under a charging order. In such a case the secured creditor is
perfected by registration.
 The relevant portions of the section read as follows:
Unperfected security interests
20(1) Except as provided in subsection (3), until perfected, a security interest,
(a) in collateral is subordinate to the interest of,
( i) a person who has a perfected security interest in the same
collateral or who has a lien given under any other Act or by
a rule of law or who has a priority under any other Act, or
( ii) a person who causes the collateral to be seized through execu-
tion, attachment, garnishment, charging order, equitable
execution or other legal process, or
( iii) all persons entitled by the Creditors’ Relief Act, 2010 or oth-
erwise to participate in the distribution of the property over
which a person described in subclause ( ii) has caused seizure
of the collateral, or the proceeds of such property[.]
 In my view, these arguments fail by virtue of the fact that
the charge that is created by s. 32(3) of the CPA should be treated
as effectively a solicitor’s lien which is an exception in s. 4(1)(a) of
the PPSA. As a result, the PPSA does not apply and s. 20(1)(a)( ii)
never takes effect to give the perfected security interest priority
over seizure under a charging order.
 Although, as noted, there are no cases directly dealing with
these issues the most useful starting point is the decision of the
Court of Appeal in Hislop v. Canada (Attorney General), supra.
In Hislop, at para. 32, the Court of Appeal defined the first
charge provided for by the CPA as “essentially a solicitor’s lien”.
Admittedly this is obiter, but there are no competing decisions
and, in my view, the analogy is a sound one. Solicitor’s liens are
also more well known to the law than the first charge provided
s. 32(3) of the CPA. There is instructive jurisprudence as to
how one should resolve conflict between such liens and other
 The common law of solicitor’s liens has been codified in
Ontario by s. 34(1) of the Solicitors Act, R.S.O. 1990, c. S.15,
34(1) Where a solicitor has been employed to prosecute or defend a proceeding
in the Superior Court of Justice, the court may, on motion, declare the
solicitor to be entitled to a charge on the property recovered or preserved
through the instrumentality of the solicitor for the solicitor’s fees, costs,
charges and disbursements in the proceeding.