Capital Assets Guide Chapter 2: Jordan's Principle

Update

An updated PDF version of the Capital Assets Guide is now available by email request and will be published online in the coming months. Please note that until web updates have been completed, some information below may be outdated. To request the most up-to-date version of the guide, please email chrt41-tcdp41@sac-isc.gc.ca.

On this page:

  1. Scope
  2. Objective and principles
  3. Eligibility
  4. Requirements for construction projects
  5. Funding request and assessment process
  6. Documents to support capital funding request
  7. Service standards and key dates
  8. Escalation and appeals process
  9. Funding agreement and payment process
  10. Reporting requirements
  11. Operations and maintenance
  12. Repayable contributions
  13. Contact information

1. Scope

This chapter was written to support the implementation of the Canadian Human Rights Tribunal (CHRT) orders related to capital projects to support the delivery of Jordan's Principle Services (i.e., 2021 CHRT 41) orders. It provides First Nations and First Nations-authorized service providers with guidance on how to request and access capital funding to provide safe, accessible, confidential, and culturally- and age-appropriate spaces that are needed to support the delivery of Jordan's Principle services to First Nations children. Capital funding includes funding for the purchase, construction or renovation of capital assets and funding for needs assessments and feasibility studies to support capital assets.

The guidance in this chapter may evolve over time to align with changes to Jordan's Principle as part of its long-term reform. Any changes will be communicated to First Nations and First Nations-authorized service providers in advance. Regardless of the changes made to this Capital Assets Guide, capital funding requests determined to be eligible prior to any changes will continue to be eligible. Funding commitments for projects underway will not be terminated due to any policy changes. Depending on the nature of the changes, funding requestors can resubmit any previously denied capital funding requests that may have become eligible as a result of the changes.

This Capital Assets Guide should be read with the 2021 CHRT 41 orders and the terms and conditions outlined in the funding agreement. If there are material differences between the 2021 CHRT 41 orders and ISC's terms and conditions and/or your funding agreement and/or this guide and/or any other policy or practices related to the 2021 CHRT 41 orders, the orders will prevail.

2. Objective and principles

The approach for implementing 2021 CHRT 41, was designed to enable First Nations and First Nations-authorized service providers with access to capital funding in a way that is streamlined and timely, addresses actual needs, and minimizes administrative burden.

ISC will apply the following principles when assessing the eligibility of requests for funding to purchase, construct or renovate capital assets, or requests for pre-capital planning of capital assets to support the delivery of Jordan's Principle services to First Nations children:

3. Eligibility

3.1 Eligible funding requestors

  • First Nations and First Nations-authorized service providers supporting the delivery of Jordan's Principle services to First Nations children who live on-reserve in a province; anywhere in the Northwest Territories; or anywhere in the Yukon.
  • In addition, funding applications to carry out a capital needs assessment or a feasibility study can be made by First Nations or First Nations-authorized service providers that deliver Jordan's Principle services to First Nations children who live on or off-reserve, anywhere in Canada.

3.2 Eligible activities

Where possible, Jordan's Principle will use existing departmental capital program terms and conditions to implement the 2021 CHRT 41 orders. Implementation will align with the Treasury Board Policy on Transfer Payments and 2021 CHRT 41.

To be eligible, the full and/or partial cost for the purchase, construction or renovation of a capital asset must be underway and/or ready to proceed, and support spaces that are safe, accessible, confidential, and culturally and age appropriate, and used for the delivery of Jordan's Principle services to eligible First Nations child(ren) to address unmet health, education, and social needs. These needs include:

  • health needs: spaces for provision of unmet health services, including where existing Jordan's Principle funding is not sufficient to ensure on-reserve residences are suitable for First Nations children with complex and/or on-going medical needs and/or disabilities; including mental health programming which need capital accommodation;
  • educational needs: for delivery of educational and early educational services;
  • social needs: for delivery of cultural and language services, respite services, land-based activities, etc.

To be eligible, capital needs assessment and feasibility studies for capital assets must show how the capital asset will support the delivery of services funded under Jordan's Principle contribution agreements.

3.3 Eligible assets

Eligible assets that support the delivery of activities listed in section 3.1 include:

  • Assets that provide safe, accessible, confidential, culturally- and age-appropriate spaces to support the delivery of Jordan's Principle services, including office space related to Jordan's Principle service coordination.
  • Assets that enable First Nations children with complex and/or ongoing unmet medical needs and/or disabilities to live safely at home in a manner that meets their distinct needs and circumstances requiring capital accommodation.

3.3.1 Multi-purpose assets

In circumstances where an asset will serve multiple purposes, Jordan's Principle may proportionally contribute towards the purchase, construction, or renovation capital costs where these costs will be towards the Eligible Activities outlined under 3.2 and align with the eligibility outlined under 3.1 Eligible Requestors and 3.6 Location of the Assets. Depending on the complexity of the capital project, consideration of a multi-purpose asset must be addressed as part of the pre-capital planning and design plan to substantiate the most effective way to provide Jordan's Principle services. Note that a decision on the capital request will only reflect the portion of a multi-purpose asset that is intended for Jordan's Principle; consideration for funding for the remainder may be considered under other ISC or Government of Canada programs through existing application and decision-making processes as applicable.

3.3.2 Ownership of the assets

Capital assets located on reserve or in the Yukon will be owned by the funding recipient. If a First Nation is a funding recipient, the First Nation has the option of having the asset owned by their holding company or their incorporated entity, which has a distinct governance structure.

3.4 Eligible costs

Eligible costs include:

  • Capital needs assessments for the purchase, construction, or renovation of assets;
  • Functional Program (services operational plan or "Master Program") - covering how funded Jordan's Principle services identified will be operationalized, including occupancy by community-based and visiting health professionals, technicians, representatives, and other support staff;
  • Functional Plan (spaces m2) - directly mapping funded Jordan's Principle services and occupancy to the number, size and type of spaces required;
  • Capital feasibility studies for the purchase, construction, or renovation of assets, including environmental and geotechnical assessments, land surveys, and other technical studies;
  • design costs;
  • purchase, construction, or renovation of assets that are ready to proceed (has relevant First Nations approval and for which feasibility and design work has been completed;
  • other auxiliary capital project costs such as: initial furniture and equipment that is fit for purpose, information technology, and other equipment to furnish new spaces, site preparation, lot servicing and site clean-up after construction; building hook-ups to water, sewer, and electrification; and upgrades to roads to enable access to the building;
  • professional fees (e.g., technical personnel, architects, consultants, and contractors to design, develop, complete or monitor the project, engineering, manufacturing or building of capital project facilities and structures);

3.5 Ineligible costs

Taxes for which the requestor is eligible for a tax rebate and all other costs eligible for rebates (e.g., Goods and Services [GST] Tax rebates or eco-retrofits to reduce greenhouse gas emissions which may be eligible under other federal funding) are not eligible.

3.6 Location of the assets

Buildings built, purchased, or renovated using this funding can be located on-reserve or in the Northwest Territories or the Yukon and must provide a safe, accessible, confidential, culturally, and age-appropriate space to support the delivery of Jordan's Principle services.

Where Jordan's Principle services are delivered off reserve, pre-capital planning funding for off-reserve capital assets to support such delivery are also eligible.

4. Requirements for construction projects

Where relevant, existing ISC program policies (e.g., policies related to the Capital Facilities and Maintenance Program) and other policies (e.g., Policy on Transfer Payments) will be used to support the implementation of eligible capital requests. In instances where requests do not fall under existing policies, ISC will work with the funding requestor to identify requirements based on industry standards and best practices.

5. Funding request and assessment process

Full and partial funding determinations

This capital funding request and assessment process has been designed to be adaptable to the numerous types of requests that will come forward, and their varying degrees of complexity and different stages of project readiness in the capital project life cycle.

For projects that are deemed "ready to proceed" to the purchase or construction of an asset or for funding requests for feasibility studies, ISC must make a determination on the full funding of a project or study within 30 business days of receiving a complete capital funding request submission (i.e., Capital Funding Request form and any supporting documentation). ISC may not need the full 30-business days to reach each full funding decision – it will vary based on the circumstances and complexity of each project.

If ISC is not able to make a full funding decision because the project is not "ready to proceed", where possible, in consultation with the requestor, ISC will make a partial funding decision to enable the advancement of the project.

If the 30-business day standard for a full funding decision cannot be met due to the level of project complexity or some other exceptional circumstances, the Coordination Unit for Jordan's Principle will notify the requestor in writing and will provide the rationale for the additional time needed.

Complexity

Where the funding request is seeking support for a complex project (for example, construction of a new building), the project will need to complete the approval stages of the capital project life cycle which includes the following stages:

  1. Pre-capital needs assessment, feasibility and planning
  2. Design
  3. Construction
  4. Completion

The number of stages that each capital project must undergo depends on the type of proposal and its level of complexity.

Stages are dependent on the type of proposal and the complexity of the capital project.

For example, straightforward funding requests (e.g., single service-type building) will not need to go through as many project approval stages as a project involving the construction of multi-purpose buildings.

The complexity of a project depends on an array of factors including but not limited to:

  • the type of project;
  • the overall anticipated cost of the project;
  • project completion time;
  • if it is a joint project with other First Nations or other partners;
  • if it is a multi-purpose building intended to offer multiple types of services;
  • the location of the capital asset; if there are health and safety implications;
  • if the property is connected to a road, water and wastewater system, and a source of power; and
  • if there are any environmental impacts.

Capital projects can be deemed complex when the capital asset delivers and/or is intended to deliver multiple Jordan's Principle services (i.e., health, educational and/or social services) and other services. In these circumstances, the requestor and ISC will consider factors including design and/or capital asset requirements to accommodate multi-service delivery, and cost sharing among the service areas.

ISC will send notifications to the funding requestor as the capital funding request moves forward through the assessment process and will notify the requestor promptly regarding any missing information. For more information on service standards regarding the assessment process and associated communication, please see Section 6.

5.1 Governance

The 2021 CHRT 41 funding request assessment process for requests under Jordan's Principle is supported by the following ISC governance structure and division of responsibilities:

  1. ISC First Nations Child and Family Services (FNCFS) National – Intake
  2. ISC Coordination Unit for Jordan's Principle National – Requestor and Recipient Support, Escalation, Appeals, Oversight and Monitoring
  3. ISC Coordination Unit for Jordan's Principle with support from a regional capital situation table (including representatives from: Capacity, Infrastructure and Accountability Division in Regional Office; Jordan's Principle in Regional Office; relevant ISC Programs (e.g., Mental Wellness, Education) in Regional Office for Completeness Assessment, Program and Recipient Eligibility, Transfer Payments, and Requestor/Recipient support when and if needed.

This breakdown of responsibilities is notional and may be refined as ISC gains further experience supporting the implementation of the 2021 CHRT 41 orders. Regardless, the different players within ISC will work collaboratively towards rendering a decision.

Collaborative process to ensure capital needs are addressed promptly

The Coordination Unit for Jordan's Principle will work with the funding requestor to confirm the complexity of each project and what steps, stages and documentation are needed for each project. ISC's goal is to help requestors access the capital that they need to deliver Jordan's Principle services. ISC will be as flexible as it can be and will exercise common-sense approaches to support requestors during the assessment process and during the implementation of these priority capital projects.

The Coordination Unit for Jordan's Principle will send notifications in writing to the funding requestor as the capital funding request moves forward through the assessment process and will notify the requestor promptly in writing regarding any missing information. To support stronger and more simplified information management, each funding request will be assigned a unique identifier number and all correspondence from ISC regarding a 2021 CHRT 41 submission will note its unique identifier number.

For more information on how the funding request and assessment process works based on the status and the stage of the capital project lifecycle, please see the rest of Section 5 and 7.

5.2 Outline of the process based on the project status scenarios

Scenario 1: If a project is not yet underway

5.2.1 Capital Funding Request form

Regardless of the stage of a project (e.g., whether a needs assessment is completed), the requestor submit a Capital Funding Request form to chrt41-tcdp41@sac-isc.gc.ca where the FNCFS team will intake and triage the request to the Coordination Unit for Jordan's Principle.

The form gathers basic information about:

  • the requestor,
  • the type of services that this capital request supports and how it aligns with Jordan's Principle,
  • the type of capital project,
  • the stage the project is at,
  • estimated costs,
  • estimated start and end dates, and
  • supporting documentation (e.g., requirements for accommodation).

Upon receipt of a capital funding request submission, the 30-business day clock will start and the FNCFS team as responsible for the intake of all 2021 CHRT 41 requests will forward the request to the Coordination Unit for Jordan's Principle and jointly review the request to confirm if all of the fields of the form were completed and if the documentation referenced by the funding requestor in the form was included.

If there is any missing information identified after the review, the Coordination Unit for Jordan's Principle will provide the requestor with a detailed list of outstanding information in writing. The 30-business day clock will pause once the message about missing information has been sent to the requestor and will resume upon receipt of the missing information.

Following the confirmation of receipt, the Coordination Unit for Jordan's Principle will lead the rest of the assessment process and communication with the requestor. If the 30-business day standard cannot be met due to project complexity or some other reason, the Coordination Unit for Jordan's Principle will notify the requestor in writing and will provide the rationale for why additional time is needed to make a partial or final funding determination.

Once confirming that the submission is complete, the Jordan's Principle Coordination Unit will assess if the request contains enough information to determine eligibility; the services of which program areas are implicated and what capital technical review may need to be engaged during the project review process. Based on this assessment, the Coordination Unit for Jordan's Principle will gather a regional capital situation table including representatives from: Capacity, Infrastructure and Accountability Division in Regional Office; Jordan's Principle in Regional Office; relevant ISC Programs (e.g., Mental Wellness, Education) in Regional Office. In addition, when and if needed, ISC RO Capital will be engaged by the Coordination Unit for Jordan's principle to provide technical capital support to Regional Office and Requestor/Recipient support.

Once the Coordination Unit for Jordan's Principle informed by the regional capital situation table determines that the project is eligible, the Coordination Unit for Jordan's Principle and the requestor will work together with the regional capital situation table to confirm what additional documentation or stages may need to be completed before the project is ready to proceed to the purchase or construction of an asset. Once these details have been confirmed, the Coordination Unit for Jordan's Principle will communicate this information in writing to the requestor.

A. Pre-capital needs assessment, feasibility and planning stage:

If pre-capital planning is incomplete and pre-capital work is necessary, the Coordination Unit for Jordan's Principle will make a determination on the request based on the requirement for pre-capital work within the service standards outlined under Section 7 and will flow funding to the requestor to complete pre-capital planning.

The pre-capital planning and feasibility stage identifies activities for which capital assets are required and determines the optimal approach - it identifies options for meeting the service need and recommends the optimal approach (e.g., commercial lease; new construction; expansion and/or repair of an existing asset).

Readiness

Readiness assessment will confirm the following pre-capital planning documentation has been completed (where required) in support of the capital asset request:

  • A capital needs assessment that outlines the scope of Jordan's Principle service activities that require the capital asset. A capital needs assessment typically gathers or determines details such as the:
    • current scope of Jordan's Principle services;
    • staffing requirements to deliver Jordan's Principle services;
    • estimated capital requirements of Jordan's Principle services; and
    • extent to which this type of capital is currently available to the First Nation or authorized First Nation service provider for Jordan's Principle services and the current condition/state of these existing assets.
  • Functional Program (services operational plan or "Master Program") - covering how the funded Jordan's Principle services will be operationalized, including occupancy by community-based and visiting health professionals, technicians, representatives, and other support staff.
  • Functional Plan (spaces m2) - directly mapping services and occupancy to the number, size and type of spaces required.
  • Technical Feasibility Study - prepared by a professional architect or engineer licensed to practice in the region where the Project is proposed to be undertaken, which examines the relative merit and feasibility of one or more design and construction or renovation options for meeting the physical space requirements for the proposed building. Part of the study must identify whether existing community-support infrastructure requires upgrading or the establishment of new systems to adequately accommodate the proposed building (e.g., roads, water and wastewater systems, electricity).
  • Geotechnical Investigation - for new or alterations to structural foundations, a soil investigation report of the lands upon which the building or expansion is proposed to be constructed from a geotechnical engineer licensed to practice in the region where the Project will be undertaken.
  • Site Survey - a survey completed by a licensed surveyor of the land upon which the Project is proposed to be constructed, to show the interrelationship of all proposed and existing buildings and infrastructure.
  • Signed letter and/or Band Council Resolution - to help ensure that a common understanding of the proposed project is achieved and well supported by the Chief(s) and/or Band Council(s) of the community, or communities, directly involved.

Regarding Technical Feasibility Study:

  • If a feasibility study has not already been completed and is deemed necessary, the Coordination Unit for Jordan's Principle will work with the funding requestor to determine the funding required to complete this study and to ensure funding is transferred to the requestor.
  • A completed feasibility study will include a recommended option. The funding requestor will review this recommendation and identify their preferred option. The Coordination Unit for Jordan's Principle working with the regional capital situation table and the ISC RO Regional Office when and if needed to assess the requestor's preferred option and determine whether ISC should support the project moving on to the next stage.
  • If the Coordination Unit for Jordan's Principle determines, after reviewing the feasibility study, that the requestor's preferred option is eligible but other documentation is still needed or the project must still undergo a design phase before a full funding decision can be rendered, the Coordination Unit for Jordan's Principle will work with the requestor to determine the funding required to complete this documentation or this plan, and the Coordination Unit for Jordan's Principle team will make a partial funding decision at this point to support the ongoing advancement of the project by funding this work.
  • *Note: Consideration of ancillary capital costs for the construction or purchase of assets, such as lot servicing, building hook-ups to water, sewer and electrification, and ensuring road access, etc., must be addressed as part of the feasibility study and design plan for this asset. These ancillary capital costs must be factored into the determination of the most cost-effective option overall.
B. Design stage

The development of a design plan is standard practice for many capital projects after the completion of a feasibility study. The need for a design plan is, however, case-specific based on the stage, nature and complexity of the capital project.

The design plan specifies in detail the preferred solution for meeting the service need, including factors such as lot servicing, access to services and supporting infrastructure (water, wastewater, internet, electricity, roads).

The design plan is the final potential component needed for ISC to confirm if a complex project is "ready to proceed" to construction and to make a full funding decision. Once the design plan is submitted, the review of the plan will confirm that the project meets applicable federal, provincial, and territorial codes and standards for the design, construction and operation of similar physical assets, that the design of the project is approved and certified by a professional engineer or architect licensed to practice as such in the province/territory where the proposed work is undertaken.

If upon review of the design plan, the requested project is confirmed to be 'ready to proceed', the funding recipient will also initiate a tendering process for construction. Federally funded capital projects administered by First Nations must align with the First Nation's own tendering policies or, in the absence of such policies, the projects must align with the Tendering policy on federally funded capital projects for First Nations on reserve. Federally funded capital projects administered by First Nations-authorized service providers must align with public sector tendering practices. The eligible recipients will call tenders to ensure the building is fit for purpose and that the project delivers value for money, prudence, probity and sound contract management. Value for money may include consideration of opportunities to secure socio-economic benefits on behalf of the community.

C. Construction stage

A contract is awarded to the construction company. ISC flows funding to the requestor and construction begins.

D. Completion stage

Once the construction is complete, the professional firm issues a certificate of project completion.

5.3 Scenario 2: Project is already underway before funding request form is submitted

Funding requestor submits a Capital Funding Request Form along with documentation to demonstrate eligibility, stages completed to date, and how they have met any applicable requirements.

The request will be assessed and key information will be communicated to the requestor in the same way as described for Scenario 1. Once it is confirmed by the Coordination Unit for Jordan's Principle that the project is eligible and that the documentation is complete, the Coordination Unit for Jordan's Principle will notify the funding requestor in writing of the approved full or partial funding decision and flow the funds for cost incurred. As any remaining applicable stages are completed, associated documentation is provided and completeness is confirmed, the Coordination Unit for Jordan's Principle will continue to render partial funding decisions and ensure that funds continue to flow in order to continue to advance the project until the project is completed.

5.4 Scenario 3: Project is already complete before funding request form is submitted

The submission will be assessed in the same way as described for Scenario 1. Once it is jointly confirmed by the Coordination Unit for Jordan's Principle that the project is eligible and that the documentation is complete, the Coordination Unit for Jordan's Principle will notify the requestor in writing of the full funding decision and will ensure that funds for costs incurred are disbursed.

5.5 Impact of remoteness or other exceptional circumstances on the funding request process

Review of capital projects for the delivery of services under Jordan's Principle that are situated in remote areas or with exceptional circumstances (e.g., time-limited availability of an ice road, First Nations located in rural areas or areas that were significantly impacted by recent flooding) will consider that some aspects of a project may need to be approved before full feasibility or design work is completed due to factors including but not limited to seasonal access to the First Nation or the limited availability of contractors.

6. Documents to support capital funding request

Where relevant, existing ISC program policies (e.g., policies related to the Capital Facilities and Maintenance Program, Health Facilities Program) and other policies (e.g., Policy on Transfer Payments) will be used to support the implementation of eligible capital requests. In cases where requests do not fall under existing policies, ISC will work with the funding requestor to identify requirements based on industry standards and best practices.

To support ISC's review of the project proposal, supporting pre-capital documentation must be provided that:

Each of these steps builds on the previous one, and the complete planning process maintains this sequence to ensure an integrated and thought-out facility plan is developed and implemented

Where design work is complete, supporting documentation must be provided that:

6.1 Technical guidance available from regional teams

In preparing your funding request, please note that ISC regional office staff can support requestors with:

  • completing the form;
  • assessing eligibility;
  • maximizing the life cycle of physical assets;
  • mitigating health and safety risks;
  • ensuring assets meet applicable codes and standards;
  • ensuring assets are managed in a cost effective and efficient manner;
  • analyzing and/or revising the scope of projects;
  • establishing professional services contracts; and
  • updating financial information (project quote).

Please contact your First Nations and Inuit health regional offices should you require assistance.

7. Service standards and key dates

If the Coordination Unit for Jordan's Principle determines that the 30-business day service standard cannot be met, it will notify the requestor in writing providing the rationale for the needed additional time.

8. Escalation and appeals process

Until a longer-term approach is established, all requests under Jordan's Principle will be approved by the Assistant Deputy Minister responsible for the Capacity, Infrastructure and Accountability Division. Prior to making a decision that a request must be fully or partially denied, as part of the escalation process, the request will be reviewed by the Senior Assistant Deputy Minister responsible for Jordan's Principle.

Upon making a final decision, the Coordination Unit for Jordan's Principle will communicate the decision on the request to the requestor in writing no later than 30 business days of receiving the complete submission.

If the request is deemed partially or fully ineligible, the communication will include a detailed explanation for the decision and information on the appeals process. The Coordination Unit for Jordan's Principle will try to identify other potential funding options to meet the requestor's needs.

Information on the appeals process to follow upon discussion with the Parties.

9. Funding agreement and payment process

9.1 Completeness and complexity

Completeness: ISC will fund the full cost of capital request that meets the criteria outlined in Section 3.2. Please provide any supporting documents such as invoices, quotes, proposals, financial documentation, cash flow of forecasts, multiyear community planning, timesheets, provincial salary grid or other information that may assist in reviewing your request.

Complexity: Capital projects become more complex when a significant amount of construction is involved. In these circumstances, the requestor and ISC must consider and evaluate many factors such as lot servicing, access to services and supporting infrastructure (water, wastewater, internet, electricity, roads), tendering, cost validation, value for money, building to code, impacts of climate change, land use plans, size, etc.

9.2 Funding agreements and payments

ISC will work with funding recipients through new or existing funding agreements to issue funding at different stages of a capital project.

10. Reporting requirements

All reporting requirements, including annual audited financial reports, are to be outlined in the funding agreement between the recipient and Canada. Other reporting requirements will be discussed with the recipient during the assessment of the request for funding.

If applicable, once an asset is built, it will be entered in ISC's information management systems. The data will be used to generate forms used for asset inspections. The inspections identify asset deficiencies, and future capital needs. This process allows for preventive or anticipatory work to be completed to ensure the infrastructure remains available to deliver services.

11. Operations and maintenance

ISC promotes a life-cycle approach for assets. All assets must be:

12. Repayable contributions

If any of these assets are sold or disposed of in some other way or, if in a manner within the control of the funding recipient, the assets become unavailable to provide services under Jordan's Principle, ISC may reserve the right to a repayment proportional to the contribution made to the project. In instances where a First Nation or a First Nations-authorized service provider for Jordan's Principle services receives funds resulting from the disposal of project assets, ISC may recover the cost from the First Nation, or the First Nations-authorized service provider.

Where asset is sold, leased, encumbered, or disposed of within: Return of contribution to ISC (In current dollars)
2 years after project completion 100%
Between 2 and 5 years after project completion 55%
Between 5 and 10 years after project completion 10%

13. Contact information

First Nations or First Nations authorized service providers can contact ISC at chrt41-tcdp41@sac-isc.gc.ca for any questions relating to this chapter.

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