Case studies · The Royal Canadian Legion
Two hundred registrations, and the branch is not the charity.
A federation whose charities are trusts: the poppy fund, the housing corporation, the command's benevolent fund, each held by the branch executive that runs the hall. 225 registrations that filed a 2024 return, read from the public record.
The hall is the branch's; the trust is the public's; the volunteers on the return are the same three people.
What the sector looks like here.
The first thing the record says about the Legion's 225 registrations is that the branch is not one of them. The Legion says so itself: it is not a registered charity, and a donation to the poppy campaign does not earn a receipt. What is registered is the thing beside the branch. A hundred and fifty-five of the 225 are poppy funds, a trust the branch's own by-laws require it to keep in a separate account and spend only on veterans and their families in need. The rest are a handful of Legion housing corporations, six funds at the command level, the national foundation, and the odd branch that registered itself years ago and kept filing. Together they report $27 million a year, and the median fund runs on $25,000.
The people on the return are the branch executive. The poppy fund has trustees, in law, and in practice they are the president, the secretary and the poppy chair, which is why a third of these boards have three members or fewer and the median board is four. The record counts the trustees; it does not count the members who sell the poppies, and it cannot see the branch, whose hall, bar, and membership roll are on no return anywhere.
Ontario has nearly half; the Prairies and the Atlantic provinces a fifth each; Quebec almost none, because Quebec branches run the campaign on the branch's books. The purpose is relief of poverty on two thirds of the returns, and that is exact: the fund exists to pay a veteran's rent, furnace, or funeral when nobody else will. The Legion counts 1,350 branches. Fewer than one in four has a registered fund. The rest raise and spend the poppy money under the same by-laws with no CRA number, and when one of them closes there is no final return to file.
By annual revenue
By region
Region follows the riding a registration's mailing address falls in; 19 could not be assigned. Median revenue is $25,000 and the whole body reports $27 million; the median board has 4 members.
What the record shows about strain.
The model flags twenty-three of the 225, ten per cent, a little over the national rate. A flag means only that an organization's filings over several years resemble those of charities that later lost their registration; twenty-two of the twenty-three run on under $150,000, and none is at the stronger level. A poppy fund's books are simple, the money comes in during one fortnight in November and goes out through the year, and one reading of the flags is a return that the same three trustees filed for years until one of them stopped.
The register shows twelve Legion funds ended since 2019, and every one of them lapsed for failing to file. None closed by choice. Five of the twelve landed in 2025. One reading is that the branch does not know the fund beside it has to be closed separately. A branch votes to surrender its charter, as the by-laws let it, on fourteen days' notice and two thirds of those in the room; the members go to the branch next door; the hall is sold; and the poppy trust, which the by-laws say may never become branch money, is left on the CRA's list under three names who thought they had finished.
The Legion's own numbers say how many branches are near that decision. Membership was close to 600,000 in 1984 and 271,000 at the start of this year, before the centenary's free memberships lifted it. Fort Garry Branch 90 in Winnipeg went from 1,500 members to fewer than 300, and in November 2025 its members were given three choices, to join another branch, to become a branch without a hall, or to surrender the charter and give the money away, and voted almost unanimously to join South Osborne and keep their charter. They chose the successor before they chose to close, which is the order the Guide recommends, and they worked it out on their own.
Revocations on the record, by year
Revocations published in the Canada Gazette, matched by name, 2011 to 5 September 2026. 31 in all.
What an ending looks like here.
The Legion's process for closing a branch is written down in full, and nothing in the record suggests the branch has read it. The General By-Laws say a wound-up branch's property vests in the Provincial Command, to pay its debts, and that the Command must have regard to the branch's clearly expressed wish for the community and may give the surplus to a continuing community organization that agrees in writing to use it that way; the members may not have it. The Poppy Manual says the poppy money is the public's, held in trust at every level, and never the branch's. Each Provincial Command keeps a central poppy trust to receive what a branch cannot use. The whole process exists. What does not exist is a sentence that names the poppy fund on the day the branch closes, and a person whose job it is to say it to the trustees.
So the branch does the first part, the one it knows: the vote, the last parade, the charter to Command, the hall on the market. The second part, under the Income Tax Act, with its final return, its transfer of the trust to another fund or to the Command's, and its notice in the Gazette, waits for someone to notice. The by-laws put the authority in the Command and the knowledge nowhere, and the three people who signed the last return are the people least likely to know that they are still, in the CRA's eyes, in charge of something.
Who sits on the boards.
Two hundred boards and almost no one in common: nineteen people sit on two or three, most often the poppy chair who is also a trustee of the branch's housing corporation. No officer above the branch appears on any of these returns; the Command that holds the authority is not on the map.
Bubbles are organizations, coloured by purpose and sized by revenue band. Dots are people who sit on two or more of these boards. Drag to move, scroll to zoom, click to see one organization's connections, click the background to clear. No one is named: the shape is public, the people are not.
The work
What we would do here.
The Legion is the body the Guide was written for. Its charities are small and local, run by the same few people who run the hall, and the hall is the last public room in a hundred towns. Every Legion fund that ended since 2019 ended by lapse; one reading is that nobody at the branch knew the fund had to be closed at all.
Branches closing together would be hosted by a healthy charity with a meeting room and a small budget for lunch, or by the Provincial Command itself. Each branch that has voted to close, or is deciding, would pass a motion at a general meeting naming a coordinator from their own members, and take a Toolkit licence at no cost where the vote to close has been taken. The Toolkit's Legion pages would set the by-laws' steps beside the Act's: the fourteen days and the two thirds, the vesting in Command, the poppy trust's transfer to the central fund, the final return, in the order they have to happen, so that the branch that has chosen the branch next door also chooses what becomes of its fund before the charter goes back.
Nothing in this case study names a branch that has not ended in public, and we do not use the model to approach anyone. A branch executive that recognizes its own branch here can start the conversation. So can a Command officer who has done this and knows what the branch did not. Start a conversation.
Roundtables · the community of practice, in one room
Come and correct us.
A day or an evening with the branches of one district, hosted by a Provincial Command, or a community foundation that already holds a branch's memorial money.
The public record only shows so much. A roundtable brings six to twenty community leaders from the branches of one district together for a day or an evening to go over this case study, correct it, and work out what the charities near them are facing. It is hosted by a Provincial Command, or a community foundation that already holds a branch's memorial money, and a sponsor helps defray the cost. Within the month we send a report in the room's own words, and the corrections this case study owes are made and dated in the correction log. How a roundtable works, and who provides what.
What we will ask at the roundtable.
- The Legion says 1,350 branches; the register shows about 225 registered funds. Which branches in a region hold a registered poppy trust, and which run the campaign on the branch's own books?
- The General By-Laws vest a dissolved branch's property in the Provincial Command, and the Poppy Manual says the poppy fund may never become branch money. When a branch votes to close, who tells the trustees of the poppy fund what happens to it, and when?
- Twelve Legion funds have lapsed for failing to file since 2019, and none has closed by choice. Where a branch surrendered its charter in that time, was its poppy fund's final return filed, and by whom?
- Fort Garry's members chose the branch they would join before they closed their own. Which branches in a region have named the branch next door, and which have not?
- A branch executive of three has done a Remembrance Day every year for forty years and a closure never. Which Provincial Command officer has done one, and would they sit with a branch that has to?
The Critical Path
Closing an organization, wherever it is incorporated.
Each organization in this case study is incorporated in a province or territory, or federally, and it closes under that statute first and under the Income Tax Act second. The two have an order, and no government page sets it out.
The Critical Path is that order on one folded sheet, one edition per jurisdiction: each step from the first hard conversation to the last filing, who decides it, and the document it files, with its regulator, its fee, and a specimen of its first page. Each edition will come as part of Foundations, with the Guide and access to the Foundations Course. Foundations is in development.
The other national bodies.
How this case study was made.
Public data, and math. The full method brief.
The counts are arithmetic on three public files: the Canada Revenue Agency's list of charities and their annual returns, 2011 to 2024; the Canada Gazette's notices of revocation; and Elections Canada's postal code file, which places a mailing address in a riding. A "flag" is the mark our model, Canary v3 / Distress v3, puts on a charity whose filings over several years resemble those of charities that later lost registration. It is a weak signal and we say so: about 1.4 in a hundred charities lose their registration within three years, about 2.9 in a hundred flagged ones do, and the rest carry on. We use flags to count, never to approach anyone.
This body's registrations are picked out by name. A few without the words in their legal name are missed, and unrelated bodies that share them are excluded by hand, so the count is close but not exact. Regions follow the riding of the mailing address, and 22 of Canada's 343 ridings are not yet in the crosswalk. Where a count is under five, we print "fewer than five", so that no organization can be picked out of it. The method brief has the model's validation, the counting rules, and the limits in full.
Local record, as reported: The Royal Canadian Legion, questions and answers (the Legion is not a registered charity; 1,350 branches; membership); General By-Laws of The Royal Canadian Legion, as amended to April 2026 (ss 121, 124, 420, 1102 to 1105); Poppy Manual, January 2025 (ss 401, 402, 501, 601); Milne, Donor Due Diligence of the Royal Canadian Legion Poppy Fund, RAUSI, 2023 (which funds are registered); CBC on the Fort Garry branch's vote to close and join South Osborne, 2025.
Sources: CRA List of Charities and T3010 returns, 2011 to 2024; Canada Gazette, Part I, revocations 2019 to 2025; Elections Canada, 2023 representation order. Model: Canary v3 / Distress v3, 1 July 2026; out-of-time AUC 0.68; flag precision 2.5 to 3.3 per cent. Counting script: case-study.py; the riding-level counts it produces: case-studies-aggregate.csv. The organization-level score file is available to a reviewer under a data agreement, and the method paper on request. If you find an error in the counting, write to info@publicbenefit.ca; we will correct the case study and record it in the correction log.