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Symcor's Submission in Response to Finance Canada's 2006 Review of Financial Sector Legislation:

Dennis Maloney
Chief Operating Officer

Phone: 905-273-1361
Fax: 905-273-1343
Email: dmaloney@symcor.com

May 26, 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, ON K1A 0G5

Dear Mr. Salembier :

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. Specifically, we support modernizing the cheque clearing process through image technology, as proposed by the Canadian Payments Association.

Symcor provides business processing outsourcing services for financial organizations. The Company was formed in 1996 when three of Canada's major banks combined their "back office" cheque processing and statement rendering operations. In addition to providing service for our three owner banks, Royal Bank of Canada, Toronto Dominion Bank and Bank of Montreal, Symcor also provides cheque-processing services for Scotiabank, the Credit Union Central of Ontario and Laurentian Bank. Through our direct clients, we provide service to other banks such as Credit Union Central of Nova Scotia and HSBC. We have sites in all Canadian clearing cities and we recently opened our first processing site in the USA.

We anticipate many benefits as a result of this approach.

With the declining volume of cheques, the unit cost to process is increasing. Image based solutions will allow processors to improve efficiency and thereby offset this trend.

Image technology will enable banks to improve service by offering enhanced services for the increasing percentage of online banking clients.

Image technology will allow processors to deploy enhanced fraud detection and prevention solutions such as Payee Name Verification..

Image exchange with USA banks will dramatically reduce the clearing time and therefore help reduce the North/South fraud, a disproportionate source of write-offs.

Immediate access to electronic images in the case of customer inquiries will result in better service.

The adoption of Cheque Imaging will substantially reduce/eliminate major service disruptions. The present system relies heavily on land/air couriers for the transport and processing of cheques which are dependant both on weather and can also be disrupted by criminal activity.

In summary, Symcor supports the CPA's recommendations for amendments to the Bills of Exchange Act to facilitate a modernization of the cheque clearing process. This technology will enable banks to increase efficiency while improving customer service.

Yours truly,

Dennis B. Maloney
Chief Operating Officer