Mortgage Services Act (MSA): Licensing Requirements & Exemptions for MICs

Under the MSA (which will fully replace the old Mortgage Brokers Act in October 2026), anyone who provides “mortgage services” (such as soliciting, negotiating, or administering mortgages) on behalf of others must be licensed unless a specific exemption applies. MICs – which lend investor funds on the security of real estate – clearly fall under mortgage services (specifically “mortgage lending” and potentially “dealing in mortgages” by soliciting borrowers) and thus require licensing. In fact, under the prior law MICs were required to register as mortgage brokers in BC, which regulated their lending activities, and this continues under the MSA’s updated framework.

No Blanket Licensing Exemption for MICs: The MSA’s regulations enumerate several categories of people who are exempt from needing a mortgage services licence, but MICs are not among them. For example, federally regulated financial institutions (like banks or federal credit unions) are exempt, as are professionals like notaries and accountants when carrying out mortgage-related tasks incidental to their practice. However, mortgage investment corporations do not have a special exemption in these rules – they are generally treated like any other private mortgage lender. The only way an MIC’s staff might avoid individual licensing is via the general rule that a director, officer, or employee of an already exempt entity doesn’t need a licence themselves – but since the MIC itself isn’t exempt, this provision offers no relief in that context. In practice, an MIC (or its management company) that originates or administers mortgages must be licensed as a mortgage broker/brokerage, and its personnel must hold the appropriate individual licences.

Planned “Mortgage Lender” License Category: Notably, the MSA introduces a new licence category for Mortgage Lenders, recognizing companies that extend mortgage loans using their own capital. This could directly apply to MICs. However, this lender licence category is not yet operational – implementation awaits further rules and confirmation by BCFSA. The MSA’s transitional provisions include an exemption for non-business individual lenders solely engaged in “mortgage lending” – this may be removed at some point in the future. If the MIC or its principals engage in mortgage brokering and lending activities – e.g. negotiating loans or dealing in mortgages on behalf of others – a brokerage licence is required  now under the Mortgage Brokers Act.

Overlap with Securities Act – Syndicated Mortgages: One area of overlap between the mortgage and securities regimes is syndicated mortgages (a single mortgage loan split among multiple investors). These have characteristics of both a mortgage deal and a securities offering. The MSA regulation specifically addresses this overlap by granting an exemption in one direction: a firm registered as an investment dealer under the Securities Act is exempt from MSA licensing when facilitating non-“qualified” syndicated mortgage investments. In essence, large or complex syndicated mortgages (those not meeting the “qualified” criteria such as simple residential loans with low loan-to-value) can be handled by IIROC-regulated securities dealers without that dealer also obtaining a mortgage broker licence. This exemption aligns with recent CSA rules that pull these riskier mortgage investments under securities regulators’ purview. By contrast, “qualified syndicated mortgages” – simpler, small-scale residential syndications – remain under the MSA’s domain and typically must be sold through licensed mortgage brokers. For MICs, which pool investors’ funds at the corporate level, syndicated mortgage distribution is usually not their model (they issue shares instead), but this carve-out shows how the MSA and Securities Act coordinate on overlapping products.

BC Securities Act: Capital-Raising Rules & Exemptions Affecting MICs

From the securities law perspective, a MIC is an issuer of securities (e.g. shares or units offered to investors). Any offering of MIC shares must comply with the BC Securities Act, meaning the MIC must either file a prospectus or (far more commonly) rely on a prospectus exemption to sell securities to investors. Virtually all MICs use prospectus exemptions – such as the Accredited Investor exemption or the Offering Memorandum exemption under National Instrument 45-106 – to raise capital privately without a full public prospectus. These exemptions allow MICs to raise money from qualified investors with less regulatory burden than a public offering, but they still carry conditions (e.g. providing an offering memorandum with prescribed disclosure, in the case of the OM exemption).

Dealer Registration Requirement – Past Exemption and Its Removal: In addition to prospectus rules, securities law normally requires that anyone in the business of trading securities be registered (for example, as an exempt market dealer or investment dealer). Historically, British Columbia had a unique registration exemption for mortgage investment entities (MIEs) like MICs. Introduced in 2010, this “MIE dealer registration exemption” (BC Instrument 32-517) allowed MICs or their managers to sell MIC securities to investors without registering as dealers, so long as they met certain conditions (such as filing information reports). This meant that a licensed mortgage broker could raise investor money for an MIC under the Mortgage Brokers Act oversight, and did not also have to be a securities dealer – a notable regulatory carve-out in BC that was not available in other provinces.

However, this exemption was permanently revoked as of February 2019. The BC Securities Commission (BCSC) decided to “lift the registration exemption” for MICs/MIEs in order to harmonize with Canada-wide standards and bolster investor protection. The change was announced in 2018 and took effect in 2019, ending an almost decade-long era in which unregistered finders or mortgage brokers could sell MIC investments directly. Now, any person or firm that trades in securities of an MIC (i.e. solicits investors, advises on the purchase of MIC shares, etc.) generally must be a registered securities dealer or exempt market dealer. In practice, many MIC firms responded by creating or partnering with a separately incorporated dealer entity to handle capital raising. During the transition, the BCSC allowed MIC firms that applied for registration by the deadline to continue operating while their applications were processed.

The removal of the dealer-registration exemption is a critical shift: BC went from exempting MICs entirely from securities dealer requirements to insisting on full dealer oversight. BCSC staff noted that this change ensures investors receive advice from licensed dealers and can check that those selling MIC investments are registered and reputable. Indeed, after the exemption’s repeal, a mortgage broker licence alone is insufficient to raise funds for an MIC – a securities registration is needed as well, or the MIC must engage a registered dealer for distribution. This was a significant new compliance burden for MICs, and industry voices (including the then CEO of BC’s Mortgage Brokers Association, Samantha Gale), raised concerns that the cost of maintaining dealer registration (compliance systems, audits, capital requirements, etc.) could be around $200,000 annually, straining smaller MICs.

Other Securities Act Exemptions: Aside from prospectus exemptions and the now-defunct dealer registration carve-out, MICs have also benefited from certain other exemptions in the securities realm:

• Investment Fund Status: MICs are corporations that lend mortgage money; they typically are not considered conventional “investment funds” (mutual funds) because investors usually cannot demand redemption on short notice, and MICs invest in relatively illiquid mortgage loans. Regulators historically provided relief so that MICs would not be treated as investment funds requiring an Investment Fund Manager registration. For example, the CSA issued blanket orders (like CSA 31-318/BCI 32-521) exempting MICs/MIEs from having to register as investment fund managers or advisers, acknowledging that their activities were already overseen under mortgage broker legislation. These exemptions (from the investment fund manager/adviser rules) have since lapsed or been replaced by guidance, but in general, MICs today are not forced to register as investment fund managers as long as their business is confined to mortgage lending and not running a securities portfolio – they focus on lending, so they aren’t regulated like mutual fund companies.
• Syndicated Mortgage Exemptions: Prior to 2021, certain syndicated mortgages in BC could be sold under a simple exemption (they were largely outside securities law if sold by mortgage brokers). That changed with the CSA’s syndicated mortgage reforms. Now, non-qualified syndicated mortgages must comply with securities rules (including investor disclosure akin to an offering memorandum and involvement of registered dealers). BC adopted these changes in March 2021, removing the old prospectus and registration exemptions for most syndicated mortgages. The remaining “qualified syndicated mortgage” category – essentially low-risk, residential mortgages – continues to be an easier-exempt case. For MICs, which raise pooled capital rather than matching individual investors to individual loans, these specific syndicated mortgage exemptions are less directly relevant. It’s worth noting, however, that the regulatory philosophy has shifted: both mortgage regulators and securities regulators are collaborating to close gaps in oversight for mortgage investments.

Overlapping and Diverging Exemptions – Practical Implications for MICs

Overlapping Regulatory Scope: MICs straddle two regulatory spheres. On the mortgage sector side, the focus is on protecting borrowers and the integrity of mortgage transactions (hence licensing requirements for those who broker or lend). On the securities side, the focus is on protecting investors who purchase MIC shares or debt. There is very little in the way of a full exemption that excuses MICs from one regime simply because they comply with the other. Instead, each Act provides targeted exemptions to avoid duplicative regulation in specific scenarios:

• The MSA exempts securities-licensed investment dealers from needing a mortgage broker licence when they deal in certain mortgage investments (syndicated mortgages). This prevents an IIROC-regulated brokerage from having to double-register when its activity (selling mortgage-backed securities) already falls under securities laws.
• Conversely, the Securities Act (formerly) exempted licensed mortgage brokers from needing to register as dealers when selling MIC investments – but this overlap exemption was eliminated in 2019, as discussed. Now, a mortgage broker licence does not confer any exemption from securities registration for MIC distribution.

Divergent Exemptions: Each regime has exemptions that matter to MICs, but they apply to different aspects:

• Under the MSA, a variety of parties are exempt for policy reasons – e.g. banks and treasury branches (federally regulated lenders) don’t need provincial mortgage licences to lend, and professionals like notaries can arrange the occasional mortgage incidental to their work without a licence. These carve-outs don’t really help MICs (which are private lenders outside those categories). MICs must either be licensed or fit under a temporary transition exemption for mortgage lending. In short, there’s no broad MSA waiver for being an MIC.
• Under securities law, MICs rely on general exempt market provisions (the same used by other private companies) to avoid a prospectus – there’s no MIC-specific prospectus exemption beyond what any issuer might use. The only unique relief MICs had was the dealer registration exemption, which, as noted, BC abandoned. Thus, today MICs are treated like any other issuer: to sell securities, they must either register or use a registered intermediary, unless another narrow exemption (like a friends-and-family dealer exemption for very limited selling) applies.

Practical Impact – Operating in Both Sectors: For an MIC operating in BC, the combined effect of these rules is that it generally needs to comply with both regulatory frameworks:

• The MIC’s lending operations (making and administering mortgage loans) fall under the MSA. The MIC will either need to be a licensed mortgage brokerage or a lender, or have its lending handled by a licensed entity. Many MICs have a brokerage licence for their lending arm or have principals who are licensed mortgage brokers, ensuring compliance with disclosure, reporting, and conduct standards in the mortgage process.
• The MIC’s capital-raising activities (selling shares or units to investors) fall under the Securities Act. The MIC cannot simply rely on its mortgage broker credentials to raise money; it typically must prepare offering documents and sell through a registered dealer (often an Exempt Market Dealer) or register a related company as such. Investors must be sourced and advised by registered representatives now, adding to compliance costs but providing greater investor safeguards

This dual regulatory compliance increases operational complexity. In effect, a BC MIC might have to form two regulated entities – e.g. a mortgage brokerage for lending and a sister securities dealer for fundraising – or otherwise align itself with firms that have the necessary licences. As a result, MICs are more tightly supervised than in the past, which supporters argue enhances trust and consumer protection on both ends (borrowers get licensed professionals; investors get registered advisors)

On the other hand, the lack of any sweeping exemption for MICs means higher costs and regulatory overhead. Smaller MICs have raised the concern that needing an in-house dealer or paying third-party dealers and compliance experts diverts funds that could have been used for lending or offering better returns. This is a trade-off regulators have chosen in the interest of market integrity.

In summary, mortgage investment corporations in BC must navigate both the MSA and the Securities Act, and neither law provides a blanket exemption that would remove MICs from its scope. The MSA demands that those engaging in mortgage business (soliciting loans, lending others’ money, etc.) be licensed, and it exempts only certain institutions and professionals – MICs receive no special pass on the lending side. The Securities Act, likewise, treats MIC securities like any other high-risk private investment: they can be sold without a prospectus under standard exemptions but must involve registered dealers now that BC has closed its historical loopholes. The overlap is managed through targeted exemptions (to avoid duplicative licensing in the case of syndicated mortgages, for example), but for the most part MICs are subject to both sets of requirements.

Practical takeaway for MIC operators: ensure your mortgage lending activities are conducted under an MSA licence (or by licensed staff), and structure your investor-facing activities to comply with securities laws – typically by engaging or becoming an exempt market dealer. This dual compliance structure is the new normal, intended to safeguard both borrowers and investors in BC’s mortgage investment sector

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(1) federal foreign investment legislation provides an initial hurdle towards foreign in-bound investment and the application of such legislation may vary in an ever-changing geopolitical climate, and

(2) foreign investors must navigate provincial and territorial regulations to determine whether an investment in agricultural land is even permissible.

Blake, Cassels and Graydon discusses how Canada’s regulatory frameworks may evolve to address food security concerns given the momentum seen in the United States.

Read the analyses here https://www.jdsupra.com/legalnews/securing-canada-s-harvest-regulations-1720025/

The post Regulation on Foreign Ownership of Agricultural Land first appeared on Canadian Association of Private Lenders.

For further information read here  https://www.jdsupra.com/legalnews/canada-extends-ban-on-foreign-home-7301260/

The post Extension of the Foreign Buyer’s Ban first appeared on Canadian Association of Private Lenders.

Mortgage Suitability Consultation

FSRA is currently conducting a consultation on new product suitability guidance, and has presented their expectations around suitability in a webinar (which contains a detailed Q and A), which can be viewed here https://www.fsrao.ca/industry/mortgage-brokering/webinars/fsras-webinar-mortgage-product-suitability-assessment-january-24-2024

FSRA’s goal is to ensure that licensees support suitability assessments with clear documentation – for those engaged in private lending in Ontario, we recommend that you review this example from FSRA on how to document suitability for a borrower obtaining a private mortgage – https://www.fsrao.ca/media/24161/download

FSRA expects licensees to be able to answer and document for private mortgage transactions the following questions:

1. Is it clear that the borrower(s) would not have qualified for a lower cost option (e.g., from a lender with lower rates
   and/or fees)?
2. Is the mortgage affordable and sustainable for the borrower for the term of the mortgage?
3. Has the broker/agent discussed a realistic exit strategy with the borrower and the risks involved in not executing
   that strategy?

In addition, you may wish to review proposed new Investor Disclosure Forms – see section F which addresses suitability advice to investors https://www.fsrao.ca/engagement-and-consultations/consultation-proposed-mortgage-product-suitability-assessment-guidance

The consultation is open until February 28, 2024 and can be found here https://www.fsrao.ca/engagement-and-consultations/consultation-proposed-mortgage-product-suitability-assessment-guidance

Vulnerable Consumer Proposed Approach

FSRA is conducting a sector wide consultation on protecting vulnerable consumers. The purpose of the consultation is to find ways to promote the inclusive and fair treatment of vulnerable consumers and to prevent their targeted financial mistreatment. In addition, FSRA is seeking feedback on improving consumer education, engagement, and awareness building efforts. The consultation closes on March 8, 2024 and can be found here Consultation on FSRA’s Proposed Approach to Strengthening Protection of Vulnerable Consumers | Financial Services Regulatory Authority of Ontario (fsrao.ca)

Deadline approaching to Complete Level 2 Private Mortgage Course

Brokers, principal brokers and level 2 agents wishing to continue dealing in private mortgages need to complete the Private Mortgages Course by March 31, 2024.

APR Compliance Blitz

Ontario mortgage brokerages should be prepared for FSRA compliance audits in 2024 and 2025 which are focussed on cost of credit disclosure and accurate APR calculations. FSRA’s recent examinations have uncovered cases where the APR has been calculated and disclosed incorrectly. Miscalculations usually arise because of the following:

• Excluding required fees (administrative, lender and/or brokerage fees, legal service and disbursement fees, appraisal fees).
• Excluding required fees from the disclosure document – resulting in both non-disclosure to the borrower and incorrect APR calculations.
• Adding incorrect fee amounts due to contradicting statements and disclosures.

For example, lender fees listed in the commitment letter do not match those shown on the disclosure document (or vice versa), and the incorrect fee was used to calculate the APR.

Please provide us with your questions and comments on these matters by emailing us at s.gale@privatelenderassociation.ca

The post Regulatory Updates for the Private Lending Industry — Ontario and the Financial Services Regulatory Authority first appeared on Canadian Association of Private Lenders.

On December 23, 2023, the federal government published proposed Criminal Interest Regulations which specify certain exemptions to the new criminal interest rate ceiling contained in the Criminal Code.

If you recall from previous discussions, the government introduced sweeping changes to the criminal interest provisions, which currently prohibits lenders from charging and/or receiving payments from loans with effective interest rates of 60% (which translates to an approximate annualized percentage rate (APR) of 48%) or more. The new prohibited rate will now be 35% APR once brought into force. Note that there is a current consultation to reduce this rate even further.

The rationale for the proposed exemptions to the criminal interest rate are based on the view that the proposed exempted loans will not trap consumers in a debt cycle. They include:

1. Commercial loans

Loans which are for commercial or business purposes to borrowers who are not natural persons are exempt from the 35% criminal interest rate prohibition, as follows:

a) commercial loans over $10,000 and up to $500,000 are exempt from the criminal rate of interest, so long as the APR does not exceed 48%; and
b)commercial loans above $500,000 are not subject to any criminal rate cap.

The regulations, therefore:

-loosen the criminal interest rate prohibitions for commercial loans by removing previous caps for loans over $500,000;
-make no changes to commercial loans over $10,000 up to $500,000; and
-create greater restrictions for commercial loans under $10,000 by creating a ceiling of 35% APR.

2. Pawn loans

Pawn loans under $1,000 are exempt from the 35% APR ceiling provided that the APR does not exceed 48% and certain other conditions are met.

3. Payday loans

There will be new federal limits on the total cost of borrowing under payday loan agreements of 14%. This limit of $14 for every $100 borrowed will apply in all provinces with a payday loan regime and is intended to create uniformity in borrowing costs from province to province.

Under the proposed regulations, all other loans, including residential mortgages, installment loans and personal loans will be subject to the new criminal rate ceiling.

If you have comments or questions on the proposed exemptions or the possible further lowering of the criminal interest rate ceiling, please let us know by emailing us at s.gale@privatelenderassociation.ca

Please consider reaching out to your Member of Parliament to share any concerns regarding the proposed legislation.

The post Regulatory Update: Criminal Interest Rate – Proposed 35% APR first appeared on Canadian Association of Private Lenders.

New Federal Consultation on Criminal Interest Rate asks the following questions:

• How much further beyond 35 percent APR should the criminal rate of interest be lowered?
• How can the government improve enforcement of the criminal rate of interest to protect Canadian consumers?
• Should further revisions to the Criminal Code’s provincial or territorial-requested payday lending exemption be considered?
• What are the features of credit products that can help Canadians improve their financial positions?
• What protections from unreasonable fees for credit products, including payday lenders, could help Canadian consumers?
• What marketing techniques target vulnerable Canadians into taking on high-cost debt, and what measures would protect Canadians from deceptive advertising?
• How could all types of credit lenders better provide Canadians with information on the costs of credit products, including associated fees and interest?
• What barriers do Canadian consumers face in accessing low-cost, small-value credit?
• What barriers do financial institutions, banks, and credit unions in particular, face in increasing their offerings for low-cost, small-value credit to a broader consumer base?
• What could various levels of government, including provincial governments, do to improve, promote, and support access to low-cost, small-value credit?
• What could financial institutions, banks, and credit unions in particular, do to improve, promote, and support access to low-cost, small-value credit?
• Are there practices to improve the availability of low-cost, small-value credit within Canada or abroad that could be learned from?

The consultation document can be found here https://www.canada.ca/en/department-finance/programs/consultations/2023/consultation-on-cracking-down-on-predatory-lending-faster-by-further-lowering-the-criminal-rate-of-interest-and-increasing-access-to-low-cost-credit.html

In October of 2022, CAPL urged the government to refrain from using the Criminal Code to regulate the lending industries, which are already regulated under various provincial licensing regimes – read CAPL’s letter here – http://privatelenderassociation.ca/wp-content/uploads/2023/04/criminal-rate-letter-3.pdf

Following the government’s decision to lower the criminal rate of interest, CAPL recommended to the government that it consider adopting various exemptions to the criminal rate of interest prohibition  – read the CAPL letter on this subject here http://privatelenderassociation.ca/wp-content/uploads/2023/06/Crim-int-exemptions-May-31-2023.pdf

Please consider either responding to the consultation or sharing your comments with CAPL at s.gale@privatelenderassociation.ca

The post New Federal Consultation on Criminal Interest Rate first appeared on Canadian Association of Private Lenders.

The Mortgage Brokers’ Regulatory Council of Canada (MBRCC) has published its strategic plan for the next three years (2023-2026). Some of the strategic priorities of the MBRCC focus on licensing issues when operating across multiple provincial jurisdictions. Contrary to some popular views, co-brokering or submission desk arrangements will not resolve the problem of a broker or agent acting in another province where they are not licensed. See the MBRCC strategic plan here https://www.mbrcc.ca/Documents/View/8385

The MBRCC is currently reviewing standards for brokers making product suitability assessments and they have created guidelines for comment by the industry – see here https://www.mbrcc.ca/Documents/View/8366  Mortgage brokers will need to make assessments of their clients needs and document recommendations, the rationale for those recommendations and alternatives. We note that private mortgages (unlike institutional mortgages) are unique transactions, making it impractical for brokers to present alternative mortgage options to lenders and borrowers. CAPL has had discussions directly with FSRA on this subject.

If you have questions or comments on any of the MBRCC initiatives or suitability consultation, please contact CAPL at s.gale@privatelenderassociation.ca

The post Regulatory Update: AML for the Mortgage Industry and more first appeared on Canadian Association of Private Lenders.

The consultation asks some specific questions impacting the real estate and finance sector. In particular, it asks whether the following additional sectors should be included in the FINTRAC reporting regime:

• for-sale-by-owner companies
• real estate auction companies
•  building supply and renovation companies
• title insurers
• mortgage insurers
• white label automated teller machine owners/operators, and
• factoring companies, which supply short-term loans or upfront payment for the accounts receivable of another business to address their cash-flow needs

The consultation also asks whether real estate representatives under the PCMLTFA should be obligated to identify unrepresented parties and conduct third-party determinations in real estate transactions involving unrepresented parties.

Of concern to all reporting entities, is a question as to whether administrative penalties should be levied against directors, officers, and agents within an entity in certain cases of violations of the PCMLTFA?

Please let us know at CAPL if you have any questions about the consultation or wish to share a perspective or provide comments – email us at s.gale@privatelenderassociation.ca

Anti-money laundering requirements for mortgage lenders

CAPL has met with consultants working for FINTRAC to assist with the roll out of AML requirements for the mortgage services sector, which includes mortgage lenders. In order to understand private mortgage lenders better, the consultants have asked that this survey be completed

[su_button url=”https://docs.google.com/forms/d/e/1FAIpQLSeZlnY3MhHUsYc0Yi82J2YyyfHKAxhy-kDxXY812aN7W-9eDQ/viewform” background=”#404040″ color=”#fff” size=”9″ radius=”0″ icon=”icon: edit” icon_color=”#fff” text_shadow=”0px 0px 0px “]TAKE THE SURVEY[/su_button]

Please know that we have explained that private mortgage lenders are not regulated by OSFI and do not underwrite loans as OSFI regulated entities do. In addition, we have also explained that mortgage borrowers are not the clients of mortgage lenders, and that some mortgage lenders/investors are clients who should not be required to comply with AML rules.

Here is CAPL’s letter on this subject 

The post Regulatory Update: AML for the Mortgage Industry and more first appeared on Canadian Association of Private Lenders.

CAPL has been advised that the Federal Government has tabled Notice of a Ways and Means Motion for Budget 2023 in the House of Commons.

Division 34 of Part 4 introduces changes to the Criminal Code to lower the criminal rate of interest to 35% annual percentage rate, as announced in Budget 2023. As part of the Amendments to the Criminal Code, the government has proposed a regulation-making authority to allow for certain types of loans to be exempt from the criminal rate of interest in future regulations.
We are therefore seeking feedback from members concerning what exemptions should be considered for inclusion in the regulation. For instance, should exemptions exist for short term loans, such as bridge financing and real estate deposit loans? Should borrowers which are commercial entities or non-consumer loan transactions be exempted?
Please give us your input by contacting us at s.gale@privatelenderassociation.ca

The post The Federal Government is planning to lower the criminal interest rate to 35% first appeared on Canadian Association of Private Lenders.

• develop and implement a comprehensive compliance program;
• perform risk assessments;
• develop staff training programs; and
• maintain records.
• Mortgage lenders, in particular, will need to explore and document a borrower’s financial capacity.

The proposed regulations for comment can be found at this link . The comment period closes on March 20, 2023.

The challenge that we see for many mortgage lenders is that the broad capture of “mortgage lenders” as reporting entities, appears to include all mortgage lenders, regardless of their sophistication, licensing status, structure or even their level of activity in performing lending services. Passive investors, who simply provide funds to borrowers secured by mortgages yet do not engage in any underwriting and casual mortgage lenders are caught in the definition – these persons act more as clients than active industry participants. Unlike other captured reporting sectors, the act of mortgage lending can be a common activity engaged in by non-professionals, such as friends and family members. The definition does NOT exclude those non-professional participant lenders who will not have the knowledge, resources or capacity to comply with complex AML requirements. We urge you to provide comments to the government or CAPL on this significant new requirement.

A comprehensive review of Alberta mortgage broker and other sector rules – the Real Estate Council of Alberta is currently inviting feedback from industry members on a broad, multi-sector consultation, and inviting comments on:

• rules applicable to mortgage brokerages;
• practice standards;
• forms, including disclosure forms,
• E and O insurance requirements;
• licensing structures;
• document storage;
• referral payments and commissions; and
• rule harmonization with other provinces.

The consultation document can be found here https://www.reca.ca/about-reca/legislation-standards/industry-and-government-consultations/

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