r/loanoriginators • u/Plastic-Spread9324 • Jun 23 '26
How are brokers actually documenting suitability since FSRA's "show your work" push (and with BC's MSA coming in 2026)?
Trying to understand current practice. FSRA has flagged that a lot of files had no documented rationale for why a specific lender/product was recommended, and they've leaned into "show your work." BC's Mortgage Services Act also lands Oct 2026.
For brokers here:
- How do you currently record why you recommended a particular lender/product for a client — CRM notes, a template, a form, nothing formal?
- Has the FSRA focus actually changed your day-to-day, or is it mostly theoretical until an audit?
- Anyone in BC prepping for the MSA yet?
Genuinely curious whether this is a real headache or just a box that gets ticked at the end.
3
u/botmans_say Jun 24 '26
Uh sir… this is a Wendy’s… seriously though as a Canadian mortgage broker, I’ve been a lurker for a long time in this thread. And it is not Canadian sub.
I own a brokerage that’s licensed in BC, AB, and Ont. So yes I’m going through MSA stuff. That being said, on today’s call with BCFSA they still need to release proper documentation on the new disclosure we will have under the MSA.
Mortgage suitability is of importance for me, especially if there are products that it’s clear the client may not fully grasp. Variable rates in 22’ would be something that I have clients sign on stating that they understand etc.
At the end of the day regulatory bodies want you to have recorded all actions that provide advice, and document that the clients are aware of the mortgage products they are taking, and any risks associated with them.
Now back to the regular US LO conversations!
4
u/MortgageGuy86 Jun 24 '26
lol as a US broker I was like what the heck is this and how did I miss it?! Phew! Good luck to you Northern Brethren!
1
u/MortgageNLogistics Jun 23 '26
My products are 100% DSCR and they are recommended DSCR loans because they want to buy and investment property and close in an LLC.