Briefing binder created for the Deputy Minister of Finance on the occasion of his appearance before the Standing Committee on Public Accounts on December 9, 2024 on the Auditor General of Canada's report 8, entitled “Canada Emergency Business Account” - Annex C

EDC should work with Finance Canada to consider appropriate actions, including legal implications and options to recoup loan forgiveness from ineligible small businesses. EDC should then identify the full population of ineligible recipients in the non-deferrable expense stream.

The Department of Finance Canada's response. Agreed.

The Department agrees to work with EDC to consider appropriate follow-up actions, including examining legal implications and options to recoup loan forgiveness from ineligible recipients in the non-deferrable expense stream. This examination will also assess the options against cost-effectiveness considerations.

The final expected outcome is completion of a comprehensive analysis of appropriate follow-up actions. Recommendations resulting from the analysis will be given to the Minister.

March 31, 2025

• December 2024: Building on ongoing discussions on this topic, a working group of officials from Finance Canada and EDC will begin to examine the options and legal considerations of identifying the full body of ineligible recipients and conducting activities to recoup loan forgiveness, which will include legal assessment and full implementation analysis of potential options.
• March 2025: Recommendations on next steps to be provided by Finance Canada to Minister of Finance.

Finance Canada: Judith Hamel, Director General, Financial Services Division, *Information Redacted"

 Finance Canada should provide analysis to support the development of a complete plan, including spending limits, for all actions required to collect on defaulted loans through to the end of the CEBA program.

The Department of Finance Canada's response. Agreed.

The Department of Finance Canada has already provided analysis on the remaining relevant aspects of the CEBA program. The Department will work with Export Development Canada and the Canada Revenue Agency to identify any other gaps in the program plan, and accordingly provide advice, as necessary.

The final expected outcome is completion of a robust program plan through identifying and addressing any gaps or weaknesses. Through joint efforts, Finance Canada, EDC, and the CRA will assess areas such as resources, timelines, and deliverables and provide targeted advice and recommendations to resolve any issues.

June 30, 2025

• December 2024: Building on existing plans, as well as analysis already provided to the Minister of Finance, a working group of officials from EDC, GAC, and CRA will begin to identify gaps in the program plan, including spending limits.
• Spring 2025: The working group will present analysis on a set of recommendations to respective Deputy Heads. Organizations will provide analysis/recommendations to their Ministers, as appropriate. If some recommendations are more urgent or constitute pre-requisite, they will be provided earlier.

Finance Canada: Judith Hamel, Director General, Financial Services Division, *Information Redacted"

Finance Canada and GAC should clarify who has the lead for key program activities such as risk mitigation and overall program outcomes.

The Department of Finance Canada's response. Agreed. 

Finance Canada will work with Global Affairs Canada, in consultation with Export Development Canada and the Canada Revenue Agency, to develop a Memorandum of Understanding for CEBA, or similar document, that will define the roles and responsibilities of each implicated organization. Approval of the document will be sought from the Deputy Heads of all responsible organizations. 

The final expected outcome is completion of a clearly outlined, mutually agreed-upon document that establishes each entity's specific obligations, expectations, and contributions (i.e., roles and responsibilities).

March 31, 2025

• December 2024: Finance Canada and GAC will begin to draft a document that outlines roles and responsibilities, in consultation with EDC and CRA.
• February 2025: Draft will be presented to Deputy Heads, with formalization and signatures shortly thereafter.

Finance Canada: Judith Hamel, Director General, Financial Services Division, *Information Redacted"

In its role as policy lead, the Department of Finance Canada should address the accountability and oversight gaps for the CEBA program, including oversight of administrative expenditures on the CEBA program that are paid through the Canada Account.

The Department of Finance Canada's response. Disagreed. 

Finance Canada has no legislative authorities to provide oversight of administrative expenditures on the CEBA program. As the administration of the CEBA program was delegated to EDC, the Board of Directors of EDC is responsible for providing oversight of the administrative expenses of the CEBA program.

N/A – Finance Canada disagreed with this recommendation

N/A – Finance Canada disagreed with this recommendation

Although Finance Canada disagrees with this recommendation, we will continue to monitor administrative expenditures and explore whether improvements to reporting could be made. Joint work with GAC to clarify who has the lead for key program activities (as committed to above) will also contribute to address any potential accountability and oversight gaps for the CEBA program.

N/A – Finance Canada disagreed with this recommendation