Ontario · CCAA
Factum of the Receiver -Motion for Distribution and Discharge Order – dated October 20, 2026
Application / notice of application · 20 October 2026
AI summary
A plain-English summary drawn only from this filing: what it is, why it matters, and the parties, amounts and dates it turns on.
What we verified from this filing7 verified
- secured creditorsnote: Aggregate amount of Proven Junior Noteholder Claims is not stated in this factum. Claims finalized through negative-notice claims process (Claims Bar Date August 5, 2026); no Notices of Dispute received, so Statements of Accepted Claim are deemed accepted. Proceeds are expected to satisfy the Junior Notes only partially (pro rata, 'partial satisfaction'). · page: 3 · debtor: Synaptive Medical Inc. · creditor: Junior Noteholders (holders of subordinated secured promissory notes issued June 26, 2025) · currency: CAD · security: Subordinated secured promissory notes (the Junior Notes), ranking junior to EDC's Senior Note
- secured creditorsnote: Principal balance of the Senior Note is not stated in this factum. Document states the ARVO transaction was expected to generate proceeds sufficient to pay all of the senior secured debt owed to EDC. Enforcement costs and interest accruing thereon form part of the senior secured obligations under the GSA (see separate enforcement-costs entry). No proceeds had yet been distributed to EDC as of the factum. · page: 3 · debtor: Synaptive Medical Inc. · creditor: Export Development Canada (EDC) · currency: CAD · security: Senior secured promissory note (the Senior Note) secured by a General Security Agreement; EDC is described as Synaptive's senior secured creditor
- unsecured creditorsnote: Document states HCS is 'owed over $1 million' in respect of its subcontract (floor, not an exact balance; 'over' is the operative word). HCS is the only known subcontractor with a claim to the $302,742.72 BuildNS holdback funds held in statutory trust under Nova Scotia's Builder's Lien Act; Receiver says these funds are impressed with a statutory trust and are not part of the estate. · page: 5 · basis: HCS statutory declaration setting out work completed and status of accounts · debtor: Synaptive Medical Inc. · creditor: Health Care Solutions Inc. (HCS) - subcontractor on BuildNS project · currency: CAD
- secured creditorsnote: Stated as '$182,447.44 plus interest' in respect of enforcement costs as of July 10, 2026. Not addressed expressly in the original Distribution and Claims Procedure Order (through inadvertence); amendment sought. Receiver's counsel (McMillan) obtained an opinion at the start of the receivership confirming validity of EDC's security. · page: 6 · as of: 2026-07-10 · amount: 182447.44 · debtor: Synaptive Medical Inc. · creditor: Export Development Canada (EDC) - enforcement costs component of Senior Note obligations · currency: CAD · security: General Security Agreement securing the Senior Note; enforcement costs and interest accruing thereon form part of the senior secured obligations
- unsecured creditorsnote: Disputed: Receiver seeks declaration that claim lies, if at all, exclusively against ResidualCo under para 7 of the ARVO. Document says the claim 'seeks $3 million in damages'. Pacer's lien rights under the warehousing agreement and the Repair and Storage Lien Act were preserved in the ARVO at its request, but the Receiver says the action is for damages, not in rem lien enforcement. Pacer had not responded to the motion. · page: 7 · basis: Statement of Claim issued September 2026 for breach of contract (warehousing arrangements); asserted claim, not adjudicated · amount: 3000000 · debtor: Synaptive Medical Inc. (claim asserted against Synaptive; Receiver says liability, if any, vested in ResidualCo under the ARVO) · creditor: Pacer Air Freight Ltd. (Pacer) · currency: CAD
- unsecured creditorsnote: Preferred/priority claims. Federal agency denied employees' WEPP claims on the basis that the ARVO negated their entitlement; Receiver disagrees and seeks permission to pay s. 81.4 priority amounts directly to employees. · page: 9 · basis: Statutory priority claims for wages under BIA s. 81.4 (preferred / priority class); amounts not stated in this factum · debtor: Synaptive Medical Inc. · creditor: Terminated employees of Synaptive (priority claims under BIA s. 81.4 / WEPP) · currency: CAD
- counselMcMILLAN LLP