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Certified General Accountants Association of Canada's Submission in Response to Finance Canada's 2006 Review of Financial Sector Legislation:

May 25, 2005

Mr. Gerry Salembier
Director, Financial Institutions Division
Financial Sector Policy Branch
Department of Finance
L'Esplanade Laurier
20th Floor, East Tower
140 O'Connor Street
Ottawa, Ontario K1A 0G5

Dear Mr. Salembier:

On behalf of the Certified General Accountants Association of Canada (CGA-Canada), I am writing in response to the Government's invitation, in Annex 6 to its budget documents, for comments on allowing financial institutions to electronically process cheque images in place of paper cheques.

CGA-Canada supports the cheque clearing process through image technology as proposed by the Canadian Payments Association.

As a national professional accounting organization representing 62,000 CGAs and students, we believe the proposal offers benefits both to the clearing system as a whole and to the business sector. Accounting and auditing practices have already been adapted to reflect the use of electronic documents in the business environment, and we believe the existing framework will accommodate the transition to cheque images in circumstances where original cancelled cheques may be used today.

The electronic imaging system will improve both the speed of cheque processing and the cost efficiency of the process. Both improvements represent benefits for Canadian businesses, consumers, and financial institutions; in short, all who participate in Canada's financial system. Accountants would benefit from the system as it will allow for faster and more efficient process for reconciling accounts and faster notification of returned items. Moreover, speedy access to images can assist in the detection of attempted fraud.

In sum, CGA-Canada supports the recommendations for amendments to the Bills of Exchange Act as a means to modernize the cheque clearing process.

Sincerely yours,

Anthony Ariganello, FCGA
President and Chief Executive Officer
CGA-Canada

cc Guy Legault, FCGA, 
President and CEO, 
Canadian Payments Association