Mortgage administrator Annual Information Return for 2023 | Financial Services Regulatory Authority of Ontario

Mortgage Brokerages, Lenders and Administrators Act, 2006

General information

The information listed on this page represents information on file with FSRA as of December 31, 2023:

Legal Name of Administrator:
Other Authorized Name:
Contact Person:
Administrator Licence Number:
Business Type:
Contact Name:

Does the administrator have a CRA business number? ▢ Yes ▢ No
(If yes) CRA business number for the administrator (9 digit):

If No, provide an explanation why the administrator does not have a CRA Business Number:

Principal place of business address
Street Address:
Apt. / Unit:
City:
Province:
Postal code:

Mailing Address (Check if same as above) ▢
Street Address:
Apt. / Unit:
City:
Province:
Postal code:

Phone Number:
Fax Number:
Principal Representative E-mail address:

Consumer complaints E-mail address*:

*Please indicate the email address to which consumers should direct complaints and/or general inquiries. This email address may be posted on the public register and may be provided to the public for the purpose of contacting the administrator.

NOTE: If any of the above information has changed, you are required to notify the Financial Services Regulatory Authority of Ontario (FSRA) within 5 business days of the change by email at: [email protected]

Welcome to the 2023 Annual Information Return (AIR). The Financial Services Regulatory Authority of Ontario (FSRA) uses the information you provide in the AIR to help identify, assess and monitor risk in the mortgage brokering sector. The deadline to file the AIR is by March 31, 2024. The reporting period is January 1 to December 31, 2023; you must file even if you did not conduct any business during the reporting period.

Before you proceed

Only the Principal Representative of the licensed mortgage administrator can complete and submit the AIR. If you fail to file the AIR on time, FSRA may take steps to suspend or revoke your mortgage administrator licence. You may also be subject to an administrative monetary penalty. Any missed deadline will result in a warning letter on your file, which may increase the level of future enforcement action taken by FSRA.

Please note that any inquiries made to FSRA regarding the AIR must be made directly by the Principal Representative.

What you need to complete the AIR

Internet requirements: secure high-speed internet connection; JavaScript, cookies, pop-ups. Recommended browsers - Chrome, FireFox and MS Edge. Internet Explorer is not supported.
administrator licence number
errors and omissions insurance provider, policy number and expiry date
total number and location of offices in Canada
dollar value of mortgages administered in Canada, by region
download and review the sample questionnaire in advance to determine what additional information you may need

Completing the AIR

data is automatically saved when you enter data into the AIR and navigate to a new question
all questions must be answered as applicable
questions can be answered in any order
use the “Tab” key and/or mouse to navigate through items on each page
use the links in the menu on the left to navigate to different parts of the AIR
you are able to print a copy of the AIR at anytime by clicking on the printer icon in the upper righthand corner of the page
pages that are incomplete or that have errors will be identified with an Asterix (*) in the navigation menu on the left
to file the AIR with FSRA, click “Submit” on the Attestation page

Refer to the AIR Frequently Asked Questions for additional tips. You may also click on the camera icon located in the upper right corner of the screen to submit a question regarding any technical difficulties with the AIR.

Note: Consistent with FSRA’s role in deterring deceptive or fraudulent conduct, practices and activities by the regulated sectors pursuant to s. 3(1)(g) of the Financial Services Regulatory Authority of Ontario Act, 2016, FSRA collaborates with other organizations, including fraud prevention organizations and law enforcement agencies, to help combat unlawful activity. Please be advised that the information you provide in the AIR may be shared with such organizations.

On average, entering information for the AIR online will require approximately 60 minutes to several hours to complete. Should you require additional time, you may return at a later time and date to complete the AIR.

If you have finished reading and understand the instructions, please proceed to the next page to begin.

Reporting changes

It is required to notify the Financial Services Regulatory Authority of Ontario (FSRA) within 5 business days of a change to the general information of an administrator by email at: [email protected].

Did any of the following information change during the reporting period, and did you report the changes to FSRA by email at [email protected]: (Check all that apply)

Administrator information	Changed? (Yes/No)	Reported? (Yes/No)
Address for Service	▢ ▢	▢ ▢
Address of Principal Place of Business	▢ ▢	▢ ▢
Email, Phone or Fax	▢ ▢	▢ ▢
Officers or Directors	▢ ▢	▢ ▢
Partners in Partnership	▢ ▢	▢ ▢
E&O Insurance	▢ ▢	▢ ▢
Open/Closed Offices	▢ ▢	▢ ▢

If No, to reporting any changes above, explain why the change was not reported.

Administrator information

a. E&O Insurance Provider

▢ AIG Insurance Company of Canada
▢ Victor Insurance Managers Inc. (formerly Encon Group Inc.)
▢ Intact Insurance Company (Western Division)
▢ International Insurance Company of Hannover SE through A.M. Fredericks Underwriting Management Ltd.
▢ Lloyd’s Underwriters through RDA Inc.
▢ Lloyd’s Underwriters through Holman Insurance Brokers Ltd.
▢ Lloyd’s Underwriters per Catalin Canada Inc.
▢ Lloyd’s Underwriters through Special Risk Insurance Managers Ltd.
▢ Lloyd’s Underwriters through Evolution Insurance Inc.
▢ Lloyd’s Underwriters as arranged by Trinity Underwriting Managers
▢ Royal & Sun Alliance Insurance Company of Canada
▢ Sovereign General Insurance Company
▢ Sovereign General Insurance through Premier Canada Assurance Managers Ltd.
▢ XL Specialty Insurance Company – Canadian Branch
▢ CUMIS General Insurance Company
▢ Zurich Insurance Company Limited
▢ Other

If Other, name of E&O insurance provider:

(i) Indicate the liability limits under your current E&O Policy.

Per Occurrence
▢ $500,000
▢ $1,000,000
▢ Other – Specify Amount:

Per Annual Aggregate
▢ $500,000
▢ $1,000,000
▢ Other – Specify Amount:

(ii) Policy Number:

(iii) Expiry Date:

Upload a copy of the administrator’s Errors & Omissions Insurance Certificate:

Note: Proof of Insurance should include Policy Number, Coverage Amount, Name of Insured, Insurer Name and Fraudulent Acts coverage.

b. Did your Errors & Omissions insurance policy lapse or was cancelled at any point during the reporting period?

▢ Yes
▢ No

If Yes, explain:

c. On August 18, 2022 FSRA and the Mortgage Broker Regulators’ Council of Canada (MBRCC) released guidance on cybersecurity preparedness. Does the administrator have in place or is the administrator working towards achieving cybersecurity preparedness as described in the guidance?

▢ The administrator has cybersecurity preparedness practices in place
▢ The administrator is currently taking action to ensure cybersecurity preparedness practices are in place
▢ No action to date on cybersecurity preparedness

If no action has been taken, please explain:

d. The revised MBRCC guidance clarifies that businesses should identify cybersecurity preparedness practices appropriate for their size, operations and IT capabilities. Does the administrator have insurance for cybersecurity liability?

▢ Yes
▢ No

e. During the reporting period, did the administrator experience any cyber security incident which resulted in a breach of the administrator’s computer systems/networks?

▢ Yes
▢ No

If Yes, explain:

i) How many cyber security incidents occurred? {numerical value}
ii) Describe the nature of the incident. {open text box}

f. FSRA’s cybersecurity guidance indicates that brokerages and administrators should notify FSRA if they experience a cybersecurity incident that could have a material impact on client information. When FSRA becomes aware of a cybersecurity incident through notification by a licensee, market intelligence, a tip or complaint, it will activate FSRA’s Market Conduct Protocol for Cybersecurity as described in the guidance.

During the reporting period did you experience a cybersecurity incident that had a material impact on client information?

▢ Yes
▢ No

If Yes, please describe:

If No, please advise if you experienced a cybersecurity incident that did not have a material impact on client information

g. Does the administrator have cyber security Policies and Procedures in place?

▢ Yes
▢ No

h. What is the administrator’s designated fiscal year end?

i. Is the mortgage administrator’s auditor a licensed public accountant?

▢ Yes
▢ No

If No, provide an explanation:

NOTE: Audited financial statements are required to be prepared by a licensed public accountant listed on CPA’s public registry in good standing.

j. Did the administrator file financial information for its most recent fiscal year-end pursuant to O. Reg. 193/08 s. 3?

▢ Yes
▢ No

(i) If Yes, what date?

If not filed within 90 calendar days from the most recent designated fiscal year-end, explain why?

(ii) If No, provide an explanation:

k. Did your annually filed audited financial statements include the Independent Auditor's Reasonable Assurance Report on Compliance as required under s.3(1)(c) of Ontario Regulation 193/08 and as indicated in the Mortgage Administrators Financial Filing Requirements?

▢ Yes
▢ No

If No, explain:

If Yes, was the Independent Auditor's Reasonable Assurance Report on Compliance in the FSRA-specified format as indicated in the Mortgage Administrators Financial Filing Requirements?

▢ Yes
▢ No

l. If the administrator or its related persons/entities are also licensed as a mortgage brokerage with FSRA, enter the mortgage brokerage licence number here:

“Related persons/entities“ includes family members, affiliates, officers, directors, partners, employees, brokers, agents, principal shareholders, etc. of the administrator.

m. Does the administrator or its related persons/entities* hold any other licenses including mortgage brokerage or mortgage administrator licenses in any Canadian jurisdiction (Ex. Financial Planner, Financial Advisor)?

▢ Yes
▢ No

If yes, provide the following information:

Type of Licence	License Number	Province in which Licence is held

“Related persons/entities“ includes family members, affiliates, officers, directors, partners, employees, brokers, agents, principal shareholders, etc. of the administrator.

n. What other lines of business was the administrator engaged in?

▢ Accounting
▢ Legal Services
▢ Advisory Services/Consulting
▢ Administering Mortgages
▢ Real Estate Brokering
▢ Construction
▢ Other:

o. Does the administrator have a website?

▢ Yes
▢ No

If Yes, please provide:

p. Is the administrator a publicly traded company?

▢ Yes
▢ No

If Yes, what is the administrator’s trading symbol?

p-i. If No, is the administrator related to a publicly traded company?

▢ Yes
▢ No

If Yes:

i. What is the name of the publicly traded company the administrator is related to?

ii. What is the trading symbol of the publicly traded company the administrator is related to?

iii. What is the relationship between the administrator and the publicly traded company?

▢ Parent of the administrator
▢ Subsidiary of the administrator
▢ Commonly controlled
▢ Other affiliations

q. Is the administrator registered as a reporting entity with the Financial Transactions and Reports Analysis Centre (FINTRAC)?

▢ Yes
▢ No

NOTE: This question is for information gathering purposes only. Registration with FINTRAC is not a mandated requirement.

r. Is the administrator rated by a credit rating agency (ex. Fitch, Moody’s, DBRS-Expand, Standard & Poors)?

▢ Yes
▢ No

If yes, what is the name of the rating agency the administrator was rated by?

If yes, please attach most recent rating report:

Note: Credit rating agencies are private, for-profit companies which assign a credit rating to the debt of governments or corporations. The credit rating is an assessment of the borrower’s credit risk and reflects the borrower’s ability to make interest payments as well as repay the original debt.

Trust account information

The purpose of these questions is to verify compliance with legal obligations under the Mortgage Brokerages, Lenders and Administrators Act, 2006 (MBLAA).

1. Did the administrator have a trust account(s) under the MBLAA?

▢ Yes
▢ No

1a. If No, Explain:

If Yes:

1b. How many designated trust accounts did the administrator have as at December 31, 2023 (as per O. Reg. 189/08 s.34)?

How many are within Ontario?

How many outside Ontario?

1c. Of the total number, how many MBLAA trust accounts did the administrator open during the reporting period?

1c-i. How many of these trust accounts were opened on Ontario?

1c-ii. For the trust accounts opened in Ontario, did the administrator obtain prior written consent from the FSRA Chief Executive Officer pursuant to O. Reg. 189/08, s. 34 (2)?

▢ Yes
▢ No

If yes, did the administrator notify FSRA with the trust account information within 5 business days after opening the account (S.4(2) of ONTARIO REGULATION 193/08)

1c-iii. If No, explain why?

1d. What accounting system/program does the administrator use to keep track of deemed trust funds (including investors’ funds remittance) and investor investment balances? If more than 1 system/program is used, please identify all and the purpose of each system/program.

1e. Did the administrator reconcile all of its MBLAA trust accounts?

▢ Yes
▢ No

1e-i. If Yes, how often did the administrator reconcile the trust accounts?

▢ Monthly
▢ Annually
▢ Quarterly

1e-ii. If No, explain why?

1f. Was interest earned from monies on deposit in your trust account fully credited to the investor/lender?

▢ Yes
▢ No

1f-i. If No, explain why?

2. Was there a shortfall, at any time during the reporting period, in any of the MBLAA trust accounts?

▢ Yes
▢ No

If Yes, provide the following information:

Date shortfall occurred	Amount of shortfall	Has shortfall been corrected	Date shortfall corrected	Reported to the FSRA CEO	Reason for shortfall and steps taken to correct
		▢ Yes ▢ No		▢ Yes ▢ No
		▢ Yes ▢ No		▢ Yes ▢ No
		▢ Yes ▢ No		▢ Yes ▢ No
		▢ Yes ▢ No		▢ Yes ▢ No

Supervision of operations

The purpose of these questions is to determine whether the administrator’s operations are organized in a way that facilitates supervision and to facilitate examination/inspection planning by FSRA.

3. Indicate the total number of owners of the administrator, including those who are Directors, Officers, Partners and Beneficial Owners as at December 31, 2023.

▢ 1 to 10
▢ 10+
▢ Publicly traded company

List any owners of the administrator including Beneficial Owners, other than the Directors, Officers, or Partners as at December 31, 2023; where an owner is a corporation, please include the ultimate individual Beneficial Owners and add in brackets the name of the corporation.

If more than five, list the top five owners, based on the greatest percentage of ownership and upload a list of ALL owners with their respective percentage of ownership:

If the administrator is a publicly traded company, insert “Shareholders” in the “Owner’s legal name” column.

Owner’s legal name	Percentage owned

3a. Where was the administrator’s head office/principal place of business in Canada as at December 31, 2023?

▢ Alberta
▢ British Columbia
▢ Manitoba
▢ New Brunswick
▢ Newfoundland and Labrador
▢ Nova Scotia
▢ Northwest Territories
▢ Nunavut
▢ Ontario
▢ Prince Edward Island
▢ Quebec
▢ Saskatchewan
▢ Yukon

NOTE: For the purpose of the AIR, "head office" is defined as: "A place of business where the administrator spends more than 50% of his or her time working on mortgage administration, including home offices."

4. Provide the total number of offices for each Ontario region as at December 31, 2023 as applicable:

Ontario region	Number of offices
Toronto (M)
Central Ontario (Excluding Toronto) (L)
Eastern Ontario (K)
Northern Ontario (P)
Southwestern Ontario (N)
Total # of Offices

NOTE: Include your head office as well as all additional offices that are open to the public.

5. Does the administrator have an individual designated to ensuring compliance with the Mortgage Brokerages, Lenders and Administrators Act, 2006 (MBLAA)?

▢ Yes
▢ No

If yes, provide their name, email and phone number:

6. Please indicate the number of staff who are involved in the administration responsibilities for the mortgage administrator?

7. Does the mortgage administrator have procedures to stay informed of mortgage performance and the condition of the underlying property as outlined in the May 12, 2020 Guidance No. MB0039INT (e.g.: maintaining awareness of significant circumstances that could impact the valuation of the property and the loan-to-value ratio, regularly assessing delinquency risk, and tracking mortgage arrears and determining the impacts on distributions to the investor / lender?

▢ Yes
▢ No

If Yes, what procedures are in place?

If No, provide rationale?

8. Does the mortgage administrator provide performance and investment reports to investors?

▢ Yes
▢ No

If Yes, how frequently are reports provided?

▢ Monthly
▢ Quarterly
▢ Annually
▢ On request

If No, provide rationale?

9. For each of the activities noted below, please check whether the administrator (as directed by the owner(s) or Principal Contact) currently deploy technology to “automate” and/ or deploy “artificial intelligence, e.g. machine learning.”

Definitions:

“Automation” means using pre-programmed algorithms that follow specified rules to complete specific tasks
“Artificial intelligence (AI)” refers to the application of computational tools that do not require pre-programmed rules to build models from examples, data, and experience.

Please select “Yes” “No,” or “N/A.” (“N/A” is to be used for any activities that you do not perform.)

Business Processes	Automation	Artificial Intelligence
Advertising and lead generation	Yes No N/A	Yes No N/A
Know your client (including ID verification)	Yes No N/A	Yes No N/A
Generate recommendation(s) with rationale (e.g.: where extensions or forbearances are being recommended by the administrator to the investors/lenders)	Yes No N/A	Yes No N/A
Ensuring fulfillment of conditions precedent progress draws funding	Yes No N/A	Yes No N/A
Monitor and report on mortgage performance	Yes No N/A	Yes No N/A
Generate Reporting/Account Statements to investors/lenders	Yes No N/A	Yes No N/A
Mortgage discharge	Yes No N/A	Yes No N/A
Corporate functions (e.g. strategic planning, human capital planning, information technology, financial management)	Yes No N/A	Yes No N/A
Other	Yes No N/A	Yes No N/A

If you deploy automation or artificial intelligence in other activities in operating your business, please specify.

***Where "Yes" is selected for AI in a specific activities, the following follow-up question will appear.

10. Please indicate how you use artificial intelligence in the selected activity by selecting ALL types of AI that apply using the following definitions:

"Critical Thinking" = reasoning, comparing and querying documents
"Planning" = decision support, forecasting, predictions
"Generative" = ideation, copywriting, drafting documents, images
"Hearing" = contact centre support, handling client queries, sentiment analysis
"Touch" = exploring physical surroundings
"Speech" = chatbots, natural language conversations
"Visualizations" = read and understand documents, including images, texts and tables

AI Types
	Critical Thinking	Planning	Generative	Hearing	Touch	Speech	Visualization	Other
Selected Activity	◯	◯	◯	◯	◯	◯	◯	◯

11. Please identify the major types of risks associated with the use of artificial intelligence in your business. Indicate your level of confidence in effectively mitigating each risk (high, medium, low levels of confidence).

Risks	Yes, applies to my business	Confidence Level in Mitigating the risk
Risks	Yes, applies to my business	High	Medium	Low
a. Reputational harm to your business	◯	◯	◯	◯
b. Real or perceived lack of transparency or explain-ability	◯	◯	◯	◯
c. Inability to provide audit trail	◯	◯	◯	◯
d. Inaccuracies, errors, or hallucinated responses	◯	◯	◯	◯
e. Cybersecurity exposure and increased security risks	◯	◯	◯	◯
f. Uncontrolled job displacements	◯	◯	◯	◯
g. Real or perceived loss of human control over outcomes	◯	◯	◯	◯

12. Does your administrator plan to deploy artificial intelligence within the next 2 years in any of your business activities?

▢ Yes
▢ No

13. Have you reviewed the administrators Policies and Procedures?

▢ Yes
▢ No

If, yes When were the administrators Policies and Procedures last reviewed?

If No, explain:

14. When were the administrator’s Policies and Procedures last updated?

Portfolio details / information

(The purpose of these questions is to gather marketplace statistics)

Where mortgage specifics, such as number or dollar value of mortgages are requested, please provide Ontario mortgage business information as of December 31, 2023, unless stated otherwise. Note: FSRA considers an Ontario mortgage to be a mortgage where any of the borrower(s), any of the lender(s) or the mortgaged property is in Ontario.

15. Provide the following information on the administrator’s mortgage portfolio as at December 31, 2023:

		Total mortgage business within Canada	Mortgage Business within Ontario
15a.	Total number of mortgages under administration
15b.	Total dollar value of mortgages under administration
15c.	Total number of investors in the mortgages under administration (including both entities and individual investors)
15d.	Total number of mortgages in arrears
15e.	Total dollar value of mortgages in arrears
15f.	Total number of mortgages in arrears where foreclosure/power of sale proceedings commenced
15g.	Total dollar value of mortgages in arrears where foreclosure/power of sale proceedings commenced

16. Provide the following information regarding the underlying properties for the mortgages under administration as at December 31, 2023:

	Property type	Number of mortgages under administration	Dollar value of mortgages under administration
16a.	Commercial (e.g., Office Building, Retail, Hotels)
16b.	Industrial (e.g., Manufacturing, Machine Shops)
16c.	Institutional (e.g., Hospitals, Schools, Churches)
16d.	Mining/Resource Based (e.g., Oil, Gas, Timberland)
16e.	Rural Land (e.g., Agricultural / Farmland, Winery, Orchard etc.)
16f.	Residential (e.g., Single Family, Multi-Unit, Vacation Property)
16g.	Other (e.g.: hospitality)

If other, please specify the property type:

17. Provide the demographic of the investors in the mortgages under administration as at December 31, 2023:

	Investor type	Number of investors	Total number of mortgages administered	Total dollar value administered
17a.	Individual (This does not include individual investors in a MIC or MIE)
17b.	Entity/Corporation
17c.	Mortgage Investment Corporation (MIC)
17d.	Mortgage Investment Entity (MIE) other than MIC
17e.	Mortgage Finance Company / Monoline
17f.	Regulated Financial Institution
17g.	Other (Non-Regulated Financial Institution)

Mortgage Investment Entity ("MIE") is a mortgage-financing business, other than a MIC, that pools together money from investors to lend on mortgages. MIEs can vary in organizational structure, and may be a trust, a limited partnership or a corporation.

Mortgage Investment Corporation (“MIC”) is an investment/lending company designed specifically for mortgage investing or lending, in Canada, and governed by the Income Tax Act.

Provide the following information if you have individual investors in the mortgages under administration as at December 31, 2023:

	Investor type	Total number of mortgages administered	Total dollar value administered
17a-i.	Designated Investor
17a-ii.	Non-designated retail Investor

18. Is the mortgage administrator related to borrowers on mortgages they have under administration?

▢ Yes
▢ No

If Yes, please advise the number of mortgages under administration in which the mortgage administrator is related to the borrower(s).

19. Did the administrator manage a Mortgage Investment Corporation (MIC) during the reporting period?

▢ Yes
▢ No

If Yes, complete the following as at December 31, 2023:

# of mortgages administered for the MICs that is/are managed by the administrator:

$ of mortgages administered for the MICs that is/are managed by the administrator:

# of different MIC lenders managed by the administrator:

20. List the top three (3) MICs the administrator administered based on the total dollar value of mortgages.

Name (a.)	Number of mortgages administered by the administrator (b.)	Dollar value of mortgages administered by the administrator (c.)

21. List the top three (3) MICs for whom the administrator administered based on the total number of mortgages.

Name (a.)	Number of mortgages administered by the administrator (b.)	Dollar value of mortgages administered by the administrator (c.)

22. Did the Administrator's Policies and Procedures include provisions specifically covering procedures relating to MIEs (including MICs)?

▢ Yes
▢ No

23. Provide a list of all MICs that were managed by the administrator during the reporting period that sold units/shares/etc. to investors through a prospectus or Offering Memorandum filed with a securities commission?

24. Not including any MIC lenders or NQSMI or QSMI-type mortgages, did the administrator administer any private mortgages?

▢ Yes
▢ No

A Private mortgage is a mortgage by a person or business who lends their own funds for a mortgage including Mortgage Investment Entities (other than MICs), other mortgage brokerages, and/or individual mortgage brokers or agents. A Mortgage Investment Entity ("MIE") is a mortgage-financing business that pools together money from investors to lend on mortgages. MIEs can vary in organizational structure, and may be a trust, a limited partnership or a corporation.

24a. If Yes, complete the following

Number of mortgages:
Dollar value of mortgages:
Number of private lenders:

24b. List the top five (5) private lenders the administrator administrated for based on the number of mortgages:

Name (24b-i.)	Type of private lender [Select from list: (a) MIE other than MIC, and (b) private lender who are persons or business other than MIC & MIE.] (24b-ii.)	Number of mortgages (24b-iii.)	Dollar value mortgages (24b-iv.)
		#
		#
		#

24b-v. If more than five (5) private lenders, upload a list of all private lenders for whom the administrator administered for during the reporting period (provide the legal first and last name of an individual or the legal business name of an entity):

24c. Did the administrator administer any mortgages for a National Housing Act approved lender?

▢ Yes
▢ No

Note: National Housing Act approved lenders are defined in the legislation

25. Does the administrator have in place policies and procedures which relate to the disbursement of funds for all types of mortgage products under its administration?

▢ Yes
▢ No

If No, Explain:

26. Please provide the total number of instances of early redemption freezes that the mortgage administrator put in place during the reporting period. “Redemption freezes” refer to both 1) redemption restrictions put on investors in pooled MIEs administered by the administrator and 2) redemption restrictions put on direct investors/lenders in individual mortgage loans.

27. Did the administrator administer any non-qualified syndicated mortgages investments (NQSMI)?

▢ Yes
▢ No

27a. If Yes, complete the following:

# of mortgages:

$ of mortgages:

# of lenders:

28. Does the Administrator's Policies and Procedures include provisions governing NQSMIs?

▢ Yes
▢ No

29. Did the administrator administer any qualified syndicated mortgages investments (QSMI)?

▢ Yes
▢ No

29a. If Yes, complete the following:

# of mortgages:

$ of mortgages:

# of syndicates/lenders:

30. Does the Administrator's Policies and Procedures include provisions governing QSMIs?

▢ Yes
▢ No

Qualified syndicated mortgage investment (“QSMI”):

A syndicated mortgage is a qualified syndicated mortgage if all of following criteria are satisfied in respect of the syndicated mortgage:

the syndicated mortgage secures a debt obligation on property that
1. is used primarily for residential purposes
2. includes no more than four units
3. includes no more than one unit that is used for non-residential purposes
the syndicated mortgage does not secure a debt obligation incurred for the construction or development of property
At the time the syndicated mortgage is arranged, the amount of the debt it secures, together with all other debt secured by mortgages on the property that have priority over, or the same priority as, the syndicated mortgage, assuming in all cases that the maximum amounts of any such mortgages are fully drawn, does not exceed 90 per cent of the fair market value of the property relating to the mortgage, excluding any value that may be attributed to proposed or pending development of the property.
the syndicated mortgage cannot be subordinated to future financing without the consent of each lender
there is no existing agreement that requires any lender of the syndicated mortgage to consent to future subordination of the syndicated mortgage
no person has the ability to consent to future subordination of the syndicated mortgage on behalf of the lenders of the syndicated mortgage without obtaining the consent of each lender. O. Reg. 695/20, s. 1 (4).

A syndicated mortgage that secures a debt obligation incurred for the construction or development of property is not a qualified syndicated mortgage.

Non-qualified syndicated mortgage (“NQSMI”): A syndicated mortgage which does not meet the requirements of a qualified syndicated mortgage.

The transfer of regulatory oversight of certain syndicated mortgages from FSRA to the Ontario Securities Commission (“OSC”) took effect on July 1, 2021. The QSMI definition above has been replaced effective July 1, 2021 to align with the OSC definition. Please refer to FSRA Guidance on the Supervision Approach for Non-Qualified Syndicated Mortgage Investments with Permitted Client and Legacy Non-Qualified Syndicated Mortgage Investments for details.

31. Does the administrator intend to end operations within the current 2024 calendar year?

▢ Yes
▢ No

If yes, provide rationale and advise if you have a transition plan for on-going mortgages under administration?

Records information

32. What format were your required records stored in? (check all that apply)

▢ Electronic
▢ Paper

Note: Reference FSRA cybersecurity guidance and MBRCC Principles for Cybersecurity Preparedness if storing records in electronic format.

33. Has the administrator taken adequate precautions to ensure the security of your records?

▢ Yes
▢ No

If Yes, please select from the list what precautions you have taken:

Electronic Records	Paper Records
▢ Access to data restricted to those who require access ▢ Stored on cloud with password controls ▢ Stored on local server ▢ VPN server ▢ Data backed up daily ▢ Up-to-date anti-virus application installed ▢ All client info sent via secured channel (e.g., DocuSign) ▢ Battery backup for local system ▢ Other (provide details)	▢ Access to data restricted to those who require access ▢ Stored in locked area (e.g., locked filing cabinets) ▢ Security alarm on office premises ▢ Other (provide details)

If No, explain:

33a. Were the required records retained at the administrator’s principal place of business in Ontario?

▢ Yes
▢ No

If No, you are required to notify the FSRA Chief Executive Officer if records were kept at a different location. (O. Reg. 193/08, s.5)

Confirm you have complied with this requirement.

▢ Yes
▢ No

Unimpaired working capital

34. Have you maintained $25,000 of unimpaired working capital or other form of financial guarantee as approved by the FSRA Chief Executive Office at all times throughout the year?

A mortgage administrator shall maintain a financial guarantee in an amount equal to $25,000. O. Reg. 189/08, s. 28 (1)

The financial guarantee may be unimpaired working capital or it may be another form of financial guarantee acceptable to the Chief Executive Officer. O. Reg. 189/08, s. 28 (2)

Confirm that you have complied with these requirements.

▢ Yes
▢ No

If No, Explain:

Complaints and complaint handling

35. You are required to designate one or more individuals to receive and attempt to resolve complaints from the public, and each designated individual must be an employee of the mortgage administrator or someone who is otherwise authorized to act on its behalf. O. Reg. 189/08, s. 26 (2).

Confirm you have complied with this requirement.

▢ Yes
▢ No

If not in compliance, please explain:

If yes, is the designated person to resolve complaints the Principal Representative?

▢ Yes
▢ No

If No, please provide the designated person’s contact information below:

Name	Position Title	Email	Phone Number

36. Total number of written complaints received by the administrator during the reporting period:

36a. Indicate the number of complaints which originated from each of the following sources:

Borrower:
Provide a summary of the complaints received from borrowers:

Lender (other than MIEs):
Provide a summary of the complaints received from lenders:

MIE:
Provide a summary of the complaints received from MIEs (including MICs):

Other Regulator:
Provide a summary of the complaints received from other regulators:

Other Source:
Provide a summary of the complaints received from other sources:

36b. Did any of the complaints received by the mortgage administrator relate to non-qualified syndicated mortgages or qualified syndicated mortgages?

▢ Yes
▢ No

36c. Of the total written complaints received, how many were responded to, as required by legislation?

NOTE: The administrator must respond, in writing, to all written complaints that are received.

36d. Of the total written complaints received, how many were resolved as at December 31, 2023?

NOTE: For the purpose of the AIR, “resolved” means that the administrator has addressed and responded in writing to all concerns raised by the complainant.

Suitability

The purpose of these questions is to help further determine if the mortgage administrator is suitable to continue to be licensed

Note: Individual disclosures must also be reported on license applications (if applicable)

37. Were there any E&O claims made against the administrator during the reporting period in any Canadian jurisdiction, during the reporting period?

▢ Yes
▢ No

If Yes, provide a brief explanation including the number of claims

38. During the reporting period, was a complaint made against the administrator to a regulatory body in any Canadian jurisdiction that was based, in whole or in part, in allegations of fraud, theft, deceit, misrepresentation, forgery, or similar conduct?

▢ Yes
▢ No