Regulator trims penalty as broker admits relying on an unlicensed referrer to vet borrowers
A former Ontario mortgage broker who let an unlicensed referral agent handle her client intake has agreed to pay $40,000 to the Financial Services Regulatory Authority of Ontario (FSRA), settling a case in which the regulator had sought more than twice that amount.
Paramjeet Kaur, whose broker licence through Trillium Mortgage Services Inc. expired on March 31, admitted to six breaches of the Mortgage Brokerages, Lenders and Administrators Act, 2006 and its regulations, including facilitating illegal conduct and giving lenders false or deceptive information.
The order, dated Sept. 24, replaces the $85,000 in penalties FSRA proposed in April. The final figure is about 47% of that amount.
How the unlicensed referral pipeline worked
The case began with a May 1, 2024, complaint from a borrower, identified as MA, who said the mortgage registered on her Hamilton property was higher than the amount she had agreed to. She told investigators she had never met Kaur and did not know Trillium was her brokerage.
According to the agreed facts, Vatsal Pareshkumar Khamar, also known as Vic Kumar, answered a Kijiji ad Kaur placed in 2023 and began referring clients to her.
Khamar, who has never held a licence, met eight groups of borrowers, collected their identification and financial documents and obtained signatures.
Kaur prepared the applications and sent them to lenders through Trillium. She relied on Khamar to confirm the borrowers’ identities and never met any of them in person.
Kaur admitted listing one borrower as single when she was married, supplying inaccurate employment and income details for that borrower and overstating MA’s income.
FSRA’s April notice said she knew MA was a low-income college student and earned approximately $90,000 in commissions on the files. Trillium collected roughly $11,000.
“Kaur knew that Khamar was unlicensed, and yet relied on him to complete some of the fundamental obligations of a Mortgage Broker and facilitated his conduct,” the notice said.
She also answered “No” on a March 2025 renewal application asking whether she was under investigation. That was months after FSRA sent her an inquiry letter.
The notice further alleged that typed notes she submitted as 2023 records had metadata showing they were created on Feb. 1.
What the case signals for Ontario mortgage brokers
The regulator’s April proposal against Trillium and three others also targeted the brokerage and its principal broker. It sought $60,000 from Trillium and $25,000 from principal broker Frank Manzo. It sought $80,000 and a compliance order against Khamar.
All four parties asked for hearings before the Financial Services Tribunal, and the allegations against the remaining three have not been proven. Kaur has undertaken to testify at a hearing on the merits.
The case resembles FSRA’s decision to revoke Expert Financial Corporation’s brokerage licence over unlicensed activity. It also fits the trend in FSRA’s first enforcement annual report for 2024–25, which recorded 100 enforcement actions, up from 65 the previous year.
“They’re finally taking seriously the role we play as mortgage professionals in the transaction. It’s frustrating to see the lack of professionalism [from some mortgage agents]. But I think what the latest regulation is doing is making the good ones even better and the bad ones are that much more obvious,” Joe Sammut, broker of record at Mortgage Architects, told Canadian Mortgage Professional earlier this year.
FSRA said Khamar’s conduct left borrowers without the Act’s protections, including errors and omissions insurance. Joe White, founder and CEO of REMIC, made a similar point about licensing at MortgageFest Canada 2026, while discussing AI tools.
“Brokers are licensed. AI isn’t. The fact that brokers have errors and omissions insurance so that if something goes wrong, the client’s protected,” White said.
At the same event, Andy Kuyper, head of partnerships and secured lending at TransUnion, warned that the risk will grow as volumes recover.
“Fraud is a problem. It’s far easier for fraud to be committed when times are busy and everyone’s busy. So right now we’re in a good spot, but I would caution the industry to be careful as this industry rebounds – to be hypervigilant on fraud,” Kuyper said.
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