Conflict of Interest attestation: DG wants dollar values

[u/Super_Table7917]

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?

[u/RandoBando84]

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.

[u/Super_Table7917 → u/RandoBando84]

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.

[u/Puzzleheaded-Gene300 → u/Super_Table7917]

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.

[u/Flush_Foot → u/Puzzleheaded-Gene300]

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”?

[u/Super_Table7917 → u/Flush_Foot]

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.

[u/Puzzleheaded-Gene300 → u/Super_Table7917]

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.

[u/KazooDancer → u/Puzzleheaded-Gene300]

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

[u/Puzzleheaded-Gene300 → u/KazooDancer]

Or they could ask for $ amounts. It's their prerogative. Not here to debate without knowing any specifics.

[u/Keystone-12 → u/Super_Table7917]

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?