January 2026
In response to a joint Ontario Securities Commission (OSC) and Canadian Investment Regulatory Organization (CIRO) report in July 2025 about sales culture, product access, and the experience of investors inside bank branches, the Canadian Association of Retired Persons (CARP) sent a formal letter to the President & CEO of the Canadian Bankers Association (CBA) in November 2025, expressing concerns from our members and seniors at large have about how their best interest may not be served at their corner bank branches.
The CBA has responded to our letter, and we are sharing their response today with CARP members.
In CARP’s view, the CBA’s response shows they are not interested in addressing predatory sales practices; putting clients and seniors’ best interests and financial security ahead of their profits; and are not interested in providing the best product options for the approximately six million Canadians who trust and invest with bank branches. Here is our analysis of key issues in their response. To read the full letter from the CBA, please click here.
A “Global Leader”? In earnings and profit? What about seniors?
The CBA’s letter, signed by its President and CEO, touts Canada’s banking system as “the most inclusive among the G7,” with 99% of Canadians having access to a bank account. While shiny and impressive on its surface, this statistic distracts from the specific issues faced by seniors—including sales practices, product suitability, and protection from financial abuse— that prompted the OSC-CIRO survey in the first place. Seniors are not questioning whether they can open an account; they are asking whether the advice and products being offered are truly aligned with their best interests. While the big banks continue to make billions in profits, even in a struggling economy, they are attempting to spin the conversation to their marketing efforts, leaving seniors’ and all in-branch investors’ issues unresolved.
Survey Results Downplayed and Questioned? Stalling action
The banks “take the feedback shared by the OSC/CIRO survey respondents seriously,” the letter claims. Yet, it quickly pivots to minimize the findings, noting the survey “reflects the sentiment of a select group of respondents in Ontario only” and “does not verify behaviours identified through a formal review or investigation.”
The survey was done by regulators and the results are based on confidential responses from nearly 3,000 bank branch employees. When faced with uncomfortable truths, big organizations sometimes attack the credibility and validity of the source, but do they not take their own employees’ views seriously?
Major concerns were identified in the joint OSC-CIRO report. Of all age groups, seniors trust and use the banks more than other groups. In other words, you, our members, are their best customers. Seniors deserve a respectful response on what the banks are going to do to address concerns. Not a feckless non-response that questions and downplays the report. Perhaps expectedly, the CBA is taking no ownership or responsibility, suggesting nothing will be done to stand up for seniors.
Client Interests—Or Bank Interests?
The CBA insists that bank branch representatives are trained to put client needs first and adhere to banks’ own Codes of Conduct. Under “Client Focused Reforms,” banks must resolve conflicts of interest and prioritize clients when recommending investments. While their evidence may show that they are doing the right thing, – the CBA CEO cites the OSC-CIRO report, which says 78% of surveyed bank staff believe the range of [bank only] mutual funds they can recommend “meets client needs.”
This begs the question. What about the other 22%? How could the CBA genuinely believe that it’s acceptable that nearly a quarter of their bank branch advisors don’t agree they have enough product choice and freedom to best serve their customers? How could the CBA in good conscience believe that it’s okay for millions of Canadians investing with them to be mistreated by frontline bank financial advisors who admit to regulators they don’t have the tools to do the job?
What are they doing to give their own employees the tools and product freedom to give the best products to Canadians and seniors? Why were they able to offer independent investment products that best served customers before, but they are mandating only their own products be used even when these might not be the best? We can only surmise that they are putting bank interests and profits ahead of client interests.
Promises, Policies, and Paperwork
The letter lists a series of initiatives: a voluntary Code of Conduct for seniors, training to prevent financial abuse, tailored account options, and retirement planning tools. It also highlights educational programs and fraud prevention resources. But for many seniors, navigating these policies and accessing meaningful support remains a challenge. Voluntary codes and flexible guidelines may sound good on paper, but without robust enforcement, are they enough?
Seniors need confidence that the “client-first” approach isn’t just a principle on paper. The real test is whether it produces consistent, measurable outcomes across branches, regions, and client groups, especially as older adults who may have less financial literacy and are more vulnerable to pressured sales tactics or confusing product recommendations.
The Bottom Line
Canada’s banks say they value CARP’s advocacy and welcome ongoing dialogue. But as the OSC-CIRO review continues, seniors and their advocates should keep asking tough questions: Are banks truly putting client interests first, or just checking regulatory boxes? Are seniors’ voices being heard—or politely deflected? Until there’s more transparency and accountability, Canada’s seniors may have reason to remain skeptical.
What the Letter Doesn’t Say:
The CBA’s letter is detailed, but there are critical gaps that matter most to seniors.
- A two-tiered system of product access. The letter does not address a growing concern where clients often have access to broader product choice through the brokerage channel for higher-net-worth Canadians, while the average person walking into a branch may be offered a narrower shelf of options. Seniors deserve transparency on what options are being offered and whether these products are still competitive and in their best interest.
- No acknowledgement of seniors’ dependence on branch‑based advice, despite reduced in‑person services. The letter emphasizes referrals to “alternative channels,” but does not understand the reality that many older adults rely on in-person, branch-based advice, particularly those facing accessibility barriers and low digital confidence.
- No data on complaints, error rates, or outcomes specific to older clients.
- No commitment to public reporting on suitability issues, mis‑selling risks, or the effectiveness of senior‑specific protections.
- No explanation of how banks ensure seniors aren’t steered toward sub-optimal bank-only products when better independent products exist. Most importantly, the letter does not explain how banks are standing up for seniors to ensure they are not guided toward, at best, average lower-performing products when better, higher-performing funds may exist.
Why CARP is Sharing This Now
CARP is sharing the bank’s response with members because transparency matters and because seniors deserve more than empty promises and marketing spin from the banks they trust. They deserve accountability and action.
CARP will continue to demand these actions from the banks, regulators and policymakers:
- Adopt a higher fiduciary duty standard for all financial advisors, ensuring that advice provided to clients is always in their best interest, not driven by internal product sales targets.
- Increase transparency and choice by allowing branch-level advisors to offer non-bank-affiliated investment products, equivalent to the quality of advice and choice offered to higher-net-worth investors at bank-owned wealth divisions.
- Invest in financial literacy for seniors, including accessible education on investment options, risk management, and retirement planning.
- Strengthen internal accountability by ensuring that sales practices align with clients’ interests, which should never be secondary to corporate profit goals.
- Work collaboratively with CARP to establish an industry-wide “Senior Investor Protection Framework” that prioritizes fairness, accessibility, and dignity in financial services for older Canadians.
We encourage our members to read the full letter and stay tuned as the OSC/CIRO work progresses. CARP will continue advocating for a financial system where older adults are protected, respected, and treated fairly.
LINK TO LETTERS
To read our full letter to the CBA, please visit this link: https://www.carp.ca/2025/11/23/carp-letter-to-canadian-bankers-association/
