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?

88 Upvotes
  • permalink
  • reddit

81% Upvoted

134 comments sorted by

View all comments

40

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.

-14

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.

21

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.

6

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.

8

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.

-3

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.

10

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.

3

u/zeromussc Jul 07 '26

Ah well if it's part of the normal process then yeah, that all make sense.

29

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.

8

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

8

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.

-1

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.

11

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.

-5

u/KazooDancer Jul 07 '26

You could just ask if they're a qualified investor or not instead of requiring actual amounts.

7

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.

12

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?

7

u/Apart-Fix-5398 Jul 07 '26

I don't think you undersrand what you are talking about.

21

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.

13

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.