I'm the policy director at Corporations Canada.
Prior to 1975 shares were issued under the Canada Corporations Act. They were a different form in that shares were issued according to par or par bought value shares. Generally, again, the act was silent with respect to bearer form. The intent always, as part of the transition from the old act to the current Canada Business Corporations Act, was to get rid of shares in par value. The concept of all shares having to be in registered form was consulted on. It was part of the original Dickerson report. It was part of two bills through Parliament. Nobody ever had any comment or objection that I've been able to find about the fact that shares would be in bearer form.
Our disagreement with the FATF has always been that we say shares have to be in registered form. They look at another provision that says securities can be in bearer form, securities involve shares. Our argument is the specific overrides the general. Their argument is that they don't agree with us. That's why we've been in the FATF last two reports and if you look at what the witnesses picked up, they were quoting the FATF report. They weren't quoting what we had always argued with them.