WINNIPEG, MB: Crystal Buhler, a licensed insolvency trustee and the president of C. Buhler & Associates Ltd., spoke on a panel at the 23rd Annual Review of Insolvency Law Conference. The panel addressed bad-faith stakeholders in consumer insolvencies.
The conference was held on February 6th, 2026, in Toronto, and welcomed 700 attendees. It was held by the Canadian Association of Insolvency and Restructuring Professionals (CAIRP), an association representing nearly 1400 insolvency and restructuring professionals.
The panel Crystal Buhler was on was titled “Enough is Enough: Navigating Bad Faith Stakeholders in Consumer Insolvencies.” The panel featured three other members, well versed in insolvency:
Alex Fernet Brochu, an insolvency lawyer and senior associate at BLG
Colleen Craig, a licensed insolvency trustee at C.E. Craig & Associates
Mark Taggart, Department of Justice (Canada)
The panel was moderated by Registrar Raffi Balmanoukian, of the Supreme Court of Nova Scotia in Bankruptcy and Insolvency.
Crystal Buhler specifically discussed section 4.2 of the Bankruptcy and Insolvency Act, which is the Duty of Good Faith.
CAIRP provided the following summary of the panel:
“This panel will address the ongoing challenge of bad faith conduct by stakeholders in insolvency proceedings and highlight practical approaches that trustees and other stakeholders can use to identify and respond to disruptive parties. Panellists will discuss how tactics such as debtor-led challenges, judicial guidance, and procedural interventions can be employed to help preserve the integrity of the process, even when direct action is limited. Drawing on recent developments and real-world experiences, the session will offer actionable insights for maintaining fairness and efficiency in the face of persistent adversarial behaviour.”
“Attending professional events like these is an essential part of the work we do here at C. Buhler & Associates Ltd.,” said Buhler. “They give us an opportunity not only to network with other insolvency and restructuring professionals, but to position ourselves as leaders in the space. I thank my fellow panellists and moderator Raffi Balmanoukian for what was an invigorating discussion on how to limit the negative influence of bad-faith actors through the use of legislation and jurisprudence.”
- Buhler & Associates Ltd. offers financial advice and services across the Prairie Provinces and Canada’s northern Territories, with offices in Winnipeg, Brandon, Calgary, Saskatoon, Whitehorse, & Yellowknife. The firm is licensed to assist clients in all three prairie provinces and all three northern territories. Its services include administering bankruptcies and consumer proposals, credit counselling, and corporate restructuring.
