Regulatory Statement

Purpose

This Regulatory Statement (Statement) provides the required form and content for disclosures to borrowers of expected remuneration as well as information on disclosures of remuneration to clients, as provided under the Mortgage Services Act (MSA), Mortgage Services Regulation (Regulation), and Mortgage Services Rules (Rules).  

This Statement comes into effect on October 13, 2026, and repeals all regulatory statements related to this topic under the previous Mortgage Brokers Act.

Background information

There are two different types of remuneration disclosure required under the Rules:

1. Disclosure to Client of Remuneration (s. 71).
2. Disclosure to Borrower of Expected Remuneration (s. 72).

Under s. 71 of the Rules, licensees must promptly disclose to their client all remuneration they receive, or anticipate receiving, from anyone other than their client. While this disclosure is not required to be made in a prescribed form, BCFSA has developed an optional form that mortgage brokers can use to make the required disclosure (Form 7: Disclosure to Client of Remuneration [Form 7]) and has also integrated the disclosure into several disclosure packages to assist brokers.

Under s. 72(2) of the Rules, the disclosure to a borrower of expected remuneration must be completed in a form approved by the Superintendent of Mortgage Services (Superintendent). This Statement establishes the form and content of that required disclosure.

Both remuneration disclosures noted above require licensees to disclose direct and indirect remuneration. If the remuneration referred to above is to be received as money, the remuneration must be expressed as a dollar amount. If the broker does not know the exact amount of remuneration they or their brokerage might receive, they must give their client and/or the borrower an estimate or explain how it will be calculated. If the remuneration is not money, the broker must describe the benefit.

For additional information on required disclosures, visit the Mortgage Services Knowledge Base.

Requirements – Disclosure to borrower of expected remuneration

When a mortgage broker presents a borrower with one or more potential mortgage commitments, they must disclose to the borrower what remuneration they expect to receive if the borrower chooses that option using Form 4 – Disclosure to Borrower of Expected Remuneration (Form 4). Licensees may also choose to provide disclosure of interests in a Forms Package #1: Disclosure to Represented Borrowers or a Forms Package #3: Disclosure to Unrepresented Borrowers, as appropriate in the circumstances. For more information on Forms Packages, please see the Disclosures: Representation and Form Packages Regulatory Statement.   

Form 4 is required any time a licensee presents a potential mortgage commitment to a borrower, whether they are a client or an unrepresented borrower. If a licensee provides the full disclosure forms package when they present mortgage/mortgage transaction options to the borrower or the lender, the licensee will meet the disclosure timelines set out in the Rules, noting the exceptions stated in the Disclosures: Representation and Form Packages Regulatory Statement. 

Whichever option is selected (i.e., Form 4 or an appropriate forms package) it is important to note that the disclosure must occur, without exception.

Definitions

Client: means, in relation to a licensee, the person who has engaged the licensee to provide one or more of the following mortgage services to or on behalf of the person: (a) dealing in mortgages; (b) trading in mortgages; (c) administering mortgages.

Remuneration: includes any form of remuneration, including any commission, fee, gain or reward, whether the remuneration is received, or is to be received, directly or indirectly.

Designated agent: means one or more licensees designated by their mortgage brokerage as the exclusive licensee or licensees, of all of the licensees related to that brokerage, to provide mortgage services to a client of the brokerage in respect of a potential mortgage or mortgage transaction.

Approved disclosure

The table below provides the title, form number, and approved version of each disclosure of conflict of interest required under the Mortgage Services Rules. A version history can be found in the Appendix.

Form # and title	Approved form version and effective date	Applicable rules
Form 4 – Disclosure to Borrower of Expected Remuneration	V1.0 October 13, 2026	s.72

​​​Legislation

MSA Rules ss. 70 and 71

Copies of the legislation are available from www.bclaws.gov.bc.ca

Additional Information

For inquires on conflicts of interest and disclosures, please email msa@bcfsa.ca.

Appendix – version history

Form 4 – Disclosure to Borrower of Expected Remuneration

Version	Effective date range	Description/summary of changes
1.0	Effective as of October 13, 2026	Initial version