We often assist clients to apply for charitable registration. We also talk to our colleagues from other firms who do similar work. As a result, we have good knowledge of the charitable registration process.

We are therefore pleased to report that the time elapsing between a new application being submitted and registration being granted has improved dramatically in recent months. In 2008 and early 2009 it was taking 6-8 months before an application file was even being assigned to a CRA examiner. However, recent simple applications have been registered in as little as two months after application filing. The Charities Directorate is to be commended for improving the timeliness of its handling of new application files.

At the same time, CRA is working diligently to process its older files. Unfortunately, in some cases it is working diligently by turning applications down (thereby closing the file as far as the Charities Directorate is concerned) rather than seeking further information. This is particularly frustrating given that the level of detail expected by (and indeed the approach taken by) individual examiners varies significantly. We have seen this approach of refusing registration most often in the context of applicant charities seeking to carry out their charitable activities abroad.

While the initial refusal to register can usually be fixed by filing an objection, the objection process is very slow and adds another layer of cost to the process.