Crown corporations and other reporting entities' letter of representation for the fiscal year ending March 31, 2021

3.3.1 Transmission of the letter of representation

You must jointly address the letter of representation to the Deputy Receiver General and to the Auditor General with the original sent by email to the addresses provided below:

Name:

c/o Yanick Patakioutas

Title:

Financial analyst

Organization:

Accounts of Canada and financial reporting
Public Accounts Section
Central and Public Accounts Reporting Directorate
Receiver General and Pension Branch
Public Services and Procurement Canada

Email:

tpsgc.cpccontrole-paccontrol.pwgsc@tpsgc-pwgsc.gc.ca

Name:

c/o Michael Walsh

Organization:

The Office of the Auditor General of Canada
Public Accounts Audit Central Team

Email:

ct.ec@oag-bvg.gc.ca

Letter of representation

We are providing this letter to the Deputy Receiver General for Canada and to the Auditor General of Canada in connection with the audit by the Auditor General of Canada of transactions and financial information for inclusion in the Public Accounts of Canada and in the audited consolidated financial statements of the Government of Canada.

We are responsible for the proper recording of financial information, and for the proper reporting of that information for inclusion in the Public Accounts of Canada and in the audited consolidated financial statements of the Government of Canada included therein, for the year ended March 31, 2021.

Certain representations in this letter are described as being limited to matters that are material. An item is considered material, regardless of its monetary value, if it is probable that its omission from or misstatement in the Public Accounts of Canada and in the audited consolidated financial statements of the Government of Canada would influence the decision of a reasonable person relying on the Public Accounts of Canada and on the audited consolidated financial statements of the Government of Canada.

We [enter the complete legal name of your organization in this space], hereinafter referred as the reporting organization, make the following representations to the best of our knowledge and belief, in respect to:

Representation number 1 (reported transactions)

All financial transactions of the reporting organization have been accurately reported to the Receiver General for recording in the accounts of Canada on forms CC-1 through CC-10^{Footnote 1} (and other plates in accordance with the Public Accounts of Canada instructions (page available on Government of Canada network only)^{Footnote 2}), as per the reporting instructions for Crown corporations and other reporting entities.

It is the responsibility of Crown corporations and other reporting entities to report details of transactions on CC forms (and other plates if applicable), in a timely and accurate manner for reporting in the Public Accounts of Canada. This includes the assets, liabilities, revenues and expenses of the reporting organization, as well as supplementary schedules or notes which are combined with the government's balances (or supplementary information) in the accounts of Canada and the Public Accounts of Canada.

Representation number 2 (books of accounts and records)

The reporting organization has maintained complete, proper, and accurate books of accounts and records, from which complete and accurate financial statements and supplementary reports and CC forms (and other plates if applicable), required for the Public Accounts of Canada, have been prepared. There are no material transactions during the year that have not been properly reflected in the accounts. The reporting organization has appropriately reconciled the books and records (for example, general ledger accounts) underlying the financial results to its related supporting information (for example, sub ledger or third party data). (We are a corporation with section 33 authority under the FAA, and further declare that all accounts representing transactions recorded in the Consolidated Revenue Fund (CRF) are reflected correctly and have been reconciled to those of the corporation^{Footnote 2}.).

All amounts recorded in subsidiary accounts in the reporting organization's accounting system must have been reconciled to the corporation's general ledger. In the case of Crown corporations which have been delegated payment authority under section 33 of the FAA, they further declare that all transactions recorded in the accounts of Canada are reflected correctly and have been reconciled to those of the reporting organization.

Section 131 of the Financial Administration Act requires Crown corporations to keep books, records and management control systems to enable the preparation of accurate financial statements. Any exceptions must be disclosed and detailed including amounts.

Representation number 3 (disclosure controls and procedures)

The reporting organization has maintained disclosure controls and procedures to provide reasonable assurance that material information relating to the reporting organization, including its consolidated subsidiaries, is made known to us by others within those entities.

Representation number 4 (internal control over financial reporting)

The reporting organization has designed, implemented and maintained internal control over financial reporting to provide reasonable assurance regarding the reliability of financial reporting and the preparation of the financial information for inclusion in the Public Accounts of Canada and in the audited consolidated financial statements of the Government of Canada. In addition, management has designed controls and procedures to provide reasonable assurance that material information relating to the reporting organization included in the CC forms is complete and accurate. The reporting organization has disclosed to you deficiencies in the operations of disclosure controls and procedures and internal controls over financial reporting that we are aware of as of March 31, 2021.

Representation number 5 (recording and reporting of financial information)

In the recording and reporting of financial information to be included in the accounts of Canada, the Public Accounts of Canada and other monthly and quarterly consolidated financial statements, the reporting organization has complied with:

1. the reporting instructions for Crown corporations and other reporting entities, significant accounting policies of the Government of Canada, if appropriate, as well as any other Treasury Board requirements (in other words, directives, circulars and regulations)
2. the FAA
3. all other legislation affecting the reporting organization (and accounts in the CRF^{Footnote 2})
4. in addition, the reporting organization's financial statements have been prepared in accordance with [include your reporting organization's financial reporting framework] (except for those accounts maintained in the CRF, for which all relevant accounting policies of the Government of Canada have been applied^{Footnote 2})
5. the consolidated Crown corporations and other entities that have adopted International Financial Reporting Standards (IFRS), have presented the information on the CC forms (and other plates, if applicable) in accordance with Canadian Public Sector Accounting Standards (PSAS) with the exception of those accounts and balances specifically excluded from this requirement, as noted in the reporting instructions for Crown corporations and other reporting entities^{Footnote 5}

The reporting organization must have complied with all relevant Receiver General and Treasury Board requirements, the Financial Administration Act (if applicable), and all legislation affecting the recording and reporting of financial information to be included in the accounts of Canada and reflected in the Public Accounts of Canada or other interim government financial reports.

All Crown corporations must comply with any and all requirements of the Receiver General, the Treasury Board and any relevant legislation, regarding the recording and reporting of their financial transactions. Subsection 131(4) of the Financial Administration Act explains how Treasury Board regulations may be developed to augment the corporation's use of Canadian generally accepted accounting principles (GAAP). Subsection 89(1) of the Financial Administration Act requires the Crown corporation to implement any and all directives from Order in Council.

The reporting organization must have complied with its financial reporting framework in the preparation of its financial statements except for accounts maintained in the Consolidated Revenue Fund (CRF) for which all relevant significant accounting policies of the Government of Canada have been applied:

• the reporting organization must comply with Canadian GAAP as detailed in the Chartered Professional Accountants of Canada Handbook (except for those accounts maintained in the CRF for which the government's significant accounting policies must apply)
  • details of non-compliance with Canadian GAAP must be disclosed and detailed in this paragraph
  • an example of such an exception might be the write-off of major capital assets to expense at the time of purchase
• Crown corporations exercising authority under section 33 of the FAA must comply with the accounting policies related to the financial transactions recorded in the accounts of Canada and the financial information reported to the Receiver General
  • exceptions must be disclosed and detailed in this paragraph
  • examples of such exceptions might be unrecorded payables at year-end, reporting of accrued liabilities as contingent liabilities, recording of contingent liabilities as payables, foreign currency transactions recorded at the time of payment in foreign currency and translated only at year-end

The consolidated Crown corporations and other entities which have adopted IFRS must present the information on the CC forms (and other plates, if applicable) in accordance with Canadian PSAS, with the exception of those accounts and balances specifically excluded from this requirement, as noted in the reporting instructions for Crown corporations and other reporting entities.

This latter representation applies only to those other government organizations, as defined within PSAS that have chosen to adopt IFRS for their external reporting. In accordance with the reporting instructions for Crown corporations and other reporting entities, these reporting organizations are required to prepare and submit their CC forms in accordance with PSAS. There are current exceptions to this requirement and these exceptions are detailed in the reporting instructions for Crown corporations and other reporting entities.Currently, this representation only applies to Canada Infrastructure Bank, Canadian Air Transport Security Authority, Canadian Broadcasting Corporation, Canadian Commercial Corporation, Canadian Dairy Commission, Defence Construction (1951) Limited, Federal Bridge Corporation Limited, International Development Research Centre and Via Rail Canada Inc.

Representation number 6 (contractual arrangements)

All contractual arrangements entered into by the reporting organization with third parties have been properly reflected in the accounting records and/or, where material (or potentially material), for inclusion in the Public Accounts of Canada and in the audited consolidated financial statements of the Government of Canada, have been disclosed to you. The reporting organization has complied with all aspects of contractual agreements that could have a material effect on the financial information in the event of non-compliance.

The reporting organization must disclose all contractual arrangements entered into with third parties. Crown corporations and other reporting entities must have complied with all aspects of contractual agreements that could have a material effect on the financial information in the event of non-compliance.

Representation number 7 (environmental liabilities)

Liabilities, contingencies and commitments related to environmental matters, including remediation of contaminated sites have been recognized and disclosed in accordance with [include your reporting organization's financial reporting framework]. We believe that such estimates are reasonable based on the available information. Remediation liabilities have been adequately reported on the appropriate CC forms as required by section 5.1 Assets, liabilities and equity of the reporting instructions for Crown corporations and other reporting entities which includes forms CC-1, CC-1a, CC-1b, and CC-1c (assets) and forms CC-2, CC-2a, CC-2b-1, CC-2b-2, CC-2b-3, CC-2b-4, CC-2b-5, CC-2c, CC-2d, CC-2d-1, CC-2d-2, CC-2e and CC-2f (liabilities and equity).

Obligations associated with future asset restoration have been estimated and recorded.

All Crown corporations and other reporting entities are required to report on contaminated sites in accordance with the reporting instructions for Crown corporations and other reporting entities. Enterprise Crown corporations and other government business enterprises should report their environmental liabilities on form CC-2 and related contingent liabilities on form CC-6a, while consolidated Crown corporations and other entities should use form CC-6b.

Representation number 8 (contingent assets and liabilities)

All known actual or possible litigation and claims, which existed at the (consolidated) statement of financial position date or exist now have been disclosed or have been reported to the Receiver General, on the appropriate CC forms (and plates I-11 and I-12, if applicable^{Footnote 2}) for disclosure in the Public Accounts of Canada. We believe that the amounts recorded reflect management's best estimates and that they will likely result in an asset or liability that can be reasonably estimated.

The reporting organization has no knowledge of any other lawsuits, tax claims or pending and threatened litigation, including possible claims, of any consequence or of any other contingent assets or liabilities of whatever nature.

The reporting organization must report all contingent assets and liabilities to the Receiver General for disclosure in the Public Accounts of Canada.

Crown corporations and other reporting entities are required to report contingent assets and liabilities in accordance with the reporting instructions for Crown corporations and other reporting entities. Contingent assets and liabilities can include guarantees, lawsuits, tax claims, and pending and threatened litigation. Contingent liabilities can also include contaminated sites (refer to representation number 7 above).

Crown corporations administering accounts for the Government should use plates I-11 and I-12 and consult plates I-11 and I-12: Contingent liabilities and contingent assets (page available on Government of Canada network only) of the Public Accounts of Canada instructions, for instructions on how to report contingent assets and liabilities for administered accounts.

Representation number 9 (letters of comfort)

Letters of comfort to financial institutions from the reporting organization have not been issued nor, to the best of our knowledge and belief, has the minister for the reporting organization issued such letters. Nor have any such letters been in force at any time during the year or during the period up to June 9, 2021.

Letters of comfort must not have been issued nor been in force at any time during the year or subsequent to the period up to June 9, 2021.

A letter of comfort is a guarantee by a Crown corporation or other reporting entity to a financial institution on behalf of another corporation, enterprise, person, association or other entity for a loan that may be issued in the future. The appropriate government minister may issue a similar letter on behalf of a Crown corporation or other reporting entities.

Representation number 10 (obligations related to capital leases, contractual obligations and details of borrowing transactions)

All obligations related to capital leases and contractual obligations as well as details of borrowing transactions have been reported to the Receiver General on the appropriate CC forms for disclosure in the Public Accounts of Canada in accordance with the reporting instructions for Crown corporations and other reporting entities.

Information regarding capital lease obligations and contractual obligations is required for disclosure in the Public Accounts of Canada. All Crown corporations and other reporting entities must comply with the requirements of the reporting instructions for Crown corporations and other reporting entities and report such amounts for disclosure in various notes to the audited consolidated financial statements of the Government. Cases of non-compliance must be reported and detailed.

All Crown corporations and other reporting entities are also required to submit details of borrowing transactions on form CC-6 during the year. Cases of non-compliance must be reported and detailed as per example below.

Representation number 11 (contractual rights)

All contractual rights have been reported to the Receiver General on the appropriate CC forms for disclosure in the Public Accounts of Canada in accordance with the reporting instructions for Crown corporations and other reporting entities.

Information regarding contractual rights is required for disclosure in the Public Accounts of Canada. All Crown corporations and other reporting entities must comply with the requirements of the reporting instructions for Crown corporations and other reporting entities and report such amounts for disclosure in various notes to the audited consolidated financial statements of the government. All Crown corporations and other reporting entities are required to submit details of contractual rights on form CC-6b-3 during the year. Cases of non-compliance must be reported and detailed.

Representation number 12 (insurance programs administered by agent Crown corporations)

The reporting organization has submitted to the Receiver General details of the insurance funds/provisions, including all underwriting statistics, results of operations, and supplementary information as required, on form CC-10.^{Footnote 1}

All financial transactions pertaining to insurance funds/provisions administered by Crown corporations and other reporting entities in accordance with the reporting instructions for Crown corporations and other reporting entities, must have been reported on form CC-10 to the Receiver General.

Crown corporations and other reporting entities operating insurance programs are required to report, on form CC-10, to the Receiver General, underwriting statistics (in other words, the amount of insurance in force, the amount of net claims paid in the year, average net claims for the past 60 months (5 years) and the revenues, expenses and net income or loss for the fund/provision). In addition, the reporting organization should describe all facts that provide an assessment of the accuracy of the fund/provision, plus other factors that have a material effect on the fund/provision in notes to the above data.

Representation number 13 (financial records/minute books)

The reporting organization has made available to the external auditor: All financial records and related data, summations of meetings, and minute books which contain complete and authentic minutes of all meetings of the management committee and internal audit committee and [specify other management level committees as appropriate] applicable to the period April 1, 2020 to June 9, 2021 (or date of Separate Opinion Audit report if no audit work was performed by the external auditor on the CC forms). The most recent meetings of these committees for the said period on and respectively.

Crown corporations and other reporting entities must have made all financial records and related data, records of decisions of meetings, and minute books available to the organization's external auditor.

Canadian Auditing Standards (CAS) include the practice of reviewing the formal minutes, informal notes or records of decisions of the meetings of management level committees. The requirement to produce minutes of the management-type committee meetings could provide the corporation's auditor with information that could have an effect on their opinion regarding the financial statements. In terms of Crown corporations, subsection 144(1) of the Financial Administration Act details the access to corporation records by the external auditor.

Representation number 14 (cash)

The books and records properly reflect and record all transactions affecting cash funds, and bank accounts of the reporting organization.

All cash and cash equivalents of the reporting entity are included in the CC forms.

Arrangements with financial institutions involving compensating balances or other arrangements on cash balances or lines of credit or similar arrangements have been properly disclosed.

Representation number 15 (receivables)

Receivables represent valid claims against debtors for transactions arising on or before March 31, 2021 and have been appropriately reduced to their estimated net realizable value. All uncollectible accounts have been properly disclosed and deletions properly authorized. The reporting organization has taken appropriate action to collect all monies owed to the organization (and to Her Majesty in Right of Canada, in which latter case, monies collected have been promptly deposited to the credit of the Receiver General for Canada^{Footnote 2}).

Crown corporations and other reporting entities must maintain receivable records and establish rules and procedures to record an appropriate allowance to reflect amounts where collection is in doubt.

Receivables represent valid claims against debtors and exceptions must be disclosed and detailed in this paragraph. In addition, the reporting organization has recorded an appropriate allowance to reflect amounts where collection is in doubt and has properly authorized deletions of receivables.

Representation number 16 (loans receivable)

Loans receivable represent bona fide claims against debtors as at March 31, 2021. Balances have been properly adjusted to reflect any concessionary terms of the agreement. These loans are subject to the ordinary terms of credit of the reporting organization. An allowance for credit losses has been made where appropriate.

Loans receivable represent valid claims against debtors and these loans are usually subject to the ordinary terms of credit of the reporting organization.

Representation number 17 (inventories, tangible capital assets and prepayments)

The reporting organization (and Her Majesty in Right of Canada^{Footnote 2}) has (have) satisfactory title to all recorded assets, essential records have been properly maintained and the rules and procedures applied are sufficient to safeguard and control them. In particular:

1. inventories are valued at cost and cost has been determined on a basis consistent with the prior year
   • inventories which are slow moving, obsolete, or unusable, or which otherwise no longer have service potential, are valued at the lower of cost or net realizable value
   • items for which the costs are not readily available, have been valued using management's best estimate of original cost based on available information
2. records respecting tangible capital assets for which the reporting organization is responsible are accurate and complete, and all acquisitions and disposals of tangible capital assets during the year have been properly authorized
3. all charges to tangible capital assets and additions under capital leases during the year represent the actual cost of the additions and no expenditures of a capital nature have been charged to expense during the year
   • book values of significant tangible capital assets no longer in use have been disclosed as surplus assets
4. tangible capital assets are appropriately recorded at cost, based on the best information available
5. book values of significant tangible capital assets sold, destroyed, abandoned, or otherwise disposed of, have been eliminated from the accounts
6. (choose one of the following):
   • [There have been no events or changes in circumstances that indicate that the carrying values of tangible capital assets are not recoverable.]
   • [During the year, we noted conditions indicating that a tangible capital asset no longer contributed to the reporting organization's ability to provide goods and services, or that the value of the future economic benefits associated with the tangible capital asset was less than its net book value
     • accordingly, the cost of the tangible capital asset was reduced by $[amount] to reflect the decline in the asset's value, and the resulting write-down has been recorded as an expense in the year, in accordance with [include your reporting organization's financial reporting framework].]
7. tangible capital assets with a limited life are being amortized over management's estimation of their useful lives in a systematic and rational manner or otherwise written off as a charge to expense
8. amortization methods and estimates of useful lives of the remaining unamortized portion of tangible capital assets have been reviewed on a regular basis and revised as appropriate
9. prepaid expenses represent amounts paid for services to be rendered in future periods
10. all lease agreements covering assets leased by the reporting entity have been disclosed in the CC forms and have been classified as capital leases or operating leases
11. all unrecognized assets and intangible assets have been appropriately disclosed in the CC forms

Crown corporations and other reporting entities must have legal title to these assets, maintain essential records and establish rules and procedures to safeguard and control these assets.

Representation number 18 (inventory quantities)

Inventory quantities at March 31, 2021 were determined from the reporting organization's perpetual inventory records, which have been adjusted on the basis of physical inventories taken by competent employees at various times during the year. The inventory balances do not include goods on consignment from others.

There have been no events, conditions, or changes in circumstances that indicate inventory held for consumption will no longer be used or consumed in the reporting organization's operations.

Representation number 19 (liens and encumbrances)

There were no liens or encumbrances on the reporting entity's assets or assets pledged as collateral.

Representation number 20 (liabilities and provisions)

We have recorded or disclosed, as appropriate, all liabilities and provisions on the appropriate CC forms.

The reporting organization must record or disclose, as appropriate, all liabilities and provisions on the appropriate CC forms.

Representation number 21 (pension and other employee future benefits)

Pension and other employee future benefit costs and obligations and the related assets have been measured, accounted for and disclosed on the appropriate CC forms in accordance with the reporting instructions for Crown corporations and other reporting entities and represent management's best estimate of the respective liabilities and expenses of the pension and other employee future benefits.

More specifically:

1. all pension and other employee future benefits of the reporting organization and the provisions of each plan have been fully disclosed to you and have been actuarially valued or estimated, as applicable
2. we have adequately considered the qualifications of the actuary
   • we did not give or cause any instructions to be given to the actuary with respect to the values or amounts derived in an attempt to bias their work, and we are not otherwise aware of any matters that have had an impact on the independence or objectivity of the actuary
3. the details of all plan amendments up to March 31, 2021 have also been identified
4. the source data used in the preparation of the actuarial present value of accrued pension benefits attributed to services rendered up to March 31, 2021 is complete and accurate
5. (choose the representation that applies to your organization):
   • for enterprise Crown corporations: The actuarial obligations for pension and other future benefits at March 31, 2021 have been determined in accordance with IFRS
   • for consolidated Crown corporations and other entities that adopted PSAS: The actuarial obligations for pension and other future benefits at March 31, 2021 have been determined in accordance with PSAS
   • for consolidated Crown corporations and other entities that adopted IFRS: The actuarial obligations for funded pension plans reported in the CC forms at March 31, 2021 have been determined in accordance with PSAS
   • [The actuarial obligations for unfunded pension plans and other employee future benefits reported in the CC forms at March 31, 2021 have been determined in accordance with [include the appropriate financial reporting framework].]
6. all assumptions used in the determination of the actuarial present value of accrued pension benefits attributed to services rendered up to March 31, 2021 are our best estimate of the most likely set of conditions affecting future events
   • these assumptions are appropriate, internally consistent, and are consistent with the asset valuation method
7. the assumptions included in the actuarial valuation are those that management instructed [name actuary] to use in computing amounts to be used by management in determining benefits costs and obligations and in making required disclosures in the [consolidated] financial statements, in accordance with the reporting instructions for Crown corporations and other reporting entities
8. the actuarial valuations for accounting purposes incorporate management's best estimates
   • the actuarial assumptions and methods used to measure obligations and costs for pensions and other employee future benefits are appropriate in the circumstances
9. in arriving at these assumptions, management has obtained advice of [consulting actuary who assisted in reaching best estimates], but has retained the final responsibility for them
10. the extrapolation of the actuarial present value of accrued pension benefits to March 31, 2021 from the date of the most recent actuarial valuations at March 31, 20XX has been properly prepared using source data which is complete and accurate
    • all assumptions used in the preparation of the extrapolation are consistent with the assumptions used in the preparation of such valuations, and events occurring in the extrapolation period that materially affect the actuarial present value of accrued pension benefits attributed to services rendered up to March 31, 2021 have been properly reflected in the determination of those accrued benefits
11. no events have occurred subsequent to March 31, 2021 that materially affect the amount of the actuarial present value of accrued pension benefits attributed to services rendered up to March 31, 2021
12. all plan assets have been disclosed on the appropriate CC forms
13. the reporting organization has good title to such assets
14. the pension plan assets are valued in accordance with [include the appropriate financial reporting framework]
15. (choose the representation that applies to your organization):
    • for enterprise Crown corporations: Adjustments arising from changes in assumptions and experience gains and losses and adjustments arising from plan amendments have been recognized in accordance with IFRS
    • for consolidated Crown corporations and other entities that adopted PSAS: Adjustments arising from changes in assumptions and experience gains and losses and adjustments arising from plan amendments have been recognized in accordance with PSAS
    • for consolidated Crown corporations and other entities that adopted IFRS: Adjustments arising from changes in assumptions and experience gains and losses and adjustments arising from plan amendments have been recognized in accordance with (PSAS or the requirements of the reporting instructions for Crown corporations and other reporting entities)

Representation number 22 (deferred revenue)

Representation number 23 (plans and intentions)

We have no plans or intentions that may materially alter the carrying value or classification of assets and liabilities reported to you on the CC forms (for example, to dispose of the business or to cease operations).

Representation number 24 (investments)

All securities and other financial assets that are controlled by the reporting organization were reported in the CC forms.

All income earned for the year on investments has been recorded in the accounts.

We are not aware of any objective evidence of impairment that would result in the recognition of an impairment loss on any investment.

Representation number 25 (expenses)

All expenses for the year have been recorded in the accounts.

Representation number 26 (non-monetary transactions)

All non-monetary transactions have been recorded and disclosed in the financial information in accordance with [include the appropriate financial reporting framework].

Representation number 27 (subsequent events)

Since March 31, 2021 (or date of last audit) to the date of this letter, there have not been any events, new or amended legislation, regulations or directives, other than those reflected in the financial statements or notes thereto, which should be reflected or disclosed in the audited consolidated financial statements of the Government of Canada or supplementary reports of the Government of Canada.

In addition, we acknowledge our responsibility to refer any subsequent events of substance ($50 million or more) identified after the date of this letter to Treasury Board Secretariat for guidance and to the Receiver General for submitting an updated letter of representation until the completion of the consolidated financial statements of the Government of Canada expected to occur on October 8, 2021 as well as up to the date they are tabled in the House of Commons.

No events, new or amended legislation, regulations or directives have come into effect since the fiscal year-end other than those described in this representation, which should be reflected or disclosed in the audited consolidated financial statements of the Government of Canada or supplementary reports of the Government of Canada.

Crown corporations and other reporting entities must disclose known events, legislation, regulations or directives, which have come into effect between the fiscal year-end and the effective date (June 9) of the representations. Subsequent events are defined as events providing further evidence of financial conditions which existed at March 31 or events which are indicative of conditions which arose subsequent to March 31. Exceptions must be disclosed and detailed in this paragraph. Examples of exceptions might be: Royal Assent given to legislation since March 31, final payment in respect of breach of contract which was reported as threatened litigation at March 31.

Events of substance identified after June 9, 2021, which have a bearing on the fiscal year ending March 31, 2021, should be referred to the Treasury Board Secretariat (TBS) for guidance on how to process and to the Receiver General for submitting an updated letter of representation.

Representation number 28 (consolidated financial statements of the Government of Canada)

The reporting organization is not aware of any information that was not disclosed to the Receiver General and to the external auditor, which could affect the consolidated financial statements of the Government of Canada or the Auditor General's opinion on them.

All known information that could have an effect on the Auditor General's opinion on the consolidated financial statements of the Government of Canada must be disclosed in the letter of representation.

Any information pertaining to a subject not specifically covered in a paragraph of the letter of representation, which could affect the consolidated financial statements of the Government of Canada, must be disclosed. Known information that has an effect on the financial information submitted by a Crown corporation or other reporting entity is considered as having an effect on the consolidated financial statements of the Government of Canada.

If there are any exceptions, the following details are required:

• clear and concise description of the item or items
• particulars, including dollar amounts, which may materially affect the consolidated financial statements of the Government of Canada

Representation number 29 (internal controls)

The reporting organization understands that the prevention and detection of error and fraud are primarily its responsibility and may not necessarily be detected by the external auditor, even if they are material in amount.

The reporting organization also acknowledges its responsibility to design, implement and maintain internal controls that are designed to prevent and detect fraud and error.

Furthermore, we have disclosed to the Receiver General and to the Auditor General the results of our assessment of the risk that the financial records may be materially misstated as a result of fraud, and have determined such risk to be (low, moderate, high).

Choose one of the following:

• [The reporting organization has no knowledge of any frauds or suspected frauds involving management, employees who have significant roles in internal control or others where the fraud could have a non-trivial effect on the financial records of the organization.]
• [We are is aware of instance(s) of fraud or suspected fraud involving management, employees who have significant roles in internal control or others, where the fraud could have a significant effect on the financial information of the reporting organization (provide details).]

Choose one of the following:

• [The reporting organization has no knowledge of any allegations of fraud or suspected fraud affecting the financial records that was communicated by employees, former employees, analysts, regulators or others.]
• [The reporting organization has disclosed below all information relating to any allegations of fraud or suspected fraud affecting the financial records that was communicated by employees, former employees, analysts, regulators or others (provide details).]

The reporting organization must assess the risk of misstatement due to fraud or error as low, moderate or high. In addition, it must provide representations related to known or suspected fraud as well as any allegations of fraud or suspected fraud.

All significant facts relating to any frauds or suspected frauds must be disclosed to the Receiver General and Office of the Auditor General. Internal controls must be in place and properly followed to prevent and detect any fraud and error.

If there are any exceptions, the following details are required:

• clear and concise details of non-compliance of internal controls
• clear and concise description of any frauds or suspected frauds
• particulars, including dollar amounts, which may materially affect the consolidated financial statements of the Government of Canada

Representation number 30 (compliance with laws and regulations)

The reporting organization has disclosed to the Receiver General and to the Auditor General all known or suspected instances of non-compliance with laws and regulations whose effect should be considered when preparing financial information.

Representation number 31 (legality of transactions)

The reporting organization is not aware of any of the following:

1. any illegal or possibly illegal acts, including those committed by directors, officers or employees acting on the reporting organization's behalf
   • we have identified and disclosed to you all facts related to illegal or possibly illegal acts
2. any conflicts of interest involving (name of organization) where it has directly or indirectly, entered into any purchase, sale or any other transaction with a member of Parliament, a member of the Board, a member of senior management, a manager, or with an organization in which one of these persons had a direct or indirect interest
3. bribes, or improper benefits rendered or accepted
4. influences applied improperly
5. business inconsistent with the Corporation's charter
6. loss of money or property as a result of defalcation, fraudulent acts or omission of corporate officer
7. any irregularities involving management or employees who have significant roles in the system of internal controls or any irregularities involving other employees that could have a material effect on the financial statements
8. any communications from regulatory agencies concerning non-compliance with laws or regulations which could have a material effect on the information for inclusion in the Public Accounts of Canada

The reporting organization must declare that it is aware of any illegal acts, violations to laws, regulations and contractual agreements, of any conflicts of interest involving (name of organization) or any other actions where it has, directly or indirectly entered into a transaction with a person that has a direct or indirect interest.

Representation number 32 (transactions with related parties)

We have not identified any related party transactions which require disclosure as per the Chartered Professional Accountants of Canada (CPA) Public Sector Accounting Handbook, section PS 2200, Related party disclosures [except as disclosed on form CC-9: Related party transactions].

The identity and relationship of related parties as well as balances and transactions with related parties are appropriately disclosed in the CC forms.

Representation number 33 (guarantees)

Choose one of the following:

• [No guarantees have been made by the reporting organization, nor have any guarantees been in force at any time during the year or subsequently.]
• [All guarantees potentially having a material impact on the financial statements have been recorded and disclosed as appropriate on the CC forms as provided to you for audit.]

All guarantees potentially having a material impact on the financial statements must be recorded and disclosed on the appropriate CC forms.

Representation number 34 (Appropriation Acts and other governing statutes)

The reporting organization has adhered to all legislative requirements respecting the entering into of financial transactions, including those pertaining to accounts payable at year-end, and all such transactions have been accurately recorded in accordance with, and as appropriate, within the authorized limits of Appropriation Acts and other governing statutes.

All financial transactions must be in accordance with legislative requirements, including those pertaining to accounts payable at year-end and must have been recorded in accordance with, and as appropriate, within the authorized limits of Appropriation Acts and other governing statutes.

Reporting Crown corporations exercising section 33 of the FAA authority must comply with the FAA, the Interpretation Act and the Criminal Code of Canada. They must specifically comply with the Treasury Board policies and Treasury Board Secretariat publications. Reporting organizations must specifically comply with the Public Accounts of Canada instructions, section 1. Ministry summary (page available on Government of Canada network only), in order to disclose overexpended amounts in form A: Summary of Source and Disposition of Authorities. Overexpended balances as at fiscal year-end, relating to budgetary and non-budgetary appropriations, must be disclosed and detailed in this paragraph by all reporting organizations.

Representation number 35 (specified purpose accounts, other liabilities and unmatured debt)

All specified purpose accounts, other liabilities and unmatured debt:

1. originated under the authority of appropriate legislation
2. represent financial obligations to organizations and individuals outside the Government of Canada as an accounting entity

All specified purpose accounts, other liabilities and unmatured debt must have originated under the authority of appropriate legislation.

Those Crown corporations exercising authority under section 33 of the FAA must make representations for the transactions which are recorded as the government's liabilities in the accounts of Canada. They must also make representations for the financial information submitted to the Receiver General, not just for the amounts disclosed in their respective financial statements or records. Exceptions must be disclosed and detailed in this paragraph. An exception would be the reporting as payables, of explicit guarantees which are contingent liabilities.

All specified purpose accounts, other liabilities and unmatured debt must represent financial obligations to organizations and individuals outside the Government of Canada as an accounting entity.

Government reporting entities must report the relevant financial information for disclosure in the "Statement of Financial Position" according to the above requirement and to the requirements of the Public Accounts of Canada instructions (page available on Government of Canada network only), section 1. Pre-drafted forms (objects) and texts on financial asset and liability accounts (page available on Government of Canada network only). Exceptions must be disclosed and detailed in this paragraph.

Representation number 36 (accounts payable)

All unpaid accounts relating to annually lapsing and non-lapsing budgetary appropriations and annually lapsing non-budgetary appropriations on which Parliament has imposed an annual ceiling have been recorded as payables.

Crown corporations exercising authority under section 33 of the FAA must disclose payables as required by subsection 37.1(1) of the Financial Administration Act and by the Treasury Board's Directive on Accounting Standards. They must charge against their appropriations those liabilities which meet the criteria established in the policy. They must also comply with the procedures described in the year-end timetable and procedures, appendix 1: Old year Departmental financial and materiel management system accrual entries, adjusting entries and closing of old year accounts (page available on Government of Canada network only) and the disclosure instructions of the Public Accounts of Canada instructions (page available on Government of Canada network only), instructions related to Volume II of the Public Accounts of Canada (page available on Government of Canada network only).

Furthermore, the Canada Mortgage and Housing Corporation administers programs for the Government, which, at least in part, allow use of the CRF. Therefore, it is required to record its liabilities at year-end in accordance with the criteria established above. Exceptions must be disclosed and detailed in this paragraph. Examples of exceptions would be: consultant fees owing but not recorded as accounts payable; amount owing to a Crown corporation pursuant to a contractual agreement not recorded at fiscal year-end.

Representation number 37 (derivative financial instruments)

The reporting organization has engaged in activities involving derivative financial instruments during the year. Management's objectives with respect to derivative financial instruments are: [list management objectives here]. The financial records reflect all transactions involving derivative financial instruments, all embedded derivative financial instruments have been identified and the assumptions and methodologies used in the valuation models applied to derivative financial instruments are reasonable. The terms of transactions involving derivative financial instruments include: [list terms here]. All transactions involving derivative financial instruments have been conducted at arm's length and at fair values. The reporting organization has not entered into any side agreements associated with any derivative financial instruments (except for, [state exceptions, if any]). The reporting organization has not entered into any written options (except for, [state exceptions, if any]). The reporting organization has complied with the documentation requirements required under [include the appropriate financial reporting framework] for hedge accounting, if applicable.

The reporting organization must report all activities involving derivative financial instruments.

Representation number 38 (significant assumptions)

The reporting organization is responsible for significant estimates and judgments related to the financial information for inclusion in the Public Accounts of Canadaand in the audited consolidated financial statements of the Government of Canada. Significant estimates and judgments made have taken into account all relevant information of which we are aware. The methods underlying data, and significant assumptions used in developing accounting estimates and the related disclosures are reasonable and appropriate to achieve recognition, measurement, or disclosure in the CC forms. The methods used in developing accounting estimates have been consistently applied in the periods presented and the data used in developing accounting estimates is accurate and complete. Accounting estimates and judgements appropriately reflect our management’s intent and ability to carry out specific courses of action, where relevant. Disclosures related to accounting estimates are complete and reasonable based on the applicable requirements of [include the appropriate financial reporting framework], and appropriately disclosed in the CC forms.

Significant assumptions used by the reporting organization in making accounting estimates, including fair value accounting estimates, must be reasonable and consistently applied.

Representation number 39 (fair value measurement)

For recorded or disclosed amounts in the financial information that incorporate fair value measurements, we confirm that:

1. the measurement methods are appropriate and consistently applied
2. the significant assumptions used in determining fair value measurements represent the best estimates, are reasonable and have been consistently applied
3. no subsequent event requires adjustment to the accounting estimates and disclosures included in the financial information
4. the significant assumptions used in determining fair value measurements are consistent with the reporting organization's planned courses of action
   • we have no plans or intentions that have not been disclosed to you, which may materially affect the recorded or disclosed fair values of assets or liabilities
5. disclosures of significant assumptions are complete and appropriate under the stated accounting policies of the reporting organization
   • significant estimates and measurement uncertainties known to management have been appropriately disclosed

For recorded or disclosed amounts in the financial information that incorporate fair value measurements, measurement methods should be appropriate and consistently applied; significant assumptions used in determining fair value measurements must represent your best estimates, be reasonable and be consistently applied; no subsequent event requiring adjustment to the accounting estimates and disclosures should be included in the financial information; and significant assumptions used in determining fair value measurements must be consistent with the reporting organization's planned courses of action. There should be no plans or intentions that have not been disclosed to us, which may materially affect the recorded or disclosed fair values of assets or liabilities; and disclosures of significant assumptions should be complete and appropriate under the stated accounting policies of the reporting organization. Significant estimates and measurement uncertainties known to management must be appropriately disclosed.

Representation number 40 (disclosing fair values)

Complete and appropriate disclosures required related to fair values have been reported to the Receiver General on the appropriate CC forms.

The reporting organization must disclose the measurement methods related to determining fair values.

Representation number 41 (accounting principles and policies)

The accounting principles and policies followed throughout the year were consistent with the previous year's practices.

Representation number 42 (classification)

All amounts have been appropriately classified within the CC forms.

Representation number 43 (Covid-19)

We have assessed the impact of the Covid-19 pandemic on the reporting organization’s internal controls over financial reporting and amounts recognized and/or disclosed in the consolidated statements. We have not identified deficiencies in the operation of the reporting organization’s internal controls over financial reporting as a result of the Covid-19 pandemic which could have a material impact on the government’s consolidated financial statements. In addition, the carrying value of assets and liabilities and total of all expenses and obligations incurred as part of the government’s Covid-19 economic response plan have been accounted for and disclosed in accordance with the appropriate financial reporting framework. We have also appropriately reflected the impacts on key assumptions for establishing estimates and disclosed all material uncertainties. We also confirm that these transactions have been in accordance with legislative and other required authorities.

On behalf of the reporting organization referred to on the first page.

Enterprise Crown corporations

• Atlantic Pilotage Authority
• Bank of Canada
• Business Development Bank of Canada
• Canada Deposit Insurance Corporation
• Canada Development Investment Corporation
• Canada Lands Company Limited
• Canada Mortgage and Housing Corporation
• Canada Post Corporation
• Export Development Canada
• Farm Credit Canada
• Freshwater Fish Marketing Corporation
• Great Lakes Pilotage Authority
• Laurentian Pilotage Authority
• Pacific Pilotage Authority
• Ridley Terminals Inc.
• Royal Canadian Mint

Other consolidated entities

• Canada Enterprise Emergency Funding Corporation
• Canada Foundation for Innovation
• Canada Foundation for Sustainable Development Technology
• Canada Pension Plan Investment Board^{Footnote 4}
• First Nations Market Housing Funds
• Public Sector Pension Investment Board^{Footnote 4}
• St.-Lawrence Seaway Management Corporation

Other government business enterprises

• Belledune Port Authority
• Halifax Port Authority
• Hamilton-Oshawa Port Authority
• Montreal Port Authority
• Nanaimo Port Authority
• Port Alberni Port Authority
• Prince Rupert Port Authority
• Quebec Port Authority
• Saguenay Port Authority
• Saint John Port Authority
• Sept-Iles Port Authority
• St. John's Port Authority
• Thunder Bay Port Authority
• Toronto Port Authority
• Trois-Rivières Port Authority
• Vancouver Fraser Port Authority
• Windsor Port Authority