Real Life Mortgage Solutions

In a critical update for the mortgage industry, Dave Teixeira joins host Len Lane to clarify the recent AML regulations. Dave highlights the importance of these rules in strengthening the role of mortgage brokers in Canada’s financial system and explains the operational challenges of ongoing compliance. He illustrates how DLCG is supporting brokers with tools to manage enhanced ID verification, risk assessments, and transaction monitoring while discussing the vital role of technology especially the Velocity platform. 

The conversation also touches on the intricacies of the regulatory landscape, including the importance of ongoing media monitoring and understanding the distinction between suspicious transaction reports (STRs) and other compliance documentation. Dave’s expertise offers mortgage professionals a roadmap to efficiently navigate AML requirements while ensuring top-notch client service. This episode is a must-listen for mortgage brokers, industry professionals, and those interested in regulatory compliance within financial services.


About Dave Teixeira
Dave Teixeira is the Executive Vice President of DLCG Operations. Since joining DLC in 2015, Dave has played a vital role in managing partnership relationships, overseeing media and government relations, and leading special projects. Known for his collaborative approach, Dave works closely with third-party partners, and his title accurately represents the wide range of operational functions he contributes to DLCG.


Resources discussed in this episode:
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Contact Len Lane | Brokers for Life: 
Contact Dave Teixeira | Dominion Lending Centres: 
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Transcript

Len 00:02

Welcome. My name is Len Lane, and I am the founder and president of Brokers for Life Inc, and we are Dominion Lending Centers in Western Canada. The topic of our podcast will be about what we consider to be Real Life Mortgage Solutions. 


Len 00:18

Welcome back if you're listening to this today, on the day it's been released, it should be December 10, 2024 we will be taking a short break over the Christmas season, as the next podcast would have come out on Christmas Eve. So, you will hear back from us on January 7th with a new set of podcasts for you to enjoy. Have a great Christmas season, and we will talk to you in 2025. 


Len 00:44

Today, we're going to talk about a hot subject within the mortgage industry. The letters AML have been tattooed on the back of our hands for the last six or seven weeks. Anti-money laundering, not new to the banking system, but in the recent few months, it has become something of importance within the mortgage industry, and today we're going to talk to Dave Teixeira, Executive Vice President of operations for DLC group. You don't know who DLC group is after the 17th podcast, lending group, so David, welcome.

 

Dave 01:17

Thanks. Len, it's great to be here, and it's great to be able to chat now that we're a little bit on the other side of the AML Regulations now coming into play. I think people are now a bit of a sigh of relief that they've gone through that first little bit but always interested to share more about the experience and to see what sort of questions might still be out there.

 

Len 01:40

Right, exactly. And like I kind of said, it's like AML is not new. Anti-money laundering has been around for a long time, especially on the banking side. Financial Planners actually it looks like it was enacted in 2006, and FINTRACS itself has been around for over 25 years. So why do you think that it's now become the mortgage industry's turn to be involved in this? 

 

Dave 02:03

I think they've realized, I think governments have realized, over the last, say, 15 years or so, the key role that mortgage brokers play in Canadians' lives. And I think that's a positive, you know, we've come from being this kind of fringe utility. You know, it's nice to have, perhaps, but it's kind of weird to now being the choice for people to make really good decisions, and we can help Canadians get into the house of their dreams. And so I think what's happened is, over the last while, regulators and organizations, regulators like FINTRAC, has said, Wait a second, this other group is playing a role here. Why are they not part of it? So, I think it's part of becoming a more professional organization. And at DLCG, we've often welcomed these sort of regulations because it shows that we're now being taken seriously. And as you pointed out so wisely, these regulations have been part of various industries for a year, everything from casinos and gambling to wealth management to legal professions, real estate. So it's just kind of our turn, and at the end of the day, I think this is these are going to be really simple regulations to follow. It's might be a little more difficult to have a process in place unless you have a good technology solution, but it's, it's a bit of a curse. They now see us as professional, which means they're going to regulate us a little more differently and more stringently.

 

Len 03:24

Right, and that's definitely part of it. I think the Cullen report, of course, a couple of years ago came out in British Columbia and highlighted a lot of spots. Do you think that was much of a catalyst to point out the mortgage brokering side of it?

 

Dave 03:40

I think it was independent of what FINTRAC was doing. FINTRAC, the Cullen report came out. I believe it was in late 22 or mid-22, and in early 2023, FINTRAC announced they were going to do something, something in the mortgage industry. Then, in September of 2023, they said, on October 11, 24, various regulations were coming in, and they laid them all out. And I think this is an industry we might have been slow to adopt. I know I was slow, and DLCG were slow to understand the importance. We kind of thought, Oh, this is just enhanced ID verification, not a big deal. And quickly we learned it's a much bigger deal. So I think the Cullen report in British Columbia, and if anyone out there hasn't read it, it's a lovely, 1800-page, breezy read, but they are looking at saving, preserving the housing markets, and making sure that, you know, criminal activity is not part of it, and part of that being anti-money or money laundering, which was apparently a fairly big problem here in British Columbia. I'm not so sure how big it was, but it was enough to merit an 1800-page report. And to that end, I think we're going to see governments, and even perhaps provincial regulators, get more involved. So, on August 8th of this year, BCFSA. The regulator in British Columbia sent out a kind of a scary email to agents and said, We're going to be performing desk audits to ensure that you are going to be compliant for FINTRACS. So two months before the regulated regulations came in, here's an unrelated, or at least an adjacently related organizations saying they want to ensure that FINTRAC regulations are being met. So, if I had my crystal ball out, I'd say that we're going to see more of a focus on AML from the regulators as well as FINTRAC. So stay tuned for that. And that's just my somewhat educated guess. 

 

Len 05:39

In our own process of setting everybody up, and we were up and running on the 11th. On the 10th. Actually, couldn't push the button till the 11th, but it was, it's an eye-opener, I think, for a lot of people, because you, we see transactions, and of course, for years, we've had to identify anything over a couple $1,000 actually, there's no minimum on that, but majority was around 2000 was kind of the buffer. Where did that money come from? What was the source of that money if it wasn't from a payroll or RSP withdrawal or something like that? So it's not really that new, I guess only now. It's taking it to another level. Where did the people come from? Where's the money come from? Right?

 

Dave 06:19

And I think the most onerous piece of that as well, Len, is the ongoing monitoring of activity. And so what was a surprise to me was you could have a client that comes into you and they get a certain way down the road, they don't even file or don't even complete the transaction, and perhaps they're high risk. You now have, as an agent and as a brokerage, the obligation to do ongoing media monitoring for up to five years. So it's quite it can be an onerous position, unless you have a technology solution doing that. And, of course, you know, we partnered with Velocity to have that. But there's other solutions out there. But what's really key is for brokerages and agents and owners and everyone in that ecosystem to work together to have something better than just a piece of paper and a filing cabinet because it's going to be very, very difficult as time goes on. So say Len, you have 100 clients this year, and 50 are high risk, and 20, you know, don't complete a file with you. That's, that's a lot of different variations of media monitoring. If someone's a client of yours as of a mortgage agent, you'll remember them, but if someone didn't complete the file, perhaps you'll forget them the next day. However, FINTRAC has a long memory, and they expect you to check up on these clients, even beyond their short time with you. 

 

Len 07:42

And part of that will get more into like the technology that been given to us. It's most advanced of what I've seen, but it's that ongoing there as well, right? If they actually end up on a sanctioned list, they'll it will alert us as well. There's only so much other checking up you can do, I guess, other than picking up the phone or something like that. So lenders obviously already involved in this for a long, long time, just to cover their own lenders and their own partners as well on the other side. So do you think having these systems in place will make them make it less legwork for the lenders, or are they going to have to do still have to do as much due diligence and hope that we did ours properly as well. 

 

Dave 08:24

Yeah, I don't think what we're doing in the mortgage industry is going to have an ease, any sort of easing, on their requirements because everyone in the chain, if you will, has to do their own level of scrutiny or AML. And again, the AML requirements are not have anything to do with mortgage suitability. This is strictly on whether or not someone may pose a risk of criminal activity or something such as that. So FINTRAC has told us that the more people in the process that are checking for this, the better. So, for years and years, we've had real estate agents, perhaps lawyers and lenders, all doing their checks. Now, they want mortgage brokers to do that. So their hope is, is that we might catch something that someone else does not. And by having those multi-layers, there's more of an opportunity to ensure something negative in our space doesn't take place in terms of anti-terror or terrorist activity or money laundering. So from the lender perspective, because we don't really, we don't share this information, right? Anything that we're recording on the AML side only is recorded for the purposes of submitting an STR or a Suspicious Transaction Report. And again, we have to remember that first word is, I think, the most important, it's not absolutely 100% Terrorist Transaction Report. It's suspicious. So, do they have a large sum of money that they're putting down? Do they come from a sanctioned country? Are they a pap, a politically exposed person, and a few other points? Then you merely mark that down, submit the report, and that's your obligation is to submit the report correctly. So, I don't think lenders are going to be impacted by us because they'll do their own checks and do their own submissions. But what's interesting to note is the information that we are collecting and recording as it pertains to AML is not to be shared with the client or with lenders, or any other parties in the transaction. It's only there to facilitate the creation of the STR, the Suspicious Transaction Report.

 

Len 10:21

Right? And that's a good point because if it's, there's a good chance that, if we consider it to be a suspicious transaction, that it may never get to be a deal that will be sent to a lender anyway. So it still has–

 

Dave 10:34

And it’s interesting, because the example I used the politically exposed person, I mean, all jokes aside, of politicians being criminals. You could have your local mayor or your local council person come to you, and because of the nature of their job, they now become high risk automatically because they're a politically exposed person. You also can have a situation. So here in British Columbia, this past weekend, we had a provincial election, we have 58 brand new MLAs. So that's 58 people who've now all of a sudden, or will soon, technically be on a sanctions because of their political exposure. So there's going to be this need to keep updated. There's going to be this need to record what you know at the time to be true. This is where I think the regulations can be onerous, and I've said this a couple of times unless you have a technology solution because there's no humanly way possible to remember when to do these checks. What process are you in? Are they high, mid or low, etc etc. So having a good system in place, along with education and just having, you know, Len, great people to lead the charge. Is the way forward, right? 

 

Len 11:44

Yeah, and it's 58 new MPs? 

 

Dave 11:48

58 new MLA, that's a whole other thing we might have to talk about. I think we'll even have another provincial election in about six months because it was too close to call. That's for another podcast. 

 

Len 12:02

I could take a little over an hour. Okay, so we keep bringing up technology. Let's talk about what Velocity has given to us. You may have seen my LinkedIn post, but maybe not. I know Eddie did because he sent me a note, but it was, you know, 35 agents or 37 agents that month. I think it was all through the system, through the training, because if you want to get paid with us now, you have to have done your AML training. The 54 pages of policy and procedures were in place. And there's a couple of other steps we took in there as well. But on the 11th we turned on the button that you can't submit to a lender unless you've done the AML, so you're in the background watching that all come together. I'm sure. How did that all come about? 

 

Dave 12:48

Well let me take a step back as well. So when we started with the AML, you know, putting together processes and programs for our DLCG agents, we had four big pillars. One was the first one was information we had to share with people that these ammo requirements are real, because there was even a little bit of that. No, no, no, my lender does it for me. No, no, no, my real estate agent does it for me. Or in Quebec, we had people say, Well, no, no, that's for Canada, not for Quebec. And that led to some other interesting conversations. So, number one was the information. Number two was it was important to us that we had a really good relationship with the regulator to understand what's there, so myself, along with our chief legal counsel, and he did most of the heavy lifting here, James Bell, made sure that we had a really strong relationship with FINTRAC that continues to this day. What are you hoping to do? What are the goals? What's written down versus the expectations, and so we were able to really marry those together. The information and relationship with FINTRAC number three was education, and it was important to us that we had the education that was free to our agents. So for those out there, for roughly 9000 DLCG agents, we provided through REMIC, we partnered with a group to provide that training. Because how do you know the rules of the game? Unless you know the rules of the game. The analogy I use is, imagine the first time you saw a hockey game if you just saw the pads and the sticks and the puck on the ice, and then someone said, All right, go ahead, figure this out, but if you do something wrong, you're going to be fined, right? You wouldn't necessarily figure out the game as quickly as if someone actually explained the rules to you. And then the last piece was technology because once you saw how big this can get, enhanced ID verification is one piece of it, but risk rating and keeping notes, filling out an STRS or a Suspicious Transaction Report, and then doing ongoing monitoring. How do you do that? So Velocity was easy to come forward too, because, I mean, obviously, DLCG owns Velocity, so we could be nimble and create a really great experience, and plus, it just integrates well within the mortgage origination process. So I think what's really special with the AML, not requirements, but the technology from the Velocities. It has all the tools that an agent would need to be successful, and then also a larger piece for owners to monitor. And as you even said, there's a kind of a switch there where you can say, you know, everyone must go, you know, must use Velocity, or must make sure that they complete a certain amount or all of the AML requirements in order to submit. So there's the tools there to be successful. And without these, again, I have no idea how an agent can, with any sort of even small book of business over the years as it multiplies, how you can do it. So yeah, today, one week, a week and a half after the regulation started, you might say, no big deal. But as you get more and more files in the AML regime, you have no choice but to have an assistant of some sort of digital assistant, and that's Velocity, who can help with the intake and the ongoing monitoring.

 

Len 15:51

Right. And that was part of it. I think the ongoing monitoring people don't realize until you not only took the REMIC course, I took the REMIC broker-owner, course, and I did the MPC one as well, just to see what the differences were, right? Just, and there wasn't really other than there's an actual test with with REMIC. There isn't one with the other. To see is everybody saying the same thing. They were quite similar, right? I got an email from one of my agents this morning saying, Oh, this other small lending platform just rolled it out today, and go like, so what did they do with the last 10 days of files, as is what I was thinking.

 

Dave 16:30

And it's funny, you should say that, like we've heard that is, well, I'm going to wait for this other provider or so on and that. And, of course, we want everyone to feel comfortable with the solutions provided. At DLCG, we provided what we believe is best in class. As time goes on, there's going to be more and more solutions out there, but if it wasn't available on September, sorry, October 11th, then you have to now figure out how are you not backdating. But how are you putting in the last week, 10 days or so, into this other system. And we're just really proud that we provided everything for our agents and owners to be successful before October 11th.


Len 17:09

Right, and you know, for us, it was, you know, we've 100% Velocity, so it was easier, I think, probably, than if you were working in two or three systems in some cases. We were at that point, at one time, and it was chaotic just to try and do regular component.

 

Dave 17:25

And I think that's going to be the norm. Len, is that, as time goes on, I mean, it's, you know, there's a, you know, a suggestion that anyone should choose whatever systems they want. And I think that's important to a degree, except when there is harsh repercussions that come down on the franchise owner, the broker of record. And you know, to have multiple systems of where the intake and the outputs are similar yet different. How does one monitor that? And again, how do you look at the overall growth or the overall health, I should say, of your office, and that's what Velocity can provide, is that sort of owner overview to see what's actually going on in your own franchise, in your own office. So I think the notion of anyone choose anything they want is a little bit outdated. But I do believe there should be ongoing evaluations, and even though I'm, of course, in the camp of Velocity and DLCG, I have no problem looking at with the critical eye as time goes on. Is Velocity providing the best in class solutions and the best results for our agents, and to be, you know, to be involved in those other webinars and all the learning opportunities about what's out there, because, you know, complacency will kill us. And you know, having the pride in what we're doing beyond just being proud that we completed it, but the pride that stops you from innovating would not be good. But I think it's going to be incumbent upon franchise owners to look at this with a critical eye themselves and say, you know, we need to plant our flag in a certain ecosystem because it's the best for our office, and doing so protects all of your agents. You mentioned 35 to 37 agents. All it takes is one agent in your realm to decide AML ain't so important, and you could have repercussions that impact the other 36, and that's the reality. It's FINTRAC will be doing audits. And in fact, part of the requirements is that every two years that agents submit themselves to an audit. What will that look like? Not quite sure yet. And kind of the interesting part here, Len, is that I've always said this is a sprint in a marathon. So we sprinted to October 11th to get everything ready, and then there's a marathon after that. There's the not the relicensing, but then, you know, you have to retake an AML course every year, and then every two years, it's the audit. So that marathon continues, and we will make sure that there are solutions that are out there, but I think owners are going to have to choose and that might upset some people, but at the end of the day, owners have a, you know, a fiduciary, I would say, responsibility to their agents, to ensure that they're running the franchise in a way that will be productive, legal and sustainable,

 

Len 20:16

Right. And I think that was part of what I had a lot of calls before, some from the RECA Mortgage Broker Advisory people. And, you know, talking about talking to lots of small brokerages that were saying that they were seeing the costs run up to 10,000 plus dollars. And after seeing a 54 page P and P that, that is, you know, I can see having somebody write that for you. Yeah, there can be some. 

 

Dave 20:46

That’s what we did as well as we provided templates. Because, you know, there are, there's other ways to do this, but we want to provide everyone, at least, with a foundation. And I think what we're seeing as well, Len is we're seeing a real cottage industry of AML experts and AML adjacent products coming out. So we have groups out there saying we'll write your policy for you. We will train you. We will do this for you. And seeing five figures and growing is not unusual. And, so, I'm not saying that they're not legitimate. It's just that I believe that there's other ways to accomplish that. And part of being a value, of being part of the DLCG network is we'll do that heavy lifting. You can decide if you don't want to use our version of the policy or our version of the tools, or you don't want to take the free training that we're providing via REMIC. Do what you need to do, but what's most important is that you least get educated. But there is a cottage industry that's growing. I get hit with emails on a daily basis telling me that there's a better way to do it. I look into them, and I feel pretty good that, you know, we can put our documents, our training, our philosophies on how we're doing this against anything out there. So I'd recommend to anyone that's listening, is check in with your network, check in with your franchise in order to see what's there. Don't just jump to paying for this because it might feel like it's the easy way. Oh, I just have to write a check, and I get everything. There might be other solutions that are less costly. Might take a little more time because you have to be a little more involved, but I think you'll be a better agent or owner for it, for doing that research yourself? 

 

Len 22:23

Yeah, and I've seen them all come, had phone calls, I've had emails and my responses, Oh, thanks for your offer. We're part of the DLC group. We're okay. We have everything already done in the conversation. Usually not gonna waste his time or mine, right? So, over the last year or so, I guess maybe more like, I keep hearing about a Velocity-certified application or submission. I guess, if you want on the other side of that, this obviously ties into it as well. Is that something that's in the near future or down the road? 

 

Dave 23:03

Yeah, and I can’t speak too authoritatively on that because I'm not from Newton, but certainly, what we are trying to do are a number of things that will make the whole mortgage origination experience smoother. And you know, everything with Velocity, or I should actually say, Newton has worked with lenders for direct document submission, and now they're looking at having this sort of verified, almost adjudicated, sort of application. So that way, you know, there would be technology, perhaps AI in the future, that would then look at what that file is, help you clean it up. So that way could be more efficient. Because at the end of the day, what we provide mortgage brokers, I should say, provide to lenders isn't just clients and an opportunity; it's efficiencies, and there's an expectation from our lenders that we're going to do more and better on our applications that we are submitting. So having a verified process through Velocity is what they're working on, so that way can really clean it up. So I wish I knew more about that, but that's certainly a really great topic that will move into that but, and I'm guessing a lot of the same sort of checks that they've used for AML will come over there. And by the way, I should say this kudos to Newton. I mean, all of us turned on a dime a year ago. We're doing our 2024 planning, and I can tell you, AML was not on our list, or it wasn't on my list as an operational focus, because we misunderstood what it was, and similarly, again, not to talk out of turn with Newton, but it certainly wasn't on their list. It was only earlier this year when a few of us, and then people way smarter than me, got involved, and we realized this is a beast. This is a bigger lift than anyone expected. And we were first out of the shoot in the industry, and we took some slings and arrows. You know, you're blowing this out of proportion. You're exaggerating it. It's just a way of getting people onto Velocity. And you know, you're giving me way too much credit for my influence on FINTRAC or any government-run organization. But instead, what Newton did, and others did was, was pivot, stop what they're doing, create the solution. Because this was an imminent threat, if you will, land is 9000 DLCG agents, and 1000s more in the industry would be impacted if someone didn't step forward. So it was a lot of work to do, and I'm sure a lot of projects were put on hold, including this verified sort of application. But I would stay tuned for that. Newton is always innovating and iterating, and they're going to have some exciting things for sure in the future. Now that they've had their AML tsunami slowed down. 

 

Len 25:38

Yeah, it did feel like a tsunami. It really felt like we only heard about it, what six weeks before. And then–

 

Dave 25:44

Yeah, I mean, honestly, for me, I kind of fell into the trap, if you will, the AML trapping, maybe February or March. And then James Bell and I, we kind of realized this was a lot bigger, and that's where we kind of spread out. But we also had a very limited time frame. So everything was heightened. Everything was a little more urgent than it needed to be. And I wish we had, or at least perhaps we wish we had understood this better six months earlier because what we have today, I think, is excellent. I think with in six months, it'll be just even more excellent. So stay tuned for all those upgrades. 

 

Len 26:18

And you have to think of how many people went through that course that quickly. I'm sure I heard the last one there was no break in it. They just went the whole two and a half hours because it was the last one they were doing. And I'm pretty sure they were tired of doing it as well. 

 

Dave 26:30

Well, we kept adding more in because, you know, the unfortunate part is, we'd have people register and then not show up, and then they would say, Oh, I'll take it by the end of the year. Like, no, no, no, no, again. Now, how do you know the rules of the game? Unless you learn the rules of the game. So, over 9000 agents, I believe about 8400, went through the training. Still leaves 6-5, 700 who did not, which will be up to the individual owners to determine what happens next. But if anyone out there has not gone through that training, REMIC has the training. MPC has the training. There's other local ones that have the training. They vary in cost from about $50 to 150, and they're all quite similar, quite frankly, make sure you take that because you might say, Oh, it's all common sense. Well, it's the lack of common sense or the forgetting of the common sense that will get you into trouble. And there are some nuances there, and I can tell you, the ongoing monitoring is the one that catches most people off guard. They go, Wait a second. So, even if I don't complete the file with the client, I may have to monitor them annually, up to five years. Yes, you may. And the better you know that, the better you'll be able to handle those issues as time goes on.

 

Len 27:39

No, that was, that was one of our criteria. It starts on the 11th. You need to have the course done by the 11th. And so one of my questions course and talking with Heather and a few others. So the courses are still available. They can just take them at REMICS. We're thinking of new hires, right? Of course. 

 

Dave 27:57

Yeah, so if you go, yeah, exactly. So we provided the the free sessions to, you know, a lot of the agents who are part of our DLCG network. And now that we're beyond that, this becomes sort of like any sort of licensing or continuing education. So REMIC has the AML course available. I just the AML or, sorry, the URL is very easy. It's remic.ca/aml, and it's now a self-paced course. So the last couple of months, it was a classroom setting, if you will, a virtual classroom, because we want to make sure people got through that. So now it's more self-paced. So if you have new agents that are starting with you, and you want to put them through that, away you go. There is a requirement that they take that at least annually. So why not at the beginning? And I really, really recommend that you do it at the beginning again. How do you not? How do you know the rules of the game? Unless you know the rules of the game. And so, REMIC and, MPC and others will continue to offer those courses.

 

Len 28:56

Right, so we have several other ones. Of course, MPP has a course they need to take when they first start with us.

 

Dave 29:01

Yeah, I think it's a great way for someone to get started is, you know, kind of do that education, whether it's how to use Velocity, whether it's local regulatory issues or now AML or insurance or other things, it's good to know that and get that training sort of out of the way and then most of these training courses, you have the ability to log back in after the fact and review it and get better. And then again, at DLCG, we have ongoing education as well, but it's learning the rules is key because, without that, it's not as easy as you think. It's also not as difficult as you think. And it's funny, I've had this conversation with people that I think a lot of this AML stuff will be just like B 20 or form 10 in British Columbia, back six, eight years ago, where we all lit our hair on fire and went, Oh my gosh, the world is ending. You know, how are we going to do this? And now it's just part of the process. It's part of being in a professional industry, and we're going to continue to have different, maybe stringent regulations put upon us, but that's what a professional, professionally run organization in a professionally run industry is all about, is we continue to get better, and we don't shy away from that. We lean into it. And while these fin track rules might seem arbitrary or difficult. We're the last in kind of the latter here, as we talked about earlier, to have this in our industry. So there's nothing different they're doing with us than they haven't already done with the lawyers, with lenders and realtors. We're just now getting in there. It's just, it's new. It's different. But I can tell you that in six months, we'll all just be like, oh yeah, this is now just what we do this is like a credit check. This is like everything else. We're just doing it differently. And as long as you have a process, and I know I'm repeating myself, as long as you have a technology process, this will be easy. But if you have spreadsheets and a filing cabinet as your only resource, then yeah, this would be incredibly onerous, and you may find yourself offside. 

 

Len 31:00

Yeah, exactly, yeah. No. A wise man once said to me, Henry said we worked for a very large concrete group, no, based in Germany. Now he basically said to me, if things stop changing, start worrying because something bad's coming down the line. 

 

Dave 31:14

Absolutely, yeah. If you're not growing, you're dying. As Gary Morris likes to say, this might not be a quite the same way, but as long as our industry continues to be looked on more professionally, the better it is. I mean, years ago, we weren't invited into any of the legislative decisions, and now we, you know, over the past 10 years, you had Gary Mohr speak before the Senate in Ottawa, many of us are getting called into our not local but I mean our provincial governments to have proposed legislation bounced off of us. So mortgage brokers in Canada are continuing to be professional, and we caught the attention of FINTRAC, and they said, Hey, wait a second. If these guys are doing 40% of all mortgages in Canada, maybe they should be part of this solution as well, and that's why we did not take an anti anti-money laundering stance. We said to FINTRAC, bring it on. Let's see what this is about. And as we checked with our other kind of partners in the industry, being realtors and lenders, we found that this was kind of the same sort of thing. And while there'll be growing pains over the next six months, 12 months, it'll all just be gravity and oxygen. It's just there. It's just part of our process.

 

Len 32:30

Yeah, I don't think it, like you said, that just becomes the norm. And just like everything else that's happened in the last 18 years, and being in this industry, there's always been a change of some kind, right? So anyways, Dave, I appreciate your time. I know you're a busy, busy man, so thank you very much for taking some time out of your day to talk to us about AML.

 

Dave 32:53

Well I think I live, breathe, dream AML. One day, I won't, but you know, it's a good topic to talk about. And thanks for putting this together, and thanks for having and thanks for having me online. Appreciate your time as well. 


Len 33:03

Absolutely. Have a great day.

 

Len 33:05

Thanks for listening today. I hope you found the information that we provided to be useful in your mortgage journey. And remember, you can always find our associates at www.brokersforlife.ca/associates. Have a great day. 


Creators & Guests

DT
Guest
Dave Teixeira

What is Real Life Mortgage Solutions?

Mortgage Solutions for the every day Canadian mortgage consumer. Are you thinking about becoming a mortgage broker learn first hand what you should look for in a brokerage and what you need to be successful.

Len 00:02
Welcome. My name is Len Lane, and I am the founder and president of Brokers for Life Inc, and we are Dominion Lending Centers in Western Canada. The topic of our podcast will be about what we consider to be Real Life Mortgage Solutions.

Len 00:18
Welcome back if you're listening to this today, on the day it's been released, it should be December 10, 2024 we will be taking a short break over the Christmas season, as the next podcast would have come out on Christmas Eve. So, you will hear back from us on January 7th with a new set of podcasts for you to enjoy. Have a great Christmas season, and we will talk to you in 2025.

Len 00:44
Today, we're going to talk about a hot subject within the mortgage industry. The letters AML have been tattooed on the back of our hands for the last six or seven weeks. Anti-money laundering, not new to the banking system, but in the recent few months, it has become something of importance within the mortgage industry, and today we're going to talk to Dave Teixeira, Executive Vice President of operations for DLC group. You don't know who DLC group is after the 17th podcast, lending group, so David, welcome.

Dave 01:17
Thanks. Len, it's great to be here, and it's great to be able to chat now that we're a little bit on the other side of the AML Regulations now coming into play. I think people are now a bit of a sigh of relief that they've gone through that first little bit but always interested to share more about the experience and to see what sort of questions might still be out there.

Len 01:40
Right, exactly. And like I kind of said, it's like AML is not new. Anti-money laundering has been around for a long time, especially on the banking side. Financial Planners actually it looks like it was enacted in 2006, and FINTRACS itself has been around for over 25 years. So why do you think that it's now become the mortgage industry's turn to be involved in this?

Dave 02:03
I think they've realized, I think governments have realized, over the last, say, 15 years or so, the key role that mortgage brokers play in Canadians' lives. And I think that's a positive, you know, we've come from being this kind of fringe utility. You know, it's nice to have, perhaps, but it's kind of weird to now being the choice for people to make really good decisions, and we can help Canadians get into the house of their dreams. And so I think what's happened is, over the last while, regulators and organizations, regulators like FINTRAC, has said, Wait a second, this other group is playing a role here. Why are they not part of it? So, I think it's part of becoming a more professional organization. And at DLCG, we've often welcomed these sort of regulations because it shows that we're now being taken seriously. And as you pointed out so wisely, these regulations have been part of various industries for a year, everything from casinos and gambling to wealth management to legal professions, real estate. So it's just kind of our turn, and at the end of the day, I think this is these are going to be really simple regulations to follow. It's might be a little more difficult to have a process in place unless you have a good technology solution, but it's, it's a bit of a curse. They now see us as professional, which means they're going to regulate us a little more differently and more stringently.

Len 03:24
Right, and that's definitely part of it. I think the Cullen report, of course, a couple of years ago came out in British Columbia and highlighted a lot of spots. Do you think that was much of a catalyst to point out the mortgage brokering side of it?

Dave 03:40
I think it was independent of what FINTRAC was doing. FINTRAC, the Cullen report came out. I believe it was in late 22 or mid-22, and in early 2023, FINTRAC announced they were going to do something, something in the mortgage industry. Then, in September of 2023, they said, on October 11, 24, various regulations were coming in, and they laid them all out. And I think this is an industry we might have been slow to adopt. I know I was slow, and DLCG were slow to understand the importance. We kind of thought, Oh, this is just enhanced ID verification, not a big deal. And quickly we learned it's a much bigger deal. So I think the Cullen report in British Columbia, and if anyone out there hasn't read it, it's a lovely, 1800-page, breezy read, but they are looking at saving, preserving the housing markets, and making sure that, you know, criminal activity is not part of it, and part of that being anti-money or money laundering, which was apparently a fairly big problem here in British Columbia. I'm not so sure how big it was, but it was enough to merit an 1800-page report. And to that end, I think we're going to see governments, and even perhaps provincial regulators, get more involved. So, on August 8th of this year, BCFSA. The regulator in British Columbia sent out a kind of a scary email to agents and said, We're going to be performing desk audits to ensure that you are going to be compliant for FINTRACS. So two months before the regulated regulations came in, here's an unrelated, or at least an adjacently related organizations saying they want to ensure that FINTRAC regulations are being met. So, if I had my crystal ball out, I'd say that we're going to see more of a focus on AML from the regulators as well as FINTRAC. So stay tuned for that. And that's just my somewhat educated guess.

Len 05:39
In our own process of setting everybody up, and we were up and running on the 11th. On the 10th. Actually, couldn't push the button till the 11th, but it was, it's an eye-opener, I think, for a lot of people, because you, we see transactions, and of course, for years, we've had to identify anything over a couple $1,000 actually, there's no minimum on that, but majority was around 2000 was kind of the buffer. Where did that money come from? What was the source of that money if it wasn't from a payroll or RSP withdrawal or something like that? So it's not really that new, I guess only now. It's taking it to another level. Where did the people come from? Where's the money come from? Right?

Dave 06:19
And I think the most onerous piece of that as well, Len, is the ongoing monitoring of activity. And so what was a surprise to me was you could have a client that comes into you and they get a certain way down the road, they don't even file or don't even complete the transaction, and perhaps they're high risk. You now have, as an agent and as a brokerage, the obligation to do ongoing media monitoring for up to five years. So it's quite it can be an onerous position, unless you have a technology solution doing that. And, of course, you know, we partnered with Velocity to have that. But there's other solutions out there. But what's really key is for brokerages and agents and owners and everyone in that ecosystem to work together to have something better than just a piece of paper and a filing cabinet because it's going to be very, very difficult as time goes on. So say Len, you have 100 clients this year, and 50 are high risk, and 20, you know, don't complete a file with you. That's, that's a lot of different variations of media monitoring. If someone's a client of yours as of a mortgage agent, you'll remember them, but if someone didn't complete the file, perhaps you'll forget them the next day. However, FINTRAC has a long memory, and they expect you to check up on these clients, even beyond their short time with you.

Len 07:42
And part of that will get more into like the technology that been given to us. It's most advanced of what I've seen, but it's that ongoing there as well, right? If they actually end up on a sanctioned list, they'll it will alert us as well. There's only so much other checking up you can do, I guess, other than picking up the phone or something like that. So lenders obviously already involved in this for a long, long time, just to cover their own lenders and their own partners as well on the other side. So do you think having these systems in place will make them make it less legwork for the lenders, or are they going to have to do still have to do as much due diligence and hope that we did ours properly as well.

Dave 08:24
Yeah, I don't think what we're doing in the mortgage industry is going to have an ease, any sort of easing, on their requirements because everyone in the chain, if you will, has to do their own level of scrutiny or AML. And again, the AML requirements are not have anything to do with mortgage suitability. This is strictly on whether or not someone may pose a risk of criminal activity or something such as that. So FINTRAC has told us that the more people in the process that are checking for this, the better. So, for years and years, we've had real estate agents, perhaps lawyers and lenders, all doing their checks. Now, they want mortgage brokers to do that. So their hope is, is that we might catch something that someone else does not. And by having those multi-layers, there's more of an opportunity to ensure something negative in our space doesn't take place in terms of anti-terror or terrorist activity or money laundering. So from the lender perspective, because we don't really, we don't share this information, right? Anything that we're recording on the AML side only is recorded for the purposes of submitting an STR or a Suspicious Transaction Report. And again, we have to remember that first word is, I think, the most important, it's not absolutely 100% Terrorist Transaction Report. It's suspicious. So, do they have a large sum of money that they're putting down? Do they come from a sanctioned country? Are they a pap, a politically exposed person, and a few other points? Then you merely mark that down, submit the report, and that's your obligation is to submit the report correctly. So, I don't think lenders are going to be impacted by us because they'll do their own checks and do their own submissions. But what's interesting to note is the information that we are collecting and recording as it pertains to AML is not to be shared with the client or with lenders, or any other parties in the transaction. It's only there to facilitate the creation of the STR, the Suspicious Transaction Report.

Len 10:21
Right? And that's a good point because if it's, there's a good chance that, if we consider it to be a suspicious transaction, that it may never get to be a deal that will be sent to a lender anyway. So it still has–

Dave 10:34
And it’s interesting, because the example I used the politically exposed person, I mean, all jokes aside, of politicians being criminals. You could have your local mayor or your local council person come to you, and because of the nature of their job, they now become high risk automatically because they're a politically exposed person. You also can have a situation. So here in British Columbia, this past weekend, we had a provincial election, we have 58 brand new MLAs. So that's 58 people who've now all of a sudden, or will soon, technically be on a sanctions because of their political exposure. So there's going to be this need to keep updated. There's going to be this need to record what you know at the time to be true. This is where I think the regulations can be onerous, and I've said this a couple of times unless you have a technology solution because there's no humanly way possible to remember when to do these checks. What process are you in? Are they high, mid or low, etc etc. So having a good system in place, along with education and just having, you know, Len, great people to lead the charge. Is the way forward, right?

Len 11:44
Yeah, and it's 58 new MPs?

Dave 11:48
58 new MLA, that's a whole other thing we might have to talk about. I think we'll even have another provincial election in about six months because it was too close to call. That's for another podcast.

Len 12:02
I could take a little over an hour. Okay, so we keep bringing up technology. Let's talk about what Velocity has given to us. You may have seen my LinkedIn post, but maybe not. I know Eddie did because he sent me a note, but it was, you know, 35 agents or 37 agents that month. I think it was all through the system, through the training, because if you want to get paid with us now, you have to have done your AML training. The 54 pages of policy and procedures were in place. And there's a couple of other steps we took in there as well. But on the 11th we turned on the button that you can't submit to a lender unless you've done the AML, so you're in the background watching that all come together. I'm sure. How did that all come about?

Dave 12:48
Well let me take a step back as well. So when we started with the AML, you know, putting together processes and programs for our DLCG agents, we had four big pillars. One was the first one was information we had to share with people that these ammo requirements are real, because there was even a little bit of that. No, no, no, my lender does it for me. No, no, no, my real estate agent does it for me. Or in Quebec, we had people say, Well, no, no, that's for Canada, not for Quebec. And that led to some other interesting conversations. So, number one was the information. Number two was it was important to us that we had a really good relationship with the regulator to understand what's there, so myself, along with our chief legal counsel, and he did most of the heavy lifting here, James Bell, made sure that we had a really strong relationship with FINTRAC that continues to this day. What are you hoping to do? What are the goals? What's written down versus the expectations, and so we were able to really marry those together. The information and relationship with FINTRAC number three was education, and it was important to us that we had the education that was free to our agents. So for those out there, for roughly 9000 DLCG agents, we provided through REMIC, we partnered with a group to provide that training. Because how do you know the rules of the game? Unless you know the rules of the game. The analogy I use is, imagine the first time you saw a hockey game if you just saw the pads and the sticks and the puck on the ice, and then someone said, All right, go ahead, figure this out, but if you do something wrong, you're going to be fined, right? You wouldn't necessarily figure out the game as quickly as if someone actually explained the rules to you. And then the last piece was technology because once you saw how big this can get, enhanced ID verification is one piece of it, but risk rating and keeping notes, filling out an STRS or a Suspicious Transaction Report, and then doing ongoing monitoring. How do you do that? So Velocity was easy to come forward too, because, I mean, obviously, DLCG owns Velocity, so we could be nimble and create a really great experience, and plus, it just integrates well within the mortgage origination process. So I think what's really special with the AML, not requirements, but the technology from the Velocities. It has all the tools that an agent would need to be successful, and then also a larger piece for owners to monitor. And as you even said, there's a kind of a switch there where you can say, you know, everyone must go, you know, must use Velocity, or must make sure that they complete a certain amount or all of the AML requirements in order to submit. So there's the tools there to be successful. And without these, again, I have no idea how an agent can, with any sort of even small book of business over the years as it multiplies, how you can do it. So yeah, today, one week, a week and a half after the regulation started, you might say, no big deal. But as you get more and more files in the AML regime, you have no choice but to have an assistant of some sort of digital assistant, and that's Velocity, who can help with the intake and the ongoing monitoring.

Len 15:51
Right. And that was part of it. I think the ongoing monitoring people don't realize until you not only took the REMIC course, I took the REMIC broker-owner, course, and I did the MPC one as well, just to see what the differences were, right? Just, and there wasn't really other than there's an actual test with with REMIC. There isn't one with the other. To see is everybody saying the same thing. They were quite similar, right? I got an email from one of my agents this morning saying, Oh, this other small lending platform just rolled it out today, and go like, so what did they do with the last 10 days of files, as is what I was thinking.

Dave 16:30
And it's funny, you should say that, like we've heard that is, well, I'm going to wait for this other provider or so on and that. And, of course, we want everyone to feel comfortable with the solutions provided. At DLCG, we provided what we believe is best in class. As time goes on, there's going to be more and more solutions out there, but if it wasn't available on September, sorry, October 11th, then you have to now figure out how are you not backdating. But how are you putting in the last week, 10 days or so, into this other system. And we're just really proud that we provided everything for our agents and owners to be successful before October 11th.

Len 17:09
Right, and you know, for us, it was, you know, we've 100% Velocity, so it was easier, I think, probably, than if you were working in two or three systems in some cases. We were at that point, at one time, and it was chaotic just to try and do regular component.

Dave 17:25
And I think that's going to be the norm. Len, is that, as time goes on, I mean, it's, you know, there's a, you know, a suggestion that anyone should choose whatever systems they want. And I think that's important to a degree, except when there is harsh repercussions that come down on the franchise owner, the broker of record. And you know, to have multiple systems of where the intake and the outputs are similar yet different. How does one monitor that? And again, how do you look at the overall growth or the overall health, I should say, of your office, and that's what Velocity can provide, is that sort of owner overview to see what's actually going on in your own franchise, in your own office. So I think the notion of anyone choose anything they want is a little bit outdated. But I do believe there should be ongoing evaluations, and even though I'm, of course, in the camp of Velocity and DLCG, I have no problem looking at with the critical eye as time goes on. Is Velocity providing the best in class solutions and the best results for our agents, and to be, you know, to be involved in those other webinars and all the learning opportunities about what's out there, because, you know, complacency will kill us. And you know, having the pride in what we're doing beyond just being proud that we completed it, but the pride that stops you from innovating would not be good. But I think it's going to be incumbent upon franchise owners to look at this with a critical eye themselves and say, you know, we need to plant our flag in a certain ecosystem because it's the best for our office, and doing so protects all of your agents. You mentioned 35 to 37 agents. All it takes is one agent in your realm to decide AML ain't so important, and you could have repercussions that impact the other 36, and that's the reality. It's FINTRAC will be doing audits. And in fact, part of the requirements is that every two years that agents submit themselves to an audit. What will that look like? Not quite sure yet. And kind of the interesting part here, Len, is that I've always said this is a sprint in a marathon. So we sprinted to October 11th to get everything ready, and then there's a marathon after that. There's the not the relicensing, but then, you know, you have to retake an AML course every year, and then every two years, it's the audit. So that marathon continues, and we will make sure that there are solutions that are out there, but I think owners are going to have to choose and that might upset some people, but at the end of the day, owners have a, you know, a fiduciary, I would say, responsibility to their agents, to ensure that they're running the franchise in a way that will be productive, legal and sustainable,

Len 20:16
Right. And I think that was part of what I had a lot of calls before, some from the RECA Mortgage Broker Advisory people. And, you know, talking about talking to lots of small brokerages that were saying that they were seeing the costs run up to 10,000 plus dollars. And after seeing a 54 page P and P that, that is, you know, I can see having somebody write that for you. Yeah, there can be some.

Dave 20:46
That’s what we did as well as we provided templates. Because, you know, there are, there's other ways to do this, but we want to provide everyone, at least, with a foundation. And I think what we're seeing as well, Len is we're seeing a real cottage industry of AML experts and AML adjacent products coming out. So we have groups out there saying we'll write your policy for you. We will train you. We will do this for you. And seeing five figures and growing is not unusual. And, so, I'm not saying that they're not legitimate. It's just that I believe that there's other ways to accomplish that. And part of being a value, of being part of the DLCG network is we'll do that heavy lifting. You can decide if you don't want to use our version of the policy or our version of the tools, or you don't want to take the free training that we're providing via REMIC. Do what you need to do, but what's most important is that you least get educated. But there is a cottage industry that's growing. I get hit with emails on a daily basis telling me that there's a better way to do it. I look into them, and I feel pretty good that, you know, we can put our documents, our training, our philosophies on how we're doing this against anything out there. So I'd recommend to anyone that's listening, is check in with your network, check in with your franchise in order to see what's there. Don't just jump to paying for this because it might feel like it's the easy way. Oh, I just have to write a check, and I get everything. There might be other solutions that are less costly. Might take a little more time because you have to be a little more involved, but I think you'll be a better agent or owner for it, for doing that research yourself?

Len 22:23
Yeah, and I've seen them all come, had phone calls, I've had emails and my responses, Oh, thanks for your offer. We're part of the DLC group. We're okay. We have everything already done in the conversation. Usually not gonna waste his time or mine, right? So, over the last year or so, I guess maybe more like, I keep hearing about a Velocity-certified application or submission. I guess, if you want on the other side of that, this obviously ties into it as well. Is that something that's in the near future or down the road?

Dave 23:03
Yeah, and I can’t speak too authoritatively on that because I'm not from Newton, but certainly, what we are trying to do are a number of things that will make the whole mortgage origination experience smoother. And you know, everything with Velocity, or I should actually say, Newton has worked with lenders for direct document submission, and now they're looking at having this sort of verified, almost adjudicated, sort of application. So that way, you know, there would be technology, perhaps AI in the future, that would then look at what that file is, help you clean it up. So that way could be more efficient. Because at the end of the day, what we provide mortgage brokers, I should say, provide to lenders isn't just clients and an opportunity; it's efficiencies, and there's an expectation from our lenders that we're going to do more and better on our applications that we are submitting. So having a verified process through Velocity is what they're working on, so that way can really clean it up. So I wish I knew more about that, but that's certainly a really great topic that will move into that but, and I'm guessing a lot of the same sort of checks that they've used for AML will come over there. And by the way, I should say this kudos to Newton. I mean, all of us turned on a dime a year ago. We're doing our 2024 planning, and I can tell you, AML was not on our list, or it wasn't on my list as an operational focus, because we misunderstood what it was, and similarly, again, not to talk out of turn with Newton, but it certainly wasn't on their list. It was only earlier this year when a few of us, and then people way smarter than me, got involved, and we realized this is a beast. This is a bigger lift than anyone expected. And we were first out of the shoot in the industry, and we took some slings and arrows. You know, you're blowing this out of proportion. You're exaggerating it. It's just a way of getting people onto Velocity. And you know, you're giving me way too much credit for my influence on FINTRAC or any government-run organization. But instead, what Newton did, and others did was, was pivot, stop what they're doing, create the solution. Because this was an imminent threat, if you will, land is 9000 DLCG agents, and 1000s more in the industry would be impacted if someone didn't step forward. So it was a lot of work to do, and I'm sure a lot of projects were put on hold, including this verified sort of application. But I would stay tuned for that. Newton is always innovating and iterating, and they're going to have some exciting things for sure in the future. Now that they've had their AML tsunami slowed down.

Len 25:38
Yeah, it did feel like a tsunami. It really felt like we only heard about it, what six weeks before. And then–

Dave 25:44
Yeah, I mean, honestly, for me, I kind of fell into the trap, if you will, the AML trapping, maybe February or March. And then James Bell and I, we kind of realized this was a lot bigger, and that's where we kind of spread out. But we also had a very limited time frame. So everything was heightened. Everything was a little more urgent than it needed to be. And I wish we had, or at least perhaps we wish we had understood this better six months earlier because what we have today, I think, is excellent. I think with in six months, it'll be just even more excellent. So stay tuned for all those upgrades.

Len 26:18
And you have to think of how many people went through that course that quickly. I'm sure I heard the last one there was no break in it. They just went the whole two and a half hours because it was the last one they were doing. And I'm pretty sure they were tired of doing it as well.

Dave 26:30
Well, we kept adding more in because, you know, the unfortunate part is, we'd have people register and then not show up, and then they would say, Oh, I'll take it by the end of the year. Like, no, no, no, no, again. Now, how do you know the rules of the game? Unless you learn the rules of the game. So, over 9000 agents, I believe about 8400, went through the training. Still leaves 6-5, 700 who did not, which will be up to the individual owners to determine what happens next. But if anyone out there has not gone through that training, REMIC has the training. MPC has the training. There's other local ones that have the training. They vary in cost from about $50 to 150, and they're all quite similar, quite frankly, make sure you take that because you might say, Oh, it's all common sense. Well, it's the lack of common sense or the forgetting of the common sense that will get you into trouble. And there are some nuances there, and I can tell you, the ongoing monitoring is the one that catches most people off guard. They go, Wait a second. So, even if I don't complete the file with the client, I may have to monitor them annually, up to five years. Yes, you may. And the better you know that, the better you'll be able to handle those issues as time goes on.

Len 27:39
No, that was, that was one of our criteria. It starts on the 11th. You need to have the course done by the 11th. And so one of my questions course and talking with Heather and a few others. So the courses are still available. They can just take them at REMICS. We're thinking of new hires, right? Of course.

Dave 27:57
Yeah, so if you go, yeah, exactly. So we provided the the free sessions to, you know, a lot of the agents who are part of our DLCG network. And now that we're beyond that, this becomes sort of like any sort of licensing or continuing education. So REMIC has the AML course available. I just the AML or, sorry, the URL is very easy. It's remic.ca/aml, and it's now a self-paced course. So the last couple of months, it was a classroom setting, if you will, a virtual classroom, because we want to make sure people got through that. So now it's more self-paced. So if you have new agents that are starting with you, and you want to put them through that, away you go. There is a requirement that they take that at least annually. So why not at the beginning? And I really, really recommend that you do it at the beginning again. How do you not? How do you know the rules of the game? Unless you know the rules of the game. And so, REMIC and, MPC and others will continue to offer those courses.

Len 28:56
Right, so we have several other ones. Of course, MPP has a course they need to take when they first start with us.

Dave 29:01
Yeah, I think it's a great way for someone to get started is, you know, kind of do that education, whether it's how to use Velocity, whether it's local regulatory issues or now AML or insurance or other things, it's good to know that and get that training sort of out of the way and then most of these training courses, you have the ability to log back in after the fact and review it and get better. And then again, at DLCG, we have ongoing education as well, but it's learning the rules is key because, without that, it's not as easy as you think. It's also not as difficult as you think. And it's funny, I've had this conversation with people that I think a lot of this AML stuff will be just like B 20 or form 10 in British Columbia, back six, eight years ago, where we all lit our hair on fire and went, Oh my gosh, the world is ending. You know, how are we going to do this? And now it's just part of the process. It's part of being in a professional industry, and we're going to continue to have different, maybe stringent regulations put upon us, but that's what a professional, professionally run organization in a professionally run industry is all about, is we continue to get better, and we don't shy away from that. We lean into it. And while these fin track rules might seem arbitrary or difficult. We're the last in kind of the latter here, as we talked about earlier, to have this in our industry. So there's nothing different they're doing with us than they haven't already done with the lawyers, with lenders and realtors. We're just now getting in there. It's just, it's new. It's different. But I can tell you that in six months, we'll all just be like, oh yeah, this is now just what we do this is like a credit check. This is like everything else. We're just doing it differently. And as long as you have a process, and I know I'm repeating myself, as long as you have a technology process, this will be easy. But if you have spreadsheets and a filing cabinet as your only resource, then yeah, this would be incredibly onerous, and you may find yourself offside.

Len 31:00
Yeah, exactly, yeah. No. A wise man once said to me, Henry said we worked for a very large concrete group, no, based in Germany. Now he basically said to me, if things stop changing, start worrying because something bad's coming down the line.

Dave 31:14
Absolutely, yeah. If you're not growing, you're dying. As Gary Morris likes to say, this might not be a quite the same way, but as long as our industry continues to be looked on more professionally, the better it is. I mean, years ago, we weren't invited into any of the legislative decisions, and now we, you know, over the past 10 years, you had Gary Mohr speak before the Senate in Ottawa, many of us are getting called into our not local but I mean our provincial governments to have proposed legislation bounced off of us. So mortgage brokers in Canada are continuing to be professional, and we caught the attention of FINTRAC, and they said, Hey, wait a second. If these guys are doing 40% of all mortgages in Canada, maybe they should be part of this solution as well, and that's why we did not take an anti anti-money laundering stance. We said to FINTRAC, bring it on. Let's see what this is about. And as we checked with our other kind of partners in the industry, being realtors and lenders, we found that this was kind of the same sort of thing. And while there'll be growing pains over the next six months, 12 months, it'll all just be gravity and oxygen. It's just there. It's just part of our process.

Len 32:30
Yeah, I don't think it, like you said, that just becomes the norm. And just like everything else that's happened in the last 18 years, and being in this industry, there's always been a change of some kind, right? So anyways, Dave, I appreciate your time. I know you're a busy, busy man, so thank you very much for taking some time out of your day to talk to us about AML.

Dave 32:53
Well I think I live, breathe, dream AML. One day, I won't, but you know, it's a good topic to talk about. And thanks for putting this together, and thanks for having and thanks for having me online. Appreciate your time as well.

Len 33:03
Absolutely. Have a great day.

Len 33:05
Thanks for listening today. I hope you found the information that we provided to be useful in your mortgage journey. And remember, you can always find our associates at www.brokersforlife.ca/associates. Have a great day.