The headline stuff is a series of shiny baubles for the poorly informed to swallow whole and parrot endlessly.

The overall initiaitve is a Trojan horse laced with unintended consequences and so much complexity and subjectivity that it is largely unworkable.  

There are much simpler and less destructive ways to address the problems Mr Morneau perceives with the existing rules.  

That is why he is encountering so much resistance.  If he doesn't want Appeals and the courts tied up for decades, he should start paying attention.