Saugeen Mobility and Regional Transit (SMART) was incorporated in 1980 by private individuals to provide public transit service to passengers with disabilities. Control of the corporation was eventually taken over by local municipalities. The Ombudsman found that SMART was not incorporated pursuant to the provisions in the Municipal Act, 2001, which permit municipalities to create municipal services corporations, because the Municipal Act, 2001 did not exist at the time SMART was incorporated.