Report #3 of the Advisory Committee on the Charitable Sector was released.   I have a few personal views/concerns with this report and the process.   My main concern with the ACCS is the huge amount of money spent on the ACCS process.   This is precious money that could have been spent on so many better things.  It is also on the heals of COVID and the Special Senate Committee Report on the Charitable Sector.  The Senate spent millions more.    It has also resulted in some of the top Charities Directorate staff focussing in on these processes.  Think of all the new guidance documents that could have been prepared if CRA did not spend the last few years focused on all this talk.  Think of all the guidance documents that have not been updated in a decade or more that could have been updated.

While there are some very capable people on this committee, this committee could one day be a case study of how when you put a whole bunch of good people together you get a very bad outcome.  In fairness, I should say that report #3 is not as bad as report #1 (here, here) which was deeply insulting to those in Canada who are trying to fight for their basic human rights.

Instead, of action and improvements, we have endless reports and little action by the current government when it comes to increasing transparency in the sector, making guidances easier to understand and just generally helping charities understand and meet their compliance burden.  The ACCS seems to have been used by the Liberals as a mechanism to avoid accountability and action.

There is no mention in this report of the guidance on religion which was finalized many years ago and has not even been released. If one is talking about the charity sector and vulnerable populations, how can one not discuss both the positive and negative of religious charities.  Also when will the guidance on the environment be released?  At the moment you can read a 2003 “summary policy” on the environment CSP-E08 which is labelled “Environment” – it is one paragraph long.  Actually, I might have misstated that – it is one sentence long!  Can we not all agree that the environment is important and that it deserves more than just one sentence.  There are 8 references to the “environment” not one of them is what we refer to as the environment – they are talking about “regulatory environment”, “enabling environment”, and “supportive environment”.

I don’t consider releasing reports to be real action.   The report talks about the need for more education as to the current rules – yeah CRA did a big program to fund charities to explain these rules – but the Liberals have in 6 years not committed any funds to that.    With turnover at charities in staff and board and changes in rules/implementation, you cannot just do education ten years ago and expect that the staff and board today is going to understand the most important compliance requirements.

There is also a lot of repetition in the reports.  It is as if it was not well explained in the previous reports so they need to mention it again and again in slightly different ways.  Or in some cases, if you have a bad idea but you just repeat it 5 times perhaps it makes it into a good idea.

It is also a little disappointing, but not surprising that there is no recommendation to increase the disbursement quota.   There are a few paragraphs on the disbursement quota under the data working group area – they can be summarized as ‘it is complicated’.   When the sub-committee looking at vulnerable groups does not making a strong recommendation for increasing the disbursement quota, that says a lot about how broken the process is.  I don’t think that increasing the disbursement quota is going to solve all of the sector’s problems but it would be a tiny move in the right direction.

There are a few paragraphs in the very long report that I do agree with but they are drowned out by the other more voluminous parts that made little sense, were contradictory, ascribed blame to wrong parties etc.  One thing is very clear – this report was written by a committee.

If I would say this report was a yawn, I would be misrepresenting the response of the sector.  That would at least imply an involuntary muscle movement.   Paul Nazareth, a great guy, prolific networker and social media expert even created a nice picture of the 3rd report and tweeted it to his 14,000 followers on August 5, 2021 to let people know about this report.  As of August 29 it had received 2 likes and one retweet.   I am the last person that thinks policy should be determined by likes – or we would have Justin Bieber running our government – but let’s just say the charity sector has largely given up interest in this expensive and ineffectual process.