A federal fee frozen since 1998 pays $170 an hour and needs no licence.

The capital is CAD $705.65 (USD $500 at 1.4113, Bank of Canada daily average, 6 November 2026 — the most recent posted rate at the time of writing) and the target is CAD $7,056.50 a month (USD $5,000), or CAD $84,678.00 a year. The claim of this edition is that Canada’s insolvency system contains exactly one well-paid job that is not licensed, that its price is set by a regulation nobody has touched in twenty-eight years, and that the entry cost of reaching it — CAD $1,582.00 — is more than twice the capital this series starts with.

Start with how closed the system looks. The Office of the Superintendent of Bankruptcy licenses Licensed Insolvency Trustees; the Superintendent’s own regulatory analysis counts about 1,000 of them, working out of about 3,200 offices, and states that “over 100 000 insolvency proceedings are filed by LITs every year.” Becoming one means the CIRP Qualification Program, articling, the national exam, and a licence the Superintendent may refuse. That is the picture most people have of this industry, and for the file as a whole it is accurate.

Now read section 157.1 of the Act. Subsection (1) says the trustee “shall provide, or provide for, counselling for an individual bankrupt…in accordance with directives issued by the Superintendent…and the estate of the bankrupt shall pay the costs of the counselling, as costs of administration of the estate, according to the prescribed tariff.” Paragraph 66.13(2)(b) does the same for a consumer proposal. Subsection 157.1(3) supplies the enforcement: the automatic discharge in s. 168.1(1) “does not apply to an individual bankrupt who has refused or neglected to receive counselling.” Two words in that chain matter commercially. Shall — the sessions are not optional. Prescribed tariff — the price is not negotiated.

The prescribed tariff is section 131 of the Bankruptcy and Insolvency General Rules, headed Miscellaneous Fees. For a consumer proposal under paragraph 66.12(6)(b), and again for a bankruptcy under subsection 157.1(1), it reads: $85 per session for individual counselling and $25 per person per session for group counselling. The amendment history on the Justice Laws Website attributes those figures to SOR/98-240, s. 1, with a later English-only correction in SOR/2007-61. The consolidated Rules are current to 19 October 2026 and were last amended on 25 March 2011. Nothing has moved the number in twenty-eight years.

Then read Directive No. 1R8, Counselling in Insolvency Matters, issued under paragraphs 5(4)(b) and (c) of the Act and in force on 18 March 2024. Paragraph 22 prescribes exactly two sessions: the first between ten and ninety days after the initial bankruptcy event or the filing of a consumer proposal, the second after at least thirty days and before discharge or the certificate of full performance. Paragraph 12 is the door. A trustee may register an individual as a BIA Insolvency Counsellor in the OSB Licence Administration Application by attesting that the person holds “either a high school diploma or high school equivalency certificate” plus three years of relevant work or thirty post-secondary credit hours; has completed the Practical Course on Insolvency Counselling; has been directly observed providing “a minimum of ten (10) insolvency counselling sessions”; carries professional liability insurance; and undertakes “a minimum of three-and-one-half (3.5) hours of professional development training” every two years.

That is the whole gate. No Superintendent’s licence, no regulator-set examination, no bond, no articling. Paragraph 13 adds the only exclusions that bite: an individual is ineligible if they are involved in lending or financing to debtors, or act as an Intermediary or a Referral Arranger — which is to say, the regulator cares that the counsellor is not selling the debtor anything, and does not otherwise care who they are.

So price the session against the regulator’s own evidence of how long one takes. The OSB’s study Opportunities to Enhance the Usefulness of the Insolvency Counselling Sessions, built from nearly 250,000 Report on Counselling forms filed between January 2020 and May 2021, found the most common session length is 15 to 30 minutes — 52.1% of all sessions — and that the OSB encourages thirty. At thirty minutes the prescribed fee is CAD $170 an hour. At the lower bound of the modal band it is CAD $340. The same study found that after March 2020, 73% of sessions were delivered by telephone and 17% by videoconference, against about 74% in person before it, so the hour in question is largely an hour at a desk.

Then look at what has happened to that number since it was written. Canada’s Total CPI stood at 91.0 in April 1998 and 169.8 in August 2026. Restated, the 1998 fee is CAD $158.60 today: 85 × 169.8 ÷ 91.0. The fee has lost 46.41% of its value standing still. On 29 November 2025 the Superintendent pre-published a proposal to raise it to CAD $120 individual and CAD $35 group, both “indexed to inflation, updated annually, and rounded to the nearest $5” from 1 April 2027. The Regulatory Impact Analysis Statement says plainly that the tariff “has not been significantly modified since 1998 and does not account for inflation.” The comment period closed on 29 December 2025. The consolidated Rules still read $85, so it has not been made.

Here is the part the consultation did not say out loud. The same proposal raises the trustee’s summary administration fee from $975 to $1,700 — a 74.36% step — and the counselling fee by 41.18%, which still leaves the counselling fee 24.34% below its 1998 purchasing power while the trustee’s line comes much closer to being made whole. Indexation from 1 April 2027 would then lock that shortfall in permanently: once a number is indexed, the gap it starts with never closes.

The demand side is not in doubt, which is unusual for this series. In the twelve months to 31 August 2026 Canada recorded 146,135 consumer insolvencies, up 5.8% year over year — 32,109 bankruptcies and 114,026 consumer proposals — against 150,893 insolvencies of all kinds. Two compulsory sessions each is 292,270 sessions a year, or 24,355.83 a month, a national fee pool of CAD $24,842,950 at $85 and CAD $35,072,400 at $120.

And here is where the arithmetic turns. Run it as an Ontario sole proprietor at the 2026 federal and Ontario rates with the Ontario Health Premium and self-employed CPP, and netting CAD $7,056.50 a month takes 123.6745 sessions a month at the full $85 — 5.6216 a working day, and only 14.27 hours a week of actual counselling at thirty minutes a session. Capacity is not the wall. Supply is: 123.6745 sessions a month is 0.5078% of the national monthly flow, but spread across 3,200 offices it is the entire counselling output of 16.25 average trustee offices — and counselling is revenue a trustee generally keeps in-house. Worse, paragraph 27 of the Directive says the trustee may remit to a registered counsellor an amount “not exceeding the fee prescribed by the Rules”: $85 is a ceiling on what you can be paid, not a price you can quote. No published figure for what counsellors are actually paid was found on this run.

The non-consensus reading, then, is not that this is easy money. It is that Canada’s insolvency system has exactly one unlicensed, compulsory, federally priced job in it; that the price is CAD $170 an hour at the regulator’s own encouraged session length; that the price has been falling in real terms since 1998 and the proposed fix leaves it 24.34% short before freezing the shortfall; and that the only thing standing between a reader and it is a trustee’s signature on an attestation. The entry cost is CAD $1,582.00 — 2.24× the capital this series starts with. The gate, for once, is cheap and the customer is the problem.