Regulatory Update: AML for the Mortgage Industry and more

MBRCC initiatives impacting co-brokering and mortgage product suitability recommendations

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

The MBRCC is currently reviewing standards for brokers making product suitability assessments and they have created guidelines for comment by the industry – see here  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