Turbulent Waters Ahead: How U.S.-Canada Tensions Threaten Canadian Banks’ Capital Stability
Former OSFI Deputy Warns Rising U.S. Tensions Heighten Risks to Canadian Bank Capital
September 25, 2025 – Toronto
A former top banking regulator from Canada has warned the nation’s largest banks. He sees rising tensions with the United States as a risk to their overseas assets and capital. Mark Zelmer, who served as deputy superintendent at the Office of the Superintendent of Financial Institutions (OSFI), points out that Canadian banks are more exposed because they work heavily across borders, mainly in the U.S.
On Thursday, the C.D. Howe Institute published a paper by Zelmer. He states that the world is changing. Foreign authorities might soon block assets held by Canadian financial firms when economies are under stress. Such actions could block banks’ access to vital capital. This in turn may lead to serious challenges in liquidity and stability.
Potential Asset Ring-Fencing Amid Rising Tensions
Zelmer recalls the case of Maple Bank in Canada. In 2016, a German bank saw its Canadian assets blocked after it ran into trouble. This past event shows that regulators can stop cross-border capital flows during crises. He warns that the United States or other nations may take similar or even stricter measures. This is especially true for Canadian banks that have large deposits and operations overseas.
Zelmer writes, "The risk of such behavior is more acute today. International cooperation is harder, especially with the United States."
Canada’s "Big Six" banks—Royal Bank of Canada, Toronto-Dominion Bank, Bank of Montreal, Bank of Nova Scotia, Canadian Imperial Bank of Commerce, and National Bank of Canada—have strong ties in the U.S. For banks like BMO and TD, their U.S. operations sometimes match the size of their Canadian business in both assets and revenue. This closeness may allow foreign regulators to restrict capital in a crisis. This would make bank runs and financial shocks harder to manage.
Recommendations to Mitigate Risk
Zelmer advises banks and insurers in Canada to keep more surplus capital and liquidity at home. While this may cost more or pay lower tax benefits than investing offshore, it lowers the control that foreign regulators have during hard times.
He also asks for clearer public disclosure and more regulatory openness. Banks should share how their Canadian and overseas parts work together. Knowing this will help policymakers and market players see the risks of asset blocks by foreign authorities.
Zelmer explains, "If these investments sit in foreign systems or custody accounts, there is a risk they might be blocked or frozen." He warns that Canada’s biggest banks have large investments in foreign securities that also appear on their home balance sheets.
He stresses that even strong banks can suffer from bank runs. He mentions Home Capital Group, which faced liquidity issues in 2017. Zelmer calls on OSFI and other policymakers to watch bank practices closely. They must manage liquidity risk while thinking about the threat of foreign asset restrictions.
Ongoing Engagement with Canadian Banks
Zelmer notes that OSFI is in active talks with major banks across Canada. They discuss steps to face these new challenges. While details have not yet been finalized, regulators clearly see the risks that come from cross-border capital exposure. This understanding is vital given today’s uncertain global politics.
This report offers the views of an expert former regulator. It points out key vulnerabilities in Canada’s banking system as international relations worsen. The report calls for careful capital management and strong regulation to protect financial stability.
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