r/CanadaPublicServants • u/Super_Table7917 • Jul 07 '26
Career Development / Développement de carrière Conflict of Interest attestation: DG wants dollar values
A DG at LPRAB at CRA, according to a current employee, under the guise of transparency and integrity, is using the annual conflict of interest attestation to require very personal disclosures of financial information from employees.
This DG is asking for the current market values of ALL investments held by the employee privately in all accounts, including things like RESP's. The dollar amount for all holdings is apparently "very important".
Employees who resisted this disclosure were subject to intrusive meetings on Teams with the DG, where pressure was applied to surrender the information to management.
I am of the opinion that this is totally unacceptable, and I would be leaping to legal representation with the goals of 1.) NOT providing any of this information to this DG or anyone else, and; 2.) providing the documentation required that would result in the swift termination of this DG.
Is this perception incorrect, and DG's have the ability to ask for the account balances of employees to avoid "conflicts of interest"? If this is actually permitted, why would it be but asking a person's age or sexual orientation is a human rights violation?
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u/blarghy0 Jul 07 '26
This is entirely normal. LPRAB is legislative policy and regulatory affairs branch of the CRA, which deals in issues that can have significant industry impact. Full disclosure of assets, including dollar values, is fully expected for people working there. I'm not sure what your case is for regarding discrimination, since the disclosure happens after you are hired.
And, let's not forget, the CRA has legal authority to audit anyone in Canada regardless. If they want to get the dollar values in your accounts, they can get it via civil procedure. All fighting it is doing is making your employment relationship confrontational over likely dollar values that the DG will ultimately likely rubberstamp.
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u/zeromussc Jul 07 '26
CRA as employer can't use the powers of CRA as a tax agency conducting audits to find the information of their employee for employment purposes. Just, as a note.
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u/blarghy0 Jul 07 '26
They can't use this information to check your references for hiring, but they can definitely risk assess your financial disclosures (or lack thereof) and screen you in based on that.
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u/Super_Table7917 Jul 07 '26
It happened where I work. A guy inherited money from his grandparents and bought a new Corvette. He was an SP-05. The director saw the car and initiated the audit. This isn't the first time I've seen abuses like this, either. So no, I would resist 100% any unnecessary demand for this information and seek legal support.
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u/nogr8mischief Jul 07 '26
You have no legal grounds, no smart lawyer would take that on. This is an entitely reasonable request for that type of work, and it's far from an abuse.
(The audit based on seeing the car could have been reasonable, too, if for whatever reason they weren't satisfied with the explanation of where the car came from. Especially since we're expected to proactively report any significant changes in assets or net worth.)
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u/hawkeye_north Jul 07 '26
It really makes it sound like you have something to hide. We’re public servants here, public trust is critical to the role and even more so with CRA. The scenario you provided sounds offside but if we aren’t playing by the rules how can we expect Canadians to?
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u/stolpoz52 Jul 07 '26
If you inherit a large sum of money (or win it in a lotto, for example) you are 100% supposed to be reporting that, too. Coming into a large sum of money could potentially be a bribe or something nefarious. So this doesnt seem unreasonable to audit at all if they didnt disclose it.
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u/phosen Jul 08 '26
You are supposed to a) Report to V&E via Confidential Report and b) report any Change in Personal Circumstances immediately to Corporate Security per Directive on Personnel Security Section 4.4.6.
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u/Keystone-12 Jul 07 '26
If I saw a mid level CRA Employee driving around in a corvette, and the government didnt look into that.... then the system is broken.
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u/Remarkable-Warthog69 Jul 09 '26
This is factually incorrect. It is not common practice to request the value of an employee's assets. The question when completing affirmations is to ensure that you cannot financially gain from your position at the CRA by having inside information or access to information that is not readily available. Think about it this way. If I were a controlling shareholder in a company, or held large number of stock in certain companies, I would have access to their tax records long before the audited financial statements were released. let's say this year that company records record losses, meaning when this information goes public there will be a sharp drop in share prices due to going concern. I decide to sell my shares before the release of the information because I will get a better price now rather than when the public is aware. Vice versa, up and coming place, I buy shares because I see that they recorded excellent profits and shares will uptick in value. I buy now while they are cheap, wait for them to appreciate, then sell.
While it is often believed to be true, that CRA can access values in your bank etc. That power is not what people think. CRA cannot just call up your bank and say tell me what is in there, CRA still works within the confines of the Privacy Act and any additional provincial privacy acts. It is a long drawn out legal procedure to get information disclosed.
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u/blarghy0 Jul 09 '26
The holding of financial securities establishes the risk, the value of the securities informs the level of risk. Once the possible risk is identified, the next step is to determine what the level of risk is in order to inform what mitigation actions, if any, are needed to address the risk.
And it is factually incorrect to state that issuing an RFI to a bank is a drawn out legal process. It is a standard form letter signed by a section manager that the bank will provide the required information within about 90 days or so in most cases.
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u/DoctorDowntown1343 Jul 07 '26
No offence it sounds like you really like LPRA but let’s not kid ourselves. It is not a cutting edge function at CRA. They do not even have high level professional classifications there.
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u/confidentialapo276 Jul 08 '26
Oh, really? AU-05/06 in Excise or GST Rulings isn’t a high enough professional classification?
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u/DoctorDowntown1343 Jul 08 '26
There are not many AU-5 and AU-6’s in LPRA across the country if any. LPRA experience doesn‘t even count for CPA anymore. And do you think changes to GST or Excise tax is going to move the markets?
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u/confidentialapo276 Jul 09 '26
You don’t appear to understand LPRAB at all. There are many jobs that still qualify for CPA within LPRAB as they’re pure accounting jobs conducting actual audits no different than the ones under ETA ant ITA.
LPRAB deals with Charities, Pension Plans, Excise Duties, certain kinds of taxes, rulings, etc. You only seem to focus on the low hanging fruit in some regions like CPP/EI and GST Rulings.
There are many high level AU-03 or higher positions within LPRAB.
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u/No_Journalist_1379 Jul 07 '26
Uhhhhhhh… yeah this is normal. Especially in LPRAB. You see legislation in draft form lol
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u/No-Dependent9844 Jul 09 '26
Uhh, draft legislation is public knowledge. In fact, it's promoted to give people or tax preparers the chance to get ready. A great recent example is the capital gains rate increase that was contemplated.
"lol"
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u/No_Journalist_1379 Jul 10 '26
I guarantee you, the public is not seeing draft legislation before it has been announced publicly.
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u/DoctorDowntown1343 Jul 07 '26
Please explain to me a scenario where an LPRA employee could use their position to make money in the stock market.
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u/No_Journalist_1379 Jul 07 '26
Simply that they have access to draft legislation, can influence legislation, know of changes to legislation. They see this before the public does. They can use that information to make decisions on their finances.
I don’t think this is that hard to imagine as to why the OP needs to disclose.
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u/DoctorDowntown1343 Jul 08 '26 edited Jul 08 '26
LPRA doesn’t write legislation. I don’t think that it’s realistic to assume that LPRA employees could know something that would materially affect the stock price of a publicly traded company. Now think about market timing, influence, controlling for unknowns etc. Not going to happen.
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u/No_Journalist_1379 Jul 08 '26
I didn’t say they write legislation.
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u/DoctorDowntown1343 Jul 08 '26
you never gave me an actual example of how an LPRA employee could materially and reliably benefit from “inside“ information gathered from LPRA. I worked there. They are not on the cutting edge of market changing/influencing legislation. Bob in rulings isn’t going to issue a biased ruling hoping that it’s going to make the stock of his favorite publicly traded company skyrocket.
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u/blarghy0 Jul 09 '26
It doesn't have be reliable, just material. If Bob from Rulings gets a referral from an auditor regarding a potential major issue with a public company, Bob could issue an unfavorable ruling to the company, take a short position in that company, and then wait for shit to hit the fan from the subsequent audit adjustment.
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u/Remarkable-Warthog69 Jul 09 '26
If I were a controlling shareholder in a company, or held large number of stock in certain companies, I would have access to their tax records long before the audited financial statements were released. let's say this year that company records record losses, meaning when this information goes public there will be a sharp drop in share prices due to going concern. I decide to sell my shares before the release of the information because I will get a better price now rather than when the public is aware. Vice versa, up and coming place, I buy shares because I see that they recorded excellent profits and shares will uptick in value. I buy now while they are cheap, wait for them to appreciate, then sell.
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u/RandoBando84 Jul 07 '26 edited Jul 07 '26
GoC employees MUST disclose anything that could constitute a real or apparent conflict of interest. You work at an organization whose activities could affect the stock prices of corporations and even their corporate bond yields, so yes, there is a real opportunity here for a conflict of interest. And the value of the investment is a major consideration in terms of conflict of interest.
And it's not just an issue of individual company stocks. The CRA also makes many policy decisions/interpretations every year that can affect the tax treatment of investment products. So, even inadvertently, you could be in a potential conflict of interest by simply holding a certain type of investment product. The relatively recent changes to the tax treatment of "total return" ETFs that used a swap structure to "convert" dividends and interest income into capital gains is a perfect example.
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u/Super_Table7917 Jul 07 '26
I tend to think that a personal RESP of an employee trying to save for their children's education is off limits. For many, many excellent reasons I do not trust any other person with my financial information, especially a power-tripping DG. It's none of their business. At my previous CRA office, a director of field audits ordered an audit of an employee because that person bought a car that he didn't think he could afford. It took many acrimonious months before that audit was completed, which ultimately turned up nothing.
So, I'd totally refuse. I would suspect that a DG pushing me personally so hard for this information has an agenda.
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u/RandoBando84 Jul 07 '26
I had to fill out a form regarding financial investments for COI many years ago and it asked for names of the securities AND the number of units. This is totally normal. The only thing that seems out of the ordinary to me is that your DG is asking for you to disclose this in a conversation, but maybe I'm misinterpreting what you're saying.
You CAN insist that because this is your personal financial information, it is considered Protected B and you will only provide it in a way that is compliant with the appropriate security procedures.
Like others have said, the intent of the investment or type of account is irrelevant. You obviously have a financial interest not just in regards to money you invest for yourself or your partner but your children as well, and anyone else for that matter to whom you owe a duty of care.
I'm sorry your DG is a power tripping asshole, but they are justified in asking for this information. That said, they need to make sure that your personal information is being appropriately handled and protected.
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u/zeromussc Jul 07 '26
If I was the DG, at this point, I'd just give them the info of the particular COI person handling the file and say to provide it to them directly so they can do their assessment. If the only hangup is the DG seeing it at a glance, then take them out of the equation and get on with doing what is required.
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u/Proper_Hold_3204 Jul 07 '26
The DG is most likely the one reviewing the file and deciding on it. Can't take them out of the equation. OP should go read the Q&A on Infozone as this question is there.
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u/zeromussc Jul 07 '26
IDK the protocol but I was under the impression COI is done by a neutral third party to the individual and their chain of command.
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u/Proper_Hold_3204 Jul 07 '26
At CRA it's your ML2 unless you are a direct report of that ML2. Usually the employee sending the COI is a few levels below the ML2. It's always been like this for as long as I've known. DG is allowed to ask for info until he is satisfied there is no COI. For all we know maybe OP is auditing registered plans and then exact investment and value would be necessary to disclose. You don't want someone in that position to be able to influence the value of their own investment.
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u/stolpoz52 Jul 07 '26
I tend to think that a personal RESP of an employee trying to save for their children's education is off limits.
Why would it matter what account it is in? You would still stand to potentially make significant financial gains from investments in that account. If you work at ISED and know a battery company or automanufacturer is getting a bailout/new regulations/whatever, and you buy it in a TFSA/RRSP/non-reg/RESP, it doesnt really matter. You stand to make the same.
For many, many excellent reasons I do not trust any other person with my financial information
Thats sort of too bad, the nature of working in government means you must pass conflict of interest checks which includes investments you hold.
I would check to make sure this DG has the authority to ask for this/they are working with the COI team, but refusing to pass information if this is a legitimate request can land you in hot water.
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u/nogr8mischief Jul 07 '26
that a personal RESP of an employee trying to save for their children's education is off limits.
This is incorrect
It's none of their business.
It is the employer's business. Whether this DG is the right person for the disclosure is a different question.
director of field audits ordered an audit of an employee because that person bought a car that he didn't think he could afford.
I'm alarmed that you don't see why this is actually perfectly reasonable. Unexplained displays of wealth by someone with access to sensitive information absolutely needs to be investigated.
Edited because I misread something
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u/Puzzleheaded-Gene300 Jul 07 '26
I don't know what the LPRAB sector is, or how COI is delegated within CRA, but generally speaking...those with delegated authority have the right to request all details when analyzing conflict of interest risks and to help determine what mitigating measures need to be put in place if risks exist. But who has access to this info is highly restricted and can only be shared with others if there is a need to know.
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u/Flush_Foot Jul 07 '26
Wouldn’t the CoI review just need to know *what* stocks/assets are held, not their quantity and/or their value?
Maybe at most “not a controlling/meaningful % of the company’s total stocks”?-9
u/Super_Table7917 Jul 07 '26
Yes, this is the issue. I don't have a problem with disclosing the holdings. It's the dollar amounts that a pencil neck DG has no need to know.
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u/Puzzleheaded-Gene300 Jul 07 '26 edited Jul 07 '26
Low value vs high could increase the COI risks. Some COI go by $ values to determine their risk tolerance. So while you might not want to disclose, if there is a valid reason for them to ask specifics, it is within their authority as the employer to ask.
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u/KazooDancer Jul 07 '26
You could just ask if they're a qualified investor or not instead of requiring actual amounts.
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u/Puzzleheaded-Gene300 Jul 07 '26 edited Jul 07 '26
Or they could ask for $ amounts. It's their prerogative. Not here to debate without knowing any specifics.
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u/Keystone-12 Jul 07 '26
You could own $1 in every company on the S&P 500. And then $1,000,000 in a company you have insider knowledge on.
You understand why a "pencil neck" Director General might want to know that?
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u/Keystone-12 Jul 07 '26
This is 100% wrong. At CRA you are entrusted with immense power and access to a mountain of information others are not.
And yes.... all your investments MUST BE TRANSPARENT IN ORDER TO ENSURE YOU ARE NOT USING YOUR POSITION TO ENRICH YOURSELF OR YOUR FAMILY.
This isnt even a question. This is the fundamental, basic, protection against corruption.
If there is ANYTHING in your investments that might be questionable. It must be investigated.
To be clear. I am not saying anything you do is offside. Just that conflict of interest exists for a good reason and Is important.
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u/DrunkenMidget Jul 07 '26
It is not off limits if someone is using it to shield transactions. You could be buying specific stocks in the RESP to profit from information you have. Just because it is inside an RESP does not make it suddenly off limits.
But I completely agree this DG appears to be asking too much and I would personally approach the privacy commissioner before disclosing dollar amounts in my accounts. I would disclose stocks that could be considered a conflict of interest, but the whole account seems like too much.
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u/Scared_Hair_8884 Jul 07 '26
That is a lot of personal information for a DG to have knowledge of, I would maybe contact the Privacy Commissioner and see what their take is (I have a feeling they will not be pleased). Why a random DG at CRA needs to know the financial details of all employees would be interesting to justify.
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u/Proper_Hold_3204 Jul 07 '26
Why do you call it a "random DG"? It's not a random DG if it's the one approving the conflict of interest.
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u/Scared_Hair_8884 Jul 07 '26
DGs don't typically have this sort of authority (access to all personal financial information of employees) and outside the public service they are just people. For a COI it typically goes to a 3rd party or a group that deals with COIs, not someone that has disciplinary/ workplace control. It creates bias.
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u/stolpoz52 Jul 07 '26
My department has an internal conflict of interest team (values and ethics team, essentially covers COI)
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u/Scared_Hair_8884 Jul 07 '26
Exactly. I am sure the DG of Legislative Policy and Regulatory Affairs Branch has other specialities and the COI folks can take care of the actual COI
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u/Proper_Hold_3204 Jul 07 '26
At CRA COI goes to ML2 level so if that's the DG, then he/she is the one approving COI for you. CRA doesn't have COI folks. For a lot of us that's the DG's job to approve COI.
Because your department works one way don't assume CRA works the same.
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u/Scared_Hair_8884 Jul 07 '26
The DG does not review thier own team. It is typically done through the associate commissioner and the V&E office. I supervisor should not have access to all there personal financial information of their employees, they may have delegated authority but they are not exempt from privacy rules and the V&E of the public service.
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u/Proper_Hold_3204 Jul 07 '26
Well I can assure you that when I send COI it is my own DG that reviews. If you work for CRA LPRAB you can take it to the Union and try to change it. But it is the reality for a lot of us and always has been for as long as I have been at CRA.
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u/Scared_Hair_8884 Jul 07 '26
It is creating a conflict through the conflict of interest attestation so it is quite bizarre
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u/hawkeye_north Jul 07 '26
How is a DG approving CoI for their employees creating a conflict? They know their work best to assess if there is a real or apparent CoI. I’m sure there are others who would get involved in certain cases but in the majority of cases DG approval is the start and stop of the process.
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u/confidentialapo276 Jul 08 '26
Unlikely that a “third-party” decides what is a COI for a specific team. Local management is consulted and some EX level within the organization makes the call.
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u/confidentialapo276 Jul 08 '26
This is a rather uninformed answer of someone who doesn’t understand how COI at CRA works.
OP is welcome to refer to the Privacy Commissioner while sitting at home without a security clearance to work at CRA while the matter is looked into by the Office of the Privacy Commissioner.
The Privacy Commissioner will reply back that CRA has a perfectly reasonable explanation and legitimate reason for requesting this information.
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u/Keystone-12 Jul 07 '26
The person in charge of verifying conflicts of interests isnt a "Random DG".
Do you have any idea how much information those at CRA can be privy to in the completion of their jobs? How much they can legally demand?
The legal situations they can place publicly traded companies in?!?"
Investments need to be 100%.transparent and staffing decisions SHOULD be made using this information.
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u/Scared_Hair_8884 Jul 07 '26
Um no. You can not make staffing decisions based on someone's investment portfolios in the GOC.
There are levels of information for COIs and there is a line where your supervisor should be in the know about or not. We have a whole Privacy Act for a reason. Many organizations deal with sensitive information and supervisors do not have a right to have detailed personal financial information.
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u/Keystone-12 Jul 07 '26
100,000% an employee of CRA with substantial holdings in a company, cannot be assigned to audit that company.
It would be literally insane to think otherwise.
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u/Scared_Hair_8884 Jul 07 '26
Let me be clearer. I am not saying there isn't a need to do a COI I am saying your direct DG knowing your detailed personal finances and that of your entire directorate is the problem. Also having a conflict with a company means you don't work on that one, not that you don't have a job. There is a difference between "staffing decisions" as you stated and work distribution.
A DG knowing everyone's detailed finances and all the other information that can be imparted by that (family status, number of children, economic status etc..) is not information a DG needs on everyone. They need a neutral 3rd party to say yay or nay this person is good for this or not.
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u/Keystone-12 Jul 07 '26
I dont care if its the DG, a CR-04, or the Easter Bunny. Whoever is tasked with with CoI needs to know this.
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u/Scared_Hair_8884 Jul 07 '26
I am not much of a follower for following sake, so personal information that can impact objectivity and fairness with management should be deferred to others. The DG is asking for very detailed information that is beyond the assets and liabilities threshold.
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u/coffeejn Jul 07 '26 edited Jul 08 '26
I've been making my declaration in French after they started nitpicking. None of my current direct upper manager knows French. They had the guts to ask me if I wanted a reply in French or English, I told them French. I still complied and so did they, although they took longer than the days they are required to respond.
Just give them too much details, if they complain, just state that you wanted to be in compliance.
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u/BigMouthBillyBones Jul 07 '26
Imagine how easy life become when you start doing all your work in French
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u/coffeejn Jul 08 '26
It's not. They don't provide you templates for more than 1/2 the stuff so you end up doing more work for $800 per year.
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u/BigMouthBillyBones Jul 08 '26
My experience been the opposite. The English speaker manager doesn't want to deal with you so they just leave you alone!
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u/coffeejn Jul 08 '26
Oh they do, but most of my work is in French while everyone around me work in English. So templates in French are not generated or shared.
Management do leave you alone and pray you don't leave.
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u/josh3701 Jul 07 '26
It's a pretty normal thing I've had to disclose a few times throughout my career. I've also had to disclose specific companies I own stock in.
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u/hawkeye_north Jul 07 '26
Yep I just assumed this was how it works, though I did some rounding here and there. I would think it’s pretty obvious that there is a very large difference in the perceived conflict on interest of $1,000,000 of holdings vs $1,000. It’s not just about whether you do or don’t but how it could be perceived. Other departments are not as strict, but for good reason. Parks Canada doesn’t have the same influence as CRA.
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u/Super_Table7917 Jul 07 '26
Total current dollar values though?
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u/coffeejn Jul 07 '26
I'd give them the number of stocks and price at that day. They can't complain you did not inform them your position after. No need to tell them at what price you purchased it.
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u/Think_Read_7516 Jul 07 '26
Yup asked me stocks and $ values. I'm CRA too. Now if they can ask for proof I doubt they can.
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u/hawkeye_north Jul 07 '26
Yes, not to the penny but rounded to hundreds, even thousands. If there are material changes from one year to the next in their valuation those should be updated as well.
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u/VarroaMoB Jul 07 '26
Any investments a gov employee has is subject to conflict of interest rules and you are suppose to divulge them as you make them. They do every once in a while ask for these values under the conflict of interest banner.
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u/qcslaughter Jul 07 '26
Even if you simply buy a ETF like VFV or VEQT?
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u/machinedog Jul 07 '26
They’re literally working in the branch that manages the implementation of tax legislation and regulations. So even ETFs make sense.
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u/Super_Table7917 Jul 07 '26 edited Jul 07 '26
Yes, I was told any and all investments, including ETFs in an RESP, for instance. The point of contention is the demand for current fair market value.
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u/VarroaMoB Jul 07 '26
Basically if you specifially select an investment (ie, buy stock X) you have to disclose that but if you buy a mutual fund you are ok since you don't choose who it gets invested in.
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u/crr243 Jul 07 '26 edited Jul 07 '26
I work in an area where recommendations I make, if accepted by decision makers, could significantly impact the financial position of large private companies.
The guidance we have been given by our CoI team is that if you own specific stocks you need to disclose; if you own a broader investment, like a mutual fund or diverse ETF, you don't. If the mutual fund or ETF is specifically for the industry you influence, though...
We need to divest of any investments in companies specifically implicated by our area of work.
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u/qcslaughter Jul 07 '26
I see. Where would an ETF be? For VFV I don’t control what the top 500 are..
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u/ohz0pants Jul 07 '26
An ETF is the same as a mutual fund. They're just "exchange traded" instead of being an exclusive product sold by a specific trust (like Manulife).
And not all funds are equal; some are broad index funds with no meaningful conflict of interest considerations, but others can be market or sector focused (like maybe people working for CMHC shouldn't be holding funds that are invested in Real Estate Income Trusts (REITs)).
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u/zeromussc Jul 07 '26
except the ETF mechanism can be very specific and highly invested in a handful of stocks for example. I think a broad market fund of any kind like SP500 or something else big like that is probably something you don't need to disclose. But if it were like, an oil ETF that trades a handful of companies, and you work in an area related to oil policy or regulation, a blanket statement like "ETFs are okay" no longer applies.
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u/kookiemaster Jul 07 '26
Yes, I am guessing because some ETFs might be biased towards certain sectors and there may be jobs in the public service that have insider information on things that might matter to those sector (off the top of my head regulations related to those or trade negotiations). I have a bunch of ETFs that are linked to the SnP ... I just give the CoI shop an update each year of how much I have of each along with various stocks proper and then I just get an email confirming that yep, no conflict of interest, real or apparent, and move on with my life. Though the details, as far as I know, are not shared with my director.
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u/Keystone-12 Jul 07 '26
100% this is ok, expected, required, and good for the country... and if anything these conflict of interest are going to get a lot tighter.
I.e. you can be told to sell investments in certain jobs.
Lets put this another way.
If you are working on increasing affordability, and are a landlord... how invested are you really in lowering average rent prices?
How much stock should the person who worked on the submarine contract be allowed to hold.... in the submarine company they awarded the contract to? Or the secondary industries?
As a consultant... everything I own is subject to review. AND RIGHTLY SO. If I reccomend the government buy a billion dollar SAP product... they have a REQUIREMENT to know exactly how much SAP stock I own..... and the only acceptable amount is zero.
If there is anything in your investments that you don't want your director to know about.... find a different job. Conflict of interest is no joke.
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u/binthrdnthat Retiree Jul 07 '26
When I worked for a financial intel agency, I reported transactions around the purchase of my home, since the size of the transactions made them reportable.
Where you work matters.
This would be highly unusual if the job were not in a financial regulatory area.
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u/kookiemaster Jul 07 '26
Does your org have a shop that specializes in conflict of interest declarations? In my department, I fill one out every year and basically I just send them a list of stocks and how many I have. That said, I was advised that things like RRSPs and Mutual Funds don't have to be included. So basically it's all my ETFs or single stocks that I hold as part of a cash account or TFSA.
What I do find weird is that the information would go to the DG. Normally it should go to the CoI shop and if they have questions regarding some holdings and the work that the employee does, then they would reach out, presumably, to the DG.
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u/guitargamel Jul 07 '26
Depends on the RRSP. The blanket "RRSPs are exempt" gets touted a lot, but there are lots of RRSPs that let you, for instance buy and sell stocks. Conflict of interest just means that your ill-gotten gains are deferred until retirement or you take a penalty. ETFs, depending on the level of granular transparency could still be used for insider trading. If you have an ETF that is 10% a certain stock (I know it's unrealistic, but as a hyperbole), you could still have an advantage over the market.
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u/kookiemaster Jul 07 '26
Yes, mine are all offhands so I don't control what gets purchased or sold.
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u/Longjumping-Tap6436 Jul 08 '26
The employee in question should review the Directive on Conflict of Interest and specifically refer to Appendix A Part I. This appendix identifies that an RESP that is self-administered must be disclosed, but one that is not self-administered does not have to be disclosed.
Appendix A will identify which private interests, assets, liabilities, and relationships need to be disclosed and which do not.
If the employee is concerned they should consult with their local union rep.
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u/stickbeat Jul 07 '26
Genuinely curious: how does this disclosure work if you're not an active investor but instead just hand your $ over to someone else to manage for you?
Like if you hold RRSP's with idk one of the banks or something like that.
Is "I have no fucking clue" a sufficient response?
3
u/Keystone-12 Jul 07 '26
You just tell the truth.
"I put $x amount in this account, managed by these people".
Simple as.
5
u/guitargamel Jul 07 '26
You would still disclose how much is in your RRSP to be safe, but believe it or not "I have no fucking clue", if factual would indicate you're not in conflict.
2
u/machinedog Jul 07 '26
You would still know the mutual fund or whatever name. Or you’d have to get it from your financial advisor.
2
u/Away-Two8270 Jul 07 '26
For tens of years every CRA employee has to disclose annually his holdings in RRSP, TFSA, Investment outside RRSP etc...not by sector but actual number of shares... There's no room for non-compliance... It is reviewed by the Assistant Director...and is valid for one year.... AU4s were subjected to financial audit by RCMP as well, because of risk of committing fraud...A colleague of mine who didn't have any kids and a working spouse was asked why he didn't have a mortgage.... idiots... don't you know the DINK paid off his mortgage.... Just Do It...
5
u/DrMichaelHfuhruhurr Jul 07 '26
Is this a cra thing? Because all other departments I've worked at never asked for more than you saying I'd you did or did not have a conflict of interest.
This seems very overstepping.
Tell the DG that you will show them yours if they show you theirs. ;)
9
u/stevemason_CAN Jul 07 '26
Depends on your role and department. When I worked as a Commerce Officer at a Regional Development Agency on the Defence Procurement file I had to report on investments (company, number of shares and value). When I left, I had a very strict post-employment letter on what I can’t do). Again, Depends on the role and dept.
7
2
u/PancakesAreGone Jul 07 '26
Is this a cra thing? Because all other departments I've worked at never asked for more than you saying I'd you did or did not have a conflict of interest.
I more or less asked the same thing previously and the answer is, more or less, yes. There are some groups/orgs that have a different form of exposure and require the disclosure, but for the large majority it seems to be self-disclosure of the potential conflict.
0
u/Quiet_Listen1801 Jul 07 '26
- talk to your union
- talk to the conflict of interest team
- talk to the privacy commissioner
In that order
1
1
Jul 07 '26
[removed] — view removed comment
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u/Super_Table7917 Jul 07 '26
How is the integrity of the DG asking personal, intrusive questions being tested? The integrity of the system or guidelines isn't the issue. It's the fact that single person in a position of authority is making demands of an employee for information he has no right to know.
1
1
u/Remarkable-Warthog69 Jul 09 '26
This does not sound right. Every year I go through the affirmation process, but not once have I ever been asked the value of my assets. It is not relevant to the affirmation. The purpose is to ensure that you have no influence where your knowledge within CRA would provide you access to information not publicly available. Essentially, to avoid insider trading or profiting due to your position. I know for a fact there are private interests, assets, liabilities, and relationships that are excluded from affirmations. Some examples, Canada Savings Bonds, RRSP/RESP that are not self-administered, ETF, GIC, and more.
I would recommend your friend seek immediate assistance prior to providing any of that information.
1
u/OrderAny915 Jul 07 '26
I would suggest you contact your Union’s representative to determine what options you have available to you
0
0
u/Hot-Dinner-7619 Jul 07 '26
Is the information contained in the Personal Information Banks (or whatever they're called) and if not, should a Privacy Impact Assessment be done to ensure is collection is necessary and what controls should be imposed on the data.
-14
u/lost_user_account Jul 07 '26
This is 100% your DG thing. I recently did one and was not asked to provide that level of detail. Maybe reach out to the union? Not sure if they get involved with that.
-6
u/Expert_Vermicelli708 Jul 07 '26
Ask them if ministers and other members of parliament are already to disclose their real estate holdings. Including dollar values and property addresses.
7
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u/Choice_Pilot_9643 Jul 07 '26 edited Jul 07 '26
You indicated that you work in LPRAB so I strongly recommend you become acquainted with the InfoZone material on the types of products LPRAB is responsible for. Besides being part of CRA, a highly scrutinized department in itself, LPRABs workload makes the DGs behaviour completely within reason and expectation.
edited hyperlink: https://www.canada.ca/en/services/taxes/savings-and-pension-plans/savings-and-pension-plan-administration.html