Thank you very much, Mr. Chairman.
I appreciate the opportunity to be able to comment in person today. My name is Katherine van Kooy and I'm the president and CEO of the Calgary Chamber of Voluntary Organizations. Our 440 members reflect the diversity of this sector in terms of the size of the organizations and the range of areas in which they operate. My comments today are really based on our concern about the implications of this legislation for the broad charitable sector.
We appreciate the response to the concerns that have been raised previously about the impact of this legislation, particularly the amendment that was introduced on November 29 to remove the salary cap. Had there been a legislated compensation cap, it would have put employees of charities into a separate class through government intervention in determining compensation that should be market-driven. In doing so, government would also be sending a very strong message that the work of the charitable sector is less valuable than that of the for-profit sector.
Our organization is committed to the promotion of high ethical standards and accountability for charities. We believe that donors, charities, and communities all benefit when donors feel comfortable that their money is being spent wisely.
Through CCVO's work, we know that one of the major issues raised by organizations in Alberta and across the country is the growing overburden of multiple reporting requirements. These requirements increase administrative costs without contributing in a meaningful way to improved accountability and services to the community. Therefore, we urge that the priority of this committee be given to streamlining reporting requirements and improving the existing mechanisms first.
As already outlined by others, there is an existing mandatory reporting system in place for all registered Canadian charities through the annual T3010 reports that are filed with the Canada Revenue Agency. The system already requires substantial reporting of information about revenues and expenditures, fundraising costs, compensation levels, details about directors, and more. When organizations are not fulfilling their reporting requirements, or when the information provided raises concerns, we fully encourage the CRA to take action. They already have the power to do so. In fact, as you know, the CRA has the power to investigate not only executive salaries that Bill C-470 is now focused on, but other areas as well.
Some concerns have been raised about the information available on the CRA website. I would point out that the timeliness of reporting requirements is far more stringent in Canada than it is in the United States. In terms of the issues raised about accessibility of the information, that's a matter that can be resolved without the need for legislation.
The focus of Bill C-470 is now entirely on disclosure of compensation levels, including compensation for fundraisers, as though this is the only basis on which donors should choose to invest in charities. This information conveys nothing about the impact of the organization in pursuing its mission, or the value of its work in the community it serves. As a donor, that's the information I need in order to be comfortable that my donation is a wise one. Meaningful information about the potential impact of my donation is hard to find. At least it's hard to find in one central location.
I suggest it would be more effective for us to extend and improve the type and quality of information that's collected and available on the CRA website. These changes could be made simply through administrative reforms. If the committee feels it is necessary, the annual T3010 return could be adjusted, as others have suggested, to provide more information about top salaries. It makes sense to use the framework that is already in place. CCVO, and I'm sure many other organizations, would be more than happy to work with the CRA to continue to improve the quality, usefulness, and accessibility of information about Canadian charities.
We do not support the need for this legislation. However, if the committee decides that legislation is required, we urge, as others have, that two amendments be included to further enhance the positive addition of a minimum threshold for reporting the top five salaries in an organization.
First, include an escalator clause that will adjust the threshold level automatically for inflation. This would preserve the intent of reporting on executive-level compensation and not drift down over time into reporting on non-executive staff.
Second, we also feel it's essential that the minister be able to exercise discretion to deal with situations where public disclosure of the names and salaries of employees could compromise their safety.
Finally, we recommend that there be opportunity for further consultation on any new changes that may be proposed to this legislation. This is to ensure that the changes do not in turn have unexpected consequences.
Bill C-470 is intended to increase transparency and improve information for donors. I encourage the committee to consider whether those goals are best achieved through new legislation and new provisions regarding the same type of monetary-only information, or if what is required is more meaningful information and increased follow-through on the provisions already in place for the CRA as the regulator of Canadian charities.
Thank you.