This project aims to lay the groundwork for a research that 1) articulates the

relationship between the current OSFI guidance on records management and the explicit or

implied record keeping requirements in OSFI`s other guidance and applicable laws and

regulation to determine its implications and 2) explores the perceived role of records

management at the top six Canadian banks and at OSFI to identify records management policy

lacunae in relation to effective business practice for the banks or in support of regulatory and

supervisory oversight by OSFI. This research will lead to further insights into the linkages

between records management, competitive viability and supervisory oversight, which then can

be used as the basis for advising OSFI and the banks on the development, in partnership, of new

Canadian bank records management guidance.

This funding will be used to conduct a preliminary assessment of the existing OSFI

guidance on records management and other relevant statements on records and documents in

applicable laws, regulations and OSFI guidance notes. The assessment will be carried out with

the support of a research assistant who will review and analyze relevant documents as well as

codify them using NVIVO qualitative research software according to a predefined schema based

on accepted records management standards and in a way that identifies how the global standards

may need to be contextualized for application to the Canadian banking sector. The seed funding

will also be used to fund travel to Ottawa and Toronto to negotiate the terms of a proposed

public-private policy partnership between OSFI and the participating banks preparatory to

commencing the full research project.