The agency says a total of 227,947 accounts were affected and that RBC transferred and refunded more than $22.4 million in refunds for those affected. The bank also made a $299,000 charitable donation.

Nathaniel Wallace, a spokesperson for RBC, says the lender takes its regulatory obligations seriously.

He says RBC self-reported the matter to the financial consumer watchdog and that RBC has fully co-operated with the regulator throughout the process.

Assuming this is all true, and assuming the refunds were full refunds, it looks like the bank was acting in good faith, which is honestly refreshing.