# 2025-062 Pay and Benefits, Canadian Armed Forces Relocation Directive, Additional Car Rental Costs, Destination Inspection Trip, Negligent Misrepresentation

Case summary

F&R Date: 2025-12-12

The grievor contended that funds were overspent from their Custom relocation account for the booking of their dependents' travel for a Destination Inspection Trip, resulting in no remaining funds to reimburse optional rental car insurance expenses later incurred. The grievor argued that Brookfield Global Relocation Services (BGRS) and American Express Global Business Travel (GBT) did not book the flights until two days before departure and that they had seen cheaper flights available online when they first submitted their booking request. As redress, the grievor sought reimbursement of the additional car rental insurance, as well as a policy change to allow Canadian Armed Forces (CAF) members more control over flight bookings

The Initial Authority (IA) found that BGRS had submitted a booking request to GBT within the seven-day prior to departure requirement stipulated in article 3.3.05 of the Canadian Armed Forces Relocation Directive (CAFRD) for the relocation provider to arrange travel. The IA acknowledged that while GBT did not issue the tickets until two days before travel, the IA found that BGRS administered the travel booking within the requirements of the policy.

The Committee found that “arranging travel” implies that travel is booked and paid for and that BGRS forwarding the booking request to GBT for later fulfillment did not constitute arranging the travel. The Committee concluded that the eventual booking of flights two days before departure did not meet the seven-day requirement of article 3.3.05 of the CAFRD. 

The Committee noted that flight costs generally increase closer to the departure date and that other policies such as the Canadian Forces Temporary Duty Travel Instructions prescribe that bookings must be booked as far in advance as possible presumably to reduce costs to the Crown. The Committee found that on a balance of probabilities, booking the flights within the seven-day requirement would have led to reduced costs and resultantly, funds available in the grievor's Custom account to have reimbursed the rental car insurance expenses. 

The Committee noted that the Final Authority had, in previous CAFRD-related decisions, taken the position that the CAF is not liable for negligent misrepresentation by BGRS. The Committee highlighted that using a third party to administer the CAFRD does not absolve the CAF of their responsibility to their members and that when BGRS fails to meet the contractual obligations of the CAFRD, it is the CAF who must hold them to account. The Committee stated that the Chief of the Defence Staff is charged with the control and administration of the CAF and remains ultimately responsible for the administration and execution of the CAFRD. 

The Committee recommended that grievor be afforded redress by compensation of the unreimbursed rental car insurance expenses.