What am I missing here? CDP advise that at the time of making...

What am I missing here? CDP advise that at the time of making the loan, the directors did not, and his spouse and children did not own or control directly or indirectly more than 20% of the capital or loan debt of Genorah.
Where does the Act state that each director should be looked at individually? Surely it is the recipient of the loan that should be considered in relation to the wording of the Act?
The company recipient of the loan, Genorah is a legal entity.
The common NKP/Genorah directors clearly control more than 20% of the Genorah legal entity.
I cannot see how CDP can issue such an opinion.