Lending operations / GUIDE + WORKSHEET
Make Canadian mortgage records retrievable for FINTRAC
Build a transaction record index with evidence pointers, owners, dates, retention fields, and a safe retrieval test for covered mortgage businesses.
THE STARTING POINT
For a business covered as a mortgage lender, broker, or administrator under Canada's PCMLTFA, make each required record traceable from a client or transaction ID to its evidence, owner, event date, secure location, and retrieval path. FINTRAC's mortgage-sector obligations began October 11, 2024; its recordkeeping guidance specifies retention and production requirements. Use the regulator's current record list to define what applies, then test that an authorized person can retrieve a sample without rebuilding the file from email.
Check that the entity and activity are in scope
Start with FINTRAC's current description of who must report and its mortgage-sector guidance, because duties depend on the entity and activity. Mortgage administrators, brokers, and lenders entered the reporting-entity regime on October 11, 2024, while financial entities are addressed under separate categories. Do not copy one checklist across a bank, mortgage investment corporation, brokerage, and private lender without confirming which legal entity performs each activity.
Index evidence by event and client relationship
Give each required record a stable client or transaction identifier, record type, event date, responsible role, source location, and retention or review date. Where relevant, link identity verification, beneficial-ownership information, third-party determinations, ongoing-monitoring notes, reports, and approvals to the same relationship without pretending they are one document. Keep a short note explaining where the authoritative evidence lives and who may correct an index error.
Route missing evidence to a person
A missing or conflicting record should create an exception with a due date and an accountable reviewer. Distinguish 'not applicable' from 'not yet obtained' and from 'unable to verify'; each needs a reason and review path. Automated imports may attach source documents or flag a blank field, but a designated person must determine whether the file satisfies the applicable requirement. Preserve the original evidence and the correction history instead of replacing them silently.
Test retrieval against the regulator's instructions
FINTRAC's mortgage recordkeeping guidance states retention periods and production requirements, including a five-year retention period for specified records and production within 30 days of a request. Confirm which period applies to each record type in the current guidance. Run a controlled retrieval exercise using an authorized reviewer: start from a client or transaction ID, collect the requested evidence, show its date and provenance, and log gaps and the person responsible for resolving them.
WORKED EXAMPLE / ILLUSTRATIVE
A fictional mortgage record index
This illustrative index points to evidence without copying sensitive documents into an extra uncontrolled folder. The record type and applicability still need review against FINTRAC guidance.
| Fictional record type | Evidence pointer | Control |
|---|---|---|
| Identity verification | Client C-104, secure vault item V-22 | Method, date, and reviewer recorded |
| Beneficial ownership, if applicable | Entity E-311, secure vault item V-07 | Unresolved ownership routes to compliance lead |
| Third-party determination, if applicable | File M-205, onboarding event 2026-10-02 | Decision and source retained |
| Record production request | Request R-19, evidence bundle B-19 | Authorized reviewer logs completion and gaps |
MAKE IT USEFUL
Mortgage record retrieval index
Use one row per applicable record type and preserve a pointer to the authoritative evidence.
Your notes stay in this page and are not sent to Smithers. Download or copy them before leaving; refreshing clears them.
Before you put it to work
- Confirm the entity's current reporting-entity category with FINTRAC guidance.
- Map record types to the official mortgage recordkeeping page.
- Limit evidence access to authorized roles and log retrieval activity.
- Test a sample record from the index through to its source evidence.
- Review retention periods and open exceptions with the compliance owner.
FINTRAC obligations depend on the entity, activity, client, and record type; an index or CRM is not proof that the business meets its obligations. This is general information, not legal advice. Confirm requirements with your compliance counsel.
Source notes
These references support the specific product or technical points discussed above. Checked October 9, 2026.
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