BC's Mortgage Services Act (2026): A Broker Compliance Checklist Before October 13
Everything BC-licensed mortgage brokers need to do before the Mortgage Services Act takes effect on October 13, 2026: the four new licensing categories, PMC licensing, new fees, and a step-by-step compliance checklist.
What do BC mortgage brokers need to do before the Mortgage Services Act deadline?
By October 13, 2026, every BC-licensed broker and brokerage must hold a license under the new MSA framework covering the specific service categories they operate in (dealing, trading, administering, and/or lending), pay the associated per-category fees, and, if compensated through a personal corporation, obtain a separate PMC license. Brokerages also face new governance and financial reporting requirements under BCFSA.
Why This Is Not Optional
British Columbia is replacing the Mortgage Brokers Act (in place since 1972) with the Mortgage Services Act (MSA) on October 13, 2026. This is a hard regulatory deadline, not a recommendation. The industry was given a 15-month transition window after the accompanying rules were approved, and that window is closing.
The core shift: BC moves from a registration system to a full licensing framework, administered by BCFSA. Registration under the old MBA will not carry over automatically, brokers and brokerages need to actively apply under the new categories.
The Four Service Categories You Must Identify
Every broker and brokerage needs to determine which of the four MSA service categories match their actual activities, and hold a license for each one they operate in:
| Category | Covers |
|---|---|
| Dealing | Originating mortgages: soliciting borrowers/lenders, advising on a specific mortgage, assessing a prospective borrower for a lender, negotiating or arranging a mortgage on behalf of another person |
| Trading | Buying, selling, or exchanging mortgages once in place, whether on your own behalf or someone else's |
| Administering | Handling an existing mortgage loan on behalf of another person, servicing and collections |
| Lending | Lending directly on the security of real property |
New Per-Category Licensing Fees
BCFSA is implementing a new fee structure alongside the MSA. Each license application or renewal covers one service category, if you (or your brokerage) operate in more than one, dealing and administering, for example, additional fees apply per extra category.
Principal brokers and brokerages specifically need to identify, in their license application, exactly which categories the brokerage intends to operate under. Budget for this as part of your transition planning, not as a surprise at renewal time.
New Qualification and Governance Requirements
Beyond the category structure, the MSA rules introduce requirements that did not exist under the old MBA:
• English-language proficiency standards for all licensees • Requalification requirements for anyone reinstating a lapsed license • Minimum experience requirements for principal brokers overseeing a brokerage • Formal governance and financial policy requirements at the brokerage level • New financial reporting and assurance obligations for brokerages, effective once the MSA is in force
If you are a principal broker, the brokerage-level requirements are yours to implement, not something that happens automatically at the individual license level.
Personal Mortgage Corporations Need a Second License
If you receive your commission through a Personal Mortgage Corporation (PMC), a common structure for brokers routing income through a personal corporation, you need a separate PMC license in addition to your individual license, effective October 13, 2026. Operating a PMC without it once the MSA is in force will not be compliant. Confirm this applies to you now if you are unsure of your current compensation structure.
Your Compliance Checklist Before October 13, 2026
1. Map your actual activities (and your brokerage's) against the four service categories: dealing, trading, administering, lending 2. Apply for an MSA license covering every category that applies, budgeting for per-category fees 3. If you operate a brokerage, confirm your principal broker meets the new minimum experience requirement 4. Update brokerage governance and financial policies to meet the new MSA standard 5. If you route compensation through a personal corporation, apply for the PMC license alongside your individual license 6. Prepare for the new financial reporting and assurance requirements that begin once the MSA takes effect 7. Confirm any team members with lapsed licenses understand the new requalification requirements before they try to reinstate 8. Monitor BCFSA's MSA transition communications directly, the specifics of forms and deadlines are managed there, not by this guide
Frequently Asked Questions
When does the BC Mortgage Services Act take effect?
October 13, 2026. It was passed as Bill 29 in 2022, with a 15-month transition period given to the industry after the accompanying rules were approved. It replaces the Mortgage Brokers Act, in place since 1972.
What are the four MSA licensing categories?
Dealing (originating mortgages), trading (buying/selling/exchanging mortgages already in place), administering (servicing existing mortgages for someone else), and lending (lending directly on real property). Most broker-facing dealing activity falls under "dealing," but brokerages involved in other activities may need additional categories.
Do I need a separate license for each MSA category?
Effectively yes. Each license application or renewal covers one service category under BCFSA's new fee structure. If you or your brokerage operate in more than one category, additional per-category fees apply, and your application needs to specify every category you intend to operate under.
What happens if I don't have a PMC license by October 13, 2026?
If you receive compensation through a Personal Mortgage Corporation, you need a separate PMC license in addition to your individual broker license starting October 13, 2026. Operating without it once the MSA is in force would not be compliant, this is a new requirement that did not exist under the old Mortgage Brokers Act.
Does the Mortgage Services Act apply to brokers outside BC?
No, it is BC-specific legislation regulated by BCFSA. Other provinces have their own regulators: FSRA in Ontario, RECA in Alberta, and the AMF in Quebec, each with their own licensing rules, unaffected by BC's MSA transition.
Where do BC brokers apply for their MSA license?
Through BCFSA directly. BCFSA administers the MSA licensing framework, including category applications, fees, and the transition process from the old Mortgage Brokers Act registration system. Check BCFSA's MSA resources for current application forms and deadlines.
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