Government Announces Peter Routledge as Next Superintendent of Financial Institutions,”
    News Release, June 24, 2021.
  4. Peter Routledge, “The Fierce Urgency of Now: The Canadian Financial Sector in a Post-Pandemic World, a Prudential Perspective,” Remarks at the 2021 Global Risk Institute Annual Summit, Sept. 29, 2021.
  5. Peter Routledge, “Clear Expectations: OSFI’s Priorities and Agenda,” Remarks on OSFI Webcast, Nov. 4, 2021.
  6. Office of the Superintendent of Financial Institutions, “Operational Resilience Consultation Results Summary,” Industry Notice, Dec. 10, 2021.
  7. Office of the Superintendent of Financial Institutions, “Culture Risk Management,” Industry Notice, Mar. 15, 2022.
  8. Ontario Securities Commission, “OSC Publishes Charter for Innovation Office,”News Release, Oct., 28, 2020.
  9. Pat B. Chaukos, “Unlocking the Power of Innovation,” LinkedIn, May 18, 2021.


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