We are writing in regards to the Department of Finance’s consultation regarding the proposed acquisition of HSBC Bank of Canada (HSBC) by RBC Royal Bank (RBC). The undersigned groups urge the Department to either reject the proposed acquisition, or accept it conditional on RBC i) implementing a Credible Climate Plan and ii) committing to meeting or exceeding HSBC’s international commitments to ending investments in fossil fuels.

RBC is both the largest bank in Canada and the largest financier of fossil fuels globally. HSBC, by contrast, set a global precedent by announcing a policy to stop financing new oil and gas projects and has stated that its investments in fossil fuels will decrease. The Canadian federal government’s climate goals can only be met if private finance flows in the right direction. If the Department were to accept the proposed acquisition without adding climate related conditions, the acquisition would result in: impeding progress on Canada’s fight against climate change, fewer green options for Canadian banking consumers, and unmanageable levels of climate-related risks destabilizing the Canadian financial system.

RBC’s ongoing financing of high emitting companies and projects contributes to worsening the effects of climate change. RBC has financed over C$340 B in fossil fuels since the Paris Climate Agreement was signed, and in 2022 was the world’s #1 funder of fossil fuels. RBC has set only “emissions intensity” targets for 2030, which would allow its total financed emissions to rise. The bank touts billions set aside for “sustainable finance,” but included in this category a C$1 B loan for an Enbridge oil sands pipeline. The scale of RBC’s investment into sustainable projects is negligible relative to its investments in climate-damaging fossil fuels, with a recent report showing RBC puts $99 of its energy finance into fossil fuels for every $1 in renewable energy. Despite claims to be Net Zero by 2050 and to support clients in the energy transition, RBC’s business practices show it has no intention of cutting its financing of fossil fuels.

RBC’s track record is relevant in comparison to that of HSBC Canada, which has taken further action to deliver on its sustainability commitments. HSBC Canada helped issue Canada’s first green bond, had many corporate clients who valued sustainability, and consistently ranks higher than RBC in Corporate Knights Corporate Citizenship rankings. In 2022, HSBC announced a global policy to stop financing new oil and gas projects, which, while imperfect, set a new global precedent and was welcomed by UK NGOs. Importantly for your consideration, RBC had that climate policy exempted from HSBC Canada as a condition for the takeover in question.

In 2022 HSBC’s global fossil fuel financing declined, and will continue to do so based on its commitments, while RBC’s increased making RBC the top global banker of fossil fuels.

Climate change has been identified by the Office of the Superintendent of Financial Institutions (OSFI) as one of the top risks to the stability of the financial system. According to OSFI, federally regulated financial institutions and private pension plans face physical risks (i.e., from climate change-related weather events) and transition risks (i.e., transition to a low greenhouse gas emitting or “low carbon” economy.) These risks are considered “transversal” in nature because they drive more traditional risks, including credit, market, insurance, operational and legal risks, which could exacerbate over time, impacting the safety and soundness of individual financial institutions, and the Canadian financial system more broadly.

Consolidation within the sector where a poor climate performer absorbs a counterpart with better performance undermines the stability of the financial system. The loss of a competitor moving to phase down its support for fossil fuels would further consolidate Canadian investment into an area at risk of becoming stranded, worsening the level of climate risk in our national economy. Over C$100 B of Canadian assets are at risk of becoming stranded, due to the financial sector moving too slowly on the climate transition. The Canadian Energy Regulator’s recent Net Zero report shows Canadian energy production would decrease by over 76% if the world succeeds in reaching net zero emissions by 2050. The Bank of Canada estimates that the Canadian economy could experience an 8-to-10 percent decline in GDP due to being unprepared for the climate transition.

The proposed transaction would have various other negative impacts on Canadians which should be considered, including implications on consumer mortgage rates, housing affordability, and the cost of living. RBC has also demonstrated significant cases of mistreatment of Indigenous Peoples and does not have meaningful policies to address the Free, Prior, and Informed Consent of Indigenous Peoples.

The Federal Government has advanced a whole of government approach to fighting climate change, however private finance remains a gaping hole. As long as financial institutions are allowed to expand support for the companies making climate change worse, Canada’s financial system and our ability to achieve the goals of the Paris Climate Agreement will be at risk.

Finance Minister Freeland has publicly stated that “the global economy is turning swiftly, decisively, and irreversibly green. It is essential for Canada to be at the forefront of this great transformation.” We therefore urge you to either reject the proposed acquisition, or to accept it conditional on our two recommended constraints of RBC i) implementing a Credible Climate Plan and ii) committing to meeting or exceeding HSBC’s international commitments to ending investments in fossil fuels.


  • Stand.earth
  • Ecojustice
  • For Our Kids
  • Decolonial Solidarity
  • Shift: Action for Pension Health and Planet Wealth
  • Environmental Defence Canada
  • Leadnow
  • Re_Generation
  • Quit RBC / Lâche RBC
  • Climate Justice Thunder Bay
  • Ontario Climate Emergency Campaign
  • Climate Action Network – Réseau action climat Canada
  • Regroupement pour la responsabilité sociale (RRSE)


The above letter was submitted to the Federal Department of Finance as part of their consultations for reviewing the takeover of HSBC by RBC.

Walking out of my home in Toronto to the smell of wildfires in the air in recent days has been jarring. I’ve felt a new wave of climate anxiety, listening to public health advice and sending my 12-year-old to school through the haze in a pandemic-era mask.

As I experience the climate crisis in a new way, it makes me think about so many other communities, most often Indigenous and racialized people, who are the most impacted by climate change and the least protected. The past few weeks were no exception, with thousands forced to evacuate remote First Nations communities.

At the same time, I’m feeling the sting of sky-high grocery bills as I support my family, and watching affordable housing become even further out of reach — realities that also hit marginalized and low-income communities hardest.

Right now, a deal is in the works that could make life even harder for Canadian families as we live through a climate crisis driven by fossil fuels and an affordability crisis fuelled by the pursuit of corporate profits.

RBC, Canada’s largest bank and the world’s largest fossil fuel financier, is trying to buy HSBC’s Canadian division. If approved, it would be the biggest bank merger in Canadian history and would mean Canadians face even higher costs to bank and borrow just as it seems the cost of living crisis couldn’t get any worse.

Less competition means less pressure to make products affordable. Last year, RBC made $15.8 billion in profits and recently raised credit card interest rates from an already high 19.99 per cent to 20.99 per cent, further squeezing families trying to cover costs.

Like everyone across the country, families in Toronto are scrambling to secure affordable housing. HSBC Bank Canada is an aggressive competitor to RBC on mortgage rates, currently beating big banks like RBC by 0.75 per cent — that’s over $30,000 less in interest paid over five years by Vancouver and Toronto residents.

RBC is the world’s largest financier of fossil fuels, financing over $55 billion in fossil fuel projects last year alone and $340 billion since 2016. Its climate plan has been largely panned since it allows the bank to keep investing in oil and gas and continue to drive up emissions, and the Competition Bureau is investigating the company for misleading climate claims across its products and advertisements as it looks into the proposed purchase.

Among the fossil fuel projects RBC finances are the Coastal GasLink pipeline and the Trans Mountain pipeline expansion project, which violate Indigenous sovereignty and have been used to justify violence against land defenders. Indigenous Peoples, meanwhile, continue to face disproportionate impacts from climate change even as their stewardship and defence of the land is one of the most effective forms of climate action.

HSBC is actually reducing fossil fuel funding year over year and announcing it will no longer invest in new oil and gas fields. HSBC Bank Canada was excluded from that policy in the lead-up to the proposed purchase by RBC.

Taking HSBC Bank Canada out of the picture means Canadians will have one less option for more sustainable banking — at a time when 70 per cent of us are worried about climate change — and will reduce pressure on RBC to move away from oil and gas.

With wildfire smoke keeping kids inside and sweltering temperatures that continue to break records, it’s clear what we’re experiencing is tied to fossil fuels and the climate crisis. As our climate changes, kids face elevated risks of asthma, allergies, food insecurity and a growing mental health crisis.

Until July 6, the public has an opportunity to weigh in on the merger. I’ll be submitting a comment on behalf of my son to say it’s time to put the well-being of our kids and communities ahead of RBC’s bottomline. The last thing we need is Canada’s biggest bank and the world’s largest fossil fuel financier becoming more powerful.

If we believe in reconciliation, an equitable society, making life affordable for all Canadians, and a safe environment for our kids to grow up in, we have to take this opportunity to say no to this merger.

Vanessa Brown is a Toronto-based parent, small business owner, volunteer with the BE Initiative, a Black-led environmental justice not-for-profit, and volunteer with For Our Kids, a national network of people taking climate action on behalf of their kids.


The above was an opinion article originally posted in the National Observer. Read the full article here.