Tan Sukhera 00:03
Hello, everybody, and welcome to Canadian regulatory fireside chats. Now, before the pandemic, gr folks used to get together on Fridays, especially at lunch and network, and they would learn from their peers and kind of troubleshoot on different issues and brush up on different tips and things like that. But unfortunately, now, it’s a bit of a thing of the past. And it’s really in this spirit that we started Canadian regulatory fireside chats, there’s really been a massive lack of information out there, especially in our social media feeds about the fantastic work that’s being done, you know, people in the space are up to and so we’re really happy to be part of the solution. Right? Now, this series is meant to be a platform for champions of industry, from government relations environments, policy, regulatory teams, to share their take on best practices, overcoming challenges and educating others. Now, if you’re a fan of the chats, please feel free to like and share and join into the conversation. And now of course, it’s time for a little bit of housekeeping roles. So for those who don’t know, it’s a 30 minute session, there’s a q&a in the chat. So you can take a couple of minutes now. And if you want to locate that within the zoom chat, you can see the q&a there. The recording is going to be shared after the event. And if you’re somebody who likes to tweet, we always, you know, we welcome that you can go ahead and tweet us hashtag fireside chats and also our handle is at no it so at GE n o w i t. Now if you’re interested in becoming a speaker, you can always give us an email at email@example.com. And there’s always different topics and industries. And we really want to share as much insights as possible. And on that note, I am your host tansa kara, I’m the VP of insights for no ink. And again, there’s always just a little a note here that we’re always looking to improve. We’re learning we’re eager to kind of get more feedback from you guys. So now this talk is powered by Noah ink. And for those who don’t know, we are a media regulatory and business intelligence company. We use AI and machine learning to actively search federal, provincial and municipal government sources of information online. And it includes a whole bunch of different sources that are really hard to find from things like the hands or the parliament Gazette committees debates, request for consultations, regulatory bodies, government agencies, live video feeds, and more you can visit www.att.com for more information. Now it’s my favorite time where I get to introduce our speaker for today on episode 11 of fireside chats. It’s called stepping into the GR pond. And we’ve got Susan with us today. So Susan is, you know has over 20 years of experience in the public policy field. Currently She’s the director of policy and regulatory affairs at the independent financial brokers of Canada, where she’s been since 2004. Now ISP is a national professional association with over 3000 members who are licensed financial practitioners. During her 10 years Susan has helped advance ifvs public stature into a respected sought after stakeholder in the financial services community. She’s spoken at various industry events and currently represents ISB on the financial services regulatory authority on Ontario’s life and insurance health insurance stakeholder Advisory Committee. Without any further ado, take it away Susan.
Susan Allemang 03:31
Um, good afternoon. I’m excited to be with you here today. And thank you can for the invitation to to speak. As Ken said, my name is Susan Elam, and I’m the director of policy and regulatory affairs at independent financial brokers of Canada, or IV as we’re more commonly known. My position at IP encompasses government relations, policy, Regulatory Affairs and compliance. While these well this combination of responsibilities may seem broad, in the context of my organization, it makes sense. If you think about it, government relations and policy development are intertwined and can be thought of as at the front end of the political and public policy process. It alerts us to the actual or potential impacts of government action. The regulations that flow from legislation, in effect put the meat on those bones. regulations to find her legislative changes will impact stakeholders and usually offer opportunities to help define what the regulatory rules will look like. So today, I’m going to take a little different tack than what I think has been taken in previous fireside chats. Because when 10 approached me about possible topics of interest to this audience, we talked about the challenges that smaller stakeholders or stakeholders wanting to build their gr practice or those with limited resources like facing engaging in the public policy process. Often the perception is that government relations is a function reserved for senior executives and legal staffers. And while this is often true, particularly for large organizations with extensive resources, it does not have to be the case. There’s a lot of room in this space for a wide variety of organizations, whether they’re small, voluntary, charitable, even individual members public to participate. It’s really about helping decision makers understand your organization’s position on a proposed direction or policy stance, and the potential impacts on your stakeholder group. So effectively, using public consultation opportunities to advance the interests of your stakeholders is a great way to achieve this because they are accessible to any stakeholder regardless of their size, resources or complexity. I think it’s fair to say that the internet has democratized access to information such that today there are many opportunities to find research reports, white papers, and content specific to your industry at no or low cost. This has removed barriers that in the past may have prevented or limited the ability of some stakeholders to participate in the public policy process. Engaging in government relations can be an exciting and rewarding way to facilitate the exchange of information with decision makers in your field, and influence the development of good public policy while adding value to your constituent group or groups. So let’s get started. As the title of this presentation suggests, using your organization’s purpose, to establish meaning, will position you to create the impact we all want from rGr efforts. You will find a return to these three concepts throughout this talk, because they are the building blocks of success. So let’s start with purpose. Without knowing your organization’s purpose, you can’t attract stakeholders to join or be associated with you. There’s strength in numbers, you might have a mission statement or a vision that identifies your organization’s purpose. But until your group’s members commit to the meaning of your purpose, and it’s relevant to them, they will remain aloof or distant. They need to see the organization’s purpose as making their work lives or membership real to them. lofty ideals are great, but if I want your support, I have to, I have to demonstrate why my organization’s purpose has meaning to you. Once you have these two concepts nailed down, you’re ready to have impact on those you represent and those outside of your organization. Ultimately, this is when your gr work will excel. So let’s use my employer as an example of how purpose and meaning contribute to impact. It is a national association with approximately 3000 members. Membership is voluntary members pin annual fee to access our various member benefits including advocacy, which interestingly, members often ranked as the most important benefit of joining I FPS mission statement is to be the predominant voice of the independent financial practitioner. That is our purpose. If the purpose is supported by its governance model, it’s governed by a board of directors elected from its membership. They are the feet on the ground in their own financial practice, the same as our other members. They understand our members world. But we still must make our purpose meaningful to individual members. So they see value in their continued membership. So let me explain. I’ve been members are licensed financial advisors and planners who often own a financial practice in their local community. They’re independent in the sense that they are not under an exclusive contract with a single company, or an employee of a financial institution. As busy self employed business people spread across Canada, it’s essential that we keep them informed of the action we take on their behalf. So they feel confident they’re being represented. We do this through regular communications such as member only updates, compliance guides, webinars, educational events, and so on. If these administrative purpose or Ibiza administrative structure supports our purpose, IP prides itself in running an entrepreneurial office with a small stuff, a model that reflects that of our members. This allows us to be close to our members, their issues and be guided by what’s important to them. We see this as a major advantage. So establishing your purpose and meaning are the foundation building blocks that I believe are essential to be successful in achieving the impact you desire. But how do you get there? To help, I’m going to offer five practical tips that I think provide a roadmap to achieving your gr goals. Tip number one, it may seem obvious, but you can’t be all things to all people. Knowing the stakeholders you represent or speaking on behalf of will help you to focus on the issues of importance, and formulate positions that are clear and concise. To illustrate, ISP provides a collective voice for our members. So regulators are informed how proposed legislative changes may affect how they conduct their business. changes that affect their business could come from within the financial services industry, or outside of the industry by affecting them as entrepreneurs and small businesses. regular communication is an important way to stay in touch with your stakeholders and their priorities. If the members are always encouraged to provide us with feedback, however, if a proposed legislative or regulatory change is likely to have particularly significant impacts on our members, or the industry more widely, we will reach out directly often by inviting them to complete a survey or respond to a targeted email. It’s important that we take care in developing such surveys or emails. So members first understand why we’re asking. They don’t live in the government relations world, so we have to break it down. And second, that it’s as easy to respond as possible. We recognize they are busy people. The point of course of any any such outreach is to encourage a high enough rate of response, that it’s informative to your submission, and you can demonstrate that many of your stakeholders share the same concern. Clearly receiving hundreds of responses from our members, for example, makes them more powerful statement than only a few. But how do you translate this information into impact? We found that it can be particularly persuasive to regulators and other stakeholders to with direct quotes from survey responses into our presentations or written submissions. In effect, this gives individual respondents a voice that makes their concerns real to a reader and lead substance to your conclusions. If we can’t provide real meaning to members unless we understand the world they live in. Our members tend to be provincially licensed life insurance advisors and securities registrants financials services industry is heavily regulated and complex. We can’t effectively influence policy outcomes without standing out without understanding the legislation, regulation and industry governing bodies that affect their everyday work life. In Canada, life, insurance and securities are regulated at the provincial and territorial level. each province and territory has a regulatory body with oversight of insurance and securities, and is responsible for enacting legislation passed by their ministries of Finance. Sometimes these changes are harmonized so that a variety of jurisdictions in at the same or similar provisions. However, it’s not always the case. It’s further complicated by the fact that many ifI members are licensed to advise clients in more than one province and have more than one financial license. So this means we must stay on top of legislative changes or proposed changes being considered by every provincial Ministry of Finance and every provincial insurance and securities regulator across Canada. In addition to the individual provincial regulatory bodies, both insurance and securities regulators have formed national cooperative bodies to centralize some of the policy and regulatory initiatives which affect their sector. They often issued joint consultations on behalf of their individual provincial counterparts, although always recognize that any single jurisdiction may not adopt the same outcome. Other legislation also impacts the financial services industry, such as the federal privacy legislation or Pepita, and the federal anti money laundering legislation known as the proceeds of crime, money laundering and terrorist financing. Their bodies responsible for enforcing the regulations of these acts are the federal laughs Privacy Commissioner and fintrac are recently to enhance the protection of consumers of financial services. provincially insurance regulators have adopted third treatment of customers guidance and securities regulators have enacted a series of client focused reforms. The Aware of such initiatives is important and helps you identify trends in the direction and industry is headed. I would note that this is just a snapshot. But the point I’m making is that you need to know which agencies ministries and regulators affect your stakeholders, whether directly or indirectly, and then monitoring them closely to stay on top of opportunities or proposed changes. Why? Because if you have impact, your members will see purpose in support for your organization. So let’s say a public consultation has been posted that’s of interest. This is a great way to engage and have your say. So tip number two is don’t assume responding to a public consultation is a waste of time. legislators and regulators want to get it right. They need and want to hear if they are missing the mark. Engage engaging in government relations can make a difference if you know your stuff, and can position it in a way that will get your message heard. Tapping into the information resources relevant to your industry, and taking other action like reaching out to your stakeholder group will help you with your research and prepare a focused and more meaningful response. Depending on the industry you’re in, you may also want to tap into resources from outside Canada, I subscribe to get updates from international securities and insurance bodies and advisory associations in other countries. Often similar issues are under review in other jurisdictions, and can be insightful in identifying trends and possible solutions or alternative strategies. Sometimes the responses submitted to a public consultation are posted on the consultation website after the closing date. If you’re new to the field or the industry, the responses received from a variety of stakeholders can provide a wealth of information and deepen your understanding of industry issues. For example, if a recommendation you want to make has been dealt with in past consultations, and there’s commentary as to why the regulator is not making the change, you may want to adapt your messaging. This also provides opportunities to observe and learn from the diverse opinions expressed in the in the responses. For example, sometimes, maybe often, industry and consumer advocates don’t see eye to eye. Why? Well, reading individuals submissions will help you to understand. And in the end, all of this is information that can strengthen your submission. By understanding the broader issues of concern, even if you don’t agree with them, you’re not wasting your time on an issue that’s non starter, but can focus on the points that may move the needle. This is impact. In my own work, I often read submissions from others who have responded to the same consultations. It alerts me to whether others share our concerns or have made similar recommendations or points. It’s helpful in identifying potential partners that we may want to reach out to and helps me understand the concerns that weren’t ours that we may have, which we may want to consider in the future. As I mentioned, this process can also help you identify seemingly unlikely sources of collaboration. in financial services, for example, we’ve seen a rise in consumer activism. This has led to a corresponding rise in governments and regulators focus on improved transparency, transparency of financial information, and enhanced consumer protection measures. consumer advocates have gained influenced by having a seat at the regulatory table. Might your organization benefit from understanding their issues, and lending support where appropriate. Remember, the overarching goal of the entire process is to enact legislation that makes sense. Wishing your submissions on your website, even if it’s posted on the submission website also has advantages. First, it keeps your stakeholders informed of the advocacy you’ve taken on their behalf which reinforces their membership, why their membership has meaning. But secondly provides a publicly available source of information that can lead to media coverage, such as being quoted in a news article, or a request for an interview. All of which helps build the credibility of your organization as a valued stakeholder and thought leader. That’s impact. So tip number three is to seek out opportunities to build partnerships with like minded organizations to deepen your industry knowledge. As I said I resubmits responses on behalf of our members to give our members of voice well our members concerns are always Paramount, we don’t conduct our government or industry relations in isolation. Over the years, we’ve developed informal and formal partnerships with other organizations, which are involved in the financial services industry. Each of us represents our own individual group of members. But together, we represent a large proportion of distributors of financial products and services. This has two big benefits for all. First, it means we have a safe space to share debate and seek support within the group on an aligned approach that may not have been apparent to any of us individually. And second, it provides regulators with a single point of contact when they want to reach out with perhaps an early warning of a change they’re considering. Getting preliminary feedback provides regulators with some indication of industry reaction. This can also happen when a regulator consults on a draft statement of priorities or proposed business plan, both of which provide insights as to its future direction. Often they will release a pre consultation confidential copy to gather input from a limited number of stakeholders. So well formal consultations are greatly to participate in the public policy process. Informal consultations and partnerships are equally valuable collaboration with like minded organizations, or those who are aligned on a particular issue, constraints in your message and create greater impact. So how do you get your organization to the table? Always, always prepare, do your homework. Know your stakeholders, the space you’re in know your regulator, and know your audience. The importance of spending the time to formulate formulate submissions that reflect your position in a clear and concise way cannot be underestimated. It needs to set up your purpose and why the consultation has meaning for your stakeholders. In order to have impact number, a regulator may receive hundreds of responses to a consultation. If they have to wade through editing errors, rambling verbiage or inarticulate arguments to decipher your message, it will get lost. And that means no impact. I can imagine that some of you are shaking your head and thinking well who would submit a response like that? Let me give you some examples. Like I said, I review the responses submitted to a consultation to learn or be aware of what others are criticizing, supporting or recommending. In doing so, I have read well meaning responses that are so rambling and unfocused, that I lost interest, it might be the best message in the world. But if I can’t find it, I’m not going to give it the time or the attention the author had hoped for. I’ve seen responses reset sections have been cut and pasted from other submissions. And even the font is different. I’m sure you can imagine such scenarios. But they happen and the organization responding has gained no benefit and may even have lost traction. Also, the value of submission is not based on its length. Longer submissions are not always better. If you have one point of concern, and the consultation has posed 15 questions, respond to the one that’s relevant, then your message will be heard. If it’s buried in trying to find something to say to the other 14 questions, it will get lost. It’s perfectly acceptable to set out at the beginning of your response, that you’re only responding to this one issue because it’s the one that’s the most relevant, or of great importance, or the greatest concern to your stakeholders. I’ve done that. And left dealing with the questions that are peripheral fries, the members for other stakeholders to address. Again, you can’t be all things to all people. So know what you want, and how best to get the message across in a way that will advance your organization’s purpose. It’s important to bear in mind that the author of the consultation has spent a lot of time setting up the reasons for the consultation and often a proposed direction. It’s intended to lead to a purposeful exchange of ideas. So building on my earlier point that regulators and legislators want to get it right, formulate a response that support some or all of the of the proposals or provides options where you don’t agree. For example, consider the difference in the impact of a response that just says no, don’t do it. Versus we don’t think this will work because, however, if this or that was tweet, we think this could achieve the public policy objective you’ve set up if it’s something you absolutely can’t live with, offer an alternative solution. For example, you might say something like, our analysis shows that approving this is likely to to create an unintended consequence, that will negatively impact competition. To address this, we recommend regulators are particularly sensitive to potential unintended consequences, such as negatively impacting competition in the marketplace. Of course, you will have to back it up and not just say. So here’s a recent example to demonstrate this point and carry the one at you update an existing regulation in the Insurance Act, to encourage among other things innovation and insurance. During COVID, insurers wanted to rebate clients a portion of their automobile insurance premium in recognition that they weren’t driving as much. They had to get special relief to do so. So they didn’t fall afoul of an existing rule, which bans insurance rebaiting the proposed change would remove that barrier and lead to benefits for consumers. Wow, sounds great. We’ll want lower premiums. However, the proposed rule change would apply to not only the PNC sector, where auto insurance falls, but life and health two very different products with different life cycles and underwriting processes. In response, IP and other life and health stakeholders identified serious concerns if it went forward as proposed. The regulator subsequently reached out to gain a deeper understanding of the concerns, especially those related to some possible unintended consequences for the life and health sector. The result was a second consultation which proposed revisions which recognized the needs of both sectors. Obviously, this is a very brief summary. What does it tell you? regulators want to reach out to their trusted partners when deeper insights are needed. They want to get legislative and regulatory changes, right? And they don’t want unintended negative consequences. So now you’ve established your organization as a credible source of commentary that catches the attention of the legislators and regulators in your sector. That’s meaning for your membership, and impact. What’s next, number five is to become a trusted stakeholder. As your gr influence grows, new opportunities can arise, such as becoming part of a pre consultation group. Regulators engage in pre consultations to test the market reaction. Often this involves releasing confidential or embargoed copies of consultation materials to a select group of stakeholders to gauge industry reaction before they are publicly published. This provides participants the opportunity to weigh in and alert regulators to anything that’s missing or incomplete. It also provides the opportunity to tell them what industry agrees with and supports or disagrees with at an early stage. Some financial regulators have set up stakeholder advisory committees. Again, this provides a forum for regulators and stakeholders to share information. Having a presence on such committees can is an important way to represent your stakeholders and your industry and have influence on the development direction of policy priorities, legislation and accompanying regulations. So my time is up. I hope this has been helpful to those of you who might be putting a toe in the government affairs pond or want to take your gr to the next level. I also hope it helps you to be more confident about engaging in the public policy process. And now I’ll turn it back to Tim
Tan Sukhera 28:51
thank you so much for that Susan that was such a simple effective and insightful talk I really love that let’s let’s now switch it over it’s time for the last five minutes of our talk where we can go through some of the q&a portion the questions that are coming through here let’s take a look at the first question here vice do you have for someone who’s thinking of dipping into the GR pond but hasn’t done so yet?
Susan Allemang 29:18
Okay, thanks for that. Um, I think that you know, overall the best advice is really you have to get known you need to get known in the in the industry as a stakeholder. So you need to reach out to other organizations or regulators or stakeholders that share your your similar similar message to you. And, you know, establish those those alliances. But I guess, to backtrack, consider like why your organization wants to get wants to engage in gr in the first place and is it to establish Bush to respond to like a single issue of importance, or do you see yourself as having a longer term presence in in the field? And then of course, you also need to identify who’s going to lead this your gr efforts for your organization? Are you going to do it in house? Are you going to hire external consultants? Or is it going to be run by volunteer organizations? Those would be some of the suggestions I would have.
Tan Sukhera 30:30
And question number two is what’s the biggest challenge that one can expect to face when they’re starting their gr dreamy?
Susan Allemang 30:39
Well, again, I would say it’s just getting No, it’s it’s, you know, that I think the tips that I talked about will will help. But certainly the, you know, the research and preparation, aspects of it are critical. And I would say that, you know, you you need to familiarize yourself with the government or regulatory agendas and priorities so that you can find some opportunities to align with those. And also, of course, you need to know the legal context of of engaging in government relations, which, which includes like lobbying, the lobbying rules so you don’t inadvertently cross the line.
Tan Sukhera 31:27
Fantastic. Well, thank you so much again, for your time today, Susan, we really appreciate you thank you for everyone who’s joined us as well. hope everybody has a great one. Take care.
Susan Allemang 31:35
Thank you. Bye.