Ontario regulator targets four parties for off-book mortgage dealings and title misuse
Ontario's mortgage regulator has moved to impose a combined $155,000 in administrative penalties against four parties following an investigation that uncovered unlicensed mortgage dealing, the use of restricted titles, and the operation of an unlicensed lending entity across Ontario.
The Financial Services Regulatory Authority of Ontario (FSRA) issued the notice of proposal on May 22, targeting Iqbal Singh Saini, 13016161 Canada Inc. operating as Infinite Mortgage Solutions (Oakville, Ontario), Sadik Sadik, and Emerald Lending Group Inc. (Brampton, Ontario).
The action, signed by Elissa Sinha, Director, Litigation and Enforcement at FSRA, falls under the Mortgage Brokerages, Lenders and Administrators Act, 2006 (MBLAA). All four parties have requested hearings before the Financial Services Tribunal, meaning the penalties are not yet confirmed.
Off-book dealings and misrepresented credentials
At the centre of the matter is Saini, formerly licensed as a Mortgage Agent Level 1 and then Level 2 under the MBLAA, who is no longer licensed.
FSRA alleges that between 2021 and 2022, while authorised by The Mortgage Alliance Company of Canada Inc. (TMACC), Saini brokered 25 mortgage transactions through Infinite Mortgage Solutions — of which Saini's mother is co-owner — without the knowledge of TMACC.
The regulator alleges he invoiced clients approximately $214,000 in commissions for those transactions.
During a November 2022 transaction involving a Toronto property, Saini used an email signature reading "IQBAL SINGH, MORTGAGE BROKER," a restricted title he was never licensed to hold.
FSRA has tracked a wider pattern of this conduct across multiple dealings, a trend consistent with other recent off-book enforcement actions in Ontario's mortgage sector.
FSRA proposes $85,000 in penalties against Saini: $75,000 for dealing outside his authorising brokerage and $10,000 for title misuse.
Sadik Sadik, principal broker of Infinite Mortgage Solutions, faces a $10,000 penalty for failing to take reasonable steps to ensure brokerage compliance under Ontario Regulation 410/07.
Infinite itself faces $25,000 for authorising Saini to deal in mortgages while it knew, or should have known, he was already authorised by TMACC.
An unlicensed lender that ignored prior warning
Emerald Lending Group Inc. raises a separate concern. Saini is the company's sole director and Emerald has never held a licence under the MBLAA.
Despite an FSRA warning letter issued on February 15, 2022, regarding its self-description as a "mortgage brokerage," Emerald subsequently issued fee agreements containing the same restricted designation.
In the same Toronto transaction, Emerald held itself out as a mortgage lender, issuing a Commitment Letter on Emerald letterhead and collecting a $2,000 payment from the borrower. The mortgage was later assigned to Vault Capital Inc., a licensed brokerage.
FSRA proposes $35,000 in penalties against Emerald: $25,000 for operating as an unlicensed mortgage lender and $10,000 for use of restricted titles.
The Saini case lands during a period of significantly heightened FSRA activity. The regulator also recently moved against a separate unlicensed mortgage scheme involving Oakville-area parties.
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