Summary
This regulation governs the Canada Disability Savings Program, providing government grants and bonds to match private contributions to Registered Disability Savings Plans (RDSPs) for people with disabilities. It sets eligibility criteria (age under 49, DTC-eligible, contribution limits), establishes an 'assistance holdback amount' that triggers clawbacks, defines complex repayment obligations when plans terminate, beneficiaries die, cease to be DTC-eligible, or make withdrawals, prescribes extensive issuer reporting requirements, and mandates that financial institutions enter into detailed issuer agreements with the Minister.
Reason
This regulation creates perverse incentives that trap beneficiaries in dependency by penalizing work, savings, and self-sufficiency through punitive clawback mechanisms (3:1 repayment ratio on withdrawals). The complex 'assistance holdback' system discourages accessing needed funds, violates property rights by allowing government to reclaim private contributions, and creates Byzantine compliance burdens for financial institutions. The DTC-eligibility requirement excludes deserving individuals based on bureaucratic classifications while linking benefits to continued disability status, directly opposing recovery. The regulation's complexity generates unseen administrative costs that ultimately reduce program effectiveness and increase financial instrument costs for all. Private charitable solutions, family support networks, and voluntary disability insurance markets would provide more flexible, dignified, and efficient support without these destructive incentives.