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  • Can a Late Higher Bid Reopen a Receivership Sale? Lessons from Cameron Stephens Mortgage Capital Ltd. v. Conacher Kingston Holdings

Can a Late Higher Bid Reopen a Receivership Sale? Lessons from Cameron Stephens Mortgage Capital Ltd. v. Conacher Kingston Holdings

Insolvency Insider
Insolvency Insider

Aug 21, 2026

Can a Late Higher Bid Reopen a Receivership Sale? Lessons from Cameron Stephens Mortgage Capital Ltd. v. Conacher Kingston Holdings

Simon Wu and Aaron Libby of Clark Wilson examine the Ontario Court of Appeal’s decision in Cameron Stephens Mortgage Capital Ltd. v. Conacher Kingston Holdings, which confirms that a court may reopen an otherwise fair receivership sale process where a materially higher late bid emerges before approval, provided the potential value gain justifies the resulting impact on process certainty and bidder expectations.

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