:
Good afternoon, ladies and gentlemen. This is meeting number 55 of the Standing Committee on Human Resources, Skills and Social Development and the Status of Persons with Disabilities. We're here to continue with our current study to explore the potential of social finance in Canada.
Members of the committee expressed an interest in bringing back government officials for further questioning after hearing from witnesses across Canada.
We're pleased today to have with us from the Department of Employment and Social Development, Ms. Siobhan Harty, director general, social policy directorate, strategic policy and research branch, along with Mr. Blair McMurren, director, social innovation, strategic policy and research branch. Welcome back to the committee.
From the Department of Finance we have Miodrag Jovanovic, director, personal income tax, tax policy branch.
Finally, from the Canada Revenue Agency, we have Ms. Cathy Hawara, director general, charities directorate, legislative policy and regulatory affairs branch, and Mr. Bryan McLean, director, policy, planning and legislation division, charities directorate, legislative policy and regulatory affairs branch.
Members, we have just the one panel today, so we'll start with seven-minute rounds during the first round. I'm at your behest in terms of how long you want the meeting to go on. If you exhaust the questioning, at a certain point we'll end the meeting, because I think there's a feeling there may be some redundancy. I'm just pointing that out. I've talked to a few members of the committee who feel that might be the case. We may end early, but I'm at your behest in terms of how many questions you wish to ask or your timing of them.
Let's begin with our first round of questioning with Madam Groguhé. Are you going first?
I want to thank the committee for giving me the opportunity to return to speak today. I am pleased to be here with my colleagues from the Department of Finance and the Canada Revenue Agency to address any final questions you may have, or indeed to provide you with clarification on particular points.
[Translation]
I would first like to take a moment to thank the committee for the valuable work you have undertaken with this study.
I also acknowledge all the stakeholder groups who took the time to contribute to your study.
Since I last spoke to you, the Government of Canada has announced new measures in Budget 2015 to grow the social finance marketplace in Canada.
First, Budget 2015 proposes that registered charities be permitted to invest in limited partnerships with some conditions. My colleague from the Department of Finance will speak about that in his remarks.
[English]
Second, the budget announced the forthcoming launch of a social finance accelerator initiative to be led by ESDC. This announcement follows up on a commitment made by the government in the 2013 report of the National Call for Concepts for Social Finance, called “Harnessing the Power of Social Finance”, to bring together innovative, not-for-profit, and private sector organizations in order to sharpen their social finance ideas into investment-ready proposals.
Greater detail on this initiative will be made available in the coming weeks. lt's expected to involve advisory services, mentorship, brokering, and investor introductions to help fast-track promising social finance ventures to a greater stage of investment readiness.
Finally, I want to advise the committee of an upcoming event. The last regular meeting of the international Social Impact Investment Taskforce will take place in Toronto next month. The task force was created during the United Kingdom's G-8 presidency in 2013, with the aim of catalyzing the development of a global market for social finance.
The former minister of employment and social development, the Honourable Jason Kenney, had nominated me and Tim Jackson of the MaRS Centre for Impact Investing to sit on the task force.
This task force meeting will be hosted by the MaRS Centre for Impact lnvesting, and it offers a unique opportunity to profile Canadian approaches to social impact investment and benefit from the perspectives of task force members, who might have advice on how to advance the development of the Canadian market. Every task force member country that has hosted a meeting has used the opportunity to organize panels profiling aspects of their market that distinguish them from other countries.
[Translation]
These panels have created important cross-national learning opportunities. For the Canadian Task force meeting, there is a proposed panel on Aboriginal models that will likely elicit strong interest. A proposed panel on using social finance to advance international development will also be of great interest, given the government's record on innovation.
Thank you again for this opportunity to appear as a witness.
[English]
My name is Miodrag Jovanovic. I am director of the personal income tax division with the Department of Finance.
Thank you very much for your invitation to appear here today before the committee regarding your study of the potential for social finance in Canada.
First, I would like to speak briefly in broad terms about the Canadian taxation and regulatory framework for registered charities in the Income Tax Act as it relates to social finance and social enterprise. I understand that my colleagues from the Canada Revenue Agency will speak in more detail about how they administer the provisions in the Income Tax Act.
Second, I would also like to draw your attention to a measure in the recent budget that responds to recommendations made to this committee.
The rules that relate to charities' involvement in social finance take into account a number of different principles, policy objectives and practical considerations. These considerations include the following:
In Canada, charities are exempt from taxes and are permitted to issue tax receipts for charitable donations for which individuals may claim a tax credit and corporations may claim a tax deduction. This results in forgone revenue and a tax expenditure of about $3 billion annually. This tax expenditure recognizes the charitable sector's important social and economic contributions. The lncome Tax Act provides a set of rules to ensure that tax assisted charitable resources are used to advance the purposes for which a charity has been established. In other words, charitable resources must be used for charitable purposes.
ln this context, the lncome Tax Act aims to strike a balance between allowing charities to engage in business activities, including social enterprise, as a source of revenue while ensuring that charities ultimately remain focused on their charitable purposes and activities.
Most charities can raise revenues directly to support their charitable activities as long as their business activities are directly related to, and subordinate to, the purposes for which they have been created. Where the business activity is closely related to the charitable purpose, it can make sense to integrate the business activities into the charity.
With the exception of private foundations, charities that wish to engage in unrelated business activities can do so by establishing a separate entity, typically a corporation, to carry out these activities. This can be an attractive option for charities since there are few, if any, restrictions on how a corporation's capital is raised and how its assets and revenues are used. Having a separate entity allows the charity to maintain its focus on charitable activities and use its charitable assets towards these activities.
The rules also attempt to provide a level playing field between businesses run by charities which are tax-exempt and businesses that pay tax. Taxpaying businesses, including small and medium-sized businesses could be placed at a competitive disadvantage if charities were able to conduct tax-exempt business activities without restriction.
[Translation]
To re-iterate, this suite of parameters is intended to allow charities to engage in business activities as a source of revenue while at the same time ensuring that charitable resources are not diverted from their charitable purposes.
As mentioned by my colleague from the Department of Employment and Social Development, I would like to discuss briefly a measure introduced in Budget 2015.
The Department of Finance discusses policy issues concerning registered charities with the charitable sector on an ongoing basis. We have been in touch with the charitable sector on social finance for several years. A number of stakeholders have told us that, if charities were permitted to invest in limited partnerships, they would be able to make more impact investments, that is, investments that generate both a social and financial return.
[English]
Up to now, charities have not been permitted to hold interests in limited partnerships in most cases because a charity that held an interest in a partnership was considered to be carrying on a business. Charitable organizations and public foundations can only engage in related businesses, with the result that few are in a position to hold interests in a partnership. Private foundations cannot engage in any business activities that prohibited them in all instances from holding interests in a partnership.
Charities have also told us that allowing them to invest in limited partnerships would permit them access to a wider range of investment opportunities to diversify their investment portfolios.
ln light of these recommendations, budget 2015 proposed that registered charities be permitted to invest in limited partnerships subject to certain conditions. This measure is expected to have two benefits. First, in allowing charities to diversify their investments, it will provide them with the opportunity to access a wider range of private market investments, such as infrastructure investments, and by so doing enable them to obtain better returns on their investments. This will in turn increase the resources they have available to fund charitable programs. Second, since there are many social impact investments that are structured as limited partnerships, allowing charities to invest in limited partnerships will enable them to better align their investment portfolios with their charitable purposes, and will potentially make available additional funds for social enterprise projects in Canada.
I would be pleased to respond to any questions the committee might have.
Thank you.
:
Thank you very much, Mr. Chair.
My name is Cathy Hawara and I am the Director General of the Charities Directorate within the Canada Revenue Agency.
As my finance colleague explained, it is their role to write the rules that support the government’s tax policy agenda. It is the CRA’s responsibility to administer those rules.
[English]
Let me start by saying that while the term “non-profit” is sometimes used to refer to both registered charities and non-profit organizations, there are some important differences. First, only charities are registered by the CRA. While both are tax-exempt, only registered charities can issue official donation receipts to donors. In exchange for the privilege of issuing receipts for donations, registered charities are also required to file a publicly accessible annual information return. Finally, while registered charities can carry on related business activities with the intention of making a profit, NPOs cannot have a profit purpose.
As the charities directorate of the CRA is responsible for the regulation of registered charities, that's where I will focus my remarks.
[Translation]
There are approximately 86,000 registered charities in Canada and these entities enjoy significant tax privileges. In 2014, the Department of Finance estimated that the fiscal cost for the federal government of tax incentives for charitable donations by individuals was more than $2.5 billion. As my colleague mentioned, when we take business deductions into account the fiscal cost is closer to $3 billion. These tax privileges come with the obligation to follow the rules set out in the Income Tax Act.
Under the basic statutory framework, there are three types of registered charities: charitable organizations; public foundations; and private foundations. Regardless of the designation, the Income Tax Act requires that all registered charities operate in one of two ways: they can carry on their own charitable activities; or they can make gifts to other “qualified donees”. In this context, the term “qualified donee” usually refers to other registered charities, but it also includes low-cost housing corporations for the aged, municipalities, municipal or public bodies performing a function of Canadian government, prescribed universities, certain foreign charities, registered Canadian amateur athletic associations, the United Nations and its agencies, and Her Majesty in right of Canada or a province.
[English]
In order to finance their charitable programs, whether they be through direct activity or funding of other qualified donees, registered charities need to generate revenues and do so in a number of ways.
The first is through fundraising. Most registered charities rely on fundraising to generate revenues. In 2013, registered charities reported $14.79 billion in tax-receipted gifts according to the information reported in their annual information return, the T3010. The recent budget proposal to exempt capital gains tax on gifts involving real estate and private shares adds a new incentive with respect to fundraising efforts.
Second, most charities can conduct related business activities. Under the Income Tax Act, there are two basic types of acceptable business activities: businesses that are related to a charity’s purposes and subordinate to those purposes, and businesses that are run substantially by volunteers. An important caveat is that private foundations are prohibited from engaging in any business activity.
Third, registered charities can generate revenues by making prudent market investments, which may include investments in separate taxable corporations or trusts established by the charity.
A charity’s board of directors would need to ensure that the investment is a prudent use of the charity’s assets. It must also ensure that no benefit of a private nature is conferred on the corporation or the trust.
Charities can also make program-related investments, commonly referred to as PRIs. A PRI is not an investment in the conventional financial sense since it would not necessarily yield a market rate of return. If a PRI furthers the investor charity’s charitable purposes, it could be considered a charitable activity. Common examples of PRIs include loans, share purchases, and leases of land or buildings.
An additional point to note, as my colleague has already, is that the recent budget announcement relating to investments in partnerships increases the flexibility charities have in structuring their investments.
Finally, registered charities can generate revenues through their charitable activities. Registered charities can charge fees for the services they provide.
In closing, while the common law and the Income Tax Act place certain restrictions on the use of charitable assets, Canadian registered charities can and do play an active role in addressing pressing social problems, as service delivery agents, as funders, and as investors.
Registered charities can also work together with the business community to deliver programs that are designed to achieve social outcomes, for example, educational activities relating to employability training, career counselling, entrepreneurial training, or on-the-job training in vocational or work skills; running social businesses with individuals with disabilities; and preserving and maintaining high standards of practice within an industry.
[Translation]
The CRA is committed to helping registered charities understand the rules and for that reason, publishes a variety of guidance products on a wide array of topics. Our website contains information of interest to charities, donors, legal representatives, and researchers.
You can also find the annual information return for each of Canada’s 86,000 registered charities. The return contains a wealth of both program and financial information on charities.
As we add new information to our website and develop and refine our tools, we continue to be interested in receiving feedback from external stakeholders.
I would now be happy to take any questions.
I want to thank the witnesses for being here today.
My first question is for our witnesses from the Canada Revenue Agency and the Department of Finance.
You quickly went over the criteria, if I may put it that way, for the new rules for charities.
However, I would like to come back to the negative impact that a number of witnesses raised here, before this committee, with regard to the costs associated with adopting social finance. For example, when David Juppe, senior operating budget manager and tax expert from Maryland testified, he illustrated to us that using social finance, including SIBs, would cost the government more because of the use of a third party and the pay-for-success model. He even described SIBs as the government's credit card.
I would like your take on this warning. In your view, how can we effectively assess the recurring cost of social finance in general and SIBs in particular? When might such an assessment take place? Before, after, or during the launch? How can we truly know, in any meaningful way, what the government is getting itself into and what costs will be associated with this social finance?
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I think that there are probably different costs. Again, I am not speaking from experience. I am speaking from a comparative perspective, knowing how other countries have managed this. The first cost is a transaction cost, just from the legal dimensions of having to make contractual arrangements related to social finance or a social impact bond. What we hear from other countries is that the more you do, the lower the transaction costs become. The transaction costs are high for the first transaction because there is a learning dimension to it, but the more you do, the lower the cost. The British case is a good example here. They have multiple social impact bonds, so they have been able to capture lessons learned from the first social impact bonds and apply them to subsequent ones, thereby reducing the transaction costs.
In terms of evaluating things as you proceed, I am not sure here if you mean the costs of implementing a social finance initiative like a social impact bond, or if you mean evaluating any kinds of savings. As with any kind of project or expenditure, costs are monitored. With any project management approach, you would monitor costs along the way, and then you would do an assessment at the end.
In terms of being able to assess whether there are any savings, that could only come at the end, unless you establish some milestones of payments along the way, which is done, for example, in standard pay-for-performance contracts in many countries, including our own, as well as in some of the social impact bond projects that have been put together in various jurisdictions.
:
Thank you, Mr. Chair, and thank you to the witnesses for being here today.
It's interesting that today I had a delegation representing national charities in my office talking about our government's initiatives and policies as far as charities are concerned and trying to encourage them and make their job easier to raise funds, and to do their good work, and they did commend the Department of Finance and CRA for the great work you've done together with the group. So thank you for that.
The chair was quite right that politicians are going to look at the value of social finance. You are here to tell us how the framework will work in order to make it happen, and also to be able to regulate it to a certain extent. One of the things that the framework has to do is to talk a little bit about best practices, and the tax framework, and financial policy.
I would like to direct my first question to Mr. Jovanovic.
In business you have two types of income. You have active and passive income, and you're taxed at a different rate for those. Is there any possibility of having something like that for a social initiative even in a small business or a large business where you could look at the social impact and have a different level of taxation so that you wouldn't have, like you say, charities competing against businesses? A business could take advantage of it too if they wanted to hire disabled people and there was a certain way that we could evaluate that social value and it could be reflected on their income and how it's taxed.
I just throw that out there, because for me I'm having some challenge in looking at the value of social finance with regard to maybe replacing some of the services provided by government, and then there's the private sector. I'd like to see an opportunity for the private sector to take advantage of what I call social finance in what they do. This could be as partners. Could you share a little bit on whether or not that would be something that could even entertained?
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I'll move away from charities. I'll give you an example.
We had a witness here when we first started this study who mentioned that there was a family foundation in Quebec that gives capital out to new businesses that want to start and they discount the interest, their ROI, if there's a percentage of the people who they hire with disabilities. I think that is a great initiative for a small business, or even a large business, that they are going to benefit by having a social conscience and hiring people with disabilities.
Is there any way we could even incorporate that in our finance or the things that we do? That's where I'm going, to that type of thing, because as I say, I just think that in Canada we don't do enough to encourage trying to help people with disabilities and work them into the workforce. I think there could be policy forwarded by the government that would assist businesses and encourage them. I had that experience myself. We had a program. We had a person with Down's syndrome work for us stocking shelves in our grocery store. It made a big difference in how our customers and our employees, as they saw that person working in our store, looked at me as the owner. The program was only for a certain length of time and then it was gone. The manager discontinued it, and everybody was disappointed, including myself. The thing is if there was some sort of initiative so that you go into that program and then you can carry on, I think it would be great and it would be an opportunity for what I call social finance. It's a government acting in a way of social finance to help a business incorporate that.
Maybe you could comment on any of those. Is there any possibility maybe in finance that you could discuss the opportunity that would present?
I'd like to thank all the witnesses for coming out today.
I'm going to follow through on the trend Mr. Mayes was starting. I was very interested in that, so it's going to be very similar.
Just to step beyond, he was talking about a grocery store, but in just about every community across Canada, we have recycling depots. Many of these recycling depots are operated by charitable groups. Some are offered by private companies, etc. They're an ideal place for handicapped people or people with learning disabilities to work because they can do one function.
I'd like you to answer what Mr. Mayes started. I think it's very important. We see it in almost every community in Canada, and for many, it's a part of social finance. It gives them a place to work.
Who wants to start?
Blair, you haven't answered—
:
I can begin answering the question.
There are actually a number of things that charities can do currently within the existing framework by working with partners that are not registered charities that might be non-profit organizations, or that might be businesses. That's what I referred to in my opening remarks in relation to program-related investments.
This is where charities might make an investment, a non-conventional investment, an investment that is really made for the purpose of furthering a charitable purpose, for furthering their own charitable purpose. Their purpose might be to relieve a condition associated with a disability or to relieve unemployment of a particular class of beneficiary, such as persons with disabilities. They can make an investment, let's say, in a corporation through the purchase of shares, for example, and then a proportional number of employees would be individuals who meet the eligibility criteria of the charity, so potentially in this case, persons with disabilities.
There are also ways in which a charity itself through charitable programming can do what you've described. In our policies, we indicate that charities can run what we call social businesses for persons with disabilities, where the majority of the workforce is made up of persons with disabilities. The work is structured and operated in a way that addresses the disability and accommodates the workers so that they can be permanently employed and productive members of society.
All of this is guidance that we've provided to charities, in particular, through our community economic development policy, and they are things we can do now. It's not so much an incentive on the business side. From our perspective, we are enabling charities to carry out these kinds of activities in furtherance of their own charitable purposes. It's a way for them to bring in other partners from outside the charitable sector to achieve the social outcomes you've identified.
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The reason they were not able to invest in limited partnerships is that the general interpretation under the Income Tax Act is that investment in a partnership is by definition carrying on business. That's why they could not invest in limited partnerships.
The way this will be brought in within the legislation is to say that the mere fact of investing in a partnership now, if you're a registered charity, doesn't necessarily mean that you are carrying on business. We're going to look beyond that. We're going to say that as long as you invest in a limited partnership and you respect these conditions, i.e., you, the charity, along with related parties, don't invest more than 20% in that partnership, are not related to any general partner in that partnership, and comply with other conditions as well, which we call “anti-avoidance” provisions, then you should be fine. You will be able to invest in that limited partnership.
That's how we're going to change the legislation, so that it provides way more flexibility for charities.
:
Mr. Chair, I want to thank everyone for being here today.
I think it's a great irony that Imagine Canada is touring around, visiting us MPs today, promoting the charitable sector, and promoting the important work they're doing. Social enterprise is very much on their minds. I think, and I'm hoping, that this study and the recommendations from this committee are going to be very helpful to the government in looking at ways we can be promoting, encouraging, and supporting greater social enterprise and social finance in the country.
One of the things a few of the charities have raised with us is their concern about their charitable status if part of the social enterprise is engaging in some commercial activity. I'm going to give you an example. There is a place called Destination Cafe in Mississauga that I'm familiar with. It specifically helps individuals with mental illness-related issues. It is affiliated to some degree with the Canadian Mental Health Association. Basically, it provides housing and employment opportunities in running a cafe. The cafe is on the ground floor. The apartments are on the second floor. The people who live in the building also work. They are earning commercial revenue as that social enterprise. As I understand it, if the revenue is a higher percentage of their overall budget in a year, it could jeopardize their charitable status.
I'd like someone to explain to me how that works, because I think that would be a real shame. I think it would be a shame if we had a group doing some excellent work on the ground, but because of the technical requirements in the rules around how much revenue they can bring in as a percentage of their overall budget it could threaten their charitable status.
I don't know who the best person is to answer. Cathy, are you the best person to answer that? Maybe you could walk us through how that would work with a typical charity that wants to do something like that.
:
Thank you for the question.
Of course, I can't speak about specific cases because of the confidentiality provisions of the Income Tax Act, but I am happy to speak generally about the rules.
I think the starting point has to be that there are a number of different ways in which charities can generate revenues. They can generate revenues through charitable programs. There's no limit on how much revenue they can generate through charitable programs. They can generate revenue through business activities, and there are rules around business activities. They need to be related business activities. If they meet all of the requirements laid out in the Income Tax Act, there's no limit to how profitable those things can be. Simply looking at the percentage of the business revenue in relation to the overall revenues wouldn't be a sufficient indicator from our perspective.
In a scenario similar to what you've described, where a charity's purpose is to help relieve employment of a group of at-risk youth, let's say, or help relieve the conditions associated or related to these at-risk youth, part of the activities of the charity could certainly be providing on-the-job training, training skills, and providing the kinds of opportunities that you've described. That could all very well be a charitable activity. It's going to be a factual determination based on the individual facts of the case.
The first question I would have is whether the activity is a charitable activity that allows the charity to generate revenue. If the activity is not a charitable activity, it could still be a related business activity. Charities are allowed to participate in related business activities to the extent that.... There are two forms of related businesses. One, either a business is linked and subordinate to the charitable purpose of the charity, so the charitable purpose always has to be the focus of the organization, or two, linkage is established by looking at whether it's a use of excess capacity or whether it's an offshoot of the charitable program. There is a number of criteria we would use to determine whether the business is a related business.
If the business is not linked to the charitable purpose, but it is run substantially by volunteers, then that is absolutely acceptable under the Income Tax Act. There are many rules in place currently that allow charities to generate the kinds of revenues and the kinds of social outcomes that you've described. You can find both of those in two of the policies we've put out. One is the community economic development policy and the other is our related business policy, which lays all of this out, including some examples, to help charities.
We are constantly looking at the policy work we do and the policies we have available to charities. We listen to the feedback that we hear from charities. A lot of times what they tell us is that examples are really helpful, and to the extent that we can provide examples of what's acceptable, those are the kinds of things that they're looking for.
I have one last comment on charities being concerned about their charitable status. Our approach is an education-first approach, whether it's through the educational materials we provide or through the compliance work we do. To the extent that we can work with charities, explain to them the rules, and help them get back on track, that's what we aim to do.
:
Yes, I can take that question. Thank you very much.
There are 86,000 registered charities in Canada today, more or less.
In order to be registered as a charity in Canada, you have to meet a few requirements. First, you have to have exclusively charitable purposes. Charitable purposes are actually not defined in the Income Tax Act. We have to look to what the courts have said. There are four broad categories of charity: charities that relieve poverty; charities that advance education; charities that advance religion; and then another catch-all with charities that advance other purposes beneficial to the community as a whole. You'll find lots of different kinds of organizations in that last category, including health organizations and animal welfare organizations.
When we receive applications from organizations that want to be registered, we have to satisfy ourselves that they have exclusively charitable purposes and activities that will further those purposes. As part of that analysis, we have to assure ourselves that they will be delivering a public benefit. Those would be the main requirements to be a registered charity in Canada, to get in the door, as opposed to a non-profit organization. Oftentimes the two types of organizations are mistaken one for the other.
A non-profit organization is defined in the Income Tax Act as being a club, association, or society that is organized to carry out activities that relate to civic improvement, recreation, pleasure, etc., for any purpose other than profit. That is essentially the definition of a non-profit organization. They cannot have a profit purpose. They are limited in the kinds of activities they can undertake that generate some income, although it is not impossible, by any means.
The difference between the two in terms of obligations is that, first of all, charities are registered; NPOs are not. Charities have to file a public return that is made available to the public through our website; non-profit organizations do not.
Those are the kinds of distinctions between the two.
Our directorate is focused exclusively on registered charities. I don't deal with non-profit organizations.
:
In terms of an active consultation process, no. There's no advisory board of charitable organizations that meets with us on a regular basis, but as with many other government departments, we regularly meet with stakeholders.
I would say that over the years we meet with stakeholders in the sector to discuss various issues. Imagine Canada was mentioned. That's a stakeholder group we meet with fairly frequently in my department. It serves as an umbrella group and that facilitates quite an energetic discussion.
In other cases, we just meet with individual organizations that might have an idea they want to share with us about a program or an intervention that they think might work within the department's mandate.
In the area of social finance per se, there have been task forces. There was an ad hoc task force created out of MaRS in Toronto in 2010. Since then there has been a national advisory board to that G-8 Social Impact Investment Taskforce that I mentioned earlier. As well, it's ad hoc. It doesn't have any long-term standing, but it did publish a report. I think, given the representation that was on that national advisory board from across the country, it does serve as one voice. It's not a model, but it's one voice, and there are many others out there.
I think, as my colleagues would agree, part of our responsibilities is to be able to meet with stakeholder groups and hear what their ideas and their concerns are.
:
That is a good question.
We currently do not have a program with a social finance component.
There aren't any at my department, but there are some examples at the Public Health Agency of Canada. The Agency has worked on projects with organizations that had social finance dimensions.
I believe that Citizenship and Immigration Canada is going to start integrating social finance aspects into a few of its subsidy programs, but we haven't done that with our programs.
However, we have this pilot project I mentioned earlier. We may have more in the future. We currently do not have an education program on social finance.
Given that we have many programs in the social and labour market fields, we may launch some pilot projects, but we currently do not have any.
Thank you.