Alleged repeat disclosure failures could keep a Markham principal broker out of the business
The Financial Services Regulatory Authority of Ontario (FSRA) is moving to keep Renkai Lin out of the province’s mortgage brokering sector and to revoke the licence of his Markham brokerage, ZK Financial Inc.
The regulator alleges the pair kept arranging mortgages while suspended and gave it false information again, about a year after settling a similar case.
In a notice of proposal dated Sept. 2, Troy Harrison, FSRA’s acting director of litigation and enforcement, proposed refusing Lin’s April 9, application to reinstate his mortgage broker licence and revoking ZK Financial’s brokerage licence.
The notice said Lin, the brokerage’s principal broker and sole director, has shown “a pattern of unwillingness to comply with the requirements of the Act and regulations.”
The allegations have not been proven, and Lin and ZK Financial have requested a hearing before the Financial Services Tribunal.
A second round after a 2025 settlement
Lin held a licence from 2018 until May 8, 2025. ZK Financial was incorporated federally in October 2020 and licensed in January 2021.
In October 2024, FSRA moved against both for failing to disclose criminal charges laid in June 2022. The charges were missing from their 2023 and 2024 renewal applications and from their Annual Information Returns (AIRs), the yearly filings brokerages submit to the regulator.
Under an April 25, 2025, settlement, Lin and the brokerage admitted providing false or misleading information. They agreed to a $6,000 administrative penalty and a suspension.
A May 8, 2025, order required Lin to personally verify that every filing was accurate. On May 22, 2025, he was charged with further criminal offences, which remain before the courts.
FSRA now alleges Lin breached that condition. His reinstatement application left out a civil claim, issued Dec. 8, 2025, over brokerage fees on a mortgage renewal.
The regulator said he also left the lawsuit off the 2025 AIR, and that the 2024 and 2025 returns omitted mortgage and fee information he admitted in that proceeding.
Undisclosed proceedings have cost other licences. FSRA cited an inaccurate civil-proceedings declaration when it refused to renew the licence of broker Joel Kelman.
It also turned down a former principal broker who applied while criminal charges were outstanding, when it denied a broker licence to former Monarch Mortgage principal Victor Peca.
What does the deposit rule mean for brokers?
FSRA says that between April 29 and June 1, ZK Financial took on a borrower while Lin was unlicensed and the brokerage was suspended. The notice identifies the borrower only as ZY and says the brokerage worked to arrange a mortgage of between $100,000 and $280,000.
According to the notice, Lin took a $2,000 deposit for his services and later refused to return it. Ontario Regulation 188/08 bars brokerages from requiring advance payments on mortgages of $400,000 or less.
FSRA also alleges that, during the suspension, ZK Financial’s website and 51.ca listings presented it as arranging a high volume of mortgages, which contradicted its 2025 AIR.
The regulator has drawn this line before. “Licensees must not facilitate activities for unlicensed individuals,” said Elissa Sinha, FSRA’s director of litigation and enforcement, when the regulator revoked the brokerage licence of Expert Financial Corporation.
At MortgageFest Canada 2026, held in Toronto in September, Joe White, founder and chief executive of the Real Estate and Mortgage Institute of Canada (REMIC), argued that the licence itself is a broker’s core protection for clients.
“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. AI can’t do that,” he said.
“What consumers will understand over time is that what they get with dealing with a broker is competency, and that takes years to create.”
Under Ontario Regulation 410/07, principal brokers must take reasonable steps to keep their brokerages compliant. FSRA alleges Lin failed to meet that duty.
The notice does not set a hearing date.
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.
