accordance with s. 7.2.1 of the Mezzanine CIP. The collective
effect of the evidence of Ms. Petroff and Mr. Hibben was that the
definition of “Invested Capital” did not provide them with contractual guidance about which foreign exchange methodology to
use. That contractual silence was one reason why RBCDS sought
outside advice from Kroll on the issue.
 Second, Mr. McFarlane, who supervised Kroll’s provision of
advice to RBCDS, did not testify that GAAP required the
Mezzanine Plan to use the exit rate for calculating payments out
to participants. His testimony was to a different effect, as can be
seen from the following exchange during his examination-in-
Q. When you provided advice to Royal Bank Capital Partners, what was your
view as to whether the foreign exchange methodology applied was consistent
or inconsistent with generally accepted accounting principles under the CICA
handbook or IFRS?
A. My view was that, you know, the — the requirements of GAAP with regard
to the foreign country translation were — were dealt with at — at the macro
level at the bank, and so the assumption was that certainly at a macro level
that the bank was conducting itself in accordance with GAAP.
Q. And what was your view as to whether the foreign exchange methodology
was consistent or inconsistent with the methodology referred to in Royal
Bank’s published financial statements?
A. It was consistent.
Q. And have you views on these issues changed?
Q. Is there any requirement under accounting standards that the foreign exchange methodology used in the carried interest plans be the same methodology used in Royal Bank’s published financial statements?
 Mr. McFarlane did testify, in re-examination, that the “exit
rate” methodology he had proposed to RBCDS was the “preferred
rate”, but he did not put his view any higher than that.
 Third, although Mr. Manastersky is not a chartered
professional accountant, he had decades of experience making
and managing investments. That experience provided a firm basis
for the trial judge’s acceptance of Mr. Manastersky’s evidence
about the appropriate foreign exchange methodology for the
investments that he had managed, especially given his
unchallenged evidence that the methodology had been used by
RBCDS to calculate payments out to participants under the