The registrant agreed with a bank (CIBC) that automatic banking services would be provided through ABM machines in the registrant's stores. Non-CIBC clients could use the machines for a $1.50 service charge, and CIBC paid a share of this revenue to the registrant. Hogan J., in dismissing the registrant's appeal, rejected its submission that it was making an exempt supply to CIBC of the service of arranging for financial services (the automatic banking services). An example of "arranging for" a financial service could be found in President's Choice Bank. Here, in contrast (para. 36):
The appellant did not help, assist and become directly involved in the provision of financial services by CIBC to ABM customers. Its role in the provision of such services was considerably more passive. The core element of its supply to CIBC was the provision of space in its stores.