Legislative review of the Mortgage Brokerages, Lenders and Administrators Act, 2006

Strengthening the mortgage industry with modern practices in Ontario

Report to the Minister of Finance on the Legislative Review of the Mortgage Brokerages, Lenders and Administrators Act, 2006

February 4th, 2026

The Honourable Peter Bethlenfalvy
7 Queen's Park Crescent, 7th floor
Toronto, Ontario
M7A 1Y7

Dear Minister Bethlenfalvy:

I am pleased to provide to you my report on the third legislative review of the Mortgage Brokerages, Lenders and Administrators Act, 2006 (MBLAA or the Act), in accordance with the requirements set out in section 57 of the Act. In fulfilling this mandate, the views of the public and the mortgage broker sector on the MBLAA and its regulations were sought through a public consultation process via a posting on Ontario’s Regulatory Registry. Stakeholders were also engaged via roundtable sessions and individual meetings.

Since the last review was completed in 2019, the Financial Services Regulatory Authority of Ontario (FSRA) and the Ministry of Finance have substantially implemented the recommendations, which focused on reducing regulatory burden and ensuring that the MBLAA framework remains modern and flexible (see Appendix 4). These changes provided a foundation for the current review, which identifies opportunities to further enhance consumer protection, raise industry standards, and modernize the MBLAA to reduce regulatory burden while also promoting greater alignment across provinces, so that the mortgage brokering sector can better serve the needs of its clients.

The recommendations included in this report are informed by detailed written feedback received from a variety of financial services sector stakeholders, and many direct conversations with interested parties. The recommendations also take into account recent legislative changes, including the Protect Ontario Through Free Trade Within Canada Act, 2025, which came into force on July 1, 2025, and enacted the Ontario Free Trade and Mobility Act, 2025 and made important amendments to the Ontario Labour Mobility Act, 2009.

I am grateful for the detailed input received from stakeholders, as well as the support provided by the Ministry and FSRA. It has been an honour to offer recommendations which support this important sector and, more broadly, the people of Ontario.

Sincerely,

Michelle Cooper,
Parliamentary Assistant to the Minister of Finance
Lead – MBLAA Legislative Review

Introduction

The Mortgage Brokerages, Lenders and Administrators Act, 2006 (MBLAA or the Act) requires that, every five years, the Minister of Finance appoint one or more persons to review the operation of the Act and the regulations and to make recommendations to the Minister. The Act requires that the appointee solicit the views of the public and that their recommendations be made available to the public.

In 2023 and 2024, the Honourable Peter Bethlenfalvy, Minister of Finance, appointed two former Parliamentary Assistants to lead the MBLAA legislative review: the Honourable Stephen Crawford and the Honourable Zee Hamid. Each was subsequently appointed to another position on the Executive Council. In June 2025, Michelle Cooper, Parliamentary Assistant to the Minister of Finance, was appointed to complete the current review.

The government initiated the MBLAA Review by launching a consultation paper on Ontario’s Regulatory Registry in 2024. The posting invited written submissions from the mortgage broker sector and the public under three key themes:

• Reinforcing professionalism in the sector
• Reducing regulatory burden
• Strengthening consumer protection

Four stakeholder roundtables were held in October and November 2024. All stakeholders that provided written submissions responding to the consultation paper were invited to attend. In total, the Ministry of Finance received written submissions from 16 stakeholders representing a variety of financial services sectors (See Appendix 3).

This report provides an overview of the issues raised during the consultation and summarizes recommendations for implementation, under the three themes.

Implementing these recommendations would help improve professionalism in the industry, streamline the regulatory framework for mortgage professionals and enhance consumer protection in the mortgage brokering and lending sector, ensuring that it continues to be one that Ontario families and investors can trust.

The mortgage marketplace

The Canadian mortgage market currently represents approximately $2.3 trillion of residential mortgage credit provided by banks, credit unions and other financial institutions and lenders^{footnote 1[1]}. The mortgage brokering sector plays a key role in facilitating home ownership for many Ontarians and supports investors in the alternative mortgage investment space. According to Mortgage Professionals Canada, about 33% of Canadians use a mortgage professional to arrange their mortgage, and 44% of those clients are first-time buyers^{footnote 2[2]}.

As of June 30, 2025, Ontario’s mortgage sector had 1,162 licensed mortgage brokerages and 266 licensed mortgage administrators. In addition, FSRA regulated 3,059 licensed mortgage brokers, 5,235 level 2 mortgage agents, and 9,923 level 1 mortgage agents^{footnote 3[3]}. Mortgage lenders in Canada experienced a decline in originations in 2025 compared to 2024, with the total number of loans originated declining from 2.18 million to 1.33 million with the value of loans originated falling from $656.74 billion to $413.25 billion^{footnote 4[4]}.

Ontario’s mortgage sector is operating in a shifting environment shaped by economic pressure, evolving regulation, and technological advancement.

Housing affordability and market pressures

The rising cost of living remains a major challenge for many Ontarians. While the average home price has declined slightly in some municipalities, housing affordability remains a concern, especially for first-time home buyers, young families, and newcomers. High interest rates have also placed pressures on existing homeowners, especially those with variable-rate mortgages or approaching renewal. According to the 2024 Canada Mortgage Housing Corporation (CMHC) Mortgage Consumer Survey Results, 65% of mortgage holders have been impacted by higher interest rates^{footnote 5[5]}.

These conditions have contributed to rising household debt and have affected mortgage products’ suitability for some consumers, making the role of mortgage professionals critical, as borrowers and investors increasingly rely on expert guidance to navigate complex mortgage decisions.

Growth of alternative and private lending market

Once a niche segment, the private mortgage market has expanded in recent years. More borrowers are turning to alternative and private mortgage lenders as access to traditional lending narrows. According to FSRA, private mortgage lenders accounted for 15.8% of Ontario mortgage originations in 2024^{footnote 6[6]}. While private lenders play an important role in meeting market demand, their products often carry shorter terms, higher interest rates, and complex conditions that may not be fully understood by all consumers. It is important for borrowers to have an exit strategy in place (i.e., a plan for transitioning to a traditional mortgage or repaying the loan). FSRA’s most recent consumer survey shows that around 20% of borrowers using non-traditional lenders did not discuss an exit strategy with their mortgage brokers or agents to facilitate a return to a traditional lender^{footnote 7[7]}. Furthermore, less experienced investors have increasingly been entering the private mortgage lending market in recent years, highlighting the need for proper disclosure to enable informed decision-making and oversight across both sides of the transaction.

In parallel, mortgage administrators have taken on more complex responsibilities. Recent failures among mortgage administrators have resulted in significant investor losses and prompted enforcement action by FSRA.

Consumer protection and digital transformation

Consumer protection challenges persist, including identity fraud, incomplete or misleading disclosures, and delays in reporting material changes of circumstances. At the same time, efforts are underway to ensure public-facing documents are clearer, simpler, and more accessible, helping Ontarians make better-informed mortgage decisions and enhancing overall sector accountability.

Technology is also reshaping how mortgage professionals interact with clients, lenders, and regulators. These changes have prompted stakeholders’ calls to modernize outdated regulatory tools and expand the methods for delivering notices and compliance information. While technology improves efficiency and modernizes how the sector operates, it also introduces new risks. Strengthening consumer protection to maintain sector integrity is essential.

Economic uncertainty and regulatory environment

Finally, this review coincides with global economic volatility caused by tariff impacts. In response, in 2025 the Ontario Government enacted the Protect Ontario through Free Trade within Canada Act, 2025. The act will support “as-of-right” mobility for licensed professionals from other provinces and territories, allowing qualified mortgage professionals to practice in Ontario more easily, starting in 2026. The Ontario Free Trade and Mobility Act, 2025, passed in June 2025, will further support brokerages and administrators based elsewhere in Canada to operate in Ontario, while also ensuring there are safeguards to protect Ontarians.

Feedback received

Written submissions from 16 stakeholders in the mortgage broker sector and related sectors, including title insurance companies and consumer advocacy groups, were received in response to the 2024 consultation paper. The submissions contained detailed and thoughtful suggestions on how the MBLAA could be modernized and streamlined to reinforce professionalism, reduce red tape, and protect consumers in the current marketplace. Some of the feedback received included the following suggestions:

Principal brokers should have access to outsourced, high-quality educational materials and resources.

Canadian Alternative Mortgage Lending Association

…the current exclusion of private mortgage insurance under the conditions of a level 1 licence unnecessarily and unfairly restricts the borrowing options available to many first-time homebuyers in Ontario.

Mortgage and Title Insurance Industry Association of Canada

Implementing these expanded reporting requirements… (e.g., criminal charges, bankruptcy) …. will enhance consumer protection, promote ethical behavior, and ensure that mortgage professionals are held to the highest standards of accountability. By requiring licensees to disclose these critical issues, we can better safeguard the interests of clients and uphold the reputation of the mortgage industry.

Mortgage Professionals Canada

Key issues and recommendations

Stakeholder feedback received during the review led to the development of the following 12 recommendations under each of the three themes: reinforcing professionalism in the sector, reducing regulatory burden, and strengthening consumer protection.

Theme 1: Reinforcing professionalism in the sector

Recommendation #1: Enhance the Mortgage Agents Level 1 (MAL1) curriculum

As of April 2023, the mortgage agent licence was divided in two separate licensing classes to reflect the different functions of mortgage agents in the marketplace. Mortgage Agent Level 1 (MAL1) is an entry-level licence requiring no prior experience and limits agents to dealing in mortgages offered by certain lenders. Mortgage Agent Level 2 (MAL2) licences are for more experienced agents, allowing them to work with complex transactions and arrange investments for private lenders.

During this review, stakeholders advocated for stronger education and experience requirements for new first-level entrants to ensure they are well-equipped to provide suitable advice to consumers. As of June 2025, FSRA had licensed 15,158 mortgage agents (of which 9,923 are Mortgage Agents Level 1), compared to 12,277 agents in 2019^{footnote 8[8]}. With the number of agents growing, it is critical to ensure both professionalism and consumer protection across the sector.

Following the 2019 MBLAA Review recommendations, FSRA adopted the Mortgage Broker Regulators’ Council of Canada (MBRCC) accreditation standards and core competencies. FSRA-approved third-party providers deliver mandatory education programs for mortgage agents and brokers using the MBRCC standardized curriculum. While the curriculum provides a consistent foundation, it serves primarily as a blueprint and does not guarantee that course content remains responsive to sector changes or regional needs.

Furthermore, as interprovincial mobility grows, there is an increased need to ensure education requirements align across jurisdictions.

Recommendation #2: Enhance education tools and resources for Principal Brokers

Under the MBLAA, a brokerage is required to designate a Principal Broker as the Chief Compliance Officer responsible for overseeing their brokerage’s conduct, licensing, and finances. The Principal Broker is central to shaping a brokerage’s compliance culture and their role has grown in importance as the sector has evolved. Key responsibilities of a Principal Broker include coordinating the licensing of brokers and agents (whose applications must be submitted by a sponsoring brokerage), overseeing brokers’ and agents’ conduct and continuing education, and certifying the accuracy of the brokerage’s financial statements. Currently, there are no education or training courses specific to the Principal Broker role in Ontario. However, FSRA has published guidance outlining their responsibilities.

The Principal Broker plays a critical role in promoting professionalism and ensuring regulatory compliance across the sector. However, stakeholders have raised concerns that Principal Brokers lack clear, consistent guidance on the full scope of their responsibilities. Without adequate direction and support, supervisory gaps may emerge, potentially exposing consumers to higher risks or unsuitable advice.

Strengthening education for Principal Brokers is increasingly important as interprovincial mobility grows, particularly as a Principal Brokers’ supervisory role in future could include agents or brokers licensed in multiple jurisdictions.

Recommendation #3: Enhance standards of practice for mortgage administrators

Under the MBLAA, mortgage administrators are businesses which are licensed to administer mortgages, that is to receive payments from borrowers on behalf of mortgage lenders. Mortgage administrators manage mortgage payments, trust accounts, and investor funds on behalf of lenders, particularly private lenders, who rely on administrators instead of banks or other large financial institutions that handle administration internally. When the MBLAA was enacted, mortgage administrators were separated from mortgage brokerages to reflect that administering mortgages involves distinct responsibilities and risks, such as managing trust accounts and protecting investors, that differ from brokering activities.

The role of mortgage administrators has evolved significantly since the MBLAA was first introduced. Today the sector deals with more complex mortgage products, a growth in private and alternative mortgages and uncertain economic conditions. In recent years, failures among mortgage administrators have resulted in significant investor losses and prompted enforcement action by FSRA, highlighting the importance of clear regulatory expectations and oversight. Unlike brokerages, administrators are not required to employ licensed brokers or agents, designate a Principal Broker or comply with suitability-related obligations as their core function is administrative rather than advisory. As the role of mortgage administrators has evolved, there is a need to review the oversight and standards of practice for mortgage administrators to improve investor protection.

At the same time, there are differences between the regulations of mortgage brokerages and mortgage administrators across provinces. Ontario, like New Brunswick, Saskatchewan, and Nova Scotia, maintains separate licensing categories for mortgage administrators and mortgage brokerages. While mortgage administrators in Ontario are not required to designate a compliance officer, Nova Scotia requires mortgage administrators to designate a “Chief Compliance Officer”. In Quebec, Manitoba, Alberta, and British Columbia there is no licensing distinction between mortgage administrators and mortgage brokerages. These differences in regulatory frameworks across provinces can lead to inconsistent oversight and protections for investors and borrowers and may hinder labour mobility for professionals in the mortgage sector.

Theme 2: Reducing regulatory burden

Recommendation #4: Modernize service delivery

As the sector regulator, FSRA is required to provide important enforcement documents, such as orders and notices, to licensees. However, FSRA is currently limited through regulations under the MBLAA to delivering such documents by registered mail or fax.

Stakeholders indicated that relying on registered mail and fax for the delivery of these documents is slow, inefficient and does not align with modern business practices, where email or other digital solutions are standard. Receiving regulatory documents in a timely manner is important as it may impact licensees’ compliance with the MBLAA and consumer protection.

Recommendation #5: Waive suitability requirements for permitted clients

Permitted clients are typically sophisticated investors, with substantial resources and knowledge to evaluate and invest in complex investments. The category of permitted clients originates in the securities sector to reduce regulatory burden for sophisticated investors by exempting them from suitability assessments designed for retail investors. Permitted clients can be entities, such as financial institutions, or individuals, such as experienced investors.

Following the 2019 MBLAA Review, changes were implemented to exempt permitted clients from suitability assessments in Non-Qualified Syndicated Mortgages (NQSMs), with entities being exempt by default and individuals exempted if they consent in writing. However, permitted clients engage frequently in other complex transactions in the mortgage sector, such as commercial lending or large-scale investments. Given permitted clients’ substantial knowledge, resources, and experience managing risks associated with these investment transactions, stakeholders have indicated that the requirement to conduct suitability assessments on permitted clients creates unnecessary administrative burden. Stakeholders have also indicated that this results in inconsistency with the treatment of permitted clients in NQSMs and in the securities sector.

Recommendation #6: Expand mortgage agents access to authorized lenders

Individuals who have Mortgage Agent Level 1 (MAL1) licences may only deal in mortgages with lenders approved by the Canada Mortgage and Housing Corporation (CMHC), or with financial institutions such as banks, credit unions, and loan and trust companies. MAL1 licensees are currently not permitted to deal in mortgages with lenders approved by private insurers under the federal Protection of Residential Mortgage or Hypothecary Insurance Act (PRMHIA).

The sector advocated for MAL1 licensees to be allowed to work with PRMHIA-approved lenders, noting that these lenders offer mortgage products comparable to those of financial institutions and CMHC-approved lenders. Stakeholders have also expressed that the approval process for PRMHIA-approved lenders align with the process used for CMHC-approved lenders, and that insurers are now prepared to make the list of approved lenders publicly available to provide transparency as to which lenders are so approved. Allowing MAL1 licensees to access these lenders would expand mortgage options for consumers, reduce administrative burden, level the playing field, and pose no greater risk to borrowers.

Theme 3: Strengthening consumer protection

Recommendation #7: Enhance education on private mortgages

Private mortgages are loans secured by real estate and offered by private lenders, rather than traditional financial institutions like banks or credit unions. These types of loans typically operate outside the direct regulation of federal or provincial authorities and are not bound by standard mortgage lending guidelines.

The growth of private mortgages raises concerns for investors, many of whom may lack the experience, knowledge, or resources to fully assess risks such as borrower default, low liquidity, or potential fraud.

The 2019 MBLAA Review highlighted the growing role of private mortgages and recommended steps to better understand and manage associated risks.

Recommendations included exploring ways to collect data on private lending and introducing enhanced licensing and education requirements to ensure mortgage agents and brokers are equipped to navigate this complex segment of the market. This led to the creation of the Mortgage Agent Level 2 licence category and the enhanced Private Mortgages Course.

All provinces, including Ontario, have mortgage disclosure requirements, to promote transparency and protect borrowers and investors. FSRA oversees compliance and provides guidance and supervision to ensure that disclosures meet consumer protection objectives. For borrowers, this means receiving key information about the mortgage terms, costs, and risks before a commitment is made. For investors, disclosures support better risk assessment. However, concerns remain about borrowers’ and investors’ limited understanding of these requirements in the context of private mortgage products.

Mortgage agents and brokers are responsible for ensuring that the private mortgage products they recommend are suitable for each client, taking into account the client’s financial situation, needs, and risk tolerance. For example, FSRA has issued Mortgage Product Suitability Assessment Guidance outlining the steps brokers and agents should take to ensure recommended mortgages meet client needs.

In 2022-23, FSRA also conducted examinations of brokerages engaged in private lending and arranging private mortgages and found that approximately 65% had missing, incomplete, or inconsistent documentation of suitability assessments and rationale, representing a 9% increase compared to the previous round of private mortgage examinations covering 2021-22^{footnote 9[9]}. FSRA has maintained private mortgages as a key area of supervisory focus, given rising delinquency rates and increasing financial pressure on vulnerable borrowers.

Recommendation #8:  Promote identity verification and authentication compliance

In recent years, concerns regarding identity fraud – the unauthorized use of someone else’s personal information – have grown in the sector. Market participants have highlighted the need to mitigate this issue.

A key aspect of mitigating identity fraud is ensuring that mortgage brokerages and administrators diligently verify and authenticate the identity of potential clients. Since October 2024, mortgage brokers, administrators, and lenders are subject to identity verification and authentication requirements administered by the Financial Transactions and Reports Analysis Centre (FINTRAC). This aligns with and supplements existing regulatory requirements under the MBLAA for licensees to verify their clients’ identity.

Currently, regulators and education providers across sectors and provinces are taking steps to support compliance with FINTRAC’s identity verification and authentication requirements. For example, the British Columbia Financial Services Authority has worked with FINTRAC to design and approve a course to support compliance as part of continuing education requirements. While FSRA has not introduced similar measures, education providers which are active in Ontario, such as Mortgage Professionals Canada, offer courses on FINTRAC compliance for mortgage brokers and agents.

Recommendation #9: Mandate reporting of certain changes of circumstances

Under the MBLAA, licensees are required to notify FSRA within five days of certain changes, including updates to contact information such as email address, phone number, or principal place of business. In addition to this, licensees are required to disclose significant changes of circumstances, such as criminal charges, criminal records, bankruptcies, lawsuits, judgments, and the initiation of enforcement or licensing proceedings by other regulatory bodies to FSRA, during the annual renewal process each year. However, FSRA typically becomes aware of significant changes in a licensee’s circumstances outside the annual renewal process, through third-party information such as consumer complaints, terminations submitted by brokerages, or through public information like news reports of charges or lawsuits.

While some provinces do not specify a reporting timeframe for key changes, Saskatchewan and New Brunswick require disclosure within seven days, and Nova Scotia and Newfoundland and Labrador allow up to ten days.

Recommendation #10: Review Errors and Omissions insurance requirements

Currently, mortgage brokerages and administrators are required to carry Errors and Omissions (E&O) insurance in a form approved by the Chief Executive Officer of FSRA. This insurance must include extended coverage for fraudulent acts and provide a minimum of $500,000 per occurrence and $1,000,000 aggregate occurrences over a 365-day period.

These requirements have remained unchanged since 2008, despite significant growth in the value of mortgage-related value of assets in the sector. Ontario’s requirements are consistent with those in most provinces. However, Quebec requires firms or independent partnerships with more than three representatives to carry double the annual coverage. Quebec also uniquely imposes a maximum deductible based on the size of the partnership. Licensees operating in multiple jurisdictions must meet the E&O requirements for each province in which they are licensed.

Recommendation #11: Use of team names

Team names, which refer to one or more individuals working together as a group within a mortgage brokerage, are commonly used as a marketing strategy across the sector. While mortgage transactions are ultimately completed under the licensed brokerage’s name, stakeholders have noted that consumers often prefer to work with familiar team members (e.g., familiar names and brands), especially in markets where shared language and culture can better inform and support consumers’ financial decision-making.

As team names become more prevalent in the sector, stakeholders have raised concerns around their inconsistent application and the resulting consumer confusion regarding brokerage accountability. Between January and September 2025, FSRA addressed seven complaints regarding team websites where the name of the licensed brokerage was not identified. In comparison, 60 such complaints were addressed in 2024, accounting for 13% of the total complaints closed that year. While the number of complaints has decreased, these gaps in compliance and stakeholders’ continued request for guidance highlights the need for clarity in advertising practices when it comes to the use of team names.

Some provinces, such as Alberta and Quebec, permit the use of team names, provided that the licensed name of the brokerage is also clear to the consumer.

Recommendation #12: Use of plain language

The last MBLAA review recommended that FSRA consult with the mortgage broker sector with regard to guidance, forms, rules and bulletins that affect the sector, as well as to gather suggestions from the industry on how required disclosures to consumers can be simplified and clarified. The goal was to ensure that documents are written in plain language and simplified as much as possible in order to enable both the industry and consumers to understand them and to support better outcomes. FSRA removed 11 mortgage brokering items reducing inherited guidance (from its predecessor) by 23% in the sector^{footnote 10[10]}.

Many stakeholders continue to advocate for the use of plain language in mortgage documentation as consumers often struggle to understand unfamiliar and complex financial and legal terms. Enhancing the clarity of these documents would support first-time homebuyers, seniors, younger demographics and newcomers make informed financial decisions by reducing confusion, promoting transparency and improving understanding of rights and responsibilities when completing mortgage transactions. Ensuring mortgage documents are easy to read also promotes accessibility and strengthens consumer protection by helping individuals avoid potential misunderstandings and financial harm.

Appendix 1: Glossary

Mortgage administrator:

An entity (corporation, partnership, or sole proprietorship) that collects and administers mortgage payments on behalf of lenders or investors. Administrators are responsible for collecting mortgage payments, maintaining records, and ensuring investors receive their entitlements.

Mortgage agent:

An individual licensed under the MBLAA to deal or trade in mortgages under the supervision of a licensed brokerage. Agents are restricted to activities based on licensing category:

Agent Level 1 (Mortgage Agent):

An individual licensee in an entry-level role permitted to deal or trade in mortgages with financial institutions and other approved lenders but cannot work with private or non-traditional lenders. Must be supervised by a Principal Broker.

Agent Level 2 (Mortgage Agent):

Individual licensee with experience as a Level 1 agent who can deal or trade in mortgages with a broader range of lenders, including private and non-traditional lenders, and are expected to have additional education and experience to assess more complex mortgage products. Must be supervised by a Principal Broker.

Mortgage broker:

An experienced individual licensee who can deal and trade in mortgages, including complex transactions. A broker may engage in more complex mortgage transactions and can supervise mortgage agents level 1 and level 2. Must be supervised by a Principal Broker.

Mortgage brokerage:

An entity (corporation, partnership, or sole proprietorship) authorized to deal or trade in mortgages or to undertake mortgage lending or administration activities.

Mortgage Broker Regulators’ Council of Canada (MBRCC):

The MBRCC is comprised of regulators across Canada responsible for administering mortgage broker legislation and regulating the industry in their respective jurisdictions. The MBRCC provides Canada's mortgage broker regulators with a forum to work cooperatively, better share information and coordinate engagement of stakeholders to identify trends and develop solutions to common regulatory issues.

Non-traditional lender:

A lender that is not a regulated financial institution, including private individuals, mortgage investment corporations, mortgage funds, and other alternative lenders. Non-traditional lenders are subject to different regulatory requirements and may carry different risk profiles for borrowers and investors.

Permitted client:

Permitted clients, defined by the Canadian Securities Administrators’ National Instrument 31-103, are typically financially sophisticated entities or individuals, such as financial institutions, registered dealers, wealthy individuals with $5 million or more in financial assets or entities with substantial resources and advanced knowledge, experience, and understanding of financial markets. These clients engage in complex transactions and typically have substantial knowledge of managing the risks associated with mortgage-related investment transactions.

Principal broker:

Designated role held by a licensed mortgage broker, appointed by a brokerage to supervise all agents and brokers, and ensure the brokerage complies with legal and regulatory requirements. Principal brokers are accountable to FSRA for ensuring all agents and brokers under their supervision comply with regulatory requirements.

Private mortgage:

Loans secured by real estate and offered by private lenders, rather than traditional financial institutions like banks or credit unions. These types of loans typically operate outside the direct regulation of federal or provincial authorities and are not bound by standard mortgage lending guidelines. These mortgages can carry higher interest rates and different terms and conditions.

Team names:

A team name refers to a name that represents one or more individuals working together as a group within a mortgage brokerage and is commonly used as a marketing strategy across the sector.

Traditional lender:

A regulated financial institution such as a bank, credit union, caisse populaire, or trust company that is authorized to issue or fund mortgage loans.

Appendix 2:  Summary of recommendations by focus area

Based on Stakeholders feedback, a total of 12 recommendations were developed, reflecting three focus areas identified through the MBLAA review.

Appendix 3: Stakeholder written submissions received

On May 9, 2024, a public consultation to seek the public and industry views was posted on the Ontario Regulatory Registry. The posting closed on June 24, 2024. A total of 16 submissions from diverse stakeholders were received.

Stakeholders

1. Canadian Alternative Mortgage Lenders Association
2. Intact Insurance
3. Mortgage Professionals Canada
4. Premiere Mortgage
5. Real Estate and Mortgage Institute of Canada Inc.
6. Timbercreek Capital
7. Approved Financial Services
8. Advocacy Centre for Elderly
9. Mortgage and Title Insurance Industry Association of Canada
10. Firm Capital
11. Credit Canada
12. Rocket Mortgage Canada
13. Canadian Credit Union Association
14. Ontario Disability Support Program
15. Canadian Mortgage Brokers Association – Ontario

Appendix 4: 2019 MBLAA Legislative Review

The 2019 MBLAA Review Report made seven recommendations aimed at reducing regulatory burden and ensuring that the MBLAA framework remains modern and flexible. Most recommendations have since been fully implemented.