undervalue In 2009, the Act was amended to reform the rules relating to setting aside any preferences, or transfers at undervalue, occurring before the initial bankruptcy event: Recovery actions under ss. 95 and 96, as for other recovery actions with respect to collections, can only be initiated by the trustee, even when they may be of benefit only to a secured creditor (unless creditors seek court approval under s. 38 to pursue the matter directly). The Act already empowered the court to inquire into circumstances where a bankrupt corporation had paid cash dividends or redeemed shares where the corporation was insolvent, or where the transactions made it so, during the 12 months prior to its bankruptcy. In that regard, the directors may be held jointly and severally liable for the amounts in question (unless they prove that they acted in good faith, or individual directors can prove that they had protested such payment) shareholders related to any of the directors held liable may also be declared liable for the amount they had received as payment existing powers under the applicable incorporating Act allowing the directors to recover such payments are not affected S. 95(2) provides that, where a preference is given, the fact that it may have been given under pressure is irrelevant. However, the courts have ruled that a payment may withstand challenge by a trustee where it is made in furtherance of a reasonable business imperative., citing Key actors in the procedure Bankruptcy court The provincial Superior Courts have "such jurisdiction at law and in equity" as will enable them to exercise bankruptcy process under the Act. The decisions of the court are enforceable in the courts of other Canadian provinces and all courts and the officers of all courts must act and co-operate in all bankruptcy matters. Appeal from the court's orders lies to the provincial Court of Appeal where: the point at issue involves future rights; the order or decision is likely to affect other cases of a similar nature in the bankruptcy proceedings; the property involved in the appeal exceeds $10,000; the aggregate unpaid claims of creditors exceed $500 (from the grant of or refusal to grant a discharge); and in any other case, leave has been granted by a judge of the Court of Appeal (but such appeal is not as of right). Registrars of the provincial Superior Courts have significant powers in relation