Evaluation of the Immigration Loan Program - Management Response Action Plan

Recommendation #1:

It is recommended that CIC fully comply with the requirements for loans programs as stated in Treasury Board (TB) Directives. In particular, given the context of overseas refugee processing, compliance with TB Directives requires policy and/or procedural changes to ensure:

Adherence to the criteria established to assess ability to repay the loan; and
Procedures for signing the loan agreement are clear and obtain free and informed consent from the client, including communicating the amount to be borrowed.

Acknowledging that some refugees may not qualify for a loan given the requirements under the TB Directives, it is therefore also recommended that CIC ensure policies and corresponding measures are in place to support its humanitarian policy objectives and to facilitate the resettlement of all refugees who do not qualify for a loan.

Recommendation #2:

It is recommended that CIC make policy and/or procedural adjustments to its loan repayment requirements and collection practices to ensure that the loan program is aligned with CIC's resettlement, settlement and integration policy objectives and does not adversely affect the settlement outcomes of resettled refugees. In particular, CIC should consider:

Aligning the loan program policies with those of other refugee programming;
Aligning the start of the repayment with the receipt of the first loan statement;
Aligning the loan repayment schedule with the time needed to repay;
Ensuring the use of interest and interest relief are appropriate to the financial situation of the client;
Providing mechanisms to allow for debt forgiveness where necessary;
Providing easy access to information on how to contact CIC Collection Services and the types of assistance available for clients.

Response to recommendations #1 and #2:

CIC agrees with this recommendation.

The Immigration Loan Program supports Canada’s efforts to offer protection to the displaced and persecuted, and reflects the Department’s commitment to having newcomers and citizens participate in fostering an integrated society.

The Immigration Loan Program provides access to funding for persons who have few personal financial resources and are unable to access traditional lending institutions.

The primary client group for the Immigration Loan Program has changed considerably since the program was first introduced. Immigration loans have now become a de facto tool for ensuring that resettled refugees arrive in Canada.

As such, the Department is committed to ensuring that the provision of financial support to refugees selected for resettlement to Canada occurs within a program structure that recognizes and accommodates their often vulnerable circumstances (including financial need) both preceding and immediately following their arrival to Canada.

The Department is committed to ensuring that the financial support that is extended to resettled refugees not only allows them to come to Canada, but also supports their full participation in the economic, social and cultural life of Canada.

Under the Immigration Loan Program, loans are issued with full expectation of repayment of both principal and interest accrued. This is because immigration loans are issued from a capped statutory authority ($110M) from which future loans are issued. Consequently, loan repayment is required in order to replenish the authority and ensure that further loans can be issued from this authority.

Actions associated with response to recommendations #1 and #2:

CIC will develop a comprehensive array of policy options to address challenges with the Immigration Loan Program, ranging from operational changes to fundamental modifications to the program's design.

In doing so, CIC will consider:

the impact of loan repayment on resettled refugees' capacity to settle and integrate in Canada;
TB directives for issuance of loans;
the humanitarian objectives for which the assistance is provided;
the potential use of other arrangements or instruments to finance resettlement costs currently covered through the Immigration Loan Program; and
the financial priorities of the Government of Canada.

Accountability for actions related to recommendations #1 and #2:

Refugee Affairs Branch/Finance Branch

Consultation: Communications Branch, Finance Branch, International Region, Integration Program Management Branch, Integration-FCRO Branch, and Operational Management and Coordination

Completion date for actions related to recommendations #1 and #2:

End Q2 2016/17

Recommendation #3:

It is recommended that CIC explore how the Immigration Loan Program could better support the achievement of CIC’s settlement and integration policy objectives (i.e., that newcomers and citizens participate in fostering an integrated society), considering opportunities such as the expansion of the in-Canada assistance loan to improve labour market access for all newcomers, including refugees.

Response to recommendation #3:

CIC agrees with this recommendation.

The Department is committed to ensuring that its services and supports contribute to newcomer settlement and integration. Actions in response to Recommendation #3 must align with those pursued in response to Recommendations #1 and #2, and must not duplicate existing programming.

Actions associated with response to recommendation #3:

In line with the policy and/or procedural adjustments proposed in response to Recommendations #1 and #2, CIC will review current labour market related programming and financial supports available for immigrants (including what is provided by CIC and the Government of Canada), identify any gaps and opportunities, and develop policy options in order to effectively leverage the Immigration Loan Program. Such policy options will aim to address both the types of support the program provides, as well as the effective range of clients it serves.

In doing so, CIC will consider:

ways to build on-but not duplicate-existing settlement and resettlement assistance programming, in support of the Department's settlement and integration policy objectives;
specific ways in which the program could promote labour market attachment for a broader range of permanent residents, including refugees, in alignment with other Government of Canada programming; and
implications for both program funding and operations.

Accountability for actions related to recommendation #3:

Integration-FCRO Branch

Consultation: Refugee Affairs Branch, Integration Program Management Branch, and Finance Branch

Completion date for actions related to recommendation #3: