A conversation with FCAC’s new Commissioner, Shereen Benzvy Miller

"The way that you create trust in the financial system is to make people feel seen, understood and respected."

Shereen Benzvy Miller

FCAC is excited to start 2025 with a new Commissioner. What attracted you to FCAC? 

Most of my career has been spent in service of vulnerable communities in one way or another, so FCAC’s mandate and the focus on finance is very attractive. If you asked people today, “What are your biggest anxieties in your life?” my bet is that 99% of conversations would come down to financial well-being and financial stability. A regulatory agency is really only as interesting as its mandate. For me, a mandate that balances protection and education really hits a sweet spot, particularly for an area as essential as financial well-being.

You're a seasoned Government of Canada executive. How will this help you lead an agency that protects financial consumers?  

I am a lawyer, and I always start there. My first question is always, what's the law on that? As a decision-maker, you have to ground yourself in the language of administrative law to meet the principles of fairness.

I'd say 3 executive roles in the Government of Canada have shaped my ability to respond to the needs of this role. First, as the human rights advocate for federally sentenced offenders at Correctional Service Canada, I learned a lot about listening to the community that you're serving, and the players inside and outside of Government who contribute to the conversation. I listened to offenders and heard what their challenges were. And then I talked with wardens and staff, to figure out what the contextual issues were around the complaints. You can't help people or protect their rights unless you understand them and the challenges in their environment.

Second, my role as Deputy Chair of the Immigration and Refugee Board of Canada—which is the largest administrative tribunal in Canada —really helped me to understand the importance of independence in decision-making. It helped me to understand how you can engage with Parliament and central agencies but still maintain your sense of equilibrium and independence, so that you are making principle-based decisions that are closely reflective of the regulatory frame.

And finally, my work with Next Generation HR-to-Pay. I walked into a situation where there was a huge trust deficit that had been created by a catastrophic failure of technology and misalignment between experts in a very complex environment. This helped me to understand modern leadership, where you need to juggle the human and the technology elements, with respect for both. To figure the way out, I needed to dissect the problem-space into manageable pieces and then manage accordingly. I discovered that one of my biggest strengths is unpacking problems into their component parts, which then turns a huge problem into smaller, more manageable challenges to be solved.

You mentioned that most of your career has focused on serving vulnerable communities. How will you prioritize the vulnerable at FCAC?   

Consumer protection and protecting the vulnerable starts with user-centric design. A financial service provider, whether it’s a bank or a fintech, needs to put the consumer at the centre for all the services that it offers. This kind of consumer protection is not a “nice to have.” As Commissioner at FCAC, I will always start by asking how an initiative will impact the individual, and how it will protect the end-user of the system. By asking these questions, I hope that our financial systems work more effectively and that trust is built. Trust is the cornerstone of our legal framework, which is focused on the financial safety and stability of institutions and the broader financial system.

Do you think FCAC should prioritize a particular segment of the vulnerable population in its work? 

It’s been said that the measure of a civilization is the way it treats its most vulnerable populations. But I don't want to favour one category of person at risk. I think finances are a great equalizer. Financial troubles affect everybody the same way—terribly. They affect mental health, personal health and families. If we think about the most vulnerable as our starting place and make sure they are well looked after, then people who are doing OK but could be doing better will also be looked after. Having said that, we have the privilege of having a strong research team and ecosystem partnerships at FCAC, so we can target our outreach to make sure it has maximum impact.

Supervising financial institutions is one of the main ways FCAC protects financial consumers. What are some of the principles that will guide you in this work?   

As I said earlier, I will always ask first: how will this impact the consumer? I realize that FCAC and financial institutions are starting from different places, but you can still have a healthy revenue model and be considerate of and protective of the community that you’re serving. The way that you create trust is to make people feel seen, understood, respected—that there's a sense of fair play and they're not being taken advantage of. FCAC’s role in making sure that this trust is engendered benefits private sector initiatives. FCAC and financial institutions can have rich conversations, can collaborate and can be creative and innovative when we understand where we are coming from as regulators and where financial institutions are coming from.

What would you describe as FCAC’s greatest strengths when it comes to regulating financial institutions and protecting financial consumers?

We are built on a strong legal framework. We have a strong legal services unit that grounds a strong regulatory and compliance framework. Our Supervision and Enforcement team is core to ensuring that regulated entities meet their obligations. We have a strong Research and Policy team providing research and data analysis that alerts us to trends that will require our attention, and that also conducts behavioural research. We ensure that the human element is accounted for. We have very effective stakeholder engagement that gives us situational awareness of the context in which we're operating. We also have really impressive educational communications to improve the financial literacy levels of Canadians. I think of these as building blocks that all work together to create a strong and dynamic institution.

FCAC works closely with organizations across the country to strengthen the financial literacy of Canadians. What financial literacy priorities will you help to advance in 2025?  

FCAC’s 5-year National Financial Literacy Strategy is almost up, so we will revisit our goals around financial literacy. This is a perfect opportunity to work with our partners to think about whether people are understanding our messages, which messages are resonating, and how we can scale them together.

We also need to work together with our partners to decide which communities are most in need of more support. I can't help but think that investing in the financial literacy of children, for example, could have the most long-term results. The future of money is very different from what previous generations had to deal with. Financial literacy for children has to involve more than identifying different currencies, because most children may never see currency in their hands. Money will not be a tactile thing for today’s generation. It will be entirely data-driven, on their phones, on their devices. So how do you make this digital shimmering oasis real for children?

Finally, I will want to hear from partners about what they see as their strategic goals for the next 5 years. I am new in the job and am looking forward to listening to those who have been working in this field, the lessons they have learned, and what their vision is for FCAC.

The financial system is going through a period of tremendous change. What would you say to Canadian financial consumers about how you hope to help them navigate this challenging environment?  

It is so true that the financial system is going through a period of tremendous change, which brings opportunities but also challenges. For example, FCAC’s mandate recently has been expanded to include responsibility for overseeing Canada’s Consumer-Driven Banking Framework (which is also known as “open banking”). This new Framework will allow Canadians to securely access and share their financial data with financial technology companies. I will want Canadians to make sure they fully understand what it means to own and control their financial information and who to share it with, to ensure that the actors that they're engaging with and agreeing to give their information to are not bad actors. Financial education offers important protection against frauds and scams and is also a critical way to ensure financial resilience.

I would also say to Canadians: Don’t be afraid to understand your finances. Even when you're not in crisis, even when things are fine, know your money. Let's take the taboo away, and talk about your finances with your children, with your spouse, with your parents, with financial experts, even with your friends. Talk about your financial worries. At some point in their trajectory, everybody will have the same worries and concerns. The more you know about the possible solutions and problem-solving recipes, the better equipped you will be to handle these worries. Learning through other people's journeys and good and bad experiences is a very healthy thing to do around something that is just so important.

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