Disclosure is not a form you file. It is a timing obligation, and the clock runs before the borrower signs anything.
British Columbia requires mortgage brokers to disclose actual, potential and perceived conflicts of interest to both sides of a transaction. The obligation is owed to borrowers and to lenders, and it is enforced on timing as much as on content.
The forms and their numbering change when the Mortgage Services Act takes effect on 13 October 2026, so anything written before then — including older templates sitting in a brokerage's file system — needs checking against the current framework.
Interests that could reasonably be seen to affect your advice, delivered before the borrower enters into a mortgage agreement.
Interests disclosed before offers to lend or borrow are delivered, or before mortgage interests are sold or purchased.
Where you act for parties whose interests conflict, a separate written agreement is required.
Borrower disclosure has to reach the borrower no later than two business days before they enter into a mortgage agreement. Handing it over at signing does not satisfy the requirement. Build the timing into the file, not the closing.
Dated, signed, and in the regulator's words true, plain and not misleading. That last phrase does real work: a technically accurate disclosure written to be skimmed past is not compliant. If a reasonable borrower would be surprised later, the disclosure did not do its job.
The duties sit alongside restrictions on acting for both sides of a transaction. Those restrictions are specific, and a general belief that everyone consented is not a defence.
Conflicts are most acute where the broker has a relationship with the lender, an interest in the lending entity, or a fee arrangement that varies by where the deal is placed. None of those is prohibited by itself. All of them have to be visible to the borrower in writing, early enough to matter.
BCFSA publishes a guideline on disclosing and managing conflicts of interest, along with the current forms, at bcfsa.ca. Current as of 1 September 2026.
Getting disclosure timing right is easier with someone to check the file before it goes out.