| December 10, 1990 | |
| Registered Plans Division | Financial |
| Stella M. Kotlar, Director | Industries |
| Division | |
| D.S. Delorey | |
| Attention: B.J. Greer | 957-3494 |
| 24(1) | 7-902864 |
SUBJECT: Proposed Self Directed Registered Retirement Savings Plan ("RRSP")
This is in reply to your memorandum of October 12, 1990 concerning the 24(1) proposed self-directed RRSP submitted to the Department for approval.
Our files indicate that we have consistently taken the view (since at least 1974) that where the word "deposit" appears in the Act, it should be given the meaning it has within the particular trade or business involved. This view is reflected in the second paragraph of number 5 of IT-360R2.
Where a bank is involved (e.g., where the "depositary" referred to in clause 146(1)(j)(ii)(C) of the Act is a bank), we have consistently maintained that a "deposit with a bank" is one that is shown on Schedule "J"; i.e., the "Consolidated Return of Assets and Liabilities" that a bank must file periodically with the Inspector General of Banks 23 21(1)(b)
We therefore support your position that 24(1) proposed self-directed RRSP should not be approved.
21(1)(b) 23
for DirectorFinancial Industries DivisionRulings Directorate