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B.C. Crown Corporation SNAFU: The UDI claims that BC Housing owes them money for an invoice that BC Housing can’t find. BC Housing also can’t figure out how it paid the UDI over a thousand dollars to “renew” a specific membership with the lobbying organization, when BC Housing claims it didn’t have that specific membership previously. The Office of the Information and Privacy Commissioner (OIPC) prefers to shut their eyes to the situation.

My investigation of this strange situation regarding what may have involved potential misappropriation public funds from a Provincial Crown Corporation by a private lobbying organization will continue.

By Sasha Izard
April 6, 2025

In a recent article, I showed how BC Housing claims records don’t exist regarding a previous membership in a lobbying organization, but at the same time estimates charging me over $1000 to find information about that membership.

Things have only gotten stranger since.

The following is part of recent surreal exchanges with the Office of the Information and Privacy Commissioner (OIPC) on the subject – to recap, this is the section of dialogue where the previous article had left off:

The OIPC had said:

I have attached an email thread provided from BC Housing. On page 17 a member of BC Housing states

“Based on our review of records, we believe that the receipt of payment does not exist because the membership renewal amount was not paid. BC Housing reached out to UDI who confirmed that they are awaiting payment for this renewal and that the invoice is still outstanding.”

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I replied:

Very simple logic here:

How could the UDI have been awaiting for a renewal payment, if what was being renewed didn’t exist previously?

Thank you,
Sasha

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After an awkward pause, the dialogue covered in the previous article continued from there:

The brief OIPC reply was as follows:

“Hi Sasha,

From my understanding of p-cards, that is correct.  Considering any new evidence, I will be drafting a findings letter for this matter. I will be sending it to both you and BC Housing by the end of the week.”

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The question about the lacking p-card data was another issue that we had discussed previously. They were responding in that sentence to my question about whether expiry dates were included in p-card data.

I replied:

Hi,

Before you do that, please answer the question that I asked, that you didn’t answer:

How could the UDI have been awaiting for a renewal payment, if what was being renewed didn’t exist previously?

Thank you,
Sasha

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Hi Sasha,

Apologies for missing this question. I reached out to BC Housing for a response and unfortunately, they could not provide an answer. BC Housing recommended you reach out directly to UDI for an answer to your question. I will be sending you my findings letter by the end of this week.

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Hi,

Thank you for your response.

You seem to be in a rush before solving this serious issue.  Please take your time and figure it out before compiling your findings.

If BC Housing does not know how they could have paid for a renewal for a membership that didn’t exist, then the UDI need to explain how they sent BC Housing a membership renewal invoice for a membership that didn’t exist, and answer why it is that they took BC Housing’s money for it.

In regards to BC Housing preferring that I ask the UDI the question, they must know perfectly well that as a member of the public, the UDI has no obligation to answer my question, and is unlikely to do so. 

On the other hand, the UDI, a private organization, has an obligation to respond to the government with an answer to why they issued the government a renewal invoice for a membership that did not exist, and they must answer why they took the money for it.

The only other possibility, would be that BC Housing destroyed records that they shouldn’t have destroyed, which would also be very serious.  Thus as the Office of the Information and Privacy Commissioner it is incumbent that you find the truth of the matter.

Thank you,
Sasha Izard

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I added:

I’d just like to make a point of clarification.  You previously mentioned: “BC Housing reached out to UDI who confirmed that they are awaiting payment for this renewal and that the invoice is still outstanding.”  

BC Housing did make a payment for the renewal of the UDI Capital Region Secondary Associate II membership for the most recent period (Nov 2, 2024-Nov 1, 2025).  The invoice and proof of payment for that is below.

Once again, the question remains, how did BC Housing pay for a renewal of a membership they did not have previously?

Also this deserves clarification: “the invoice is still outstanding.”  

If the invoice for the previous year’s (2023-2024) UDI Capital Region Secondary Associate II membership is still outstanding.  Where is that invoice?  Did the UDI present it to BC Housing, before saying BC Housing owes them money for it?  If so, where is it?  That invoice should have been provided in the FOI response.

Thank you again,
Sasha

This is the invoice followed by the proof of payment for it of BC Housing to the UDI for the Secondary Associate II Capital Region membership for the period Nov 2, 2024-Nov 1, 2025.  Note under “Payment Options” in the invoice is the word “renew” in the url.

One last bit of evidence about the most recent renewal having been paid for:  If to go to that url on the 2024-2025 invoice.  This is what it says:

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Without addressing the evidence of major accounting and narrative inconsistencies including seemingly missing documents from BC Housing and the UDI, the OIPC curtly responded:

Hi Sasha,

I hope you are doing well. Please see attached my findings letter for this adequate search complaint.

I have reviewed the materials you provided in your last three emails and believe I have addressed all relevant facts in this case. I also noted your request for me to contact UDI for information and records. However, I do not have the legal authority or jurisdiction to request information from UDI, as they fall under PIPPA.

This concludes my investigation, and I have now closed your file. By copy of this letter, I am advising BC Housing of the status of this file.

If you disagree with my decision, below are the avenues for a reconsideration. While there is no statutory obligation under FIPPA to reconsider a decision about whether a complaint has been properly decided, it is OIPC policy to review requests to reconsider a decision when there are reasonable grounds to do so. 

A decision may be reconsidered under the following circumstances:

·     When it is necessary to correct a clerical error, an accidental error or an omission by the investigator;

·     When the finding has resulted from a breach of natural justice or administrative fairness;

·     When relevant issues were not addressed or fully resolved; and

·     Where new evidence or facts are brought forward that were not previously available to the individual seeking the reconsideration.

Please send any reconsideration request to info@oipc.bc.ca. Please note, as I have outlined your avenue of appeal, I will not be responding to any more emails regarding this file.

Thank you,

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The OIPC did note in their findings letter that p-cards another ongoing issue that could resolve missing payment information, do not show expiry dates, and were thus out of my original search scope.

On the subject of the issue covered in this article, they responded in the letter:

“You also informed me that:

“It appears likely that there were other invoices and/or receipts related to the UDI Capital Region Associate II membership, as the FOI material reveals the membership was discussed and a renewal was being asked for, thus a previous UDI Cap Region Associate II membership should have existed. These also did not materialize.”

I spoke with a BC Housing representative regarding this matter, they advised our office that no receipts or invoices exist because no payment had been made. BC Housing also reached out to the Urban Development Institute (UDI) to confirm that no payment had been made. UDI confirmed this. You requested further clarification on this matter, and BC Housing advised you to reach out to UDI for additional information, as they did not have an answer to your question, and these records are not in the custody and control of BC Housing.

A public body must demonstrate to the OIPC that they conducted an adequate search under s. 6 of FIPPA. They are required to answer an investigator’s questions about the search. This may include providing an explanation as to why they did not locate certain records when a complainant can provide reasonable evidence that such records exist. If there is no reasonable evidence that certain records exist, the OIPC does not require the public body to explain why these records weren’t located in the search.

Conclusion

In summary and based on the above explanation, I am unable to substantiate your complaint. I am satisfied that BC Housing has conducted an adequate search for the records responsive to your access request.

This concludes my investigation, and I have now closed your file. By copy of this letter, I am advising BC Housing of the status of this file.

Sincerely,”

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[The reader can view my letter of reconsideration of the file to the OIPC in the Appendix at the end of this article.]

Conclusion:

So there the OIPC investigation had been ‘ended’ in a rush before the OIPC investigator would sort out the issue by finding the answers to the overwhelming inconsistencies in the data, and in regard to BC Housing and the UDI’s narratives about it, as I had pointed out.

BC Housing can’t find the invoice that the UDI says it owes it money over, and the OIPC/BC Housing won’t ask the UDI to show them the invoice. (Will BC Housing then have to pay the UDI interest over it in addition to the full cost?

Yet, BC Housing paid the UDI over a thousand dollars for a renewal of the most recent time period of that specific membership without having any evidence that it ever had that specific membership in the first place to renew. BC Housing claims it can’t figure out how this happened, and it has shown that it doesn’t want to find out how it happened, and neither does the OIPC.

Are we looking at a potential case of fraud, whereby the UDI gained money from BC Housing inappropriately through a fake “renewal” of a membership BC Housing didn’t previously have, and is in addition saying that BC Housing owes it even more money for a previous invoice BC Housing hasn’t been able to find?

Or has BC Housing potentially illegally destroyed, deleted, or omitted to provide records, which would would have otherwise corroborated statements from its own communications e.g. that such a membership last year was up for renewal?

The OIPC doesn’t seem to want to know the answers. It would rather slam the door shut before they can be found. Is the OIPC representing the public’s interest here? I don’t think so. Neither does it look like this is the case with BC Housing. Both entities appear to have done everything they can to sandbag revealing the answer, including BC Housing providing an estimate of over $1000 for what they would charge me to find information about this membership.

If they think sandbagging me is going to work, they should have learned by now that it isn’t. I will not as a member of the public, stop my investigation until I find the truth that should be 100% transparent from a public institution using public funds. They owe the public the truth about it including a proper and fulsome investigation of it that seeks to find the answers, instead of ignoring the key questions.

What does BC Housing and the OIPC have to hide? At any point in time BC Housing could pick up the phone and demand the UDI to explain why it claims BC Housing owes them money for an invoice BC Housing supposedly doesn’t have. It could also demand the UDI explain how BC Housing were led to paying over a thousand dollars to the lobbying organization to “renew” a specific membership BC Housing claims they didn’t previously have. Yet it doesn’t do that. Why?

My investigation of this strange situation regarding what may have involved potential misappropriation of public funds from a Provincial Crown Corporation by a private lobbying organization will continue.


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See also: BC Housing claims records don’t exist regarding a previous membership in a lobbying organization, but at the same time estimates charging me over $1000 to find information about that membership. – CRD Watch Homepage

Index of Crown Corporations and Statutory Entities that have acted evasively about their UDI memberships. – CRD Watch Homepage

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Appendix: Letter for reconsideration of the file, sent to the OIPC on April 6, 2025

Hello OIPC,

I am hereby submitting this file to your office for reconsideration based on the following:

 “When it is necessary to correct a clerical error, an accidental error or an omission by the investigator;”

1. The OIPC investigator omitted to determine why BC Housing had not found documents related to earlier Secondary Associate II memberships in the UDI Capital Region, despite that BC Housing paid for a renewal of this specific membership, the renewal covering the time period Nov 2, 2024 to Nov 1, 2025.  For a renewal to have taken place, a previous membership of that variety in the UDI Capital Region must have existed, and BC Housing in its own previous communication in 2024 as revealed by FOI, had mentioned that a payment would be a renewal of that specific membership. 

When asked how a renewal payment could have taken place without the previous membership having existed, BC Housing had no answer.  This suggests that documents may have been withheld or even inappropriately destroyed by BC Housing, yet the OIPC investigator simply accepted BC Housing not being able to answer that question without searching BC Housing’s system to see if relevant document(s) had been destroyed, deleted or withheld.

2. The investigator/BC Housing also omitted to determine how the UDI could claim that an invoice for that specific membership type is still outstanding, when no evidence of that invoice turned up in the FOI request.  This can only mean one of two things: a. that the UDI is saying BC Housing owes it money, when it does not (something that deserves an answer), or b. that the UDI issued BC Housing an invoice that BC Housing did not release in the FOI response.

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“When the finding has resulted from a breach of natural justice or administrative fairness;”

It was apparent from the communications that the OIPC “investigator” was determined to close the file as quickly as possible without answering a number of key questions regarding major inconsistencies in BC Housing’s and the UDI’s narrative, that suggest the strong likelihood of documents having been omitted from the FOI response, that were within its scope.  This in my view shows that the investigator was not providing due diligence to learn the truth of an important inquiry by a member of the public regarding payments made from BC Housing to a private organization, and considering of serious inconsistencies in the organization’s narrative and own communications around it.

“When relevant issues were not addressed or fully resolved;”

See the previous items above.

Conclusion:

This has 3 out of the 4 hallmarks of a decision that may be reconsidered under the type of circumstances mentioned by the OIPC investigator, and as such I ask that the OIPC provide due diligence to learn the truth of the matter, and get to the bottom of what really happened here, and whether or not relevant documents were either withheld or destroyed by BC Housing.

I look forward to a thorough and sincere investigation of this serious matter by the OIPC.

Thank you, 
Sasha Izard