FSRA case highlights risks when brokers lean on unlicensed players
Ontario’s financial services watchdog imposed $20,500 in administrative penalties on former mortgage agent Rebecca Thien Kim Nguyendo after finding she helped unlicensed operators arrange mortgages and failed to assess whether loans were suitable for vulnerable clients.
According to minutes of settlement released by the Financial Services Regulatory Authority of Ontario (FSRA), Nguyendo was licensed as a mortgage agent from May 2021 until March 2024 and worked under Myriad Mortgage during the period in question.
She and her mother, Kim Thanh Do, “arranged a total of eight mortgages” for three borrowers identified as FM, MS and JT while relying heavily on two unlicensed intermediaries, Gyula “George” “Julien” Zambok and Jordan Ovejas.
FSRA said Zambok and Ovejas “convinced the Affected Clients to enter into mortgages to finance the removal of pre-existing security interests on their homes and to finance renovations that Zambok facilitated.”
Nguyendo “did not believe they were” licensed, yet “relied on them to collect borrower information for the purpose of arranging a mortgage, explain mortgage terms to borrowers, obtain borrower signatures on mortgage applications, and to facilitate mortgage closings.”
The regulator found that Nguyendo “did not conduct a meaningful assessment of suitability of the mortgages she arranged for the Affected Clients given their needs and circumstances, nor did she ensure that the Affected Clients understood the full costs of borrowing, payment obligations, material risks, and exit strategies for the mortgages.”
She also “ought to have known that Ovejas and Zambok were receiving remuneration for their mortgage dealing activities through the proceeds of the mortgages” and failed to disclose conflicts tied to referrals and compensation.
In one case involving a reverse mortgage for client MS, FSRA said Myriad Mortgage did not obtain a signed statement from a lawyer confirming independent legal advice and “Nguyendo did not provide one.”
In another, she arranged a mortgage for client JT with 5015977 Ontario Inc. as lender even though “5015977 Ontario Inc. was not licensed” and she has not verified its status.
FSRA concluded that Nguyendo breached provisions on mortgage suitability, conflict disclosure and reverse mortgages by “doing or omitting to do things that might reasonable be expected to result in her brokerage, Myriad Mortgage, contravening or failing to comply” with the Act.
It also found that she “ought to have known she was facilitating both the unlicensed mortgage dealing activities of Zambok and Ovejas … as well as facilitating the unlicensed mortgage lending activities of 5015977 Ontario Inc.”
Under the order, three administrative penalties totaling $20,500 were imposed, and Nguyendo agreed to withdraw her tribunal hearing request and accept that FSRA could treat the conduct as an aggravating factor in any future licensing decisions.
Part of a wider FSRA enforcement push
FSRA recently imposed a six‑month suspension and a $5,000 penalty on mortgage agent Chanderkant Jindal over forged insurance applications. It also issued a $75,000 package of penalties and a compliance order against former broker Yashna Singh for unlicensed dealing and misuse of restricted titles.
FSRA also flagged that monitoring private and alternative mortgage activity would remain a core priority for 2026.
For experienced brokers, the Nguyendo decision reinforces a familiar message: when unlicensed parties drive a transaction, documentation and advice still rest with the licensee.
In a sector where regulatory expectations have been steadily increasing, the case underlines that delegating those responsibilities to unregistered actors could carry serious costs.
Make sure to get all the latest news to your inbox on Canada’s mortgage and housing markets by signing up for our free daily newsletter here.
