Submissions

We noted that the draft Integrated Transition Assessment makes only a few references to Indigenous Peoples. However, in jurisdictions with Indigenous populations, companies will have obligations with respect to Indigenous rights and title. Therefore, we believe that corporations should be aware that there are significant risks and opportunities in jurisdictions with Indigenous populations. Read FMB’s…

There are several aspects to the Ontario Securities Commission’s (« OSC ») broad vision for the Action Plan for Truth and Reconciliation (the « APTR ») that are worth noting. We think that OSC’s commitment to using Indigenous-owned consulting and communications firms was correct in this instance. We further and specifically support the OSC’s vision of the APTR being…

Our review of the exposure draft for a new Canadian Intangible Assets standard (the “ED”) suggests that if measurable direct costs are incurred to secure rights-based licenses or quotas, these could potentially qualify as internally generated intangible assets. This could be a positive development, as it provides an opportunity for First Nations Entities to report these…

The International Public Sector Accounting Standards Board (IPSASB) consulted on its draft sustainability disclosure standards for public sector entities, like governments. The standard will require two kinds of disclosures. First, disclosures about an entity’s climate-related information (e.g. how much CO2 is released in their operations). Second, disclosures about climate-related policy programs. The FMB said that…

The International Public Sector Accounting Standards Board (IPSASB) consulted on Exposure Draft 92, Tangible Natural Resources. The draft standard is to propose guidance on the recognition, measurement, display and disclosure of tangible natural resources. The FMB said the standard needs to include options for public sector entities to disclose a tangible natural resource because of…

The Global Battery Alliance (« GBA ») is a public-private collaboration platform founded in 2017 at the World Economic Forum to help establish a sustainable battery value chain by 2030. In this project, the GBA proposes a “digital passport” for entities operating along the battery value chain: from mining though to refining; preparation and sale of batteries;…

The FMB responded to Finance Canada’s “Consultation on Proposals to Strengthen Canada’s Financial Sector”. This is the third phase of Finance Canada’s consultation. Among other things, FMB advocated for: Read FMB’s Response to Finance Canada

The International Federation of Accountants (IFAC) has proposed changes to certain of its international education standards. These standards will be used for entry into the professional accounting education programs, for initial professional development or for CPD. The proposed changes include key sustainability reporting concepts, and create certain new assurance competence areas and learning outcomes. The…

FMB submitted a response to the Alternative Minimum Tax (AMT) legislative changes from Budget 2024. The AMT “is a parallel tax calculation that allows fewer tax credits, deductions, and exemptions than under the ordinary personal income tax rules. Taxpayers pay either regular tax or AMT, whichever is highest.” The proposed changes seek to exempt trusts…

FMB submitted a letter of comment to the Canadian Sustainability Standards Board (CSSB) regarding its inaugural sustainability standards. In brief, we have submitted the following: FMB’s Comment to CSSB

The Indigenous-led First Nations Financial Management Board and our sister FMA institutions are bringing UNDRIP to life by supporting First Nations to build their capacity and boost economic opportunities. Through opt-in tools, Nations are increasing their own-source revenue, building badly needed infrastructure, and creating wealth for future generations. We must build on that success. This…

The FMB responded to Finance Canada’s “Consultation on Strengthening Competition in the Financial Sector”. This was the second phase of Finance Canada’s consultation. This consultation specifically asked respondents about mergers and acquisitions (“M&A”) for financial institutions and about how competition could be increased in the financial sector. Among other things, FMB advocated for a review…

The Auditing and Assurance Standards Board (the “AASB”) published a set of requirements for sustainability assurance engagements in Canada (the “CSSA 5000”). The CSSA 5000 included certain Indigenous factors and considerations in its proposed requirements. The FMB was pleased to see this because Indigenous lands and territories are indelibly intertwined with business in Canada, with…

The FMB responded to Finance Canada’s “Consultation on Upholding the Integrity of Canada’s Financial Sector”. This was the first phase of Finance Canada’s consultation on the federally regulated financial institutions statutes as part of the financial sector legislative review announced in Budget 2022. The first phase of the consultation sought views and written submissions on…

Canada has reformed the Alternative Minimum Tax or AMT. The new tax measures are intended to ensure that the wealthiest Canadians pay their fare share. The government consulted on whether they should exempt Indigenous settlement trusts from the application of the AMT. The FMB responded to Canada’s consultation. We said that not only should Indigenous…

FMB has commented on the Canadian Securities Administrators’ (the CSA) Proposed Amendments that seek to increase diversity reporting in either a more (Form B) or less (Form A) prescriptive manner. We generally support the more prescriptive Form B, although we think it could be further improved upon by requiring that issuers set diversity targets; disclose…

FMB was asked to give our opinion about what the International Sustainability Standards Board (ISSB) should work on next. We believe the ISSB should prioritize biodiversity, with an Indigenous focus. Indigenous Peoples are long-term stewards of the natural environment and experts on biodiversity. Companies should be required to disclose to investors about their track records…

The Federal Government’s Budget 2023 commits Indigenous Services Canada to support the co-development of an Economic Reconciliation Framework with Indigenous partners. This framework is supposed to build on the strong foundations of recent Indigenous-led initiatives including the First Nations Financial Management Board’s RoadMap project. FMB’s 2024 Pre-Budget Submission to the House of Commons Finance Committee…

FMB response to draft evaluation of CIRNAC’s Indigenous Institutions and Governance Modernization Branch Crown‐Indigenous Relations and Northern Affairs Canada (CIRNAC) has prepared an evaluation of its activities in support of First Nations jurisdiction over land and fiscal management. CIRNAC has invited the First Nations Financial Management Board (FMB) to review the evaluation and provide comments.…

We are heartened by the increased authorities specifically given to the Action Plan Committee, and overall, the United Nations Declaration on the Rights of Indigenous Peoples Implementation Act (Bill 85) is in keeping with the change that Canada’s Indigenous Peoples have been asking for in the implementation of this important international instrument. While we see the…

This feedback was compiled primarily by FMB, with support and input from many Indigenous institutions. It was produced to communicate present concerns and ideas surrounding the UNDA Action Plan. More importantly, we are signaling the need and willingness for Indigenous institutions to have participation in the successful implementation of UNDRIP, as part of a long-term,…

FMB had the opportunity to provide feedback on Guideline B-20: Residential Mortgage Underwriting and we have outlined considerations which concern us. While we do not take issue in principle with any of the general objectives of these measures, we do have concerns as to how some may adversely affect First Nation Canadians. Read FMB’s Response…

The First Nations Financial Management Board (“the FMB”) is pleased to provide the Ombudsman for Banking Services and Investments with comments on the 2023 Governance Review. The OBSI should strive to identify and meet their obligations under United Nations Declaration on the Rights of Indigenous Peoples and under their public interest mandate. One simple and…

The First Nations Financial Management Board (“the FMB”) is pleased to provide the Ontario Securities Commission with comments on their 2023-2024 Statement of Priorities. The main point the FMB wishes to convey in this letter is that while we welcome the intention to “incorporate Indigenous peoples’ issues and perspectives in CSA policy work”, it is…

FMB is pleased to provide the International Public Sector Accounting Standards Board (“IPSASB”) with comments on the Consultation Paper (“CP”) – Natural Resources. FMB Comments on Natural Resources Consultation Paper

The First Nations Financial Management Board is pleased to provide you with our comments that emphasize the need for the inclusion of Indigenous consideration in the CAPSA Guideline – Environmental, Social and Governance Considerations in Pension Plan Management. FMB’s Response to ESG Considerations in Pension Plan Management

One of the purposes of the FMB is to enable the economic and social development of Indigenous peoples by improving their relationships with financial institutions, business partners and other governments. Canada acknowledged in its Consultation request that Canada’s federally regulated financial institutions (FRFls) should take into account the changing social and economic context in which…

On Monday, October 17, 2022, FMB Executive Chair Harold Calla spoke at The Indigenous and Northern Affairs Committee’s hearings on Bill C-29 – the establishment of a national council for reconciliation. Speaking notes are also available below. Watch the full video HERE. Speaking Notes from Harold Calla to INAN

Systemic change starts with supporting Indigenous-led initiatives, like the First Nations Fiscal Management Act institutions. According to a 2003 study by the Harvard Project on American Indian Economic Development and the Native Nations Institute for Leadership, Management, and Policy, economic development is not just the result of natural resources, education, geographic location, or chance. The…

FMB is pleased to provide you with our comments on the staff draft of the IFRS® Sustainability Disclosure Taxonomy. FMB Comments on IFRS® Sustainability Disclosure Taxonomy

FMB is pleased to provide you with comments on the Office of the Superintendent of Financial Institutions (“OSFI”) proposed Draft Guideline B-15 Climate Risk Management (“the guideline”). The guideline is an important step in setting clear guidance for the management of climate-related risks for Federally Regulated Financial Institutions (“FRFIs”). The FMB commends the work that…

The First Nations Financial Management Board (“FMB”) is pleased to provide this submission on CSA Consultation Paper 43-101 Consultation on National Instrument 43-101 Standards of Disclosure for Mineral Projects (“Consultation Paper”) issued April 14, 2022 by the Canadian Securities Administrators (“CSA”) on behalf of Canadian provincial and territorial securities regulatory authorities. FMB Submission on CSA Consultation…

The First Nations Financial Management Board (“the FMB”) is pleased to provide the International Public Sector Accounting Standards Board (“the IPSASB”) with a response to the Consultation Paper – Advancing Public Sector Sustainability Reporting (“the CP”). The CP is an important step in expanding disclosure requirements for sustainability-related financial information. The FMB commends the work…

FMB provided the International Sustainability Standards Board (ISSB) with comments on Exposure Draft ED/2022/S1 General Requirements for Disclosure of Sustainability-related Financial Information and Exposure Draft ED/2022/S2 Climate-related Disclosures. FMB Comment Letter on Exposure Draft ED/2022/S1 FMB Comment Letter on Exposure Draft ED/2022/S2

The First Nations Financial Management Board (“the FMB”) is pleased to provide comments on the proposed rule by the U.S. Securities and Exchange Commission (“the Commission”), File Number S7-10-22. The FMB is providing feedback on the proposed rule as climate-related disclosures by SEC registrants will impact investment decisions being made in Indigenous territories. These same…

The First Nations Financial Management Board (FMB) is thrilled to welcome the new Canadian Sustainability Standards Board (CSSB), which can help advance Economic Reconciliation with Indigenous Peoples in Canada. Today’s announcement was a clear response to the growing demand for standardized sustainability disclosures in Canada and around the world. It’s critical that disclosure standards recognize…

The First Nations Financial Management Board (FMB) and the First Nations Tax Commission (FNTC) call on the leader of the NDP, Jagmeet Singh, to meet regarding systemic changes necessary to accompany new investments in First Nations infrastructure. This follows recent a letter written by Harold Calla, Executive Chair, FMB, and C.T. (Manny) Jules, Chief Commissioner…

The First Nations Financial Management Board (« the FMB ») supports the creation of a Canadian Sustainability Standards Board (« CSSB ») that acknowledges, respects and reflects Indigenous Rights in Canada. To do this, First Nations, Inuit and Metis Peoples must have a voice in both Canadian and international standard setting activities and have a permanent seat in all…

C.T. Manny Jules, Chief Commissioner with the First Nations Tax Commission, and Harold Calla, Executive Chair at the First Nations Financial Management Board have submitted a letter to Prime Minister Justin Trudeau as the drafting of Budget 2022 nears completion. They are calling for the need to establish the First Nations Infrastructure Institute (FNII). The…

This Letter provides to securities regulators the FMB’s comments on a proposed national instrument for disclosure of climate-related matters. The FMB decided to comment because the Canadian Securities Administrators are required to cooperate and consult with Indigenous Peoples according to the United Nations Declaration on the Rights of Indigenous Peoples. FMB thought it important to…

It is the belief of signatories to this letter that the International Sustainability Standards Board (ISSB) should ensure that Environmental, Social and Governance (ESG) standards are made with the consultation of Indigenous Peoples. Standards that capture the United Nations Declaration of the Rights of Indigenous Peoples (UNDRIP), will create a much more equitable, favourable and…

Making ESG into ESGI: Letter to the Secretary General, Canadian Securities Administrators The signatories to this letter are all involved in enabling the economic and social development of Indigenous peoples including by improving relationships with financial institutions, business partners and other governments. Each organization that has signed this letter advocates for their members on financial…

The Need To Marry Economic Reconciliation With Social Reconciliation The Province of British Columbia made history by passing the Declaration on the Rights of Indigenous Peoples Act unanimously in the B.C. legislature in 2019. This legislation establishes the United Nations Declaration on the Rights of Indigenous Peoples as the framework for reconciliation in B.C. It…