Mortgage brokering sector Supervision Plan 2024-25

Ontario mortgage borrowers and investors continue facing housing market uncertainty and reduced mortgage affordability.

Despite interest rate cuts, these risks have remained mostly the same over the last year. The 2024-2025 Plan maintains our areas of supervision focus from last year given that the top consumer protection risks have not changed. Risks in mortgage investments remain elevated and private mortgages continue to be a supervision priority, especially as more consumers are turning to them.

As a result, the Plan has three focus areas to ensure that:

• brokerages and principal brokers have in place a strong conduct culture that supports fair treatment of consumers
• consumers receive mortgage advice and products that are suitable for their individual needs and circumstances
• investors and lenders have confidence that mortgage administrators are appropriately handling and protecting investments in administrators’ care

Our continued focus on private mortgages is crucial as the number of consumers turning to these more complex products continues to grow, as data from our first ever Private Lending Report shows.

To further help the sector understand our expectations around conduct culture and consumer protection, FSRA expects to finalize our proposed principal broker Guidance in October. The guidance will clarify expectations for principal brokers regarding their agents’ and brokers’ conduct and supports the fair treatment of consumers.

We will also host our first ever Principal Brokers’ Conference in November. This event is tailored specifically to enhance brokerages’ approaches to achieving positive client outcomes and strengthening consumer confidence in the sector.

Finally, FSRA will continue to run its Private Mortgage education campaign to better protect consumers who need to use a private mortgage.

We urge you to closely read the Plan, and all relevant Guidance and publications to stay informed about your regulatory responsibilities.

Background

Ontario’s Mortgage brokering sector

As of August 1, 2024, FSRA licensed 2,925 mortgage brokers, 5,203 level 2 mortgage agents, and 9,937 level 1 mortgage agents with 1,193 brokerages. This compares to 2,833 brokers and 12,277 agents on June 30, 2019, representing nearly 12% growth in the combined number of agents and brokers between 2019 and 2024.

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Licensees brokered 265,000 mortgages, worth more than $148 billion in Ontario in 2023.^[1]

As of March 31, 2024, FSRA licensed 242 mortgage administrators who administered about $ $400B and over 920,000 mortgage investments for 28,500 investors.^[2]

How does FSRA protect consumers when they are obtaining a mortgage product?

FSRA supervises and examines the business practices of mortgage brokerages, administrators, brokers and agents to ensure they:

• provide products and services suitable for each client’s individual needs and circumstances
• help clients understand the features, implications, risks and costs of their mortgage or mortgage investment
• provide services in a transparent and fair manner
• comply with all regulatory expectations and applicable legal and regulatory requirements

FSRA has extensive resources to assist consumers when they are seeking a mortgage. Consumers should ask questions if there is something they don’t understand when they are dealing with a mortgage professional. Brokers and agents should ensure that they properly understand their clients’ needs and circumstances to recommend a suitable mortgage product.

The past year saw rapid changes in housing markets and in the economic fundamentals backing them. The Bank of Canada began to increase interest rates in March 2022 and these increases accelerated throughout 2023. In total, the bank increased rates 10 times over two years.^[3] These rate increases had a slowing effect on housing markets, leading to an initial softening in early 2023, yet housing prices continued to remain high. As a result, mortgage volumes plummeted by over 25% in 2023 compared to 2022.^[4]

At the same time, restrictive underwriting conditions for traditional financial institutions (e.g., banks) continued to create challenges for consumers seeking to access affordable mortgage financing. Some consumers were no longer able to qualify for a mortgage from their bank and, as a result, more consumers sought financing from private mortgage lenders. FSRA’s annual report on private lending observes that despite a general decrease in mortgage activity during this period, private mortgage lenders increased their market share of the total number and value of mortgages originated in 2023.^[5] While traditional lenders, like banks, continue to account for the majority of mortgage activity, their market share declined to 79.6% of the total number of mortgages and 84.4% of the total value of mortgages in 2023, down from 83.4% and 87.9%, respectively, in 2022. Inversely, private mortgage lenders increased their market share to 20.4% of the total number and 15.6% of the total dollar value of mortgages in 2023, up from 16.6% and 12.1%, respectively, in 2022.^[6]

FSRA addressed risks to consumers by enhancing education, releasing Guidance and intensifying engagement with the sector

FSRA has undertaken a long-term strategy to enhance professionalism in the mortgage broker sector to foster consumer confidence in the industry. This strategy focuses on strengthening competence and conduct culture within brokerages. A firm’s culture drives the norms, attitudes and behaviours of its management and staff. Conduct culture refers to a firm’s norms, attitudes and behaviours with respect to treatment of and outcomes for their customers. FSRA considers a firm with a strong conduct culture be one which takes actions and makes decisions that will not deliver poor or unfair outcomes for its customers, or otherwise harm customers’ interests.

In support of this strategy, FSRA recently implemented a new licensing class and enhanced education for those individuals who deal in private mortgages. We will continue to strengthen education requirements (e.g. continuing education) in the coming years.

During 2023-2024, FSRA responded to emerging consumer risks by proposing key pieces of guidance for the mortgage broker sector. As part of a multi-year process to strengthen conduct culture in the mortgage broker sector, FSRA issued proposed guidance to clarify expectations of principal brokers and their brokerages with respect to ensuring compliance and influencing conduct.

We also finalized mortgage product suitability assessment guidance on what brokers and agents should do to ensure the mortgages that they recommend to their clients are suitable. This was intended to address consumer protection concerns in an environment of low mortgage affordability.

Rising real estate prices and online real estate or mortgage transactions have contributed to increased attention to real estate and mortgage fraud over the past year. Fraud can be income or document falsification to get qualified for a mortgage (known as fraud for shelter) or stealing a homeowner’s identity to mortgage or sell their home (known as fraud for profit). Other fraud types involve scam artists posing as contractors for renovations that resulted in mortgages placed on homes.

Fraud and identity theft can happen during any stage of a real estate or mortgage transaction and can be equally perpetrated by firms and individuals who are licensed or not licenced with FSRA. FSRA’s effort with respect to fraud focuses on those within our jurisdiction. As part of our response to this rising threat, in September 2023 FSRA finalized guidance on detecting and preventing mortgage fraud to set out regulatory expectations on the minimum steps a licensed firm and individual must take to prevent and address fraud, including validating identity and documents, and following up on red flags (e.g. inconsistent information between documents).

To further protect consumers and help to ensure they are receiving mortgage advice from individuals who are suitable to hold a mortgage broker or agent licence, in July 2024 FSRA finalized guidance on mortgage agent and broker licensing suitability. This guidance supports increased professionalism and integrity in the mortgage brokering sector by helping mortgage professionals understand how past and current conduct may affect their suitability to hold a licence. It outlines best practices for brokerages and principal brokers to screen applicants for suitability and monitor their authorized licensees.

In November 2023, FSRA also finalized its guidance on mortgage administrators’ financial filing requirements. This guidance clarifies existing reporting requirements and, for fiscal years after December 31, 2024, expands the scope of the required audit on compliance with specific requirements under the Mortgage Brokerages, Lenders and Administrators Act, 2006 (MBLAA). The objective is to protect funds and investments mortgage administrators handle for investors.

During the 2023-2024 Supervision cycle, FSRA also intensified its direct engagement with some of the larger licensed entities in the sector. This was done by meeting with them individually on a semi-annual basis to discuss consumer protection, conduct expectations and industry trends that may pose heightened risks for consumers. These types of touchpoints support FSRA’s knowledge of the sector and encourages the industry’s understanding of FSRA’s supervision priorities.

In addition to issuing guidance to address consumer protection risks and engaging with licensees who have a substantial impact in the sector, FSRA’s supervision exam programs for the past year were aimed at addressing areas of high risk for consumers and sector participants.

Private mortgage brokering

Given the increasing number of consumers turning to private mortgages in Ontario and rising indicators of consumer vulnerability,^[7] FSRA determined that private mortgage brokering would be a key supervision focus for 2023-2024.

FSRA undertook exams focusing on private mortgage brokering. These exams assessed how well a brokerage’s agents and brokers demonstrated that they assessed whether the mortgage was suitable for the borrower and whether a borrower was made aware during the transaction that if they are undertaking higher cost mortgage financing, they should have an “exit strategy” that would help them to qualify for lower cost financing after the term of the mortgage ends. Similarly, the exam program also looked at whether the brokerage accurately described and disclosed conflicts, or potential conflicts, of interest and the brokerage’s role in the transaction.

Conduct culture, compliance structure and principal broker supervision in large brokerages

For 2023-2024, FSRA undertook a series of large brokerage exams focused on the corporate and compliance structures at these brokerages, the effectiveness of the supervision of their authorized agents and brokers, as well as the brokerage’s compliance controls.

Taken together, these exams looked at the practices of mortgage brokerages that:

• authorized approximately 1,780 licensed brokers/agents (11.4% of licensees as of December 31, 2023)
• funded approximately $7.7 billion in total (representing approx. 5.2% of all mortgage fundings by $ value);^[1] and funded approximately $850.6 million in private mortgages (representing about 3.3% of all private mortgage fundings)^[8]

Mortgage brokerages with related mortgage investment corporations

Continuing its focus on private mortgage brokering, FSRA examined 15 mortgage brokerages that have a related mortgage investment corporation (MIC) and who represent both the borrower and the lender in the same transaction. These 15 brokerages, combined:

• represent 22% of mortgage brokerages who reported they have total lending and investment control of a MIC and 16% of all MIC related mortgage brokerages
• have funded approximately $190 million in mortgages with a related MIC and approximately $213 million with a MIC over which the brokerage has total control of investment and lending^[9]

Mortgage investment sales and administration

In addition to protecting consumers who are borrowers, FSRA also addressed risks faced by consumers who are mortgage lenders / investors. These consumers deal with mortgage brokerages when they invest in mortgages and they may rely on mortgage administrators to service and monitor the performance of those investments. Higher interest rates made investing in mortgages increasingly attractive to more Ontario investors. But high construction and financing costs for developers, a dramatic slowdown in pre-sales created and heightened affordability issues with borrowers increased risks on mortgages investments. Noting this context, FSRA undertook an examination program to review private mortgage investments from the point of sale by brokerages to the servicing of these investments by a related administrator.

These exams reviewed sample private mortgage investment files from 4 MBs and 5 MAs:

• The initial 5 mortgage administrators have over 1,290 mortgages under administration with a dollar value of approximately $368.8 million.
• The 4 mortgage brokerages have brokered collectively 3,435 mortgages with a value of approximately $1.53 billion including approximately $231 million in traded mortgages.

Findings from our 2023-2024 Supervision activities help to inform our overall supervision of the mortgage broker sector and the areas of focus for the 2024-2025 Supervision Plan.

Insufficient documentation of suitability assessments

Suitability assessments are an important part of the mortgage process since they help ensure that a consumer obtains a mortgage suitable for their individual needs and circumstances. Suitability assessments are particularly important to consumers seeking private mortgage financing, since these types of mortgages are often more costly and contain terms, features, and penalties that consumers may not readily understand.

FSRA found, across all mortgage brokerage exams, deficiencies in documentation to support the determination of mortgage product suitability. For example, in FSRA’s examinations^[10] of brokerages in 2023-2024, 81% of reviewed files had no documentary evidence that a borrower suitability assessment had been performed (as compared to 80% in 2022-2023 exams). Similarly, 65% of brokerages examined in 2023-2024 were found to have provided inadequate disclosure of material risks to borrowers (as compared to 53% of those brokerages examined in 2022-2023). Ensuring appropriate material risk disclosure, including documenting that a client is aware they should have an exit strategy when they are taking on a short term, higher cost private mortgage, is an essential part of establishing product suitability for a borrower. Failure to document how a broker or agent determined that the mortgage was suitable for their client also means that brokerages are unable to properly oversee their authorized licensees to ensure they are making suitable recommendations to their clients. Given the rising uncertainty in the economy, and that more Ontarians are seeking private mortgage products, it is more important than ever that brokerages ensure their agents and brokers are giving clients all the information they need to obtain a mortgage that is suitable for their needs and circumstances.

Inconsistent or missing disclosures to borrowers

Our exam findings also indicated that brokerages are not ensuring that borrowers receive the appropriate disclosures required during the mortgage process. Some of the issues we saw were unclear, absent, or incorrect disclosures of:

• cost of borrowing
• conflicts of interest
• fees payable by brokerage to others
• number of lenders represented by brokerage
• material risks
• lender’s name (not disclosed on commitment letter) with no process outlined for informing borrower

Failure to provide disclosures, providing inaccurate disclosures, or not providing disclosures within the required time during the mortgage process creates serious risks for consumers. Accurate and timely disclosures give consumers the information they need to make educated decisions about their mortgage products and to better understand why the recommended product is suitable to their needs.

Large brokerages – Inadequate supervision processes and internal controls

In addition to the deficiencies described above, FSRA’s large brokerage exam program revealed weaknesses in oversight and internal compliance controls. Most notably, these exams revealed a lack of understanding of the principal broker’s role and the brokerage’s responsibility to provide adequate oversight over their authorized agents and brokers through transaction monitoring.

Supervision processes in these brokerages demonstrated limited oversight of their functional teams and inconsistent delegation of compliance duties and responsibilities (formal or informal) to team leads. Delegation of compliance oversight is permissible under MBLAA but that delegation must be clearly outlined, consistent, and monitored by the principal broker.

Compliance controls in large brokerages were also found to be inadequate. 100% of the brokerages examined had validation procedures for file reviews that emphasized form over substance by checking primarily for the existence of a document within a file package, rather than an assessment of the quality/accuracy of the information contained in it or the suitability of the recommendation (e.g., confirming that a ‘suitability rationale’ has been provided, but no evaluation of whether the documentation in the file demonstrated that the product actually was suitable). Likewise, 100% of entities examined had the majority of file reviews being handled after mortgage transactions had closed, even for agents who are new to the brokerage and may need closer supervision during the course of their transactions. Reviewing files of inexperienced agents post-closing prevents the brokerage or its principal broker from being able to intercede in a transaction to prevent a poor consumer outcome (e.g., if a recommended product is unsuitable).

The large brokerages examined were also found to not be collecting and cross-referencing key information such as:

• Concurrent business of agents/brokers and the potential impact these business activities might have on independence and judgement. 0% of entities examined had policies or procedures to track an agent’s or broker’s concurrent business for conflicts of interest or other relationships that may be relevant to their mortgage brokering activities.
• number of complaints and/or complaint trends per team/individual

Staying informed of agents’ and brokers’ concurrent business activities and/or tracking how they may affect the potential for perceived or real conflicts of interest when dealing in mortgages is important information a brokerage should be aware of. Likewise, having a sound complaints review process with a view to detecting and correcting patterns of non-compliance is critical for brokerages and principal brokers in identifying consumer protection issues proactively and ensuring that their authorized licensees are complying with requirements under MBLAA, are exercising good judgement, and treating consumers fairly.

Inadequate mortgage administration agreements and monitoring of mortgage investments

Our exam findings related to administrators also revealed some key deficiencies. 50% of administrators examined were not providing ongoing monitoring of mortgage performance or prompt and complete notifications to investors of significant events (e.g., if the mortgage had subsequent encumbrances on title). Investors depend on administrators to provide the information they need on an ongoing basis to support informed decision making about their investments. Not providing this information creates investor protection risks.

Likewise in 50% of the cases, FSRA found that administrators did not have in place mortgage administration agreements, or if these agreements existed, they were inadequate and did not contain all the provisions required under MBLAA.

Taken as a whole, these findings, for both mortgage brokerages and mortgage administrators, in combination with the risks posed by the current economic environment, will play a significant role in informing our supervision approach for the coming year.

Elevated interest rates continue to affect mortgage affordability for Ontario consumers. Although the Bank of Canada began cutting its key interest rate in June 2024, with a 25 basis point cut to 4.75% followed by a further cut in July by another 25 basis points to 4.5%, housing prices remain high and mortgage affordability remains challenging. The Office of the Superintendent of Financial Institutions (OSFI) noted that, of the mortgages outstanding as of February 2024, 76% will be coming up for renewal by the end of 2026.^[11] In the context of lower mortgage affordability, coupled with inflationary pressures, record levels of household debt and potential housing market volatility, FSRA observes that Ontario consumers, particularly those who will need to renew their mortgages in the coming two years, will face greater financial pressures and are more vulnerable than ever before, especially in the event of an economic downturn.

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Source: BOC Financial Stability Report 2024

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Source: BOC Financial Stability Report 2024

CMHC’s Residential Mortgage Industry Report notes that for the first time since the beginning of the COVID-19 pandemic, mortgage delinquency rates are trending upward. Vulnerabilities first detected in credit card and auto loan markets are beginning to move into the mortgage market as well. This suggests the financial buffers built up during the pandemic are becoming exhausted for some households.^[12]

OSFI Superintendent Peter Routledge recently observed that many Canadians facing renewals may see their mortgage payments rise by between 15% and 30%.^[13] A subset of consumers who will need to renew, particularly those with variable rate mortgages with fixed payments, could see their mortgage payments increase by as much as 50%. These consumers may find it more difficult to cope with the strain this will create on their household finances.

Data on private lending trends and from FSRA’s Annual Information Return, indicate that private lending activity is still trending upward in terms of volumes and dollar amounts, even though the total number and value of mortgages brokered in 2023 dropped as compared to volumes and values from 2022. This means the trend of more consumers seeking private mortgages will continue this year. The increased utilization of generally more costly and less standardized mortgages (i.e., private, high-ratio and low-ranking mortgages) continues to raise consumer protection concerns for FSRA. Ensuring that these mortgages are suitable for borrowers based on their unique needs and circumstances, and whether borrowers understand the features and implications of holding these mortgages will be a consumer protection priority for FSRA in the current environment. Ensuring that borrowers are provided with accurate disclosure of the cost of borrowing, represented by the APR, for their mortgages will also be important to enable consumers to make educated decisions about their mortgage product options.

The challenges created by the current economic environment and the increased utilization of private mortgages mean that mortgage brokers and agents need to be more alert to their client’s interests. FSRA also expects brokerages and their principal brokers to give due attention and resources to providing adequate oversight, supervision, and training for their licensed individuals to ensure good outcomes for consumers.

Source: FSRA, Private Residential Mortgage Lending in Ontario Report 2023.

Current economic conditions pose risks for mortgage investors as well as borrowers. Developers continue to face high materials costs and labour shortages. Some segments of the market, like condominium developments, are encountering heightened challenges due to a continuing disconnect between the development costs, the market price of the resulting units, and what condo buyers are willing to pay for them. This disconnect is leading to a dramatic drop in unit pre-sales which in turn is causing stalls or failures of ongoing projects, thereby threatening the performance of the mortgage investments that back them.^[14] Investors rely on mortgage administrators to monitor their mortgage investments and provide timely notifications of any significant events that could impact the investment. Given the current environment, administrators properly performing these duties for investors is critical, now more than ever.

Taken together, these trends and developments suggest an intensification over the near term of some of the key consumer protection risks FSRA identified in 2022-2023. With higher levels of consumer financial vulnerability and more consumers obtaining private mortgages, the risk of consumers being placed in mortgages that could be unsuitable continues to be high. As well, with total mortgage volumes and dollar values contracting, competition within the mortgage broker sector is becoming more pronounced, which further increases FSRA’s concern about potential increased misconduct in the sector. FSRA’s supervision activities for 2024-2025 will respond directly to these risks to support better outcomes for consumers.

With housing prices remaining high and interest rates just beginning to moderate, FSRA remains concerned that consumers face elevated risks. Over the coming months consumers will continue to find it difficult to qualify for financing from a traditional financial institution, leading to many seeking mortgage financing from private lenders. Private mortgages are generally more costly and often contain terms and features that consumers may not be aware of or understand fully, which means it is critical that mortgage agents and brokers are able to provide competent advice to their clients to ensure they receive a mortgage that is suitable to their needs and circumstances.

Likewise, though labour and other input costs may begin to moderate in the near term,^[15] the disconnect between supply and demand within some segments of the housing market continues to create uncertainty for the performance of mortgage investments and raise concerns for developers and the investors who invest in their projects. Investments in residential mortgages may also face performance uncertainty in the coming year. Mortgage delinquencies and defaults are expected to continue trending upward as homeowners, particularly those who are more vulnerable, face higher housing costs when their mortgage renews. This strain will be compounded further by statistically higher consumer debt-loads overall and rising costs of living.^[16]

FSRA protects consumers through a continued supervision focus on private mortgage brokering and large brokerages for 2024-2025

FSRA will continue to intensify its supervision focus in 2024-2025 on:

• Private mortgage brokering practices – given the increased demand for these products, FSRA is focussed on ensuring borrowers have the protections and information they need when they are considering private mortgage products.
• Large brokerages – due to the high number of consumers they interact with, large brokerages have an outsized impact on the mortgage brokering sector and the customers they serve.

FSRA will do this by comprehensively assessing, through exams, whether brokerages are ensuring:

• adequate know-your-client processes
• adequate, accurate, and timely disclosure about mortgage features and material risks
• adequate and accurate disclosure of conflicts, or perceived conflicts, of interest and other relevant relationships
• appropriate documentation of mortgage product suitability
• for private mortgage borrowers, that there is adequate consideration of an exit strategy to ensure clients can transition back to more affordable financing
• adequate supervision of their brokers and agents

In addition to supervision, FSRA will continue to build out our consumer education content on private mortgages to support consumers who need to turn to private mortgages to finance their homes.

Since private mortgages are often more costly, come with a higher interest rate and often additional fees (lender, late payment, renewal, foreclosure fees), FSRA will also assess whether all fees are being disclosed fully and clearly in private mortgage transactions. As noted in the 2023-2024 Supervision Plan, we will be undertaking a compliance blitz in the 2024-2025 period focussing on whether licensees have been accurately calculating and disclosing the Annual Percentage Rate (APR) in mortgage transactions completed in the last 12 months prior to the blitz. FSRA will take action against any brokerages which exhibit systemic or material deficiencies in disclosing an accurate cost of borrowing.

As noted above, FSRA will soon finalize its proposed principal broker guidance which clarifies expectations for principal brokers and brokerages in ensuring the compliance of their agents and brokers to support fair treatment of consumers. Once finalized, FSRA will begin to supervise against this guidance in the 2024-2025 brokerage exam programs. This guidance has been informed by FSRA’s work in reviewing the conduct culture, compliance structure and principal broker’s supervision within large brokerages, which began at the end of fiscal year 2022-2023. FSRA will continue with this work in the 2024-2025 period. The objectives are to ensure all brokers and agents are conducting their activities with integrity and competence while ensuring brokerage clients receive mortgage recommendations that are suitable to their needs. These outcomes are supported by a strong conduct culture within the brokerage, where new agents and brokers are appropriately hired, trained and overseen.

In addition to these supervision activities, FSRA will host its inaugural mortgage brokering sector Principal Brokers’ Conference in November 2024 as a means of intensifying outreach to principal brokers, directors, officers, and owners of brokerages, to help educate the sector about FSRA’s expectations regarding the role of principal brokers and brokerages in supporting a strong conduct culture.

FSRA maintains its supervision focus on protecting investors

Given the economic conditions that continue to pose risk and uncertainty for mortgage investments, FSRA will extend its 2023-2024 examination of the distribution and handling of mortgage investments by our licensed firms. FSRA will take an end-to-end approach to reviewing practices from an investment’s point of sale to its subsequent maintenance, including the practices of licensed or unlicensed firms related to a licensed brokerage or a licensed administrator that provide services to clients during the life cycle of the investment. FSRA will be looking to see that licensees are providing investors with the required information they need at all points during the investment process to make informed decisions.

Our examinations will focus on and assess the following investor protection risks:

• failure to disclose conflicts of interest and as a best practice, manage those conflicts, when an administrator is related to the borrower of the mortgage they administer or to the brokerage that arranges the mortgage investment
• failure to establish a mortgage administration agreement or failure to act in accordance with that agreement
• mishandling or loss of funds from mortgage payments
• mishandling or loss of mortgage investments, when a mortgage is registered in a name in trust for the investor(s) or when an administrator has discretion over a mortgage
• inadequate monitoring of mortgage performance and inadequate reporting to investors

Mortgage administrators are required to submit audited financial statements, a management letter and an auditor’s reasonable assurance report on compliance to FSRA within 90 days of their fiscal year end. This financial filing is critical to ensure that the mortgage administrators are adequately handling the deemed trust funds under their administration. Using a risk-based approach, FSRA reviews these financial filings and contacts the mortgage administrators where clarifications are needed or concerns are noted.

FSRA expects to leverage and rely on the expertise of the auditors engaged by the mortgage administrators to provide assurance on their financial filings. It is important to FSRA that the auditors understand the regulatory requirements and expectations that their administrator clients should meet. To that effect, FSRA has been reaching out to auditors where specific auditing questions and clarifications on the financial filings are needed.

^[1] FSRA 2023 Annual Information Return (AIR)
^[2] Ibid.
^[3] Canadian Broadcast Company, “Bank of Canada holds key interest rate at 5% again, saying it’s still too soon for rate cuts”. March 6, 2024.
^[4] Canadian Mortgage Trends, “2023 Mortgage Market – Year in Review” , December 29, 2023.
^[5] Financial Services Regulatory Authority of Ontario, Private Residential Mortgage Lending in Ontario Annual Report, August 2024.
^[6] Financial Services Regulatory Authority of Ontario, Private Residential Mortgage Lending in Ontario Annual Report, August 2024 (pg. 6)
^[7] FSRA’s 2022 Consumer Research Study Executive Summary.
^[8] Ibid.
^[9] Ibid.
^[10] This data does not include examination findings for non-qualified syndicated mortgages.
^[11] The Office of the Superintendent of Financial Institutions, “OSFI’s Annual Risk Outlook – Fiscal Year 2024-2025”, May 22, 2024.
^[12] CMHC, Residential Mortgage Industry Report – Spring 2024. Pg. 7
^[13] Peter Routledge, Opening Remarks at House of Commons Standing Committee on Finance, June 11, 2024.
^[14] Benjamin Tal, CIBC Economics In Focus, “GTA Condo Investment: Challenging Times”, July 25, 2024.
^[15] Ibid.
^[16] Toronto Star, “Banks are expecting a wave of mortgage defaults: Economists say a credit crunch could hurt us all”, July 19, 2024