[2] For example, a single person receiving assistance through Ontario Works currently receives a maximum of $560 per month ($6720 annually). The 2007 Low Income Cutoff for a single person was $14,914 for rural areas and $21,666 for large urban areas.
[3] For more information on the Government’s anti-poverty initiative, see the Government of Ontario’s website, www.ontario.ca/GrowingStronger.
[4] The most recent figures are those provided by the Financial Consumer Agency of Canada. See Les Études de Marché Créatec, General Survey on Consumer Financial Awareness, Attitudes, and Behaviours (Ottawa: Financial Consumer Agency of Canada, 2006) at page 4. 96 per cent of those responding to this survey reported holding a bank account. Extrapolated to population figures, it was estimated that nearly 1 million adult Canadians do not hold a bank account.
[5] R. Morisette, “On the Edge: Financially Vulnerable Families”, Canadian Social Trends (Statistics Canada: Winter 2002) at 13.
[6] The poverty rate for First Nations households is 34 per cent. (Statistics Canada, Selected Income Characteristics, 35). A 2000 Report by the Ontario Federation of Indian Friendship Centres reported that over 50 per cent of Aboriginal children growing up off-reserve in Ontario are poor (Ontario Federation of Indian Friendship Centres, Urban Aboriginal Child Poverty: A Status Report on Aboriginal Children and their Families in Ontario (Toronto:2000), available online at www.ofifc.org/ofifc.home/page/Document/UP_FILE/20070723101231NVN.pdf
[7] For a very thorough and recent discussion of the phenomenom of low-income among racialized communities, including newcomers, see Michael Ornstein, Ethno-Racial Groups in Toronto 1971 – 2000: A Demographic and Socio-Economic Profile (Institute for Social Research, January 2006).
[8] Ontario Association of Food Banks, Our Choice for a Better Ontario: A Plan for Cutting Poverty in Half by 2020 (Toronto: 2008), at 7, available online at www.oafb.ca.
[9] These initiatives also discussed in detail in Part IV. As examples, Quebec has longstanding legislation prohibiting any charge for exchanging or cashing a cheque issued by the federal, provincial or any municipal government; the provinces of Manitoba and British Columbia have undertaken legislative initiatives to regulate the fees charged for cashing government cheques; and the federal government, in conjunction with an indemnity agreement with the banks, prohibits banks from charging a fee to non-account holders for cashing a federal government cheque in an amount less than $1,500.
[10] Also see, Financial Consumer Agency of Canada, What You Should Know About Low-Cost Accounts, available online at http://www.fcac-acfc.gc.ca/eng/publications/LowCostAccounts/ LowCostAccounts_TOC_e.asp.
[11] Acceptable identification includes a driver’s license, social insurance number, Canadian birth certificate, current passport (either Canadian or from another country), debit or bank cards, credit cards, Old Age Security cards, Certificate of Indian Status, Certificate of Canadian Citizenship or Naturalization, or Permanent Resident card. This arrangement is dealt with in more depth at section IV.E.1.
[12] Bank Act, S.C. 1991, c. 46, s. 458(4); Access to Basic Banking Regulations, S.O.R./2003-184, ss. 6-10.
[13] As these arrangements are local and informal, it is difficult to assess how common they are. Often, they also involve initiatives on the part of the social service agency to provide verification of the cheque as some protection against fraud.
[14] The Canadian Payday Loans Association, which represents 21 payday loan businesses, has adopted a Code of Best Business Practices which prohibits members from providing payday loans to social assistance recipients. The Code is available online at http://www.cpla-acps.ca/english/consumercode.php. The practice of providing payday loans to social assistance recipients was referenced during Committee hearings on Bill 48: see Ontario Legislative Assembly, Official Report of Debates (Hansard), Standing Committee on General Government, (26 May 2008) at 1430 (Honourable Ted McMeekin).
[15] Ipsos-Reid, Public Experience with Financial Services and Awareness of the FCAC (Ottawa: Financial Consumer Agency of Canada, 2005) at page 10.
[16] Wendy Pyper, “Payday Loans”, Perspectives (Statistics Canada: Ottawa, April 2007).
[17] Les Études de Marché Créatec, cited above at note 4, at page 5.
[18] Les Études de Marché Créatec, cited above at note 4, at page 5.
[19] Manitoba Public Utilities Board, Transcript of Proceedings, “To Determine Allowable Fee for Cashing Government Cheques” (Manitoba: March 8, 2007) at 286. Available at: http://www.pub.gov.mb.ca/transmisc.html
[20] Figures on government cheques in this section are based on information provided through the Office of the Provincial Controller.
[21] The Ontario Child Benefit was launched in July 2008. This is a monthly benefit to low-income families with children under the age of 18, payable both to families that are employed and those in receipt of social assistance. Families in receipt of social assistance will have their social assistance rates adjusted to take into account the new Ontario Child Benefit and the National Child Benefit Supplement. For more information on the Ontario Child Benefit see http://www.gov.on.ca/children/english/programs/ocb/index.html.
[22] For a general overview, see Human Resources and Social Development Canada, Social Assistance Statistical Report: 2005.
[23] Ministry of Community and Social Services, Ontario Social Assistance Quarterly Report (Toronto: Social Policy Development Division, March 2008).
[24] Statistics Canada, Low Income Cut-offs for 2007 and Low Income Measures for 2006 (Ottawa: Ministry of Industry, 2008).
[25] See Les Études de Marché Créatec, cited above at note 4, at 1.
[26] See Les Études de Marché Créatec, cited above at note 4, at 8.
[27] Jerry Buckland, Strengthening Banking in Inner Cities: Practices & Policies to Promote Financial Inclusion for Low-Income Canadians (Canadian Centre for Policy Alternatives: Ottawa, March 2008).
[28] Centre Francophone de Toronto – Nos clients doivent donc, surmonter plusieurs obstacles dont la barrière linguistique, le choc culturel et surtout sur le plan économique, l’intégration est de plus en plus difficile le marché du travail leur étant inaccessible. La plupart ne peuvent compter que sur le chèque d’aide sociale et l’aide financière qu’ils reçoivent du gouvernement. Et comme ils ne peuvent pas ouvrir facilement un compte bancaire soit par ignorance de leurs droits ou des exigences des banques ils se tournent vers des services d’une société de prêt sur salaire ou d’encaissement de chèques.
[29] For information on the activities of the FCAC, visit their website at www.fcac-acfc.ca.
[30] See www.fin.gc.ca/toce/2003/cu_e.html.
[31] According to a recent survey conducted for the FCAC, almost half of all Canadians surveyed reported using the Internet to do some of their everyday banking activities. Over 90 per cent of Canadians are estimated to have debit cards. See Les Études de Marché Créatec, cited at note 4, at pp. 4 and 7.
[32] See Les Études de Marché Créatec, cited at note 4, at pp. 12, 15, and 16.
[33] Task Force on the Future of the Canadian Financial Services Sector, Background Paper #4: Change, Challenge, Opportunity: Canadian’s Expectations and Corporate Conduct (Ottawa: Department of Finance, 1998) at 11.
[34] This is the definition adopted by the federal government’s Policy Research Initiative: See Policy Research Initiative, Why Financial Capability Matters (Government of Canada: Ottawa, 2005) at page 6.
[35] See note 4 above.
[36] In the United States, conservative estimates of the proportion of the population that is unbanked hover around 10 per cent. See Jean Ann Fox, and Patrick Woodall, Cashed out Consumers Pay Steep Premium to “Bank” at Check Cashing Outlets (Consumer Federation of America: November 2006) at 16.
[37] Policy Research Initiative, cited above at note 34, at pp. 7-12.
[38] Task Force on the Future of the Canadian Financial Services Sector, cited above at note 33, at page 21.
[39] Manitoba Public Utilities Board, see note 19, above.
[40] Task Force on the Future of the Canadian Financial Services Sector, cited above at note 33 at page 22.
[41] Tavia Grant, “Sharia compliant finance is increasingly popular”, Globe and Mail (7 May, 2007). The South Asian Legal Clinic noted that as a result of the lack of appropriate services, some of their clients are operating in a cash economy.
[42] Jerry Buckland, Social and Economic Factors to Consider in Setting Government Cheque Cashing Fees in Manitoba (Winnipeg: Manitoba Public Utilities Board, 2006) at page 9.
[43] Task Force on the Future of the Canadian Financial Services Sector, cited above at note 33, at page 22.
[44] Michael Grant, Canada’s Social Payment Disbursement System and the Financial Services Sector (Ottawa: Task Force on the Future of the Canadian Financial Services Sector, 1998) at page 12.
[45] Financial Consumer Agency of Canada, cited at note 10 above. Also see Appendix E.
[46] Access to Basic Banking Regulations, cited at note 12.
[47] Financial Consumer Agency of Canada, 2004-2005 FCAC Mystery Shopping Results, available online at www.fcac-acfc.gc.ca/eng/Publications/SurveyStudy
[48] Access to Basic Banking Regulations, cited above at note 46, at s. 4.
[49] Erika Khandor and Kate Mason, The Street Health Report 2007 (Toronto: Street Health, September 2007), available at: http://www.streethealth.ca/Downloads/SHReport2007.pdf.
[50] See, for example, Jerry Buckland, cited above at note 42 at page 15; Michael Grant, cited above at note 44, at page 28.
[51] Bill 85, Photo Card Act, 2008, at section 3. Bill 85 received first reading on June 3, 2008 and second reading on June 11, 2008.
[52] Ministry of Transportation, Enhanced Driver’s License (EDL), Photo Card, and Photo Comparison Technology, Frequently Asked Questions, June 3, 2008.
[53] S.O. 2004, c. 3, Sched. A.
[54] Ontario, Legislative Assembly, Official Report of Debates (Hansard) (December 13, 1990) (Hon. E. Gigantes).
[55] Canadian Bankers Association, “Taking a Closer Look: Access to Basic Banking Services” (August 2006), available online at http://www.cba.ca/en/content/stats/fastfacts/ABBS2006_ UpdateEN(1).pdf.
[56] S.O.R./2002-39.
[57] Cheque imaging technology will allow financial institutions to exchange electronic cheque images rather than physical cheques.
[58] Les Études de Marché Créatec, cited above at note 4, at page 6.
[59] Jerry Buckland and Thibault Martin, Fringe Banking in Winnipeg’s North End (Canadian Centre for Policy Alternatives: March 2005) at 24.
[60] Jerry Buckland et al, Choosing Financial Services Where the Options are Limited (May 2008), available online at: http://io.uwinnipeg.ca/~buckland/.
[61] As of July 2008, the fee for cheque cashing was 1.4 percent, with no additional transaction fee.
[62] Les Études de Marché Créatec, cited above at note 4, at pp. 4 and 7.
[63] Kaufman v. Royal Bank of Canada, [1994] O.J. No. 4162 (Small Claims Court)
[64] Richer v. Ubdegrove, [1989] O.J. No. 73 (Small Claims Court).
[65] Ontario Works Act, 1997, S.O. 1997, c. 25, Schedule A., s. 23(1).
[66] Ontario Disability Support Program Act, S.O. 1997, c. 25, Sched. B, s. 18.
[67] Ontario Works Policy Directive 53.0, “Protection from Seizure and Garnishment”.
[68] “White label” ABMs are usually privately owned, and are often found in convenience stores. While ABMs operated by mainstream financial institutions offer a range of basic banking services, such as deposits, withdrawals, bill payments, and transfers, white label ABMs offer only cash withdrawal services. As well, they charge a fee in addition to regular banking fees of approximately $1.25 per withdrawal. Angie Barrados, Banking in Rural Canada: Ensuring that Rural Consumers Have Adequate Service (Ottawa: Public Interest Advocacy Centre, 2000) at page 25.
[69] Jacquie McNish, “The Dark Side of Class Action Settlements” The Globe and Mail (18 June 2005).
[70] Angie Barrados, cited above at note 68, at page 14.
[71] Notice of Branch Closure (Banks) Regulation, SOR/2002-104, ss. 4-6.
[72] S.C. 1991, c. 48, ss. 375(a) and 375.1, as amended by S.C. 2001, c. 9, ss. 306 and 307.
[73] Canadian Rural Partnership, “Rural Action Plan Report Card” (Government of Canada: November 2002), available at www.rural.gc.ca/conference/documents/card_e.phtml#2.
[74] ACORN Canada, Protecting Canadians’ Interest: Reining in the Payday Lending Industry (Vancouver: ACORN Canada, November 2004), available at: http://acorn.org/fileadmin /International/Canada/Reports/Payday_Lending_Report.pdf; United Way of Greater Toronto, Losing Ground: The Persistent Growth of Family Poverty in Canada’s Largest City (Toronto: November 2007); Jerry Buckland and Bruce Guenther, “There are No Banks Here”: Financial & Insurance Exclusion in Winnipeg’s North End (September 2005).
[75] Iain Ramsay notes the existence of this form of cheque cashing, without further comment in his paper Access to Credit in the Alternative Consumer Credit Market (Office of Consumer Affairs and Ministry of the Attorney General: February 2000) at footnote 29. When questioned, the organizations serving low-income individuals that the LCO spoke with were aware that some clients occasionally cashed cheques at, for example, convenience stores, but did not believe it to be a very widespread practice.
[76] In 1976, approximately 1.5 billion cheques were cleared through the chartered banking system, and it was anticipated that that number would exceed 2 billion by 1980 (see www.fin.gc.ca/toce/2000/ccu_e.html). However, according to the Canadian Payments Association, the number of cheques cleared in 2007, excluding large value cheques, was just over 1 billion (see http://www.cdnpay.ca/publications/acss_ann.asp).
[77] Katherine Turner and Andrew Bolter, “Submission to the Task Force on the Future of the Canadian Financial Services Sector” (LIFE*SPIN, 1997), available at: http://www.fin.gc.ca/ taskforce/pdf/lifespin1.pdf.
[78] Les Études de Marché Créatec, cited at note 4 above, at page 5.
[79] Manitoba Public Utilities Board, Transcript of Proceedings, cited above at note 19, at page 55 (North West Company).
[80] See http://www.moneymart.ca/about.asp.
[81] Ontario, Legislative Assembly, Official Report of Debates (Hansard), No. 1102-A (19 December 1991) (G. Morin).
[82] Ontario, Legislative Assembly, Official Report of Debates (Hansard), Standing Committee on General Government, (28 May 2008) at 1450 (B. Whitelaw).
[83] The Canadian Payday Loans Association has developed a Code of Best Business Practices for its members (see note 14 above), and has an Ethics Commissioner who monitors compliance.
[84] See Ontario, Legislative Assembly, Official Report of Debates (Hansard), Standing Committee on General Government, (28 May 2008) at 1450 (B. Whitelaw). Also see Joanna Smith, “New rules Attract U.S. Lenders” Toronto Star (11 April 2008), available at: www.thestar.com
[85] Ontario, Legislative Assembly, Official Report of Debates (Hansard), No. 1015 (5 April 1984) (R.F. Johnston).
[86] Bill 210, An Act to Prohibit the Charging of Fees for the Cashing of Government Cheques, introduced January 26, 1989.
[87] Ontario, Legislative Assembly, cited above at note 81.
[88] Ontario, Legislative Assembly, Official Report of Debates (Hansard), No. 1068 (19 October 1992), (Honourable M. Boyd, Minister of Community and Social Services).
[89] Ipsos-Reid, cited above at note 15, at page 11.
[90] Pollara, Payday Loan Customer Survey – Ontario (Canadian Payday Loan Association: November 2007).
[91] Submission to the LCO from National Money Mart Canada, June 2008.
[92] Environics Research Group, Understanding Consumers of Canada’s Payday Loan Industry (Canadian Association of Community Financial Service Providers, 2005) at 11.
[93] The Manitoba Public Utilities Board, in its hearings into setting rates for fees for cheque cashing services, concluded that cheque cashing was now a secondary source of revenue for AFS businesses: Manitoba, the Public Utilities Board Act, Maximum Fees for Cashing Government Cheques, Order 72/07, May 28, 2008 at 11. Available at: http:www/pub. gov.mb.ca/pdf/misc/072.07.pdf.
[94] R.S.C. 1985, c. C-46, s. 347.
[95] The Canadian Payday Loans Association mandate explicitly includes working with government towards a regulatory framework: see http://www.cpla-acps.ca/english/home.php.
[96] See note 1, above.
[97] Ontario, Legislative Assembly, Official Report of Debates (Hansard), (31 March 2008) (Hon. T. McMeekin, Minister of Government Services).
[98] In his submission to the Standing Committee on General Government in its review of Bill 48, the Payday Loans Act, 2008, the Executive Vice-President of Cash 4 You Corp, Amir Mahmoudzadeh stated that his stores charged 59% interest for a payday loan, and in addition charged a cheque cashing fee of approximately $20 per $100. (Ontario Legislative Assembly, Official Report of Debates (Hansard), Standing Committee on General Government, (26 May 2008) at 1530).
[99] See Les Études de Marché Créatec, cited above at note 4, at page 5.
[100] Ipsos-Reid, cited above at note 15, at page 15.
[101] The Canadian Payday Loan Association’s Code of Best Business Practices (see note 14 above) states that “A Member shall not grant payday loans to customers on the basis of social assistance payments received by that customer.”
[102] Ontario Legislative Assembly, Official Report of Debates (Hansard), Standing Committee on General Government, (26 May 2008) at 1430 (Hon. T. McMeekin).
[103] Cheque cashing businesses have been a feature of the American financial landscape since the 1930s, although they grew very rapidly in the 1980s, following the passage of the Bank Deregulation Act (see http://www.fisca.org/NavigationMenu/AboutFISCA/FiSCA.htm.). It is estimated that there are over 26,000 cheque cashing centres in the United States, serving over 30 million customers (Matt Fellowes and Mia Mabanta, Banking on Wealth: America’s New Retail Banking Infrastructure and Its Wealth-Building Potential, available at http://www.fisca.org/pr106.htm). The cheque cashing industry in the United States processes more than 180 million cheques annually worth more than $55 billion, generating $1.5 billion in fees (Michael S. Barr ”An Inclusive, Progressive National Savings and Financial Services Policy”, 1 Harv. L. y Rev. 161 (2007) at 163).
[104] Ernst & Young, The Cost of Providing Payday Loans in Canada (Tax Policy Services Group, October 2004) at 37.
[105] Professor Jerry Buckland, cited above at note 59, at page 17.
[106] Manitoba Public Utilities Board, cited above at note 93, at page 11.
[107] Michael S. Barr ”An Inclusive, Progressive National Savings and Financial Services Policy”, 1 Harv. L. y Rev. 161 (2007) at 163.
[108] Michael S. Barr, Banking the Poor: Policies to Bring Low-Income Americans into the Financial Mainstream (The Brookings Institute: September 2004) at 2.
[109] Gerald Goldman and James R. Wells, Check Cashers are Good Bank Customers (Financial Service Centers of America, Inc.: 2002) at 2.
[110] Jerry Buckland, cited above at note 42, at page 27.
[111] Les Études de Marché Créatec, cited above at note 4, at page 8.
[112] Les Études de Marché Créatec, cited above at note 4, at page 8.
[113] The Social Research and Demonstration Corporation is a registered charity that researches policy innovations through practical demonstrations. Further information may be accessed at www.srdc.org.
[114] Ontario Association of Food Banks, cited above at note 8, at page 51.
[115] The Alberta Works Manual states that:
The direct deposit method of payment is mandatory for Income Support (IS) clients, unless specifically exempted, as it:
· Is less costly and more efficient resulting in increased savings to taxpayers in administrative costs and fewer phone calls to workers.
· Provides cost savings to clients (who may otherwise pay fees at cheque cashing agencies).
· Encourages client financial responsibility.
(Alberta, Employment and Immigration, Alberta Works Policy Manual, Expected to Work/Not Expected to Work/ Administrative Procedures, Payment Methods and Processes, Direct Deposit Section at 1, available online at http://employment.alberta.ca/hre/awonline/reg/ Display.asp).
[116] Michael Grant, cited above at note 44, at page 14.
[117] A thorough explanation of the operation of the Alberta program can be found in the Alberta Works Policy Manual: Alberta, Employment and Immigration, Alberta Works Policy Manual, Expected to Work/Not Expected to Work/ Administrative Procedures, Payment Methods and Processes, Direct Deposit Section, available online at http://employment.alberta. ca/hre/awonline/reg/Display.asp.
[118] Communication from Alnoor Rajan, Director of Financial Operations, Alberta Employment and Immigration, July 31, 2008.
[119] A thorough review and analysis of the implementation of the Alberta direct deposit program may be found in Michael Grant, cited above at note 44.
[120] See Michael Grant, cited above at note 44, at page 17.
[121] Ontario, Legislative Assembly, Official Report of Debates (Hansard), No. 1102-A (19 December 1991) (Hon. M. Boyd).
[122] Michael Grant, cited above at note 44, at page 16.
[123] Task Force on the Future of the Canadian Financial Services Sector, cited above at note 33, at 31.
[124] Canadian Bankers Association, cited above at note 55.
[125] Jonathan Fowlie, “B.C. to Put Welfare Payments on Government Debit Cards” Vancouver Sun, (December 6, 2007); Ministry of Employment and Income Assistance, 2008/09 – 2010/11 Service Plan (February 2008) at 16; Tara Perkins, “RBC looks to market prepaid benefits cards, The Globe and Mail (26 March 2008) B3.
[126] For example, MasterCard provides a DirectExpress debit card for payments to Social Security recipients in a number of American states.
[127] Communication from Alnoor Rajan, Director of Financial Operations, Alberta Employment and Immigration, July 31, 2008.
[128] Canadian Payments Association, Rule G8: Procedures/Criteria Pertaining to the Encashment of Government of Canada Payment Items for Non-Customers (Implemention Date, May 21, 2001), s. 6.
[129] Access to Basic Banking Services Regulations, cited at note 12, at ss. 8, 11.
[130] Access to Basic Banking Services Regulations, cited at note 12, s. 6(1).
[131] Canadian Payments Association, cited above at note 128, at s. 3(b).
[132] Canadian Payments Association, cited above at note 128, at s. 8.
[133] Access to Basic Banking Services Regulations, cited at note 12, s. 10.
[134] Financial Consumer Agency of Canada, cited above at note 47.
[135] See note 12, above.
[136] Task Force on the Future of the Canadian Financial Services Sector, cited above at note 33. at 31.
[137] Canadian Bankers Association, cited above at note 55.
[138] Les Études de Marché Créatec, cited at note 4 above, at page 8.
[139] Ipsos-Reid, cited above at note 15, at page 16.
[140] Financial Consumer Agency of Canada, cited above at note 47.
[141] 127097 Canada Ltd. v. Quebec (A.G.) (1991) R.J.Q. 2526 (C.A.). For a recent case in which the Supreme Court of Canada considered the constitutionality of provincial legislation regarding insurance that affecting the activities of banks, see Central Western Bank v. Alberta, [2007] 2 S.C.R. 3, 2007 SCC 22.
[142] The prohibition dates back to the 19th century. See Banks and Banking Act, R.S.c. 1890, c. 31, s. 103, which states that “The bank shall not charge any discount or commission for cashing any official cheque of the Government of Canada, or of any department thereof, whether drawn on itself or another bank”.
[143] Bank Act, cited above at note 12, at s. 458(4).
[144] Bank Act, s. 458.1(1); Access to Basic Banking Services Regulations, s. 7, citations at note 12 above.
[145] Ipsos-Reid, cited above at note 15, at 16.
[146] Consumer Protection Act, R.S.Q., c. P-40.1, s. 251.
[147] Letter from Me Johanne Renaud, Agente de recherche en droit, Office de la protection du consommateur, to the Law Commission of Ontario (8 May 2008) at 1.
[148] Consumer Protection Act, cited at note 146, s. 278.
[149] 127097 Canada Ltd. v. Quebec (A.G.) (1991) R.J.Q. 2526 (C.A.) at 5.
[150] Gillian Wansbrough, “Firm stops cashing government cheques: Service Charges Weren’t Legal, Consumer Protection Office Says”, The Gazette (Dec 31, 1991) A4.
[151] See http://www.desjardin.com/en/a_propos/qui-nous-sommes/index.jsp.
[152] Sue Lott and Michael Grant, Fringe Lending and “Alternative” Banking: The Consumer Experience (Ottawa: Public Interest Advocacy Centre, November 2002) at 61-62.
[153] “Poor Canadians bounced from banks: Despite having proper ID, welfare recipients refused opportunity to open account”, Edmonton Journal (June 28, 1996) B.11.
[154] Consumer Protection Amendment Act (Cheque Cashing Fees), S.M. 2006, c. 17.
[155] Government Cheque Cashing Fees Regulation, (Man. Reg. 191/2006), s. 4.
[156] Manitoba Legislative Assembly, Hansard, No. 75 (May 24, 2006) at 2504 (Hon. G. Selinger, Minister of Finance).
[157] Consumer Protection Amendment Act (Payday Loans), S.M. 2006, c. 31. The Act has not yet fully come into force as it involves a licensing process.
[158] Manitoba Legislative Assembly, cited above at note 156, at 2743.
[159] Manitoba Public Utilities Board, cited at note 93, above.
[160] See above.
[161] Manitoba Public Utilities Board, cited at note 93, at pp. 19-20.
[162] The fifteen unregulated states are Alabama, Alaska, Colorado, Idaho, Kansas, Michigan, Missouri, Montana, Nebraska, New Hampshire, New Mexico, Oklahoma, South Dakota, Texas and Wyoming.
[163] Ohio provides a comprehensive example of such regulation.
[164] This is the form of regulation in Arkansas, Connecticut, Ohio and Pennsylvania.
[165] Delaware, New York and West Virginia.
[166] California, Florida and Maine.
[167] Arkansas, Maryland, California, Hawaii, Pennsylvania, Tennessee and Vermont.
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