Our Public Comments

Our Public Comments

The FMB is often invited to provide expert commentary on proposed legislation, regulations, and guidelines proposed by governments, agencies, and organizations. These range from corporate setting to policy changes that impact or could impact First Nations. Below are some of our submissions/public comments.

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FMB Comments to the World Benchmarking Alliance Regarding the Draft Integrated Transition Assessment

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…

Ontario Securities Commission Action Plan for Truth and Reconciliation

There are several aspects to the Ontario ×Trade-able financial property such as stocks and bonds.See More 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…

Comments on PSAB’s Exposure Draft for a New Canadian Intangible Assets Standard

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…

FMB Response to IPSASB Regarding Climate-related Disclosures

The International Public Sector Accounting Standards×Required or agreed levels of quality or excellence.See More 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…

FMB Response to IPSASB Regarding TNR Disclosures

The International Public Sector Accounting Standards×Required or agreed levels of quality or excellence.See More 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…

Global Battery Alliance – Indigenous Peoples Rulebook

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;…

Phase Three Consultation on Proposals to Strengthen Canada’s Financial Sector

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

International Federation of Accountants Proposed Revisions to IES 2, 3 and 4 – Sustainability

The International Federation of Accountants (IFAC) has proposed changes to certain of its international education standards×Required or agreed levels of quality or excellence.See More. 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…

Consultation on Exempting Indigenous Settlement and Community Trusts from Alternative Minimum Tax

FMB submitted a response to the Alternative Minimum Tax (AMT) legislative changes from × Plan ou description des fonds attendus et des dépenses prévues durant une période donnée. See More 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…

Adoption of Canadian Sustainability Disclosure Standards 1 and 2

FMB submitted a letter of comment to the Canadian Sustainability Standards×Required or agreed levels of quality or excellence.See More Board (CSSB) regarding its inaugural sustainability standards. In brief, we have submitted the following: FMB’s Comment to CSSB

FMB Submission for the 2024 UNDA Action Plan Progress Report

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…

Consultation on Strengthening Competition in the Financial Sector

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…

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