Government Relations

Anti-Fraud Standards for Mortgage Brokers

Samantha Gale, CMBA, responds to comments made by S&P Global regarding their opinion of mortgage brokers having less incentive than lenders to prevent fraud.

Read Letter here

School Tax Hike on Residential Properties Assessed at Over 3 Million

CMBA – British Columbia has appealed to the BC government’s Finance Minister, the Hon. Carol James, outlining how this new tax policy actually decreases housing affordability – across their entire constituent base – and works in opposition to their own stated affordability goals.

Letter to BC Finance Minister

BC Government 2018 Budget Announcement

The BC Government recently announced their 2018 budget, including a 30-point plan addressing housing affordability.

Of note, the plan calls for the elimination of the BC Home Partnership Program (HPP), championed by the BC Liberals and launched in 2017.

The HPP offered down payment assistance for prospective home buyers in the form of a second loan, with interest and payments deferred for five years.

“We are concerned that there is nothing significant in the government’s new housing program for people entering the housing market,” says CMBA-BC Chief Operating Officer Samantha Gale. “The only program in place to help people needing assistance with down payments in Canada’s most expensive housing market will be dismantled, and there are no real measures which will increase the supply of market housing.”

Read full statement here

Responding to Announced Money Laundering Crackdown

A recent Globe & Mail story calling attention to alleged drug money laundering via the real estate sector has prompted a response from the BC government.

Attorney General, David Eby, has promised a crackdown to close loopholes that the government believes enables lenders to launder money through mortgages.

“We need to distinguish between private lenders who are licensed under the Mortgage Brokers Act and criminals who lend money as part of a money laundering scheme,” says CMBA-BC Chief Operating Officer Samantha Gale.

Read the Press Release here

BC Empty Homes Tax

Read the details here

CMBA Joins Coalition for Small Business Tax Fairness

Coalition for Small Business Tax Fairness, representing hundreds of thousands of independent businesses, professionals and taxpayers, submitted a letter to the Honourable Bill Morneau regarding the proposed tax changes. Read the letter here

CMBA Submission to OSFI RE: Draft Guideline – Residential Mortgage Underwriting Practices and Procedures

The Canadian Mortgage Brokers Association (CMBA) submission to OSFI concerning the Draft Guideline – Residential Mortgage Underwriting Practices and Procedures. Read the submission here

CMBA Bulletin on Purchases and Sales Involving Non-resident (Capital Gains Tax)

A mortgage broker forewarned with knowledge about the capital gains tax, as it applies to sales of real estate by non-residents, is better forearmed to assist in avoiding later delays and collapsing of transactions. CMBA Purchase and Sales Involving Non Resident Bulletin

CMBA Bulletin on Mortgage Brokers Issuing Promissory Notes

Mortgage brokers in Canada who arrange loans from clients using promissory notes may, at least in some circumstances, be breaching securities legislation. CMBA Promissory Notes Bulletin

Consumer Protection and Oversight in Relation to Schedule I Banks

Letter to the Standing Committee on Finance – Click here

Housing Stakeholders Position Paper

The below listed construction and housing industry associations, primarily in market housing, have collaborated to identify several recommendations to improve housing supply. Some of the recommendations can be achieved by municipal governments, but the provincial government can also encourage or assist these processes.

Real Estate Board of Greater Vancouver
Fraser Valley Real Estate Board
BC Real Estate Association
Real Estate Institute of BC
Greater Vancouver Home Builders’ Association
Canadian Home Builders’ Association – Fraser Valley
Canadian Home Builders’ Association – BC
Urban Development Institute – Pacific Region

Read the paper here

Down Payment Assistance from BC Government for First Time Home Buyers
(BC Home Owner Mortgage and Equity Partnership Program)

Press release regarding the BC Government’s announcement made December 15, 2016 – CMBA-BC Press Release Dec 15 2016

New Mortgage Rules – Exemption Request and Recommendations

Letter to Hon Bill Morneau and Hon Jean-Yves Duclos – Click here

Federal Government Mortgage Rules Changes Announced October 3, 2016

The new rules affect CMHC insured and Low Ratio Bulk Insured Mortgages. Read the Press Release – Click here

Application of GST to Mortgage Broker Fees/Commissions

The Issue

Do mortgage broker fees/commissions attract GST? Read a summary of the case – Click here

CRA’s new NOAs Create Fraud Risk

New simplified NOAs remove several security features preventing mortgage fraud. Read the CMBA’s recommendations to the Minister of National Revenue on this issue – Click here


2015 CMBA letter re: Offering Memorandum Exemptions – OM letter


2015 CMBA letter to Matt Galloway, CBC Radio One – Click here



logo - 3 CMHC2014 CMHC Consumer Survey – Click here

  • Modifications to CMHC multi-unit condominium construction and low ratio mortgage loan insurance – Q&A – External
  • Discontinuation of CMHC second home and CMHC self-employed without traditional third party validation of income products.  Effective May 30th, 2014, CMHC will limit the availability of homeowner mortgage loan insurance to a maximum of one residential property (1-4 units) per borrower/co-borrower at any given time – Q&A – Self-employedQ&A – Second Home


  • Letter to the Honourable Suzanne Anton, Q.C., Minister of Justice and Attorney General regarding ‘The Application of Debt Repayment Agent Licensing to Mortgage Brokers in BC’ – Click here
  • Letter to Real Estate Magazine regarding Letter to the Editor: Help your clients with mortgage shopping – Click here
  • Letter to Registrar regarding Compensation Disclosure and the Registrar’s Open Letter to Mortgage Brokers – Click here
  • Letter to Law Society regarding Changes to Definition of ‘Institutional Lender’ – Click here
  • Letter to the Registrar of Mortgage Brokers regarding Disclosure of Fees to Borrowers  – Click here
  • MBABC’s comments on the Registrars proposal to amend Form 10 requiring Disclosure of Fees – Click here
  • Letter to the Minister for Core Review regarding the proposed self-regulation of mortgage brokers in BC – Click here
  • MBABC position paper on the Mortgage Brokers Act – Click here
  • Mortgage Brokers Act – Personal Mortgage Broker Corporations – Click here
  • Mortgage Brokers Act – Advance Fees Charged by Mortgage Brokers – Click here
  • MBABC Recommends solutions for unregistered BC mortgage brokers who collect fees – Click here


  • MBABC recommendations to proposed New Brunswick Mortgage Brokers Act Rules. –  Click here


  • Letter re: Comments on Draft initial Regulations for the Cooperative Capital Markets – Click here
  • Our letter to the Premier and Minister of Finance – Click here
  • CSA Proposed Amendments Relating to the Offering Memorandum (“OM”) Exemption – Click here 
  • Mortgage investment entities survey letter November 4th, 2013 – Click here
  • Second syndication letter April 10 2013 regarding  supplemental submissions for BC Notice 2013/01- An Analyses of BC Syndicated Mortgage Lending Under American Jurisprudence –  Click here
  • Survey results to determine the impact of EMD registration on MICs and Syndicators – Click here for MIC Results, Click here for Syndicator Results, Click here to view All Comments
  • Letter to BC Securities Commission regarding proposed registration of mortgage syndicators as exempt dealers:  BC Notice 2012/01 Click here
  • Letter regarding proposed registration of MIC’s as exempt dealers:  BC Notice 2013/01 Click here


  • Mortgage Brokerages, Lenders and Administrators Act – Click here


  • Draft Mortgage Regulation Act Regulations – Click here


  • MBABC submission regarding FICOM’s proposed mortgage underwriting guideline – Click here


  • The MBABC, in conjunction with other associations has made a joint submission to the Mortgage Broker Regulator’s Council of Canada, which includes regulators from BC, Alberta and Ontario on some key issues relating to mortgage broker regulation.  These issues include the regulation of roving bank representatives and suitability standards.  The MBABC met with the MBRCC at their industry meeting on November 23, 2013 and addressed some of these issues.  Canadian Mortgage Broker Industry Submission to MBRCC Nov 19, 2013 – Click here
  • Letter regarding regular in‐person meetings between the MBRCC and industry representatives – Click here