Here is CRA Guidance on Credit Counselling. The document was obtained through access to information and privacy.
The guidance “discusses considerations for assessing whether credit counselling services further charitable purposes and meet other requirements of the Income Tax Act. It identifies a number of questions to ask to help determine:
• whether credit counselling activities further charitable purposes;
• whether an organization devotes all of its resources to charitable purposes/activities; and/or when applicable,
• whether credit counselling activities qualify under the related business provisions of the Income Tax Act.
CRA notes that “The courts have not recognized credit counselling purposes as being charitable.”
The guidance discusses debt management plans and whether some organizations in the credit counselling area could be charitable under the relief of poverty, advancement of education and promotion of health.