I imagine that would always be possible. However, I will not get into hypotheticals, especially since I don't work on approvals at the Office of the Superintendent of Financial Institutions, but rather on legislation.
However, we have to look at the criteria the minister must assess. According to the proposed amendment, he can use any criteria, but he must absolutely use two, one of which is the interest of the overall financial system.
If the superintendent believes that a transaction should not go forward because the financial institution is not strong enough to enter into that transaction, for example, how could the minister find that that same transaction is in the system's interest? It is therefore unlikely that the minister would find grounds to decide otherwise.
However, this is speculation, and I will not go any further.