As a practical matter, the parties’ differing positions only
affect the valuation of U.S. dollar investments that had been
written off during the lifetimes of Funds 1 and 2.
 The trial judge accepted the methodology proposed by Mr.
Manastersky. RBCDS submits he erred in so doing.
B. The evidence
 From the point of view of the main investor in the Mezzanine Fund — the Bank — its capital investments in the Fund
were fully hedged at the Bank, not Fund, level against the risk of
foreign exchange fluctuations. However, the Mezzanine CIP did
not contain any express provision dealing with the impact of
foreign currency exposure on returns to employee participants.
 The methodology advanced by Mr. Manastersky at trial
had been used by RBCDS to calculate payments made under the
2000 Plan to participant employees for the investment periods
between 2001 and 2004.
 In August 2013, RBCDS retained Kroll Inc. to provide
advice on the appropriate foreign exchange methodology to use in
winding-down a carried interest plan that was separate from, but
used language similar to that in, the Mezzanine CIP. Ms. Bessie
Petroff, a vice-president on the financial and accounting side of
RBCDS, testified that the company had reached out to Kroll for
their “guidance and assistance . . . because there was nothing
implied in [the other carried interest plan] to help guide us on
how to do it”. According to Ms. Petroff, the Mezzanine CIP also
was “silent” on what foreign exchange methodology to use. When
taken to the definition of “invested capital” in the Mezzanine CIP
as “the original book value of the Investment . . . determined in
accordance with Canadian generally accepted accounting
principles consistently applied”, Ms. Petroff testified that the
definition did not specify the currency or the applicable exchange
 Alan Hibben, the RBCDS executive involved in setting up
both the 2000 Plan and the Mezzanine CIP, acknowledged that
the absence of any foreign exchange methodology was a “miss” in
the plan documents, which they had to cover by adopting a
 The trial judge heard evidence from Mr. Peter McFarlane,
the individual at Kroll who supervised giving RBCDS foreign
exchange methodology advice in 2013. Mr. McFarlane is a chartered professional accountant. He was not qualified as an expert
witness nor did he provide a report under rule 53.03 of the
Rules of Civil Procedure, R.R.O. 1990, Reg. 194. Mr. McFarlane