( ii) Application of Saskatchewan River Bungalows criteria
 The first criterion to be examined in deciding whether to
grant relief from forfeiture is the conduct of the applicant.
 I cannot find that the applicant was reasonably careful or
diligent in the manner she went about complying with her obligations as a candidate under the MEA.
 The applicant’s affidavit effectively claims to have delegated the entire (and important) matter of campaign finance
compliance to a third party, her “accountant” Mr. Elias. There is
no suggestion that Mr. Elias held himself out to be an accountant or that he had any particular experience in compliance with
the MEA. Her faith in his expertise was said to be founded upon
previous experience Mr. Elias had acting as chief financial
officer for Lebanese Friends of Canada and as a financial
controller for GS Group Inc. While both roles may well imply
a certain degree of bookkeeping and financial skills, they do not
involve prior experience with MEA compliance and certainly do
not require certification as an accountant.
 Whether careful delegation of responsibility for compliance would adequately support an application for relief from forfeiture I need not say. The delegation in this case amounted to
abandonment and was neither reasonable nor careful.
 The lack of care and diligence demonstrated in this case is
all the more flagrant in light of the persistent attempts by the
City Clerk’s Office to advise Ms. Giannini and all candidates of
their important obligations, advice that included a wealth of
information made available for the asking (online or by attending information seminars for candidates) and pushed out to candidates in mailings and e-mails.
 Ms. Giannini knew or clearly ought to have known from
a cursory review of the information sent to her ( i) that the MEA
required audited financial statements in all cases save campaigns raising or spending less than $10,000; ( ii) that the deadline for filing the audited financial statements was March 27,
2015; ( iii) that she had the option of applying to the Ontario
Court of Justice for an extension of time; and ( iv) that the
penalty for non-compliance in the case of an unsuccessful candidate was ineligibility to run in the next election.
 The actions of the applicant after discovery of her breach
are also relevant. The applicant was made aware of the problem
of the lack of an audit report on March 27, 2015 at the latest.
She did not retain an auditor immediately nor did she take
immediate steps (as in Singh) to correct the problem. She claims
— on the basis of extremely limited financial disclosure —