FSRA actions put suitability, fraud and disclosure back in the spotlight
Ontario’s mortgage regulator moved to shut the door on two industry professionals after court findings and allegations that cut to the heart of suitability, disclosure and fraud risk in the broker channel.
In separate notices of proposal, the Financial Services Regulatory Authority of Ontario (FSRA) said it would seek to refuse the licence renewals of mortgage broker Sanjive Kumar (Sam) Joshi and mortgage agent level 1 Ananthie Alex, with both matters headed to the Financial Services Tribunal.
Alleged unlicensed lending and “inequitable behaviour”
FSRA alleged that Joshi “carried on business as a mortgage lender in Ontario while not being licensed or exempt” and “dealt in mortgages for renumeration outside of his brokerage,” contrary to the Mortgage Brokerages, Lenders and Administrators Act, 2006.
According to the notice, Joshi advanced funds to corporate borrowers through promissory notes that “provided for the loan to be secured by a mortgage,” then later registered nine $5 million mortgages against nine properties, including the complainants’ home, without authorization and well above the total $2.6 million face amount of the notes.
The Ontario Superior Court declared the notes void and struck the mortgages due to Joshi’s “inequitable behaviour” and his material alteration of their terms, including registering demand mortgages at 18.99% interest where the notes had set 18% and fixed maturities.
FSRA also said Joshi failed to disclose multiple civil proceedings and a prior court finding against him and his company for “false or fraudulent misrepresentation, breach of contract, unconscionability, and the tort of deceit,” instead answering “no” to suitability questions on his 2024 renewal application.
The regulator said that failure “prevents FSRA from performing its gatekeeping function” and that Joshi posed “a risk to consumers that cannot be cured by attaching conditions to his license.”
Criminal conviction at centre of second case
In Alex’s case, FSRA said she was “not suitable to be licensed as a mortgage agent” after she was found guilty in 2025 as “the directing mind of a conspiracy” to use forged employment and income documents to obtain a mortgage, contrary to sections 368(1)(b) and 465(1)(c) of the Criminal Code. She received an 18‑month conditional sentence.
The notice also cited earlier discipline from the Real Estate Council of Ontario, which ordered Alex to pay $60,000 and complete an ethics course after finding she “facilitated the illegal trading in real estate by an unregistered individual” and failed to properly represent clients.
Part of a wider FSRA compliance push
In recent actions, the regulator revoked a brokerage licence and imposed $430,000 in penalties over “widespread compliance failures and unlicensed activity, with vulnerable clients steered into complex, high‑fee mortgages.”
FSRA also recently proposed sanctions against an Ontario broker accused of submitting 19 loan applications with altered or fabricated documents, and penalties and restrictions in another case involving an unlicensed referrer and a high‑cost private loan with an annualized borrowing cost above 200%.
More recently, the regulator moved to sanction an agent, a broker and an unlicensed corporation over an alleged scheme that pushed a London family from a bank mortgage at 2.5% into layered, high‑cost loans and ultimately the sale of their home.
Both Joshi and Alex requested hearings before the Tribunal, and the allegations in FSRA’s notices have yet to be tested there.
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