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The Commissioner of the Financial Consumer Agency of Canada (FCAC) is seeking comments on three proposed guidance documents it has published to assist with the implementation of new disclosure requirements set out in the April 2015 update to the Code of Conduct for the Credit and Debit Card Industry in Canada (the Code). Submissions to FCAC regarding the draft guidance documents are due April 15, 2016.

The April 2015 update amended the code to require, among other things, that all merchant-acquirer agreements include a cover page containing an information summary box and fee disclosure box. The proposed guidance documents (CG-10, CG-15 and CG-16) are meant to clarify the April 2015 update and to provide further guidance with respect to compliance.

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Torys LLP

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