Thank you.
I'm Terry Anne Boyles. I'm vice-president of public affairs with the Association of Canadian Community Colleges. We represent Canada's 150 colleges, institutes, CÉGEPs, polytechnics, and universities with a college mandate. We have campuses in over 1,000 communities in the country and work very closely with the charitable sector in each of those communities and in the wider communities, the regions the colleges serve.
Colleges and their foundations, both formats, are registered charities under the Income Tax Act. We also appreciate the changes within the legislation, as Alain Pineau has just mentioned. I won't address that much further, except to say that while we support the goal of increased transparency and accountability that motivated the bill, there are elements that do have a direct negative impact on member institutions. They're particularly concerned about some of the cost factors that will impact the administration of the bill.
We believe the existing authority of the CRA's charities directorate does provide an adequate mechanism for ensuring transparency and accountability, and we would urge you to defeat Bill C-470. Our members are multi-million-dollar organizations that deal with complex management issues. If the cap hadn't been removed, we would have been telling you about how to attract the high-calibre people they need to run these institutions, being able to have that flexibility. It's important in terms of the salaries. We believe reporting those salaries on the form T3010 through CRA is an adequate, accountable, and transparent way to do the reportings, and we support that. As public institutions, our member institutions report their top salaries, both within the annual reports of their institutions and under whatever the provincial or territorial government accountability measures are.
Fundraising is absolutely vital. One of the points is that within the economic context of the country, our member institutions are struggling with the raising of funds to meet the capacity needs of those institutions and provide access for those who are disadvantaged, and maintaining their charitable status is absolutely critical to moving forward.
The other point we want to address is to support the points of all the other charities. We and our member institutions are concerned about the small charities and their communities and the disclosure requirements for the top five salaries. We believe this disclosure is unnecessary and an unwarranted invasion of privacy. We're also concerned that this puts the employees of some charities at substantive risk.
We are pleased to be working with the other charities appearing before the committee. We each represent quite different areas of the charitable sector in the country, but we are united in our view that the legislation is flawed, unnecessary, and will increase costs, both to the charities and to the Government of Canada. As we've said before, the CRA's charities directorate already has the tools at its disposal to guarantee transparency and accountability. The Income Tax Act provides the minister with the authority to investigate and take action where necessary on those who have undue benefit from their positions at charities, and certainly in our sector the provincial-territorial legislative frameworks do the same.
We urge the committee to defeat Bill C-470.
Thank you.