After quoting authorities on the meaning of "security," including a statement in Canadian & Foreign Securities Co. v. M.N.R., [1972] C.T.C. 391 at 395, 72 DTC 6354 at 6356 (F.C.T.D.) referring to "instruments for the payment of money," the questioner submitted that "segregated funds should be considered ‘securities' within the popular sense or commercial meaning of the term." CRA responded: