SABs for medical and rehabilitation benefits and attendant care
benefits did not match the jury award for future care costs
because the SABs would be exhausted shortly after trial, but the
jury award was for lifetime damages. In effect, in making this
latter argument the appellants’ position is that it does not matter
whether the jury award necessarily covered the same damages;
since the SABs payments can be linked temporally to specific
damage periods while the jury award cannot be, the temporal
matching required by strict matching standards is defeated.
 The respondents maintain that no strict matching principle should be imported into the current statutory scheme, as the
significant amendments that were subsequently made to the legislation after Bannon address the policy rationale underlying that
decision, namely, ensuring fair compensation and preventing
double recovery. They contend that Gilbert should be overruled
because it erroneously applied the Bannon approach and cannot
be reconciled with the decision of the Supreme Court of Canada
in Gurniak v. Nordquist,  2 S.C.R. 652,  S.C.J. No. 60,
2003 SCC 59.
 The McEwens alternately suggest that if the strict matching approach applies, it can be satisfied: as in El-Khodr v. Lackie
(2017), 139 O.R. (3d) 659,  O.J. No. 4828, 2017 ONCA 716,
leave to appeal to S.C.C. refused  S.C.C.A. No. 461, Ms. Carroll is catastrophically impaired, no temporal matching problem
arises and there are no benefits for which assignment is requested that would not be permitted under the legislation.
 For the reasons that follow, we do not agree with the appellants’ submissions. In our view, the silo approach adopted in
Cadieux should similarly apply to the assignment of SABs.
 In Cadieux, we outlined the historical development of two
inconsistent approaches to matching SABs to tort damages, as
well as the state of the authorities. We noted that while the broad
silo approach has more recently been applied to the deduction
of SABs received or available before trial, the strict approach
has continued to apply to those assignment cases that cannot be
factually distinguished from Gilbert. This state of the law is
 In Cadieux, in the face of this conflicting authority, we
affirmed that the silo approach applies to the deduction provisions. We did so because the silo approach is consistent with the
current statutory language, is fair to plaintiffs, defendants and
their insurers, and promotes efficiency in motor vehicle accident
litigation. It is also consistent with the reasoning in Gurniak.
 In our view, these considerations apply equally in assignment cases. Section 267.8 is integrated in the sense that, together,