Share Structure of New Generation Cooperatives

Recent changes to the Manitoba Cooperatives Act have altered the ways in which cooperatives may be financed.  These recent changes may have a significant impact on the potential for the creation of NGCs in Manitoba; the expanded range of available financing may provide a stimulus for investment in NGCs.

Cooperatives may offer several types of shares:


Membership shares

Every producer who wants to become a member of the cooperative will be required to purchase one or more membership shares.  The by-laws will stipulate the minimum number of membership shares needed to be held by a producer in order to become a member.  Typically, each member is only required to purchase one membership share.  The cooperative can have only one class of membership shares and these shares must have a par value.  The par value of the membership shares does not change.  These shares are typically sold at a nominal value, which is the par value.  A cooperative does not have to file an offering statement for an issue of membership shares in which the aggregate par value of the membership shares that qualify a person for membership is $500 or less.

Regardless of how many membership shares must be purchased in order to become a member, each member has only one vote on all matters that are to be decided by the cooperative’s members.  In other words, the right to vote is attached to membership in the cooperative rather than to the membership shares.  This is consistent with the democratic cooperative principle of one member, one vote. 

Membership in a cooperative is governed by the cooperative’s by-laws.  Generally, a person cannot become a member unless the following conditions have been met:
 

  • the person has submitted a written application for membership and this application has been approved by the cooperative’s directors or by a person authorized to approve such applications; and
  • the person holds the minimum number of membership shares and has complied with all other requirements for membership that are specified in the by-laws.


In an NGC, there may be a requirement that, in order to qualify for membership, the producer must also purchase a minimum amount of a special class of investment shares.  These shares are outlined below.
 
 

A special class of investment shares

The new Manitoba Cooperatives Act includes a section that deals with a special class of investment shares.  This section is of particular interest to new generation cooperatives, as it indicates that a cooperative’s articles can allow for a special class of investment shares that
 

  • can only be issued to members;
  • does not have a fixed value;
  • entitles or obligates the holder of these shares to conduct a specific amount or percentage of business with the cooperative.  The specified level of business that the member must conduct with the cooperative depends on the number or percentage of special investment shares held by the member; and
  • can share in the surplus of the cooperative if it sells its assets and winds up.


These special investment shares represent the typical NGC marketing/delivery rights shares that tie delivery rights to the level of equity invested by the member.  By purchasing these special investment shares, the producer acquires delivery rights to supply the cooperative.  Inclusion of this special class of investment shares is an improvement from the previous Act, in which the only method to tie producer supply to investment was by a par-value membership share which could never appreciate in value.

Because investment shares (including special investment shares) do not have a par value, they can appreciate or depreciate in value.  Thus, if the business or assets of the cooperative grows in value, then the value of a producer’s special investment shares can appreciate in order to reflect their underlying market value.  Under the previous legislation, when all shares were required to have a stated par value, the potential for appreciation of share value was not possible.
 
 

Non-member investment

Because the cooperative’s articles may set out that investment shares (other than the special class of investment shares) can be issued to non-members, the cooperative can choose to offer investment shares to the public.  For example, communities could show their support for the cooperative by purchasing this type of share.  Because investment shares are issued without par value, they have the opportunity to provide a flexible way of rewarding investors and to appreciate in value if the return on this investment (established at the time of purchase) compares favorably to fluctuations in the general marketplace.  This feature increases the attractiveness of cooperative investment shares as an investment opportunity for non-members.  The investment shares, however, could depreciate in value if the cooperative is unable to pay dividends or repurchase the shares after first meeting its obligations to its employees, suppliers, secured creditors and other creditors.

The cooperative’s articles also set out the voting rights of investment shareholders.  Subject to the articles, no right to vote at member meetings is attached to an investment share.  However, the articles may provide that holders of investment shares may elect a fixed number or percentage of the cooperative’s directors.  Investment shareholders cannot elect more than 20% of the cooperative’s directors.  Neither the cooperative’s articles nor unanimous agreement of the cooperative can change this 20% limit.   Thus the amount of control that investment shareholders can exert on the cooperative is limited.  This allows control of the NGC to remain in the hands of its members.  If investment shareholders are allowed to vote, each investment share entitles the holder to one vote.  In others words, holders of investment shares are given voting rights that are proportional to the number of investment shares they own.  This is in contrast to the voting rights attached to membership shares, in which each member is only entitled to one vote, regardless of the number of membership shares he or she holds.
 
 

New Generation Cooperatives and the offering of securities in excess of $500.00

1) Governing legislation

Sections 88 to 91 of the Manitoba Cooperatives Act outline the regulation of securities issued and sold by a cooperative.  The Cooperatives Act indicates that the Securities Act applies to the sale or issue of securities of the cooperative when the securities may be issued or sold to the public.  The Cooperatives Act also indicates that the Securities Act does not apply to the sale or issue by a cooperative of membership shares or the sale or issue of securities that are restricted to members only.  A difficulty arises with respect to the sale or issue of special investment shares that convey delivery rights to members in that subscribers to an initial offering of special investment shares will not be members at the time the offering is made.

2) Prospectus and registration requirements

In Manitoba, trading in securities is regulated by the Securities Act and its regulations.  The Securities Act fosters investor protection by requiring the registration of people who are allowed to give advice to the public concerning the purchase of securities and by requiring that a prospectus be used when an entity sells securities to the public.  In some cases, however, certain types of trades may be exempted from the registration requirement, the prospectus requirement, or both. 
 

3) Offering statement requirements

In cases where the Securities Act does not apply, the cooperative must send to the Registrar an offering statement and obtain approval from the Registrar before issuing any securities.  The Registrar indicates his approval of the offering statement by filing the offering statement and issuing a receipt to the cooperative.  An offering statement must contain full, true and plain disclosure of all the material facts relating to the securities to be issued, and the purpose for which the money raised will be used.  The Registrar may refuse to file and issue a receipt for the offering statement if, in his discretion, the offering statement contains such things as a false or misleading statement, omits a material fact, or does not comply with the Cooperatives Act

Before a security is sold, a copy of the offering statement must be provided by the cooperative to the person who is purchasing the security.  The Regulations of the Cooperatives Act, however, indicate that an offering statement is not required when the securities issue is comprised of membership shares that have an aggregate par value of $500 or less.
 

The preparation of a prospectus or an offering statement can be a time consuming and lengthy process.  Legal advice should be sought by the NGC when considering the issue of securities.  In addition, consultation with the Manitoba Securities Commission and the Registrar needs to be undertaken in order to determine the cooperative’s reporting requirements.
 

Exemptions from the Requirement for an Offering Statement

Section 89(7) of the Cooperatives Act allows the Registrar to exempt a cooperative from the requirements for an offering statement.  In such instances, the cooperative would be required to prepare a disclosure document.  For more information regarding possible exemptions, contact the Registrar.

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Sources:

Manitoba Cooperatives Act S.M. 1998, c. 52- Cap. C223.

Manitoba Securities Commission. Trading in securities. Online. Retrieved May 4, 2000. www.msc.gov.mb.ca/trading.html .

Manitoba Securities Commission. 1999. Order No. 2526. Blanket Exemption Order: Offerings of securities pursuant to the Cooperatives Act.  Order dated June 10, 1999.