Proposed subsection 23(5) wasn't intended to address the “Yes, we're issuing a reference number” or “No, we're not issuing a reference number”. It was intended to ensure that there is authority should the registrar, or the people acting on behalf of the registrar, need to go a bit further and explain to the transferor that the registrar was not satisfied that the person was eligible. It was just intended to ensure that there is that statutory authority for the registrar to take that step beyond that.
On June 7th, 2018. See this statement in context.