In December 2013, the Attorney General of Canada filed a Request for Direction regarding the implementation of the 2006 Indian Residential Schools Settlement Agreement (IRSSA) by the Corporation of Catholic Entities Party to the Indian Residential School Settlement (CCEPIRSS). Specifically, Canada sought clarity from the courts on CCEPIRSS’ deduction of its legal fees from its financial payments under IRSSA. This factum, or statement of facts, was submitted by William F. Pentney, Deputy Attorney General of Canada, and Alexander Guy and Anne McConville, Counsel for the Attorney General of Canada, on May 15, 2014. It outlines Canada's position regarding the facts, issues, argument, and order sought in this case.

The factum includes the following sections:
1. Introduction
2. PART I - FACTS: Background to the IRSSA; Understanding the Structure of the IRSSA; The Creation of CCEPIRSS; Financial Commitment of the Catholic Entities/CCEPIRSS; AANDC Communications with CCEPIRSS; Status of Contributions made by the CCEPIRSS/Catholic Entities; Accounting Discrepancies Identified on Cross-Examination.
3. PART II - ISSUES
4. PART III - ARGUMENT: CCEPIRSS must Transfer no Less than 80% of all Contributions received from the Catholic Entities to the AHF, before Deducting Administrative Expenses; CCEPIRSS is not Entitled to Deduct Legal Fees for Services not Related to the Management of the Contributions or for Matters that are the Sole Responsibility of the Catholic Entities?; Canada can Withhold Consent if the Administration Costs are not Reasonable; The Actions of CCEPIRSS are "Oppressive", "Unfairly Prejudicial" and "Unfairly Disregard" the Interests of the Public; Canada is not Estopped from Refusing to Approve the Legal Fees; The IRSSA precludes Collateral (Oral) Agreements.
5. PART IV - ORDER SOUGHT