I'll speak to three areas of impact that we would note.
First, as noted, this has been a collective exercise over the course of successive rounds of legislative amendments to try to ensure a cohesive approach with the provinces and territories across the country. The 25% standard was what was agreed to with the provinces and territories. That's what they are working to hold their beneficial ownership standard to as they build out their legislative requirements.
The differential between those potentially does a couple of things. One is that it may shift people out of the Canada Business Corporations Act and into a provincial or territorial incorporation. The second is obviously that it doesn't create a unified national standard.
The second is, as you have noted, the comparability across regimes in terms of the ability to be able to look across and actually understand they are comparing apples to apples.
The third is probably more of an implementation issue. This is premised on the the notion of belts and suspenders, in many ways. There is a corresponding obligation in the Proceeds of Crime (Money Laundering) and Terrorist Financing Act for financial institutions to collect information related to 25% beneficial owners and to discrepancy match that information against the information that is contained in our registry.
They will be collecting different information from what we will be collecting in our registry, so the capacity for the efficiency of the discrepancy matching becomes both administratively burdensome and inconsistent.