Proposed penalties totalling $250,000 expose how a Kijiji ad enabled a year-long fronting operation across eight groups of borrowers
Ontario's financial services watchdog has proposed sweeping enforcement action against a licensed mortgage brokerage, its principal broker, a former mortgage broker, and an unlicensed individual.
The allegations include fraud, falsified documents, and identity shortcuts that left at least eight groups of borrowers exposed to unsuitable mortgages.
The Financial Services Regulatory Authority of Ontario (FSRA) issued a Notice of Proposal on April 16, 2026, targeting Trillium Mortgage Services Inc., Frank Manzo, Paramjeet Kaur, and Vatsal Pareshkumar Khamar, also known as Vic Kumar.
Combined proposed administrative penalties amount to $250,000. All four parties have requested hearings before the Financial Services Tribunal.
The case originated with a single complaint filed on May 1, 2024, by an Ontario resident, identified only as "MA," who alleged that Khamar arranged a mortgage on her behalf on a property in Hamilton and that the registered mortgage amount exceeded what had been agreed.
MA stated she never met Kaur, had no knowledge that Trillium was her brokerage, and denied that her signature appeared on the mortgage commitment documents.
Read more: FSRA moves against trio over alleged fake gift letters, unlicensed brokering
A Kijiji connection at the centre of the case
FSRA's investigation uncovered a chain of events that began not through industry channels but through an online classifieds listing.
Kaur posted an advertisement on Kijiji, through which Khamar — who has never held a licence under the Mortgage Brokerages, Lenders and Administrators Act, 2006 — made contact and proposed referring clients to her.
What followed, according to FSRA's findings, was a two-year arrangement in which Khamar took on tasks that the Act reserves for licensed professionals.
He met with borrowers directly, collected identification and financial documents, prepared mortgage applications, obtained signatures, and forwarded that material to Kaur.
Kaur, for her part, never met any of the borrowers in person, relying instead on Khamar to verify their identities, a responsibility that falls squarely on the licensed brokerage under subsection 10(1) of Ontario Regulation 188/08.
FSRA determined that Khamar referred at least seven additional groups of borrowers to Kaur beyond the original complainant.
Kaur completed the applications, arranged electronic signatures through Khamar, and submitted them to lenders through Trillium. She received approximately $90,000 in commissions across the transactions; Trillium collected roughly $11,000.
FSRA is proposing an administrative penalty of $80,000 on Khamar for dealing in mortgages for remuneration without being licensed, along with a compliance order requiring him to cease and desist from all mortgage-related activities in Ontario.
The regulator previously issued a public warning about Khamar's conduct in August 2024, following a cease-and-desist letter sent the prior month.
Read more: Tribunal fines Harold the Jewellery Buyer $210k in mortgage case
Falsified applications and fabricated notes
The allegations against Kaur extend well beyond the unlicensed referral arrangement. FSRA contends that Kaur knowingly provided false information to lenders, including misrepresenting one borrower's marital status, fabricating employment and income details, and overstating another borrower's income.
She is also alleged to have performed no suitability analysis on any of the eight borrower groups, a core obligation under subsection 24(1) of Ontario Regulation 188/08, despite Trillium's own policy and procedures manual requiring Client Risk Profile Forms and File Check Lists for every file.
The record-keeping failures deepened during FSRA's investigation. Kaur told investigators she prepared contemporaneous handwritten notes during her dealings with the borrowers, then later shredded them.
Ontario’s financial services watchdog imposed twelve administrative penalties totaling $25,000 on former mortgage agent after finding she submitted falsified bank records to support a series of Manulife Bank mortgage applications.https://t.co/rN60Z4k2Ba
— Canadian Mortgage Professional Magazine (@CMPmagazine) April 28, 2026
She provided typed notes she claimed to have created in 2023. Metadata analysis, however, showed the notes were created on February 1, 2026, well after the investigation was underway.
There was also a licence renewal application in question. Kaur applied to renew her broker licence on March 17, 2025, responding "No" to a question asking whether she was currently the subject of an investigation or proceeding that may result in a penalty. That's despite having been notified of FSRA's inquiry in November 2024.
Her licence expired on March 31, 2026. FSRA is proposing $85,000 in total administrative penalties against her, the largest individual penalty in the case.
Manzo, as Principal Broker of Trillium, faces a proposed $25,000 penalty for failing to take reasonable steps to ensure that Trillium and its authorised brokers complied with the Act, a duty set out under subsection 2(1) of Ontario Regulation 410/07.
Investigators found that Trillium has not maintained the relevant borrower records, and that Manzo sought to obtain them from Kaur only after FSRA requested them.
His explanation — that records had been shredded during multiple office moves — did not satisfy the regulator. Trillium itself faces $60,000 in proposed penalties across three violations: suitability, identity verification, and record-keeping.
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.
