Ontario regulator cracks down on off‑book broker deals

FSRA penalty puts renewed focus on brokerage oversight and disclosure

Ontario regulator cracks down on off‑book broker deals

The Financial Services Regulatory Authority of Ontario (FSRA) imposed $20,000 in administrative penalties on former mortgage agent Shan Jamal after finding he arranged multiple mortgage deals outside his brokerage and took fees directly from borrowers.

According to FSRA’s order, Jamal, formerly licensed as a Mortgage Agent Level 2 with Aimacon International Inc. (operating as Aimacon Financial), brokered and closed eight mortgages in 2023 for seven sets of borrowers without running those deals through his brokerage.

He then received a total of $61,550 in fees directly or through a corporation he controlled and an unlicensed associate, instead of through Aimacon as required under provincial rules.

What FSRA found in the Jamal case

FSRA said Jamal met with borrowers, gathered financial information, identified lenders, prepared applications and submitted those to lenders – all outside Aimacon’s oversight.

The regulator also found he failed to give borrowers “key disclosures and information” the Act required and that Aimacon had no records of the files.

The Director of Litigation and Enforcement concluded Jamal contravened subsection 2(3) of the Mortgage Brokerages, Lenders and Administrators Act by dealing in mortgages for remuneration without acting on behalf of his brokerage.

He also violated subsection 4(1) of Ontario Regulation 187/08 by accepting fees from parties other than the brokerage that had authorized him.

FSRA determined the conduct was intentional and repeated, noting Jamal admitted he took fees outside the brokerage to pay down personal debt and routed many payments through other entities to avoid detection.

Jamal’s licence expired on March 31, 2024, and he did not renew. After the Director issued a Notice of Proposal on January 19, 2026, Jamal had 15 days to request a hearing before the Financial Services Tribunal but did not do so. FSRA therefore proceeded to finalize the $20,000 penalty order on February 13, 2026.

Why off‑book deals matter in today’s market

More than two million mortgages are expected to renew between 2024 and 2026, putting added pressure on brokers to manage client risk and documentation carefully.

In that context, FSRA’s order serves as a reminder that keeping all fees and files within the brokerage framework is not a technicality but a core consumer‑protection safeguard.

When brokers arrange off‑book deals or accept payment directly from borrowers, they bypass the very oversight that regulators and lenders rely on to catch inappropriate charges, missing disclosures or misaligned products before harm crystallizes.

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