Mortgage Brokering
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Thank you for providing your feedback on FSRA’s proposed Guidance on Mortgage Administrators’ Financial Filing Requirements.

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The Financial Services Regulatory Authority of Ontario (FSRA) is taking steps to ensure mortgage administrators are better protecting funds and investments they handle for investors and lenders.

FSRA is now consulting on proposed guidance that explains what mortgage administrators need to do to comply with existing and expanded financial reporting requirements. 

By complying with these reporting obligations, mortgage administrators will help prevent funds and investments from being misplaced, stolen or treated improperly.

The consultation period for proposed guidance on Mortgage Administrators’ Financial Filing Requirements is now open and will close on June 16, 2023.

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Sector Comment Date posted Sort ascending
[2023-006] Murray Snedden  - MarshallZehr Group Inc.
Here are my thoughts:
• Financial Statements - I have no issue with this requirement and assume this is similar to the financial statement reporting requirements of the past.
• Internal Controls - My concern here is this broadens the scope of the annual audit significantly (assumed to be intentional). The concern here is there is meaningful additional cost, both external audit resources and internal resources necessary to provide the additional information and testing necessary to satisfy the new audit requirements. Administrators are being asked to do this during the auditors' busiest time of the year, likely year end for most mortgage administrators, as well as the personal tax year end, making qualified audit resources difficult to come by at that time of the year. Further, many of these engagements may be viewed as "small/specialized audits" from the auditor's perspective (not worth the effort) and as such will require a "premium" of sorts to get it done. This may in the long run force smaller administrators out of the business and concentrate mortgage administration in fewer, more professional hands, which may be the desired outcome. That said, smaller groups will be disproportionately impacted by these changes.
• Compliance with Trust Account and Assets and Liabilities under Administration Requirements - Reasonable Assurance Report - Same issues as the Internal Controls.
• "Licensed Public Accountant" - No issue with this portion
Enforcement - The monetary penalties per contravention reads exceptionally punitive in my opinion, which may be the point, but there should be some form of "gearing" to the damages caused indicated (I know many will say it is implied, however, better to clearly state rather than be silent). Perhaps the language could be ""softened/expanded"" to introduce the "fairness" concept. Regulators should be trying to "inspire" compliance, as trust in authorities/institutions has dramatically eroded in recent years and all authorities are viewed more suspiciously than ever. I would suggest ensuring the concept of "balance, fairness, and due process" are explicitly incorporated in the language to entice compliance - it can't be "all stick and no carrot", encouraging the spirit of compliance because the rules are "reasonable, relevant, fair and just" is much easier and more efficient than identifying and pursuing rule breakers.
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