Mortgage Broker Reporting Requirements

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Regulatory Statement

Date: 25 June 2026
Regulatory Statement Number: 26-010
Distribution: Mortgage Services Act
Legislation: Mortgage Services Act

Purpose

This Regulatory Statement (Statement) provides the form and content requirements for mortgage brokerages licensed under the Mortgage Services Act (MSA) for the following reports:

Accountant’s Report;
Trust Account Declaration;
Financial Statements;
Brokerage Financial Information Filing; and/or
Periodic Activity Report.

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

Superintendent Authority to Require Reports and Statements

This Statement provides the reporting requirements for mortgage brokerages licensed under the MSA, pursuant to section 63(7) of the MSA and sections 83 to 86 of the Mortgage Services Rules (Rules). Section 63(7) of the MSA provides that the Rules may require brokerages to submit reports, including setting requirements related to the form and content of brokerage reports. Section 84 of the Rules provides that within 120 days after the brokerage’s fiscal year end, a brokerage that provides the services of administering or lending, or that maintains a trust account, must submit to the Superintendent:

Financial statements for that fiscal year; and
An accountant’s report for that fiscal year¹.

^{1 Or, as an alternative to an accountant’s report, a mortgage brokerage that did not hold or receive any trust money during the relevant fiscal year may file a solemn declaration (Trust Account Declaration) with the Superintendent instead.}

These reports must be completed in accordance with the Rules and this Regulatory Statement.

In addition to the above, Section 111(b) of the Rules provides that in instances where a brokerage ceases to carry on the business of a brokerage, that brokerage must also promptly submit a winding up report. More information on winding up a brokerage can be found on BCFSA’s Mortgage Services Knowledge Base.

For information on financial filing requirements for in-flight files that are active over the transition from the Mortgage Brokers Act to the MSA, see BCFSA’s Mortgage Services Knowledge Base.

Superintendent Authority to Review

As part of licensee’s regulatory obligations, a mortgage brokerage is required to permit the Superintendent of Mortgage Services (Superintendent) to examine its accounts and financial records, as well as any other records associated with the brokerage’s operations and those of its licensees. The authority to review these records includes the ability to conduct audits to ensure compliance with the MSA, Rules and Mortgage Services Regulation (Regulation).

Under s.83 of the Rules, the Superintendent has the authority to temporarily remove the brokerage’s accounts, financial records, and any other records associated with the brokerage’s operations and those of its licensees for the purpose of making copies. The Superintendent is then required to provide a receipt for any records that are taken.

Should a review reveal that a mortgage brokerage’s records are not properly maintained or up to date, the Superintendent has the authority to require the brokerage to cover all or part of the review costs. This requirement is subject to financial limits outlined in section 46(2) of the MSA and s.12 of the Regulation.

Requirements

Annual Financial Statements

Mortgage brokerages that provide the services of administering or lending, as well as licensees who maintain trust accounts, are required to submit annual financial statements for that fiscal year to the Superintendent. These reports must be filed within 120 days following the conclusion of each fiscal year of the mortgage brokerage.

For a mortgage brokerage that qualifies as a public company under the Business Corporations Act, these statements must be audited by an accountant. For other types of mortgage brokerages, the financial statements must undergo, at a minimum, a review engagement by an accountant or a compilation engagement report prepared by an accountant.

The Superintendent may permit a mortgage brokerage to file financial statements that have undergone a compilation engagement report by an accountant, provided certain conditions are met. These conditions include:

For a minimum of three consecutive fiscal years immediately before the authorization date, the brokerage must have filed financial statements that have been audited by an accountant (for a public company) or conducted a review engagement by an accountant.
There must have been no significant exceptions related to the trust account or general records reported or identified during any reviews within those three fiscal years.
The Superintendent must be satisfied that, at the end of each of those three fiscal years, the mortgage brokerage’s current assets exceeded its current liabilities.

An accountant who audits or reviews a brokerage’s financial statements or prepares a compilation engagement report in relation to those financial statements, must be independent from the brokerage, any related licensee and any controlling person or significant interest holder of the mortgage brokerage. The mortgage brokerage must disclose and provide certain information to this accountant, including every savings institution account that was opened, closed or maintained by the mortgage brokerage during the fiscal year; access to all financial and other records of the mortgage brokerage for the fiscal year; and any other information the accountant considers necessary to complete their work for the brokerage.

The Superintendent may withdraw a mortgage brokerage’s authorization to file financial statements that have been subject to a compilation engagement report prepared by an accountant under certain circumstances. These conditions include:

If the mortgage brokerage fails to submit financial statements that adhere to Rules requirements.
If there are any reported or discovered exceptions in the trust account or the general books and records related to the mortgage brokerage.
The Superintendent may withdraw authorization if, at the conclusion of any fiscal year, the mortgage brokerage’s current assets are deemed insufficient to cover its current liabilities.

Before withdrawing an authorization, the Superintendent is required to provide the mortgage brokerage with notice of the intended action and the specific reasons for it.

Accountant’s Report

Mortgage brokerages that provide the services of administering or lending, as well as licensees who maintain trust accounts, are required to submit an annual accountant’s report for that fiscal year to the Superintendent. This report must be filed within 120 days following the conclusion of each fiscal year of the mortgage brokerage or the licensee’s related mortgage brokerage.

An accountant who completes a brokerage’s Accountant’s Report must be independent from the brokerage, any related licensee, and any controlling person or significant interest holder of the mortgage brokerage. The mortgage brokerage must disclose and provide certain information to this accountant, including every savings institution account that was opened, closed or maintained by the mortgage brokerage during the fiscal year; access to all financial and other records of the mortgage brokerage for the fiscal year; and any other information the accountant considers necessary to complete their work for the brokerage.

After the brokerage completes the fiscal year, the brokerage must prepare an Accountant’s Report for the fiscal year containing the following information:

The legal name of the brokerage;
The start and end dates of the brokerage’s fiscal year in relation to which the report is filed;
All savings institution accounts opened, closed, or maintained by the brokerage during the fiscal year, including:
1. The name and branch location of the savings institution at which the account is or was kept,
2. The account number,
3. An indication of the type of account (mortgage brokerage trust, general, etc.),
4. If the account was opened or closed, or both, during the fiscal year, the date of the opening or closing, or both, as the case may be, and
5. Names of Authorized Signatories;
The address and type (head office, branch, etc.) of brokerages that operated at any time during that fiscal year;
A list of each brokerage trust account (if applicable), including:
1. The name and branch location of the savings institution at which the account is or was kept,
2. The account number,
3. An indication of the type of account,
4. If the account was opened or closed, or both, during the fiscal year, the date of the opening or closing, or both, as the case may be, and
5. Names of authorized signatories.

The brokerage must provide the report as described above to the accountant who is to complete the report in accordance with the information above.

In completing the Accountant’s Report, the accountant will select three months³ within the fiscal year, including the final month of the applicable fiscal year. These months (“selected months”) will be reported to BCFSA and used for the purpose of completing many of the procedures outlined in the Accountants Report. In completing the Accountant’s Report for the selected months, the reporting accountant must perform procedures and report findings that address, at a minimum, the following matters:

Whether the brokerage had any contingent liabilities at the end of the applicable fiscal year, and the details of any such contingent liabilities;
Whether the brokerage’s bank accounts are held with savings institutions located in B.C., and identification of any accounts that do not meet this requirement;
Whether the brokerage’s trust accounts are clearly designated as trust accounts, and identification of any accounts for which a trust designation is not evident; and
Whether each trust account has at least one authorized signatory who is a principal broker, and identification of any trust accounts that do not meet this requirement.

With respect to trust accounts, including pooled trust accounts, the reporting accountant must address, at a minimum, the following matters in the Accountant’s Report for each selected month:

Whether bank reconciliations were prepared for each trust account, including pooled trust accounts, for each selected month;
Whether bank reconciliations were prepared as of month‑end, reviewed by a principal broker or a person designated by the principal broker, and prepared within the required timeframe following month‑end⁴;
Whether trust account reconciliations identify outstanding disbursements dated at least six months before month‑end and outstanding deposits that did not clear in the subsequent month;
Whether trust account bank statements indicate that the account is held with a financial institution located in B.C., is designated as a trust account, and is maintained in the brokerage’s legal or trade name;
Whether ending balances shown on trust account bank statements correspond to the ending balances reported in the related bank reconciliations, and whether ending trust account ledger balances correspond to the trust asset balances reported in those reconciliations;
Whether trust account general ledgers (or individual trust ledgers, where applicable) were prepared and contain sufficient detail to clearly identify trust transactions;
Whether trust money was deposited and disbursed in accordance with the MSA, Regulation, and Rules, including requirements respecting the timing of deposits and the permitted use of trust funds; and
Whether any trust account had a negative balance during the selected months and, where a negative balance was not eliminated within the required timeframe, whether the brokerage provided the required notification to BCFSA.

With respect to pooled trust accounts, the reporting accountant must address, at a minimum, the following matters for each selected month:

Whether a trust liability and asset reconciliation was prepared for each pooled trust account;
Whether trust liability and asset reconciliations were prepared as of month‑end, include trust liability balances, were reviewed by a principal broker or a person designated by the principal broker, and were prepared no later than five weeks (35 days) after month‑end;
Whether total trust liability balances reported in the trust liability and asset reconciliation correspond to the trust asset balance reported in the related bank reconciliation;
Whether trust liability balances are clearly attributable to a specific mortgage, transaction, or client, and identification of any trust liability balances that lack sufficient reference;
Whether individual trust ledgers were prepared for pooled trust accounts and contain sufficient detail to clearly identify trust transactions;
Whether ending balances in individual trust ledgers correspond to the related trust liability balances; and
Whether pooled trust account records, including trust liability and asset reconciliations and individual trust ledgers, reflect any negative balances during the selected months and, where a negative balance was not eliminated within the required timeframe, whether the brokerage provided the required notification to BCFSA.

With respect to general (non‑trust) bank accounts, the reporting accountant must address, at a minimum, the following matters for each selected month:

Whether bank reconciliations were prepared for each general bank account;
Whether bank reconciliations were prepared as of month‑end and were prepared no later than five weeks (35 days) after month‑end;
Whether bank reconciliations identify outstanding disbursements dated at least six months before month‑end and outstanding deposits that did not clear in the subsequent month;
Whether general ledgers were prepared for general bank accounts and contain sufficient detail to clearly identify transactions;
Whether ending general ledger balances correspond to the book balances reported in the related bank reconciliations; and
Whether deposits recorded in general bank accounts include any amounts that meet the definition of “trust money,” and identification of any such amounts.

After the accountant has completed the accountant’s portion and returned the report to the brokerage, the brokerage must have the report certified in accordance with the below requirements, as follows:

In the case of a brokerage that is a sole proprietorship,
1. By the sole proprietor, if the sole proprietor is acting as a principal broker for the brokerage, or
2. In any other case, by both a principal broker and the sole proprietor;
In the case of a brokerage that is a partnership, by both a principal broker and a partner of the brokerage; or
In the case of a brokerage that is a corporation, by both a principal broker and a director or officer of the brokerage.

The certification above must be, subject to any noted exceptions, that:

All books, records, accounts, and subordination agreements of the brokerage, together with any correspondence between the brokerage and BCFSA relating to the applicable fiscal year in respect of those books, records, accounts, and subordination agreements, have been disclosed to the reporting accountant;
The individual(s) providing the certification have reviewed the Accountant’s Report and, to the best of their knowledge, believe the report to be true and complete;
The individual(s) providing the certification have reviewed the Accountant’s Report completed by the reporting accountant, understand the documented findings, and have addressed any exceptions or qualifications by way of an accompanying written submission to BCFSA, where applicable;
There have been no changes in capital structure, directors, officers, shareholders, partners, or accountants of the brokerage since the date of the previous Accountant’s Report filed; and
To the knowledge of the individual(s) providing the certification, the report is true, complete and in accordance with the Rules and this Regulatory Statement.

^{3 The selected months should, whenever possible, be representative of the operations of the brokerage during the year and must include a transaction. If there is only one month with a deposit, that month should be selected, even if there were no disbursements in that month.}
^{4 The reconciliation mut be prepared within 5 weeks (35 days) after month end.}

Solemn Declaration (Trust Account Declaration)

As an alternative to submitting an Accountant’s Report, a mortgage brokerage that did not hold or receive any trust money during the relevant fiscal year may choose to file a solemn declaration with the Superintendent. This declaration must comply with any requirements set forth by the Superintendent and should pertain to the entire fiscal year or, if the brokerage carried on business only for a portion of the fiscal year, the part of the year during which the brokerage was in business.

A solemn declaration filed by a brokerage with the Superintendent under Section 84 (8) of the Rules must:

Be made by a principal broker of the brokerage on oath or by solemn declaration;
Be made before a commissioner for taking affidavits for Canada;
Be in a form approved by the Superintendent;
Be signed by the principal broker and the person before whom the declaration is made;
Include the information and statements required by the Rules and this Statement; and
Be submitted to the Superintendent together with the brokerage financial information filings and the financial statements for the applicable fiscal year.

The declaration must contain, or have attached to it, the following:

The name of the brokerage;
The name of the principal broker making the declaration;
The end date of the brokerage’s fiscal year to which the declaration relates, or a statement that the declaration relates only to the portion of the fiscal year during which the brokerage carried on business;
A list of all bank accounts maintained by the brokerage during the fiscal year, including trust and general accounts; and
For each account listed,
1. The name and branch location of the savings institution at which the account is or was maintained,
2. The account number,
3. The type of account, and
4. If the account was opened or closed, or both, during the fiscal year, the date of the opening or closing, as applicable.

The declaration must also state that:

The brokerage did not hold or receive any trust money during the fiscal year (or portion of the fiscal year) to which the declaration relates;
The principal broker has read and understands section 84(8) of the Rules; and
To the knowledge of the principal broker, all information and statements contained in the declaration are true and complete.

Brokerage Winding Up Report

When a mortgage brokerage ceases carrying on business and begins winding up, it must undertake several important steps to ensure proper closure. In addition to promptly surrendering all licenses, including those of related licensees, to the Superintendent, the brokerage must promptly submit a winding-up report to the Superintendent, completed in accordance with the below specified requirements. Upon request by the Superintendent, the brokerage must also provide annual financial reports and periodic mortgage brokerage activity reports. The Superintendent may also request any other financial records or further information regarding the brokerage’s business activities.

The brokerage winding-up report must contain, or have attached to it, the following:

The legal name of the brokerage;
The address of the brokerage head office and any branch offices;
The name of the brokerage’s principal broker(s);
The reason for the winding up;
The effective date on which the brokerage will cease to carry on the business of mortgage services;
Information relating to each of the brokerage’s trust accounts (where applicable), including for each account:
1. The name of the savings institution, and the location of the branch, with which the account is held,
2. The account number,
3. The type of trust account,
4. The account balance, and
5. Written confirmation, or a copy of the trust account statements, from the relevant savings institution verifying that the trust account balances;
Particulars of the brokerage’s trust accounts, including:
1. For mortgage services, a list of all transactions in relation to which the brokerage holds money in a trust account, including:
  1. the date,
  2. file reference number,
  3. applicant names,
  4. mortgage amount,
  5. address of the subject property, and
  6. the lender.
2. For remuneration held either in a brokerage trust account, or anticipated to be received:
  1. The names of all licensees on whose behalf the remuneration is being held or is anticipated to be received;
  2. The amount for each such licensee; and
  3. The expected date of pay out;
3. Any unclaimed amounts held in a trust account; and
4. A certification of a principal broker, director, officer, partner, or sole proprietor of the brokerage in accordance with the certifying individual requirements below.

All mortgage brokerage records under Part 7, Divisions 1 and 2 of the Mortgage Services Rules must be kept for seven (7) years after their creation or after the last transaction, depending on the type of record. When winding up a brokerage, these records must be kept by another brokerage, a lawyer, accountant or notary public, or another person acceptable to BCFSA. For the purposes of identifying the location of the brokerage’s records, the following information is required:

The name of the brokerage or other person responsible for maintaining the brokerage’s records;
Where the records are maintained by a person other than the brokerage, the occupation of that person;
The full address at which the brokerage’s records are kept;
A telephone number for the person or entity maintaining the brokerage’s records; and
An email address for the person or entity maintaining the brokerage’s records.

For the purposes of a certification of the brokerage, the certifying individual must certify the following:

The brokerage has ceased or will cease to carry on the business of the brokerage on the effective date indicated;
The brokerage has provided written notice to all related licensees that:
1. the brokerage has ceased or will cease to carry on the business of the brokerage, and
2. the licences of those licensees will become inoperative at that time, but may be reinstated in accordance with the Rules and any applicable regulatory statements;
The licence of the brokerage and the licences of all related licensees that are displayed or otherwise held by the brokerage have been or will be immediately taken down and destroyed, and any electronic versions deleted, in accordance with the Rules;
The certifying individual, as trustee of the brokerage’s trust accounts:
1. will be responsible for paying out all amounts held in trust, and
2. will immediately notify the Superintendent as each trust account balance reaches zero, other than in respect of unclaimed trust monies;
The certifying individual acknowledges that BCFSA may require the brokerage to submit one or more financial statements or reports under the Rules, or any other information relating to the business and financial records of the brokerage;
The certifying individual has arranged for the brokerage’s records to be retained in accordance with the Act, Regulation, Rules, and applicable regulatory statements;
The certifying individual has ensured that any mortgage files that are not yet completed have been or will be transferred to a mortgage brokerage that is appropriately licensed to conduct the relevant mortgage services, in compliance with the Act and Rules; and
To the best of the certifying individual’s knowledge, all information and statements contained in the report and any attachments are true and complete.

Periodic Activity Report

A mortgage brokerage is required to file a mortgage brokerage activity report with the Superintendent at intervals specified by the Superintendent. This report must be completed in accordance with any requirements set forth by the Superintendent. The Superintendent will issue an advisory to principal brokers if and when a periodic activity report is requested.

Definitions

Accountant: a person who is:

a member of a provincial organization of chartered professional accountants within Canada who is authorized by that organization to perform an audit,
a professional accounting corporation, as defined in the Chartered Professional Accountants Act, that is authorized by the Chartered Professional Accountants of British Columbia to perform an audit, or
a registered firm, as defined in the Chartered Professional Accountants Act, that is authorized by the Chartered Professional Accountants of British Columbia to perform an audit, or
in relation to a mortgage brokerage that is a reporting issuer within the meaning of the Securities Act, a person referred to above or a person who is authorized under the Securities Act to sign an auditor’s report.

Legislation

MSA s. 63(7)
MSA Rules ss. 83 to 86; 111
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.