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MORTGAGE BROKER CONFLICT OF INTEREST DISCLOSURE GUIDELINES - UPDATE Office of the Registrar of Mortgage Brokers 1

Mortgage Broker Conflict of Interest DISCLOSURE Guidelines · 2017. 9. 1. · MORTGAGE BROKER CONFLICT OF INTEREST DISCLOSURE GUIDELINES - UPDATE Office of the Registrar of Mortgage

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Page 1: Mortgage Broker Conflict of Interest DISCLOSURE Guidelines · 2017. 9. 1. · MORTGAGE BROKER CONFLICT OF INTEREST DISCLOSURE GUIDELINES - UPDATE Office of the Registrar of Mortgage

MORTGAGE BROKER CONFLICT OF INTEREST DISCLOSURE

GUIDELINES - UPDATE

Office of the Registrar of Mortgage Brokers

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Page 2: Mortgage Broker Conflict of Interest DISCLOSURE Guidelines · 2017. 9. 1. · MORTGAGE BROKER CONFLICT OF INTEREST DISCLOSURE GUIDELINES - UPDATE Office of the Registrar of Mortgage

1. Introduction 2. Approach to enforcement 3. Principles based regulation4. What the law says5. Interests in transactions - examples6. FAQs – how it works7. Conclusion and questions

Overview

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Page 3: Mortgage Broker Conflict of Interest DISCLOSURE Guidelines · 2017. 9. 1. · MORTGAGE BROKER CONFLICT OF INTEREST DISCLOSURE GUIDELINES - UPDATE Office of the Registrar of Mortgage

INTRODUCTION

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Page 4: Mortgage Broker Conflict of Interest DISCLOSURE Guidelines · 2017. 9. 1. · MORTGAGE BROKER CONFLICT OF INTEREST DISCLOSURE GUIDELINES - UPDATE Office of the Registrar of Mortgage

• Update – Effective May 25, 2017• Replaces all earlier presentations• This presentation is focused on helping you

understand the requirements• This is the law; its now being fully enforced• Principles based Guidelines and FAQs

published on FICOM website• Questions – please save for the end

INTRODUCTION

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Page 5: Mortgage Broker Conflict of Interest DISCLOSURE Guidelines · 2017. 9. 1. · MORTGAGE BROKER CONFLICT OF INTEREST DISCLOSURE GUIDELINES - UPDATE Office of the Registrar of Mortgage

• Escalation approach:– Learning curve, natural uncertainty– Informal: education, guidance, cautions,

adjustment– Formal: notice of hearing, orders, penalties– Good faith and reasonableness

ENFORCEMENT

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Page 6: Mortgage Broker Conflict of Interest DISCLOSURE Guidelines · 2017. 9. 1. · MORTGAGE BROKER CONFLICT OF INTEREST DISCLOSURE GUIDELINES - UPDATE Office of the Registrar of Mortgage

PRINCIPLES BASED GUIDELINES

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Page 7: Mortgage Broker Conflict of Interest DISCLOSURE Guidelines · 2017. 9. 1. · MORTGAGE BROKER CONFLICT OF INTEREST DISCLOSURE GUIDELINES - UPDATE Office of the Registrar of Mortgage

• Law is not prescriptive• Allows for flexibility • Registrar will review disclosures by applying

principles• Test your own methods of disclosure against

the principles

PRINCIPLES BASED GUIDELINES

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Page 8: Mortgage Broker Conflict of Interest DISCLOSURE Guidelines · 2017. 9. 1. · MORTGAGE BROKER CONFLICT OF INTEREST DISCLOSURE GUIDELINES - UPDATE Office of the Registrar of Mortgage

• Three key principles:1. Clear and understandable2. Comprehensive, complete and accurate3. Meaningful to users

PRINCIPLES BASED GUIDELINES

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Page 9: Mortgage Broker Conflict of Interest DISCLOSURE Guidelines · 2017. 9. 1. · MORTGAGE BROKER CONFLICT OF INTEREST DISCLOSURE GUIDELINES - UPDATE Office of the Registrar of Mortgage

WHAT THE LAW SAYS

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Page 10: Mortgage Broker Conflict of Interest DISCLOSURE Guidelines · 2017. 9. 1. · MORTGAGE BROKER CONFLICT OF INTEREST DISCLOSURE GUIDELINES - UPDATE Office of the Registrar of Mortgage

• Mortgage Brokers Act and Regulations• Sections 17.3 and 17.4• Conflicts of interest arise by virtue of being an

independent “middle person” in deals• Transparency to both borrowers and lenders• Use the Form 10 as prescribed in Regulations

WHAT THE LAW SAYS

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Page 11: Mortgage Broker Conflict of Interest DISCLOSURE Guidelines · 2017. 9. 1. · MORTGAGE BROKER CONFLICT OF INTEREST DISCLOSURE GUIDELINES - UPDATE Office of the Registrar of Mortgage

• “Mortgage Broker” is the brokerage firm acting in the transaction

• “Submortgage broker” is an individual who is employed by a mortgage broker / brokerage, acting in a transaction

• Both the registered Mortgage Broker / Brokerage and the Submortgage Broker are responsible for providing Form 10 disclosure

WHAT THE LAW SAYS

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Page 12: Mortgage Broker Conflict of Interest DISCLOSURE Guidelines · 2017. 9. 1. · MORTGAGE BROKER CONFLICT OF INTEREST DISCLOSURE GUIDELINES - UPDATE Office of the Registrar of Mortgage

• If:– A mortgage broker / brokerage:

• Acts in a transaction• As an independent “middle person” • Arranges a mortgage between a borrower and a lender

WHAT THE LAW SAYS

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Page 13: Mortgage Broker Conflict of Interest DISCLOSURE Guidelines · 2017. 9. 1. · MORTGAGE BROKER CONFLICT OF INTEREST DISCLOSURE GUIDELINES - UPDATE Office of the Registrar of Mortgage

• And where:– Mortgage broker / brokerage– Associates of the mortgage broker / brokerage

• Includes submortgage brokers

– Related parties of the mortgage broker / brokerage

WHAT THE LAW SAYS

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Page 14: Mortgage Broker Conflict of Interest DISCLOSURE Guidelines · 2017. 9. 1. · MORTGAGE BROKER CONFLICT OF INTEREST DISCLOSURE GUIDELINES - UPDATE Office of the Registrar of Mortgage

• Will acquire• May acquire • Direct interests (benefits)• Indirect interests (benefits)

WHAT THE LAW SAYS

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Page 15: Mortgage Broker Conflict of Interest DISCLOSURE Guidelines · 2017. 9. 1. · MORTGAGE BROKER CONFLICT OF INTEREST DISCLOSURE GUIDELINES - UPDATE Office of the Registrar of Mortgage

• Then:– Mortgage broker / brokerage and submortgage

broker is required to describe these interests (benefits)

– To borrowers – To lenders– In the Prescribed Form 10

WHAT THE LAW SAYS

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Page 16: Mortgage Broker Conflict of Interest DISCLOSURE Guidelines · 2017. 9. 1. · MORTGAGE BROKER CONFLICT OF INTEREST DISCLOSURE GUIDELINES - UPDATE Office of the Registrar of Mortgage

• Who are “Associates” and “Related Parties” of the mortgage broker / brokerage?

WHAT THE LAW SAYS

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Page 17: Mortgage Broker Conflict of Interest DISCLOSURE Guidelines · 2017. 9. 1. · MORTGAGE BROKER CONFLICT OF INTEREST DISCLOSURE GUIDELINES - UPDATE Office of the Registrar of Mortgage

“Associate” includes, but is not limited to:• submortgage broker employed by the mortgage

broker / brokerage• Business partners • Corporations owned by the mortgage broker /

brokerage or submortgage broker• A relative, including a spouse

WHAT THE LAW SAYS

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Page 18: Mortgage Broker Conflict of Interest DISCLOSURE Guidelines · 2017. 9. 1. · MORTGAGE BROKER CONFLICT OF INTEREST DISCLOSURE GUIDELINES - UPDATE Office of the Registrar of Mortgage

“Related party” includes, but is not limited to:• Parties that influence the mortgage broker • Parties that the mortgage broker influences• Parties that, together with the mortgage broker,

influence a third party• Parties that, together with the mortgage broker,

are influenced by a third party

WHAT THE LAW SAYS

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Page 19: Mortgage Broker Conflict of Interest DISCLOSURE Guidelines · 2017. 9. 1. · MORTGAGE BROKER CONFLICT OF INTEREST DISCLOSURE GUIDELINES - UPDATE Office of the Registrar of Mortgage

• Timing of disclosure:– Section 14 of the Regulations

• To borrowers:– Earliest opportune time– No later than before the borrower signs anything that

commits the borrower to the transaction

• To lenders:– Before lender directs that any funds in a trust are released– Before funds advanced by lender

WHAT THE LAW SAYS

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Page 20: Mortgage Broker Conflict of Interest DISCLOSURE Guidelines · 2017. 9. 1. · MORTGAGE BROKER CONFLICT OF INTEREST DISCLOSURE GUIDELINES - UPDATE Office of the Registrar of Mortgage

INTERESTS

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Page 21: Mortgage Broker Conflict of Interest DISCLOSURE Guidelines · 2017. 9. 1. · MORTGAGE BROKER CONFLICT OF INTEREST DISCLOSURE GUIDELINES - UPDATE Office of the Registrar of Mortgage

DIRECT INTERESTS INDIRECT INTERESTS

WILL ACQUIRE • Benefits that arise from a transaction

• Known at time of transaction

• e.g. Base commission

• Contingent on something else

• Deal contributes to a benefit

• e.g. volume bonus already earned

MAY ACQUIRE • Future• ?

• Future Benefits• Contingent on

something else• e.g. Potential volume

bonus if hit target in future

INTERESTS

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Page 22: Mortgage Broker Conflict of Interest DISCLOSURE Guidelines · 2017. 9. 1. · MORTGAGE BROKER CONFLICT OF INTEREST DISCLOSURE GUIDELINES - UPDATE Office of the Registrar of Mortgage

• Direct interests – examples:– Base commissions – Known volume or efficiency bonuses – Monetary value of loyalty or rewards points– A mortgage broker or family member is the lender

or has ownership interests in the lender or is a part of a syndicate lender

INTERESTS

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Page 23: Mortgage Broker Conflict of Interest DISCLOSURE Guidelines · 2017. 9. 1. · MORTGAGE BROKER CONFLICT OF INTEREST DISCLOSURE GUIDELINES - UPDATE Office of the Registrar of Mortgage

• Direct interests – examples:– A family member or business partner of the

mortgage broker is the borrower – The mortgage broker receives a fee from the

borrower

INTERESTS

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Page 24: Mortgage Broker Conflict of Interest DISCLOSURE Guidelines · 2017. 9. 1. · MORTGAGE BROKER CONFLICT OF INTEREST DISCLOSURE GUIDELINES - UPDATE Office of the Registrar of Mortgage

• Indirect interests – examples:– Expected trailer fees at renewal– Potential volume or efficiency-based bonuses– Aggregated volume-based compensation paid by a

lender to the mortgage broker firm or a “related party” or “associate” of the registered mortgage broker / brokerage

INTERESTS

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Page 25: Mortgage Broker Conflict of Interest DISCLOSURE Guidelines · 2017. 9. 1. · MORTGAGE BROKER CONFLICT OF INTEREST DISCLOSURE GUIDELINES - UPDATE Office of the Registrar of Mortgage

• Indirect interests – examples:– Fees paid by a lender to a network, franchise or

mortgage broker related to mortgage transactions being directed to that lender, where that entity is a “related party” of the registered mortgage broker / brokerage

– E.g. “access fees”

INTERESTS

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Page 26: Mortgage Broker Conflict of Interest DISCLOSURE Guidelines · 2017. 9. 1. · MORTGAGE BROKER CONFLICT OF INTEREST DISCLOSURE GUIDELINES - UPDATE Office of the Registrar of Mortgage

• Indirect interests – examples:– Benefits mortgage brokers receive based on

achieving targets with a “preferred” lender of the firm, franchise / network

– Any benefit arising from achieving a certain status or designation with a lender

– Beneficial ownership interests the broker has in the lender or the borrower

• More than 10% of voting shares

INTERESTS

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Page 27: Mortgage Broker Conflict of Interest DISCLOSURE Guidelines · 2017. 9. 1. · MORTGAGE BROKER CONFLICT OF INTEREST DISCLOSURE GUIDELINES - UPDATE Office of the Registrar of Mortgage

FAQS – HOW IT WORKS

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Page 28: Mortgage Broker Conflict of Interest DISCLOSURE Guidelines · 2017. 9. 1. · MORTGAGE BROKER CONFLICT OF INTEREST DISCLOSURE GUIDELINES - UPDATE Office of the Registrar of Mortgage

• What version of the Form 10 should I use?– As of July 1, 2017, only the Prescribed Form 10 – Enhanced Form 10 and Form 11 discontinued– Industry and IT vendors are free to create their

own electronic forms, with drop down menus etc., provided they exactly match the content of the Prescribed Form 10

FAQs – HOW IT WORKS

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Page 29: Mortgage Broker Conflict of Interest DISCLOSURE Guidelines · 2017. 9. 1. · MORTGAGE BROKER CONFLICT OF INTEREST DISCLOSURE GUIDELINES - UPDATE Office of the Registrar of Mortgage

• Do commission splits between the mortgage broker / brokerage and the submortgage broker need to be described, or just the total amount of compensation to be received by the mortgage broker / brokerage?

FAQs – HOW IT WORKS

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Page 30: Mortgage Broker Conflict of Interest DISCLOSURE Guidelines · 2017. 9. 1. · MORTGAGE BROKER CONFLICT OF INTEREST DISCLOSURE GUIDELINES - UPDATE Office of the Registrar of Mortgage

• The amount each party receives needs to be described

• The Registrar will accept:– Total compensation to mortgage broker/brokerage

expressed as a dollar amount– Splits between mortgage broker/brokerage and

submortgage broker expressed as a percentage

FAQs – HOW IT WORKS

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Page 31: Mortgage Broker Conflict of Interest DISCLOSURE Guidelines · 2017. 9. 1. · MORTGAGE BROKER CONFLICT OF INTEREST DISCLOSURE GUIDELINES - UPDATE Office of the Registrar of Mortgage

• If a deal is co-brokered with two different mortgage broker firms involved, can a single Form 10 be provided on behalf of both brokerages? – Yes, but…

FAQs – HOW IT WORKS

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Page 32: Mortgage Broker Conflict of Interest DISCLOSURE Guidelines · 2017. 9. 1. · MORTGAGE BROKER CONFLICT OF INTEREST DISCLOSURE GUIDELINES - UPDATE Office of the Registrar of Mortgage

• Each participant is individually responsible regardless of who provides it

• Needs to provide complete disclosure of the interests pertaining to each participating mortgage broker/brokerage, submortgage broker and any other associates or related parties

FAQs – HOW IT WORKS

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Page 33: Mortgage Broker Conflict of Interest DISCLOSURE Guidelines · 2017. 9. 1. · MORTGAGE BROKER CONFLICT OF INTEREST DISCLOSURE GUIDELINES - UPDATE Office of the Registrar of Mortgage

• I have registered my personal corporation (PC) as a mortgage broker and my commission split is paid directly to my PC rather than to myself. How do I provide Form 10 disclosure?

FAQs – HOW IT WORKS

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Page 34: Mortgage Broker Conflict of Interest DISCLOSURE Guidelines · 2017. 9. 1. · MORTGAGE BROKER CONFLICT OF INTEREST DISCLOSURE GUIDELINES - UPDATE Office of the Registrar of Mortgage

• Similar to a co-brokering situation• Two “mortgage brokers” are now acting in the

transaction:– The main mortgage broker / brokerage of record

with the lender– The PC mortgage broker / brokerage dealing with

the borrower

• Same requirements as for co-brokering

FAQs – HOW IT WORKS

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Page 35: Mortgage Broker Conflict of Interest DISCLOSURE Guidelines · 2017. 9. 1. · MORTGAGE BROKER CONFLICT OF INTEREST DISCLOSURE GUIDELINES - UPDATE Office of the Registrar of Mortgage

• A lender provides me with a large marketing allowance, or pays for my expenses, or provides other benefits in addition to base compensation and volume bonus. Are these types of benefits considered to be “interests” in the transaction that need to be included in Form 10 disclosure to borrowers?

FAQs – HOW IT WORKS

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Page 36: Mortgage Broker Conflict of Interest DISCLOSURE Guidelines · 2017. 9. 1. · MORTGAGE BROKER CONFLICT OF INTEREST DISCLOSURE GUIDELINES - UPDATE Office of the Registrar of Mortgage

• Yes• Indirect interest (benefit) acquired from

sending mortgage deals with that lender • Each deal contributes to obtaining that

interest (benefit)• One-off small perks not anticipated by the

broker are not a concern• Substantial benefits will attract our interest

FAQs – HOW IT WORKS

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Page 37: Mortgage Broker Conflict of Interest DISCLOSURE Guidelines · 2017. 9. 1. · MORTGAGE BROKER CONFLICT OF INTEREST DISCLOSURE GUIDELINES - UPDATE Office of the Registrar of Mortgage

• How do I describe compensation for a particular transaction when a submortgage broker who acts in a transaction is paid a salary by the mortgage broker / brokerage?

FAQs – HOW IT WORKS

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Page 38: Mortgage Broker Conflict of Interest DISCLOSURE Guidelines · 2017. 9. 1. · MORTGAGE BROKER CONFLICT OF INTEREST DISCLOSURE GUIDELINES - UPDATE Office of the Registrar of Mortgage

• A salary paid to a submortgage broker is not an “interest in the transaction,” and does not need to be described

• Just describe total compensation paid to mortgage broker / brokerage

FAQs – HOW IT WORKS

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Page 39: Mortgage Broker Conflict of Interest DISCLOSURE Guidelines · 2017. 9. 1. · MORTGAGE BROKER CONFLICT OF INTEREST DISCLOSURE GUIDELINES - UPDATE Office of the Registrar of Mortgage

• May I provide borrowers a document to explain the costs I incur in running my business when I provide borrowers with the Form 10?

– Yes, but…

FAQs - HOW IT WORKS

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Page 40: Mortgage Broker Conflict of Interest DISCLOSURE Guidelines · 2017. 9. 1. · MORTGAGE BROKER CONFLICT OF INTEREST DISCLOSURE GUIDELINES - UPDATE Office of the Registrar of Mortgage

• Must be clear to users that:– Separate and distinct from Form 10– Not a regulatory requirement – Not endorsed by the Registrar

FAQs – HOW IT WORKS

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Page 41: Mortgage Broker Conflict of Interest DISCLOSURE Guidelines · 2017. 9. 1. · MORTGAGE BROKER CONFLICT OF INTEREST DISCLOSURE GUIDELINES - UPDATE Office of the Registrar of Mortgage

• What if mortgage brokers / brokerages, or firms, have contracts with lenders that contain confidentiality provisions preventing disclosure of compensation information?

FAQs – HOW IT WORKS

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Page 42: Mortgage Broker Conflict of Interest DISCLOSURE Guidelines · 2017. 9. 1. · MORTGAGE BROKER CONFLICT OF INTEREST DISCLOSURE GUIDELINES - UPDATE Office of the Registrar of Mortgage

• The Mortgage Brokers Act requires that registered mortgage brokers / brokerages describe interests, including those of “related parties” and “associates”

• The Registrar expects that registrants will make necessary business adjustments to enable full compliance with the law

FAQs – HOW IT WORKS

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Page 43: Mortgage Broker Conflict of Interest DISCLOSURE Guidelines · 2017. 9. 1. · MORTGAGE BROKER CONFLICT OF INTEREST DISCLOSURE GUIDELINES - UPDATE Office of the Registrar of Mortgage

• How do I disclose a possible volume bonus which may or may not be paid in the future, dependent on how much business I place with that lender for the year and/or dependent on what volume tier I might hit with different possible bonus amounts?

FAQs – HOW IT WORKS

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Page 44: Mortgage Broker Conflict of Interest DISCLOSURE Guidelines · 2017. 9. 1. · MORTGAGE BROKER CONFLICT OF INTEREST DISCLOSURE GUIDELINES - UPDATE Office of the Registrar of Mortgage

• Simply state the maximum potential bonus for the deal as a dollar amount

• It is an indirect interest that may be acquired• If the volume bonus amount is known at the

time, then simply state that amount directly in the Prescribed Form 10

FAQs – HOW IT WORKS

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Page 45: Mortgage Broker Conflict of Interest DISCLOSURE Guidelines · 2017. 9. 1. · MORTGAGE BROKER CONFLICT OF INTEREST DISCLOSURE GUIDELINES - UPDATE Office of the Registrar of Mortgage

• Some lenders award “points” for deals, which can be accumulated and exchanged for valuable goods or services. How do I describe loyalty programs to consumers?

FAQs – HOW IT WORKS

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Page 46: Mortgage Broker Conflict of Interest DISCLOSURE Guidelines · 2017. 9. 1. · MORTGAGE BROKER CONFLICT OF INTEREST DISCLOSURE GUIDELINES - UPDATE Office of the Registrar of Mortgage

• Rewards points have a monetary value and can be quantified and described

• If variable, just state the range• Obtain specific information from lenders

and/or check with your brokerage or network/franchise company

FAQs – HOW IT WORKS

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Page 47: Mortgage Broker Conflict of Interest DISCLOSURE Guidelines · 2017. 9. 1. · MORTGAGE BROKER CONFLICT OF INTEREST DISCLOSURE GUIDELINES - UPDATE Office of the Registrar of Mortgage

• Do lenders who are registered as “mortgage brokers” also have to provide a Form 10 to borrowers? – No – Disclosure is only required of brokers arranging

mortgages between the borrower and the lender – Conflicts of interest arise by virtue of being the

“middle person”

FAQs – HOW IT WORKS

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Page 48: Mortgage Broker Conflict of Interest DISCLOSURE Guidelines · 2017. 9. 1. · MORTGAGE BROKER CONFLICT OF INTEREST DISCLOSURE GUIDELINES - UPDATE Office of the Registrar of Mortgage

• Do I need to disclose compensation received from selling Group Creditor Life Insurance in the Form 10? – No– It is not a mortgage

FAQs – HOW IT WORKS

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Page 49: Mortgage Broker Conflict of Interest DISCLOSURE Guidelines · 2017. 9. 1. · MORTGAGE BROKER CONFLICT OF INTEREST DISCLOSURE GUIDELINES - UPDATE Office of the Registrar of Mortgage

• Sometimes a mortgage loan amount may vary from the time the Form 10 is provided to the consumer and the time it actually funds. How accurate does the compensation disclosure need to be?

FAQs – HOW IT WORKS

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Page 50: Mortgage Broker Conflict of Interest DISCLOSURE Guidelines · 2017. 9. 1. · MORTGAGE BROKER CONFLICT OF INTEREST DISCLOSURE GUIDELINES - UPDATE Office of the Registrar of Mortgage

• The Registrar expects values to be determined in good faith, and to be reasonable and defensible, as contemplated at the time the disclosure is provided

• Minor variations that, for example, result from adjustments at closing, are unlikely to attract the attention of the Registrar

FAQs – HOW IT WORKS

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Page 51: Mortgage Broker Conflict of Interest DISCLOSURE Guidelines · 2017. 9. 1. · MORTGAGE BROKER CONFLICT OF INTEREST DISCLOSURE GUIDELINES - UPDATE Office of the Registrar of Mortgage

CONCLUSION

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Page 52: Mortgage Broker Conflict of Interest DISCLOSURE Guidelines · 2017. 9. 1. · MORTGAGE BROKER CONFLICT OF INTEREST DISCLOSURE GUIDELINES - UPDATE Office of the Registrar of Mortgage

• Contact us with any questions as you continue to prepare.

• July 1, 2017• [email protected]

CONCLUSION

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Page 53: Mortgage Broker Conflict of Interest DISCLOSURE Guidelines · 2017. 9. 1. · MORTGAGE BROKER CONFLICT OF INTEREST DISCLOSURE GUIDELINES - UPDATE Office of the Registrar of Mortgage

Copyright © 2017, Province of British Columbia.All rights reserved.This material is owned by the Government of British Columbia and protected by copyright law. It may not be reproduced or redistributed without the prior written permission of the Province of British Columbia.PermissionTo request permission to reproduce all or part of any other materials on this website, please complete the Copyright Permission Request Form.Questions or concerns?For more information, please read the Frequently Asked Questions or contact the Intellectual Property Program.e-mail: [email protected]: 250-216-8935

COPYRIGHT

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Page 54: Mortgage Broker Conflict of Interest DISCLOSURE Guidelines · 2017. 9. 1. · MORTGAGE BROKER CONFLICT OF INTEREST DISCLOSURE GUIDELINES - UPDATE Office of the Registrar of Mortgage

QUESTIONS?

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Suite 2800 - 555 West HastingsVancouver BC, V6B 4N6Phone: 604-660-3555

E-mail: [email protected]