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SettleADebt — C_CA PASS-01

Ontario, Canada: Debt-settlement provider regulation, fees, contracts, and consumer safeguards

Focused primary-source research dossier Not independently reviewed

Research baseline: October 22, 2026, America/Los_Angeles Actual verification: October 26, 2026 — Pacific Daylight Time (UTC−7), Eastern Daylight Time in Ontario (UTC−4), and UTC. Jurisdiction: Ontario, Canada, with limited Canadian federal insolvency-law boundaries. Parent assignments: A097/A098 remain open.

Executive determination

Ontario has a specific statutory regime governing businesses paid by debtors to negotiate or arrange debt settlements. The principal legislation is the Collection and Debt Settlement Services Act, R.S.O. 1990, c. C.14 (CDSSA), together with R.R.O. 1990, Regulation 74.

The law generally treats a covered, paid debt-settlement provider as a collection agency for registration purposes, even when the business negotiates on behalf of the debtor rather than collecting debts for creditors.

The most consequential findings are:

1. Registration: A covered debt-settlement business must be registered in Ontario. Individual collectors are no longer separately registered, but remain subject to conduct rules.
2. Fee eligibility: Most compensation cannot be demanded or received for a particular creditor until the debtor has an agreement with that creditor, has made at least one payment under it, and the agency has written proof of that payment.
3. Two fee models: The regulation distinguishes negotiated payment schedules, generally capped at 15% of payments to creditors, from one-time settlement offers, generally capped at 10% of each qualifying debt's balance when the services agreement was signed. A limited CAD $50 charge is permitted for the payment-schedule model.
4. Cancellation: A debtor generally has a 10-day period after receiving the written agreement to cancel without giving a reason. A separate one-year cancellation right applies when the prescribed agreement-copy requirements have not been met.
5. Refunds: Illegal fees and payments under properly cancelled agreements have statutory refund routes. The prescribed agency refund period is 15 days after receipt of a qualifying demand.
6. Client funds: Money handled by a registered agency can be subject to statutory trust-account and disbursement requirements. These are distinct from whether the agency has earned its service fee.
7. Underlying debts: Cancelling a provider agreement does not, by itself, extinguish the consumer's original creditor debts.
8. Federal boundary: Private settlements are not statutory consumer proposals or bankruptcies under Canada's Bankruptcy and Insolvency Act.

These determinations rest principally on CDSSA ss. 1–2, 4, 16.3–16.10, 22.1 and 32, Regulation 74 ss. 13–19.11 and 26–30, the 2013 Ontario legislative amendments, and official Ministry guidance.

Important source-access qualification

Ontario's official e-Laws pages were discoverable through current official indexed text, including section-level extracts, but direct attempts to open the consolidated statute and regulation returned HTTP 403. Accessible Legislative Assembly enactment text and Ontario government PDFs were read directly where available.

Accordingly, this report distinguishes directly read primary text, official indexed extracts, historical enactments, official guidance, and unresolved text-access gaps. It does not claim a complete page-by-page inspection of the current e-Laws consolidations.

The current e-Laws listing identifies the CDSSA consolidation as running from December 6, 2023, and Regulation 74 from March 1, 2022, subject to the e-Laws currency date. The Consumer Protection Act, 2023 is identified as not yet in force in the official listing checked for this report.

A. Controlling law and jurisdiction

The central Ontario law is the Collection and Debt Settlement Services Act (CDSSA), R.S.O. 1990, c. C.14, particularly sections 1, 2, 2.1, 4, 16.3–16.10, 22 and 22.1. Its detailed operating rules are in R.R.O. 1990, Regulation 74, particularly sections 13–19.1, 26–30.

The Act's scope test is unusually concrete: under CDSSA section 2(0.1), it applies to a collection agency or collector dealing with a debtor if the debtor or the agency/collector is in Ontario when the dealing occurs. A website's incorporation address, a telephone number, or a foreign licence alone cannot settle that test. Section 2.1 requires attention to the real substance of an arrangement, including an apparent workaround using separate entities or differently named fees. ontario.ca+5

A crucial scope distinction is that Ontario removed corporate-debt collection from the CDSSA framework effective January 2018. That does not prove that every debt incurred for business purposes is excluded, particularly where an individual proprietor or guarantor is involved. Nor does it automatically answer whether a paid debtor-side negotiation arrangement satisfies the separately worded definition of debt settlement services. The general Consumer Protection Act, 2002 uses a personal, family or household consumer concept; its ordinary consumer remedies cannot simply be assumed for a business-purpose contract. Each activity and debtor must be classified independently. January 2018+3

Ontario's Ministry of Public and Business Service Delivery and Procurement administers this provincial registration and enforcement system through the Registrar and consumer-protection operations. The federal Office of the Superintendent of Bankruptcy (OSB) regulates the distinct statutory insolvency system discussed in section E. Neither regulator's role establishes jurisdiction over every other province or foreign transaction.

B. Who is regulated, and what authorization is required?

The definition turns on the activity and payment source—not the marketing title.

These distinctions follow CDSSA sections 1–2, 4–5 and 11 and Regulation 74 sections 18.1–19.11. The 2018 Registrar bulletin expressly confirms removal of individual collector registration and bonds. Legislative Assembly of Ontario+4

Registration and operating conditions

For an ordinary covered agency:

• Registration with Ontario's Registrar is required before operating. A business operating under another province's registration is not thereby registered in Ontario.
• A corporate agency must be incorporated under legislation of Ontario, Canada, or another Canadian province or territory. A foreign-only incorporation fails that particular statutory condition unless the structure changes in a legally valid way.
• Regulation 74 requires a permanent Ontario business location that is not a dwelling and is open during normal business hours. The Registrar's September 2021 bulletin permits remote work activities while requiring specified records to remain at the registered premises.
• The applicant's relevant experience must satisfy the regulatory two-year-or-equivalent test. Where the examination requirement applies, the official pass mark is 75% and the examination fee is CAD $10.
• Ontario's published application material lists CAD $290 for an agency application or renewal and CAD $290 per branch. These are governmental registration charges, not permissible charges to a debtor.
• Renewal material includes agency and key-person disclosures and accountant-certified financial statements addressing trust-account compliance. A complete timely renewal is important: a lapse can require cessation of agency operations and a new registration approval.
• No current general agency bond requirement was identified; the Registrar expressly recorded its removal effective January 2018. That does not mean there are no financial-statement, accounting or trust requirements. ontario.ca+6

A February 2026 Registrar bulletin concerning place-of-business requirements was discovered, but the document body was inaccessible. The enacted section 13(10) is therefore the controlling verified text; any administrative elaboration from that bulletin remains a follow-up item.

Exceptions require their predicates

The statutory exceptions include specified work by Ontario lawyers, regulated financial institutions, insurers and certain insolvency or court-appointed professionals, as well as other narrowly described persons acting in their authorized capacities. Regulation 74 section 18.1 applies some provisions back to lawyers who publicly present a debt-collection service outside their regular professional work; section 18.2 addresses paralegals. Neither “lawyer,” “charity” nor “financial institution” should become an automatic database-wide exemption flag. ontario.ca+3

A particularly easy error involves charitable credit counselling. Regulation 74 section 19.1(2) provides a government-fee exemption for a non-profit corporation that is an Income Tax Act registered charity providing credit counselling. The section's older individual-collector-registration language must be read in light of the 2018 removal of that registration system. It should not be used to infer exemption from agency registration, consumer-fee caps or contracts. ontario.ca+2

Ontario provides a public read-only business licence and registration search that covers collection agencies, debt-settlement providers and debt purchasers. The relevant checks are registration type, name, status, number and location, with attention to the directory's update limitations. No person or business was searched in this pass. ontario.ca

C. Consumer fees, performance and funds

Two prescribed contract methods

Regulation 74 section 27 requires an agency to specify the applicable method. The two alternatives have distinct bases:

These are ceilings, not Ontario's mandatory price for all providers. They apply to the ordinary covered agency under the relevant model. A contract can charge less; an exempt professional or a transaction outside the definition cannot automatically be assigned this fee schedule. ontario.ca+2

When may the agency earn or take its fee?

Under Regulation 74 section 28(1)–(2), for each creditor separately:

1. The debtor must have an agreement with that creditor about the amount to be paid to settle the debt.
2. The debtor must have made at least one payment under that agreement.
3. The agency must possess written evidence of that payment.
4. The charge must remain within the applicable contractual and regulatory limits.

A success on debt A does not authorize a fee for debts B and C. Section 28(3) adds a proportional ceiling on fees allocated to each creditor, using the agreement-wide permissible amount multiplied by that creditor's share of the debts. Section 28(4) permits a distinct one-time fee of no more than CAD $50 in the schedule-of-payments model before the normal earning prerequisites are met. Section 28(5) has a narrow dishonoured-cheque charge tied to the financial institution's actual charge. ontario.ca+3

CDSSA section 16.6 additionally prohibits unauthorized advance payment or security and reaches compensation paid indirectly or to another person as a condition of entering the arrangement. An agency that contracts before being registered is not entitled to fees for those services simply because it later registers or eventually negotiates a settlement. Legislative Assembly of Ontario

Money held for creditors is not the agency's earned fee

Regulation 74 section 17(1) treats normal-course money received from clients or debtors as trust money, except amounts clearly representing earned fees. It also expressly includes advance deposits for future services or expenses in the trust definition. Section 17 imposes designated separate trust-account and controlled-withdrawal rules; trust funds received from Ontario debtors generally must be deposited within two banking days. Use of a qualifying trust account elsewhere in Canada is conditioned on creditor instructions, equivalent restrictions, notification and written Registrar consent—not a free choice of foreign account. Section 18 requires accounting and remittance, generally by the 20th of the following month, subject to specified small-balance and unclaimed-fund rules. January 2018+4

Material source inconsistencyOntario's online agency guide places advance payments for future services outside its short description of trust funds, whereas the Registrar's official bulletin reproduces section 17(1) expressly including those advances. The enacted regulation is the stronger authority. More importantly, characterizing a prohibited upfront fee as “trust money” cannot make charging it lawful. That conflict requires direct regulatory-text reconciliation before publishing categorical instructions. ontario.ca+1

Creditor-funded remuneration is addressed by a mandatory contract disclosure: the agency must say whether it receives or seeks creditor funding connected to the debtor's agreement. The precise application of the debtor-paid statutory definition to a genuinely creditor-only-funded advisory arrangement remains fact-dependent. An agency cannot safely evade debtor-fee rules with a compulsory third-party payment or a differently labelled referral charge. Tax treatment or a GST/HST addition to a particular price was not established here and is not included in the examples.

D. Agreements, cancellation and remedies

The statute also provides a particular private court remedy. Under section 16.10, a debtor can bring an action in Ontario's Superior Court of Justice to recover prohibited charges/payments; if successful, the court ordinarily orders full recovery unless inequitable and may award exemplary, punitive or other proper relief. This is legally distinct from a Registrar penalty, registration suspension, administrative charge or criminal conviction. Legislative Assembly of Ontario+5

For amendments, Regulation 74 section 27 provides a renewed 10-day copy-receipt cancellation window for a qualifying amendment and preserves previously acquired rights and already settled debts. For an agreement entered before July 1, 2015, section 32's transition must be assessed before applying the later debt-settlement contract provisions. ontario.ca+1

Published forms access limitation: Both prescribed Ontario form entries were located in the Central Forms Repository, including English and French downloads. The one-time-payment PDF yielded only an Adobe/XFA compatibility message; the schedule-form download returned an unsupported content type. Consequently, the actual form-body wording was not readable and has not been invented. Their identity and first-page requirement are verified, but compliance with their complete printed content remains an explicit publication hold. Central Forms Repository (CFR)+5

Ontario's complaint guidance directs consumers first toward a documented written attempt to resolve the issue with the business and subsequently identifies the ministry's complaint route. A published ministry complaint-notice form describes a three-week business-response stage and possible Registrar enforcement; it is not a judicial decision or a guarantee of individual reimbursement. Official court/legal-help information remains a separate read-only pathway. No complaint or contact was made. files.ontario.ca+2

E. Federal boundary: private negotiation is not insolvency

The federal Bankruptcy and Insolvency Act (BIA), R.S.C. 1985, c. B-3, governs statutory bankruptcy and consumer-proposal processes; its official current text is consolidated through September 30, 2026, with a recorded June 20, 2026 amendment. Relevant gateways include sections 13 and 66.11–66.14. The OSB identifies a licensed insolvency trustee as the authorized professional administering these statutory proceedings. Under BIA section 66.13, a consumer-debtor proposal begins through assistance from the administrator and prescribed financial information—not a private settlement company's promise. laws-lois.justice.gc.ca+3

The OSB expressly warns about fee-charging debt advisors or lead generators that imply they can file consumer proposals, possess LIT status or provide access that consumers must buy. It also makes the important counterpoint that debt-management advice as such is not inherently prohibited; the activity and any insolvency-process representations determine the applicable rules. No federal statutory stay, compromise of dissenting creditors or discharge should be represented as the automatic consequence of an ordinary private settlement contract. ised-isde.canada.ca

F. Worked decisions — invented Ontario examples

All amounts are hypothetical Canadian dollars. They assume a current, properly registered Ontario agency; covered debtor-paid services; a compliant written agreement using the specified method; disclosed fees no higher than the stated examples; no taxes or separate creditor charges; and no accrued interest during the snapshot. The actual documents, creditor assent and time facts would govern any real case.

Example 1 — three debts, one-time-settlement method

At agreement signature:

Section 28(3) allocation independently produces:

• A: $1,000 × $4,800 / $10,000 = $480.00
• B: $1,000 × $3,600 / $10,000 = $360.00, but $0 currently earned
• C: $1,000 × $1,600 / $10,000 = $160.00, but $0 currently earned

If the firm charges the allowable $480, debtor cash outflow is $2,400 creditor payment + $480 provider fee = $2,880. Assuming creditor A's written terms make the $2,400 payment full satisfaction, A's remaining balance is $0; B and C still total $5,200 before interest or charges.

If the debtor then validly exercises a still-open statutory cancellation right and makes the qualifying refund demand, the provider returns the $480 already paid. Net consumer cash outflow becomes $2,400, while the completed agreement with A remains separately effective. Without the full-satisfaction writing, do not infer A was discharged. ontario.ca+3

Example 2 — two debts, payment-schedule method

At signature A owes $6,000 and B owes $4,000. The compliant schedule proposes to repay the full $10,000 in creditor payments. Its eventual percentage ceiling, if all such payments occur, is 15% × $10,000 = $1,500. The proportional creditor ceilings are:

• A: $1,500 × $6,000 / $10,000 = $900
• B: $1,500 × $4,000 / $10,000 = $600

Suppose A agrees in writing to the schedule; the debtor makes one $500 payment to A, and the agency obtains written evidence. B has neither agreement nor payment. The agency's currently supportable percentage fee for the A payment is 15% × $500 = $75—well within A's proportional ceiling. The contract also calls for the separately permitted one-time $50 schedule-model fee, already paid. Thus:

If proper statutory cancellation and a timely refund demand occur, the assumed $75 + $50 = $125 paid under the agency agreement is refundable, leaving a net consumer cash cost of $500 to the creditor. The original creditor balance remaining is still $9,500. This computation does not make the agency entitled to $75 without the written creditor agreement, actual creditor payment, agency evidence, valid provider registration and compliant contract. The treatment of any different contractual allocation of the $50 charge would require contract review. ontario.ca+4

Example 3 — claimed charitable exemption with a missing predicate

A company advertises itself as “non-profit credit counselling” and negotiates debts for a consumer fee. Its Canadian registered-charity status cannot be established.

Decision: Do not suppress the agency-registration or fee rules. Obtain evidence of its legal structure, registered-charity qualification, actual activities and Ontario registration. Even proven section 19.1(2) charitable status affects the government registration fee, not an unlimited right to charge consumers upfront. If the entity only supplies uncompensated financial education and never performs the statutory activities, the initial classification may differ. ontario.ca+2

Example 4 — out-of-province remote provider

A corporation based outside Ontario solicits an Ontario resident remotely, charges for negotiating credit-card debts and claims that its home-jurisdiction authorization is sufficient.

Decision: The Ontario debtor's location during the dealing potentially satisfies CDSSA section 2(0.1). The agency-registration, Canadian-incorporation and permanent-Ontario-location requirements need examination. Unknown facts include who made the offer, where each party was when dealing occurred, which legal entity contracted, where money is held and whether any claimed exemption applies. An unrelated province's authorization alone does not resolve Ontario compliance. ontario.ca+3

Example 5 — delivered copy, defective copy or uncertain notice

An Ontario debtor signed an agreement, but cannot establish whether the agency delivered the prescribed written copy or when a cancellation email was sent.

No calendar deadline is calculated because signature, compliant-copy receipt, notice method, destination and possible amendment facts are missing. Legislative Assembly of Ontario+3

Example 6 — professional title without professional-work facts

A debt-relief service says that “a lawyer oversees all negotiations.” It does not establish that the contracting and negotiating person is an Ontario-licensed professional acting in regular professional practice.

Decision: This claim alone is insufficient for the professional exception. Determine contracting entity, professional qualification, work actually performed, fee recipient, employee authority, public-facing collection activity and Regulation 74 sections 18.1–18.2 carve-backs. The adverse branch is unregistered agency activity and loss of fee entitlement under section 16.6(4), without any automatic cancellation of the consumer's original debts. ontario.ca+2

Register 1 — primary sources and access provenance

Source-check window: October 26, 2026, approximately 20:38–20:53 UTC / 1:38–1:53 p.m. Pacific (PDT) / 4:38–4:53 p.m. Ontario (EDT). All entries below are fresh public-source retrievals in this pass; no sibling findings, previous model reports or coordinator materials were adopted.

Reading-status terms:

• Body read: relevant text actually returned and examined.
• Indexed excerpt: official source's relevant statutory or guidance wording surfaced in search, but direct page access failed. This is weaker than examination of the complete current consolidation.
• Metadata only / unread: the item was identified but its substantive body could not be examined.
• PDF P0, P1, etc., means a zero-based text-extraction page index, not a visual screenshot. No PDF page pixels were inspected.

The full URLs are given literally, rather than shortened citation references.

Version caution: A prior historical version of a regulation may display a now-repealed bond or individual-collector-registration clause, or a prospective commencement note. The current consolidations (S001–S002), with applicable historical and transitional provisions, control the present rule. A form listing, an inaccessible PDF, an HTML search snippet, a ministerial guide and a formal statute do not have identical evidentiary weight.

Register 2 — atomic claim-to-authority ledger

This register assigns a separate identifier to each material rule or research-limitation finding. “Indexed” means the rule was recovered from Ontario's official indexed text but the entire current enactment was not directly readable. Statutory provisions are controlling to the extent accurately reflected in the current consolidation; a ministry interpretation is identified separately.

A. Framework, jurisdiction and classification

B. Actors, registration, exemptions and oversight

C. Agreements, fees, payments and accounting

D. Cancellation, refund, remedies and enforcement

E–F. Federal boundary and worked computations

The two monetary examples use whole-dollar/whole-cent values and therefore have CAD $0.00 rounding adjustments. Neither includes an unsupported tax surcharge, interest estimate, consumer's actual contractual price, creditor-settlement probability or provider earnings guarantee.

Register 3 — granular A097/A098 Ontario component coverage

“Answered” means a substantive rule was identified within this focused component, not that every underlying source has passed independent verification. “Partial” identifies a material evidence or interpretation gap. “Unresolved” means no safe operative conclusion. All references are to claims above and findings A–F already displayed.

A. Controlling framework and territorial application

B. Actor classification and authorization

C. Fees, performance and money

D. Contracts, cancellation and enforcement

E. Narrow federal route

F. Scenarios and quantitative validation

Consumer document checklist and likely adverse branches

For a consumer or editorial case study, collect or request the following from the consumer's own records before deciding entitlement:

1. All signed versions of the provider agreement, amendments, appended first-page disclosure, delivery emails and original document metadata.
2. Agency's exact contracting name, stated Ontario registration number, any separate fee recipient, business address and dated advertisements or sales representations.
3. Each creditor's name, original and signing-date debt balance, interest terms, offers, written acceptance and release or full-satisfaction language.
4. Every payment confirmation, recipient, bank statement excerpt, receipt, agency-held-funds ledger and refund transaction.
5. Written agency evidence of the debtor's first payment under each creditor agreement, if supplied; the actual agency claim of fee entitlement.
6. Cancellation and refund notices with full text, address or channel, transmission receipt and delivery evidence.
7. Performance reports, creditor refusals, authorization notices and service correspondence.
8. Any pre-2015 contract and amendment chronology or claimed lawyer/charity/LIT exemption evidence.

Likely adverse branches include an unregistered agency, fee claimed before its creditor-specific trigger, prohibited indirect charge, noncompliant first page, missing copy, late or unprovable cancellation notice, missing refund demand, mishandled trust money, or creditor refusal. None, standing alone, proves that an underlying debt has vanished. The proper next actor may be the Ontario Registrar, a lawyer, or a licensed insolvency trustee depending on which distinct legal issue is actually present.

Explicit country/province research boundary register

Ontario only — other Canadian jurisdictions unresearched| Jurisdiction | Status in C_CA-P01 | Required next focused investigation | | --- | --- | --- | | Ontario | Focused provider component researched; partial evidence holds | Resolve unread forms, complete e-Laws text, professional carve-backs, money-account treatment and decisions | | Alberta | Not researched | Establish independently the current collection/debt-repayment licensing categories, exemptions, consumer fees, agreements, refund and money-handling rules | | British Columbia | Not researched | Independently investigate debt repayment agency regulation, licensing, fee formula, trust funds and cancellation | | Manitoba | Not researched | Independently identify collection and credit-counselling/debt-management laws and the current licensing/contract rules | | New Brunswick | Not researched | Independently investigate its enacted debt-settlement act/rules, commencement, fees and oversight; no New Brunswick draft used as Ontario authority | | Newfoundland and Labrador | Not researched | Locate current collection/debt settlement enactments, licences, exemptions, fees and cancellation | | Nova Scotia | Not researched | Investigate collector and debtor-side debt-management categories, licensing, trust and contracts | | Prince Edward Island | Not researched | Establish present statutory collection/debt counselling activities, provider authorization and safeguards | | Quebec | Not researched | Research applicable Quebec legislation independently in authoritative French and English where available; no Ontario terms transplanted | | Saskatchewan | Not researched | Identify current collection-agent/debt-adjustment licensing, fees, contracts and provincial enforcement | | Northwest Territories | Not researched | Independently research territorial licensing and consumer fee/contract rules, plus applicable federal gateways | | Nunavut | Not researched | Independently research territorial collection/debt-settlement authority, commencement and consumer safeguards | | Yukon | Not researched | Independently investigate territorial consumer/collection agency statutes, exemptions and money handling | | Canada federal boundary | Only insolvency gateway reviewed | Separate federal banking, communications, competition, privacy, financial consumer, taxation and cross-border analyses remain necessary |

No findings for the other provinces or territories, local jurisdictions, Indigenous governance systems or contracts are incorporated by analogy.

Explicitly deferred A097/A098 country questions

Briefly mentioning any of these as a boundary does not count as researching or completing it.

Researcher self-check and publication controls

Material new questions generated

1. Does the present Ontario e-Laws text of Regulation 74 section 17(1) still reproduce every word of the Registrar's 2018 bulletin, and why does the Ontario trust guide describe advances differently?
2. What exact wording appears on all four English/French prescribed first-page PDFs, including cancellation instructions, warnings and language-specific nuances?
3. Which specific portions of sections 18.1 and 18.2 apply back to lawyers/paralegals conducting high-volume or separately advertised collection and negotiation activities?
4. Does section 19.7's corporate-debt collection exclusion affect a debtor-paid settlement arrangement involving a corporate guarantor or individual business-purpose borrower, and by which exact statutory route?
5. What happens to the section 28(3) proportional ceiling when debts are added, balances change, or a separate CAD $50 schedule charge is contracted?
6. Which payment processors or independent trustees holding consumer funds require a distinct authorization or satisfy the agency's trust duties—and who legally owns deposited money?
7. What current Ministerial registration fee order, February 2026 place-of-business guidance, and tribunal decisions add to the publicly indexed rules?
8. Which additional CPA 2002 requirements actually apply to qualifying online, remote or direct agreements without conflicting with the CDSSA-specific regime?

Evidence-grounded SettleADebt opportunities

These are proposed information products, not implemented or approved for publication:

Final disposition

C_CA PASS-01 focused research is completed to the extent of available public primary-source access, with the complete findings, quantitative scenarios and visible registers provided here. The outstanding evidence holds are material: unread prescribed forms, direct complete current e-Laws text, professional carve-back details, some money-handling and nonresident branches, and unverified case-law coverage.

This is a research submission, not independent legal review, a published consumer legal article, or an operational determination about any firm or debtor. The coordinator must separately verify consequential primary-source wording, arithmetic, exceptions, effective dates and the coverage classifications before accepting any Ontario component. The Canada country dossier and A097/A098 remain open; no provincial, territorial, operational or publication acceptance is asserted.

END C_CA PASS-01