Set-off and security interests

In the 2009 decision 'Caisse populaire Desjardins de I'Est de Drummond v Canada', Rothstein J, on behalf of a majority of the Supreme Court of Canada (SCC), acknowledged, by extension, that a transaction incorporating or prominently featuring a right of set-off may create a security interest under the 'Personal Property Security Act ("PPSA")'. In this article, I approximate an answer to an important threshold question that flows from that acknowledgment, and pose and address a further series of derivative questions.