Mortgage brokers, lenders and administrators became reporting entities on 11 October 2024. Here is what that actually requires, in the order you have to build it.
Written by A.I.M.I. Collective Mortgage Group, Brokerage editorial team
Published September 2026 · Last reviewed 5 October 2026
Official sources: FINTRAC
Since 11 October 2024, mortgage brokers, mortgage lenders and mortgage administrators are reporting entities under the Proceeds of Crime (Money Laundering) and Terrorist Financing Act. The obligations are not a lighter version of what banks do — they are the same framework, scaled to the sector.
This page summarises what applies. It is general information, not compliance advice, and FINTRAC's own guidance is the authority.
Since 11 October 2024, mortgage brokers, lenders and administrators are FINTRAC reporting entities. Every brokerage needs a compliance program with six parts: a compliance officer, written policies, a risk assessment, ongoing training, records of that training and a review at least every two years. Client identification, record keeping and reporting follow from that.
FINTRAC groups the mortgage sector requirements into five obligations. Every mortgage brokerage, lender and administrator must: 1. implement a compliance program, 2. know your client (verify identity, record the purpose of the relationship, monitor it, and screen for third parties, beneficial owners and politically exposed persons), 3. report transactions (suspicious transactions, large cash and large virtual currency transactions, and listed person or entity property), 4. keep records of transactions and client identification, and 5. apply ministerial directives. Each is expanded below.
Identity verification is the visible part, but it is not the whole obligation. You also need to record the purpose and intended nature of the business relationship, monitor that relationship on an ongoing basis, determine beneficial ownership where an entity is involved, and make a politically exposed person determination.
Beneficial ownership is where mortgage files most often fall short. Where a corporation or trust is the borrower, you need to know who ultimately owns or controls it, take reasonable measures to confirm that information, and record what you did when you could not.
A dedicated compliance team reviews files centrally and the Deal Desk places the hard ones, so your hours go to clients.
No dollar threshold. Filed as soon as practicable once you have reasonable grounds to suspect. Attempted transactions count.
$10,000 or more in cash, subject to the 24-hour rule that aggregates related transactions.
$10,000 or more in virtual currency, with the same 24-hour aggregation rule.
No threshold. Filed immediately where you know property is owned or controlled by a listed person or entity.
EFT reporting obligations attach to financial entities, money services businesses and casinos. A mortgage entity that separately meets the financial entity definition would be caught in that other capacity, but the mortgage sector obligations alone do not include EFTRs.
FINTRAC can issue administrative monetary penalties, classified as minor, serious or very serious, and can publish the name of a penalised entity. Amendments increasing the maximum amounts have been legislated, so check FINTRAC's current penalty page rather than relying on figures quoted anywhere else, including here.
In practice the more common exposure is not a headline penalty but an examination finding against a brokerage with a compliance program that exists on paper and nowhere else. The effectiveness review is the part most often skipped.
A dedicated compliance team reviews files centrally, tracks licence deadlines across all three provinces and keeps the audit trail in a form a regulator can read. What does not move off your desk is the knowledge: you sign the disclosure and the FINTRAC record, so you have to understand them. This is general information rather than legal advice, and the regulator's own guidance is the authority.
Related: how to check a mortgage broker or agent licence with FSRA, BCFSA and RECA.
FINTRAC publishes sector-specific guidance for mortgage brokers, lenders and administrators at fintrac-canafe.canada.ca. Current as of 1 September 2026.
Look up any mortgage agent or broker licence in Ontario, BC or Alberta. Direct links to each free regulator search and what to check before you sign.
How CASL applies to mortgage broker marketing: express and implied consent windows, unsubscribe rules, the past client myth and the penalties.
Conflict of interest disclosure in BC is a timing obligation, not a form. What brokers must disclose, when, and how the Mortgage Services Act changes it.
Ontario regulates the investor side of a private deal as heavily as the borrower side. Two suitability assessments, material risk disclosure and the forms.
A.I.M.I. Collective brokers work with a compliance team that answers the phone. If you are carrying this on your own, that is worth a conversation.