The following checklists are designed as a practical reference for the activities described in FINTRAC’s scenarios, including new mortgage originations, renewals, payment handling, and lender-administrator payment flows. They are not a substitute for the legislation, regulations, or FINTRAC guidance, but they provide a useful framework for reviewing whether required recordkeeping, client identification, beneficial ownership, third-party determination, politically exposed person screening, and ongoing monitoring steps have been addressed.

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1. Checklist: Arranging a New Mortgage Loan

Activity: Mortgage broker arranges a new mortgage loan for a client; lender funds the loan.

Mortgage Broker

• Keep an information record on the borrowing client.
• Keep a mortgage loan record on the client.
• Verify the client’s identity using a prescribed method.
• Keep records of the identity verification.
• Record the purpose and intended nature of the broker’s business relationship with the client.
• Begin ongoing monitoring of the business relationship.
• Keep records relating to ongoing monitoring.
• Take reasonable measures to determine whether a third party is involved.
• Take reasonable measures to determine whether the client is a politically exposed person (PEP) or head of an international organization (HIO).
• If a third party is involved, obtain additional required information and keep records of it.
• If the client is a PEP or HIO, obtain additional required information and keep records of it.
• Confirm whether the required prescribed information is already contained in the mortgage application or other retained documents.

Lender

• Keep an information record on the borrowing client.
• Keep a mortgage loan record on the client.
• Verify the client’s identity using a prescribed method.
• Keep records of the identity verification.
• Record the purpose and intended nature of the lender’s business relationship with the client.
• Begin ongoing monitoring of the business relationship.
• Keep records relating to ongoing monitoring.
• Take reasonable measures to determine whether a third party is involved.
• Take reasonable measures to determine whether the client is a PEP or HIO.
• If a third party is involved, obtain additional required information and keep records of it.
• If the client is a PEP or HIO, obtain additional required information and keep records of it.
• Confirm whether the required prescribed information is already contained in the mortgage application or other retained documents.

Practical Note

• Confirm that the broker’s and lender’s descriptions of the purpose and intended nature of the relationship reflect their different roles.

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2. Checklist: Processing a Mortgage Renewal

Activity: Mortgage broker arranges a renewal for an existing client with the same lender.

Mortgage Broker

• Keep or update the information record on the client.
• Keep or update the mortgage loan record.
• Determine whether identity verification must be repeated.
• If relying on prior verification, confirm that:
  • identity was previously verified using a prescribed method;
  • records were retained in accordance with the applicable rules at the time; and
  • there is no reason to doubt the information previously obtained.
• Update the purpose and intended nature of the business relationship, as needed.
• Continue ongoing monitoring.
• Keep updated records of monitoring activities.
• Take reasonable measures to determine whether a third party is involved.
• Take reasonable measures to determine whether the client is a PEP or HIO.
• If a third party is involved, obtain additional required information and keep records of it.
• If the client is a PEP or HIO, obtain additional required information and keep records of it.
• Confirm whether existing records remain complete and current.

Lender

• Keep or update the information record on the client.
• Keep or update the mortgage loan record.
• Determine whether identity verification must be repeated.
• If relying on prior verification, confirm that:
  • identity was previously verified using a prescribed method;
  • records were retained in accordance with the applicable rules at the time; and
  • there is no reason to doubt the information previously obtained.
• Update the purpose and intended nature of the business relationship, as needed.
• Continue ongoing monitoring.
• Keep updated records of monitoring activities.
• Take reasonable measures to determine whether a third party is involved.
• Take reasonable measures to determine whether the client is a PEP or HIO.
• If a third party is involved, obtain additional required information and keep records of it.
• If the client is a PEP or HIO, obtain additional required information and keep records of it.
• Confirm whether existing records remain complete and current.

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3. Checklist: Mortgage Administrator Receives First Borrower Payment

Activity: Mortgage administrator receives the first payment from a borrower and remits it to the lender.

Mortgage Administrator

• Keep an information record on the lender.
• Keep an information record on the borrower.
• Keep a receipt of funds record for the payment received.
• Keep official corporate records for the lender showing authority to bind the corporation.
• Keep official corporate records for the borrower showing authority to bind the corporation.
• Keep a mortgage loan record for the borrower’s loan.
• Verify the identity of the lender using a prescribed method.
• Verify the identity of the individual acting on behalf of the lender.
• Verify the identity of the borrower using a prescribed method.
• Verify the identity of the individual acting on behalf of the borrower.
• Keep records of all identity verification steps.
• Record the purpose and intended nature of the relationship with the lender.
• Record the purpose and intended nature of the relationship with the borrower.
• Begin ongoing monitoring of both business relationships.
• Keep records relating to ongoing monitoring.
• Obtain beneficial ownership information for the lender.
• Take reasonable measures to confirm the accuracy of the lender’s beneficial ownership information.
• Obtain beneficial ownership information for the borrower.
• Take reasonable measures to confirm the accuracy of the borrower’s beneficial ownership information.
• Take reasonable measures to determine whether a third party is involved.
• If a third party is involved, obtain additional required information and keep records of it.
• Confirm whether required information is already contained in other retained documents and whether those records are complete.

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4. Checklist: Mortgage Administrator Receives Subsequent Borrower Payments

Activity: Mortgage administrator receives later payments from the borrower and remits them to the lender.

Mortgage Administrator

• Keep a receipt of funds record for each payment received.
• Confirm whether the information record on the lender remains current.
• Confirm whether the information record on the borrower remains current.
• Confirm whether official corporate records for both entities remain current.
• Confirm whether the mortgage loan record remains accurate and current.
• Determine whether new copies of records are necessary or whether existing records can be relied upon.
• If any required information has changed, update the relevant records.
• Determine whether identity verification must be repeated.
• If relying on prior verification, confirm that:
  • identity was previously verified using a prescribed method;
  • records were properly retained; and
  • there is no reason to doubt the information previously obtained.
• Continue ongoing monitoring of relationships with both the lender and the borrower.
• Confirm that the purpose and intended nature of each relationship remains current.
• Confirm that beneficial ownership information remains current.
• Take reasonable measures to determine whether a third party is involved.
• If a third party is involved, obtain additional required information and keep records of it.

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5. Checklist: Lender Advances Loan to Corporate Borrower

Activity: Lender initially provides the mortgage loan to a corporate borrower.

Lender

• Keep an information record on the borrower.
• Keep a mortgage loan record on the borrower.
• Keep official corporate records showing the borrower’s authority to be bound.
• Verify the identity of the borrower using a prescribed method.
• Verify the identity of the individual acting on behalf of the borrower.
• Keep records of identity verification.
• Record the purpose and intended nature of the relationship with the borrower.
• Begin ongoing monitoring of the business relationship.
• Keep records relating to ongoing monitoring.
• Obtain beneficial ownership information for the borrower.
• Take reasonable measures to confirm the accuracy of that beneficial ownership information.
• Take reasonable measures to determine whether a third party is involved.
• If a third party is involved, obtain additional required information and keep records of it.

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6. Checklist: Lender Receives Payments Through Mortgage Administrator

Activity: Lender receives payments from a mortgage administrator that were originally submitted by the borrower.

Lender

• Keep a receipt of funds record on the mortgage administrator.
• Record the borrower’s:
  • name;
  • address; and
  • nature of business.
• Keep official corporate records showing the mortgage administrator’s authority to be bound.
• Verify the identity of the mortgage administrator using a prescribed method.
• Verify the identity of the individual acting on behalf of the mortgage administrator.
• Keep records of identity verification.
• Record the purpose and intended nature of the relationship with the mortgage administrator.
• Conduct ongoing monitoring of that relationship.
• Keep records relating to ongoing monitoring.
• Obtain beneficial ownership information for the mortgage administrator.
• Take reasonable measures to confirm the accuracy of that beneficial ownership information.
• Take reasonable measures to determine whether a third party is involved.
• If a third party is involved, obtain additional required information and keep records of it.
• Confirm whether existing records can be relied on and whether they remain current.

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7. General Recordkeeping and Monitoring Checklist

Activity: Ongoing compliance management across mortgage activities.

All Reporting Entities

• Ensure internal policies and procedures reflect applicable FINTRAC obligations.
• Confirm that responsibilities are clearly assigned among broker, lender, and administrator functions.
• Confirm that required records are complete, retained, and current.
• Avoid unnecessary duplication, but ensure existing documents contain all prescribed information.
• Review whether any changes in client information require record updates.
• Review whether any changes in ownership or control require updates to beneficial ownership records.
• Review whether ongoing monitoring is being documented consistently.
• Review whether third-party determinations are being made and documented where required.
• Review whether PEP/HIO screening is being performed where required.
• Confirm that identity verification records are retained and can support reliance on prior verification where permitted.