Dear Attorney General Sharma,
I am writing on behalf of the Canadian Association of Private Lenders to urge the Government of British Columbia to introduce legislation that gives consumers the right to place, suspend, and remove a security freeze, or credit freeze, on their credit files at no cost.
As the minister responsible for the Business Practices and Consumer Protection Act, you are well placed to advance this practical and increasingly necessary consumer protection measure. In our view, a statutory credit freeze regime would be a sensible and proportionate response to the growing risks of identity theft, application fraud, and mortgage-related fraud in British Columbia.
Ontario has now confirmed implementation of a credit freeze framework that will allow consumers to place and terminate freezes beginning July 1, 2026, with full suspension functionality required by July 1, 2027. Quebec has already implemented similar protections. British Columbia should not lag behind where an effective, low-cost fraud prevention tool is already available and increasingly recognized as a modern baseline safeguard.
A credit freeze is a relatively simple protection to implement, but it can have significant practical value. By restricting access to a consumer’s credit file for new-credit underwriting purposes unless the consumer lifts or suspends the freeze, the regime helps prevent fraudsters from opening new credit cards, loans, lines of credit, and mortgages using stolen identities. This kind of preventative control is especially important in the current environment, where financial fraud is rampant and growing more sophisticated due to AI-enabled impersonation, synthetic identity techniques, and broader circulation of compromised personal data.
From the perspective of private lenders and the broader mortgage market, the case for this reform is particularly strong. Mortgage fraud is not a single problem; it takes multiple forms. In one category, a fraudster uses stolen personal information to apply for mortgage financing, a home equity line of credit, or other secured borrowing in the name of an unsuspecting victim. In those cases, a credit freeze can be highly effective because it blocks or disrupts the lender’s ability to obtain the credit report needed to underwrite the application, often causing the application to be declined or escalated for further review.
That protection matters not only for consumers but also for lenders, brokers, and the integrity of the credit system. When fraudulent applications make it through the front end of the process, the resulting losses, disputes, and recovery efforts impose real costs across the market. A credit freeze helps stop some of that harm before it occurs.
We appreciate that a credit freeze is not a complete answer to every type of mortgage or housing-related fraud. It does not, for example, eliminate title fraud risks where land title records are manipulated and financing is obtained through other means. Nor does it replace the need for robust identity verification, anti-fraud underwriting controls, registry safeguards, or title insurance protections. However, that is not a reason to delay action. It is a reason to add another useful layer of prevention. In fraud prevention, layered controls are essential, and credit freezes are now a well-understood and effective part of that toolkit.
There are also compelling consumer protection reasons to act. British Columbians are already facing cases in which fraudsters change addresses on credit files, open multiple credit accounts without authorization, trigger hard inquiries with service providers the victim has never dealt with, and leave fraudulent balances outstanding while the victim struggles to navigate disputes with credit bureaus, creditors, and law enforcement. Once that damage is done, the cleanup process is burdensome, slow, and stressful. A credit freeze helps move the system from reaction to prevention.
We believe British Columbia can and should implement a statutory framework through amendments to the Business Practices and Consumer Protection Act or related consumer reporting legislation that would:
- Give consumers the right to place, suspend, and remove a credit freeze on their credit files free of charge.
- Require Equifax Canada Co. and Trans Union of Canada, Inc. to implement freezes, suspensions, and removals within clear, enforceable timelines.
- Ensure consumers can obtain electronic access to their credit reports and credit scores without charge on a regular basis.
- Require consumer reporting agencies to publish clear information explaining what a credit freeze does, what it does not do, how to request one, and the circumstances in which a file may still be disclosed.
- Support coordination with lenders, brokers, and other market participants so the regime functions smoothly in practice and strengthens, rather than complicates, legitimate underwriting.
This reform would align British Columbia with a growing national trend toward stronger consumer controls over credit file access. It would also demonstrate that the province is prepared to respond to modern fraud risks with practical tools rather than relying solely on after-the-fact remedies once a consumer’s identity and financial profile have already been compromised.
The Canadian Association of Private Lenders would welcome the opportunity to engage further with your office on this issue and to support the development of a workable framework that protects consumers while preserving efficient credit decision-making for legitimate transactions.
Thank you for your consideration. We would appreciate the opportunity to discuss this proposal further.
Sincerely,
Samantha Gale,CEO
Canadian Association of Private Lenders