Just activated a 3100 that I had bought a while back from flea bay. Was new in box and had the previous gen smartcard. Called up Bell, got a CSR, checked the firmware, IRD and smartcard numbers and activated it. Now I have 198 and a new N3 card on the way out to me.
The "current" Bell policy appears to be that if the card in the box is one gen old (previous gen) they will provide a N3 card at no charge. If it is two or more generations old, they will sell you a N3 for $100, but they recommend you buy a new sub-$100 receiver (aka 3100/4100).