Financial Rights Awareness Coalition (FRAC)

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FRAC is dedicated to promoting financial literacy and consumer rights in Canada. Our mandate is to empower individuals with the knowledge to make informed financial decisions. We have successfully conducted numerous awareness campaigns and educational programs, reaching thousands of Canadians.

EasyFinanical Proceeding

Consumer reports not based upon the best evidence reasonably available.
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B.O.L.D – Break Out, Loudly Defend

Credit Check: What You Must Know

 A credit check must be B.O.L.D or underlined, in a font size no less than 10 points.

Verifiable Consumer Report

Consumers are entitled to verifiable consumer reports based on mandatory notices as best evidence.

To determine whether a consumer report is verifiable, check for the presence of the following eight key notices:

  1. Written instructions from the consumer, which would allow the consumer reporting agency to furnish information from its files; otherwise, the consumer reporting agency is prohibited unless written instructions and a documented permissible purpose are provided. (s. 8(1), CRA)
  2. Permissible purpose A permissible purpose for obtaining information from the files of a consumer reporting agency or such action is prohibited (s. 8(2), CRA).
  3. Notice of intention to obtain a consumer report in consideration of extending credit (s. 10(2), CRA).
  4. Notice of intention to obtain a consumer report for the purposes of extending credit (s. 10(3), CRA).
  5. Notice or consent of divulgence of personal information (s. 10(5), CRA).
  6. Notice compliant with statutory visibility and formatting requirements  Notices must be easy to see and read, such as bold type or underlined letters, in a font size no less then 10 points— never hidden in fine print (s. 10(6), CRA).
  7. Notice of adverse action  If adverse action is taken based on the report (such as being denied credit or charged higher rates), the institution must tell you the source and your right to request details within sixty days(s. 10(7), CRA).
  8. Proof of Receipt of Notice
    Proof of receipt of a notice is required when the notice is not delivered personally or sent by ordinary or registered mail to the person’s last known address. When a notice is delivered by another method — such as electronically or through an online application system — the sender must be able to demonstrate proof of receipt, for example, by sending notices to an email address with a read receipt or through an online portal capable of tracking delivery, opening, and acknowledgment. This requirement is particularly relevant for organizations that rely on digital or online application processes instead of traditional paper-based delivery methods (s. 20(1)(d), CRA)

This information should be presented upfront (such as at the time of the application for credit) — not buried in terms and conditions. It must also include the name and address of the consumer reporting agency providing the report when requested(s. 10(1), CRA). Without this, your consent may not be valid under federal and provincial laws.

Why It Matters

These mandatory notices protect your right to fair, accurate, and verifiable consumer reporting.
If an institution fails to provide or document these notices, it may be in non-compliance with the Consumer Reporting Act — and you may have grounds to challenge or correct your credit information.

R.I.S.K – Reform In Systems & Knowledge

Financial institutions are required to provide information about the nature, purpose, and consequences of the collection, use, and disclosure of personal information at the time of decision, enabling consumers to make informed choices. This includes the impact on consumer reports, such as activities that may lead to a lower credit score, denied loans, or diminished credit ratings, and institutions must make reasonable efforts to ensure that consumers to whom the organization’s activities are directed understand these factors, as this information is essential for informed decision-making. 

 Financial institutions also must provide consumers with upfront notice of the potential risks, harms, and consequences associated with accessing their services, including reasonably foreseeable risks such as those caused by bad actors. These may include financial loss, reputational damage, humiliation, negative effects on credit records, and identity theft resulting from the use of their products or services. This transparency ensures that consumers can make informed decisions and avoid deceptive practices.

This directive is supported by the Guidelines for Obtaining Meaningful Consent, which require organizations to clearly inform individuals of (a) the types of personal information being collected, (b) the parties with whom the personal information is shared, (c) the purposes for which the personal information is collected, used, or disclosed, and (d) the risks of harm and other potential consequences at the time of accessing services.

T.E.C.H – Transparency, Encryption, Consent, Honesty

Financial institutions have shifted to the digital era of e-commerce and are moving away from paper-based applications. However, unlike paper-based processes, financial institutions must now implement adequate technological safeguards to protect electronic consent, particularly when it is collected through checkboxes as a form of electronic signature.

Financial institutions must demonstrate that they have implemented technological safeguards, specifically secure electronic signature technology or digital signature certificates, ensuring that the electronic signature (a) is unique to the individual using it, (b) is under the sole control of the individual incorporating, attaching, or associating their electronic signature with an electronic document, (c) can be used to identify the individual, and (d) is linked to the document in a manner that allows detection of any modifications after its incorporation.

Financial institutions must also demonstrate compliance with the Secure Electronic Signature Regulations, including digitally signing documents with valid certificates, applying recognized cryptographic hash functions to generate and encrypt message digests using private keys, attaching or embedding encrypted digests into documents, transmitting documents together with verifiable certificates, and performing proper verification upon receipt, including certificate validation, as required under Sections 2 and 3 of the Regulations.

Financial institutions cannot without full compliance benefit from the presumptions under Section 5 of the Secure Electronic Signature Regulations; the only acceptable alternative is the use of a valid digital signature certificate.

Latest Insights

09/12/2025
Mogo Finance Technology Inc.

POLICY AMENDMENT

Successfully led recommendations to Mogo Finance Technology Inc., through the Office of the Privacy Commissioner of Canada, to remove hard inquiry information from the informational pop-up — which was only triggered when a user clicked the information icon — and relocate it to a more visible, unobstructed section of the interface. This change will help consumers make more informed decisions when assessing services.
09/12/2025
Equifax Canada

POLICY AMENDMENT

Successfully led privacy policy revisions at Equifax through the Office of the Privacy Commissioner of Canada, ensuring the inclusion of consent processes. Also prompted Equifax to clarify that they neither store nor process consent forms, helping consumers better understand how their personal information is handled.
09/12/2025
Home Trust

POLICY AMENDMENT

Successfully led credit application and privacy policy revision recommendations at Home Trust Canada through the Office of the Privacy Commissioner of Canada, for the inclusion of risk, harm, and consequences awareness information related to the collection, use, and disclosure of personal information. These revisions help support informed decision-making during product or service selection.
09/12/2025
Capital One Bank

POLICY AMENDMENT

Successfully led practices and policy revisions at Capital One through the Office of the Privacy Commissioner of Canada, requiring the company to retain the check box users would select when applying for a credit product online.
09/12/2025
Mogo Finance Technology Inc.

POLICY AMENDMENT

Successfully led Mogo Finance Technology Inc. to amend its policies and practices regarding access requests, ensuring more thorough searches for personal information are completed. This will help consumers gain access to personal information with due diligence and timely responses from the organization.
09/12/2025
Metropolitan Credit Adjusters Ltd.

POLICY AMENDMENT

Successfully led Metropolitan Credit Adjusters Ltd. in revising their policy to eliminate fees for accessing personal information. This change allows consumers to obtain their information at no cost, helping the company reduce complaints related to personal information requests.
09/12/2025
Equifax Canada

POLICY AMENDMENT

Successfully led privacy policy revisions at Equifax through the Office of the Privacy Commissioner of Canada, ensuring the inclusion of consent processes. Also prompted Equifax to clarify that they neither store nor process consent forms, helping consumers better understand how their personal information is handled.
09/12/2025
Capital One

POLICY AMENDMENT

Successfully led practices and policy revisions at Capital One through the Office of the Privacy Commissioner of Canada, requiring the company to retain personal information to allow access and recourse.
09/12/2025
Capital One

POLICY AMENDMENT

Successfully led practices and policy revisions at Capital One through the Office of the Privacy Commissioner of Canada, requiring the company to retain personal information to allow access and recourse.
09/12/2025
Capital One

POLICY AMENDMENT

Successfully led consumer service agreement and privacy policy revision recommendations at Koodo Mobile through the Office of the Privacy Commissioner of Canada, for the inclusion of risk, harm, and awareness information associated with the collection, use, and disclosure of personal information. These revisions support informed decision-making during product or service selection.
09/12/2025
Capital One

POLICY AMENDMENT

Successfully led privacy policy revision recommendations at Capital One through the Office of the Privacy Commissioner of Canada for the inclusion of risk, harm, and consequences information related to the collection, use, and disclosure of personal information. These revisions aim to support informed decision-making during product or service selection.
09/12/2025
Neo Financial

POLICY AMENDMENT

Successfully led Neo Financial to reverse charges related to fraudulent activity where consumers unknowingly participated. However, Neo Financial failed to include in their privacy policy that sharing personal information could result in financial loss. Neo Financial agreed to reverse the charges based on the argument presented.
09/12/2025
Home Trust

POLICY AMENDMENT

Successfully led credit application and privacy policy revision recommendations at Home Trust Canada through the Office of the Privacy Commissioner of Canada, for the inclusion of risk, harm, and consequences awareness information related to the collection, use, and disclosure of personal information. These revisions help support informed decision-making during product or service selection.
09/12/2025
Home Trust

POLICY AMENDMENT

Successfully led credit application and privacy policy revision recommendations at Easy Financial through the Office of the Privacy Commissioner of Canada, for the inclusion of risk, harm, and consequences information related to the collection, use, and disclosure of personal information. These revisions help support informed decision-making during product or service selection.
09/12/2025
Home Trust

POLICY AMENDMENT

Successfully led credit application and privacy policy revision amendments at Easy Financial through the Office of the Privacy Commissioner of Canada, to emphasize provisions allowing consumers to opt out of secondary purposes such as marketing and promotions associated with the collection, use, and disclosure of personal information. These revisions support informed decision-making during product or service selection.
09/12/2025
TransUnion Canada

POLICY AMENDMENT

Successfully led TransUnion, through the Office of the Privacy Commissioner, to agree to conduct further training and monitoring of their Complaint Management team. TransUnion apologized for any frustration or inconvenience caused to the complainant. This initiative aims to improve consumer outcomes by ensuring better responses, acknowledgment, and access to information requests.
09/12/2025
TransUnion Canada

POLICY AMENDMENT

- Successfully led recommendations to TransUnion, through the Office of the Privacy Commissioner:

1. Acknowledging the receipt of an access request in writing within 30 days. The recommendations included adding explanatory wording within their written acknowledgment (e.g., clarifying identification requirements and that they engage directly with the consumer, not with credit repair companies). This ensures the requester is informed of any missing information needed to fulfill the access request.

2. Informing the requester/complainant of their right to file a complaint with the Office of the Privacy Commissioner of Canada once an access request has been fulfilled or a complaint/dispute investigation is completed. This helps the requester/complainant understand that this is the organization’s final response to the request or complaint/dispute.

09/12/2025
TransUnion Canada

POLICY AMENDMENT

Successfully led recommendations to Equifax, through the Office of the Privacy Commissioner:

1. Acknowledging the receipt of an access request in writing within 30 days. I recommended adding explanatory wording within their acknowledgment (e.g., clarifying identification requirements and their process for receiving access requests via mail, as per their policy). This ensures the requester is informed of any missing information needed to fulfill the access request.

2. Informing the requester/complainant of their right to file a complaint with the Office of the Privacy Commissioner of Canada once the access request has been fulfilled or the investigation into a complaint/dispute is completed. This helps the requester/complainant understand that this is the organization’s final response.

09/12/2025
TransUnion Canada

POLICY AMENDMENT

Successfully led recommendations to TransUnion, through the Office of the Privacy Commissioner of Canada, ensuring that requesters clearly understand when TransUnion is processing their access request. The recommendations also emphasized the need for specific information to advance the investigation and provide results.

Community Resources

Access community resources designed to help you protect your rights and challenge compliance practices of financial institutions and consumer reporting agencies. These tools can assist you in confirming the accuracy and consent of information placed in your consumer reports.
TEMPLATE
Demand Proof of Consent
  • Consent Verification
  • Proof Request
  • Rights Protection
  • Accountability Tool
Download
GUIDE
Understand Mandatory Notice Requirements
  • Notice Requirements
  • Consumer Protection
  • Legal Compliance
  • Rights Awareness
Download

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FRAC – Standing Strong for Your Financial Rights

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The Financial Rights Awareness Coalition (FRAC) exists to educate, advocate, and protect consumers against unfair financial practices. We raise awareness of financial rights, hold institutions accountable, and provide resources to empower individuals to make informed decisions. FRAC brings together voices, expertise, and action to ensure fairness, , and transparency in the financial system.

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Organizations are required to provide mandatory notice of intent to obtain a consumer report from a consumer reporting agency in consideration of, or for the purpose of, extending credit at the time of the application. The notice must also be clear, bold, or underlined, in a font size no less than 10 points. at the time of application. #spreadtheword