Finance Committee on Dec. 6th, 2010

[The Chair, Conservative, James Rajotte]

I call this meeting to order.

This is the 51st meeting of the Standing Committee on Finance, and I want to thank all the witnesses who are appearing today.

Pursuant to the order of reference of Wednesday, April 21, 2010, we are continuing our study of Bill C-470, an act to amend the Income Tax Act. We have two panels here today of seven organizations or presenters, so we do have a lot of people to hear from.

We have the Canadian Conference of the Arts; the Association of Canadian Community Colleges; Mr. Gary Bizzo as an individual; the Ontario Hospital Association; l'Association des universités et collèges du Canada; the Canadian Red Cross; World Vision Canada.

You have five minutes to make your presentations.

We will start with the Canadian Conference of the Arts. If you would keep your presentation to five minutes it would be greatly appreciated.

Thank you.

[Alain Pineau, National Director, Canadian Conference of the Arts]

Thank you, Mr. Chair.

Good afternoon, members of the committee. My name is Alain Pineau and I'm the national director of the Canadian Conference of the Arts. Thank you for giving me the opportunity to present our views on Bill C-470.

The CCA is the oldest and most broadly based cultural umbrella organization in Canada. The CCA provides a national forum for the entire arts, culture, and heritage community, from all disciplines and regions. Our membership reaches over 300,000 artists, creators, and cultural workers.

The CCA fully supports the objectives of transparency within the structures of charitable organizations in Canada, but it is our opinion that Bill C-470 is fundamentally unnecessary, intrusive, and ill-conceived. Like other members of Imagine Canada, we rejoice in the fact that the sponsor of the bill has proposed to drop the controversial cap on salaries. This suggestion was certainly the most intrusive aspect of the bill. While it may not affect many organizations in the cultural sector, salaries of over $250,000 are rarely found in our arts sector. We all object to this unjustified intervention of the government in the governance of civil society organizations.

In our view, the second aspect of the bill remains objectionable, even after the proposed amendment to establish a $100,000 floor on salaries to be made public. Again, this would not apply to many people or organizations in the arts sector, but it is our opinion that it remains intrusive and unjustified. A large number of organizations in the arts, culture, and heritage sector have the status of charitable organizations. However, the vast majority receive only a small percentage of their revenue from donations. Very few arts, culture, or heritage organizations receive even 10% of their revenue from charitable donations.

Take the CCA's own case. Over the past three years charitable donations have contributed a small but much needed 1% of the total revenue of our organization. People who give to an organization like ours do so because they support the work we do and want to help us pay the expenses related to our main activities. Our case is not unique in the arts, culture, and heritage sector. It is our position that even with a floor of $100,000, this clause in Bill C-470 would still constitute an unwarranted and unnecessary intrusion on Canadians' right to privacy.

Why do we think it unnecessary? Because the CCA believes that Revenue Canada already has measures in place to regulate non-profit spending. Canadian charities are already required to publicly account for their organizational activities and finances, including information on staff compensation. Form T3010 requires the provision of a substantial amount of information, including contact information, details about directors, detailed revenue and expenditure information, description of charitable programs, political activities, transfers to qualified organizations, and fundraising revenues and expenditure. Charities must also report compensation information on schedule 3 to form T3010, to include total number of full-time staff, total amount of staff compensation, and the total amount paid to part-time staff.

The information is available, but I guess we can agree with the Honourable Albina Guarnieri that this information may be difficult for Canadians to understand and access. We agree that all Canadians should have easy access to the information in order to be better informed on the operations of charities. But instead of approaching the problem of transparency by applying intrusive legislation onto charities, we suggest that this is an opportunity for this committee and interested members of Parliament to work with Revenue Canada to make the information on charities more easily accessible to a Canadian audience.

[The Chair, Conservative, James Rajotte]

One minute, please.

[Alain Pineau]

To sum up, the CCA considers this bill ill-conceived, intrusive, and unnecessary, and would urge you to defeat it.

Thank you for your attention. I'll be pleased to answer any questions you may have.

[The Chair, Conservative, James Rajotte]

Thank you for your presentation.

We'll now hear from the Association of Canadian Community Colleges.

[Terry Anne Boyles, Vice-President, Public Affairs, Association of Canadian Community Colleges]

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.

[The Chair, Conservative, James Rajotte]

We'll now hear from Mr. Bizzo.

[Gary Bizzo, As an Individual]

Thank you, Mr. Chairman.

First, there are a great many charities in Canada that provide exceptional service, above and beyond, to the Canadian public. I represent donors.

I work for a society with charitable status in Vancouver called SUCCESS. Our 400 dedicated employees will tell you that they are committed to the good of our community. We operate dozens of programs that are not-for-profit. As a senior manager with eight years of experience, I earn $60,000 a year—comfortable by many standards. For the most part, my colleagues and I work for SUCCESS because we like the work and the 180,327 clients we served in 14 languages in 2009.

At the airport on the way here, I ran into my ex-CEO, who had just retired two weeks ago, Tung Chan. He candidly told me he made $110,000 to manage our $40 million society. He said there is a trend to find experienced CEOs who have retired and who are willing to give something back to the community. He felt transparency was paramount and expected.

Transparency is needed with charities. The vast majority of charities fear nothing from openness around the percentage of contributions that go to administration. I prefer to give to charities that understand that as a middle-class person, my contributions represent a big deal to me. I want a charity that has a low administration percentage.

Corporations are obliged to give shareholders information. Why should executives of large charities have any special status? When we the people give them tax benefits, should we not get the same obligation on transparency?

A CEO friend of mine, Gordon Ross, a former adviser in President Clinton's White House committee on Internet security, told me that the general population has no idea what is going on around them because everything is filtered. In a digital age, we are told what people want us to know. I want to go back to the days when it was not filtered. I want disclosure.

As a social media networker with almost 100,000 followers, I put it out to my followers for their opinions on transparency. I have a word-of-mouth influential reach of just over 6.7 million, according to a website called “gripe”. In the space of an hour, I received just under 1,000 messages. The first messages were adamantly against my criticism of CEOs, mainly commenting that good mainstream people needed high compensation. Over 900 messages were against these salaries and wanted transparency.

I run a business blog, so when I switched to promoting this bill on my blog, I did not anticipate the results and fervour of my roughly 5,000 readers per month. While many bloggers with my numbers may expect three to four people to respond to their writings, on my first blog on “excessive charity salaries and transparency”, April 14, 2010, I received 129 comments. The numbers are roughly 50 to 60 times the usual average of responses. Nearly all support Bill C-470, transparency, and salary cap.

I insist that, as important as it is that there is a cap on the size of salaries, transparency is fundamental for me to make an informed determination whether I will contribute to make the world a better place through donations. However, it must be my choice.

Thank you.

[The Chair, Conservative, James Rajotte]

We will now hear from the Ontario Hospital Association.

[Tom Closson, President and Chief Executive Officer, Ontario Hospital Association]

Good afternoon. My name is Tom Closson and I'm president and CEO of the Ontario Hospital Association. The OHA represents Ontario’s 154 public hospitals, virtually all of which are CRA-registered charities.

We originally requested the opportunity to appear before this committee because we had grave concerns about the effect the proposed salary cap included in Bill C-470 would have on hospitals across Ontario and the largest and most successful hospital foundations. The majority of Ontario's hospitals employ at least one individual who earns more than $250,000 per year. In many hospitals these individuals include physician leaders or physician specialists. In Ontario, approximately 15 hospital foundations pay at least one employee, usually only one employee, more than $250,000.

Hospitals are in the business of providing patient care. Hospital foundations are responsible for raising the funds necessary to support the associated hospitals.

In Ontario, hospital foundations fund two-thirds of the salaries of many hospital medical researchers who are principal investigators. They're also responsible for raising 10% of the funds necessary for major capital construction projects and 100% of the funds necessary to purchase medical equipment like MRIs and CT scanners. If a hospital lost its charitable designation, its foundation could not give the hospital the funds it has raised. If a hospital's foundation lost its charitable designation, the hospital could not receive the funds raised by the foundation. In either case, the result would be devastating for the hospital's patients.

Leading a hospital or a hospital foundation is not easy. Leadership has a big impact on the success. In Ontario, hospitals and hospital foundations have volunteer boards of directors who are responsible for recruiting in-demand medical research and management talent. They also determine appropriate compensation structures and they manage performance. Their leadership has helped to make Ontario's hospitals some of the highest performing in the world. If passed unamended, Bill C-470 would undermine the responsibilities of those boards of directors, which in the case of hospitals have a direct legal relationship to the Government of Ontario. For these reasons, the OHA does not support Bill C-470 as it currently is drafted, but we acknowledge and appreciate the sponsoring member of Parliament's commitment last week to stripping out the salary cap from the bill.

With respect to the proposal to create a salary threshold of $100,000, above which registered charities would be required to publicly disclose the salaries of the top five executives, Ontario's hospitals have no objection to that. As you may know, Ontario's hospitals are already subject to our province's public sector salary disclosure, which requires us to disclose the top compensation for every hospital employee who earns more than $100,000 per year every March 31.

I also understand there has been some discussion here regarding the disclosure of the relationship that some charities have with third-party fundraising companies and that action could be taken through an amendment to Bill C-470. I would encourage the committee to refrain from doing so without additional formal examination of the issue. The operations of charities are complex and sensitive, as are their vendor relationships. I believe a full examination of all of the issues would be beneficial before action is taken by legislators.

Let me sum up by saying that the Ontario Hospital Association would have no objection to Bill C-470 if it were amended to strip out the salary cap or include a public sector requirement for the top five executives earning more than $100,000. That said, we believe that the Canada Revenue Agency already has sufficient authority to properly police the charitable sector, and we remain unclear about what substantial new benefit even an amended Bill C-470 would provide to the public.

Thank you for your time today, and I look forward to questions.

[The Chair, Conservative, James Rajotte]

Thank you very much for your presentation.

We'll now hear from the Association of Universities and Colleges of Canada.

[Paul Davidson, President, Association of Universities and Colleges of Canada]

Good afternoon, Mr. Chair and members of the committee. It's a pleasure to be back before you again.

Before I talk about my prepared remarks, may I just say that as a front-line volunteer and someone who has served on the national boards of a number of charities, and as someone who has led charities and not-for-profits in three very distinct parts of this country, I take a very keen interest in good public policy and the role of the voluntary sector. So I really welcome the committee's interest in this set of issues. But as you might expect, we have some profound reservations about the bill as it was first presented.

AUCC represents 95 universities and degree-granting colleges from coast to coast. All of them are not-for-profit. Most of them are registered charities.

And I want to acknowledge the good work of Imagine Canada in articulating very well the impacts of the proposed legislation, and the AUCC supports Imagine Canada's approach and recommendations.

Let me underscore that Canada's universities fully support efforts towards transparency and accountability, and are already doing much more in some areas than this legislation would request. And there are many different ways to talk about the compensation cap, but the one I want to focus on today is the impact on Canada's science and technology strategy. One of the great public policy success stories of the last decade has been reversing the brain drain and being able to attract the best talent in the world to do innovative research here in Canada that has real impact for Canadians. This bill threatens our ability to attract that kind of talent, most specifically in terms of the Canada excellence research chairs, which is a flagship program of the science and technology strategy, which has dedicated $10 million to attract globally significant researchers. This program, where the chairs are just moving into Canada now, would put at risk every university's charitable status.

And I raise that just as an example of the good intention of the bill and the very problematic consequences that the bill presents.

I am very pleased that the Honourable Albina Guarnieri tabled amendments last week about the compensation cap, so I won't dwell on that point. I will say that AUCC strongly urges the committee to accept those proposed amendments.

There has been some discussion already this afternoon about the issue of compensation disclosure, and I want to just make a couple of observations about that.

First of all, again, universities are committed to the principle of accountability to the public and to governments. Universities account for their expenditure of public funds through their boards and through a range of audit and public reporting mechanisms. A variety of accountability mechanisms are in place in all provinces and at the federal level to provide for openness, transparency, and accountability by universities.

A couple of areas that are problematic include the issue of safety, for those doing international work. And I know you're hearing from other international organizations momentarily. But many faculty and staff from universities do work in some of the most dangerous parts of the world, and I'm talking about Afghanistan, Haiti, and other areas where there is grave risk to personal security. If those salaries are made public, the risk to those individuals is increased. I won't belabour the point, because there are others here who can make it more emphatically.

The other point I would like to make around the disclosure mechanism is that universities are doing this much and more already in many provinces. So adding yet another layer of accountability, another layer of administration, is problematic for the members of AUCC.

I would suggest also—and I think there was a really good question raised last week at the committee—about whether you need legislation to address the concerns that have been put forward. The CRA and the legislation regulations governing the work of CRA provide ample opportunity to increase the disclosure mechanisms. And we work quite closely, and the sector works quite closely, with CRA to make sure there is adequate disclosure on these issues.

In conclusion, I would just say that we're very pleased with the amendments to remove the cap on compensation. And with regard to the floor of $100,000 for compensation disclosure, if the committee still feels legislation is necessary, we would hope the committee would consider putting in an escalator clause because we've seen in other jurisdictions the way people who were never expected to have their salaries disclosed end up being put on the sunshine lists.

Again, I want to thank you for the opportunity to present before the committee, and I would just close by saying that the work of the voluntary sector is absolutely vital in this country. There are many, many areas where this committee could engage fruitfully, whether it's around alternative financing, whether it's around incenting people to give more, whether it's around engaging young Canadians. There is lots of work we can do together, and I look forward to doing that work with you once this bill has been concluded.

Thank you.

[The Chair, Conservative, James Rajotte]

Thank you very much, Mr. Davidson.

We'll now hear from the Canadian Red Cross, please.

[Alan Dean, Vice-President, Board of Governors (volunteer), National Office, Canadian Red Cross]

Thank you, Mr. Chairman and members of the committee.

My name is Alan Dean. I'm very pleased to be here today in my capacity as vice-president of the board of governors of the Canadian Red Cross. I also chair the pension committee and the governors committee of the Red Cross in Canada. I fulfill these roles as a volunteer and have been involved with the Red Cross for eight years, both at the provincial and the national level. In my professional life I'm a partner with the law firm of Gowling Lafleur Henderson.

The Canadian Red Cross is Canada's leading humanitarian organization, providing services in Canada and abroad ranging from health intervention to disaster response. The Canadian Red Cross is an independent organization governed by a volunteer board of governors. Internationally, we are members of the Federation of Red Cross and Red Crescent Societies. In Canada, we are a large and a complex organization. We have over 6,400 staff, supplemented by a trained volunteer force of approximately 20,000 people.

The volunteers and the staff are responsible for carrying out the Canadian Red Cross's mandate. They also ensure, in doing that, that our programs are properly funded and that our funds are managed efficiently. Our revenues in 2009 were $372 million, and we are fully compliant with the CRA filing regulations.

Our governance model is woven throughout the organization from a regional to a fully national level. We strongly support the objectives of accountability and transparency. We strive to maintain the highest level of public trust through our efforts. We believe firmly that our donors deserve no less, both in terms of accountability for the use of the funds donated by Canadians who work hard for their money and of the best possible information upon which to base their charitable donation decisions.

So we commend the work of this committee in ensuring that Canada's laws and regulations are up to date and sufficient in terms of ensuring an appropriately high level of transparency.

We are pleased to note that the sponsor of Bill C-470 has chosen to amend the bill in order to remove the previously included compensation cap. Directors of charities must serve without remuneration. They bear a heavy duty and are viewed as higher-order fiduciaries with trustee-like responsibilities, unlike their counterparts in the for-profit sector. A salary cap would have severely limited a board's ability to select qualified management staff and hire the best and the brightest, so we applaud the amendment to remove the compensation cap.

We currently comply with the robust reporting and transparency requirements mandated by the Canada Revenue Agency. As you know, charities like ours are now required to identify the salary range for their ten highest-paid positions, and these salary categories have been expanded. If parliamentarians decide that the existing disclosure regulations, including the new Canada Revenue Agency requirements of 2009, are lacking, we would welcome the opportunity to work with you in examining other models for disclosure and transparency.

In particular, we take positive note of the proposed amendment to Bill C-470 that establishes a floor for salary disclosure of $100,000. We have no objection to this proposed floor, nor to the concept of releasing specific information regarding job titles or descriptions and specific salary amounts for employees who would fall into the categories for disclosure that Parliament might establish. That said, there may be specific circumstances in which the information related to a particular individual should not be disclosed, to protect that individual's safety and security. To address those, we agree with the notion of giving the minister responsible some discretion to withhold information, to protect individuals from harm.

Thank you very much, Mr. Chair and members of the committee. I would be pleased to respond to any questions you may have.

[The Chair, Conservative, James Rajotte]

Thank you very much, Mr. Dean.

As our final organization, we'll hear World Vision Canada, please.

[Sharon Dymond, Chair, Board of Directors, World Vision Canada]

Thank you.

As chair of the board, I thank you for the opportunity to speak with you about a subject to which World Vision is very committed; that is, transparency.

In the next few minutes that I have with you, I'd like to give you a brief description of World Vision, underline how we understand transparency and the steps we are taking to ensure accountability, indicate why we are pleased that the cap has been removed, present our concerns about the salary focus of the bill, and give our recommendations for enhancing transparency—and all in five minutes.

World Vision is Canada's largest relief, development, and advocacy organization, and one of Canada's largest charities. Our work includes emergency relief, health, education, skills training, agricultural assistance, and policy. It is governed by 39 corporation members, of which 21 are also board members. World Vision Canada is also a member of World Vision International, which is composed of a federated structure of nearly 100 national entities and more than 40,000 staff, governed by an international board of directors. My long career in human resources with Bell Canada helps me serve on a human resources committee of World Vision International as well.

More than 700,000 Canadians regularly give to support our child-focused, community-based programs. Together with almost 10 million like-minded supporters internationally, these Canadians enable World Vision to respond to some of the world's poorest children. We manage revenue and programs exceeding $400 million and a staff of more than 500.

World Vision appreciates the spirit and purpose of this bill; that is, to ensure greater transparency. Transparency is about equipping Canadians with easily accessible information to make the best charitable giving decisions. Our commitment to transparency has led us to increase the amount and quality of information available to Canadians about our work, including our programs, our donations, and our finances. We disclose on our public website details on our approach to executive compensation and we make the top salary known; all our completed audited financial statements are readily and easily found on our website; we give detailed information on the program spending; and there is full consistency between our reporting to the government and our audited statements.

It is our view that the donors have a right to know, and we haven't always done this right. Frankly, it's a challenge to make complex information clear and simple for supporters and the public, but also detailed enough for those who want to know more. This being said, we are pleased to have been recognized with awards for a high level of accountability and transparency.

We thank you for your response to our concerns about the compensation cap. As we indicated in our brief, we question the need for the cap, on the grounds both of future compensation flexibility as well as of our board's governance autonomy. Although our CEO's salary is public and well below market value, we are concerned about an arbitrary, inflexible number that may not reflect future requisite skill sets and that, over time, would not be updated. We are concerned that this will limit the independence and autonomy of charitable boards.

We are also concerned that by focusing on such a narrow aspect of charitable accountability, the bill won't achieve what it's really meant to achieve. In fact, the focus on listing top salaries will undoubtedly ensure that donors become focused on the wrong issue: salaries. The focus should be on impact and achieving the mission of the organization, not on salaries alone.

Additionally, reports have suggested that the sunshine list in Ontario, the public list of all public service employees who earn $100,000 or more—

[The Chair, Conservative, James Rajotte]

You have one minute remaining.

[Sharon Dymond]

—has actually increased salaries, because people are comparing and negotiating higher salaries.

Another concern with the focus on salaries relates to security and privacy. Senior World Vision staff travel frequently in fragile contexts, placing themselves at risk for kidnapping and ransom demands. The release of salary figures that include names and titles for senior staff would impact their safety and security and our security costs. The bill would mean breaching the confidentiality and privacy of thousands of Canadians, putting many who work in the international development sector at risk when they travel overseas.

We welcome the CRA to introduce more stringent requirements in reporting. Would it not be more effective to work through the existing CRA mechanism to achieve the spirit and intent of this bill? Let's continue to work with the CRA to make charitable giving information easier to access and understand. The proposal's focus on salaries won't achieve these.

In conclusion, thank you so much for your time. Also, knowing that our donors and the people we serve demand transparency, we recommend using the already proven CRA reporting mechanism to do so.

Thank you.

[The Chair, Conservative, James Rajotte]

Thank you very much.

We'll go to members' questions, starting with Mr. Brison.

[Scott Brison, Liberal, Kings—Hants, NS]

Actually, we'll start with Mr. Szabo. I have to go momentarily.

[Paul Szabo, Liberal, Mississauga South, ON]

Thank you.

Thank you to the witnesses for proceeding with their statements.

I suspect that all of you know that at the presentation by the member whose bill this is, Ms. Guarnieri, substantial amendments were proposed. This no longer will have anything to do with salary caps. So that's off the table. This bill ultimately melts down to a disclosure of salaries of persons who have salaries in excess of $100,000.

Most of you mentioned privacy. Being the former chair of the access to information, privacy, and ethics committee, until about three months ago, I'd like to just read a little segment out of this.

The act stipulates that “no personal information shall be collected by a government institution unless it relates directly to an operating program or activity of the institution”. As well, whenever possible, the information should be collected “directly from the individual to whom it relates”, and the individual should be informed of the purpose for which it is being collected.

There's a technical note, as well.

The bottom line is that this does not violate privacy, although many of you said that it's a breach of privacy. I wonder if any of you have any reference or information related to the Privacy Act or to PIPEDA that would indicate that the disclosures made would violate privacy. Is there any one of you?

Okay. Thank you.

With regard to transparency, which is ultimately what this bill has become about, as you know, those who give charitable donations receive a tax benefit that's paid for by all taxpayers, by Canadians. That is our contribution. Therefore, because it's an expenditure of the Government of Canada, it is subject to transparency. To disclose what taxpayers' money is used for, given the related benefit given to whomever and the benefit given to those who use that money for purposes under their registration, requires transparency.

Does any one of you disagree with any of that?

Mr. Pineau.

[Alain Pineau]

I don't disagree with the principle. I'm questioning whether it's appropriate that in an organization--and I use our own example--in which 1% of the revenue comes from donations and charity, my staff and I are obliged to post our salaries publicly. It may not be contrary to the Privacy Act--and I'm no lawyer--but it's certainly contrary to common sense, the way I see it.

[Paul Szabo, Liberal, Mississauga South, ON]

Okay. It's an unusual situation where an entire organization that only has 1% of its activity being charitable activity is registered as a charity.

[Alain Pineau]

It may be so, but it is recognized. And I believe that we did not steal our status, nor did any of the organizations in the arts and culture sector to which this applies. Even among the largest ones that have that status, I don't believe there's one that draws more than 10% of its revenue from donations.

It remains important for organizations like ours. One percent of our revenue pays for half an intern for six months. Given the small team that we are, it's important revenue that we're not ready to forgo. We're not in the business of raising money like that. We receive it from people, and we solicit, to some extent, from our members, but we're not campaigning, and we've never hired any agency to raise that money. Very few in the arts and culture sector do so.

[Paul Szabo, Liberal, Mississauga South, ON]

I think you raise an interesting point. I think the committee would want to consider whether or not there was a way to segregate the charitable activity from the people who solicit the funds. I don't see it as a problem. You said you agreed with the principle.

What I heard was some pretty strong language about intrusiveness in a flawed piece of legislation. Other than the salary cap, which is off the table, is there anything else in this bill that anyone would characterize as flawed? If so, can you tell us what that is and why?