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May 19, 2023 ACORN Canada would like to make a submission with reference to the feedback sought by the Department of Finance in relation to a proposed regulation-making authority to allow for certain types of loans to be exempt from the criminal rate of interest in future regulations. [...] ACORN members are encouraged to note that the federal government announced changes to the Criminal Code to lower the criminal rate of interest to 35% APR in the Budget 2023. [...] However, at the same time, we are deeply concerned that any exemptions from the criminal rate of interest in future regulations can undo the positive impact of the lowering of the criminal interest rate. [...] ACORN strongly feels that the Criminal Rate of Interest must apply to all consumer credit in the market today or in the future (including those yet invented), be inclusive of all associated costs and fees (including insurance) and must be rigorously enforced. [...] How can these exemptions be clearly and precisely defined in regulation (e.g., loan size, loan term, type of legal entity borrowing, etc.)? As stated earlier, the Criminal Rate of Interest must apply to all consumer credit in the market today or in the future, regardless of loan size, term, or type of legal entity lending, and be inclusive of all associated costs, including insurance.