Madam Chair, the way the RAP operates is that it largely deals with individuals who face sudden income loss. For sudden income loss, the income tax return that CRA has from the previous year is not actually useful for us in determining that.
For example, if we had someone who lost their job today and applied under the RAP, even if I had access to that person's data at CRA, the data would be for their 2019 tax year and it would not allow me to evaluate whether they were eligible for the repayment assistance program. We have to do that evaluation based on their income in the previous month. That's the way the program is structured. It's not retrospective and looking at their income in the previous year because indeed their income from the previous year would have been higher to be able to do that. That's why, for individuals who suffer that sudden loss, we have to use pay stubs and other methods to assess whether they're doing that.
Where the CRA data would be very useful for us is looking retrospectively where you have individuals in the program for a longer period of time. Since the program was set up in 2008, the government has never looked at making it obligatory for individuals to file taxes. The rules around filing taxes are rooted in whether an individual has sufficient income. For example, if they have no income, there would be no obligation to file taxes and we would have to find another way. That's something we can certainly look into. It's just not something that's been in place since Mr. Solberg set up the program in 2008.