CLHIA comments on OSFI Corporate Governance Guideline for FRFIsRelease Date: 01/15/2013 Staff Reference: Frank Zinatelli
January 15, 2013
Mr. Vlasios Melessanakis
Director, Policy Development
Office of the Superintendent of Financial Institutions
255 Albert Street
Ottawa, Ontario K1A 0H2
Dear Mr. Melessanakis:
Re: Comments on Revised Guideline on Corporate Governance
Thank you so much for providing us with the opportunity to comment on the revised version of the Guideline on Corporate Governance (“the Guideline”) which you shared with us in mid-December.
While in our review we have focused, as requested, on “fatal flaws” in the document, we have also noted some other points that are more in the realm of inconsistencies, either within the Guideline itself or with other OSFI documents or FRFI legislation. We have noted these as well, so that the final Guideline that will be published shortly can be as workable as possible for both OSFI and regulated institutions. For your ease of reference, as much as possible, we refer specifically to the relevant page and paragraph of the Guideline...