What does the deposit rule mean for brokers?
FSRA states that from April 29 to June 1, ZK Financial took on a borrower while Lin was unlicensed and the brokerage was under suspension. The notice refers to the borrower only as ZY and mentions that the brokerage was working on arranging a mortgage between $100,000 and $280,000.
According to the notice, Lin collected a $2,000 deposit for his services but later refused to give it back. Ontario Regulation 188/08 prevents brokerages from asking for advance payments on mortgages of $400,000 or less.
FSRA also claims that during the suspension, ZK Financial’s website and listings on 51. ca suggested it was facilitating a large number of mortgages, which went against its 2025 AIR.
The regulator has made this clear before. “Licensees must not facilitate activities for unlicensed individuals,” stated Elissa Sinha, FSRA’s director of litigation and enforcement, when the regulator revoked Expert Financial Corporation’s brokerage license.
At Mortgage Fest Canada 2026 in Toronto this September, Joe White, founder and CEO of the Real Estate and Mortgage Institute of Canada (REMIC), argued that having a license is essential protection for clients.
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