Lobbied Canada

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Ben Gully

Deputy Superintendent, Office of the Superintendent of Financial Institutions Canada (OSFI)1 communications in the past year

Lobbied by

The Toronto-Dominion Bank

10

Financial Services Policy in respect to adhering to banking. Cyber Security Policy as it applies to financial institutions Consumer Issues as it pertains to government changes in policies in relation to financial institutions Privacy Act as it applies to the protection of customer and bank information Personal Information Protection and Electronic Documents Act (PIPEDA) Review in respect to providing input on privacy regulations Income Tax Act as it applies to corporate taxation, investment and international taxation. Housing Policy as it applies to financial institutions Diversity and Inclusion Policy as it applies to financial institutions Data Transfer Policy as it applies to financial institutions Climate Change Strategy in respect to government's plans for a strategy on climate change Canadian Payments Association Act in respect to the five year financial system review Canada Labour Code in respect to employment standards Bank Act in respect to the five year financial system review. Agricultural Support Programs in respect to lending programs

Work with the government to protect Canadians against fraud and scams. Stablecoins Act in respect to the government's strategy on digital assets Artificial Intelligence in respect to the government's AI strategy Natural resources in respect to the development of Canada's natural resources including energy, minerals, forests and water. Imposition of tariffs and renewal of Canada, US, Mexico trade agreement Financial Services Policy in respect to adhering to banking. Cyber Security Policy as it applies to financial institutions Consumer Issues as it pertains to government changes in policies in relation to financial institutions Privacy Act as it applies to the protection of customer and bank information Personal Information Protection and Electronic Documents Act (PIPEDA) Review in respect to providing input on privacy regulations Income Tax Act as it applies to corporate taxation, investment and international taxation. Housing Policy as it applies to financial institutions Diversity and Inclusion Policy as it applies to financial institutions Data Transfer Policy as it applies to financial institutions Climate Change Strategy in respect to government's plans for a strategy on climate change Canadian Payments Association Act in respect to the five year financial system review Canada Labour Code in respect to employment standards Bank Act in respect to the five year financial system review. Agricultural Support Programs in respect to lending programs

Canadian Bankers Association

8

Discussions relating to the legislative, regulatory, and policy developments related to digital currencies and cryptoassets Providing input on the prudential regulation of the banking sector Providing input on amendments to the Bank Act Providing input on federal budget measures that may impact the banking sector Discussions on supporting women’s advancement, career opportunities, and equitable outcomes in the financial services sector Discussing the Accessible Canada Act with the purpose of identifying, removing and preventing barriers for people with disabilities Discussions on strategies to mitigate tariff risks and navigate the review of the Canada-United States-Mexico Agreement Providing input on effective Artificial Intelligence regulation to balance risks and foster innovation Providing input on the regulatory framework to facilitate the process to become a federal credit union and support their operations Discussing plans on the Data Collection Modernization initiative Providing views on the Macroeconomic Stress Test (MST) 2.0 review Discussing Bill C-27 – Digital Charter Implementation Act, 2022, relating to the privacy and artificial intelligence provisions Discussions relating to the efficiency and effectiveness of the financial sector regulatory system Discussions on consumer issues relating to potential postal strike ensuring an appropriate scope of guidance Providing inputs on criminal interest rate as it relates to the calculation of the rate and exclusions Office of the Superintendent of Financial Institutions guidelines with respect to capital adequacy requirements, prudential limits and restrictions, accounting and disclosure, and sound business and financial practices Providing inputs on OSFI regulations and draft guidelines including in connection with culture, integrity and security, third-party risk, and operational risk Providing input on the development of the Consumer-Driven Banking Framework Providing inputs on Basel III Implementation with respect to capital floor phase-in and risk weights Providing inputs on Competition Act amendments Personal Information Protection and Electronic Documents Act (PIPEDA): seeking workable, practical approaches in the reform of PIPEDA Excise Tax Act with respect to Goods and Services Tax (GST) and Harmonized Sales Tax (HST) Support the development of an innovative, efficient, and secure payments ecosystem in Canada that benefits consumers Support the goals outlined in the National Cyber Security Strategy and collaborate with government, including the Canadian Centre for Cyber Security, to strengthen Canada’s cyber resiliency The Access to Basic Banking Services: seeking to clarify appropriate identification for opening accounts and to make account opening procedures more workable U.S. Mexico Canada Agreement (USMCA), trade agreements with other jurisdictions, World Trade Organization rules regarding cross-border trade in financial services Support the Government initiative of modernizing the Employment Equity Act and provide input to further strengthen the Act. Discussion relating to agricultural financing, including the efficient administration of the Advance Payments Program and the Canada Loan Administration Act Discussions relating to the development of Financial Consumer Protection Framework and voluntary commitments to promote protection for consumers Capital markets statutory, regulatory and self-regulatory organization regime applicable to banks as corporate issuers and their provincially regulated subsidiaries that are capital markets participants Discussion relating to housing finance framework, including reforms to expand housing supply, mortgage underwriting regulations and covered bonds Providing inputs on climate standards and disclosures Corporate governance statutory and regulatory regime for banks Canada Labour Code with respect to (i) impact on bank management of human resources, (ii) review of Part III of the Canada Labour Code, (iii) flexible work

BMO Financial Group

4

The Consumer Driven Banking Act and related regulations as it applies to banks The federal government’s framework for stablecoins and digital assets Canada Deposit Insurance Corporation Act as it relates to banks and the administration of the deposit insurance framework Federal government programs and policies related to Artificial Intelligence regulation Housing finance framework, including reforms to expand housing supply, mortgage underwriting regulations and covered bonds Financial institutions with respect to Canada/US relationship and trade policy Office of the Superintendent of Financial Institutions guidelines with respect to capital, liquidity, and non-financial risk The Canadian Payments Act, as it relates to management of Canada’s payment system and payments modernization The modernization of the supervisory framework for financial institutions as it relates to the responsibility for administering prudential and consumer measures Requirements for financial institutions as they relate to corporate governance rules under the Bank Act Promotion of the importance of a competitive financial sector in achieving improved economic development in Canadian regions Providing inputs with respect to capital requirements as they relate to Basel III and lending for businesses Official languages policy as it relates to financial services. Federal government programs and policies supporting growth for small businesses Federal government programs and policies respecting financing for infrastructure projects Federal government programs and policies on employment and training as they pertain to financial institutions Federal government programs and policies respecting consumers as they pertain to relationships with financial institutions Federal government programs respecting financing for the agriculture industry Federal government programs respecting financial services for Indigenous communities The Bank Act and the National Housing Act as they relate to potential measures affecting housing affordability and lending Promotion of resources to support mental health and well-being of Canadians Promotion of financial services available to finance Canadian infrastructure development; sharing of international best practices with respect to infrastructure policy, particularly in terms of options for project financing arrangements Privacy legislation and acts with respect to the banking industry’s collection, use and protection of personal information Office of Superintendent of Financial Institutions Guidelines regarding accounting rules regulating financial institutions Income Tax Act with respect to corporate income tax, capital tax, international taxation, personal taxation, and registered saving products Impact of federal national security policy as it relates to the banking sector Financial services policy with respect to study of retirement income security Federal government programs and policies to combat financial crimes Federal government programs and policies related to sustainability, natural resources and climate change in support of achieving net zero targets Federal government position with regard to ongoing discussions on international financial regulation reform, as it pertains to Canadian banks Federal government policies affecting Canada’s payment systems as well as access to financial data Bank Act with respect to its impact on financial sector

CANADIAN IMPERIAL BANK OF COMMERCE ( CIBC)

4

The Proceeds of Crime (Money Laundering) and Terrorist Financing Act, initiatives for enhancement of reporting mandatory information, and risk assessment methodology. The introduction of policies, programs or legislation related to "Open Banking". The Canadian labour force and labour mobility as it relates to the Express Entry program. Policies related to Canadian economic growth, and international trade. Policies related to Canada's development of natural resources. Policies related to asset recycling and industry investment in public infrastructure development . Policies and programs that affect the Canadian housing market and lending practices. Policies and programs related to gender diversity, inclusion and accessibility. Personal Information Protection and Electronic Documents Act (PIPEDA), the Privacy Act, and any legislation and associated regulations with regard to privacy and security, identity theft risks, use and protection of information Payment Processing System with regard to rates, fees, oversight of credit and debit procedures Office of the Superintendent of Financial Institutions Act (OSFI) and regulations, in respect of regulatory compliance for banks Immigration policies and programs to address labour shortages and market needs. Canadian Payments Act, as it applies to applicable legislative reviews and the government's Payment's Modernization initiative. Canada Labour Code, Parts II and III Bank Act and regulations, in respect of the five year financial system review, as well as any changes resulting from the review.

National Bank of Canada

4

Discussions quant au cadre réglementaire applicable aux banques, incluant la Loi sur les banques et les lignes directrices du Bureau du surintendant des institutions financières Loi sur la protection des renseignements personnels, activités liées à la mise en place des dispositions de la loi Discussions relative au cadre de financement du logement, y compris les réformes visant à accroître l'offre de logements, les réglementations en matière de souscription de prêts hypothécaires et les obligations sécurisées Perspectives et politiques relatives à la croissance de l'économie canadienne et aux projets d’intérêt national Révision réglementaire du projet d’acquisition de certains portefeuilles de la Banque Laurentienne dans le cadre de l'acquisition de cette dernière par la Banque Fairstone Fournir des commentaires sur les mesures budgétaires fédérales susceptibles d’avoir une incidence sur le secteur bancaire Discussions concernant la stratégie nationale de cybersécurité du Canada Discussions sur la réglementation visant l'intelligence artificielle Discussions concernant les plans de protection des infrastructures essentielles Discussions concernant le financement des petites entreprises, y compris le Programme de financement des petites entreprises du Canada Fournir des commentaires sur l’élaboration du Cadre canadien des services bancaires pour les gens Discussions sur les stratégies visant à atténuer les risques tarifaires Certains sujets liés à la Loi sur le recyclage des produits de la criminalité et le financement des activités terroristes incluant les exigences d'identification Soutenir le développement d’un écosystème de paiements innovant, efficace et sécurisé au Canada au bénéfice des consommateurs Discussions relatives au développement d'un cadre de protection des consommateurs financiers et engagements volontaires pour promouvoir la protection des consommateurs Discussions relatives au cadre de protection des consommateurs Loi sur l'impôt concernant l'impôt sur les entreprises, l'impôt sur le capital, la taxation internationale, l'impôt personnel et les produits d'épargne enregistrées Collaboration avec le gouvernement pour protéger les Canadiens contre la fraude et les arnaques Commentaires relatifs au plancher de fonds propres de Bâle III Révision réglementaire du projet d’acquisition de la Banque canadienne de l’Ouest Règlement sur le commerce d'assurance, activités de lobbyisme liées à la mise en oeuvre de la loi de façon générale, et plus précisément dans le cadre de la révision quinquennale de la législation en matière bancaire Programme des travailleurs étrangers temporaires Loi sur les sociétés d'assurance, activités de lobbyisme liées à la mise en oeuvre de la loi de façon générale, et plus précisément dans le cadre de la révision quinquennale de la législation en matière bancaire Loi sur les prêts aux petites entreprises, activité de lobbyisme liée à l'application de la loi en général et plus particulièrement à l'égard des règles concernant le crédit consenti Loi sur les banques, activités de lobbyisme liées à la mise en oeuvre de la loi de façon générale, et plus précisément dans le cadre de la révision quinquennale de la législation en matière bancaire et dans l'application des dispositions de la Loi et du Règlement visant les consommateurs dans les opérations bancaires Loi sur le recyclage des produits de la criminalité et le financement des activités terroristes, activité de lobbyisme liées à l'application de la loi de façon générale, et plus précisément en ce qui concerne la révision de la règlementation applicable à la Banque Loi sur la société d'assurance-dépôts du Canada, activités de lobbyisme liées à la mise en oeuvre de la loi de façon générale, et plus précisément dans le cadre de la révision quinquennale de la législation en matière bancaire et dans l'application des dispositions de la Loi et du Règlement visant les consommateurs dans les opérations bancaires Loi sur la société canadienne d'hyp

Canadian Western Bank

3

Housing policies and CMHC programs National Security/Security in respect of its implications for financial institutions. Proceeds of Crime (Money Laundering) and Terrorist Financing Regulations with respect to the proposed changes Personal Information Protection and Electronic Documents Act (PIPEDA) as it applies to the banking industry’s collection, use, disclosure, and protection of personal information Payment Clearing and Settlement Act as it applies to the five year financial system review Office of the Superintendent of Financial Institutions Act as it applies to regulation and compliance Investment Canada Act as it applies to competitiveness Income Tax Act as it applies to corporate taxation, investment, competitiveness and registered savings products Financial Consumer Agency of Canada Act as it applies to consumer protection Employment Equity Act as it applies to banks as employers Competition Act as it applies to banks and competitiveness Canadian Payments Association Act as it applies to the five year financial system review Canada Small Business Financing Act as it applies to credit for SMEs Canada Labour Code as it applies to banks as employers Canada Deposit Insurance Corporation Act as it applies to the five year financial system review Bankruptcy and Insolvency Act in respect of its implications for banks Bank of Canada Act as it applies to the five year financial system review Bank Act and other financial services legislation as they apply to financial institutions in the context of the five year financial system review Anti-Spam legislation as it applies to anti-spam requirements

Citibank Canada

3

Providing inputs on OSFI regulations and draft guidelines including in connection with culture, integrity and security, third- party risk, and operational risk Providing input on effective Artificial Intelligence regulation to balance risks and foster innovation Support the goals outlined in the National Cyber Security Strategy and collaborate with government, including the Canadian Centre for Cyber Security, to strengthen Canada’s cyber resiliency Proceeds of Crime (Money Laundering) and Terrorist Financing Act and Regulations with respect to a number of issues including identification requirements Providing input on federal budget measures that may impact the banking sector. PIPEDA discussion seeking workable, practical approaches in the reform of PIPEDA Supporting the development of an innovative efficient, and secure payments ecosystem that benefits consumers Providing input on the development of the Consumer-Driven Banking Framework Working with government to protect Canadians against fraud and scams General information regarding financial institutions and an introduction to Citi Canada Discussion relating to housing finance framework, including reforms to expand housing supply, mortgage underwriting regulations and covered bonds. Providing inputs on Basel III Implementation with respect to capital floor phase-in and risk weights. Discussions on strategies to mitigate tariffs and navigate review of CUSMA Responding to inquiries and speaking with government organizations about global banking and impacts on Canada Responding to inquiries and speaking with government organizations about global banking and impacts on Canada General discussions regarding Anti-Money Laundering and Proceeds of Crime and the PCMLATF legislation General discussions, information regarding foreign interference and the OSFI Integrity & Security Guideline General discussions about climate change and government policy

Discussions on strategies to mitigate tariffs and navigate review of CUSMA Responding to inquiries and speaking with government organizations about global banking and impacts on Canada Responding to inquiries and speaking with government organizations about global banking and impacts on Canada General discussions regarding Anti-Money Laundering and Proceeds of Crime and the PCMLATF legislation General discussions, information regarding foreign interference and the OSFI Integrity & Security Guideline General discussions about climate change and government policy

ROYAL BANK OF CANADA

3

Financing infrastructure projects, as it relates to investments by insurers. Discussions relating to the development of Financial Consumer Protection Framework and voluntary commitments to promote protection for consumers. Communicating with the government on the 2026 Spring Economic Update, including their plan to introduce Canada’s first sovereign wealth fund—the Canada Strong Fund. Discussions with respect to federal government policies to improve the economic potential, contribution and capacity of Canada's Indigenous communities. Capital markets statutory, regulatory and self-regulatory organization regime applicable to banks as corporate issuers and their provincially regulated subsidiaries that are capital markets participants. Discussions regarding general economic conditions and fiscal policy that can stimulate economic growth, competitiveness and social progress. Providing inputs on climate standards and disclosures. Providing input on the prudential regulation of the banking sector. Providing input on federal budget measures that may impact the banking sector. Discussions on policies, legislation, or regulations related to stablecoins and other digital assets. Financial Institutions, with respect to the Canadian regulatory framework. Financial institutions with respect Canada/US relationship and trade policy. Providing inputs on Basel III Implementation with respect to capital floor phase-in and risk weights Advocate for globally competitive policies that position artificial intelligence as a positive economic driver, and support the responsible development, deployment, and use of AI in business. Prescription drugs - Seeking to raise awareness about prescription drug & workplace benefit coverage. Federal government programs and policies respecting consumers as they pertain to relationships with financial institutions. The Proceeds of Crime (Money Laundering) and Terrorist Financing Act, initiatives for enhancement of reporting mandatory information, and risk assessment methodology. Work with the government to protect Canadians against fraud and scams. Providing input on the development of the Consumer-Driven Banking Framework Office of the Superintendent of Financial Institutions guidelines with respect to capital adequacy requirements, prudential limits and restrictions, accounting and disclosure, and sound business and financial practices Income Tax Act as it applies to corporate taxation, personal taxation, registered saving products, investment and competitiveness. Support the goals outlined in the National Cyber Security Strategy and collaborate with government, including the Canadian Centre for Cyber Security, to strengthen Canada’s cyber resiliency. The financial sector regulatory framework as it relates to electronic payments, credit, debit and interchange rates. Regulatory review of the proposed acquisition of HSBC Canada. Policies and programs that affect the Canadian housing market and lending practices. Personal Information Protection and Electronic Documents Act (PIPEDA), the Privacy Act, and any legislation and associated regulations with regard to privacy and security, identity theft risks, use and protection of information. Payment Clearing and Settlement Act as it applies to the five year financial system review. Over-the-counter (OTC) Derivatives: seeking to void duplicative OTC derivatives regulation and negative effects on the competitiveness of Canadian businesses and further negotiations regarding derivatives regulation with foreign regulators in order to avoid duplication of requirements. Initiatives related to gender diversity, inclusion and accessibility as they apply to financial institutions. Financial Consumer Agency of Canada Act as it applies to consumer protection. Employment Equity Act as it applies to banks as employers. Discussions to understand and determine the nature of the banking industry’s role in facilitating COVID-19 government benefit programs and about the possible challen

Scotiabank

3

Discussions around defence spending and the Defence Investment Agency as it relates to financial institutions Stablecoin Act in respect to the government's strategy on digital assets Providing input on federal budget measures that may impact the banking sector Income Tax Act as it applies to corporate taxation, personal taxation, registered saving products, investment, and competitiveness. Data and artificial intelligence policy, as it relates to financial institutions. Discussions on how to mitigate tariff risks and ensure the financial sector’s views are properly captured in trade dialogues. Proceeds of Crime (Money Laundering) and Terrorist Financing Regulations, with respect to a number of issues including identification requirements Financial Institutions, with respect to the Canadian regulatory framework. Financial Institutions with respect to the review of the global and Canadian regulatory framework. Financial Institutions, as it relates to consumer protection Legislation and regulation as it relates to data policy and governance issues International Trade, with respect to the Government of Canada's international relations strategy as it relates to the government's diplomatic and trade relations with Latin America and specifically the Pacific Alliance. Financial Institutions with respect to Environment, Social and Governance issues (ESG). Financial Institutions, with respect to small business banking Financial institutions, as it relates to housing Cyber Security policy as it applies to Financial Institutions Agricultural Support Programs in respect to lending programs

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