Federal Stablecoin Act issuer journey — issuer-class determination, BoC + FINTRAC + RPAA registration, reserve composition, mint authorization, redemption-on-demand, periodic attestation, wind-down. Walks the path that QCAD, CADD, and CADC operators are themselves walking.
"The pre-charter strategic decision at a federally-incorporated bank — the board affirms that the proposed activity falls within a permissible business under the Bank Act and the OSFI Guideline E-21 operational-risk envelope, before any application for a §22 letters-patent ever leaves counsel's desk."
Before any application is filed with the Bank of Canada, the issuer's board determines whether the proposed stablecoin meets Bill C-15's scope test and falls within an eligible issuer class. The §10 interprovincial / international application test is the threshold gate — closed-loop intra-provincial stablecoins are excluded under §11; financial institutions issuing closed-loop deposit liabilities are excluded under §12; central banks under §13. §3 carves the proposed activity out of the Bank Act, Insurance Companies Act, and Trust and Loan Companies Act treatment of stablecoin issuance as 'dealing in securities' or 'accepting deposit liabilities' — meaning that the stablecoin issuer's path is the Stablecoin Act path exclusively, not a parallel deposit-acceptance or securities-dealer charter. §§4–5 confirm that the stablecoin is engaged in 'dealing in virtual currencies' for PCMLTFA §5(h)(iv) and §5(h.1)(iv) purposes — the binding hook into the AML / CTF / sanctions-evasion overlay. §14 lets the Bank of Canada Governor exempt issuers under provincial or foreign laws that are 'substantially similar' (Quebec AMF MSB Act being the obvious provincial candidate; this is the Canadian analogue of GENIUS Act §18 comparability determinations). L4 Account and L5 Application are lit, both above the enforcement line — the determination is policy-enforced board governance on the issuer's books, not on-chain code. Builder: structure the corporate decision as a board resolution citing §§3, 10–14, with counsel's opinion on the §11–§13 carveouts and any §14 substantial-similarity strategy on file before any FINTRAC registration application or Bank of Canada §17 application is drafted. Compliance officer: satisfies C8 (licensing scope determination) and C9 (issuer-class governance — OSFI Guideline B-15 §2.1 board-mandate expectation activates here for FRFI-affiliated issuers; OSFI E-21 operational-risk envelope activates alongside). For the three issuers in scope: QCAD (Stablecorp / VersaBank) and CADC (Loon, ex-Paytrie) predate Royal Assent and walk the §94 transitional path (transitional regulations to issue under §94 specify the exemption period for issuers operating before §15 comes into force). CADD (CAD Digital Inc. / Tetra Trust) launched 2026-05-04 — post-Royal-Assent — and lands directly under the operative regime once §97 OICs publish. The Compliance Scorecard component renders inline at this band as the per-issuer cross-reference on the issuer-class axis (forthcoming, Phase C). Honesty marker: Bill C-15 received Royal Assent 2026-03-26 but every operative provision is gated by §97 Order in Council coming-into-force; as of this writing no §97 OICs have published, meaning the determination at this band is narratively in scope but the §94 transitional regime details are not yet known. The Atlas resolver correctly excludes Bill C-15 provisions from any asOf query before the OIC date via the framework's 2099-01-01 placeholder — the band carries the obligation prospectively.
"The Form 1A bank-charter application at OSFI plus the parallel CIRO / OBSI consumer-disclosure overlay — the regulator is told what the issuer plans to do, the public is told the same thing in plain language, and any commercial electronic messaging about the product is gated by an opt-in consent regime separate from either filing."
The issuer files its registration application with the Bank of Canada under Bill C-15 §17, accompanied by ten classes of information: ownership and organisational structure; technological systems; redemption policy; compliance measures; certified accountant's statement of financial condition; lawyer's compliance opinion on §§38 / §39; governance, risk, data, and recovery policies; foreign and domestic enforcement-action history; and a fee. §18 lets the Bank request additional information; §19 obliges the applicant to notify the Bank of any change to information provided; §20 triggers Bank notification to the Minister of Finance, designated authorities, and FINTRAC on completeness. §§21–29 give the Minister a national-security review track that suspends Bank registration pending review. In parallel with the regulatory application, consumer-facing disclosure obligations activate: §§30–34 substantive prohibitions on yield, legal-tender claims, deposit / insurance representations, and prohibited terms / symbols apply to every public-facing statement about the product (§30 false / misleading rule); CASL §6 consent-to-receive obligations activate on every commercial electronic message about the stablecoin (sign-up flows, marketing emails, newsletter announcements). PIPEDA Principle 4.3 consent activates on the issuer's collection of personal information from prospective Canadian users, including the moment the user enters CDD data on a sign-up flow. L5 Application is lit, above the enforcement line — disclosure and consent are policy-enforced at the application surface, with regulatory and contractual consequences for non-compliance rather than on-chain reverts. Builder: separate the Bank-of-Canada-facing application package (private, regulator-only) from the consumer-facing disclosure surface (public, prospectus-equivalent in tone but not formally a prospectus); for institutional-only issuers like CADD, ensure the consumer-disclosure track is scoped only to the institutional onboarding flow. Compliance officer: satisfies C8 (regulatory application content), C14 (consumer disclosure including the §§30–34 substantive-prohibition perimeter — particularly the §32 yield prohibition, distinguishing the stablecoin from interest-bearing deposits and securities), and C15 (PIPEDA consent at the data-collection gate). The Compliance Scorecard component renders inline at this band on the §17 application-content axis (forthcoming, Phase C). Honesty marker: §17 application content is heavily gated by Treasury Board regulations under §93 — the prescribed-content detail is pending implementing regulations. Until the regulations issue, applicants prepare under the statutory text plus the Bank's pre-OIC guidance, with [VERIFY] required for any specific application-content claim.
"The senior-officer fit-and-proper check at OSFI for a Schedule-I-bank applicant, layered on top of the FINTRAC MSB / MSB-VC registration check at the same applicant's payments arm, layered on top of the Bank-of-Canada PSP registration check at the same applicant's retail-payments side — three parallel registration gates that must each clear before any operational activity can begin."
Three parallel registration tracks fire at Identity. (a) Senior-officer and UBO attestation: Bill C-15 §17(d) requires the §17 application to include ownership and organisational structure; §17(g) requires foreign and domestic enforcement-action history of every senior officer and UBO; OSFI fit-and-proper review (Guideline E-17) for FRFI-affiliated issuers layers on top. (b) FINTRAC MSB-VC registration: PCMLTFA §11.1 requires every §5(h) / §5(h.1) reporting entity — including a Canadian stablecoin issuer 'dealing in virtual currencies' under §5(h)(iv) — to register with FINTRAC. PCMLTFA §11.11 makes the issuer ineligible if subject to UN Act terrorism sanctions, SEMA financial-services prohibitions, Magnitsky sanctions, listed-entity status under Criminal Code §83.01(1), or specified prior money-laundering / terrorist-financing convictions. PCMLTFR §§109 (corporation verification), 112 (other-entity verification), and 138 (directors-of-corporation information) prescribe the entity-verification methods. (c) Bank of Canada PSP registration: RPAA §23 prohibits the issuer from performing any retail payment activities until registered with the Bank under §25; §29 sets out application content (business name, ownership, retail-payment-activity description, safeguarding plan, third-party-service-provider list, agent list, prescribed information); §35 lists the Bank's refusal grounds, including a five-year look-back for prior PCMLTFA serious-violation penalties. §37 lets the Minister of Finance, on national-security or public-interest grounds, direct the Bank to refuse registration. L4 Account and L5 Application are lit, above the enforcement line — every gate is policy-enforced regulator action rather than on-chain code, but failure at any gate halts the journey. Builder: track all three registration timelines in parallel from Day 1; the FINTRAC MSB-VC and RPAA-PSP registrations are independent, with separate eligibility tests, disclosure obligations, and renewal cadences. The Bill C-15 §17 application is the longest track because of the §§21–29 ministerial-review window. Compliance officer: satisfies C1 (UBO and senior-officer identity verification — KYB / KYA bedrock) and C8 (three parallel licensing gates, each with its own ineligibility list). For the three issuers in scope: QCAD (Stablecorp) and CADC (Loon) hold pre-existing FINTRAC MSB registrations; CADD (CAD Digital) is post-launch new and was registered before the 2026-05-04 launch [VERIFY current registration status for all three]. RPAA-PSP registration came into force §23 on 2024-11-16 — all three issuers performing retail payment activities are required to be registered with the Bank of Canada as of this writing. Honesty marker: registration timing in practice has a long tail — FINTRAC MSB-VC processing is well-documented; RPAA-PSP processing under the new regime is less so [VERIFY current Bank-of-Canada PSP registration backlog and average decision time]. Bill C-15 §17 processing has not yet been tested in production.
"The §6045 broker-reporting obligation paired with the SEC monthly-disclosure rhythm at a US PPSI — the issuer states what is in the reserve, in what proportion, and at what fair-market value, and an independent auditor confirms the statement on a regulator-published cadence."
Bill C-15 §37 constrains reserve composition to 'the reference currency or other high-quality liquid assets denominated in the reference currency, as approved by the Bank or specified in regulations.' For a CAD-pegged stablecoin, the reference currency is the Canadian dollar; permitted reserve assets follow the same general structure as GENIUS Act §4(a)(1)(B) — Canadian-dollar bank deposits, short-dated Government of Canada Treasury bills, repurchase agreements backed by such Treasuries, money-market funds invested solely in the foregoing, central-bank reserve deposits — though the specific Canadian permitted-asset enumeration is gated by Treasury Board regulations under §93 and is not yet published. §38 prohibits the issuer from pledging, encumbering, or creating a security interest in reserve assets. §46 requires the issuer to file with the Bank a periodic report including a certified accountant's statement of financial condition, outstanding stablecoin count, reserve composition, fair-market value of reserve, and conformity opinion on §37(1) and §37(3); plus a lawyer's compliance opinion on §§38 and 39; plus a monthly statement to the Bank of the financial-condition / outstanding / reserve-composition data per §46(3). The report is publicly available under §46(4). For three issuers in scope, on-chain attestation oracles (Chainlink Proof of Reserve pattern, Armanino-style attestation feeds) are the natural implementation — the L3 Execution layer surfaces the on-chain attestation; the L4 Account layer surfaces the bank-account / custodian balance; the L5 Application layer surfaces the public attestation report. L3, L4, and L5 are all lit; the cadence is policy-enforced (monthly, per §46(3)) but the attestation itself can be code-enforced via on-chain oracle. Builder: wire the attestation oracle to publish on-chain at the §46(3) monthly cadence (or more frequently for operational liveness), and emit a `ReserveAttestation(date, outstanding, reserveAssets[], opinion)` event keyed to the Bank-of-Canada-filed report's hash. Compliance officer: satisfies C9 (reserve adequacy + composition declaration) and C11 (recordkeeping — the §46 report is the authoritative record of reserve composition over time). Issuer-specific posture: QCAD's VersaBank custody arrangement supports continuous reserve attestation [VERIFY current cadence — historically monthly]; CADD's Tetra Trust arrangement and the institutional-only access posture suggest a more bespoke attestation approach [VERIFY]; CADC's custodian structure post-Paytrie transition is less publicly documented [VERIFY current custody arrangement and attestation cadence]. Honesty marker: §37 permitted-asset enumeration is gated by Treasury Board regulations under §93(c). Until the regulations issue, every issuer's reserve composition is operating against the statutory floor — high-quality-liquid-asset criterion in the reference currency — without the prescribed-asset specificity that would make audit work straightforward.
"The pre-issuance subscription-agreement gate at a Reg D 506(c) tokenized-fund offering — the issuer accepts only counterparties who have cleared the eligibility check, signed the documents, and committed to the holding-and-transfer rules embedded in the security's transfer-restriction module."
Before any mint event fires at the next stage, the issuer's framework defines who can hold the stablecoin and on what terms. Bill C-15 §35 establishes a statutory at-par redemption right that runs to every holder; §36 obliges the issuer to make the redemption policy publicly available — meaning the issuer cannot enforce a hidden eligibility framework that creates classes of holder with different redemption rights. §37(1) reserve-adequacy is a per-mint pre-condition: every additional unit of stablecoin issued must be matched by at least an equivalent amount of permitted reserve assets, which means the mint is effectively gated by the Step 4 attestation reading. For institutional-only issuers (CADD), an on-chain transfer-restriction module — ERC-3643 / Securitize DS Protocol pattern — enforces the institutional-only access list at the chain layer; the issuer's subscription / KYB process populates the allowlist through the transfer agent or equivalent identity-registry function. For retail-accessible issuers (QCAD, CADC), the eligibility framework is enforced at the on-ramp / off-ramp boundary (custodian KYC at the API layer) rather than on-chain — transfer between two retail wallets that have both passed onboarding is unrestricted at the chain layer. L3 Execution and L4 Account are lit; enforcement is mixed — code-enforced (transfer-restriction module) for institutional-only issuers, policy-enforced (custodian KYC at the boundary) for retail-accessible issuers. Builder: for institutional-only flows, expose `isEligible(walletAddress)` against the ERC-3643 identity registry as the pre-mint check; cache eligibility status with appropriate TTL. For retail-accessible flows, the equivalent check fires at the custodian's API gateway before mint authorization is forwarded to the on-chain mint contract. Compliance officer: satisfies C1 (counterparty / holder identity verification — flowing from the Step 3 KYB / KYA stack), C8 (eligibility framework consistency with Bill C-15 §§35–36 redemption-right uniformity), and C16 (programmable compliance — code-enforced transfer-restriction module where present). The Compliance Scorecard component renders inline at this band on the reserve-check axis (forthcoming, Phase C). Honesty marker: the §35 statutory at-par redemption right plus the §36 publicly-available redemption-policy obligation create a structural tension with eligibility-framework opacity. An issuer that gates redemption on undisclosed eligibility classes, or that varies redemption terms between holder tiers, is in tension with §§35–36 even if the on-chain transfer mechanics permit it. The three issuers in scope have not yet published §36 redemption policies under the operative Bill C-15 cadence (OIC pending).
"The Federal Reserve banker's-acceptance issuance event paired with the qualified-custodian segregation-in-trust attestation — the new stablecoin enters circulation only against a documented increase in segregated reserve assets, and the segregation is bankruptcy-remote against both the custodian's and the issuer's other obligations."
The mint event fires: the on-chain mint contract emits a `Transfer(0x0, recipient, amount)` event, the issuer's outstanding-stablecoin balance increments, and an equivalent amount of permitted reserve assets is segregated into the §39 qualified-custodian arrangement. Bill C-15 §37 requires the reserve to remain at or above par with outstanding stablecoins continuously; §38 prohibits any pledge, encumbrance, or security interest in reserve assets; §39 requires placement with one or more qualified custodians, with assets segregated from the custodian's own assets and from the issuer's other assets, and with bankruptcy-remoteness vis-à-vis the custodian's and issuer's creditors — including under the Bankruptcy and Insolvency Act and analogous provincial / foreign insolvency law — except for satisfying redemption claims. RPAA §20 layers an additional safeguarding obligation where the issuer is also a registered RPAA-PSP holding end-user funds: trust account, prescribed account / manner, or dedicated account with at-or-above-par insurance / guarantee. L2 Consensus, L3 Execution, and L4 Account are all lit — the mint operation traverses every layer at or below the enforcement line. Enforcement is mixed: the on-chain mint is code-enforced; the segregation and bankruptcy-remoteness are policy-enforced and statutory. Builder: structure the mint contract so that it cannot fire without a successful pre-mint reserve-adequacy attestation reading (Step 4 oracle); emit `Mint(recipient, amount, reserveAttestationHash)` linking the mint event to the attestation it relied on. For the segregation side, the custodian's account agreement should explicitly invoke §39 and the Bankruptcy and Insolvency Act analogue; counsel's §39 compliance opinion goes into the next §47-on-request lawyer's statement. Compliance officer: satisfies C9 (reserve adequacy at par, §37), C10 (custodian segregation and bankruptcy-remoteness, §39), and C16 (code-enforced mint gated on attestation hash). Issuer-specific posture: QCAD's VersaBank arrangement is the most documented segregation structure of the three [VERIFY current §39 custody-agreement language]; CADD's Tetra Trust Company is an Alberta-chartered trust company supervised by Alberta Treasury Board and Finance, providing a province-supervised segregation track [VERIFY current §39 custody-agreement language]; CADC's custody structure post-Paytrie is less publicly documented [VERIFY]. The Compliance Scorecard component renders inline at this band on the segregation axis (forthcoming, Phase C). Honesty marker: §39 bankruptcy-remoteness is a sophisticated legal-engineering claim, not a pure documentation claim — the structural integrity of the segregation in a real insolvency scenario depends on the Court's reading of the trust / agency / contractual framework, the custodian's specific arrangement, and any commingled-assets factual finding. The §47 lawyer's compliance opinion and the §43 recovery-and-resolution mandatory policy together are the load-bearing controls, not the on-chain attestation.
"The discount-window standing-facility commitment plus the OSFI Guideline E-21 operational-continuity expectation at a Schedule-I bank — the issuer commits, by statute and by board-approved policy, to redeem at par at any time, and to maintain the operational capacity (technology, personnel, third-party arrangements) to do so through any incident short of full insolvency."
In operational steady state, the issuer's primary obligation is at-par redemption-on-demand. Bill C-15 §35 makes the redemption right statutory; §36 requires the redemption policy to be publicly available and filed with the Bank; §43 (mandatory recovery and resolution policy) requires the issuer to maintain orderly resolution / wind-down capability including redemption of outstanding stablecoins and protection of holders' claims to the reserve. §41 (mandatory risk-management policy) requires operational resilience, incident response, business continuity, recovery from disruption, third-party risk management, cybersecurity, and AML / CTF risk identification — all of which feed the §49 incident-notification obligation when an incident materialises. RPAA §17 layers a parallel operational-risk-management framework obligation on registered RPAA-PSPs; §18 requires without-delay notification of material-impact incidents to affected end users, in-chain PSPs, and PCSA-designated clearing houses. The redemption obligation itself is monitored by the §46(3) monthly cadence — every monthly report's outstanding-stablecoin count plus reserve-composition data lets the Bank of Canada verify continuous §37 compliance. L3, L4, and L5 are all lit; enforcement is policy-enforced (statutory + supervisory + contractual) rather than on-chain code, but the on-chain redemption mechanism is the operational expression of the policy. Builder: structure the redemption mechanism so that any holder can initiate redemption through the issuer's published policy with a deterministic SLA; track redemption volumes by hour for the Bank-of-Canada §46 reporting and for internal operational-risk-management framework metrics. Compliance officer: satisfies C9 (continuous reserve adequacy / redemption-funding adequacy), C10 (operational continuity + incident response framework), and C14 (consumer protection — redemption-right uniformity per §§35–36). For the three issuers in scope: redemption mechanics differ — QCAD operates a documented Stablecorp-owned redemption surface against VersaBank reserves; CADC operates a Paytrie-consumer-surface redemption with secondary-market liquidity on Uniswap and Aerodrome serving as a soft redemption proxy [VERIFY current Loon-direct redemption surface]; CADD's institutional-only model operates redemption through a CAD-Digital-direct surface with Tetra Trust [VERIFY current Tetra-Trust-direct redemption SLA]. Honesty marker: secondary-market liquidity is NOT a substitute for the §35 statutory at-par redemption right — an issuer cannot satisfy §35 by directing holders to a DEX with a 1% bid-ask spread plus slippage. The §35 right is to par redemption from the issuer; secondary-market liquidity is a separate facility. The three issuers' redemption policies under operative Bill C-15 are pending the §97 OIC schedule.
"End-of-period attestation at a registered investment company — the §17 financial-statement filing at the SEC is paired with the SOC 1 / SOC 2 audit of the transfer-agent function and the PCMLTFA-equivalent recordkeeping retention, and every record is available to the regulator on demand."
Periodic attestation and recordkeeping fire continuously through Finality. Bill C-15 §46 (Provision 6 of the framework) imposes a periodic report to the Bank of Canada — a certified accountant's statement of financial condition, outstanding stablecoin count, reserve composition, fair-market value of reserve, plus a §37(1) / §37(3) conformity opinion — at a regulator-published cadence (monthly per §46(3) for the core data). §47 obliges the issuer, on Bank request, to provide a lawyer's statement on §§38 / §39 compliance. §48 imposes independence requirements on the certified accountant and the lawyer. §51 governs retention, use, and disposal of personal information (in conjunction with §42's data-security policy). §52 prohibits false / misleading information to the Bank, Minister, or designated authorities — a more general anti-misrepresentation rule than §30. PCMLTFA §6 + PCMLTFR §§31, 32, 36 layer the AML-side recordkeeping with five-year retention from creation or from the last business transaction. RPAA §21 layers a parallel annual-report obligation to the Bank under the retail-payments-supervisory frame. CRA-ITA tax recordkeeping flows through CRA's general books-and-records standard. L5 Application is lit — finality lives entirely in the policy layer because the regulatory record of operational steady-state is the issuer's books plus the on-chain attestation evidence, with the issuer's Bank-of-Canada / FINTRAC / Bank-of-Canada-RPAA / CRA registrations as the accountable points. Builder: align the §46(3) monthly cadence with the PCMLTFA recordkeeping cadence and the RPAA §21 annual-cadence into a single internal reporting calendar; emit the §46 report's hash on-chain alongside the Step 4 attestation oracle for an end-to-end audit trail. Use durable WORM-compliant storage with retention to the longest of: §51 PCMLTFA five-year retention, RPAA §21 prescribed-period (pending regs), and CRA's six-year general standard. Compliance officer: satisfies C11 (multi-framework recordkeeping + retention) and C12 (audit / attestation — the §46 report plus the §47 lawyer's opinion plus the on-chain mint event chain together form an externally-verifiable audit trail). The Compliance Scorecard component renders inline at this band on the attestation axis (forthcoming, Phase C). Honesty marker: the §47 lawyer's compliance opinion and the §46 certified-accountant attestation are operationally non-trivial — the §48 independence test for both, plus the §52 anti-misrepresentation backstop, plus the §74 PCMLTFA-side hybrid offence on §6 / §6.1 contraventions, mean that the issuer's choice of accountant and counsel is itself a regulator-relevant fact.
"The OCC's bank-resolution playbook plus a FinCEN SAR escalation overlay plus the SEC enforcement-track surface — back-office machinery activates on signal: an incident triggers regulator notification, a sanctions hit triggers a freezing workflow, a compliance breach triggers a penalty proceeding, and a strategic-exit decision triggers the §43 recovery-and-resolution policy."
Disposition is the back-office tier of the path — the obligations and workflows that activate on signal rather than continuously. Four parallel tracks fire: (a) Wind-down: Bill C-15 §43 mandatory recovery-and-resolution policy is activated where the issuer initiates an orderly wind-down of stablecoin activities; the policy must include redemption of outstanding stablecoins and protection of holders' claims to the reserve. The Bank of Canada's §65 prudential measures, §66 unsafe-or-unsound-practice directions, and §74 ministerial prohibition orders all flow through this stage. (b) Incident response and notification: §49 obliges the issuer, without delay, to notify the Bank of any incident; the Bank notifies the Minister and designated authorities. RPAA §18 layers a parallel without-delay notification obligation to affected end users, in-chain PSPs, and PCSA-designated clearing houses. (c) AML / CTF / sanctions filing: PCMLTFA §7 STR fires on reasonable grounds to suspect a money-laundering, terrorist-financing, or (per S.C. 2024, c. 15) sanctions-evasion offence; §8 anti-tipping; §7.1 SEMA / UN Act / Magnitsky disclosure. PCMLTFA §9 + PCMLTFR §30(1) LCTR / LVCTR / EFTR fire on CAD 10,000+ thresholds. (d) Enforcement: Bill C-15 §§79–92 Administrative Monetary Penalty regime fires on violations (notice of violation under §80, penalty under §§81–82, Federal Court appeal under §83, public registry of violations under §92). RPAA §§76–86 layer a parallel AMP regime for retail-payment-services violations. PCMLTFA §74 hybrid offence layers on top for criminal contraventions of §11.1 / §6.1 / specified other provisions. L5 Application is lit; enforcement is policy-enforced (statutory regulator action). Builder: surface the §49 incident-notification obligation as a Day-1 runbook with regulator-contact chains and the Bank-of-Canada incident-form template (pending §49(2) prescribed form); separately, surface the PCMLTFA §7 STR workflow with the FINTRAC submission API; track all four tracks separately because their triggers and timelines differ materially. Compliance officer: satisfies C2 (sanctions screening on disposition / breach-response — SEMA / UN Act / Magnitsky integration), C3 (STR disposition workflow), C9 (wind-down planning + recovery-and-resolution policy), C11 (filing obligations across Bill C-15, PCMLTFA, RPAA, CRA-ITA), and C13 (market-conduct and AMP enforcement). Honesty marker: the four tracks have very different time horizons. STR / LCTR / RPAA-incident notification fire within hours to days. Bill C-15 §43 wind-down is a multi-quarter to multi-year process. AMP proceedings under §§79–92 of Bill C-15 (and the parallel RPAA AMP regime) are still untested under the operative Bill C-15 regime — until §97 OICs operative-ize the supervisory and enforcement track, the §43 / §49 / §§79–92 obligations are narratively in scope but the procedural detail is pending Treasury Board regulations under §93(j) (AMP penalties and classifications). The PCMLTFA-side filings (STR / LCTR / LVCTR / EFTR) are operative now and bind the issuer immediately.
Resolved 9 steps across 1 chain(s). 0 threshold(s) triggered. Frameworks: Common Reporting Standard / FATCA.
Coverage notes: 5 disclosed gap(s).