Federal Court Upholds TRV Refusal Due to Insufficient Financial Resources

Date: 20260302 Docket: IMM-20794-24 Citation: 2026 FC 285 Vancouver, British Columbia, March 2, 2026 PRESENT: The [NAME]: [NAME] Applicant and THE MINISTER OF CITIZENSHIP AND IMMIGRATION Respondent

JUDGMENT AND

REASONS [ 1 ] The Applicant, a 43-year-old citizen from Iran, seeks judicial review of the decision of a [NAME] officer [Officer] refusing the Applicant’s application for a temporary resident [NAME] [TRV] to permit him to visit his sister in Montreal, Quebec, from April 1 to May 1, 2025. [ 2 ] By letter dated October 16, 2024, the Officer stated that the TRV was refused as the Officer was not satisfied that the Applicant would leave Canada at the end of his authorized stay, as required by subsection 179(b) of the Immigration and Refugee Protection Regulations SOR/2002-227 [ IRPR ]. The Officer supported this conclusion by referring to the following three factors: (i) the Applicant’s assets and financial situation were insufficient to support the stated purpose of his travel; (ii) the Applicant did not have significant family ties outside of Canada; and (iii) the purpose of the Applicant’s visit to Canada was not consistent with a temporary stay given the information the Applicant had provided in his application. [ 3 ] The Officer’s decision is largely contained in their [NAME] [[NAME]] notes, which form part of the reasons for decision. The [NAME] notes provide: I have reviewed the application. I have considered the following factors in my decision. The documentation provided in support of the applicant’s financial situation does not demonstrate that the funds would be sufficient or available. The banking transaction history shows pre-existing low balances, lump-sum deposits and fluctuating transactions with total deductions often equaling/exceeding the total deposits. Little evidence on file to demonstrate the history of funds accumulation. The presence of lump-sum deposit does not satisfy me that the applicant will have access to the funds provided in support of the application. Therefore, it appears that the bank accounts have been inflated for the [NAME] application. In the absence of satisfactory documentation showing the source of these funds, I am not satisfied the applicant has sufficient funds. Evidence of available funds associated with assets such as a vehicle, rental properties, or potential income, have not been included in the calculation of available funds. The applicant does not have significant family ties outside Canada. The purpose of the applicant’s visit to Canada is not consistent with a temporary stay given the details provided in the application. Weighing the factors in this application, I am not satisfied that the applicant will depart Canada at the end of the period authorized for their stay. For the reasons above, I have refused this application. [ 4 ] On this application, the Applicant challenges the reasonableness of the Officer’s decision. The substance of the Officer’s decision is reviewable on a reasonableness standard. When reviewing for reasonableness, the Court must determine whether the decision under review, including both its rationale and outcome, is transparent, intelligible and justified . A reasonable decision is one that is based on an internally coherent and rational chain of analysis and that is justified in relation to the facts and law that constrain the decision-maker [see Canada (Minister of Citizenship and Immigration) v Vavilov , 2019 SCC 65 at paras 15, 85]. [ADDRESS] will intervene only if it is satisfied there are sufficiently serious shortcomings in the decision such that it cannot be said to exhibit the requisite degree of justification, intelligibility and transparency [see [NAME] v Canada (Citizenship and Immigration) , 2020 FC 418 at para 11]. [ 5 ] The Applicant has asserted that the decision is unreasonable on a number of grounds. However, I find that it is only necessary to consider the reasonableness of the Officer’s determination that the Applicant has failed to establish sufficient and available financial resources. The Applicant asserts that the Officer’s determination in this regard was unreasonable, as he had provided evidence to demonstrate sufficient funds to cover the cost of the trip —namely, $10,000 CDN in savings. Given that he would be staying with his sister, and thus would not have to pay for accommodations, he states that the funds available in his bank account would more than cover the costs of the trip. The Applicant asserts that the Officer’s reasons fail to justify this determination. Moreover, the Applicant asserts that the Officer conducted an unreasonably narrow analysis which improperly focused on transaction patterns rather than the Applicant’s financial evidence in its totality. [ 6 ] I am not satisfied that the Applicant’s assertions have merit. In support of his application, the Applicant provided a bank account balance certificate showing a balance of the equivalent of $10,394 CDN, together with four months of bank statements for this account. During those four months, the account balance fluctuated significantly and, on seven occasions, the account had a zero balance. I find that the Officer’s reasons accurately describe the Applicant’s bank account statements and reasonably note the absence of any explanation from the Applicant regarding the significant accumulation of funds in the account immediately prior to his application. Numerous deposits were made to the Applicant’s bank account in the final month of the statement that brought it to a balance far in excess of any previous month and which deposits could not be attributable to his salary (based on the employment information in the application). [ 7 ] While the Applicant is critical of the sufficiency of the Officer’s reasons, the Officer’s duty to provide reasons on a TRV application is minimal, in recognition of the institutional context in which such decisions are made — namely, the high volume of temporary resident visas that must be processed in Canada’s missions [see [NAME] v Canada (Citizenship and Immigration) , 2021 FC 596 at para 9]. In any event, I find that the Officer’s reasons adequately explain their findings regarding the Applicant’s finances in a manner that is intelligible and transparent and consistent with the evidence before them. [ 8 ] The Officer’s finding regarding the sufficiency and availability of financial resources was, on its own, a sufficient basis upon which to refuse the Applicant’s TRV application [see [NAME] v Canada (Citizenship and Immigration) , 2024 FC 1343 at para 10]. As such, I need not consider the Applicant’s additional arguments related to the reasonableness of the Officer’s decision. [ 9 ] As the Applicant has failed to demonstrate that the Officer’s decision was unreasonable, the application for judicial review shall be dismissed. [ 10 ] No question for certification was raised and I agree that none arises.

JUDGMENT in IMM-20794-24 THIS COURT’S

JUDGMENT is that: The application for judicial review is dismissed. The parties proposed no question for certification and none arises. “[NAME]” Judge FEDERAL COURT SOLICITORS OF RECORD DOCKET: IMM-20794-24 STYLE OF CAUSE: [NAME] v THE MINISTER OF CITIZENSHIP AND IMMIGRATION PLACE OF HEARING: VANCOUVER, BRITISH COLUMBIA DATE OF HEARING: MARCH 2, 2026

JUDGMENT and reasons: [NAME]. DATED: MARCH 2, 2026 APPEARANCES: [NAME] For The Applicant [NAME] For The Respondent SOLICITORS OF RECORD: [NAME] and Solicitor Surrey, British Columbia For The Applicant Attorney General of Canada Vancouver, British Columbia For The Respondent