The Ontario Securities Commission recently published its draft Action Plan for Truth and Reconciliation (APTR) for engagement and comment.

The news release put it as follows:

• Further to the Calls to Action from the Truth and Reconciliation Commission of Canada, the OSC is developing the APTR as part of its vision to ensure that Ontario’s capital markets are inviting, thriving and secure for everyone. The APTR will serve as a roadmap for how the OSC can build a culturally aware, safe and more inclusive workforce, while working collaboratively with Indigenous peoplesand partners and communities to foster a culture of inclusion and investor confidence for the benefit of all.
• “The OSC is committed to pursuing truth and reconciliation and insupporting equitable access to the capital marketsby, with and for Indigenous Peoples in Ontario,” said Grant Vingoe, CEO of the OSC. “We look forward to engaging with and receiving feedback that we will consider when we publish our inaugural Action Plan for Truth and Reconciliation.”

The document virtually shimmers with commitment, referring to the hiring of Creative Fire, an Indigenous-owned consulting and communications firm, and to “extensive internal and external engagements (including) Indigenous political organizations in Ontario, Indigenous-led market participants, and Indigenous experts in the capital markets, among others.” Much of the resulting plan is fairly inward-looking, concerned with the workings of the OSC itself, for example in “(building) a culturally aware, culturally safe, and inclusive workforce that respects and reflects the diversity of Indigenous Peoples and communities in Ontario” or “(reviewing) the employee benefits program or other providers for culturally sensitive healthcare options and explore opportunities for programs that foster a sense of inclusion and demonstrate the OSC’s commitment to supporting the evolving needs of Indigenous employees.” Of broader interest are the more outward-facing elements:

• Truth includes recognizing that Indigenous Peoples have been systematically excluded from equal participation in the economy, including the capital markets.
• Reconciliation includes engaging with Indigenous Peoples and organizations to better understand their perspectives, needs and experiences within the capital markets, reflecting on them meaningfully, and making appropriate changes to enhance their participation.

The document seems vague though on that aspect of the Truth. After all, more people are systematically excluded from the capital markets than not (those in poverty, to take an obvious example), and nothing will happen in our lifetime to change that. Because the capital markets inherently depend on a form of exploitation (on allowing the holders of capital to extract rent from the users of it), there is no “equal participation” in the markets that’s not also a form of shared complicity. Looked at that way, the “appropriate changes to enhance (the) participation” of Indigenous Peoples in the capital markets might seem like a promise to develop a more specifically poisoned apple (it’s hard to imagine that any amount of Indigenous advocacy would have caused the OSC to not kick aside the sustainability standards, to take a recent example). And if we see reconciliation as a process necessarily involving a movement of two sides…well, the capital markets ain’t moving, and if they are, it’s mainly to become faster and meaner. It’s notable that the document devotes five of its thirty-two pages entirely to showcasing a traditional canoe, commissioned by the OSC “as a metaphor to represent our Truth and Reconciliation journey.” It’s an impressive, respectfully presented artifact, but one that inherently gives the document a performative feel: a “journey” that so strenuously begins in metaphor, one feels, may not be that likely to arrive at a very tangible destination.

My friend Walter Ross suggested to me that the “real question is how the OSC, and other Canadian securities commissions, should relate to the First Nations Financial Management Board,” an organization unmentioned in the document, a passing acknowledgement aside. The FMB “establishes financial management standards that lead to the principles of sound and transparent practices,” attempting to counter, in concert with other organizations, the challenges of infrastructure being “two to three times more expensive to finance on First Nation lands,” and of investments on such lands being “four to five times more expensive…due to lack of investor confidence, legislative uncertainty, and a lack of financial information and statistics.” These challenges, it’s fair to note, are not at all the OSC’s problem to solve. But, returning to my earlier point, they do seem relevant to why the First Nations might feel inhibited in full participation in the capital markets, and their absence from the plan is just one item that speaks rather loudly to its limitations.

One of the action items is to: “Develop or promote existing content on GetSmarterAboutMoney.ca tailored to Indigenous audiences to address the knowledge and resource gap systemically experienced by Indigenous Peoples as a result of colonialization, such as financial literacy content specific for individuals.” That such as speaks volumes, as if the best online education material in the world could begin to grapple with the systemic toll of colonialization. Ah well, no doubt the process will yield many “tough but necessary lessons,” as the document puts it…

The opinions expressed are solely those of the author.