How ABC + EBC = SNAFU, and when it comes to answers, we are S.O.L.

by Sal Robinson

Ken Sim and ABC Vancouver should not have had the advantage of thousands of dollars of prohibited contributions in their 2022 election campaign. They did.

Elections BC’s Financial Reports and Political Contributions System should provide transparency about those prohibited contributions.  It does not.

If you don’t remember what “snafu” is an acronym for, you’ll get the picture by the end of this article.

Some unanswered questions

• How did ABC get away with keeping over $200,000 in excess and/or prohibited contributions, made in advance of the 2022 election, for more than a year after election day?

• Which date did Ken Sim appoint Corey Sue as his financial agent: September 14, 2022 according to the publicly available document they both signed, or January 22, 2021 according to Elections BC records? The date affects each man’s liability to monetary penalties and appearing careless or incompetent.

• Why were contributions accepted by ABC as early as 2019 not reported until many amendments to their original 2023 disclosure had been filed?

• Why, after being the subject of an investigation on its 2022 election financing, would ABC again report accepting contributions (to the 2025 by-election) in excess of the annual limit?

• Why did ABC not disclose some $72,000 in contributions it received in 2024 in the lead-up to the 2025 by-election?

• Why was Elections BC’s enforcement so uneven? If it had applied its criteria consistently, it would have penalized Sue for accepting prohibited contributions from 46 people, not just 8. And it penalized Sue for not promptly returning prohibited donations from just one of six people who got their refunds the same day.

• Did Corey Sue contravene the Local Elections Campaign Financing Act by holding on to excess contributions for more than a year, instead of returning them “as soon as practicable” as required?

• Did the investigation take so long because of slow responses from ABC, Elections BC or both?

• Why doesn’t Elections BC enhance transparency of donor records in its Financial Reports and Political Contributions System (FRPC) by adding refund information instead of deleting the records entirely?

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Guides clearly set out financing rules so nobody messes up

All the rules about raising money for civic elections are to be found in provincial legislation called the Local Elections Campaign Financing Act (LECFA, for short). 

The rules include who can donate, how much they can donate, who can receive donations, records that must be kept, banking, spending limits, and so on.

Elections BC (EBC) publishes two detailed guides, one for candidates and their financial agents and one for parties and their financial agents, so that nobody messes up.  Notice that “financial agents” are in the target audience for both guides. That’s because the financial agent is the person responsible for ensuring that the rules are adhered to.  Candidates who haven’t appointed a financial agent are acting in that capacity for themselves.

Any literate person who reads the guides carefully will understand the responsibilities and duties imposed on a financial agent, who is legally bound to fulfill them.  All scenarios a financial agent is likely to encounter are described, and contact information is provided for EBC staff who are quite quick to respond to queries.

Since many candidates run under the endorsement of a party which typically handles the fundraising, the party must have a financial agent and that person’s task is more complicated than if there were only a single candidate’s records to deal with. Those complications are explained in the guide.

The guide makes clear there is an annual limit for an individual to contribute to a party and/or its endorsed candidates. The donation can be split between the party and one or more candidates, but the donor can’t exceed the annual total. The limit in 2022 was $1250.  If someone gave that amount to Ken Sim, then tried to give anything at all to ABC after Sim was endorsed, ABC would have to refuse it.

A candidate might start off as an independent and later join a party, bringing in funds already raised before the endorsement.  That happened in 2022 with ABC-endorsed candidates Rebecca Bligh, Lisa Dominato, Sarah Kirby-Yung and Ken Sim, all of whom had been accepting contributions since 2020 (and late 2019 for Dominato and Sim).

Following an election, candidates and parties must file disclosures of how much money they raised, who they got it from, how much they spent and what they spent it on. The disclosure shows who their financial agent was for that process.

The timing of appointing a financial agent is critical

The election disclosures of the four independent-turned-ABC candidates show (a) they each appointed Corey Sue as their financial agent a month before the October 2022 election and (b) none had appointed a financial agent previously.   

The natural conclusion to draw is that each had acted in the capacity of financial agent for their independent fundraising until throwing in with ABC and appointing Corey Sue.  So far, so good, with an important exception involving a curve ball from Elections BC you’ll read about later on.

ABC’s 2022 election disclosure outlines a number of transfers it received from those four candidates over the course of late 2022: about $25,000 from Bligh; about $80,000 from Dominato; about $31,000 from Kirby-Yung and $275,000 from Sim.  

But there’s a mystery about what happened in 2021, when Sim threw $27,500 into ABC coffers in three payments between September and October. That was before Corey Sue officially became ABC’s first financial agent on November 30, 2021 -- so who received that money on ABC’s behalf?  (ABC reported no former financial agent in its 2022 election disclosure.) Section 19 (1) of LECFA states that a party may not accept a transfer from a candidate before appointing a financial agent.

The transfers from the four candidates made for some complicated accounting, since a single individual might have contributed to more than one of them when they were independent, or to one or more of them and to ABC, the organization, before their endorsement.  All above-board and permitted under LECFA – until they joined forces with ABC.  Then, that single individual’s contributions added up to more than the annual limit set by Elections BC, and any excess contribution would need to be refunded in a timely way. 

Such multiple contributions formed the lion’s share of the refunds made by ABC in December, 2023. In news coverage of the $115,000 in refunds, Corey Sue is quoted as claiming that ABC’s “unique situation with four independent candidates doing their own thing before joining ABC” was the cause of the problem.  Remember Sue’s statement. It’s important later. And while most of the refunded donations were the result of the “unique situation” cited by Sue, not all were, as we will see.

Guides are clear about what should happen when independent candidates join a party

The situation may have been unique, but it was not unanticipated by Elections BC which covers it exactly on page 17 of both the guides it provided:

When an elector organization endorses a candidate, the financial agent for the candidate must give the elector organization’s financial agent the candidate’s contribution information. The financial agent for the elector organization must ensure that contributions from eligible individuals do not exceed the limit. 

When the formerly-independent candidates transferred funds to ABC, their financial agents – in this case, they themselves – were required to submit to ABC’s financial agent Corey Sue all the details of each donation they had accepted: the amount, name and residential address of the donor, and the date.

Sue, as the financial agent for ABC since November 30, 2021, was required to check all the information provided him by Bligh, Dominato, Kirby-Yung and Sim to see if the “merging” of donations resulted in excess contributions. Which, of course, it did: thousands of dollars’ worth.

How soon is “practicable”?

Section 30.05 (3) of LECFA required that Sue review the information “as soon as practicable” after receiving it.  S. 30.05 (4) required that Sue refund the excess contributions “as soon as practicable” after finding them, which was the whole point of review he was duty-bound to undertake.  But it seems that “practicable” was “not inside of a year.” Section 30.05 (8) points out that a financial agent who contravenes Section 30.05 commits an offence.  Did Sue contravene it?

The phrase “as soon as practicable” appears 37 times in LECFA. But it’s so vague that it’s meaningless, allowing huge leeway in when things get done.  For example, the phrase applies to back-and-forth communication between a municipality’s election officer and EBC’s chief electoral officer during the nomination period and when candidates are declared. In 2022, this amounted to 14 working days. It also applies to how promptly names of those receiving monetary penalties must be released. Ironically, in Corey Sue’s case, the time frame was one day.

But some timelines are firm. Parties must file disclosures within 90 days of the election – although they can amend them indefinitely.  (ABC filed its sixth amendment in December 2024.) Their scanned forms become public, and donor details are posted in EBC’s  Financial Reports and Political Contributions System (FRPC).

On a research quest that led to this one, I familiarized myself with that database and discovered dozens of instances where individuals had donated more than the annual limit either by supporting more than one ABC candidate or by donating multiple times to Ken Sim.  (The other three independents accepted no multiple contributions from their supporters.)

The data vanishes

TEAM wrote to EBC in July 2023 with concerns about the multiple donations to ABC as tracked in FRPC.  Another letter in October included a spreadsheet of potential prohibited contributions totalling $119,000  - data then available in FRPC which I exported at that time.  On December 20, ABC returned donations totalling $115,000 to its supporters.

But because returned donations disappear from FRPC, an enquiring mind will neither find them there now, nor know that they had ever been there.  There exists, however, the semblance of a paper trail.

I was advised by Elections BC that all the data can be found in scanned reports, even if not in the easily-searched FRPC.  The scanned reports are in PDF, but you can search for a name, provided you know it exists.

Elections BC’s FRPC allows the user to set search parameters. Two years ago, I exported the results of a search for election contributions accepted by ABC and its endorsed municipal candidates between January 1, 2019 and December 31, 2022.   I recently exported the results of the same search, with a startling result.

On October 20, 2023 the database showed 2981 donation records totalling  $2,192,081.47.  On October 20, 2025 the database showed 2729 donation records totalling $1,989,671.31:  $202,410 less.

There are fewer records now, and I thought those missing would yield the details of the supporters ABC collected from and later refunded to, long after the election.  Wrong!

What I didn’t know was that records are not only deleted from FRPC but added  - long after the fact -  when donations are disclosed in amendments.  Since October 2023,  281 records were deleted, and 28 were added.  From significant contributors, $217,676 was gone, and $20,710 was added.  (If you’re wondering why the amount gone minus the amount added doesn’t equal the $202,410 mentioned above, it’s because I didn’t count the contributions of under $100 that appear in the records as one chunk.)

Where did the money go? 

The scanned disclosure reports are supposed to tell the story, provided you know what to look for.  We can trace how and when some was refunded to ABC supporters fourteen months or more after the 2022 election that put their candidates in office. 

To do this, I looked at the most recent amendments of the 2022 General Election disclosures, all dated December 4, 2024.  (Why so many amendments to disclosures?  Things turn up during audits that must be corrected in the records.)

The big refund day, December 20, 2023, accounts for a large chunk of the disappeared contributions, about $120,000.  This included nearly $60,000 in refunds ABC made on behalf of candidates who accepted them prior to their ABC endorsement and transferred them to the party.

According to the fifth version of Ken Sim’s disclosure, thirteen people who had contributed more than they were allowed to (and one corporation, which isn’t allowed to contribute at all) got refunds totalling $27,324 on December 20, 2023. Another person got his $1200 refund on June 30, 2024, more than two and a half years after he donated it. All of the money had been in ABC’s hands for at least twenty-one months, most for more than two years.

Lisa Dominato’s amendment number four  shows that eighteen people got refunds totalling $20,382 on “refund day.”  Nine supporters of  Sarah Kirby-Yung received a total of $10,834 that day, two years after making their donations, according to the fifth iteration of her disclosure.

Refunds made in 2024 come to some $6100, ($2438 from Dominato, $2400 from Kirby-Yung, and $1240 from Sim).  That brings us to about $126,000 of the roughly $218,000 no longer in FRPC.

Notably, no refunds of contributions to Rebecca Bligh were made, even though she was the recipient of donations from people who also gave to the other independents, in some instances on the same day, or later.  How was it decided which excess contribution to refund? 

Around $92,000 is still “lost,” and I don’t know where else to look for it. I have written to EBC to ask why some donor records have just gone “poof” from FRPC as well as from ABC’s disclosures.

Where did the new money come from, and why did it take so long to find its way into FRPC?

It came from 27 people who donated it to Ken Sim as early as New Year’s Eve, 2019 and to ABC as recently as September 2022. That final one didn’t make it into an amended report (the fourth one) until February 2024.  A person whose $1250 contribution was made in February 2022 doesn’t get a mention until ABC’s fifth amended disclosure, filed July 17, 2024.

Why the delay? Two delays, really.  Only ABC knows why it didn’t report the contributions in their original January 2023 disclosure and not until more than a year later.  As to updating FRPC,  Elections BC was getting its ducks in a row through the spring of 2024, as evidenced by the background information in the enforcement letter that comes next.

Minor penalties after long delays

On April 11, 2024, EBC announced it was investigating ABC Vancouver “for potential contraventions” of LECFA. But it wasn’t until more than a year later, in late June of 2025, that a penalty was announced – well after that year’s April 5 by-election.

The timing was a disappointment to Vancouver’s other civic parties, who joined in a media event in January of 2025 calling on Elections BC to resolve its investigation of ABC before the by-election. The call went unheeded. The enforcement notice against Corey Sue wasn’t posted on the EBC website until June 24, 2025.

And what was the cost to ABC for keeping over $200,000 in contributions it shouldn’t have, paying insufficient attention to excess contributions, not returning prohibited or excess contributions until more than a year after it had the use of them for its campaign?  A penalty of $11,888 and a warning letter.  Vancouver voters, if they were paying attention at the end of June – months after the April 5 by-election campaign – might have registered a moment of bad publicity.

All of the prohibited contributions cited in the enforcement notice related to donations made to ABC and/or to Ken Sim while he was an independent candidate, and none to fundraising done by the other independent-then-endorsed candidates.

• Sue was fined for accepting $13,125.74 in prohibited contributions to ABC from ten individuals and a corporation. Eight of those people had contributed both to Sim and to ABC in 2021, the remaining two having donated double to ABC in 2022. But 38 other people had done exactly the same thing, donating to both Sim and the party in a single year, to the tune of over $44,000. Why were those contributions not included?

• Sue was fined for accepting $14,204.10 in prohibited contributions to Ken Sim in 2021 from six individuals who donated multiple times to Sim alone. And there was a further fine.

• LECFA requires that prohibited contributions be refunded within 30 days of when the financial agent “becomes aware of the contravention.” Sue was fined $960 for failing to return $2400 in prohibited contributions made to Ken Sim from one of those six 2021 donors. Why not the other five of them, when they all got their refunds the same day – December 20, 2023 – some fifteen months after Sue should have received Sim’s donor information?

The fines imposed on Corey Sue added up to $11,888.  I was mystified as to why he should pay for Ken Sim’s apparent turning a blind eye to the responsibilities he undertook as his own financial agent prior to appointing Sue.  You may have noticed that everything you’ve read up to this point was written on my assumption  – based on the public record – that Sim was acting as his own financial agent until September 14, 2022.

In an effort to understand, in July I wrote to the man who had signed the enforcement notice, Adam Barnes, Director of Investigations.  (See all letters in Appendix below.)

I asked why Ken Sim was able to collect, with impunity, more than $14,200 in prohibited contributions in 2021, and why he is not responsible for the prohibited contributions he accepted prior to appointing Corey Sue as his FA on September 14, 2022. 

The response I received on August 21 didn’t do much to enlighten me.  Mr. Barnes wrote, ”Some of the contributions you appear to be concerned about are excess campaign contributions under s. 30.05 of LECFA rather than prohibited contributions, and therefore not subject to monetary penalties.  To further clear up some potential confusion, according to our records Corey Sue was appointed as Financial Agent for Ken Sim on January 22, 2021.”

Two issues are raised here.  First is the distinction between “excess” and “prohibited” contributions. In some of my earliest correspondence with Elections BC, because the data I was examining was puzzling, I proposed a scenario in which a party endorsed a candidate for mayor and two candidates for council, and a donor had contributed to all three, as well as to the party: what appeared to be quadruple the limit.  On June 21, 2023 I received this clarification (my emphasis) from Compliance Officer Ania Avila:

“…a single eligible individual could not contribute more than $1250 in 2022 to the elector organization and the three candidates in total. If a contributor has exceeded the contribution limit, the excess amount is a prohibited contribution, and the funds must be returned to the contributor or remitted to Elections BC.”

Second is Mr. Barnes’ closing sentence,  the curveball I mentioned earlier.  The whole issue of Sim’s responsibility hinges on the date he appointed Sue as his financial agent.  If he did it January 2021, why did he do it again in September 2022?

Remember what Sue said in response to queries about the massive refunds? About “four independent candidates doing their own thing before joining ABC”?  Is that a reasonable statement for a person to make who had been the financial agent for one of those four independent candidates for nearly a year?  Had Sim been doing his own thing, or not?

Questioning the reasoning in EBC’s “explanation”

On September 2, 2025  I wrote again to Adam Barnes, appending a list of 38 donors, and responding that his statement that Corey Sue has been Ken Sim’s financial agent (FA) since January 22, 2021 creates more confusion than it clears up. Key points in that letter:

• LECFA required that, “as soon as practicable,” Sue scrutinize contributions to Bligh, Dominato and Kirby-Yung once he became their FA. Seemingly he did not.  More than $30,000 donated to them in 2021 was not refunded until some fifteen months after Sue was appointed their FA.  Can LECFA be interpreted in any other way than that once the FA discovers an excess contribution, he must ensure it is refunded “as soon as practicable” and that failure to do so is an offence?

• If Sue were already Sim’s FA why did Sim appoint him again? Sue’s January 2021 appointment as Sim’s FA makes a huge difference in reducing Sim’s exposure to any penalty.  How could Sue, as financial agent for both candidate and party, fail to notice that so many donors to Sim were also donors to ABC?

• $18,761.64 in refunds were made to 22 people in July, 2022. If scrutiny of the 2021 accounts revealed those 24 prohibited donations, why did it not catch all the rest?  Since it didn’t, ABC got to keep and use the money for a further year and a half, through the civic election and beyond.

• While LECFA does not disallow contributions from minors, is it reasonable to infer that donations from toddlers made the same day as their parents are “indirect” and therefore prohibited?

• What conduct on the part of a financial agent, EO, or donor would merit imposition of the maximum monetary penalty?

No response being forthcoming in more than a month, I wrote again on October 8, asking to be directed to someone who could answer my questions. I explained I was “preparing an article for the edification of Vancouver voters and would vastly prefer to leave them with greater understanding of EBC’s compliance/audit/penalty process than I have been able to get since I began looking into ABC’s prohibited contributions in the spring of 2023.”

I reiterated the questions of my earlier letter and asked a few more:

• What public record shows the January 2021 appointment of Corey Sue? 

• Why did EBC penalize Sue for accepting prohibited contributions from only 8 of 46 people who had donated to both ABC and Ken Sim in 2021?

• Why did EBC penalize Sue for not promptly returning prohibited donations from only one of six people who got their refunds on the same date?

• Why do refunded donations not appear as such in FRPC?  It’s not as if they were never made.

No response to either letter has yet been received.

At it again?

One of the factors in the leniency of the penalty assessed against Corey Sue was that he “has not previously been the subject of a monetary penalty under LECFA.”  Well, that factor won’t help next time. 

Judging from the disclosures and data postings concerning the April 2025 by-election, ABC has learned nothing from the investigation and penalty. It’s business as usual.

A September 26 FRPC search for by-election donations yielded a list of 188 records of donors to ABC who ponied up a total of $172,970.20.  Surprisingly, all the donations had been made since January 1 of this year. Surely ABC had been fundraising for the by-election as soon as it was on the horizon?  Of course they had, according to their scanned by-election disclosure.

Form 4404 is the document in the by-election disclosure that details donors whose contributions add up to $100 or more (known as “significant contributors”), and all parties hope that it will run to many pages.  ABC’s Form 4404 covers sixteen pages and details more than $387,000 in donations, starting in August 2024.  The day I first checked, records from the final seven pages were to be found in FRPC, but not from the first nine.   

Those first nine pages, which turned up later, revealed several contributions in excess of the 2024 annual limit ($1370.68) or the 2025 limit ($1402.40).  They add up to $3939.04.  Not an earth-shattering amount in the scheme of things, but a financial agent is supposed to notice, while recording a donation, that it is more than is allowed.  And to remember that Ken Sim had already donated in September when he donated again in December, putting him over the annual limit for 2024.

I wrote to Elections BC on September 27^th  querying the missing pages. Compliance Officer Greg Macdonald promptly replied that an error had occurred during publication. The contribution data in FRPC has now been updated and matches what was in the by-election disclosure.

But the fundraising total in the disclosure is still wrong, reflecting only seven pages and all from 2025. 

A closer look at ABC’s 2024 Annual Financial Report – the required annual report that’s supposed to include details of all donations for the year -- turned up interesting results. It does not show $71,830 worth of donations from 52 significant contributors listed on the by-election disclosure as having been donated in 2024. Why were their contributions omitted from the 2024 Annual Financial Report when other by-election donors are there?

I wrote again to Mr. Macdonald with these observations and a list of the missing names.  He thanked me for the information and replied that EBC’s scrutiny of the Vancouver by-election disclosures is ongoing.

Probably not as soon as “practicable”

LECFA requires election disclosures to be filed within 90 days of election day. From the time ABC filed its first 2022 election disclosure to the date of Elections BC’s commencing an investigation was a year and a quarter. The investigation took just about as long to conclude. 

ABC’s 2025 by-election disclosure was filed June 30^th.  What’s the likelihood we’ll see a resolution to their latest eccentric accounting before Vancouverites go to the polls next October?

I am grateful to Carol Volkart for her editorial advice. - S.R.

Further reading: 

How ABC and Ken Sim Skipped Campaign Financing 101 and Came Out Ahead (February 2024)

The ABCs of Local Election Campaign Contributions (March 2024)

The ABCs of Local Election Campaign Contributions, Part II  (March 2024)

The BC Local Elections Campaign Financing Act is a Farce (by Sasha Izard, October 2025)

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APPENDIX

Correspondence over the course of 28 months and counting

I appreciate the prompt and helpful responses I have received from the EBC Compliance Officers at the other end of electoral.finance@elections.bc.ca. Further up the food chain, not so much.

Letter No. 1,  Sal Robinson to Elections BC

June 16, 2023

Subject: seeking clarification of local election contributions

Please clarify this statement from page 16 of the Guide to Local Elections Campaign Financing for Elector Organizations:

“An eligible individual cannot contribute more than the annual campaign contribution limit to any elector organization and its endorsed candidates.”

If an elector organization endorsed a candidate for mayor and two candidates for council, could a single individual contribute $1250 in 2022 to the EO, as well as to each of the three candidates, for a total of $5000?  I’ve been seeing this scenario in FRPC searches.

And another query regarding something I’ve run across on the FRPC… If a person is recorded as having contributed to a single candidate four times in one year (for a total $4800 in 2021), and that error was spotted and corrected, would it still appear in the system?

Response No. 1,   Ania Avila, Compliance Officer, EBC to SR

June 21, 2023

If an elector organization endorsed a candidate for mayor and two candidates for council in the same jurisdiction, a single eligible individual could not contribute more than $1250 in 2022 to the elector organization and the three candidates in total. If a contributor has exceeded the contribution limit, the excess amount is a prohibited contribution, and the funds must be returned to the contributor or remitted to Elections BC.

If a prohibited contribution was discovered and corrected in an amended election financing report, a copy of the amended report would be made publicly available along with the original report in our Financial Reports and Political Contributions System. The searchable contribution data would also be updated when the correction was received.

As the Electoral Finance Audit & Assessment team are currently reviewing election financing reports for compliance, there may be remaining reports awaiting corrections.

Please let me know if you have any additional questions.

Letter No. 2,  TEAM to Anton Boegman, Chief Electoral Officer, EBC

July 5, 2023

Subject: 2022 Municipal Campaign Contributions

Dear Mr. Boegman,

After reviewing the publicly available 2022 municipal campaign donation lists for Vancouver parties

and candidates, TEAM members noticed multiple entries that appeared to be possible violations of the Local Elections Campaign Financing Act (the Act). I have been asked to bring them to your attention.

We noticed on the donor contribution lists of the ABC Party that there were several names with maximum allowable contributions made to the party and to candidates on more than one occasion in the same calendar year. For example, there are names that in 2021 and 2022 appeared to donate the maximum allowable contribution on two or more occasions in each year. It is our understanding that the Act only permits up to a maximum dollar amount of $1250.00 per year from an individual. The maximum allowable annual amount was $1239.18 in 2021. This would mean that some donors gave over their maximums each year, and that ABC accepted prohibited contributions. A quick addition of the donations we found made in this manner total over $100K in 2021 and approximately $15K in 2022. We did not review contributions accepted prior to 2021.

We also noted a lesser number of contributions that appeared in violation as anonymous contributions over the anonymous donation limit and contributions from ineligible entities such as corporations.

As a critical part of your mandate is to ensure fair elections through the enforcement of campaign contribution laws, you may wish to undertake a thorough review of the donations made to the ABC party and its candidates in the years since its inception until the recent election. We have not provided the specific names that rose to our attention as presumably you will find them, but we can do so if requested.

Yours truly,

Cleta Brown

President, TEAM Board of Directors

Response No. 2, Stephanie Phelan, Compliance Officer,  EBC to TEAM

July 7, 2023

Thank you for bringing this to our attention, we will look into the matter. Reports on the website appear as they are submitted. The review process for the 2022 General Local Elections campaign financing reports is still underway so some reports may yet be amended.

A second response No. 2, Patrick James, Team Lead, Audit and Assessment, EBC to TEAM

July 20, 2023

Subject: 2022 Municipal Campaign Contributions

I was forwarded your letter regarding campaign contributions received by the elector organization ABC Vancouver.

Thank you for highlighting your concerns. You are correct that an eligible individual cannot contribute more than the annual campaign contribution limit to any elector organization and its endorsed candidates.

The information provided has been noted and will be considered during the review of ABC Vancouver’s disclosure statements. I can not speak to specifics regarding individual reviews.

Any amendments to the report and contribution information will be posted on our Financial Reports and Political Contributions System.

Please let me know if you have any questions.

Letter No. 3, SR to Ania Avila, Compliance Officer, EBC

October 16, 2023

Subject: RE: seeking clarification of local election contributions

I do have another scenario as I try to understand the rules fully: 

Three unaffiliated persons, planning a 2022 run,  collected contributions in 2021 and all gained the endorsement of the same EO in 2022.  Their contributions came with them, so that an individual who donated the maximum amount to each of them in 2021 appears in the post-election EO’s disclosure as having contributed triple the maximum allowable that year.

Is this a loophole or must the excess 2021 money be returned to the donor?

Response No. 3, Ania Avila, Compliance Officer, EBC  to SR

October 19, 2023

If the three initially unaffiliated candidates all gained the endorsement of the same EO in 2022, the financial agent for each candidate must give the elector organization’s financial agent the candidate’s contribution information which includes contributions made in 2021 and 2022. The financial agent for the elector organization must ensure that contributions from eligible individuals do not exceed the campaign contribution limit. If a contributor has exceeded the campaign contribution limit, the excess amount is a prohibited contribution, and the funds must be returned to the contributor or remitted to Elections BC.

For elector organizations that endorse candidates in multiple jurisdictions, eligible individuals may contribute up to the limit to each of the elector organization’s campaigns during a calendar year.

Please let me know if you have any additional questions.

Letter No. 4, TEAM to Anton Boegman, Chief Electoral Officer, and  Patrick James

Team Lead, Audit and Assessment, EBC  [chart referred to below not reproduced here]

October 19, 2023

Dear Mr. Boegman  and Mr. James,

Further to my letter of July 5, 2023, please find attached a chart, drawn from publicly disclosed documents, outlining apparent unlawful contributions and ineligible contributors to the Vancouver municipal election campaign of the ABC party and certain of its candidates.   The chart reveals many individuals who appear to have contributed  in excess of the LECFA annual financing contribution limits to the ABC party and candidates.  There are also instances where the contributor is not a person or names are incomplete, negating any ability to identify them, thus making them ineligible contributors.  

The scope of the apparent violations is significant and strongly points to a pattern of misconduct -  of deliberately soliciting and accepting unlawful contributions – rather than occasional inadvertent lapses.  The chart reveals a potential over-the-limit amount of $119,528.30 accepted by ABC over the course of 2021 and 2022. 

The intent of the LECFA is to fix a ceiling on what an individual may contribute annually to a candidate or to an elector organization’s treasury.  How, then, are formerly unaffiliated candidates permitted to pool their resources - as apparent on the chart - when they are later endorsed by the same party?  Is this strategy within the spirit of the legislation?  

Even if such a loophole allows for de facto “limitless” donations, considering only 2021 and 2022 contributions to ABC and Ken Sim, and not including the formerly independent council candidates who joined Sim to run under the ABC endorsement,  there are excessive contributions of more than $68,000.

On August 8, 2020, Vancouver’s Province newspaper reported on the circumstances and outcome of a campaign compliance investigation your office concluded regarding campaign loans made by Ken Sim when he ran for mayor in 2018. You found that Sim’s loans to his campaign were violations of the LECFA but no penalty was assessed  as the violation was considered to be a mistake.

Undoubtedly these new breaches of the LECFA have already been brought to your attention, as my previous letter raised this issue and the entries are not hidden.  TEAM was a competitor party in the Vancouver election and with an entirely volunteer staff strove diligently to adhere to the campaign contribution rules.  The ABC financial agent and certain of its candidates appear to have flouted these rules which were designed to “level the playing field.”  The ABC party had a war chest for the campaign that was substantially larger than all of the other parties.  Mr. Sim has a history of campaign finance violations and is a sophisticated accountancy-trained businessman.  It is imperative that the legitimacy of the ABC campaign funds be ascertained.

Could you please advise whether the outcome of your investigation/review of their campaign financial disclosure documents will be shared with the Vancouver voters?  In the case of the LECFA violations you found with the Progress Vancouver party, your decision and reasoning were made public.   Should you decide that violations did in fact occur by the ABC party, will you be publicizing this decision and the criteria for any penalty assessed?  There is compelling public interest in this matter.

Yours truly,

Cleta Brown

President, TEAM Board of Directors

Response No. 4, Patrick James, Team Lead, Audit and Assessment, EBC to TEAM

October 19, 2023

Thank you for your email and the additional information.

Our review of ABC Vancouver is ongoing. Overcontributions and incomplete contributor information (partial names) are addressed as part of the review and audit process.

Candidates who raise funds prior to becoming endorsed are required to provide their contribution listings to the financial agent for the elector organization at the time of endorsement (or as soon as possible thereafter). Contributions received above the limit shared by a group of endorsed candidates are required to be returned. This process is outlined in section 30.05 of the Local Elections Campaign Financing Act (LECFA).

At the conclusion of our review, all contraventions discovered will be forwarded to our Investigations team for consideration of administrative monetary penalties (AMPs). Accepting contributions above the limit can result in AMPs, as outlined in sections 68.13-68.18 of LECFA. All AMPs are posted publicly here: https://elections.bc.ca/resources/investigations/administrative-monetary-penalties/.

Please let me know if you have any additional questions.

Letter No. 5, SR to EBC

March 5, 2024

Subject: FRPC should maintain records of all contributions, thus allowing public scrutiny

Dear EBC folks,

I have been spending considerable time attempting to track contributions and refunds in my research of who supports whom in Vancouver civic politics.  In doing so I have encountered what I consider a serious obstacle to public scrutiny of campaign financing.

PROBLEM: Elections BC’s searchable database, the Financial Reports and Political Contributions System (FRPC)  deletes records of prohibited contributions after they have been returned to donors.  This is counter to the mandate of transparency in local election financing.

Prohibited contributions may still be found by reading scanned documents, but those are not searchable, and you have to know that there’s even something to look for.

As one example, prohibited contributions were accepted in 2021 by candidate Ken Sim, endorsed by ABC Vancouver, seen in this screen shot of data I exported from FRPC  in October 2023.

They were returned to the donor on December 12, 2023, according to ABC’s amended 2022 Election Disclosure Statement of that date. Also returned, apparently, was the donation of 2020/09/18, though I can’t find a record of it as a prohibited contribution on either Sim’s or ABC’s amended disclosures. If not for my data export I would never know it happened.

Below is a screen shot taken today of this donor’s contributions.

It is in the public interest to know that for more than two years candidate Ken Sim had the use of $4760.82 in prohibited contributions for his campaign, and from a single donor.  This amounts to a prohibited loan that is not in the public record. This example is the tip of the iceberg of prohibited contributions accepted and refunded by ABC.  My current total is a whopping $128,094.51 refunded by ABC as of mid-February 2024.   (Another chunk of the iceberg is a total of $6964.92 “loaned” from Ken Sim and his family, donated on November 16, 2021 and returned 25 months later.  After his 2018 experience, Mr. Sim must surely be aware of the issue of prohibited loans to his own campaign.)

Citizens interested in knowing who is funding their local campaigns are not served by a system that deletes returned contributions with neither record nor explanation.

SOLUTION: The addition of three columns to the FRPC database.

• one for the amount of a refunded prohibited contribution

• one for the date of the refund

• one indicating the reason why the contribution was prohibited (over the limit, indirect, etc.)

I hope you will consider making these improvements to the Financial Reports and Political Contributions System.

Response No. 5, Amber Lindquist, Senior Compliance Services Representative, Compliance Services EBC to SR

March 8, 2023

Thank you for the feedback on how to improve FRPC. We will consider how to incorporate this information into a future enhancement.

Prohibited contributions are removed from the contribution forms, as well as the Election Contribution search, when they are returned. An overcontribution for Kim Kawaguchi was identified during the compliance review process and was returned to the contributor. When the overcontribution was returned, the financial agent removed the contribution from Form 4303 and reported the over contributions as prohibited contributions on Form 4306. There are 3 separate lines for the over contributions returned to this contributor that were originally received in 2021. This is reflected on page 50 of Ken Sim’s disclosure statement, amendment #2.

As you noted, information relating to prohibited contributions is included in scanned reports. These reports include text recognition to support searching for specific contributor names. If you encounter a report that is not text recognized, please let our office know so we can add this feature.

If you have any questions or note other discrepancies, please email our team at electoral.finance@elections.bc.ca.

Letter No. 6, TEAM to Anton Boegman, Chief Electoral Officer, EBC

March 18, 2024 

Dear Mr. Boegman,

I am writing with deep concern about the lack of progress apparent in your office’s audit of ABC Vancouver and with the want of transparency in the Financial Reports and Political Contributions System regarding its prohibited contributions.

In the fourteen months since 2022 General Election Disclosure Statements were filed, your office has posted details of administrative monetary penalties for nine candidates who were deemed to have made or accepted prohibited contributions during their 2022 civic election campaigns. Four were issued on December 5, 2023 and five three months later on March 5, 2024.  Each outlines a single infraction made by the candidate.

Director of Investigations Adam Barnes notes in his Notice of Enforcement to the offending candidates that “Accepting a prohibited contribution gives a candidate an advantage in that the candidate did not need to seek a contribution of that amount from an eligible source, saving the candidate time during a busy campaign.”

One electoral organization in Vancouver had a colossal advantage.

In the Vancouver municipal jurisdiction, candidate Ken Sim has been required to return fifteen prohibited contributions totalling $17,904.10 because they were over the limit in a calendar year (2020 or 2021), or came from a corporation, or from a non-B.C. resident. 

Sim’s electoral organization,  ABC Vancouver, has been required to refund a further 127 contributions totalling $115,140.41, prohibited for a variety of reasons: contributed by a corporation; the donor was over the annual limit because of contributing to both Ken Sim and ABC; the donor was over the annual limit because of contributing to multiple candidates who were later endorsed by ABC; the donor contributed over the annual limit to ABC; unknown because they are not stated in ABC’s 2022 General Election Disclosure Statement, Amendment 3, page 72.

While some (19) of these refunds took place in July, 2022, the vast majority of donors got their money back in December 2023.  The 47 supporters who gave to both Sim and ABC got theirs an average of 24 months after they contributed it, for all intents and purposes nearly four dozen two-year prohibited loans.

What will be the process for assessing penalties on multiple infractions made by a candidate and elector organization? Will there be dozens of Notices of Enforcement?  How long will it take before Vancouver’s voters are made aware of the magnitude of the financial transgressions made by the campaign of the party now holding a majority of city council seats?

Everything I’ve mentioned here is in the public record, but a person looking for the prohibited contributions we forwarded to your office last October would not find them today, and that is a flaw in the FRPC that could be corrected quite simply.

Once prohibited contributions have been returned to their donors, they no longer appear in the Local Election Contributions Search Results.  Why don’t they?  The public should be able to clearly find information on what donors funded their local election campaigns, and by how much those broke the rules, if they did. Instead, prohibited donations are erased from the easily-searchable record and inquisitive voters must looked to scanned documents for information – an onerous and time-consuming process.

The addition of three columns – “Amount of Prohibited Contribution,”  “Reason” and “Date of Refund” –  to the FRPC search results database would keep all the information in a single, accessible place. 

Yours truly,

Cleta Brown

President, TEAM Board of Directors

Response No. 6., Aidan Brand, Senior Director, Corporate Planning and Strategic Initiatives, EBC to TEAM

March 21, 2024

Subject: RE: Audit progress and FRPC transparency

Dear Cleta Brown,

Thank you for your email, and for sharing your concerns with us. Chief Electoral Officer Anton Boegman has asked me to respond on his behalf.

Our compliance and enforcement work related to the 2022 General Local Elections is ongoing. This work is complex and takes time. It includes ensuring that all prohibited contributions are dealt with in accordance with the Local Elections Campaign Financing Act.

We are fully committed to reporting publicly on our compliance and enforcement work once it is complete. Any administrative monetary penalties we levy are reported publicly on our website here. This page is updated every Wednesday, as required. Enforcement notices may include a single or multiple infractions.

Thank you for your feedback on our Financial Reports and Political Contributions (FRPC) system. We will consider the points you have raised in future improvements to this system.

Letter No. 7, TEAM to Anton Boegman, Chief Electoral Officer, EBC

August 13, 2024

Dear Mr. Boegman,

In the thirteen months since I first wrote to you with concerns about irregularities in donations to Ken Sim and the ABC Vancouver electoral organization, we have seen Sim and  ABC refund some $120,000 in prohibited contributions to their supporters in December 2023 and June 2024.  

These prohibited contributions tracked consistently with the data we provided to EBC in October.  Sim has amended his 2022 General Election Disclosure Statement three times; ABC’s 2022 General Election Disclosure Statement has been amended four times. 

A list of potential indirect contributions to Ken Sim and/or ABC from children, one as young as two, was provided to your office in January; a check today of FRPC finds those donations still active.

Elections BC’s April 11 announcement that ABC Vancouver, along with four other Vancouver electoral organizations, was under investigation gave us hope that news of a resolution would come soon.

The 2022 General Local Elections Report released July 18 notes that investigation process can be as lengthy as “over a year.”

In a normal local election cycle, even the lengthiest investigation would surely be concluded before the next campaign begins.  But Vancouver voters may face a by-election if one of our current councillors is successful in her provincial bid this coming October.

Of the five Vancouver elector organization investigations announced in April, some are of parties that may run candidates in a by-election.   Indeed, ABC Vancouver has already advised its supporters of the need to raise $250,000 “to elect another councillor.”

Will Vancouver voters have a determination of the campaign financial integrity of sponsoring electoral organizations before they go to the polls?

Yours truly,

Cleta Brown

President, TEAM Board of Directors

Response No. 7,  Cameron Harrison, Investigator, EBC to TEAM

August 15, 2024

Thank you for your email of August 13, 2024 and the information you have previously provided.

 Our investigation remains ongoing and active. Because you are listed as a complainant on the file, you will be notified when the investigation concludes. Additionally, if administrative monetary penalties are issued, you will find them on our website here.

(EBC sent TEAM a second response to Letter No. 7 on June 27, 2025, after the April 5 by-election. It is included below.)

Letter No. 8, four Vancouver civic parties to Anton Boegman, Chief Electoral Officer, EBC

December 21, 2024

Sent by Priyan M. Samarakoone on behalf of The Green Party of Vancouver,

TEAM for a Livable Vancouver, One City Vancouver, Coalition of Progressive Electors 

Mr. Anton Boegman

Chief Electoral Officer

Re: LECFA compliance, penalties for ABC Vancouver and up-coming by-election. 

Dear Sir,

We, the undersigned, have grave concerns that Elections BC has failed to hold ABC Vancouver {ABC} accountable to the standard required by the Local Elections Campaign Financing Act (LECFA).

As early as July 2023 TEAM for a Livable Vancouver wrote to you outlining excess contributions of at least $115,000 accepted by Mayor Ken Sim and by ABC. In January 2024, it was publicly reported that ABC had repaid $116,000 of prohibited contributions to its donors for the 2022 municipal election campaign. At that time, Elections BC stated that it was reviewing ABC’s amended report. To date, no further action against ABC Vancouver has been announced. Some of these breaches occurred as long as three years ago and your department clearly should have investigated and addressed the matter.

In view of the upcoming Vancouver municipal by-election, we believe it is incumbent on Elections BC to complete its investigation and apply any penalties it deems is warranted, recognizing the substantial illegal advantages ABC realized by its misconduct:

• It had access to prohibited campaign contributions during the campaign.

• It avoided expenses required for financial monitoring and internal management during the campaign.

• It did not reject donations during the campaign, thus avoiding giving offense to potential voters or donor networks.

• It was enabled to announce inflated fundraising totals during the campaign, both internally and publicly.

ABC campaigned on  a platform of fiscal honesty and competence yet these benefits of misconduct could reasonably be expected to have significantly affected the voting outcome.  Your continued failure to publicly address the matter is bound to affect the outcome of the upcoming by-election.

Enhanced penalties are required to recognize that ABC Vancouver delayed returning some of the excess contributions for a period of up to 30 months, when the law plainly states that erroneous contributions must be returned within 30 days. You should consider this inordinate delay in your assessment of their conduct.

Our organizations all made strict observance of the campaign finance rules, a key compliance factor during the 2022 municipal election. While a few errors were identified after the campaign, they were relatively minor and quickly resolved by our Electoral Organizations, as required by Elections BC under relevant law. We absolutely expect ABC Vancouver to be held to the same standards as its opponents---which does not appear to be the case.

Further, we have been advised that additional prohibited sources of money listed on the ABC Vancouver campaign 2022 finance records may have been overlooked in the first round assessment and may be subject of an investigation and further compliance audit by Elections BC. These concerns relate to potential indirect contributions, out-of-province and corporate donations, based on the limited public disclosures currently available. If Elections BC is not already aware of these potentially illegal funding sources, we can provide some details to the limited extent of our knowledge.

We are calling on Elections BC to promptly execute its expected statutory obligations to reinforce election fairness and support compliance with campaign finance rules before the expected Spring 2025 Vancouver by-election. Public faith in the integrity and effectiveness of Elections BC is at stake,

We look forward to your prompt and comprehensive response to the questions and concerns we have raised and would be pleased to meet with you to discuss the potentially illegal funding sources referenced above.

Letter No. 9, TEAM to Anton Boegman, Chief Electoral Officer, EBC

December 23, 2024

In July 2023, TEAM for a Livable Vancouver wrote to you about excess contributions of at least $115,000 accepted by Vancouver mayor Ken Sim and ABC Vancouver (ABC). It is now more than a year since ABC refunded $116,000 of prohibited contributions to its donors for the 2022 municipal election campaign. Some of these breaches occurred over three years ago and your department clearly should have investigated and addressed the matter.

Your April 11 media advisory that an investigation had been initiated, and June 5 update that it was ongoing, gave us cause to hope that a decision was imminent.

It is now more than four months since we last wrote to you about our concerns that Elections BC has not held ABC accountable for its failure to meet the standard required by the LECFA, and that Vancouver electors might go to a by-election in 2025 without a resolution of this issue.  Recognizing that the problem is not limited to eligible donors giving too much, we wrote at that time that a list of potential indirect contributions to Ken Sim and/or ABC from children, one as young as two, was provided to your office last January; a check today of FRPC finds the status of those donations -  made more than four years ago - unchanged.

For all of the reasons that LECFA was enacted, we ask you to ensure that Vancouver elector organizations who respected both the spirit and the letter of the law in the 2022 election will be competing in an atmosphere of fairness in the upcoming by-election, and that your determination on the ABC investigation be made public promptly.

Vancouver voters are entitled to know how the ruling party conducted itself. Public faith in the integrity and effectiveness of Elections BC is at stake.

We look forward to your comprehensive response to the concerns we have been raising for nearly a year and a half.

Response to Letters No. 8 and 9: nil

Second response to Letter No. 7, Cameron Harrison, Investigator, EBC to TEAM

June 27, 2025

This email is in response to your letter on August 13, 2024.

Please see the Media Advisory posted to our website here.

Elections BC has issued administrative monetary penalties (AMPs) against the financial agent for ABC Vancouver and Ken Sim. The AMPs issued are for accepting prohibited contributions and failing to return prohibited contributions.

Letter No. 10, SR to Adam Barnes, Director of Investigations, EBC

25 July, 2025

Dear Mr. Barnes,

Having studied your Enforcement Notice on Corey Sue (EBC File 15110-30/2024/141), I don’t understand why Ken Sim was able to collect, with impunity, more than $14,200 in prohibited contributions in 2021.

Ken Sim broke this rule in 2018 when he was a mayoral candidate, and made a personal loan to the campaign:

Campaign contribution limits: An eligible individual cannot contribute more than the annual campaign contribution limit to any elector organization and its endorsed candidates. This limit includes any loans made by an eligible individual to an elector organization.  

That is also the rule that Ken Sim broke on November 16, 2021, when he and five family members each contributed the maximum to the electoral organization that endorsed him, when they had all already contributed the maximum to candidate Sim on February 25, 2021.  As a financial agent, how could Sim not have known those second contributions were prohibited?   Since those excess contributions were not refunded until over two years later, on December 20, 2023, this was, in effect, a personal loan Sim made to his own campaign. Again.

In 2021, Sim accepted the maximum contribution four times each from two people, three times from two more, and twice from two more.  In five cases the donations were made only two weeks apart.

Why is Ken Sim not responsible for the prohibited contributions he accepted prior to appointing Corey Sue as his FA on September 14, 2022? 

Candidate:   In relation to candidate obligations applicable under LECFA, an individual who:

(a) intends to become a candidate in an election

Financial agent: A representative that a candidate and elector organization is required to appoint. A candidate may either act as their own financial agent or appoint another individual to this position.

If I were, today, to declare my intention to become a candidate and, acting as my own Financial Agent, start collecting money from my generous friends and supporters, some of whom contribute quadruple the annual limit, then a year from now appoint a different person as my FA, would I be absolved of liability to monetary penalties for my repeated failure to act according to the rules imposed by LECFA?

Please explain why LECFA allows for such a scenario.

Yours truly,

Sal Robinson

Response to Letter No. 10, Adam Barnes, Director of Investigations, EBC, to SR

August 21, 2025

Dear Sal Robinson,

Thank you for your email of July 25, 2025. I will address your points below.

Elections BC issued Corey Sue a $5,680 monetary penalty for accepting $14,204.10 of prohibited contributions, in their role as financial agent for Ken Sim. You can find that on page 5 of the Enforcement Notice here. Under the Local Elections Campaign Financing Act (LECFA) a penalty is often against a financial agent as the individual who accepted the prohibited contributions. Because Corey Sue was Ken Sim’s financial agent and he accepted the prohibited contributions, the penalty was issued to Corey Sue.

Some of the contributions you appear to be concerned about are excess campaign contributions under s. 30.05 of LECFA rather than prohibited contributions. While ABC reported those contributions as prohibited on form 4451s, they were excess not prohibited contributions. Excess contributions are contributions that have been accepted by a candidate and elector organization separately, that when combined exceed the contribution limit. Unlike prohibited contributions, excess contributions are not subject to monetary penalties under LECFA. Our investigation determined no further enforcement action was warranted, and we issued a warning letter to Corey Sue.

To further clear up some potential confusion, according to our records Corey Sue was appointed as Financial Agent for Ken Sim on January 22, 2021.

Sincerely,

Adam Barnes, Director, Investigations

Letter No. 11, SR to Adam Barnes, Director of Investigations, EBC  [list referred to below not reproduced here]

September 2, 2025

Subject: RE: Enforcement notice query

Dear Mr. Barnes,

Thank you for your reply.  Your statement that Corey Sue has been Ken Sim’s FA since January 22, 2021 creates more confusion than it clears up.

I see how s. 30.05 of LECFA is applicable to the contributions received by the three formerly independent candidates (Bligh, Dominato and Kirby-Yung) before their endorsement by ABC.  Sue should have scrutinized these once he became their FA in order to prevent ABC receiving “excess contributions” from their donors, though seemingly did not.  More than $30,000 donated to them in 2021 was not refunded until some fifteen months after Sue was appointed their FA.  It’s hard to believe this was “as soon as practicable.”

But  s. 30.05 (2)  “As soon as practicable after an elector organization endorses a candidate in an election, the financial agent for the candidate must provide to the financial agent for the elector organization the following information…”  is nonsensical in relation to the FA for Ken Sim and the FA for ABC if they are one and the same person.  Corey Sue had Sim’s donor information if he’d been his FA since long before his apparently unnecessary September 2022 appointment.  Either Sue was already Sim’s FA, or he wasn’t.

Sim’s Campaign Financing Arrangement, signed by Sim on September 14 and Sue on September 15, is clear enough.  But your records contradict that, and the date is critical.

If Ken Sim had been acting as his own FA in 2021, he would be responsible for improperly accepting multiple donations to his own campaign, but blameless regarding the duplicate contributions his donors made to ABC late that year. Sue’s January 2021 appointment as Sim’s FA makes a huge difference in reducing Sim’s exposure to any penalty and surely increases Sue’s, because so much more money is involved.

From data I exported from FRPC in July 2023 I found that, in addition to the donors and contributions named in your enforcement notice, 35 people donated to both Sim and ABC in 2021, for a total of $83,939.18. Three more people donated to both Sim and ABC in 2022, for a total of $7450.  The $44,357.06 in combined prohibited – or “excess” –  contributions (see below) are among those refunded by ABC on December 20, 2023, all but three more than two years after Sue accepted them. 

Can s. 30.05 (4) through (8) be interpreted in any other way than that once the FA discovers an excess contribution, he must ensure it is refunded “as soon as practicable” and that failure to do so is an offence? 

In a January 2024 interview regarding those prohibited donation refunds, Sue explained that most of them stemmed from the party’s “unique situation with four independent candidates doing their own thing before joining ABC.”  (It may well have been a “unique situation” but not one unanticipated by the Guide to Local Elections Campaign Financing for Elector Organizations.)  One of those four independent candidates was Ken Sim.

In his position as FA for both Sim and (as of November 30) ABC in 2021, with responsibility for ensuring campaign contributions from eligible individuals did not exceed the contribution limit, it is astonishing that Sue failed to notice that so many donors to Sim were also donors to ABC.

Another 22 people who donated in 2021 received refunds of 24 prohibited contributions on July 11, 2022, according to page 72 of  Amendment 3  of ABC’s 2022 General Election Disclosure Statement. The same list appears in  Amendment 1 of ABC’s 2021 Annual Financial Report, filed July 11, 2022. None of those people are named in your enforcement letter, and only one appears in the list below.  The July 11 list totals $18,761.64.

Adding the above to the totals in your enforcement letter, Corey Sue’s non-fulfillment of his FA responsibilities would amount to over $90,000.

If scrutiny of the 2021 accounts revealed those 24 prohibited donations, why did it not catch all the rest?  Since it didn’t, ABC got to keep and use the money for a further year and a half, through the civic election and beyond.

So, again I am seeking clarification of how ABC’s records kept as required by LECFA could produce this result.

Noting that s. 30.06 requires that an electoral organization be registered in order to accept  a campaign contribution, and that s. 30.07 requires that the EO have a financial agent in order to be registered, I wonder who was accepting donations to ABC as early as October 14, 2021 and a transfer from Ken Sim a month before that (see Sim’s 2022 General Election Disclosure Statement) if Corey Sue was not appointed as ABC’s FA until November 30, 2021?

On a separate topic, while LECFA does not disallow contributions from minors, is it reasonable to infer that donations from toddlers made the same day as their parents are “indirect” and therefore prohibited?

And a final question: What conduct on the part of a financial agent, EO, or donor would merit imposition of the maximum monetary penalty?

Yours truly,

Sal Robinson

Response to Letter No. 11: nil

Letter No. 12, SR to EBC

September 27, 2025

Subject: Query about FRPC missing data and prohibited contributions to ABC in Vancouver 2025 by-election

In scrutinizing election contributions to ABC Vancouver in the 2025 by-election, I note that only 188 records are showing in the Financial Reports and Political Contributions System, as seen in this screen shot, and that the total for the search is $172,970.20. 

That same total is reported on Form 4403 of ABC’s disclosure statement (https://contributions.electionsbc.gov.bc.ca/pcs/lepublished/100149716.pdf) and is perplexing, because nine more pages of contributions are present in Form 4404 than appear in FRPC, and the total of all pages is $387,058.72.

Even if the first nine pages had been accidentally omitted from the upload process and only the final seven made it into the FRPC database, that would not explain the agreement of the totals.

Problematic details:

Three donations in one day, December 5, 2024, of $1370 from Cecilia Wong, an over-contribution of $2789.32.

A donation on March 13, 2025, of $1750, from Sonya Wall, an over-contribution of $347.60

A donation on March 13, 2025, of $1750, from Helen Hall, an over-contribution of $347.60

A donation on March 13, 2025, of $1500 from Colin Wall, an over-contribution of $97.60

A donation on March 13, 2025, of $1750, from Charlotte Wall, an over-contribution of $347.60

Total donations in 2024 (September 13 and December 1) totalling $1380 from Ken Sim, an over-contribution of $9.32.

And curious accounting of negative donations on August 28, 2024 from Cyrus and Pilar Navabi, who both donated positively on September 26.

I can’t make sense of this; maybe you can.  Why weren’t all the contributions uploaded to FRPC, and where did the difference of some $214K go?

Response to Letter No. 12,  Greg Macdonald, Compliance Officer, EBC to SR

October 2, 2025

Hi Sal Robinson,

Thank you for bringing these concerns to our attention.

You are correct that the contribution totals differed between the published disclosure statement and the contribution data in FRPC. This oversight occurred during publication. Our office has updated the contribution data in FRPC to match what was disclosed in the disclosure statement forms.

We have noted your concerns regarding the transactions you describe as problematic. As our compliance process for the by-election is still ongoing, we cannot speak to specific contributions at this time.

I trust this information will assist you. Please reach out again if you require more information.

Letter No. 13, SR to Greg Macdonald, Compliance Officer, EBC [list referred to below not reproduced here]

October 2, 2025

Thanks for your prompt response.  I remain mystified about why the value of campaign contributions (Form 4402) is only $172,970.20 when the total in the updated FRPC is $387,127.72.

Another issue is raised by a  comparison of ABC’s 2025 by-election donors and their 2024 Annual Financial Report.  I found 52 people (see list below) who, in 2024,  contributed a total of $71,830.00 to ABC’s by-election campaign whose names do not appear in ABC’s 2024 Annual Financial Report for the civic jurisdiction.

Shouldn’t all 2024 contributions be reported in the 2024 Annual Financial Report?

Response to Letter No 13, Greg Macdonald, Compliance Officer, EBC to SR

October 10, 2025

Thank you for bringing this information to our attention.

As I mentioned before, as our compliance process for the by-election is still ongoing, we cannot speak to specific contributions at this time. However, generally, we do expect all campaign contributions collected by an elector organization during a calendar year to be reported in the annual financial report for that year.

Letter No. 14, SR to Adam Barnes, Director of Investigations, EBC

October 9, 2025

Dear Mr. Barnes,

Please direct me to the person who can shed light on my questions, if you are not in a position to do so. 

I am preparing an article for the edification of Vancouver voters and would vastly prefer to leave them with greater understanding of EBC’s compliance/audit/penalty process than I have been able to get since I began looking into ABC’s prohibited contributions in the spring of 2023.

In my letter of September 2, 2025 to which I haven’t had a reply, I asked these specific questions:

• Can s. 30.05 (4) through (8) be interpreted in any other way than that once the FA discovers an excess contribution, he must ensure it is refunded “as soon as practicable” and that failure to do so is an offence? 

• If scrutiny of the 2021 accounts revealed those 24 prohibited donations [refunded July 11, 2022], why did it not catch all the rest?

• Is it reasonable to infer that donations from toddlers made the same day as their parents are “indirect” and therefore prohibited?

• What conduct on the part of a financial agent, EO, or donor would merit imposition of the maximum monetary penalty?

In addition to those, I would be grateful for answers to these:

• Which date did Ken Sim appoint Corey Sue as his financial agent: September 14, 2022 according to the publicly available document they both signed, or January 22, 2021 according to Elections BC records – and what public record shows that? The date affects each man’s liability to monetary penalties and to appearing careless or incompetent.

• How is it decided which excess contributions are refunded when a supporter has donated to two or more formerly independent candidates who are later endorsed by a party?

• Why did EBC penalize Sue for accepting prohibited contributions from ten people who had donated to both ABC and Ken Sim in 2021, and ignore the 38 others who had done exactly the same thing?

• Why did EBC penalize Sue for not promptly returning prohibited donations from one person, when five others got their refunds equally late in the game?

• And concerning those six people, how stringently are reasons for returning donations examined? ABC’s 2022 General Election Disclosure Statement (amendment 2) indicates that the “Ken Sim – Prohibited Contributions Accepted” (as per your enforcement notice) were returned to them because they had “donated to multiple candidates” when formerly-available data shows they were all duplicate donations to Sim.

And while this one is likely outside your sphere of influence, why do refunded donations not appear as such in FRPC?  It’s not as if they were never made.  The final bullet above is an example of how the only public record now available is incorrect.   A comparison of search results for election contributions to ABC and its endorsed municipal candidates between January 1, 2019 and December 31, 2022 shows that since I exported the data two years ago, 252 records totalling $202,410 have vanished.  In the interest of transparency, all contributions and their status should remain in the system.

Thank you for your prompt consideration of my queries.

Yours truly,

(Ms) Sal Robinson

Response to Letter No. 14: nil as of November 3, 2025

Letter No. 15, SR to EBC

October 27, 2025

Good afternoon,

I understand that when prohibited contributions have been refunded, they no longer appear in FRPC.

I’m trying to account for the difference in the total of the contributions that was reported in FRPC for a municipal EO two years ago, and what the same search parameters yield now.  If the total is less now, due to contributions having been returned, should I be able to track where they went by looking at the scanned reports for the EO and its endorsed candidates?  If I can find some but not all, Is there somewhere else to look?

Is there anything besides returned contributions that could account for the difference between two years ago and now?

Thanks for your help, as always.

Response to Letter No. 15, Sydney Stoltz, Compliance Officer, EBC to SR

October 28, 2025

Good afternoon Sal,

Thank you for contacting Elections BC. If there have been changes to a report, you may see multiple versions in the form of amendments (e.g. “Amendment 1”). Changes could also be due to corrections made post-filing, if requested by Elections BC. The most recent amendment should be the most up to date at this time.

Prohibited contributions are reported on the scanned reports so you will see that activity in the report section only, as prohibited contributions will have been returned or remitted, they are no longer contributions and will not be in the contribution section or the election summary. 

I hope that the above information helps, and if you have any further questions please feel free to let me know.

Letter No. 16, SR to Sydney Stoltz, Compliance Officer, EBC

October 28, 2025

Hi Sydney,

I appreciate your prompt response.

I need to be more specific about the issue.

Two years ago, I exported data from FRPC on contributions to the municipal campaign of an EO between January 1, 2019 and December 31, 2022.  The total for the party and its endorsed candidates came to $2,192,081.  A week ago, I exported data using the same dates and the total was $202,410 less.

I have compared the two donor lists and find that 218 records were deleted, 5 altered (partial refunds), and 28 added.

I have totalled everything I can find of prohibited contributions in all the scanned reports of 2022 General Election disclosures and multiple amendments for the party and its candidates, and I can account for only about $126,000 of the $202,410 that has disappeared from FRPC.

Further, I have searched the scanned reports for quite a few of the missing donor records (of smaller amounts like $100) and while they appear in the original and first four amendments, their names do not appear at all in the fifth or sixth, either as donors or people whose contributions were returned as prohibited. 

What would be the explanation for that?

Response to Letter No. 16: nil as of November 3, 2025